ML20024E281
| ML20024E281 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/18/1983 |
| From: | Wells D DETROIT EDISON CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20024E279 | List: |
| References | |
| EF2-64308, NUDOCS 8308100180 | |
| Download: ML20024E281 (4) | |
Text
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Donald A. Wells Vvaw QLaW Asme (313) 237 % 57 Ecison in!!s5=>-
July 18, 1983 EF2-64308 Mr. R.L. Spessard, Director Division of Engineering U.S. Nuclear Regulatory Cm mission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Noncmpliance at Enrico Fermi Unit 2 - IE Report 50-341/83-12
Dear Mr. Spessard:
This letter responds to the itcm of nonompliance described in your IE Report No. 50-341/83-12. This inspection of Enrico Fermi Unit 2 con-struction site activities was performed by Messrs. C. Ramsey, F. Maura and J. Ulle on March 18, 21 and May 10-13, 1983.
The item of nonempliance is discussed in this reply as required by Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code i
of Federal Regulations.
The enclosed response is arranged to correspond to the sequence of itm s cited in the body of your report. The number for the item of noncmpliance and the applicable criterion are referenced.
4 We trust this letter satisfactorily answers the concern raised in your report. If you have questions, please contact Mr. G.M. Trahey, Assis-tant Director - Project Quality Assurance.
Very truly yours, cc: Mr. Richard DeYoung, Director Office of Inspection and Enforcment U.S. Nuclear Regulatory Cmmission Washington, D.C.
20555 Mr. Bruce Little, Senior Resident Inspector U.S. Nuclear Regulatory Cmmission 6450 North Dixie Highway Newport, Michigan 48166 i
9 e3o8100100 e30804 M 2,, 33 PDR ADOCK 05000341 O
THE DEIROIT EDISON COMPANY PROJECT QUALITY ASSURANCE ENRICO FEEMI 2 PROJECf Response to NRC Report No. 50-341/83-12 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport, Michigan Inspection Conducted: March 18, 21 and May 10-13, 1983 i
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Response to NRC Inspection Report No. 50-341/83-12 (83-12-09)
Statment of Nonconpliance, 83-12-09 10CFR50, Appendix A, General Design Criterion No. 1 requires estab-lishment and implementation of a Quality Assurance Program to provide adequate assurance that all fire protection structures, systems and cmponents will satisfactorily perform their safety function.
Your response to Sections C, C.1 and D.1. (d) of Appendix A to NRC Branch Techncial Position APCSB 9.5.1. as stated in Amendment No.12 to the Fermi 2 FSAR, dated June 12, 1978, cmmitted Detroit Edison Ompany to apply portions of the plant operations Quality Assurance Program to Fire Protection in safety-related areas to assure that the requirements on design control and procurement th-nt control are maintained and that plant structural cmponents for fire protection are listed by a nationally recognized testing laboratory, such as Fac-tory Mutual or Underwriters Laboratories, Inc.
Paragraph D(j) of Amendnent 24 to the Fermi 2 FSAR, dated June 1979, states in part, " Door openings are protected with equivalently rated doors, frames and hardware that have been tested and approved by a nationally recognized testing laboratory".
Detroit Edison Cmpany construction Specification Nos. B6-NS-01A and B6-NS-02A, Revision A, dated June 25, 1980, Part 5, requires U.L.
Labels (permanently affixed) attesting to the fire resistive capabi-lity of fire doors delivered to the Enrico Fermi 2 jobsite.
Contrary to the above, Detroit Edison Cmpany Purchase Orders 1A-53112 and 1A-53113, dated January 13, 1981, did not specify U.L. Labels attesting to the fire resistance capability of doors numbered R3-13, T3-6, R3-20, RM2-1, R2-11 and R2-16 which are installed in safety related areas of the plant. Adequate documentation was not available to attest to the fire resistive capability of these doors and no U.L.
Labels attesting to their fire rating was affixed to them. Four doors, RM2-2, RM2-3, RM2-4 and R2-20 had 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> U.L. Labels affixed to them but did not have the required three hour fire resistive rating as l
stated in the Fermi 2 FSAR.
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Corrective Action Taken and Results Achieved I
l As an explanation, Detroit Edison offers the following:
r When the bids to supply the security doors to Edison were originally received, Stone and Webster (then the A/E for security systems) evaluated the bids.
Chicago Bullet / Proof Equipnent Cmpany's (CBP) bid took exception to the requirments that the doors bear U.L.
(Underwriter's Laboratories, Inc.) fire labels.
Stone and Webster's evaluation of the bids noted CBP exception to pro-viding U.L. labels and found that acceptable because they were of the
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Response to NRC Inspection Report No. 50-341/83-12 (83-12-09)
Corrective Action Taken and Results Achieved (cont'd) opinion the doors were to be constructed to fire specifications.
Edison personnel involved with security, noting that the actual con-struction of the doors would be adequate for fire, did not recognize the consequences in not receiving a label and therefore, agreed with Stone and Webster's recmmendation.
In order to provide effective corrective action, Edison has contracted with Underwriter's Laboratories (U.L.) to investigate, evaluate and fire test where necessary, to assure the doors in question will satis-factorily perform their safety function, i.e., fire resistive capabi-lities are satisfactory. The investigation, evaluation and fire test results will be made available in a report released by U.L. to authorized NRC and Edison personnel.
The fire hazard analysis in section 9B.4 of the FSAR and drawings 6A721-2400 through 6A721-2424 inclusive described the rating of bar-riers at Enrico Fermi 2 and are the documents utilized for fire analy-sis. Due to an editorial oversight, Paragraph f(2), f(3) and f(5) are incorrect. We will be amending these FSAR paragraphs.
Utilizing these fire protection drawings, doors RM2-2, RM2-3, RM2-4 and R2-20 are shown as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated doors. It is Edison's opinion the correct rating was assigned to these doors. NOI'E: Door RM2-1 is not a security door and was purchased through a different purchase order.
Corrective Action to be Taken to Avoid Further Noncmpliance The corrective action that Engineering will take to alleviate future proolems and conflicts dealing with fire rated door assemblies will be to revise G.E.I. (Generation Engineering Information) technical form No. M-102, Revision 2, entitled " Fire Protection for Buildings and Equignent for Fossil and Nuclear Plants" and add section on fire rated door and frame assanbly mquirements and ratings.
The purpose of the above mentioned G.E.I. technical form is to present information and set policy to be used by all engineers and designers in the Generation Engineering Department.
The Date When Full Cmpliance will be Achieved The investigation report frmt U.L., procedure revision and FSAR change should be ccraplete by approximately Noverrber 30, 1983.