ML20151X603
| ML20151X603 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/18/1988 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| P-88302, TAC-61578, NUDOCS 8808260042 | |
| Download: ML20151X603 (8) | |
Text
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August 18, 1988 R.O. WILUAMS, JR.
Fort St. Vrain Unit No. 1 ES'[rN8k"dmoss P-88302 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Docket No. 50-267
SUBJECT:
Proposed Record Storage Center at Fort St. Vrain (TAC No. 61578)
REFERENCE:
See Page 3 Gentlemen:
In Reference 1, PSC received a notice of deviation in NRC Inspection 85-16 concerning the fire rating of a door in the Records Center file room at Fort St. Vrain.
In References 2 and 3, PSC provideo' the NRC information concerning the proposed construction of a new records storage facility.
The new facility was expected to resolve the inspection deviation.
Although, PSC had intended to construct a new records storage facility, the plant writedown in October, 1986 resulted in a re-evaluation of proposed construction projects.
PSC has determined that a new facility is not economically prudent at this time and has therefore, postponed indefinitely construction of the new records storige f?cility as originally envisioned. Given the postponement of the new facility, PSC is evaluating the feasibility of making some modifications to the existing facility.
In zhis evaluation, however, the disparity of fire ratings recommended by different versions of ANSI N45.2.9 must be resolved.
The Fort St. Vrain FSAR, Section B.S.19.9 describes PSC's application of ANSI Standard N45.2.9-1974 to quality assurance records associated with the operation of Fort St.
Vrain.
Although not explicitly addressed in the FSAR, the rating of fire doors within the records hhkU}jgK2 000010 05000267 0
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P-88302 Page 2 August 18, 1988 storage facility is covered by ANSI N45.2.9-1974, Paragraph 5.6 which states, "Structures, doors, frames and hardware should be Class A i
fire rated with a recommended four hour minimum rating." The Fort St. Vrain Records Center was constructed before the issuance of ANSI N45.2.9-1974 and PSC has not specifically made exception to this m
standard concerning fire protection requirements (as noted in 4
Reference 1).
PSC, however, does not consider a recommended rating 1
to be explicitly binding.
Additionally, PSC has been unable to locate a vendor which is able to supply 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> fire rated components.
In 1979, ANSI Standard N45.2.9 was revised to require that, "Structures, doors, frames and hardware shall be designed to comply with a minimum two hour fire rating."
Given the fire rating j
disparity between the 1974 and 1979 versions of ANSI N45.2.9, PSC proposes to revise FSAR Section B.5.19.9 to explicitly exempt the FSV 4
i records center from the recommended four hour minimum rating and class A designation and would substitute a commitment to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating for the structure, doors, frames and hardware.
This i a.
consistent with doors and hardware more readily available from 8
vendors and is yet more conservative than ANSI N45.2.9-1979.
)
PSC considers this request to fall under the provisions of i
10CFR50.54(a)(3) and therefore requests NRC concurrence so that the
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deviation identified in Inspection 85-16 can be resolved, and evaluations of modifications to the Records Center can be completed.
3 Attached are marked up pages for FSAR Appendix B reflecting PSC's 4
proposed changes.
Upon receipt of NRC concurrence PSC will revise 4
FSAR Section B.S.19.9 to reflect this change.
PSC will also keep the
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NRC abreast of any modification plans and schedules for the Records Center as they are developed.
Should you have any questions concerning this issue, please contact Mr. M. H. Holmes at (303) 480-6960 for further information.
Very truly yours, Asd4Kad R. O. Williams, Jr.
Vice President Nuclear Operations j
R0W:0G/bre l
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Reviewed by:
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Attachment l
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P-88302 Page 2 August 18, 1988 storage facility is covered by ANSI N45.2.9-1974 Paragraph 5.6 which 1
states, "Structures, doors, frames and hardware should se Cl us A fire rated with a recomended four hour minimum rating." The Fort St. Vrain Records Center was constructed before the issuance of ANSI j.
N45.2.9-1974 and PSC has not specifically made exception to this standard concerning fire protection requirements (as noted in Reference 1).
PSC, however, does not consider a recomended rating i
--to be explicitly binding.
Additionally, PSC has been unable to locate a vendor which is able to supply 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> fire rated components.
In 1979, ANSI Standard N45.2.9 was revised to require that, "Structures, doors, frames and hardware shall be designed to comply with a minimum two hour fire rating."
Given the fire rating disparity between the 1974 and 1979 versions of ANSI N45.2.9, PSC proposes to revise FSAR Section B.S.19.9 to explicitly exempt the FSV records center from the recomended four hour minimum rating and class A designation and would substitute i commitment to a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating for the structure, doors, frames and hardware.
This is l
consistent with doors and hardware more readily available from vendors and is yet more conservative than ANSI N45.2.9-1979.
PSC considers this request to fall under the provisions of i
10CFR50.54(a)(3) and therefore requests NRC concurrence so that the deviation identified in Inspection 85-16 can be resolved, and evaluations of modifications to the Records Center can be completed.
Attached are marked up pages for FSAR Appendix B reflecting PSC's j
proposed changes.
Upon receipt of NRC concurrence, PSC will revise FSAR Section B.S.19.9 to reflect this change.
PSC will also keep the NRC abreast of any modification plans and schedules for the Records Center as they are developed.
Should you have any questions concerning this issue, please contact j
Mr. M. H. holmes at (303) 480-6960 for further inform 6 tion.
Very truly yours,
)
/Mlk R. O. Williams, Jr.
Vice President i
Nuclear Operations l
R0W:DG/bre 1
j Attachment a
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'E P-88302-Page 3
, August-18, 1988
..y References
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1.
NRC letter, Johnson to Lee dated August 13,1985(G-85327) 2.
PSC letter, Warembourg to Johnson dated September 10, 1985 (P-85310) 3.
PSC letter, Warembourg to Berkow *ted April 25, 1986 (P-86069)-
4.
NRC letter, Hinson to Williamt du,2a September 18, 1986 (G-86507) 5.
PSC letter, Warembourg to Berkow dated August 16,1986(P-86516)-
S.
PSC letter, Williams to Calvo dated December 15, 1987 (P-87422) l
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Attachment
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UPDA7"' NSAR-
'Revi n.
S.5-45 Cleani ; (Section 2.4)
Implementation of' ANSI N46.2.1 is specified by separate accumentation.
(See-B.5.19.2)-
Receiving, Storage'and Handling (Section 2.5)-
Implementation of ANSI N45.2.2 is specified by separate documentation.
(See B.5.19.3)
Housekeeping (Section 2.6)
Implementation of ANSI N45.2.3 is specified by seoarate documentation.
(See B.S.19.4)
Personnel Qualification (section 2.7)
Implementation of ANSI N45.2.6 is specified by separate cocumentation.
(See B.5.19.7) 8.5.19.9. ANSI N45.2.9-1974 Recuirements for Collection, Storage, anc Maintenance of Quality Assurance Recorcs for Nuclear Power Plants (a) Scope and Aoplicability The guidance provided by this standard and the associated Regulatory Guide 1.88 shall be applied to quality a s su ra,1ce records associated with operation of Fort St. Vrain Unit No.
1.
Those design, manufacturing, construction and operating records s derated prior to implementation of this standard e
are not backfitted. to the detailed requirements of this standard.
All such records,
- however, are designated initially for lifetime storage.
Until specific review dictates otherwise, they will be stored in the permanent record storage facility.
Appropriate record indexes and filing systems permit reasonable identification and retrieval.
The records are stored and preserved per the requirements of Section 5.0 of this standard.
(c) /A4. Specific Comments Spfekeeping (Section 5.5)
The Records Storage Building is located at the plant site within the site access control fence.
During off-duty hours the facility is kept locked and is monitored by regular guard patrols under the auspices of the plant security program.
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Insert for FSAR Section B.5.19.9 (b) Specific Exceptions-Facility (Section 5,6)
The Records Storage Building shall be designed to comply with a minimum three hour fire rating.
The records stored in the Records Storage Building shall be afforded the protection provided by a three hour minimum fire rated facility.
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UPDATED FSAR Revision 6 B.5-47
. Facility (Section 5.6)
A records storage building has been constructed onsite'to provide for storage of records.
This facility was constructed to provide adequate record protection to prevent destruction by fire, theft, flooding and vandalism.
B.5.19.10.
ANSI N45.2.10-1973 Ouality Assurance Terms and Definitions The quality assurance terms and definitions contained in this standard shall be used as guidance and applied as appropriate to the Operational QA Program for Fort St. Vrain Unit No. 1.
There may be instances where existing procedures contain definitions that may not be in strict accordance with those provided by this standa"d. ~As existing procedures are revised, however, such cefinitions shall be evaluated to determine if the intent of definitions meets the intent of those provided by this standard.
B.5.19.11.
ANSI N45.2.11-1974 Ouality Assurance Recuirements for Desion of Nuclear Power Plants The guidance provided by this standard and the associated l Regulatory Guide 1.64 Rev. 2 (except for excectional circumstances I cescribed in Section B.5.3.4.f.)
shall be applied to design activities involving modification work controlled by the QA Program and the revision or development of plant design documents occurring curing operation of Fort St. Vrain Unit No. 1.
Where codes, standards or desfgn requirements are referenced, or are incoroorated into the standard by references, which are in conflict with original design commitments as set forth in the FSAR, the FSAR commitments shall govern.
Later revisions of applicable codes and standards may be invoked specificall" by the design requirements where ceemed appropriate, consistent
+5e overall commitment to maintain the plant in an "equal Detter than" original condition.
Approcriate design controls have been implemented to control modification work and associated cesign activities to assure that all modification work meets, or exceeds, original design requirements.
l B.5.19.12.
ANSI N45.2.12-1974-Draft 3. Rev. 4, February 1974 Reouirements for Auditino of Quality Assurance Proorams for Nuclear Plants (a)
Scope and Aoplicability Except as expressly modified below, the guidance provided by this standard shall be applied to the audit program identified by the Operational QA Program for Fort St. Vrain Unit No. 1.
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