ML19354E011

Forwards Rev to Response to Deviations Noted in Insp Rept 50-285/89-09.Corrective Action:Water Curtains Currently Installed to Protect Doorway Opening from Fan Room Into Turbine Bldg

ML19354E011
Person / Time
Site:	Fort Calhoun
Issue date:	01/17/1990
From:	Morris K OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-89-1206, NUDOCS 9001250198
Download: ML19354E011 (4)

Text

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Omaha PubHC Power District  !

1623 Harney Omaha, Nebraska 68102 2247 -i 402/536 4000

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January 17, 1990 LIC-89-1206 l

i U. S. Nuclear Regulatory Commission

! Attn: Document Control Desk Mail Station PI-137  !

! Washington, DC 20555 l

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References:

1. Docket No. 50 285  ;

l 2. Letter from NRC (L. J. Callan) to OPPD (K. J. Morris) dated March 31, 1989 .

l 3. Letter from OPPD (K. J. Morris) to NRC (Document Control  :

Desk) dated June 1, 1989 (LIC-89-408) i

! 4. Letter from OPPD (K. J. Morris) to NRC (Document Control .

! Desk) dated July 27, 1989 (LIC-89-662) j 5. Letter from NRC (C. E. McCracken) to NRC (F. J. Hebdon) j dated September 28, 1989 ,

6. Letter from OPPD (K. J. Morris) to NRC (Document Control Desk) dated October 27, 1989 (LIC-89-1001)

Gentlemen: l

SUBJECT:

Revision to Response to Notice of Deviation - Inspection Report  ;

50-285/89-09 l

Omaha Public Power District (OPPD) submits the attached revision to the  :

Response to Notice of Dev_1ation (89-09)' contained in Reference 3 concerning I failure to install and test portions of the Fire Water Sprinkler System. l l I i- In Reference 3, OPPD committed to requesting an amendment to the Fire i l Protection Safety Evaluation Report (SER). Reference 4 requested this.

i. amendment to the SER.. In Reference 5, the NRC concluded that OPPD's existing  ;

visual surveillance practice for the deluge valves is an acceptable means of j ensuring system operability and.that the amendment request should-be withdrawn. D OPPD's request for license amendment was withdrawn in Reference 6. 1 AD pe 9oo317 g1250gCKosco  !

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U. S. Nuclear Regulatory Commission LIC-89-1206 ,

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Attached please find the revision to the Response to Notice of Deviation with changes denoted by vertical lines in the right hand margin.

i If you should have any questions, please contact me. ,

Sincerely, W. W y

M . Division J. Morris Manager  :

Nuclear Operations  ;

KJM/pje Attachment c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator, Region IV A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector  ;

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l RESPONSE TO NOTICE OF DEVIATION j l

i Based on the results of an NRC inspection conducted on February 1-28, 1989, a ,

deviation of OPPD commitments made to the NRC was identified. The deviation  ;

consisted of the failure to install and test portions of the fire water sprinkler system. In accordance with the " General Statement of Policy and j Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the '

s deviation is listed below.

, I Failure to install and Test Portions of the Fire Water Sorinkler Systes  ;

(1) Section 9.11.3 of the Updated Safety Analysis Report (USAR) states, in j part, that a safe shutdown analysis has been perfonned on an area-by-area basis to satisfy the provision of Appendix R to 10 CFR part 50. Evaluation i of fire protection for safe shutdown is contained in the Safety Evaluation  !

Report (SER), ' Fort Calhoun Power Station Unit 1," dated August 23, 1978. l Section 4.9 of the SER states, in part, that water curtains will be l installed to reinforce protection by 3-hour fire doors at doorway openings  !

between the turbine and the auxiliary building.

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In deviation from the above, the licensee did not install a water curtain at the doorway opening between the fan room (in the turbine building) and-  !

Room 81 (in the auxiliary building). l (2) Section 9.11.4 of the USAR states in part that testing is performed and f verified by inspection and audit to demonstrate conformance with subsequent  ;

design and system readiness requirements.  !

In deviation from the above, the licensee failed to test the eight l fusible-link valves that supply the water curtains. l l OPPD RESPONSE

1. Reason for the Deviation. if Admitted a i

OPPD respectfully requests that this deviation of OPPD commitments made  ;

to the NRC be withdrawn. With respect to Item No. I above, subsequent i to the exit meeting with the senior resident inspector, more information i became available which was not presented at the exit meeting. Water '

curtains are installed at all doorway openings between the turbine building and the auxiliary building. Water curtains are not required between the  ;

i fan room (Room building. Due to t82) he unavailability of this information at the exitandl Room 81 b '

meeting, an apparent misunderstanding regarding the location of the fan ,

room (called the turbine building mechanical equipment room) occurred ,

since this room was evaluated in conjunction with the turbine building l.  !

in the FCS Updated Fire Hazards Analysis, Rev. 3, dated September 9,1988,  !

as Fire Zone 46.1. The Fire Protection Program Review dated December 31, l 1976, upon which the SER is based, described iM fan room as Fire Area 44 i located in the auxiliary building. Water curtains are currently installed -

to protect the doorway opening from the fan room into the turbine  !

building. l -

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With respect to item No. 2, no specific surveillance program is required l [

or in place to test the fusible-link valves. These valves are considered >

part of the turbine building sprinkler system and are visually inspected  ;

weekly by Operating Instruction 01-FP-6 " Fire Protection System Inspection 4 and Test" as part of the turbine building sprinkler system as described in l the USAR. OPPD classifies the fusible link valves as special hazard wet l pipe sprinkler heads and considers this classification to be more in ,

keeping with the intent of the NFPA codes and ANI recommendations. In i Reference 5, the NRC concluded that OPPD's existing visual surveillance ,

practice for these valves is an acceptable means of ensuring system  !

operability and should be continued. .

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2. The Corrective Steos Which Have Been Taken and the Results Achieved; With respect.to Items No. I and No. 2, no corrective actions have been ,

l taken or are necessary (see OPPD response No, I above).  ;

3. The Corrective Steos Which Will Be Taken To Avoid Further Deviations.  :

With respect to Items No. I and No. 2, no further actions.are necessary (see OPPD response No. I above).

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4. Date When Full Como11ance Will Be Achieved .

With respect to Items No. I and No. 2, OPPD is presently in full '

compliance (see OPPD response No. I above).

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