ML20204J779
| ML20204J779 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/20/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-87-0099, WM-87-99, NUDOCS 8703270306 | |
| Download: ML20204J779 (3) | |
Text
NUCLEAR OPERATING CORPORATION March 20,1987 U. S. Nuclear Regulatory Comnission ATTN: Document Control Desk Washington, D. C.
20555 Letter: NM 87-0099 Re:
Docket No. STN 50-482 Ref:
Letter dated 2/19/87 from JEGagliardo, NRC, to BDNithers, NCFK)C Subj:
Response to Violation ~ 482/8701-01 Gentlemen:
Attached is a detailed response to violation (482/8701-01) which was documented in the Reference.
The violation concerned an inproperly routed flexible conduit which rendered a fire danper inoperable.
If you have any questions concerning this matter, please contact me or Mr. O. L.
Maynard of my staff.
Very truly yours, L-Bart D. Withers President and Chief Executive Officer BEM:wbb Attachment cc: P0'Connor (2)
RMartin JCunnins 8703A70306 B70320 PDR ADOCK 05000482 l
G PDR l
'O P O. Eku 411/ Buriengton, KS 66839 i Phone. (316) 36&B831 l
An EquaJ Opper:un:ty Emp4cyer nt F HCVET
- ^
' Attachment to 1H 87-0099 Page'l'-
Violation (482/8701-01):
Fire Danper Not Operable As Required By
. z Technical Specifications e
Finding:
. TS
- 3.7.111 requires
- that, "All fire barrier penetrations (walls,
' floor / ceilings, cable tray enclosures,. and.other fire barriers) separating safety-related fire. areas. or separating portions of. redundant systems
.inportant to safe shutdown within a fire area and all sealing devices in fire-rated assembly penetrations (fire doors, fire windows, fire d m rs,--
cable, piping, and ventilation duct penetration seals) shall be OPERABLE."
Contrary to the above,'on January 29, 1987,.the NRC. inspector observed that the flexible conduit to the electro-thermal link in Fire Danper GK GD050 was routed under the danper fire curtain and could possibly interfere with. the operation of the fire curtain -and prevent it from fully closing;and rendering the danper inoperable. On February 3, 1987, the licensee tested the fire danper by melting its thermal link and the danper curtain failed to -
fully close as required, thereby verifying that Fire Danper GK GD050 was inoperable.
Reason-For The Violation:
Fire damper GK GD050 is a vertical' danper operated by an.' electro thermal link which,is controlled by a signal from a.Halon System Control. Panel.
'It is-located.in a wall-duct separating Switchboard Room 4 and Battery Room 4 on the 2016 foot elevation of the Control Building.
The 'danper had. been-cycled on December 1, 1986, as part of an 18 month surveillance to demonstrate Halon System operability.
The cycling was acconplished by uncringing the damper S-hook, disconnecting the electro thermal links, and allowing the danper blades to drop.
It is believed that the flexible ' conduit was installed inproperly during ' restoration from this testing through personnel error.
Had a fire occurred'in the area while the danper was inoperable, the Fire ~
Detection System would have generated an alarm in the Control Room, thus ensuring pronpt Fire Brigade response to mitigate the consequences of the fire.-
Additionally, - the inoperable danper would not have prevented Halon
[
System discharge into the Switchboard Room.
l Corrective Steps Which Have Been Taken and Results Achieved:
On January 29, 1987, the potential for flexible conduit interference with closure of damper GK GD050 was identified by a NRC Resident Reactor Inspector.
In order to determine the operability of the danper, on February 3,
1987, maintenance personel tested the danper by actuating the electro thermal link.
The test confirmed that the flexible conduit did interfere i
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4.:.
Attachment to WM E7-0099 Page 2 with damper closure.
The maintenance personnel then notified Control Room personnel of the failure, and the control room personnel ordered that the danper be closed and maintained closed pending rework.
In the closed position, the damper fulfilled its intended fire protection function.
Additionally, an inspection of the other similar dampers controlled by electro thermal links was conducted.
During this inspection four (4) dampers were identified as being susceptible to flexible conduit interference.
Three of these dampers were Technical Specification required dampers.
These danpers were also closed and maintained closed pending rework.
Corrective Steps Which Will Be Taken To Avoid Further Violations:
In order to prevent flexible conduit interference with damper closure, the design of the conduit installation to the electro thermal links is being changed for the dampers controlled by electro thermal links.
Plant Modification Request No.
02009 involves the addition of a 90 degree connector between the flexible conduit and the electro thermal link pigtails outside of the damper enclosure to ensure that they cannot be trapped under the damper blades upon closure.
The Date When Full Conpliance Will Be Achieved:
Plant Modification Request No.
02009 will be fully implemented by July 1,
1987.