ML20205S410

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Forwards Correspondence from Underwriters Labs,Inc Re Bullet Resisting Fire Doors for Info.Related Info Also Encl
ML20205S410
Person / Time
Issue date: 01/05/1983
From: Williams C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Baer R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20205S388 List:
References
FOIA-88-344 NUDOCS 8811110056
Download: ML20205S410 (14)
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FIMM8.NLUM FOR: R. L. Beer, Chief, Etigineering & Technical Support i Branch, Division of Engineering S Guelity Assurance, If ,

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C. C. Willisses, Chief, Plant Systems Section

. 5JBJEC1: SULLET RESISTING F2RE D00R5 The a tache d cor respondenct from Underwriters Laboratories, Inc.,

res.rding Ballet Resisting Fire Doors" is forwarded for your informa-1 i O r. .

(( - h/d* w C. C. Wittiais, Chief Plant Systems Section  ;

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SULLET RESISTANT FIRE DOORS .

1. Fireproofed doors with UL label which were later modified to bullet k resistant doors appear to be not in compliance with Undantriter Laboratories,
1nc. requirements for OL labels for fire doors and must bewualified.

(see attached memorandum, C. E. Morelius to E. L. Jordan, 11/23/82).

2. Some licensees are comitted to install bullet resistant fire doors  !

with an Underwriters Label (UL) or a certificate that these doors have f

been tested by a nationally recognized testing laboratory.

In the past such doors were not comnercially available. On March 20,  ;

1978, UL issued successful test data to Chicago Bullet Proof Equipment '

Company of Park Forest, Illinois on a single door which passed.the full scale test and had previously received a bullet resistive rating for high powered rifle (HPR). As a result., UL's "frillowup and labeling departrent" agreed to combine the text of the .wo labels that would normally appear on such a product into one 16el that can be affixed to bullet resistive fire doors manufactured by Chicago Bullet Proof

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, Equipment Comparty. ,

Based on this information, licensees comitted to bullet' resistant fire doors with UL labels or a testing certificate from a nationally recognized testing laboratory, could be cited for noncomo11ance if these doors are installed without such a label or certificate'.

l j A ttachment: As stated ,

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my nu y + m s w. o . u =*.. n h' UN6EnWl:1TEEE LABORATOR mm. i.

a,. inaryudre,,. t-n.s ;ure nt erraui:ati<*u latio.plvr veMic at cia i l

' 333 Pfingsten Road '

Northbrook, Illinois 60062 l' subjects 105, 752 December 3D, 1982 .

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TO: Fire Counell of Underwriters Laborat.ories Inc.,

surglary Protection ccnmci3 of t':W.rwritors ,

Laboratories Inc.,

subscribers to UL's C2 Asnification Service for Fj.re . Doors, subscribers to UL's Listing Service for Bullet .

Red stitig' Materia 1w, Misca33tr.ecur Devices (CNSV) and -

o.hcra Jr.ta:ested SUNIT.C7 :

F.r t abli t tr,e nt of a I;ev Freduct C:.teuory Erititled "Bullet RAvistant Firt Duurs' 4

Several some author Underwritersitics having Lt.boratorit'r juriad'iction2nc.

havefire door rubscribers s equested that UL and establish a new category for fire doors that are evaluated for

(( both fire resistant e at:d bu13et resist.ance.

Current 3y, t.here are several n.Armfacturers authori7ad to produce UL Classified fire door aznamblics that have also been In order to successf ully evaluat.ed for bu)38 t. resist ant ratings.

provide inpreved identification for thane, doors and/or door assembli:s, e new product catent.ry entitled "Bullet Resistant Fire Dcors" will be ertablished.

The door ar.somblies covered unde r the new product category woeld be authorsned to bear a combinat$on labe3 referencing both 43ia . .1 fire and the bullet resistant ra t ings, a3 rmg with,,suppleinen t information for the door asserrM ses, such as t5

,, ,'. rating. ' / :.

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g, Manuf actur ers desiririg to subn.it doors for invest gati

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the requircrwints written request, of t.hi s new pr uiuct category may' subunit s'to construction and detai3ed drawings, or e.xisting UL Follow-Up suryJcc 72o.adure vef.rences, :r Undervi ' i err Laboratories Inc. 333 attentiu . liucard .3. Gruar}nuki, Fire :'rev 4 t ion det.,irteent, In addition to the Ffingnt en Muad, Northbs oor., 21*,teois 6DDR.

written re quest' is to inc3ude a detai3ed drawings regocr.teid, t .h t-j f

summary of the types nf door at semblion to be submitted, as wel)

\ as construct.$on and inet.allatf or. details.

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0; re, r e et f rt of a p.anuf6cturer's request, UL will-forward the ,

a;.;;1 eat son forens covering the investigation and a project plan '

describing the details of the investigation. asaw Follow-Op ..

service. Proecdures will be pre. pared and issued upon the * .

st.rt:ct rful conpletion of t.hese investigations.

U.*;DL kWRITERF 3.A.BORATORIES 2NC.

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M. J. GRUSZYNS . .

Ss:.ior I's cjert F.nglriedr '

T:rc Protortion Department

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Atu.ociate hnnging Engineer Pf e Proteetjon Department R. D. McCLT.ARY . .-

Arucciate hnnging icngineer * *.l ,'

Burglary Protection and Signaling ..

Department . ',

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MEMORANDUM FOR: File FROM: C. E. Norelius, Director, DPRP j

SUBJECT:

BYRON ASLB DECISION Based on a Headquarters meeting on January 17. I understand the following eqcr.n of actionsw wq * .

1. Detennine from the decision whether the staff was misir.terpreted in any particular araa.
2. E$f;ls.J.

R. c--!= why we accepted a sampling program for the reinspection activity.

3. Set up a merW9 with Cumonwealth Edison Company for them to present the results of their reinspection program.
4. Get back to Cocaonwealth Edison by the end of this week and advise them of how long it will take for us to assess the results of their reinspection program, i

A separate enclosure is attached addressing each of these issues.

C. E. Norelius

Enclosures:

As above

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i, Ddi_~050RE1 R O s the staff misinterpreted based on our review of the_ Board's decision.

It appears that there are two general area,s in which the Board may have i.w.w misinterpreted what the staff was saying. Gae 4 relates to the issue of 4 rt W red w W L.4gs.

delegation to the staff for post hearing verificationg In raising this issue on paragraph d-413, the decision alludes to the staff's initial slighting of the issue of the reinspection program and a position that the matter can be left to the staff for post-hearing verificationg Iuts 4, The Board's apparently views the staff did not fully present the .

Os g4-4 m 1mport of the reinspection program at an early date. it.; .;=:,; io, a.4%% ss th 4-are:

y At the time the staff testimony was being prepared, the reinspection program had not been fully defined and therefore l was omitted from the prepared testimony. The failure of the staff to supplement A eet4e%or 4e orally indicate its import me was an oversight on the part of the staff. The Board does acknowledge that once the issue was brought up again, the matter was fully aired.

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@t$ 1 know of no place in which the staff made any statement to preclude l l

the Bosrd's role in the reinspection program. The staff did state that i that the reinspection program would be verified by the staff such that there was assurance that the matter was finally resolved.

This was not intended ,to prelude the Board from taking any action l

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I . or reaching any decision on its own.

2. The decision states that "the NRC staff was unable to assure the

. Board that the reinspection program will provide the necessary assurance that the deficiencies in Hatfields Quality Assurance Program will be identifieri and corrected.' As a matter of clarification, the inability of the staff to satisfy the Board in this regard was based on the fact that the ceinspection. program was not completed and the results had not been ev21uated. As l stated in this decision, the staff felt confident that the program as laid out was ' adequate. Tfils however, does not preclude requesting the licensee and/or its contractors to take additional l action based on the findings of this reinspection program. ,,

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ENCLOSURE 2 o

"'g 4 Question: _. de we accept a sampling program?

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Prior to accepting this pwtiwhr plan,4+re-Cc :=::lth Edi:en Cuy&T,y numerous discussions were conducted within Region III and with IE Headquarters personnel . A number of factors were considered in acceptance of this particular plare. The attached memorandum, Norelius to Keppler dated February 15, documents the meeting with IE. The attached "Coments" regarding corrective actions outline th: i n t i .., v ." items to be considered in detennining what type of reinspection program might be appropriate.

Based on consideration of these factors, the licensee's proposed program was reviewed and finally accepted. The important factors in this ,,

determination are set forth below.

1. A sampling program was not accepted for all contractors. Some contractors,because of known hardware problems or extensive evidence of improper qualifications,resulted in 100% reinspection.
2. For the contractors included in this sampling program, there was the following considerations:
a. No known hardware problems existed 2 : 0 1J y, s ely le:d e : 5 .1GGk vec . . liureet ka.

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b. While the licensee proposed a sampling program which was based on the chronological hiring of inspectors, Region III

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proposed and the licensee agreed, to add te ;l,J.w at least  ;

three additional inspectors for each contractor. The ones added i

were those which, based on our own revieg may have been more l likely to show problems that existed. i

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c. The :- ing program that was accepted, was not n :;p;sJ wi t#c bui: Of ry statistical significance. It was a program
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, COMMENTS REGARDING CORRECTIVE ACTIONS Periodically, during inspections of Ilcensees, violations are Identified ,

where QC inspections have not been properly conducted or where persons not appropriately certlfled have conducted Inspections and therefore, because of their lack of appropriate certification, the quality of such inspections comes into question. While corrective action for future work 9

can be citarly defined, such findings normally raise the question as to the a # ,

adequacy of past construction work. The further question which then arises is the extent to w;.lch completed work soust be reviewed to provide assurance of adequate quality of construction.

The specific percentage of reinspections necessary to provide assurance may not be definable and will Ilkely vary for different situations. Matters to be considered in arriving at such' a decision include the following:  !

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1. Were QC Inspectors not certified because Lf poor paperwork or are inspector qualifications in question 7 f f proper certification forms  :

I have not been completed, but further review shows that Individual j inspectors had proper qualifications, no reinspection work may be required. Ikwver, a question of unquallfled Inspectors would require a greater degree of reinspection work to provide the ,

necessary assurance.

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2. Were actual hardware probles Idantifled in the areas where Inspector l

. qualification or certification has beer questioned? The finding of hardware deficiencies would lead to a higher level of reinspection.

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2-3 What has been the history of earlier licensee audit programs and NRC Inspections in this area? Is the general feeling that the

plant is constructed in an adequate mann'er or have there been eactier questions related to construction deficiencies?  ;

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4. What is the severity of the errors which have been' identified in this particular area? Do such' missed Inspection findings or questions raise the spector of significant safety problems. If so, a greater degree of reinspection should be considered.

5 What is the safety significance of the component system or operation I

{ in question? The greater the safety significance, the greater degree l of reinspection should be considered.

d j 6. What is the possibility of analysis or testing of matarlal strengths i to analyze the safety algnificance of potential problems with the i system.

7 To what extent would a preoperational test program Identify any ,

l construction deficiencies which may have been missed by QC Inspectors?

I j 8. To what extent has the licensee conducted Independent verifications i

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J 3 What has been the results of the ANI Inspection program and overview in the area under question.

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in Instances where the quality of construction is questlor.ed, licensees -

may propose a statistical sampling program to provide the necessary assurances. The following matters should be considered in acceptance of buch a plan: (1) the sample must be representative of the population in question covering all variables which may have been involved;. (2) Ilcensees should define before the start of the plan what.ls meant by "defects" and clearly define the criterla as to what extent of defects will require an expanded sampling program. The expanded sampilng plan should also be

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cisarly defined.

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. s ENCLOSURE 3 J ,l I,

8 Set up a meting date. A date for the comonwealth Edison meeting has been i.

set for Thursday, January 26. IE and NRR have been invited to attend. ,

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ENCLOSURE 4 How long will it take for Region III to assess the results of the CECO reinspection program?

The licensee provided a report of the results of their reinspection program received in Region III January.13, 1984. The report indicates that

, additional supplemental data will be received by February 10, 1984. j Region I!!'s evaluation will involve evaluation of the written report, l evaluation of the oral information presented at the January 26 meeting and i

site reinspection to verify that the inputs into the report. Assuming that the supplemental information is submitted by the licensee by February 10 I 1984, Region III's review of the report, and inspection activity can be

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concluded by March 16, 1984.

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It should be noted as indicated to the Board, that a final determination 1

or judgment on the reinspection program does not necessary preclude a conclusion that additional work may be required. That can only be determined after the above work is completed with regard to analyzing the reinspection program results.

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