ML20211P255
| ML20211P255 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/15/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20211P243 | List: |
| References | |
| NUDOCS 8612190023 | |
| Download: ML20211P255 (3) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 20556 SAFETY EVALUATION RY THE OFFICE OF NUCLFAR REACT 0P REGtlLATION RELATING TO OPEDATING LICENSE Nn. PF-11 WITH RESPECT TO LICENSE CONDITION ?.C.(25)(di COWONWEALTH EDISON COMPANY LA SALLE COUNTY STATION, UNIT 1 DOCKET N0. 50-373 1.0 INTRODilCTION License Condition 2.C.(25)(d) for la Salle County Station, Unit 1 pertained to correction of several different deficiencies noted for many individual fire doors or doors in rated fire barriers. By letter dated June 15, 1983, Comonwealth Edison Company (licensee) committed to certain modifications and other actions by way of resolution of those deficiencies. Durino a site audit in May 1986, an NRC Staff Inspector found that the licensee had complied with their June 15, 1983, commitments for all deficiencies except for those associated with stops installed on six doors.
2.0 EVAlllA1 TON License Condition 2.C.(25)(d) for La Salle Unit I reovired the licensee to perform an engineering review, conduct a fire test or replace individual components for certain fire door assemblies in the plant. By letter dated June 15, 1983, the licensee comitted to four separate actions with respect to the separate issues involving these fire doors. With= respect to these six doors, the licensee comitted to remove existing unlabeled door stops and install Underwriters Laboratories (U.L.) approved and labeled door stops.
In additien, the licensee stated that U.L. would provide a letter stating that the door stop construction would be identical to a tested assembly. By letter dated April 74, 1986Property "Letter" (as page type) with input value "05000000/LER-1986-005-03, Informs of Planned Site Visit to Obtain Info Supporting Implementation of Emergency Response Data Sys,Including Availability of PWR or BWR Parameters in Digital Form & Characterization of Available Data Feed Points"April 74, 1986" contains a sequence that could not be interpreted against an available match matrix for date components." contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., the licensee stated that the stops on the six door installations in question were beinp replaced with Pionaer Fireproof Door Company's "PIO-SEAL." door stops (Modification 1-1-84-069). The licensac also furnished a letter from U.L. (dated May 15, 1986,11.1..
Reference:
NC-963) shortly after the staff's May 1986 site audit as evidence that they had complied with their comitment. The letter was, in #act, not eviderce of com-p11ance with the licensee's comitment, but rather in response to an earlier request from the licensee (throuch their Architect /Encineer, Sargent & Lundy Engineers) concerning a proposed investigation of installed fire doors and frames at la Salle. The U.L. letter simply stated that the fire stops described by a sketch and a discussion with Sargent & Lundy were understood to have been furnished by Pioneer Industries.
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The staff indicated by telecom tha+ the U.L. letter noted abnve did not satisfy the commitment.
Following several telephona conversations involving represent-atives from the licensee. Sargent & Lundy, Underwriters Laboratories, and the staff, the licensee and ll.L. proposed a plan of action that was acceptable to the staff. The plan included the following:
1.
U.L. would axamine the door stops to ascertain authenticity of materiels and verify proper installation technioues.
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U.L. would take samples of tha actual oaskot material and sub.iect then to various laboratory analytical tests.
3.
U.L. would furnish a letter to Sargent t Lundy sunmarizing the results of their examination and laboratory tests, and give their conclusions.
a.
During the ir.terim, the licensee would maintain an hourly fire watch patrol of all areas involved with these doors until the staff hed reviawed the letter to be furnished by U.L. and was satisfied that the fire door installations in question were acceptable.
Py letter dated October 14, 19P6, tha licensee transmitted to the staff a copy of the U.l.. latter dated October 8,1986 (H.1. Gruszynski and James J. Urban of U.L. to p. 1.lanowiak at Sargent & Lundy). The conclusions reached by U.L. are:
(li the appearance and dimensions of the material used by the licensee on the six door installations in question are comparable to and within the tolerances permitted for similar materials used on ll.L.
labeled frames manufactured by Pioneer.
'(2) results of the various laboratory tests conducted on the gasketing material samples were inconclusive.
The samples of gasket material taken by U.L. were similar in all respects to material that would be elicible to be used by Pioneer in their U.L. la'eled fire door assemblies. However, differences were noted.
U.L. could not determine the extent to which these differences were due to the effects of natural aging, the presence of foreign substances (paint, dirt, etc.) absorbed by the material during its installed life, or to different materials used during manufacture. Thus, U.l.. cannot positively show that the gaskets used in the new door steps as replacements of the originally installed unapproved stops, are constructed of either U.L. approved or unapproved materials.
However, U.L. did find that the metal components of the door stops are identical to components manufactured by Pioneer for their labeled assemblies.
In addition, the licensee's intent, clearly, was to replace the stops on these doors with U.L. labeled assemblies.
... 3.0 CONCLtlSTON The staff concludes that the installation of these six fire doors now conforn to applicable NDC fire protection guidelines and reouirements and that the intent of the license condition 2.C.f?5)(d) has been satisfied with respect to these six doors. This conclusion is based upon the followino in#ormation:
1.
The orioinal license condition involved various problems associated with a total of 73 fire door installations of which 67 can he deron-strated tn comply #ully with the license condition.
2.
At the time of the staff's site audit in May 1986, the licensee had completed all of the actions required to comply with their Jure 15, 1983 conmitment (tests, engineerino evalua+1ons and replacement of hardware). The only thinp lacking was the confirmation letter from U.L. that the new replacement seals installed on these six door franes were identical to those components manu#actured by Pioneer and licensed by U.L.
3.
U.L. was able to determine that the metal components of the replacament door stops were the same as those labeled by U.L.
4.
U.L. was able to determine by ohysical examination and laboratory analytical tests of the casket material that (a) appearance and dimensions were within tolerances for U.L. labeled material, and (b) ccmposition was similar to U.L. labeled material.
11.l_. did find differences but could not de+ ermine the source of those differences.
Given that the licensee had fully complied with their commitment to correct deficiencies with respect to 67 of the 73 fire doors, and that with respect to the remaining six doors thev had replaced the deficient door seals, and that the metal portion of the replacement seals conformed to U.L. listed speci-fications: the s**
f believes it is unlikely that the licensee would have in-tentionally used.,askets that were not U.L. listed. The staff's position is further strengthened by the results of the U.L. laboratory tests.
For although these tests could not conclusively show that the gasket material was identical to U.L. labeled gaskets, neither is there conclusive evidence to show that the gaskets were not of approved Pioneer manufacture, and other physical characterts-tics are similar to approved gaskets in all respects.
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