ML20040A207

Responds to NRC 811124 Ltr Re Violations Noted in IE Insp Rept 50-461/81-27.Corrective Actions:Spreading Room Drawings Will Be Reviewed,Revised & Reissued to Include Necessary Fire Barrier Provisions for All Ladder Rack Chutes

ML20040A207
Person / Time
Site:	Clinton
Issue date:	12/28/1981
From:	Koch L ILLINOIS POWER CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20040A199	List: ML20040A207
References
0981-L, 981-L, Q37-81(12-28)-L, U-0347, U-347, NUDOCS 8201200531
Download: ML20040A207 (3)

Text

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[p-500 SOUTH 27TH STREET, DECATUR, ILLINOIS 62525 December 28, 1981 Mr. C.E. Norelius, Director Division of Engineering and Technical Inspection U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 61037

Dear Mr. Norelius:

This is in response to your Notice of Violation and Inspection Report 50-461/81-27. Illinois Power Company's response to the item of noncompliance cited is as follows:

1. Design Control

a. The Notice of Violation States in part:

" Contrary to this requirement" (PSAR paragraph 8.3.1.4.2.2.3), "eight installed Class lE cable trays were physically separated from non-class lE cable trays by less than the required three foot vertical separation. The licensee stated that it was the design intent to install fire protection barriers in accordance with PSAR requirements.

The applicable S&L cable trays installation drawings did not specify the use of fire resistant barriers in these instances."

A. Corrective Action Taken and the Results Achieved:

The Architect-Engineer was advised of the cited condition and determined that appropriate drawings need to be revised to include tray covers which will provide an acceptable fire barrier in accordance with PSAR commitments.

B, Corrective Action Taken to Avoid Further Noncompliance:

A review of applicable design drawings has shown that the separation problem is limited to ladder racks used for special applications. The use of ladder rack (other than over areas of equipment entry where.only one division is present) is limited to the cable spreading room " chutes" that provide access from the spreading room trays to the i

I 0201200531 820113 l PDR ADOCK 05000461 Q PDR .

i l

Mr. C.E. Norelius December 28, 1981 NRC 3 control room PGCC termination cabinets. All

, spreading room drawings will be reviewed, revised, and reissued to include necessary i

fire barrier provisions for all ladder rack chutes.

j C. Date when full compliance will be achieved:

Revised cable spreading room drawings will be j issued by July 31, 1982.

b. The Notice of Violation, further states in part:

j " Contrary to this requirement" (PSAR Paragraph

): 8.3.1.4.4.3.4) "two installed Class lE instrumentation cable trays were of the open ladder type. Neither S&L drawings nor other

, documents specified the use of solid trays."

A. Corrective Action Taken and Results Achieved:

! The requirements of paragraph 8.3.1.4.4.3.4 i of the PSAR and the FSAR to enclose instrumentation cable in separate conduit or solid bottom tray with covers were written i

based upon the designer's standard practice and not upon regulatory requirements. In

instances in which a high volume of instrumentation cables enter over a short li length of tray, the additional shielding 4

afforded by tray covers cannot always be provided, but shielding is provided by the shielded construction of the cables

themselves. Consequently, the FSAR will be 4

modified by amendment to permit the use of ladder rack tray with or without covers, solid bottom tray without covers, or racewcys shared with control cables (when internal barriers are provided) for instrumentation cables in these special instances.

l ,

B. Corrective Action Taken to Avoid Further

' Noncompliance:

i The amendment to the FSAR, as discussed

above, will preclude this type of noncompliance for all affected j instrumentation cables.

l C. Date when Full Compliance will be achieved:

't i

The CPS FSAR will be amended to reflect the revised instrumentation raceway requirements l by February 28, 1982, i

_ ,_ _ _ _ _ _ _ _ - _ _ _ . _ _ _ . _ . . . ~ -

Mr. C.E. Norelius December 28, 1981 NRC I trust that our response is satisfactory to allow closure of this item of noncompliance. I hereby affirm that the information contained in this letter is correct to the best of my knowledge.

Sincerel ,

L. . Koch Vice President rlj I

cc: H.H. Livermore, Resident NRC Inspector Director-Quality Assurance

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