ML20042B687
| ML20042B687 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/07/1982 |
| From: | Lutkehaus T, Mardis D FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20042B668 | List: |
| References | |
| 3F-0182-06, 3F-182-6, NUDOCS 8203250533 | |
| Download: ML20042B687 (4) | |
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January 7,19">2
- 3F-0182-06 File: 3-0-3-a-2 U.S. Nuclear Regulatory Commission Region 11 Attn: Mr. 3. P. O'Reilly, Regional Administrator 101 Marietta St., Suite 3100 Atlanta, GA 30303
Subject:
Crystal River Unit 3 Docket No. 50-302 Opcrating License No. DPR-72 IE Inspection Report 81-25
Reference:
Ril:WHM 50-302/81-25
Dear Sir:
We offer the following response to the violation listed in the referenced inspection report.
NOTICE OF VIOLATION Technical Specification 3.7.12 requires all penetration fire barriers protecting safety related areas 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.
Contrary to the above, the firc 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.
8203250533 820318 PDR ADOCK 05000302 O
PDR General Office 3201 in rty-fourtn street soutn. P o Box 14042. St Petersburg. Florida 33733. 813-866-5151
- 3F-0182-06 January 7,1982 Page 2
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 the subject clearly indicate that the specification applies to "... passive elements..." which we would interpret to mean fire retardant material (s) in-and-around piping / electrical penetratic,as, etc. We concur that doors (and dampers) are fire barriers and they are covered in some technical specifications 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 puts us in an undue hardship. In short, we feel that when ONRR meant to include doors, they did so specifically.
Additionally, aside from the lack of legal requirement to include fire doors, the following technical aspects also mitigate this particular situation and are consistent with the reviews required by certain other technical specifications:
That area between the " Hot Machine Shop" and the " Auxiliary Building" is free of excessive amounts of combustibles.
The fire door was open due to extensive material movement through this opening. This constituted an area where constant manning was available to close the fire door if and when a fire should occur.
Thus, no undue risk of fire and/or threat to public health and safety was created by this circumstance.
Florida Power Corporation, in our reviews in support of our position stated in the initial l
paragraph, has observed that many technical specifications on fire protection are quite j
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.
It is apparent that NRC positions stated therein do address doors and dampers as well as passive barriers.
Thus, to bring CR-3 Technical Specifications in line with your i
technical position, we will propose changes to include doors and dampers protecting safety related equipment.
In order to do this properly, we will address MODE l
dependency, alternate ACTIONS (i.e., operable fire detection, continuous occupation, l.
Iow fire loading, etc.) and associated surveillance. We anticipate submittal of such changes before April 30, 1982, and leave it to NRC/ONRR to evaluate their priority for issuance.
l l
- 3F-0182-06 January 7,1982 Page 3 i
We will not and, in fact, cannot fully comply with your position until modifications are made to some of the doors. In the interim, we will administratively increase our control of fire doors and will, in some cases, establish fire watches.
Should there by further questions, please contact us.
Very truly yours, fh h
mA T. C. Lutkehaus David G. Mardis Nuclear Plant Manager Acting Manager Nuclear Licensing DGM:mm cc:
Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555
STATE OF FLORIDA COUNTY OF PINELLAS D.
G.
Mardis states that he is the Acting Manager, Nuclear Licensing, of 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.
d*+
M. G. Mardfs Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 7th day of January,1982.
Yh Notapy Public Notary Public, State of Florida at Large, My Commission Expires: May 29,1984
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