ML20244B564

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-352/89-06 Re Failure to Maintain fire-rated Barrier Between Unit 1 & 2 Cable Spreading Rooms

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

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JUN 0 61989

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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

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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

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PHILADELPHIA ELECTRIC COMPANY

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LIMERICK GENER ATING STATION

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S AN ATOG A. PENNSYLV ANI A 19454

April 19, 1989

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Docket No. 50-352

License No. NPF-39

-U.S. Nuclear Regulatory Commission

ATTN:

Document Control Desk

Washington,.D.C.

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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,

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M. J. McCormick, Jr.

Plant Manager

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W. T. Russell, Administrator, Region I, USNRC

cc:

T. J. Kenny,,USNRC Senior Resident Inspector

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Attachment

Page 1 of 3

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Docket No. 50-352

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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

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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

inoperable.

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

fire barrier.

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

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Docket No. 50-352

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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.

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