ML20138E932

Responds to NRC Re Violations Noted in Insp Repts 50-277/84-40 & 50-278/84-19.Corrective Actions:Fire Patrol Established Until Maint on Problem Doors Corrected

ML20138E932
Person / Time
Site:	Peach Bottom
Issue date:	04/12/1985
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20138E867	List: IR 05000277/1984040 ML20138E932
References
NUDOCS 8510250146
Download: ML20138E932 (4)

Text

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PHILADELPHIA ELECTRIC COMPANY l 2301 M ARKET STRECl l l

P.O. BOX 8699  !

PHILADELPHIA. PA.19101 SHIELDS L DALTROFF au S E M E U on April 12, lis85 Docket 14cs. 50-277 50-278 Inspection Report 50-277/84-40 50-278/84-19 1:r. Stewart D. Ebneter, Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 631 Park Avenue '

Ling of Pruscia, PA 19406

Dear Mr. Ebneter:

4 Tour letter dated Earch 8, 1965, forwarded Combined Inspection Report 50-277/84-40 and 50-278/84-19 for Peach Botton Atomic Power Station. The need to delay our response to thic report was discussed with J. Grant of your staff on April 4, 1985 and found acceptabic. Appendix A to your letter addresses one itec which doca not appear to be in full compliance with Nuclear Regulatory Commincion requirements. This item in restated below along with our responce.

Violation 10 Crn 50, Appendix R, requirco that 3-hour fire barricro shall be installed no necessary to protect redundant cystems and componente neccccary for cafo chutdown.

Contrary to the above, the 3-hour fire rated walla installed to protect the redundant battery rooms and switchgcar roomo in both Unita 2 and 3 contain door openings with degraded doorn.

This in a Severity Level IV violation (Suppiccont I) .

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• g Mr. Stewart D. Ebneter April 12, 1985 Page 2

Response

The five specific concerns noted by the inspector during his inspection are addressed as follows:

1. Some door closers did not work properly.

An investigation is underway by Philadelphia Electric's Engineering & Research Department to develop a solution to the door closing problem. The mechanical closers for these doors function properly; however, the air flow in these rooms has been affected by our penetration' sealing program (which was conducted to bring the plant in compliance with 10 CPR 50, Appendix R) such that a positive pressure now exists which can prevent some doors from fully closing. Possible solutions being investigated include, but are not limited to: rebalancing the air distribution system or providing relief dampers.

2. The door between A and C switchgear rooms on Unit 2 had been delaminated.

Investigation of this concern revealed that the weld between the face sheet and the hinge side edge channel of the door had cracked. The crack area was exposed only when the door was opened. lihen the door is closed, the damaged area would not be directly exposed to fire. The face sheet covering the door was not directly affected.

The National Fire Protection Association requires that any breaks in the face covering of doors be repaired immediately. Since the crack did not affect the face covering and the damaged area would not be directly exposed to a fire with the door closed, this deficiency had minimal significance on the door's integrity as a fire barrier.

In order to correct this situation, a Unintenance Request Form (MRF) was generated on December 18, 1984, and repairs were completed on January 8, 1985.

In addition, the surveillance test for inspecting fire doors (ST16.16 " Fire Door Inspection") will be reviewed and revised by plant staff to ensure that

?'6 Mr. Stewart D. Ebneter April 12, 1985 Page 3 sufficient detail is provided by the test to identify such deficiencies in the future.

3. Unit 2 door No. 223 was found opened.

The door in question is one of the 41;V switchgear room doors which is subjected to the pocitive pressure from unbalanced air flow as discussed in response to item 1. The corrective actions stated in item 1 should prevent recurrence.

4.&5. Some doors and hardware were found without Underwriters Laboratories (UL) label indicating their fire rating.

The Engineering & Research Department had initiated action for a similar concern prior to this NRC inspection. In an attempt to verify a three-hour fire rating for these doorc and hardware, a document search was performed. iihile it was verified that these doorc were originally designed and inctalled as a three-hour fire barrier, it could not be demonstrated that these doors and hardware had not been nodified since installation. Underwriters Laboratories has been requested to perform an evaluation on these doors. This evaluation should be completed by September 1, 1985. The results of thic evaluation will determine what action, if any, is required to resolve these concerns.

In clocing, since September 15, 1984, an hourly roving fire watch has been established as a precautionary measure while the quality assurance and control portion of our penetration sealing program is being performed. Because of the nature of a roving fire watch, the requiremente for an inoperabic fire barrier as defined in Technical Specification 3.14.d are saticfied. The applicable Technical Specification states, "All fire barrier penetrations ...... separating portions of safety-related systemc ..... be functional. If these requirements cannot be met ..... verify the operability of fire detectors on at least one side of the inopcrable fire barrier and establish an hourly fire watch patrol .....". The detectors for these areas

?* a h e Mr. Stewart D. Ebneter April 12, 1985 Page 4 have been proven operable since the inception of this fire watch patrol. While this patrol was initiated as a result of another concern, the additional precautions provided by these actions minimize the consequences of any degraded fire barriers in these areas. This patrol will continue until the ventilation problem in the switchgear room is resolved, and the proper fire ratings for unlabeled doors can be established.

.Should you require additional information, please do not hesitate to contact us.

Very truly yours,

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N /k$i cc: T. P. Johnson, Resident Site Inspector 1

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