ML20082P817

Revises 830718 Response to NRC Re Violations Noted in IE Insp Rept 50-341/83-12.Corrective Actions: Ul Contracted to Investigate,Evaluate & Fire Test Fire Doors & FSAR Paragraphs Will Be Amended

ML20082P817
Person / Time
Site:	Fermi
Issue date:	11/14/1983
From:	Wells D DETROIT EDISON CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20082P786	List: ML20082P817
References
EF2-64308-REV-1, NUDOCS 8312090193
Download: ML20082P817 (4)

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Donald A. Wells ManageoOuahty Assuvance (313) 237 tM57

• 2000 Second Avenue 4 fa$$3$$$"# November 14, 1983 EF2-64308, Rev. 1 Mr. R. L. Spessard, Director Division of Engineering U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

Noncompliance at Enrico Fermi Unit 2 -

IE Report 50-341/83-12

Dear Mr. Spessard:

This letter responds to the item of noncompliance described in your IE Report No. 50-341/83-12, 83-12-09. This inspection of Enrico Fermi 2 construction site activities was performed by Messrs. C. Ramsey, F. Maura and J. Ulie on March 18, 21 and May 10-13, 1983.

The item of noncompliance is discussed in this reply as required by Section 2.201 of the NRCs " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.

In the original. response dated July 18, 1983 DECO stated in the

" Corrective Action to be Taken to Avoid Further Noncompliance" that engineering would revise GEI (Generation Engineering Information) technical form M-102, and add a section on fire rated door and frame assembly requirements and ratings. It has since been discovered that the equipment portion (GEI, M-102) pertained strictly to fossil plants and this GEI could not be adapted to nuclear plants.

The enclosed response is a revis.on of the letter dated July 18, 1983.

We trust this letter satisfactorily answers the concern raised in your If you have questions, please contact Mr. G. M. Trahey,

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report.

Assistant Director - Project Quality Assurance.

8312090193 831202 Very truly yours, PDR ADOCK 05000341 G pyg ( L DAW /WEM/pn cc: Mr. Richard DeYou4g, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Paul Byron, Senior Resident Inspector U. S. Nuclear Regulatory Commission 6450 North Dixie Highway Newport, MI 48166 MOV 251983

C THE DETROIT EDISON COMPANY

-PROJECT QUALITY ASSURANCE ENRICO FERMI 2 PP.0 JECT

. Response to NRC Report No. 50-341/83-12 Docket No. 50-341 License No. CPPR-87 Inspection at: Fermi 2 Site, Newport,' Michigan

' Inspection conducted: March 18, 21 and May 10-13, 1983 Approved by:

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h A. Alessi, Director 4

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Project Quality Assurance Date: //[h/73

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Response,to NRC Inspection Report No. 50-341/83-12' (83-12-09)

Statement of Noncompliance, 83-12-09 10CFR50, Appendix A, General Design Criterion No. I requires establishment and implementation of a Quality Assurance Program to provide adequate assurance that all fire protection structures, systems and components will satisfactorily perform their safety. function.

Your response to Sections C, C.1 and D.1.(d) of Appendix, A to' NRC Branch Technical Position APCSB 9.5.1 as stated in Amendment No.: 12' to the Fermi 2 FSAR, d2ted June 12, 1978, committed Detroit Edison Compcny to apply por-tions of t_he-plan,t operations Quality Assurance Program to Fire Protection in safety-related areas to assure that the requirements on design control and procuremeno document control are maintained and.that plant structural components for, fire protection are listed by a nationally recognized testing laboratory, such as Factory Mutual or Underwriter's Laboratories, Inc.

Paragraph D(j) of Amendment 24 to the Fermi 2 FSAR, dated June 1979, states in part, " Door openings are protected with equivalently rated _ doors, frames

> and hardware that have been tested and approved by a nationally recognized testing laboratory".

Detroit Edison Company Construction Specification Nos. B6-NS-01A and B6-NS-02A,- Revision A, dated June 25, 1980, Part 5, requires U.L. labels (permanently; affixed) attesting to the fire resistive capability of fire doors delivered to the Enrico Fermi 2 jobsite.

Contrary to the above, Detroit Edison Company Purchase Orders 1 A-53112 and IA-53113, dated January- 13, 1981, did not specify U.L. labels attesting to the' fire resistance capability of doors numbered R3-13, T3-6, R3-20, RM2-1, R2-11 and R2-16 which are' installed in safety-related areas of the plant.

. Adequate documentation KIS not available to attest to the fire resistive capability of these doors and no U.L. labels attesting to their fire rating was affixed to them.' Four doors, RM2-2, RM2-3, RM2-4 and R2-20 had 1 1/2 hour U.L. labels affixed to them-but did not have the required three hour fire resistive rating as stated in the Fermi 2 FSAR.

Corrective Action Taken and Results' Achieved When the. bids.to supply the security doors to Edison were received, Stone and Webster (then the A/E for security systems) evaluated the bids.

Chicago Bullet / Proof Equipment Company's (CBP) bid took exception to the

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' requirements that the doors ~ bear U.L. (Underwriter's Laboratories, Inc.)

fire labels.

' tone and Webster noted the CBF exception in their evaluation of the bids, and found that it was acceptable because they were of the opinion the doors

were to be constructed-to fire' specifications.

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Response to NRC Inspection Report No. 50-341/83-12 (83-12-09)

Corrective Action Taken and Results Achieved (cont'd)

Edison personnel involved with security, noting that the actual construc-

. tion of the doors would be adequate for fire, did not recognize the consequences in not receiving a label and therefore, agreed with Stone and Webster's recommendation.

To provide effective corrective action, Edison has contracted with Under-writer's Laboratories (U.L.) to investigate, evaluate, and #*re test where necessary,'to assureLthe doors in question will satisfactorily perform their safety function, i.e.. fire resistive capabilities. The investiga-tion, evaluation and fire test results will be available in a report released by U.L. to NRC and Edison personnel.-

The fire hazard analysis in Section 9B.4 of the FSAR and drawings 6A721-2400 through 6A721-2424~ inclusive described the rating of barriers at Enrico Fermi 2 and are.the documents utilized for fire analysis. Due to an .

editorial oversight, Paragraph f(2), f(3) and f(5) are incorrect. These FSAR paragraphs will be amended.

Utilizing these fire protection drawings, doors RM2-2, RM2-3, RM2-4 and R2-20 are shown as 1 1/2 hour rated doors. It is Edison's opinion the correct rating was assigned to these doors.

Corrective Action to be Taken to Avoid Further Noncompliance

-The corrective action that engineering will take to alleviate future

. problems and conflicts dealing with door and frame assemblies (including fire doors) will be as follows:

' Instruct engineers and designers in the utilizing group to write project specifications and purchasing requisitions for door and frame assemblies based on Generation Engineering Departments approved Guide

Specification No. GS-AC7001-08100 entitled, " Metal Doors and Frames".

-The purpose of this document is to outline provisions of metal doors and frames and installation of doors and. hardware for all Edison buildings and facilities.

The use of the above mentioned guide specification will eliminate future

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problems with fire-doors, doors and frames in general.

The Date When Full Compliance will be Achieved The investigation report from.U.L'., procedure revision and FSAR change shouli be. complete by approximately January 31, 1984.

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