ML20203M455
| ML20203M455 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/25/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| CNSS864272, NUDOCS 8609030468 | |
| Download: ML20203M455 (5) | |
Text
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o GENERAL OFFICE
- "L&f!A%'f"^Mt"'".
Nebraska Public Power District Ngg g 3 CNSS864272 August 25, 1986 I
AUG271986 l
.u Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV Gil Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Subject:
NPPD Response to Inspection Report 50-208/86-15
Dear Mr. Gagliardo:
This letter is written in response to your letter dated July 25, 1986, transmitting Inspection Report 50-208/86-15.
Therein you indicated three of our activities were in violation of NRC requirements.
The following is a statement of the violations and our responne in accordance with 10CI'R 2.201.
STATEMENT OF ALLEGED VIOLATION A.
CNS Technical Specifications Limiting Condition for Operation (LCO) 3.10
" Fire Barrier Penetration Seals,"
states that:
"A.
Fire barrier and fire wall penetration fire seals integrity shall be maintained.
B.
If the requirements of 3.19. A cannot be met, a continuous fire watch shall be established on at least one side of the penetration within one hour."
Contrary to the above, it was found, at the time of this inspection, that the lleensee had failed to establish a continuous fire watch while the locking mechanisms were removed from the access doors to the auxiliary relay room, reactor protection system rooms 1A and ID in the Control Building at elevation 903'6".
This is a Severity Level IV Violation.
(Supplement I)
(298-8615-06) lleason for the Alleged Violation This violation resulted from a misconception by the District that the requirements of Technical Specification 3.19 were superceded in certain cases by a schedular exemption und its
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hg0 attendant compensatory measures submitted to the NitC in a esoyoaouo noOa2D i n 4 g{
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CNSS864372 P"g] 2 August 25, 1986 letter from J. M. Pilant to D. B. Vessallo dated June 7,1985.
The compensatory measure had a roving fire watch patrol on the 903' 6" level of the control building via an established route until certain fire doors had been inspected and/or replaced to meet the requirements of 10CFR50, Appendix R.
The subject door had been replaced as part of the above program.
It was not recognized that with the ricor's locking mechanisms removed,
the requirements of Technical Specification 3.19. A (i.e. a continuous fire watch) were not met by the roving watch who passed by the area at least once every 20 minutes.
Corrective Steps Taken And The Results Achieved The District, upon learning of the alleged violation immediately initiated a continuous fire watch and installed the locking devices on the doors in question during the next day.
The NRC inspector was advised of the District's corrective actions, and that the repairs to the doors were completed prior to his departure from the site.
Corrective Steps Which Will Be Taken To Avoid Further Violations To climinate any further confusion in this area, the District will submit a Technical Specification change request to revise LCO 3.10.B to read " fire wetch patrol or continuous fire watch".
This will revise CNS Technical Specifications to be consistent with standard BWR Technical Specifications.
Date When Full Compliance Will He Achieved The District is in full compliance at the present time.
The review and changes to the Technical Specifications will be completed through the normal administrative procedures which govern such changes.
STATEMENT OF VIOLATION 13.
CNS Technical Specifications Section 6.3.2.E states that:
" Written procedures and instructions...shall be provided and adhered to for the following s...E.
Implementation procedures for the Fire P"otection program."
CNS Technical Specifications Section 3.10 states that:
"A. Fire barrier and fire wall penetration fire seals integrity shall be maintained.
13.
If the requirement of 3.19A cannot be met, a continuous fire watch shall be established on at least one side of the penetration within one hour."
The " applicability" paragraph of 3.10 states that: " Applies to the integrity of all fire barrier and fire wall penetration fire seals."
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- CNSS864272 Paga 3 August 25, 1986 Contrary to the above, ~ CNS Procedure 0.16, " Control of Fire Doors", Revision 1, dated December 19, 1984, does not i
uniformly apply LCO 3.19 to all fire doors.
The procedure defines three categories of doors and stipulates the requirements for posting or not posting a fire watch.
This is a Severity Level V Violation (Supplement I)
(298/86-15-07)
Reason For The Violation 4
The statement of the alleged violation describes CNS Procedure 0.16.
In the District's opinion, Procedure 0.16 correctly identifies the need to categorize fire doors and l
accordingly describes various levels of requirements for posting a fire watch or security guard on the various types of doors.
Procedure 0.16 is. intended to fulfill the requirements of LCO i
i 3.19.
However, we agree, as a result of this finding, that procedure 0.16 should be reviewed for its effectiveness and i
clarity.
Corrective Steps Taken and the Results Achieved Procedure 0.16 was reviewed for its conformance with the requirements of Technical Specification 3.19.
It was decided that Procedure 0.16 needed clarification to remove ambiguities.
l
_ Corrective Steps Which Will Be Taken To Avoid Further Violations 4
Procedure 0.16 will be revised to more fully clarify the fire i
doors that are used in the safety related fire area barriera.
Date When Full Complianco Will Be Achieved Procedure 0.16 will be revised by October 1,1P86.
4 STATEMENT OF ALLEGED VIOLATION, I
C.
10CFH50, Appendix D,
Criterion V states, in part,
" Activities affecting quality shall be prescribed by
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documented instructions, procedures, or drawin gs.... Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance i
criteria for determining that important activities have been satisfactorily accomplished."
i CNS Technical Specification Section 6.3.3 states, in part, f
"The following maintenance and test procedures will be i
provided.... C.
Proventive or corrective maintenance of plant equipment and systems that could have un effect on nuclear safety."
1
CNSS864272 Pzga 4 August 25, 1986 Contrary to the above Work item No. 86-0692, dated February 12, 1986, contained no acceptance criteria, did not define an installation tolerance, was not identified as a Technical Specification item, and did'not identify the work as affecting a fire penetration.
This work item installed the inactive side of a double door H-109 which is a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated door for the DC Switchgoar Room 1B.
The work was signed off as completed but the floor to door gap was in excess of the 3/4" allowed by NFPA-80.
This is a Severity Level IV Violation.
(Supplement I)
(298-8615-08)
Reason For The Violation Fire Door H-109's inactive leaf was recently replaced with one containing a fire damper.
Replacement of the inactive leaf on the original hinge points allowed a greater dimension at the threshold than permitted by NFPA-80.
The Corrective Steps Which llave Been Taken And The Results Achieved At the time this alleged violation was pointed out by the NRC Inspector, CNS immediately took corrective action to bring the installation into compliance with NFPA Standard 80.
The Work Item No. 86-0692 was reviewed by the District's Fire Protection Engineer and the CNS Fire Protection Specialist.
It was determined that in fact the distance between the bottom of the door and the floor exceeded the 3/4" permissible dimension as stated in NFPA Standard 80, Section 3-6.1.
A sill was installed beneath the inactive leaf which reduced the gap to less than 3/8", which brought the complete installation within the specified tolerances.
In addition, CNS personnel advised the NRC Inspector of the above Itated corrective action's completion prior to the conc!usion of the inspection.
Corrective Steps Which Will He Taken To Avoid Further Violations The applicable maintenance procedures will be revised to include reference to NFPA Standard 80 for the installation of fire doors.
This revision to maintenrnce procedures will be completed by October 1,1986.
Date When Full Complianco Will Be Achinved The violation was corrected prior to the departure of the NRC Inspection Team from CNS.
CNS will be in' full compliance by October 1,1986.
F
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- CNSS864272 P:ge 5 August 25, 1986 If you have any questions regarding this response, please contact me.
Sincerely, k
cJ.
. Pflant Technical Staff Manager Nuclear Power Group JMP/ Fila /jas:lkCNS.2(COMM9)
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