ML20247E154
| ML20247E154 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/20/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-690, NUDOCS 8907260098 | |
| Download: ML20247E154 (3) | |
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Omaha Public Power District 1623 Harney Ornaha. Nebraska 68102 2247 402/536 4000 July 20, 1989 LIC-89-690 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from NRC (J. L. Milhoan) to OPPD (K. J. Morris) dated June 20, 1989 Gentlemen:
SUBJECT:
Response to Notice of Violation (Inspection Report 50-285/89-22)
Omaha Public Power District (0 PPD) received the subject Notice of Violation.
The report identified two violations. As stated in Reference 2 the second violation (285/8922-03) does not require a response. Attached please find OPPD's response to violation 285/8922-02 in accordance with 10 CFR Part 2.201.
If you have any questions concerning this matter, please contact us.
Sincerely, K
J. Norris Division Manager Nuclear Operations KJM/pjc Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator p
A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector j,
t 8907260098 890720 l
PDR ADOCK 05000285 Q
PDC onpinumengr as wa oppononow j
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Attachment I RESPONSE TO NOTICE OF VIOLATION Ouring an NRC inspection conducted May 1-31, 1989, two violations of NRC requirements were identified. The violations involved the failure to institute a fire watch patrol and the failure to designate succession of authority.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation requiring a response is listed below:
A.
Failure to Provide a Fire Watch Patrol Technical Specification 2.19(7) states, in part, that all. penetration fire barriers protecting safety-related areas shall be functional (intact).
With a penetration barrier nonfunctional, verify the operability of fire detectors on at least one side of the penetration and establish an hourly fire watch patrol.
Contrary to the above, the licensee had not established a fire watch patrol' on March 21, 1989, for all nonfunctional penetration fire barriers (fire doors). The doors had been installed with a 3/4-inch unprotected hole on one side of the door frame, thus making the doors potentially nonfunctional.
This is a Severity Level IV violation.
(Supplement I) (285/8922-02)
OPPD RESPONSE (Violation A) 1 1.
Reason for the Violation, if A.d_mitted OPPD admits the violation occurred as stated.
The reason for Violation A is incoQplete acceptance criteria established in the installation procedure MP-FIFC000R-2 Rev 3 " Replacement of Firedoors".
Twenty-three fire doors were procured with the 3/4 inch r.osiduit connection 4
holes, and the doors carried a Ut label as a Class A (three ho'ur) fira door. The doors were in:tslied using an approved procedue designed to ensure the furictional requirecepts of NFPA 80, " Standard'for Fire Doors and 4
'Wtndows", were met during installation. The insta11cth procedure j
required the establishment of a fire watch patrol per Technical Specification 2.19(7) prior to removal of ths existing door, and required that the fire Watch patrol romaiS in place 'ontil final Quality Control acceptance of the instal 16d f o6e per the acceptance criteria in the l
procedure.
The installation proceduG 1:i effect at the time of the fire door replacement project (MP-FIRED 00R-2 Rev 3) did not require permanent cointuit connect W t'o the electric strike as a condition of acceptance for 1
operability.
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.If the acceptance of the installation procedure criteria had included the requirement for provision of permanent conduit connections to the electric strikes, the doors would not have been declared operable, and the fire I
watch patrol would not have been released.
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It was felt that the 3/4 inch hole was insignificant with regard to fire l
resistance, and with the proper installation of functional hardware such as i
closers, locksets, hinges, and strikes, as well as the proper alignment of j
the door with regard to maximum perimeter gaps,the installation was J
sufficient to ensure the operability of the resulting fire door.
The fire door frame's primary purpose is to retain its structural integrity during' a fire, and not to provide an insulating fire resistance. UL Standard 108, " Fire Tests of Door Assemblies" allows for limited flame-through in door to frame perimeter gaps, and sets no limitation on j
backside temperatures during a furnace fire test. Conditions for acceptability of a doer during a fire test require the integrity of the assembly be maintained such that final perimeter gaps, as well as flame through distance and duration, are within maximum limits.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A fire watch patrol was established, assuming the 3/4 inch holes on the door frames made the fire doors inoperable. A technical evaluation, PED-STE-89-72-J, using the provisions of Generic Letters 85-01, was performed to determine the adequacy of the fire resistance of the twenty-three doors in their existing configuration. The evaluation uok into consideration the UL criteria for passing a three hour endurance test, the significance of the unprotected hole as it applies to the test criteria, and the combustible 1
loadings involved in the areas affected. The evaluation concluded that the I
existing twenty-three fire doors provided a more than' adequate margin of safety for protection from the hazards involved. Upon completion and approval of the evaluation, the fire watch patrols were discontinued.
l CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Procedure Change Number 28845 to the current fire door installation procedure, GM-RR-FP-0502 Rev 0 "Firedoor Replacement" (supercedes MP-FIRED 00R-2) has been submitted to the PRC for approval.
The change incorporates comprehensive acceptance criteria to be met following installation of a fire door prior to declaring the door operable as a fire resistive assembly.
The general issue of door attachments will be reviewed and incorporated into this change along with an overall rewrite of the acceptance criteria.
The requirement for provision of permanent conduit connections to electric strike assemblies has been Included in this acceptance criteria.
Procedure change to GM-RR-FP-0502 will be incorporated into the Operating Manual by July 26, 1989.
Q8JJJHEN FULL COMPLIANCE WILL BE ACHIEVED OPPD is currently in full compliance with Technical Specification 2.19(7) regarding operability of Fort Calhoun Station firedoors.
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