RBG-25121, Forwards Response to NRC Re Violation Noted in Insp Rept 50-458/86-30 on 860922-26.Corrective Actions: Procedure STP-000-3001, Daily Fire Door Position Check, Revised & Fire Watches Established

Forwards Response to NRC Re Violation Noted in Insp Rept 50-458/86-30 on 860922-26.Corrective Actions: Procedure STP-000-3001, Daily Fire Door Position Check, Revised & Fire Watches Established

ML20212E089
Person / Time
Site:	River Bend
Issue date:	12/22/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20212E048	List: ML20212E043 RBG-25121, Forwards Response to NRC Re Violation Noted in Insp Rept 50-458/86-30 on 860922-26.Corrective Actions: Procedure STP-000-3001, Daily Fire Door Position Check, Revised & Fire Watches Established
References
RBG-25121, NUDOCS 8701050241
Download: ML20212E089 (4)

Text

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. 1 GULF STATES UTILITIES COMPANY river BEND STATION POST OFFtCE BOX 220 ST FRANC!$VILLE. LOUISIANA 70775 ARE A CODE 504 635 6094 346 8651 December 22, 1986 RBG- 25121 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000

@@]ggh Arlington, TX 76011 /

Dear Mr. Martin:

!j.9 DEC 241986 oi lj River Bend Station - Unit 1 l  !

Refer to: Region IV Docket No. 50-458/ Report 86-30 This letter responds to the Notice of Violation contained in NRC I&E Inspection Report No. 50-458/86-30. The inspection was perfromed by Mr. M. E. Murphy during the period September 22-26, 1986 of activites authorized by NRC Operating License NPF-47 for River Bend Station - Unit 1.

Gulf States Utilities Company's (GSU) response to Notice of Violation 86-30, " Failure to Identify an Inoperable Fire Door and Establish the Required Fire Watch", is provided in the enclosed attachment at this time as per telephone conversations with your

. staff. This completes GSU's response to the Notice of Violation.

Sincerely,

/ 1 W. J. Cahill, Jr Senior Vice President River Bend Nuclear Group WJC/ / / /je tu Attachments 8701050241 861231 PDR ADOCK 05000458 O PDR a

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY C(BSESSION STATE OF IMISIAEA 5 FARISE OF WEST FILICIANA $

In the Matter of 1 Docket Bos. 50-458 GULF STATES UTILITIES C(BIFANY $

(River Bend Station, Unit 1)

AFFIDAVIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice President of Culf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Rggulatory Coussis sion the documents attached heretos and that all such documents are true and correct to the best of his knowledge, information and belief.

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fCahil'1,Jr./

Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this / I day of /cfMt. 19d. (

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• hel _ f_ f r-r- w Joan 11. Middlebrooks Notary Public in and for West Feliciana Parish, Louisiana My Conunission is for Life.

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ATTACHMENT

, -RESPONSE TO NOTICE OF VIOLATION 50-458/8630-01 LEVEL IV 4

REFERENCE.

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- Notice of Violat' ion - J. E. Gagliardo letter to W. J. Cahill, Jr.

dated November 12, 1986.

FAILURE TO IDENTIFY'AN INOPERABLE FIRE DOOR AND ESTABLISH THE REQUIRED FIRE WATCH

+- Technical Specification Surveillance Requirement 4.7.7.2.

requires, in part, that fire doors shall be verified operable by inspecting the closing mechanism and latches and by verifying at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that each unlocked fire door without electrical supervision is closed.

Technical Specification Limiting Condition for Operation (LCO) 3.7." requires, in part, that all fire barrier assemblies shall

be operable,and identifies fire doors as fire barrier assemblies.

The action statement.for this LCO requires the establishment of a

continuous fire watch'within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or verify the operability of i fire -detectors on at'least one side of the inoperable assembly and establish an hourly fire watch patrol.

Contrary to the above, fire door CB-116-23 was found to be inoperable on September 24, 1986, due to the absence of a lock

mechanism, and with the closing and latching mechanisms disabled.

i This condition had not been identified or reported during the 1 daily fire door position check of procedure STP-000-3001 from June through September 1986; thus, the required fire watch had not been provided.

REASON FOR THE VIOLATION j During a revision of the security program to utilize the vital

! island concept (as opposed to vital areas) the door in question l (CB-116-23) was downgraded from a security door to a free. access door. This revision was made prior to implementation of the current design control program, and did not consider other design L requirements for this door.

Also, Surveillance Test Procedures (STP's) by which this door was j verified operable were determined to be insufficient. While the

door was veritied- to be closed, the STP's did not require an '

j inspection of the latches and closing mechanisms.

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ATTACHMENT (cont ' d . )

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon identification of this concern, the actions required by Technical Specification Limiting Condition for Operation (LCO) 3.7.7 were implemented. Investigation into this condition determined that operable fire detection existed on at least one side of the fire barrier and that an hourly fire watch patrol had been previously implemented on March 19, 1986 for this area by LCO 86-235.

STP-000-3001, " Daily Fire Door Position Check" has been revised to clarify the acceptance criteria for normally closed fire doors to include a check of latches and closing mechanisms.

CORRECTIVE STEPS WHICH WERE TAKEN TO PREVENT RECURRENCE Following the clarification to STP-000-3001, the subsequent performance of the STP identified several additional doors with inadequate latching mechanisms. Fire watches were implemented in each case as required by the Technical Specification.

A review was conducted of each door which was similarly downgraded as CB-116-23 was from a security door to a free access door. This review was to determine if the downgrading may have affected other design requirements for the door. Additional doors were determined to have had their fire barrier design requirements affected in violation of the Technical Specifications. Fire watches will remain in effect for each of these doors until appropriate modifications are completed to return them to a configuration which meets the fire barrier

. design requirements.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED River Bend Station has been in compliance since establishment of the fire watches in accordance with the Technical Specifications.

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