ML20244B564
| ML20244B564 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/06/1989 |
| From: | Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8906130172 | |
| Download: ML20244B564 (2) | |
See also: IR 05000352/1989006
Text
-_
_-.
.
,
. . . .
..
'
.-
p :. .
. .!
I
JUN 0 61989
l
Docket No. 50-352
Philadelphia Electric Company
ATTN: Mr. C. A. McNeill, Jr.
Executive Vice President
Nuclear-
Correspondence Control Desk
P.O. Box 7520
Philadelphia, PA 19101
Gentlemen:
Subject: ' Inspection No. 50-352/89-06
This refers to your letter dated April 19, 1989, in response te our letter
dated March 20, 1989 which transmitted a violation for failure to maintain a
fire rated barrier between the Limerick Unit I and Unit 2 cable spreading rooms.
Thank you for informing us of the corrective and preventive actions documented
in your letter. These actions will be examined during a future inspection of
your licensed program.
Your cooperation with us is appreciated.
Sincerely,
Ori::ind Signed By:
Jack R. Str0 snider
Jack R. Strosnider, Chief
Engineering Branch
Division of Reactor Safety
cc w/ encl:
J. S. Kemper, Sr., Senior Vice President - Nuclear Construction
G. M. Leitch, Vice President - Limerick Generating Station
S. J. Kowalski, Vice President - Nuclear Engineering
D. R. Helwig, General Manager - Nuclear Servcies
M. J. McCormick, Jr. , Manager - Limerick Generating Station
W._ T. Ullrich, Manager - Limerick Unit 2 Startup
.
A. S. MacAinsh, Manager - Limerick Quality Division
G. A. Hung.er, Jr. , Director - Licensing Section
,
T.. B. Conner, Jr. , Esquire
E. J. Bradley, Esquire, Assistant General Counsel
H. D. Honan, Branch Head - Nuclear Engineering Licensing
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear' Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
8906130172 690606
~0FFICIAL RECORD COPY
RL LIM 89-06 - 0001
0
06/06/89
ADOCK 05000352
=Q
)\\
.
- _ _ _ _ _ - - _ _ - - _
- _ . _ _ - _
,
_ . -
_--
_
- - _ _
i
.
.
_
.
JUN 0 61969
Philadelphia Electric Company
2
bec w/ enc 1:
Region I Docket Room (with concurrences)
u = getra+ Ace 4c+=+
DPua (.:/; enc!)
Section Chief, DRP
Robert J. Bores, DRSS
l
Q *NI
Cf
(,
RI:URS
RI:DRS
Krasopoulos/pmb
Anderson
6/ 1 89
6/ 2489
/
0FFICIAL RECORD COPY
RL LIM 89-06 - 0002.0.0
06/02/89
l
u__
_
_
_
_ _ _ _ _
- _ - -
-- . . - - - - - - - - - - - - - - - - - - - -------
____ _
- .
,
,
(.
,
.,
' . . _
,
PHILADELPHIA ELECTRIC COMPANY
I>
LIMERICK GENER ATING STATION
P. O. BOX A
S AN ATOG A. PENNSYLV ANI A 19454
April 19, 1989
..
Docket No. 50-352
License No. NPF-39
-U.S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
Washington,.D.C.
.20555.-
SUBJECT:
Limerick Generating Station, Unit 1
Reply to a Notice.of Violation
.
NRC Combined Inspection Report Nos. 50-352/89-06
and 50-353/89-06
NRC' letter dated March 20, 1989, forwarded Combined
Inspection' Report'Nos. 50-352/89-06 and 50-353/89-06 for the Limerick
. Generating Station, Units 1,and 2.
This Inspection Report contained a
- Unit l~ Notice of Violation concerning the failure to maintain'a fire
' rated barrier between the Unit-1 and Unit 2 Cable Spreading Rooms.
Our. response to this Violation is.provided in the attachment to this
letter.
If you have any questions, or require additional information,
please contact us.
Very truly yours,
4 ' b [L af\\
c
r
J
M. J. McCormick, Jr.
Plant Manager
DMS:sc
Attachment
'
W. T. Russell, Administrator, Region I, USNRC
cc:
T. J. Kenny,,USNRC Senior Resident Inspector
,
g~ww
'
.
~
.
h
Attachment
Page 1 of 3
.
,
Docket No. 50-352
l
Violation:
License Condition C.(3) Fire Protection, stipulates that the licensee
shall maintain in effect all provisions of the approved Fire
- Protection program described in the Fire Protection Evaluation Report.
The Fire Protection Evaluation Report, in Section 3.1.1,
Item 38,
states that 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers are provided to separate Unit 1
structures from Unit 2 structures, and common structures such as the
control structure are separated from the adjacent structures of both
reactor enclosures by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers.
Contrary to the above, a door separating the Unit 1 cable spreading
room from the Unit 2 cable spreading room was not 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated.
The door was not rated because it could only stay latched closed by
the use of electromagnets.
Loss of power to the magnetic contacts as
a result of a fire in either cable spreading room could render the
door and the entire barrier inoperable.
This is a Severity Level IV Violation (Supplement I).
Response:
Admission of Alleged Violation:
Philadelphia Electric Company acknowledges the violation.
Reason for the Violation:
The cause of this condition was inadquate consideration of fire
protection aspects in the design of a modification.
Door 381 separating the Unit 1 Cable Spreading Room (CSR) from the
Unit 2 CSR was not providing a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barrier, because the
mechanical latching mechanism was removed and replaced with a
electromagnetic latch in accordance with a modification designed and
completed on October 18, 1984.
In October of 1984, during Unit 1 Start Up/ Unit 2 construction, Unit 2
enclosures were open to the atmcsphere to allow for construction
activities.
The Unit 2 CSR had many wall and floor openings to allow
cable pulling operations.
Since the Unit 2 CSR was open to the
atmosphere, a tornado depressurization could create a differential
pressure of 1.5 psi across the wall separatinj the Unit 1 CSR from the
Unit 2 CSR.
This wall, which forms the Unit 1/ Unit 2 boundary, is
designed to withstand only 0.87 psi.
In order to protect the Unit 1
CSR, door 381 was modified such that it would open into the Unit 2 CSR
when subjected to the tornado depressurization effect.
The
modification equipped door 381 with a magnetic lock and pressure
activated switch to ensure that the door would open at a differential
_ _ _ _ - _ - -_ - _
_ _ _ _
__
-
1
,
j
-
Attcchm:nt
Page 2 of 3
,
'
3
-
Docket No. 50-352
pressure of 0.75 to 0.80 psi.
Overlooked by the Philadelphia Electric
Company (PECo) and the Architect / Engineer (A/E) design groups was the
fact that loss of pcwer to the electromagnetic latch as a result of a
fire in either CSR, could render the door and the entire fire barrier
Corrective Actions Taken and Results Achieved:
When the problem with door 381 was identified by the NRC inspector
during the special team inspection,
the fire door was declared
inoperable requiring a roving fire watch in accordance with Technical Specification (TS) 3.7.7, " Fire Rated Assemblies."
It should be noted
that a roving fire watch had already been established in both CSRs
since December 3, 1986, due to the Unit 2 construction activities.
Door 381 is being replaced with a new United Laboratories (UL) listed
door that uses a mechanical latching mechanism rather than a
electromagnetic latch, to secure the door.
The new door complies with
the Fire Protection Evaluation Report (FPER), such that a fire in
either CSR will have no affect on the door's ability to function as a
Additionally, all penetrations entering the Unit 2 CSR
are sealed, and the effects of a tornado depressurization to this room
is no longer a concern.
Door 381 is scheduled to be replaced by April
24, 1989.
The roving fire watch will remain in effect until door 381
has been replaced.
Corrective Actions Taken to Avoid Future Non-Comoliance:
Upon review of the procedures and mechanism's used in the development
of modifications prior to the issuance of the Unit 1 Low Power License
(October 26, 1984), it has been determined that procedural control
existed to direct that modifications would be appropriately reviewed
for fire protection concerns.
The failure of the design groups to
recognize the impact of this modification on fire protection is
considered to be an isolated occurience related to the modifications
emphasis on structural integrity.
Subsequent to issuance of the Unit 1 Low Power License on October 26,
1984, PECo engineering assumed full responsibility for design and
approval of safety related modifications with the A/E assisting in the
design process.
To enhance the design review process, a fire
protection review checklist has been incorporated into PECo
engineering and the A/E modification procedures.
This checklist is
used in the review of modifications to assure that fire protection
requirements and concerns are reviewed.
A review was performed on all Unit 1 and Common 3-hour fire rated
doors required by the FPER.
Two additional doors were identified
which contained similar electromagnetic latches.
But, these doors
still contain the mechanical latching mechanisms which can be used to
- _-_.
_ _ _
-
__ __
~ ' '
Attachmant
)
,.
Paga 3 of 3
,
- . ,
t
Docket No. 50-352
!
i
I
maintain the fire barriers in the event of loss of power.
Additionally, these doors do not separate safe shut down areas.
A
sign will be posted on these doors by April 24, 1989, instructing that
the door be mechanically latched shut in the event of a fire in the
The appropriate pre-fire strategy plans, will be revised by May
area.
15, 1989, to include instructions to-latch these doors closed.
Prior to Unit 2 Start-Up, all fire doors or barriers interfacing.with
Unit:1 or protecting Unit 2 areas, will be inspected prior to
acceptance by the Plant Fire Protection group to assure compliance
with the FPER.
Date When Full Compliance Will be Achieved:
Door 381 is expected to be operable on April 24, 1989.
l
l
_______-________________m
_________m_m.-___._-__
_.._-____.-..__..-_m.
-____--._-m-m__.
__m-
'