ML20042B676
| ML20042B676 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/25/1982 |
| From: | Mardis D FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20042B668 | List: |
| References | |
| 3F-0182-22, 3F-182-22, NUDOCS 8203250516 | |
| Download: ML20042B676 (7) | |
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January 25,1982
- 3F-0182-22 File: 3-0-3-a-2 Mr. J. P. O'Reilly, Regional Administrator Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta St., Suite 3100 Atlanta, GA 30303
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Inspection Report 81-21 (RII:TFS)
Inspection Report 81-25 (Ril:WHM)
Dear Mr. O'Reilly:
Florida Power Corporation offers the following supplemental responses to the violations cited in the subject inspection reports.
l 81-21E:
l Technical Specification 3.7.12 requires all penetration fire barriers protecting safety-l related areas to be functional. In addition, a continuous fire watch is to be established for any non-functional fire penetration barrier.
Contrary to the above, on October 20,1981, at approximately 0645, fire barrier door D-203, separating "A" and "B" emergency diesel generator motor control center rooms and D-204, separating "A" emergency diesel generator were found propped open without a continuous fire watch established.
81-25:
Technical Specification 3.7.12 requires all penetration fire barriers protecting safety related arer, to be functional at all times. With one or more of the penetration fire barriers nonfunctional, a continuous fire watch is required to be established on at least one side of the affected penetration within one hour. Fire doors in fire barriers are penetration fire barriers and must be maintained functional or a fire watch established.
O$foffy}18 General umuo _$k P
aet soutn. P O. Box 14042, St Petersburg, Florda 33733 e 813-866-5151
Mr. J. P. O'Reilly January 25,1982 Page 2 Contrary to the above, the fire door for the fire barrier penetration between the hot machine shop and the 119 foot elevation of the auxiliary building was found on November 17, 1981, to be nonfunctional and a fire watch had not been established. This door was found blocked and wedged in the open position due to inoperative door closers and latching hardware.
RESPONSE
Florida Power Corporation does not concur that the cited conditions constitute an item of noncompliance. The legal basis is our interpretation of the word " barrier" in our technical specifications. Virtually all structures (doors, walls, etc.) serve as barriers in a sense of the word, but Technical Specification 3.7.12 obviously deals with some limited number of fire barriers. Our BASES on this technical specifications clearly indicates that the specification applies to "... passive elements..." which we would interpret to mean fire retardant material (s) in-and-around piping / electrical penetrations. We concur that doors (and dampers) are fire barriers and that they are covered by some technical specification when specifically included (e.g., Brunswick 2).
We do not agree that technical specifications which failed to include them were somehow meant to imply the inclusion of doors.
Furthermore, those technical specifications which do include doors / dampers are considerably less stringent than ours.
Thus, your interpretation coupled with our requirements places us under undue hardship.
In short, we feel that when ONRR meant to include doors, they did so specifically.
Florida Power Corporation, through review in support of our position, has observed that many technical specifications on fire protection are quite different, even among
" standard" technical specification plants. Our review included Brunswick 2, Arkansas 2, Hatch 2, Sequoyah 1, Three Mile Island 2, Cook 2, and Trojan 1; NUREG-0103 revisions 1 through 4 (B&W Standard Technical Specifications); NRC/IE Enforcement Manual; Standard Review Plan; 10 CFR 50 Appendix R; and related documents.
Our review has revealed that some NRC positions do address doors and dampers as well as passive barriers. Thus, to bring the CR-3 Technical Specifications in line with your technical position, we will propose changes to include doors and dampers protecting i
safety-related equipment.
In order to do this properly, we will address MODE dependency, alternate ACTIONS (i.e., operable fire detection and fire suppression equipment, continuous occupation, low fire loading, etc.), and associated surveillance.
We anticipate submittal of such changes before April 30,1982. A draf t of a "model" of l
the Technical Specifications to be submitted is attached.
l In the interim, we are taking the following additional actions:
1.
At the discretion of the Nuclear Fire Protection Specialist, we will take administrative actions, up to and including posting fire watches to mitigate the consequences of inoperable fire doors / dampers. Consideration will be given to the following in identifying necessary and sufficient actions:
l
Mr. 3. P. O'Reilly January 25,1982 Page 3 Occupancy of affected area (s);
a.
b.
Availability and operability of associated fire detection equipment; Availability and operability of associated fire suppression equipment; c.
and d.
Existence and operability of redundant fire doors.
2.
Any steps taken to mitigate the consequences of an inoperable fire door less than the establishment of a fire watch will be surveyed at a frequency determined by the Nuclear Fire Protection Specialist (e.g., if credit for mechanical systems is taken, additional surveillance may be minimal; if credit for occupancy is taken, changes at shift change, etc., must be adequately surveyed).
3.
We are identifying and procuring necessary equipment to increase the reliability of our active fire barriers. These willinclude:
a.
Upgrade and/or repair of existing fire doors to include, where applicable, automatic latching devices, fusable links, etc.;
b.
Replace, if needed, existing fire doors with new roll-up fire doors; and Repair existing fire dampers by replacing spring assemblies,if needed.
c.
Florida Power Corporation considers the above to be sufficient to meet the intent of most Technical Specifications and to greatly exceed our own legal requirements. We, therefore, request that the items of noncompliance be withdrawn.
Very truly yours, Y$
0+ N David G. Mardis Acting Manager Nuclear Licensing Attachments KRW:mm cc:
Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C 20555 l
l
i STATE OF FLORIDA
. COUNTY OF PINELLAS D. G. Mardis states that he is the Acting Manager, Nuclear Licensing, cf Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
mA M. G. Mardis Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 25th day of January,1982.
O14Y W
Nota (f Public Notary Public, State of Florida at Large, My Commission Expires: May 29,1984 l
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"D R A F T" ACTION STATEMENTS ACTION 1 With any of the required fire barriers in an area INOPERABLE, within one hour establish a continuous fire watch on at least one side of the affected penetration. The continuous fire watch shall be i
maintained until the fire barrier is restored OPERABLE.
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ACTION 2 With any of the required fire barriers in an area INOPERABLE, within one hour establish a roving fire watch to check the area on both sides of the penetration at least once per hour. The roving fire watch shall be maintained until the fire barrier is restored OPERABLE.
ACTION 3 With any of the required fire barriers in an area INOPERABLE, within one hour verify the operability of the area fire detection system.
Operability of the area fire detection system shall be verified at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until the fire barrier is restored OPERABLE.
ACTION 4 With any of the required fire barriers in an area INOPERABLE, within one hour verify the operability of the area fire supression system.
Operability of the area fire supression system shall be verified at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until the fire barrier is restored OPERABLE.
ACTION 5 With any of the required fire barriers in an area INOPERABLE, within one hour verify the operability of redundant fire doors.
Operability of the redundant fire doors shall be verified at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until the affected fire barrier is restored OPERABLE.
ACTION 6 With any of the required fire barriers in an area INOPERABLE, within one hour verify that the transient combustible loading in adjacent fire zones is less than (
) BTU /ft.2 Combustible loading verification shall be made at least once per shift thereafter until the fire barrier is restored OPERABLE.
ACTION 7 With any of the required fire barriers in an area INOPERABLE, within one hour verify that the adjacent fite zones are in an area of continuous occupancy. Verification of continuous occupancy in the adjacent fire zones shall be done at least once per shift thereafter until the fire barrier is restored OPERABLE.
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"D R A F T" PLANT SYSTEMS 3.4.7.13 ACTIVE PENETRATION FIRE BARRIERS LIMITING CONDITION FOR OPERATION 3.4.7.13 All active penetration fire barriers listed in Table 3.7-6 shall be functional.
APPLICABILITY:
As shown in Table 3 7-6.
ACTION:
a.
As shown in Table 3.7-6.
b.
The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.7.13.1 Each of the a*x>ve required penetration fire barriers shall be verified to be functional by a visual inspection:
a.
At least once per 18 months, and b.
Prior to declaring a penetration fire barrier functional following repairs or maintenance.
1 CRYSTAL RIVER - UNIT 3 3/4 7-48 l
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