05000361/LER-1990-001, :on 900220,TS Violation Involving Missed Fire Watch Occurred.Caused by Procedural Inadequacy.Fire Protection Procedures Revised

:on 900220,TS Violation Involving Missed Fire Watch Occurred.Caused by Procedural Inadequacy.Fire Protection Procedures Revised

ML20059H478
Person / Time
Site:	San Onofre
Issue date:	01/17/1994
From:	Krieger R SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-001, LER-90-1, NUDOCS 9401280063
Download: ML20059H478 (7)

LER-1990-001, on 900220,TS Violation Involving Missed Fire Watch Occurred.Caused by Procedural Inadequacy.Fire Protection Procedures Revised

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(viii)(B)
3611990001R00 - NRC Website

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Southem Califomia Edison Company P. O. BOX 128 SAN CLEMENTE, CALWORNIA 92674 0t28

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January 17, 1994 w u.....

MVCot An Ge he matsow U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.

20555

Subject:

Docket No. 50-361 Supplemental Report Licensee Event Report No.90-001, Revision 1 San Onofre Nuclear Generating Station, Unit 2

Reference:

Letter, H. E. Morgan (Edison) to USNRC Document Control Desk, dated March 22, 1990 The referenced letter provided Licensee Event Report (LER) No.90-001 for an occurrence involving a missed fire watch due to a procedural inadequacy.

The enclosed supplemental LER provides~

additional information regarding the schedule for completion of

planned corrective actions

Neither the health nor the safety-

- i of plant personnel or the public was affected by this occurrence.

l If you require any additional information, please so advise.

4 Sincerely, ll.! GW[/

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Enclosure:

LER No.90-001, Rev. 1 cc:

K. E. Perkins, Jr., Acting Regional Administrator, NRC Region V J.-Sloan, Senior Resident Inspector, San Onofre Units 1, 2&3 3

M. B. Fields, NRC Project Manager, San Onofre Units 2&3 1

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I TECHNICAL SPECIFICATION VIOLATION INVOLVING A MISSED FIRE WATCH DUE TO A PROCEDURAL INADEQUACY l.

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1ASSTEACT ILimit to 1400 spaces, i.e.,

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J At 1552 on 2/20/90 with Unit 2 operating at 100% power, Technical' Specification (TS) fire door DG2201 located in the Unit 2 Diesca Generator (DG) building was determined to be impaired-due to a sticky-door' latch.

At 1656, in accordance with TS 3.7.9, Action "a",

an' hourly fire watch was posted in two fire areas- (2-DG-30-156, room 101 and 2-DG-30-158, room 103) which were located on either side of the fire door,'according to the fire protection system computer data base.

During a review on 2/22/90 at 1328, it was determined that a TS-violation had occurred because the rooms identified to be protected by.

fire door DG2201 were determined to be incorrect.

The correct' rooms were rooms 201 and 202 located in fire areas 2-DG-30-156 and 2-DG 158, respectively.

Since these rooms'do not contain any' fire detection' or suppression systems,'a continuous fire watch should have been q

posted.

As required by TS 3.7. 9, Action "a",

a continuous fire watch 1

was posted in Room 201 on 2/22/90 at 1352.

j The root cause of this event was procedural inadequacy, in that the J

- fire protection procedures do not provide sufficient guidance-to identify the correct data needed to properly establish the required compensatory measures for this fire door impairment.

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1 Fire protection procedures have been revised to provide the guidance

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required to properly identify the necessary compensatory measures for 1

impaired fire protection equipment.

This event has been discussed with appropriate EP personnel.

The rooms-which are protected by fire door-DG2201 have been corrected in the fire protection equipment computer data base.

An audit of the fire protection equipment data base will be~

performed and any errors found will be corrected.

The computerized Fire Protection Impairment Program will be upgraded so that it can be used to make fire equipment impairment evaluations without requiring reference to other controlled documents.

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TEXT-CONTINUATION-y

- LICENSEE EVENT REPORT - (LER)

LS1W ONOFRE NUCLEAR GENERATION STATION DOCKET NUMBER

- LER NUMBER.

PAGE' I

s

UNIT'2 05000361 90-001-01 l2 OF 6--

H cPlant: San Onofre Nuclear Generating Station-Unit: Two Reactor; Vendor:

Comuustion Engineering Event Date:. 02-20-90 Time: 1656 i

5 A.

CONDITIONS AT TIME OFLTHE EVENT:

Mode:

1, Power Operation at 100% Power 1

~ B.

BACKGROUND INFORMATION

At San Onofre Units 1, 2, and 3, when inoperable fire protection equipment [KP, KQ)-is identified, the Emergency: Service Officers-(ESO), who are part of the Emergency Preparedness (EP) 1 organization,-are responsible for-the establishment.of appropr'iate

.i compensatory measures required by th'e Technical Specifications-

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(TS).

Upon notification of a' failed surveillance, the ESOs'use.

impairment evaluation procedures to identify the= inoperable-fire protection equipment and to establish'the appropriate compensatory

.l measures pursuant to the TS Action requirements.~ Based ontthe;

j ESO's evaluation, a Fire Impairment Form isninitiatedi to-document

't and track the establishment and termination of the compensatory measures such as firewatches.

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j The Fire Protection-Information System.(FPIS) is aJcomputer [ CPU) based data management system designed to provide-for tracking'of

' fire protection. equipment status -and associated compensatory measures.

Also, FPIS is a secondary tool for ESO.s to uselin-evaluating impairments and. determining the required compensatory measures.' In.this capacity,~FPIS is to be used in. conjunction with' impairment evaluation procedures.

The Plant and Equipment Data Management. System'(PEDMS) is'the-l centralized information data base reflecting plant. configuration in accordance with SONGS Design Documentation (with associated-changes) and other associated field information.

The Updated Fire Hazards Analysis (UFHA) describes the capability-of the plant to achieve safe shutdown in the eventJof a fire.

The UFHA divides the plant into fire area / zones and a fire area / zone may be further divided into rooms.

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LICENSEE. EVENT REPORT (LER)- TEXTLCONTINUATION SAN ONOFRE NUCLEAR GENERATION STATION DOCKET NUMBER LER NUMBER 1

PAGE UNIT'2 05000361

'90-001-01 3 OF 6 C.

DESCRIPTION OF THE EVENT:

1.

Event:

At 1552 on 2/20/90, with Unit 2 operating'at.100% power',.TS:

E Fire Door DG2201 [DR], located-in the. Unit 2 Diesel Generator (DG) building, was discovered by EP personnel to be impaired' as the result of a sticking door latch. -At 1606, the ESOsi initiated an unanticipated. fire impairment -(Impairment Number:

90020331-00) and an impairment' analysis. form for the fire.

door.

The impairment evaluation determined that an hoarly fire watch should be posted in fire area / zone.2-DG-30-156, 1

room 101, and fire area / zone'2-DG-30-158, room'103,'which according to PEDMS were located on: either side of fire ~ door.

DG2201.

This evaluation was based on information' contained in PEDMS and a determination that fire detection and suppression-was operable in fire area / zone 2-DG-30-158, Room ^103.

As required by TS 3.7.9, an hourly fire watch was posted:in Rooms 101 and 103 on 2/20/90 at 1656.

During a review of impairment 90020331-00' by Fire' Protection Engineering (FPE) on 2/22/90 at 1328, it was determined that the PEDMS identified room numbers protected by fire door-DG2201 were~ incorrect.

The correct rooms separated by fire door DG2201 were determined to be-Rooms 201' and:202 located irn UFHA area / zones 2-DG-30-156.and,2-DG-30-158,Erespectively.

The rooms in these fire area / zones do not.contain~any fireL detection ~or suppression systems. _As requiredcby TS 3.7.9,.

Action "a",

continuous fire. watch ~was posted:in Room 201 en

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2/22/90 at 5 2.'

2.

Inoperable Structures, Systems or Components that-Contributed.

to the Event:

Not applicable.

3.

Sequence of Events:

DATE TIME ACTION 2/20/90 1552 Fire Door DG2201 failed TS surveillance..

2/20/90 1656 Hourly fire watch set in Rooms 101 and-103 of Unit 2 DG building.

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2/22/90 1328 FPE determined that the~ original' fire impairment for fire door DG2201 was incorrect.

2/22/90 1352 A continuous fire watch was posted.in Room 201 for' fire door DG2201.

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LICENSEE' EVENT REPORT (LER) TEXT CONTINUATION:

SAN ONOFRE NUCLEAR GENERATION STATION

' DOCKET NUMBER.

LER NUMBER.

PAGE

? UNIT 2-05000361 90-001-01 c4 OF 6 4.

_-Method of Discovery:

During an operability evaluation of'the fire door,-FPE determined.that an incorrect fire watch-had been established' for fire door DG2201.

h fi 5.

Personnel Actions and Analysis of. Actions:

Upon identification that the fire watch"had'been incorrectly established, action was initiated to establish'the correct-fire watch.

6.

Safety System Responses:

Not applicable.

D.

CAUSE OF THE EVENT

1.

Root Cause:

The root cause of this_ event was procedural inadequacy in that-the fire protection impairment evaluation-procedures-do-not' provide sufficient guidance to the ESO personnel.to identify' the correct data needed to properly establish the required' compensatory measures for:this fire door impairment.

Specifically, the UFHA fire area / zone inLthe.DG building.

covers two elevations and is divided into1several' rooms.

The room' numbers were not identified in the station' procedures or in the UFHA, so the ESOs' relied on the infonnation supplied by' PEDMS~to FPIS and, because it wasLincorrect,'twere unable to' correctly. evaluate the-impaired fire _ door-andLimplement:the:

correct type of fire watch.

2.

Contributing Cause

The PEDMS data base information identifying the rooms that were on either-side of the impaired fire door was: incorrect.

This information was'used to determine the compensatory; measures required for the impaired fire door and caused the ESOs to post an hourly fire watch 1in the-wrong room.insteadLof a continuous fire watch in the correct room.

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LICENSEE EVENT REPORT (LER) TEXT CONTINUATION y

SAN ONOFRE NUCLEAR GENERATION STATION DOCKET NUMBER LER NUMBER

.PAGE-j

= UNIT 2 05000361 90-001-01 5~OF-6~

j E.

CORRECTIVE ACTIONS

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1.

Corrective Actions Taken:

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a.

This~ event has been discussed with appropriate EP l

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personnel, emphasizing that the PEDMS data base may be 1

incorrect and that the information provided by1 EDMS.to.

P FPIS must be verified in station procedures or other~-

i controlled documents prior to.use.

If this informationi l

cannot be verified prior to implementing:the TS; required compensatory measures within the one hour' time Li constraint,.the most restrictive compensatory-measure j

will be implemented in all affected' fire area / zones.

1 until the information provided by PEDMS has=been'

]l verified by the means stated above. 'This. practice will be discontinued once the planned corrective. actions 1

discussed in Sections E.2.c and E.2.d are_ complete..

j b.

The room numbers of the rooms associated with fire door I

DG2201 have been corrected in the PEDMS data base.

The PEDMS data base was reviewed to determine 'that the UFHA fire area / zones and rooms. protected by each fire door i

were correctly identified for all other fire doors in

j the Units 2 and 3 DG buildings.

Other discrepancies 1

were noted and corrected.'

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c.

Fire protection. impairment evaluation procedures have 1

been revised to include a cross-reference of TS fire

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doors with associated fire area / zones and rooms.

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d.

Limitations on the use of FPIS, as' discussed in I

corrective action a above, have been incorporated fut the 1) 1 fire-protection impairment evaluation procedures.

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Planned Corrective Actions

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'l a.

The PEDMS data base for fire protection equipment and other data files relied upon by'FPIS will be completely audited to determine if other incomplete or incorrect i

'i UFHA area / zone and/or room information exists.

July

- incomplete or incorrect information discovered will be corrected.

I b.

The computerized Fire Protection Impairment. Program will-I be upgraded so it will befable to.belused to provide 1the!

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necessary data to EP personnel making. fire equipment impairment evaluations without requiring reference to y

the UFHA and/or-other controlled documents.

1 These planned corrective actions will be completed during-g I

normal TS surveillance 4.7.9.2.c, which requires visual

.. inspection.of 10% of the fire rated penetration sealing.

I devices at least once per 18 months and 100% at~1 east once.per-l 15 years.

The inspection cycle will be completed by the,end-il of 1997.

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i LICENSEE EVENT REPORT ~ (LER)-TEXT CONTINUATION i-~ tSAN ONOFRE NUCLEAR GENERATION STATION-DOCKET-NUMBER

.LER. NUMBER PAGE LUNIT:2'

'05000361 90-001-01<

6 OF'6 l

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SAFETY SIGNIFICANCE OF ' THE EVENT

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'The-TS-basis for_ operability requirements of fire' barriers:ensuresi

.that fire damage will;be limited.

These design features minimizef I

the possibility of a single fire affecting'more than one' fire area.

prior to detection and extinguishment.

The safety. significance 3of

]

1 this event'is minimized by the fact that.an hourly' fire watch was-posted in the fire area / zones located on both sides of the-fire.

i door, even though it was not in-the~ correct' rooms within'the fire area / zones.

This is because fire area / zone 2-DG-30-156,;which isca t

staircase that interfaces with fire area / zone 2-DG-30-158, consists.

of two rooms (Rooms 101 and 201) that are physically open to each other.

Thus the' development of a' fire in either fire' area / zone.

a most likely would have been detected by the hourly-fire watch thatL r

was posted in tire area / zones 2-DG-30-156, room 101, and 2-DG :

158, room 103.

Therefore, the likelihood ofia single' fire affecting more than'one fire area prior'to detection'and controllof-this fire was minimal.

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ADDITIONAL INFORMATION

1.

Component Failure Information

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Not applicable.:

2.

Previous LERs for Similar Events:

LER 89-003 (Docket No. 50-362) reported an event involving a:

j missed fire watch caused by a procedural inadequacy,;which-y resulted in'a-failure by Operations' personnel to notify the-ESOs of.a failed' fire protection surveillance.

This-event did not preclude the event being reported.in this LER since it involved an inadequacycin an Operations procedure.

3.

Results of NPRDS search:

3 Not applicable.

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