ML19324B114

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LER 89-024-00:on 890920,safety Review Group Staff Member Identified Committed Fire Door S102A as Possibly Inadequate. Caused by Design Deficiency.Fire Watch Established & Door repaired.W/891019 Ltr
ML19324B114
Person / Time
Site: Catawba Duke Energy icon.png
Issue date: 10/20/1989
From: Glover R, Owen T
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-024, LER-89-24, NUDOCS 8911010034
Download: ML19324B114 (6)
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Docket No..50-413-W ' .LER 413/89-24 ,

Gentlemen:

.. Attached is Licensca Event Report 413/89-24, concerning Technical-

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Specification violation for inoperable fire door due to latch failure ,

  1. and inadequate policy regarding controlled access fire doors.  ;

This event'was considered to be of no significance with respect to the, health and safety of the public. .

.Very truly'you:5 .

Tian.n B. o- .'

Tony B. Owen '  !

Station Manager keb\LER-NRC.TBO-1 xc: Mr. S. D. Ebneter American Nuclear Insurers

. Regional Administrator, Region II c/o Dottie Sherman, ANI Library U.~S. Nuclear Regulator Commission The Exchange, Suite 245 101 Marietta Street, NW, Suite 2900 270 Farmington Avenue ,

l O Atlanta, GA 30323 Farmington, CT 06032

.M & M Nuclear Consultants Mr. K. Jabbour 1221 Avenues of the Americas U. S. Nuclear Regulatory Commission New York, NY 10020 Office of Nuclear Reactor Regulation Washington, D. C. 20555 INPO Records Center Suite 1500 Mr. W. T. Orders 1100 circle 75 Parkway NRC Resident Inspector Atlanta, GA 30339 Catawba Nuclear Station

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'" Technical Specification Violation For Inoperable Fire Door Due to Latch Fai;.ure ,

-and Inadequate Policy Regarding Controlled Access Fire Doors ,

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On, September 20, 1989, at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, with Units 1 and 2 in Mode 1, Power Operation, a Catawba Safety Review Group staff member en route to the Diesel Generator Rooms identified Committed Fire Door S102A as being a possibly inadequate fire boundary door. This door is equipped with a manual latchbolt l

(which was found broken), a key operated lock, and a Controlled Access Door (CAD) mechanism which is actuated by a security badge access key. A fire watch was established, pending a Design Engineering (DE) operability evaluation. On September 21, DE determined that the CAD mechanism for this door was inadequate as a fire protection latching device. Door S102A was repaired on October 4, and the fire watch was terminated. The latch is known to have been in a failed condition between April 27, 1988 and September 20, 1989, with no fire watch posted, thereby violating Technical Specifications. This incident is attributed to a design deficiency, for the selection of a door not capable of withstanding frequent use, resulting in a failed latch, and to an inadequate policy regarding Controlled Access Fire Doors, resulting in the belief that the CAD mechanism would meet the intent of Technical Specifications when a fire door latch was failed. Corrective actions included establishment of a fire watch and repairing the door, and will include a policy statement from DE.

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, Technical . Specification 3.7.11, fire Barrier Penetrations, states that all sealing devices (including fire doors) in fire rated assembly penetrations (EIIS: PEN] shall be operable at all times, or within one hour establish a continuor.s fire watch on at least one side of the penetrition, or verify the

.! operability of fire detectors [EIIS:XT] on at least one side of the penetration

and establish an hourly fire watch patrol. Surveillar:e Requirement 4.7.11.2 states that fire doors shall be verified operable by inspecting the' closing

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mechanism and latches at least once per six months. This surveillance is met by the performance of PT/0/A/4200/48, Periodic Inspection of Fire Barriers and

, Related Structures. National Fire Code, Volume 4, NPFA80, requires that fire

doors be equipped with both latching (paragraph 2-8.2.3) and closing (paragraph ,

j 2-8,5.2) devices.

NRC Committ'ed Fire Door $102A is located on the 554 foot elevation of the

!.. Auxiliary Building [EIIS:VF], coordinates AA-54. It is frequently used, providing access from the Servi e Building [EIIS:MF] to the Battery [EIIS:BTRY) -

Room. Corridor and the Diesel Generator [EIIS: GEN] Rooms. It is equipped with a i key operated dead bolt lock, a manual lever actuated latch bolt, and a -

Controlled Access Door (CAD) mechanism, which is actuated by a security badge access key. The door was manufactured by R.V. Harty Company, Inc., and its selection was based on an estimated use frequency.

EVENT DESCR!pTION On September 28, 1987, NRC Committed Fire Door S102A successfully latched during the performance'of PT/0/A/4200/48.

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, On April 27, 1988, Door S102A failed to latch during the performance of l PT/0/A/4200/48. A fire watch was not established, due to the belief that as L long as the CAD mechanism was operable, the door was operable per Technical ll Specification 3.7.11. On April 29, 1988, Priority 3 Work Request 5368 MNT was written to repair the latch.

1 On July 7, 1988, Station Problem Report (SPR) No. CNPR03510 was initiated by Maintenance Engineering Services (MES) due to the latch bolt on Door S102A not working properly, due to worn internals. The SpR stated that the R.V. Harty Company had gone out of business, and that replacement parts were not available. ,

Possible resolutions provided were to either fabricate new internals, or to L

l replace the door (as well as other R.V. Harty doors in the plant).

l l On November 2, 1988, SPR No. CNPR03830 was initiated to replace Door $102A with Door AX300A, which was the entrance door to the Unit 2 Upper Head Injection (UHI) Building. Work Request 5368 MNT was voided, on November 11, 1988, since Door S102A was to be replaced (however, this replacement was not performed and no repair was done).

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4 On May 25, 1989, Door S102A again failed to latch during the performance of  ;

PT/0/A/4200/48. The door was thought to be operable, due to the operability of 1 4

the CAD mechanism. ,

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On. June 20, 1989, Prior.ity 4 Work Request 1428 MES was written to  !

fabricate / replace the needed parts on Door S102A, .

On Septe:nber 20, 1989, at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, with Units 1 and 2 in Mode 1, Power Operation, a Catawba Safety Review Group staff member en route to the Diesel  ;

Generator Rooms identified Committed Fire Door S102A as being a possibly [

' inadequate fire boundary door. The manual lever actuated latch bolt was found ,

to be broken. The Fire Protection' Console Operator was notified, and a fire r watch was established by Security, pending a Design Engineering (DE) operability '

evaluation.. On September 21, DE determined that the CAD mechanism for this door was inadequate as a-latching device for fire protection purposes. Door S102A was repaired under Work Reg'ue w 142S MES, and the fire watch was subsequently terminated, on October 4.

CONCLUSION This incident is attributed to a design deficiency, due to the selection of a door having a latch bolt mechanism not capable of withstanding the frequent use encountered at the location of Door S102A. This selection was based on an t estimated use frequency which was lower than the actual frequency of use, and '

resulted in the eventual material failure of the latch bolt mechanism. The corrective action for worn internals on the R.V. Harty doors will be to fabricate new internals for each door. This has been successfully performed for Doors S303A, the 'iingle Point A: cess door, and for Door S102A.

This . incident is also attributed to an inadequate policy regarding the Technical Specification operability of CAD operated fire doors with inoperable latch bolts. This policy appeared to be reinforced by a July 27, 1988 memorandum from DE' to MES, which stated that the requirement of closure and latching for two other fire doors had been met because the doors were CAD doors. This memorandum, however, was in reference only to the closure ability of the doors.  ;

This policy was reflected in the Fire Door Inspections procedure, PT/0/A/4400/01H, in which fire door surveillances are performed. This procedure states that if CAD alarm capability is not degraded, that a fire watch need not be established. The latch is known to have been in a failed condition between April 27, 1988 and September 20, 1989, with no fire watch posted, thereby violating Technical Specification 3.7.11.

According to DE, the CAD device does not meet the requirement for a fire door latching device since a fire near the door could damage the CAD circuitry.

De-energization of the CAD mechanism would fail the CAD latch open, as a safety

' feature, rendering it inoperable as a fire barrier. As a corrective action, DE will provide a written policy regarding the role of the CAD device in NRC

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On May 25, 1989, Door S102A again failed to latch during the performance of  ;

PT/0/A/4200/48. The door was thought to be operable, due to the operability of the CAD mechanism. ,

On June 20, 1989, Priority 4 Work Request 1428 MES was written to

-fabricate /repir.ce the needed parts on Door S102A.

6 On September 20, 1989, at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />, with Units 1 and 2 in Mode 1, Power Operation, a Catawba Safety Review Group staff member en route to the Diesel Generator Rooms identified Committed Fire Door S102A as being a possibly

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inadequate fire boundary door. The manual lever actuated latch bolt was found to be broken. The Fire Protection Console Operator was notified, and a fire watch was established by Security, pending a Design Engineering (DE) operability evaluation. On September 21, DE determined that the CAD mechanism'for this door was inadequate as a latching device for fire protection purposes. Door S102A was repaired under Work Requ'est 1428 MES,'and the fire watch was subsequently terminated, on October 4.

CONCLUSION This incident is attributed to a design deficiency, due to the selection of a door having a latch bolt mechanism not capabic of withstanding the frequent use encountered at the location of Door S102A. This selection was based on an estimated use frequency which was lower than the actual frequency of use, and resulted in the eventual material failure of the latch bolt mechanism. The

' corrective action for worn internals on the R.V. Harty doors will be to fabricate new internals for each door. This has been successfully performed for Doors 5303A, the Single Point Access door, and for Door 5102A. -

This incident is also attributed to an inadequate policy regarding the Technical Specification operability of CAD operated fire doors with inoperable latch bolts. This policy appeared to be reinforced by a July 27, 1988 memorandum from DE to MES, which stated that the requirement of closure and latching for two other fire doors had been met because the doors were CAD doors. This memorandum, however, was in reference only to the closure ability of the doors.

This policy was reflected in the Fire Door Inspections procedure, PT/0/A/4400/01H, in which fire door surveillances are performed. This procedure

'j states that if CAD alarm capability is not degraded, that a fire watch need not be established. The latch is known to have been in a failed condition between April 27, 1988 and September 20, 1989, with no fire watch posted, thereby violating Technical Specification 3.7.11.

According to DE, the CAD device does not meet the requirement for a fire door 1atching device since a fire near the door could damage the CAD circuitry.

De-energization of the CAD mechanism would fail the CAD latch open, as a safety feature, rendering it inoperable as a fire barrier. As a corrective action, DE will provide a written policy regarding the role of the CAD device in NRC

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  • e =c %=sr., nn Committed Fire Doors. In addition, PT/0/A/4400/01H will be changed to reflect '

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! this policy. A letter has been sent to Security teams, stating that if a door i

latch is broken, then either a fire watch must be established, or the door must P beLlocked. ,

P Door problems at Catawba are considered to be a recurring problem. A task force

. has been formed to investigate and resolve' door closure problems, including High
. Fadiation doors and fire doors.  ;

L CORRECTIVE ACTION-I SUBSEQUENT ,

E A fire watch was established at Door S102A.

.1) ,

2) Door S102A was repaired under Work Request 1428 MES, and the fire r watch was terminated.
3) MES is in the process of replacing the worn internals of R.V. Harty .

doors.

. 4) A letter was sent to Security teams, stating that when a door latch is broken, either the door must be locked or a fire watch established.

~5) A task force ef Station personnel has been formed to discuss and resolve door problems. L PLANNED.

1) Guidance will be provided regarding the role of the CAD mechanism in satisfying the operability requirements for NRC Committed Fire Doors.

12 l 2) PT/0/A/4400/01H, Fire Door Inspections, will be revised to reflect the determination that the CAD mechanism cannot be used to establish fire o door operability when a latch is inoperable. ,

SAFETY ANALYSIS Although the CAD mechanism was not an acceptable latching device for Door S102A, .

it would have provided immediate notification to Security if the door was open.

If a fire had occurred, the fire detectors in the Battery Room Corridor would

.have sounded, and the Fire Brigade would have responded to extinguish the fire.

In the event that the detectors did not alarm, and the CAD mechanism failed.

Security personnel would have responded to an " illegal unlock" alarm, discovered the fire, and could have secured the door using the key operated dead bolt lock, if desired. The health and safety of the public were not affected by this incident.

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