ML20235K125

Notice of Violation from Insp on 870713-17.Violation Noted:Fire Barrier Separating West Electrical Penetration Room from Auxiliary Bldg Did Not Have 3 Hr Rating as Described in Fire Hazard Analysis

ML20235K125
Person / Time
Site:	Millstone
Issue date:	09/25/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235K073	List: ML20235K071 ML20235K125 ML20235K138
References
50-336-87-16, GL-86-10, NUDOCS 8710020248
Download: ML20235K125 (2)

Text

l APPENDIX A NOTICE OF VIOLATION i

i Northeast Nuclear Energy Company Docket No. 50-336 l Waterford, Connecticut License No. DPR-65 l Millstone Nuclear Power Station, Unit 2 i 1

a esult of the inspection conducted on July 13 - 17, 1987 and in accordance i

. " General Statement of Policy and Procedure for NRC Enforcement Actions," l 10 CFR i_rt 2, Appendix C (Enforcement Policy) (1987), the following violations were identified:

1 A. 10 CFR 50, Appendix R, Section III.G.2.a requires separation of redundant trains by a fire barrier having a three hour rating.

10 CFR 50.48(a) requires that a plan describing the specific features ,

necessary to limit fire damage to components important to safety and l safe shutdown be implemented. '

The Millstone Unit 2 Fire Hazard Analysis describes the fire barriers installed to limit fire damage in compliance with 10 CFR 50.48(a). The  !

wall separating the west electrical penetration room from the auxiliary j building is specified as a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier.

The " interpretations" in Generic Letter 86-10 specify that where a licensee chooses not to seek prior NRC review and approval in the form of an exemption for a deficiency in a fire area boundary an evaluation to i support the acceptability of the deficiency must be performed and retained l for future NRC audit.

Contrary to the above, on July 16, 1987, the fire barrier separating the west electrical penetration room from the auxiliary building did not have a three hour rating as described in the Fire Hazard Analysis because a ventilation duct penetrating this barrier did not have a fire damper.

Nor, had the licensee performed an analysis to support the acceptability of the deficiency in the fire barrier.

This is a Severity Level V violation.

B. 10 CFR 50, Appendix R, Section III.G.1 requires that fire protection features shall be provided for systems and components important to safe shutdown, such that one train of systems necessary to achieve and maintain hot shutdown remains free of fire damage. One method of achieving this is to provide separation of redundant safe shutdown equipment by a horizontal distance of more than 20 feet with no intervening combustibles in accordance with 10 CFR 50, Appendix R, Section III.G.2.b.

An exemption from the above requirement may be requested and granted by the commission in accordance with the 10 CFR 50.12 requirements.

8710020248 PDR ADOCK 0 B h h36 PDR:

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Appendix A 2 Contrary to the above, the distance separating the redundant Auxiliary Feedwater headers and their isolation valves 2FW43A and B was less than '

the required 20 feet and there were intervening combustibles. In addition no exemption from the above requirement was requested.

This is a Severity Level V violation. (Supplement I) l Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice for Violation B, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time. The corrective actions for Violation A are satisfactory.

Therefore, ne response to the Notice of Violation is required for Violation A.

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