ML20128D553
| ML20128D553 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/02/1985 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8505290115 | |
| Download: ML20128D553 (5) | |
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O PSEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038 609 339-4800 Cortpin A. McNeill Jr. Vice Presdent - Nuclear May 2, 1985 Dr. Thomas E. Murley, Regional Administrator Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
NOTICE OF VIOLATION - NON-FUNCTIONAL FIRE BARRIERS COMBINED INSPECTION REPORT NOS. 50-272/84-46 AND 311/84-46 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company is in receipt of
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your letter dated April 2, 1985 which transmitted a Notice of Violation on non-functional fire barriers.
Pursuant to the requirements of 10 CFR 2.201, our response to the items of violation is included in attachment 1.
Sincerely,
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8505290115 850502 PDR ADOCK 05000272 G
PDR Attachment The Energy People
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ATTACHMENT 1 10 CFR-PART 2.201 INFORMATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY SALEM GENERATING STATION RESPONSE TO NOTICE OF VIOLATION Your letter of April 2, 1985, identified a violation of Technical Specification 3.7.ll. involving non-functional fire barriers.
This involved degraded fire doors, fire. dampers and unsealed penetrations.
A special report as required by the technical specification was not submitted.
The following is a response to the Notice of Violation and constitutes the special report required by Technical Specification 3.7.11.
1.
PSE&G DOES NOT DISPUTE THIS-VIOLATION 2.
THE. ROOT CAUSE OF THIS VIOLATION WAS INADEOUATE MANAGEMENT ATTENTION TO FIRE PROTECTION REQUIREMENTS WHICH ALLOWED THE FOLLOWING CONDITIONS TO BE LEFT UNATTENDED FOR AN EXCESSIVE PERIOD OF TIME:
a.
Inoperable fire doors due to broken or non-functional hardware.
b.
Missing UL labels on fire doors.
c.
Missing fire protection wrap (FS-195) from-dampers at electrical cable tray penetrations.
d.
Unsealed ventilation duct penetrations through stairwell walls.
e.
Fire doors remaining open due to excessive pressure differential.
3.
IMMEDIATE CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED A comprehensive review of the degraded fire barrier penetrations was performed.
Af ter an extensive UL fire door audit in August 1984, a detailed program was initiated in January 1985 for the repair of inoperable fire doors.
The actions completed to date are:
a.
For those fire doors having UL labels and with broken hardware, new hardware has been purchased and installed.
16.
'b.-
Fire-doors.either missing a UL label or having hardware inconsistent with UL' label requirements,
' 'per'UL audit, are being replaced in total.
There are:77 doorsf in.this category..All doors have been
_ ordered with approved UL' hardware and are on site.
As of'-this date, 58.new doors have been installed..
c.
Missing. fire protection wrapping (FS-195) on the fire' dampers has'been replaced.
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Design changes concerning the unsealed ventilation
. duct. penetrations through stairwell walls-have been initiated.
These' design changes call for the
' addition of one-and one-half hour fire. rated dampers 4
on.all discharge ducts into stairwells.
These i
design changes ' are described in our January 31, 1985 Appendix R exemption request.
i e.
A. review of the. pressure-differential ~ problem has been initiated.
Some improvement has occurred.
Certain improper operations of the ventilation systems have'been identified-and-corrected.
Controllers have been found misoperating and have
'been corrected.-
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4 4.
LONG TERM CORRECTIVE ACTIONS TO AVOID FURTHER' VIOLATIONS A.
.The. following additional specific. actions.are being taken to correct specific deficiencies:
1.
An'on-going maintenance program has been established.
A folio system for maintaining a sufficient inventory of spare UL fire door hardware has been instituted in conjunction with a computer program designating specific hardware required-for each door with a folio reference.
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. :2.
Concerning the 77 inadequate fire doors, the remaining 19 doors are'bein'g installed..
=3.
Fire Damper Functional Test Procedures are being revised to require immediate reinstallation of-the.
' removed fire wrap.after completion of testing.
Also the Station Fire. Department'is now-responsible
'for performing this functional. test and will be tracking the-impairments.
4.
Concerning the unsealed ventilation duct.
penetrations, design changes will be implemented upon NRC approval of our January 31, 1985 Appendix R r
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'5.
In order.to_ resolve the excessive pressure differential problem, a review is being conducted of related operating and maintenance procedures.
In an effort totidentify any system' incompatibilities, air
' flow tests are being performed on individual systems.- A review of.the system's design is being conducte'd to improve system characteristics.
This should limit the pressure differentials which will result'in less impact'upon fire door operation.
B.
An indepth review of the entire Fire Protection issue was performed.
As a result of discussions between the Vice President - Nuclear, General Manager - Salem Operations and his staff,. increased attention and awareness of requirements for maintaining the Fire Protection Systems operability has been reinforced.
An aggressive program is in place to identify and rectify design and operational concerns associated with the Auxiliary Building Ventilation System, which in the past has impacted proper Fire Door operation.
A contributing factor related to this. problem was the large number of outages that have occurred on both Units since October 1982, which directly affected Fire Protection priority status.
The increased number of contractor support personnel also aggravated the amount of maintenance needed to keep the Fire Doors in an operable condition.
In addition, there are no effective mechanisms in place to determine the length of time that Fire Barriers are in a degraded condition, or to indicate to management that the number of degraded Fire Barriers is becoming excessive.
Such mechanisms will be instituted.
5.
FULL COMPLIANCE FOR ITEMS 4.A.1, 4.A.2 AND 4.A.3 WILL BE ACHIEVED BY MAY 31, 1985. ' COMPLIANCE WITH ITEM 4.A.4 WILL BE COMPLETE WITHIN 7 MONTHS OF NRC APPROVAL.
RESULTS FROM ITEM 4. A.5 SHOULD BE AVAILABLE BY AUGUST 1, 1985.
COMPLIANCE WITH 4.B WILL BE ACHIEVED BY MAY 31, 1985.
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