ML20196G347

Notice of Violation from Insp on 981026-30.Violation Noted: on 981030,control Room Pantry Fire Door,Identified as Being Nonfunctional Without Fire Barrier Impairment Permit or Conpensatory Actions,As Required by Procedure APA-ZZ-00701

ML20196G347
Person / Time
Site:	Callaway
Issue date:	11/25/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20196G320	List: IR 05000483/1998024 ML20196G319 ML20196G347
References
50-483-98-24, NUDOCS 9812070315
Download: ML20196G347 (3)

Text

___ _ _ .

ENCLOSURE 1 NOTICE OF VIOLATION Union Electric Company Docket No.: 50-483 Callaway Plant License No.: NPF-30 During an NRC inspection conducted on October 26-30,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below: ,

Operating License Section 2.C(5)(c) states, in part, that the licensee shall implement l and maintain in effect all provisions of the approved fire protection program as described l in the Standard Nuclear Utility Power Plant System Final Safety Analysis Report for the l facility through Revision 15, the Callaway site addendum through Revision 8, and as approved in the SER through supplement 4.

The SNUPPS Final Safety Analysis Report Section 9.5.1.7.3," Fire Barrier Penetrations,"

states, in part, that fire barrier penetrations including fire doors are considered functional when the visually observed condition is the same as the as-designed condition. For those fire barrier penetrations that are not in the as-designed condition, an evaluation shall be performed to show that the modification has not degraded the fire rating of the fire barrier penetration. During periods of time when a barrier is not functional, either:

(1) a continuous fire watch is required to be maintained in the vicinity of the affected barrier, or (2) the fire detectors on at least one side of the affected barrier must be verified operable and an hourly fire watch patrol established, until the barrier is restored to functional status.

The Final Safety Analysis Report - Callaway Site Addendum Section 9.5.1.14. " Fire Doors," states, in part, that fire doors separating safety related areas are provided with closing mechanisms and will be inspected semiannually to verify that the closing mechanisms are operable. Fire doors that are locked closed will be inspected weekly to verify position. Fire doors that are closed and latched will be inspected daily to verify 1 that they are in the closed position. ,

1 Procedure APA-ZZ-00701, " Control of Fire Protection Impairments," Revision 7, requires '

that a fire protection impairment permit and compensatory actions be implemented when a fire door is impaired. ,

I Procedure OSP-KC-00015, " Fire Door inspections," Revision 7 and Procedure SDP-KC-00002, " Fire Door Position Verification," Revision 4, identify fire doors requiring inspection in accordance with the approved fire protection program. I Procedure APA-ZZ-00703,

• Fire Protection Operability Criteria and Surveillance Requirements," Revision 10, identify operability and surveillance requirements to implement the approved fire protection program.

I 9812070315 981125 i PDR ADOCK 05000483 '

G PDR

.- 1 1

i 2-t Contrary to the above, the following examples of a failure to implement the requirements of Operating License Section 2.C(5)(c) were identified: I

1. On October 30,1998, the control room pantry fire door, a fire barrier penetration between Fire Areas C-27 and C-28 required by the approved fire protection ,

. program, was identified as being nonfunctional without a fire barrier impairment e

permit or compensatory actions, as required by Procedure APA-ZZ-00701. In addition, an hourly f;re watch required by Procedure APA-ZZ-00703 was not i implemented.  !

l

2. On October 30,1998, several fire doors required by the approved fire protection l

~

program were not included in Procedures OSP-KC-00015 or SDP-KC-00002 to i ensure their operability via performing required surveillance inspections and were 4-not addressed in Procedure APA-ZZ-703 for actions required when the subject  !

. doors were inoperable. The subject doors included control building doors  ;

between the control room and control room pantry, janitor's closet, toilet, and i secondary alarm station; and, the auxiliary building elevator and dumbwaiter

, doors.

] This is a Severity Level IV violation (Supplement I) (50-483/9824-01). j i

The NRC has concluded that information regarding the reason for the violation, the corrective i

actions taken and planned to correct the violation and prevent recurrence is already adequately addressed on the docket in Inspection Report 50-483/98-24. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein ,

i does not accurately reflect your corrective actions or your position. In that case, or if you  !

choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it

~

to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, i D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite j 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the i subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation

] (Notice).

4 If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington,

. DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your

_ i

. . - - . .- . _ _ . _ _ _ _ . _ . _ _ . _ . _ _ _ ~ . _ . . _ . . _ _ _ . . . _ . _ . . _ . . _ _

j response that deletes such information. If you request withholding of such material, you must )

specifically identify the portions of your response that you seek to have withheld and provide in i detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21. 1 Dated at Arlington, Texe.s this 25th day of November 1998 l

I l

l l

l l

1 l

i. _ a , . _ , . . - - -- - - - . - - -- -