ML20011F469
| ML20011F469 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 02/22/1990 |
| From: | Crawford A PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| P-90055, NUDOCS 9003060081 | |
| Download: ML20011F469 (3) | |
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P.O. Box 840 February 22, 1990 Denver CO 80201- 0840 Fort St. Vrain i
Unit No. 1 A. Clegg Crawford P-90055-Vice President Nuclear operations e
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 i
Docket No. 50-267 1
SUBJECT:
NRC INSPECTION REPORT 89-23 h
REFERENCE:
NRC Letter, Collins to Crawford, dated January 16,1990(G-90010) i
Dear Sirs:
This letter is in response to the Notice of Violation (see Referenced j
Letter) received as a result of the NRC inspection conducted by Messrs. R. E. Farrell and P. W. Michaud during the period November 16 through December 31, 1989. As a result of a phone conversation -with
. Mr.
T. - F.
Westerman of NRC Region IV on February 15,1990, an extension of seven days was granted for submittal of this response.
The following response is hereby submitted:
Inoperable Fire Door 10 CFR Part'50, Appendix R, paragraph III.N " Fire Doors," requires, in part, that fire doors be self-closing or provided with closing mechanisms.-
Additionally, fire doors are to be kept closed or provided with automatic release mechanisms.
The licensee's fire protection program plan as stated in Fire Protection Operability Requirement FPOR-14 requires, in part, that a continuous fire watch be established for fire doors that are opened for more than 20 minutes at a time.
Contrary to the above, on November 29, 1989, the NRC resident inspectors found Fire Doors 13 and 9 between the 480 VAC Switchgear Room and Building 10 had been propped open for apparently several hours without establishing a continuous fire watch.
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P-90055 Page 3 o-February 22, 1990 (2)The' Corrective Steps Which Have Been Taken And The Results Achieved:
Since there was no violation, no corrective action is required.
However, Shif t Supervisors have been instructed to relay any concerns expressed by an NRC Inspector to line management and not to assume that the issue is resolved unless the Inspector specifically indicates so.
Public Service Company is actively working on improving communications. That is a primary objective of our recently formulated " Service Excellence" Program.
(3) The Corrective Steps Which Will Be Taken To Avoid Further Violations:
Not Required (4) Re Date When Full Compliance Will Be Achieved-Not Applicable If you have any questions, please contact Mr. M. H. Holmes at (303) 480-6960.
Sincerely, 4-
- r A. Clegg Crawford Vice President Nuclear Operations ACC/MED/km cc:
Regional Administrator, Region IV ATTN: Mr. T. F. Westerman, Chief Projects Section B Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain b
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P-90055
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(1) The Reason For The Violation If Admitted:
The violation is not admitted. The workman (a contract laborer)
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had obtained a Fire Prevention Work Permit (FPWP) as required by Station ManagersAdministrativeProcedure-24(SMAP-24). SMAP-24 applies to personnel whose work involves welding, cutting, grinding or the use of open flame or spark producing equipment in b
areas not designated as shop or fabrication areas.
The FPWP provides for notification, authorization, pre and post-job
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inspection, and implementation of fire prevention measures when i-the abeve mentioned actions are involved.
Since the workman had followed the requirements of SMAP-24 and a continuous fire watch was in place as required by Fire Protection Operability Requirement-14 (FPOR-14), appropriate precautions had been taken.
The Fire Protection Operability Requirements are ct;ntained in Section 6 of the NRC approved Fort St. Vrain Fire Protection Program Plan (FPPP).
FPOR-14 requires that "With one or more of the required fire doors inoperable, within I hour, establish a continuous fire watch on at least one side of the affected door (s)."
A continuous fire watch was needed and, in fact, was in place.
The fire watch was on twenty minute rcunds which qualifies as a continuous fire watch per the following definition contained in Section FP 6.1, Step 3.2.3 of the FPPP:
" Continuous Fire Watch Action shall be taken to establish these watches within I hour after the determination that they are required.
The area (s) shall be checked at least once per 20 minutes.
In areas which are continuously occupied, those individuals may serve as the fire watch for that area."
During performance of this work, there were redundant fire watches in place while hot work was taking place.
There was a dedicated fire watch as described in Si4AP-24, and there was a continuous (i.e., 20 minute rounds) fire watch as required by FPOR-14.
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