ML20195B247
| ML20195B247 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/24/1988 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-88-938, NUDOCS 8811010409 | |
| Download: ML20195B247 (4) | |
Text
-
f, h au Omaha Pubilc Power District 1623 Harney Omaha, Nebraska 68102 2247 402/536 4000 0: 1ober 24, 1988 UC-88-938 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (L. J. Callan) to OPPD,K. J. Harris) dated September 23, 1988 Gentlemen:
SUBJECT:
Response to Notice of Violation NRC Inspection Report 50-285/88-28 Omaha Public Power District (0 PPD) recently received the subject inspection report on fire protection.
Identified in the report are two violations; one on failure to take prompt corrective action and one on inadequate emergency lighting.
Pursuant to the provisions of 10 CFR Part 2.201, please find attached OPPD's response to these violations.
If you have any questions concerning this matter, please contact us.
Sincerely, n
/
J Morris Division Manager Nuclear Operations KJM/sa c: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager i
P. H. Harrell, NRC Senior Resident Inspector lk4h l
8811010409 881024 1
PDR ADOCK 050002S5
((
o PDC
(
n w4 i m. Wm ommumtv
RESPONSE TO NOTICE OF VIOLATION During an NRC inspection conducted on August 22-26, 1988, violations of NRC requirements were identified.
The violations involved the failure to take prompt corrective action in response to an NRC-identified concern and failure to have adequate emergency lighting.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed belo.n A.
Failure to Take, Prompt Corrective Action Criterion XVI of Appendix B of 10 CFR Part 50, and the licensee's approved quality assurance program require that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, the licensee was notified in July 1987 by an NRC inspector of a potential degradation of a seismic gap fire seal due to the intrusion of tendon grease. As of August 1988, although compensatory measures were in place, the licensee had not analyzed the functional capability of this seal nor stopped the intrusion of tendon grease.
This is a Sev;rity 1.evel IV violation.
(SupplementI)(285/8828-01) f OPPD'S DESPONSE THE REASON FOR THE VIOLATION IS ADMITTED The violation is admitted as stated.
The fire-rated seal in question consists of Dow Corning 3-6485 silicon foam injected into the seismic gap between the containment wall and the auxiliary building wall.
Another component of the seal is daming material (ceramic fibec board) on each side of the foam for vertical seals.
The daming material is installed to contain the liquid foam upon injection, to allow it to expand and "set" in place.
Subsequent to the seal installation, a building material caulk was applied to the seal to facilitate painting of the wall.
This Odditional caulk is not a com>onent of the seal nor does it effect the seal's ability to perform.
The caulc has, over time, begun to crack in several areas f
due to normal aging conditions. The concern originally expressed by the NRC inspector was whether the tendon grease in the seal area had caused the i
i cracking of the caulk, and since the grease is a petroleum-based substance, what effect the grease has on the seal's ability to perform its intended i
function.
Unresolved item 8715-03 was written pending an evaluation of the possible effect of the tendon grease on the adequacy of the fire rated seal since it was not found in the tested configuration.
OPPD's response to the concern was to determine whether the grease chemically or physically deteriorates the foam, and whether the tendon grease constituted an additional combustible load that required analysis in the fire Hazards Analysis.
The answers to these questions were sumarized in OPPD internal memorandum FC-1816-87 dated November 20, 1987, which concluded by stating that i
no problems are caused by the tendon grease and that the item could be closed.
This information was given to the Senior Resident Inspector; however, during an NRC inspection in January, 1988, OPPD was informed that their response was l
inadequate since no analysis of the particular seal configuration was i
performed.
At that time, OPPO verbally agreed to have the seal analyzed, but timely action was not taken, in part because this verbal comitment was not l
being tormally tracked.
-I
(.
5 CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED f
An undocumented walk down of the Technical Specification required seismic gap seals was perfonwd to determine other affected areas.
The seal in question and one similarly affected seal were declared inoperable (treated as if they weredegradedormissing),firedetectioncapabilitiesonatleastonesideof the affected seals was verified as operable, and an hourly fire watch patrol perTechnicalSpecification2.19(7)wasinitiatedononesideofeachseal.
l These compensatory measures will remain in place until resolution of the issue is achieved.
To correct the concern that verbal commitments made during inspections were not adequately addressed, OPPD has changed its practice concerning exit meeti.igs.
6 In April, 1988, OPPD began conducting pfst audit conferences immediately following the NRC exit meetings. These post-audit conferences document OPPD's L
verbal commitments and NRC concerns, assign responsibility for response / action preparation, and initiate the response / action process. Assignments are subsequently tracked and monitored by the formal commitment tracking process and published tracking logs.
}
Effective July 15, 1988, a dedicated fire protection engineering position was established within the System's Engineering organization.
On September 26, 7
1988, a second fire protection engineer was added to System's Engineering to assist in upgrading the overall fire protection program.
The engineers' primary focus has been the increased daily attention to active and passive fire protection systen operability and maintenance.
L CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOIO FURTHER V10LAT10ES.
Information has been collected which is to be used as input to a technical f
evaluation of the affected seals. The evaluation will be used to determine i
whether the existing configurations will qualify as 3-hour rated seals.
The l
evaluation is scheduled for completion by January 31, 1989.
The results will either qualify the seal, determine the need for small scale testing or rede-i sign, and determine if it is necessary to stop the intrusion of grease.
If it i
is deemed necessary to redesign or conduct testing, a schedule for completion of these actions will be provided by February 28, 1989. As indicated above, compensatory measures will be maintained until this issue is resolved.
l OATE WHEN FULL COMPLIANCE WILL BE ACHIEVED t
OPPD is currently in full compliance with Technical Specifications as they l
relate to fire barrier penetration seals.
l l
i l
l l
i l
l l
f l
I l
i
.s i
~
B.
iiiadeauate Emeraency Liahtina Section III.J of A)pendix R to 10 CFR Part 50 states that "Emergency lighting units witi at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto."
Contrary to the above, there was not adequate emergency lighting in the control room corridor used by operators when a fire causes evacuation of the control room.
This is a Severity Level IV violation.
(SupplementI)(285/8828-02) j f
OPPD'S RESPONSE THE REAS0W FOR THE VIOLATION IF ADMITTED The violation is admitted as stated.
Safety-related areas, and their corres-ponding access / egress routes are provided with emergency lighting. However, a l
detailed study of emergency lighting for access / egress in the immediate area of the con ml room corridor has not been performed.
The exit signs for the doors located in the corridor are DC powered, and it was believed that this supplied sufficient lighting for personnel to exit the control room in the event of the loss of normal lighting.
4 CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An emergency lighting unit with an 8-hour DC power sup)1y was immediately installed in the corridor on August 26, 1988.
The lig1t was positioned to r
provide illumination throughout both corridor areas.
j CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATl@ l
[
Modification MR-FC-81-51 is underway which will remove the wall separating the l
j control room corridor and the control room. OPPD is performing a comprehensive review of the post fire safe shutdown emergency lighting.
The completion date
]
for this evaluation is March 31, 1989.
j j
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is currently in full compliance, i
I l
l
[
i r
t I
\\
(
f i
l I
'