ML20012C486

LER 90-006-00:on 900209,determined That Four Fire Dampers Missing.Caused by Not Identifying Penetrations as Requiring Dampers When Fire Hazards Analysis of Plant Conducted.Hourly Fire Watch Continued.Missing Dampers installed.W/900312 Ltr

ML20012C486
Person / Time
Site:	Calvert Cliffs
Issue date:	03/12/1990
From:	Denton R, Volkoff J BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-006, LER-90-6, NUDOCS 9003220061
Download: ML20012C486 (7)

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BALTIMORE i OAS AND ELECTRIC CHARLES CENTER

• P.O. BOX 1475

• BALTIMORE, MARYLAND 21203 1475 CALVERT CLIFF 8 buttinR POWER PLANT DEPARThitNT

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March 12, 1990 U. S. Nuclear Regulatory Commission Docket No. 50 317 Document Control Desk License No. DPR 53 1 White Flint North Mail Stop P1-137 11555 Rockville Pike Rockville, MD 20850

Dear Sirs:

The attached LER 90 06, Revision 0, is being sent to you as required under 10 CFR 50.73 guidelines.

Should you have any questions regarding this report, we would be pleased to discuss them with you.

Very truly yours, f(WW A

R. E. Denton Manager JV/sdw cc: William T. Russell Director, Office of Management Information and Program Control Messrs: G. C. Creel C.11. Cruse J. R. Lemons L. B. Russell R. P. Heibel 9003220061 900312 PDR ADOCK 05000317

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On February 9, 1990, while performing an inspection of Technical Specification (TS) ventilation duct fire barrier dampets, it was determined that four fire dampers were missing. Both units were shutdown at the time of discovery.

The cause of the event is that the penetrations were not identified as requiring dampers when the Fire Hazards Analysis of the plant was conducted.

The safety significance of the missing dampers is low based on other available fire safety features.

Fire detection and automatic sprinkler system operability were verified and an hourly ,

fire watch has continued. A Facility Change Request has been initiated to install the missing dampers. All TS ventilation duct fire barrier dampers have been identified and inspected. The Surveillance Test Procedure used for inspecting ventilation duct fire barrier dampers will be rewritten to specify the fire dampers to be inspected. The Fire Protection / Appendix R Design Basis reconstitution is an ongoing long term effort to verify the Fire Hazards Analysis and other fire protection documents.

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1. DESCRIPTION OF EVENT At 1445, on February 9, 1990, while performing an inspection of Technical i Specification (TS) ventilation duct fire barrier dampers, it was verified that four fire dampers were missing in the supply and exhaust ducts for the Battery Room Ventilation Systems. At the time, Calvert Cliffs Unit I was in Mode 5 (Cold Shutdown) at a temperature of 130 degrees F and a pressure of 150 psia. Unit 2 was _defueled. The Shift Supervisor was immediately notified and TS Action Statement 3.7.12.a was entered. *:quivalent compensatory actions had already been performed as a conservative measure. As required by the Action Statement, the operability of the automatic sprinkler systen in Cable Chases 1A and 1B were verified and thernfore, no fira watch was neesssary. There is no automatic sprinkler in the Cable Spreading Room but there is a smoke detector. As a result, an hourly fire watch tour was initiated in the Cable Spreading Room.

The first step in the TS ventilation duct fire barrier damper inspection was to identify *he location of each such fire damper on Calvert Cliffs mechanical prints. This inspection was part of the Fire Protection / Appendix R Design Basis reconstitution effort. Four of the ventilation duct locations requiring fire dampers were in two walls. One wall was between the Unit 1 Cable Spreading Room and Cable Chase IB. The other wall separated the IB and 1A Cable Chases. The second step of the inspection was to physically verify the existence and-operability of the damper locations identified on the prints. The internal areas of the ducts in which these four dampers should have been installed were not accessible.

On December 8, 1989 it was determined that inspection holes were not available to inspect the four dampers. A compensatory action statement was entered equal to tha one in the TS 3.7.12.a until the inspection holes were completed. This actfon was taken as a conservative measure until che existence and operability of the dampers could be verified. On February 9, 1990, inspection holes were completed allowing visual examination of the inside of the ventilation ducts. It was then disecvered that the four dampers were missing.

11. f.AUSE OF EVENT The root cause of this event is that when the Fire Hazards Analysis of the plant was conducted, these four ventilation Cire duct barriers were not identified as requiring fire dampers.

On December 21, 1979, we provided information to the NRC concerning Calvert Cliffs' compliance with Appendix A to Branch Technical Position APCSB 9.5 1. In our submittal we stated that the Cable Spreading Room and associated chases were enclosed by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire be.criera. The research done to veri #y that the

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A review of fire protection documentation did not reveal the reason that the j requirement for these four dampers was not identified in the Fire Hazards l Analysis. The personnel performing the Surveillance Test Procedure (STP) for  !

inspecting the dampers did not identify the fact that the dampers were missing because the ducts had not been identified as requiring dampers and there was no I access to the inside of the ducts. '

III, tR LYSIS.OF EVENT A fire damper is typically installed in a ventilation duct where the duct penetrates the rated fire barrier. The damper is normally open to allow ventilation air flow, and will close in the event of a fire. In most dampers at Cnivert Cliffs, a fusible link keeps the damper open and will separate when expoced to the high temperatures of a fire, allowing the damper to close.

The supply and exhaust ducts for the Battery Room Ventilation Systems penetrate '

tue wc11 between the Unit 1 Cable Spreading hoom 16to Cable Chase 1B. The ducts then penetrate the wall between the IB Cable Chase and the 1A Cable Chase. There are no fire dampers in the sentilation ducts. The fire barriers aro 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated TS barriers.

This event is reportable under 10 CFR 50.73(a)(2)(1)(B) because it represents a condition prohibited by the plants' Technical Specifications.

l TS 3.7.12 states that, "All fire barrier penetrations (i.e., cable penetration l'

barriers, fire doors and fire dampers), in fire zone boundarier, shall be OPERABLE." The fire dampers in this case were not OPERABLE because they were missing.

TS 4.7.12 requires that each of the fire dampers covered by TS 3.7.12 be

, verified OPERABLE at least once per 18 months by visual observation. In this case the fire dampers were not verified operable because they had not been previously identified or made accessible.

Mitigating circumstances in this case include.

- There are no duct openings in any of the rooms addressed in this report.

Thus the duct would have had to fail on both sides of the barrier for heat and/or smoke to pass from one fire area to the other.

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- The rooms involved all have suppression systems installed. The 1A and 1B Cable Chases have automatic sprinklers. The Unit 1 Cable Spreading Room has a total flooding Halon System. These systems would commence operating prior to a fire threatening the barrier.

- All three rooms have smoke detection capability. This early notification of a fire allows manual fire fighting activities to begin during the early stages of fire.

- The primary combustible material in all 3 rooms is cable insulation. The cable insulation at Calvert Cliffs was chosen for its fire resistant properties.

Any one of the above mitigating factors provides reasonable assurance that the potential for smoke and/or fire propagation through the ductwork was very small.

Thus, the safety significance of the missing dampers was low.

IV. CORRECTIVE ACTION

1. Upon suspecting that the dampers were missing, compensatory actions equal to l

Action Statement 3.7.12.a were performed until the ducts could be visually

! inspected. Fire detection and automatic sprinkler system operability were l verified, and the hourly fire watch patrol was established. When it was determined that the dampers were missing, Action Statement 3.7.12.a vas entered. Fire detection and automatic sprinkler system operability were again verified and the hourly fire watch has continued.

3 . 2. A Facility Chan6e Request has been initiated to install the missing fire dampers.

3. Plant drawings have been reviewed to identify ventilation ducts requiring

, fire dampers. All of the dampers have been inspected. The fire dampers are l all accessible and inspected as part of our STP program.

4. A new STP will be written that will specify the location of each TS ventilation duct fire barrier damper including the four fire dampers found missing.

l S. The Fire Protection / Appendix R Design Basis reconstitution is an ongoing long-term effort to verify the Fire llazards Analysis and other fire protection documents.

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varu - . we % ,. mon V. ADDITIONAL INFDRMATION A. Previous Similar Event l

A similar event was documented in LER 317 89-011 " Missing Fire Protection Damper." The missing damper in that LER was identified as part of the same TS fire barrier review that identified the missing dampers in this LER.

A related event was documented in LER 317 89 025 " Technical Specification Violation Missed Fire Watch Tour Due to Personnel Error." On December 11, 1989, the hourly fire watch tour was missed at midnight. The fire watch was part of the compensatory Action Statement entered based on suspicion that four of the dampers in the Battery Room Ventilation System were missing.

B. Affected Component Identifiention IEEE 805 IEEE 803 Component System ID Component Fire Damper VF BDMP Battery Room Ventilation System VF VF Automatic Sprinkler KP SRNK ,

Smoke Detector IC DET Halon System KQ N/A N.C t.an se6A (6491

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