ML19337A914

Responds to NRC Re Violations Noted in IE Insp Rept 50-295/80-11.Corrective Actions:Approved Fire Barrier Was Installed & Maint & Use of Fire Doors Will Be Periodically Discussed W/Personnel

ML19337A914
Person / Time
Site:	Cooper
Issue date:	09/05/1980
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19337A911	List: ML19337A910 ML19337A914
References
LQA8000432, NUDOCS 8010010006
Download: ML19337A914 (4)

Text

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I COOPER NUCLcAR STATtoN k [ Nebraska Public Power District -

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a LQA8000432 September 5, 1980 Mr. Karl V. Seyfrit, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Taxas 76011 Subj ect:

NPPD Response to IE Inspection Report No. 50-298/80-11

Dear Mr. Seyfrit:

This letter is written in response to IE Inspection Report No. 50-298/80-11.

Statement of Infraction A.

Technical Specification 3.19 requires that:

"3.19.A Fire Barrier and Fire Wall Penetration Fire Seals in-tegrity shall be maintained.

"3.19.B If the requirement of 3.19.A cannot be met, a continuous fire watch shall be established on at least one side of the penetration within one hour."

Contrary to the above, at approximately 1115 hours0.0129 days <br />0.31 hours <br />0.00184 weeks <br />4.242575e-4 months <br /> on July 25, 1980, the inspector found a breached fire wall penetration between the Cable Spreading room and the "B" DC Switchgear and Battery Charger room. No fire penetration watch was posted.

Subsequent investigation indicates that the fire wall penetration was breached during the installation of Conduit Number DC-25 as a part of Major Design Change 76-2, which was completed on June 10, 1977, and apparently remained undiscovered in this condition until found by the inspector. The licensee immediately repaired che penetration.

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Mr. Karl V. Seyfrit September 5, 1980 Page 2.

Response

Corrective Action Taken and Results Achieved Upon identification of the breached fire wall, an approved fire barrier was promptly installed.

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Corrective Action Taken to Avoid Further Noncompliance Major Des!gn Change 76-2 has been reviewed with respect to additional penetrations which were routed through fire walls.

A physical check of these penetrations was performed and each penetration had an acceptabla fire barrier installed.

Section 1.4.15 " Control of Excavation and Core Drilling Activities", of Administrative Procedure 1.4, " Station Rules of Practices", has been reviewed and is considered adequate with. respect to specific instruc-tions concerning fire barrier walls.

Surveillance Procedure 6.4.5.2 has been revised and Surveillance Procedure 6.4.5.16 now addresses fire barrier and fire wall penetration seal inspections.

Surveillance Pro-cedure 6.4.5.16 has been reviewed and is considered acceptable.

It is believed that the < k" gap around the lh" conduit, which is the subject of this infraction, was an oversight on the inspector's behalf.

This infraction has been discussed with the subject inspector.

Date When Full Compliance Will Be Achieved Full compliance has been achieved in that the subject penetration was sealed on July 25, 1980.

Secondly, a procedure review and physical inspection of fire wall penetrations associated with Major Design Change 76-2 were completed on September 5, 1980.

Statement of Infraction B.

Technical Specification 6.3.2 states in part:

" Written integrated and system procedures and instructions including applicable check off lists shall be provided and adhered to for.

. E.

Imple-menting procedures for the fire protection program."

Plant Administrative Procedure 1.4.16, Control of Fire Doors, states:

"1.4.16.2.3 Category 3 - Fire Doors In Safety-Related Areas that Require A Fire Watch.

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Mr. Karl V. Seyfric September 5, 1980 Page 3.

This category includes all doors within safety-related areas that are not common to the security system.

These doors will normally be maintained in the closed position.

If the door is equipped with an automatic closure device (fusible link) it may be left open and unobstructed without requiring a fire watch, but should be returned to the closed position as soon as practical.

If the door must be obstruc-ted so as to prevent it from closing securely a continuous fire watch must be established within one (1) hour on at least one side of the door.

Special circumstances may allow the fire watch requirement to be waived by the Sbift Supervisor."

Contrary to the above, on July 26, 1980, at approximately 1640 hours0.019 days <br />0.456 hours <br />0.00271 weeks <br />6.2402e-4 months <br /> the inspector found the door to the HPCI Pump Room propped open.

This door is a Category 3 fire door.

No fire watch was posted and the Shift Supervisor was not aware that the door was left open or that the requirement for a fire watch had been waived.

Response

Corrective Action Taken and Results Achieved Investigation revealed that the door may have been left open by two operators after performing a HPCI Surveillance Test.

The subject in-dividuals are not positive that they shut the door upon leaving.

The problem with the door was discussed in a letter to the Operations Department in an effort to raise the level of awareness towards main-taining firc doors in an operable status.

Corrective Action to be Taken to Avoid Further Noncompliance The proper maintenance and use of fire doors will be periodically covered with all CNS personnel.

s Date When Full Complianca Will Be Achieved Full compliance has been achieved in that the door is maintained closed or an approoriate watch provided as per approved procedures.

Personnel have been informed on the use of fire doors and retraining will be a continuous item.

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Mr. Karl V. Seyfrit September 5, 1980 Page 4.

4 If you have any questions regarding this response, please contact me.

I Sincerely, M

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Pilant Director of~ Licensing and Quality Assurance JMP:LCL:cg 4

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