ML19325F395

LER 89-002-01:on 890228,discovered That Fire Barrier Penetration Inoperable & Action Statement Requirements Not Satisfied.Caused by Inadequate Administrative Controls. Penetration Returned to Operable status.W/891115 Ltr

ML19325F395
Person / Time
Site:	Calvert Cliffs
Issue date:	11/10/1989
From:	Russell L, Sly C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-002, LER-89-2, NUDOCS 8911210052
Download: ML19325F395 (5)

Text

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. BALTIMORE OAWAND ELECTR6C CHARLES CENTER e P.O. BOX 1475

• BALTIMORE. MARYLAND 21203 1475 CALVERT Cliff 4 NUCllAR POWit PLANT DEPAtim(NT CALVEi? Cull $ EfCLt Ah POWth PLANT LubSV. WAF *A#. 70667 i

' November 15, 1089 U.S. Nuclear Regulatory Commission Docket No. 50 318 Document Control Desk. License No. DPR 69 Washington, DC 20555

Dear Sirs:

The attached LER 89-02, Supplement 1, is being sent to you as required by 10 CFR l, 50.73.

Should you have any questions regarding this report, we would be pleased to

[l . discuss them with you. -

,Very truly yours e fu, .

l f h L.Manager-Calvert

. Russell Cliffs Nuclear Power Plant Department I- LBR:CDS:1sr cc: William T. Russell ,

Director, Office of Management Information and Program Control ,

Messrs: C . C . c'C re el l C.H. Cruse l

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.. , ac t m ,, , m .. . . . ,,. . , . . ,, , , ,, ,. .n. . . , n . i L On February 28, 1989 at approximately 0900, it was discovered that Calvert Cliffs l Unit 2 was in an ACTION statement associated with Technical Specification (TS) 3.7.12

" Penetration Fire Barriers". It was later determined that a fire barrier penetration s was inoperable and the ACTION statement requirements were not being satisfied and that the Unit was being operated in a condition prohibited by the plant's TS. At the time ef discovery of the incident the plant was operating at 100% rated thermal power.

The cause of the event has been determined to be inadequate administrative controls to cssure that internal conduit fire seals are maintained intact during maintenance cetivities which affect or could have the potential to affect a fire seal. No adverse safety consequences resulted from this event.

Immediate corrective action was taken to return the penetration to an operable status j by 0920 that same day. This placed the Unit in compliance with TS. To prevent l recurrence a memo has been issued to all site supervisors discussing internal conduit

(. ceals and referencing associated sealing requirements as well as applicable procedures to follow to assure that compliance is maintained. Recently performed fire barrier surveillance tests have confirmed that this does not appear to be a widespread or rect.rring problem at Calvert Cliffs. Walkdowns of fire barriers near high maintenance creas will be perfolned prior to unit restart. Plans are underway to uniquely identify c11 condulet, pullbox, and junction box covers.

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On February 28, 1989 at approximately 0900, it was discovered that Calvert Cliffs i Unit 2 was in the ACTION Statement associated with Technical Specification (TS) )

3.7.12 ' Penetration Fire Barriers", It was also discovered that the appropriate i cctions were not being taken as required by the ACTION Statement. Thus, Calvert 1 Cliffs Unit 2 was not being operated in accordance with its Technical Specifications. At the. time of discovery of the incident the plant was operating I ct 100% rated thermal power.

l The ACTION Statement to TS 3.7.12 lists the actions required in the event that one or more fire barrier penetrations is inoperable. The ACTION Statement requires j l th:t with one or more fire barrier penetrations inoperable, within one hour either; l o Establish a continuous fire watch on at least one side of the j l penetration; or l o Verify the operability of fire detectors on at least one side of the inoperable fire barrier and establish an hourly fire watch patrol; or o Verify the operability of automatic sprinkler systems (including the )

water flow alarm and supervisory system) on both sides of the inoperable  !

fire barrier. l l On February 28, while walking through the plant, Fire Protection personnel noted I th:t an 18" x 18' electrical junction box in the overhead of the Unit 2, 27 foot l c1 vation East Penetration Room was missing its cover plate. Upon further invastigation it was noted that one of the conduits leading to the junction box was v id of any fire retardant material.

l Intornal criteria at Calvert Cliffs specifies that conduits with cable which extend a cinimum of ten feet beyond a fire barrier need not be sealed. On the other hand, ernduits with cable which extend less than ten feet beyond a fire barrier shall be cocled. Acceptable sealing methods include pull box, junction box, and condulet i

esvars or a plug of kaowool in the end of the conduit. Thus, with the 18" x 18" l junction box cover in place, an acceptable sealing mechenism is provided for the cubject conduit, However, with the junction box cover removed and no alternate cccling mechanism in place, such as a plug of kaowool, the open conduit was censidered to be an inoperabin fire barrier penetration. This particular conduit cxtends through the wall and into the adjacent room, which is the 27 foot Switchgear Room.

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01 1 ol3 0' ol4 no&,,.. . e = wnn Purther investigation into the event found that a maintenance request to replaco l the junction box cover had been submitted approximately 7 days earlier. No action had been taken to report the inoperable fire barrier. The personnel who originally discovered the junction box cover were not aware that it was providing a fire I barrier seal. Thus, the subject fire barrier penetration was inoperable for a l period of at least 7 days without performing any one of the three acceptable  !

l actions specified in the ACTION statement. There were no other components or  !

systems which were inoperable that contributed to this event nor were any other components or systems affected by this event. No operator action was required as a result of this event.

l CAUSE OF EVENT l l

The root cause of the event has been determined to be inadequate administrative

! controls to assure that internal conduit fire scala are maintained intact during maintenance activities which affect or could have the potential to affect a fire l barrier.  !

I ANALYSIS OF EVENT 1

This event is considered reportable in accordance with 10CFR50.73 (a)(2)(1)(B),

"Any operation or condition prohibited by the plant's Technical Specifications *.

Contrary to the ACTION statement for TS 3.7.12, a fire barrier penetration was j inoperable for greater than one hour without performance of any one of the three ACTION $tatement options specified.

It has been determined that no adverse safety consequences resulted from this '

event. The following supporting reasons are cited: i o The side of the fire barrier in which the junction box was missing is I protected by an automatic sprinkler system. This type of system is i operable independent of the operability of the fire barrier.

o The room on the opposite side of the fire barrier is protected by an automatic Halon System, This type of suppression system is typically dependent on the integrity of the fire barrier to maintain proper concentration. However, the long conduit run within the room, the conduit's relatively high cable fill, the number of bends in the conduit, and the elevation difference between the conduit opening and the wall penetration would have combined to effectively prevent a loss of Halon.

o The likelihood of a fire starting in the 27 foot East Penetration Room or the 27 foot Switchgear Room during the time period that the fire barrier penetration seal was inoperable was remote. In addition, the likelihood of any fire propagating through the conduit and into the other room is concidered extremely remote.

It is concluded that the potential of the open conduit to compromise the fire barriers effectiveness to prevent the spread of fire from one area to another is minimal.

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CORRECTIVE ACTIONS j 1

Immediate corrective action was taken by the Fire Protection personnel who  !

diccovered the condition to return the fire barrier penetration to an opel able status by stuffing a piece of knowool into the open electrical conduit. This cetion was performed approximately 20 minutes after the adverse condition was l l

discovered. The junction bo:t cover plate was replaced on March 1,1989, j A site wide memorandum was issued to all Nuclear Energy Department Supervisors and l

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neral Supervisors on the subject of Internal Conduit Seals. The meno reiterates 3 l the current site policy regarding internal conduit seals in fire barriers at i C;1 vert Cliffs. The memo also identifies conduit configurations and associated  ;

s ling requirements as well as applicable procedures to follow to assure future  ;

! compliance. Unique configurations shall be handled on a case.by. case basis by a Firo Protection Specialist or a Fire Protection Engineer. ,

i Since LER 89 02, Revision 0 was issued we have performed fire barrier surveillance ,

t sts which include verification that conduit ssal are intact. There were no l situations found while performing the surveillances which were similar to the situation d):cribed in this LER. Therefore, this does not appear to be a widespread or recurring {

pr:blem at Calvert Cliff.. The surveillance tests for Unit 1 and Unit 2 were completed

, on August 25, 1989 and June 29, 1989, respectively. i l

l To casure that the recent high amount of maintenance activity at CCNPP has not affected th) operability of any fire barriers since the last surveillance, we will perform the I surveillance test for Unit 1 and Unit 2 for all high maintenance areas prior to restart ,

cf the applicable Unit.

l-Du) to the high work load at Calvert Cliffs in conjunction with restart efforts, we h va not yet initiated action to uniquely identify pull box, junction box, and condulet ctvors which are considered fire barrier seals. We expect to complete this item s:metime after restart efforts are complete.

l ADDITIONAL INFORMATION l

l Th3re has been one previous similar reportable events at Calvert Cliffs involving in:perable fire barrier penetration seals. Details of this event may be found in LER 50 317/80 20.

Identification of Components referred to in this LER.

IEEE 803 IEEE 805 COMPONENT Ells FUNCT SYSTEM ID Penetration PEN N/A Conduit CND N/A Junction Box JBX N/A Cable CBL N/A csc esa e . .v.s. m. n m.ma,,, w S4h

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