ML20012D028

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LER 90-002-00:on 900216,determined That Fire Dampers May Not Be Operable Under Expected Ventilation Flow Conditions Due to Design Error.Caused by Failure of Original Design Criteria to Address Need.Documentation updated.W/900319 Ltr
ML20012D028
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/19/1990
From: Boldt G, Moffatt L
FLORIDA POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0390-14, 3F390-14, LER-90-002, LER-90-2, NUDOCS 9003260333
Download: ML20012D028 (6)


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March 19, 1990 3F0390-14 U. S. Nuclear Regulatory Commission

l. Attention: Document Control Desk l Washington, D. C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72  ;

Licensee Event Report No. 90-02

Dear Sir:

Enclosed is Licensee Event Report (LER) 90-02 which is submitted in accordance with 10-CFR 50.73.

!.aould there be any questions, please contact this office.

Sincerely, G. Boldt ,

Vice President, Nuclear Production '

WLR: mag Enclosure xc: Regional Administrator, Region II '

Senior Resident Inspector 9003260333 900319

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POST OFFICE BOX 219

  • CRYSTAL RIVER, Fl.ORIDA 32629 0219 * (904) 563-2943 A Florida Progress Company

NRC FORs 306 U.S. NUCL eel REOULATOAV COMMISSION APPROVED OMS NO.31600104

. EMPIRE 5 4/30/92 e ESTIMATED b'JRDEN PER FIESPONSE TO COMPLY WTH THIS LICENSEE EVENT REPORT (LER) E'8MEWe'UJR'DEo'fuRDE8Es'T?dA'TE"5"*HE RECE>S

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FIRE DAMPERS MAY NOT CLOSE UNDER VENTILLATION FLOW CONDITIONS DUE TO FAILURE TO CONSIDER FLOW CONDITIONS IN ORIGINAL DESIGN CRITERIA PER NRC IEN 89-52 EVENT DATE ($1 LE R NUMutR (Si REPORT DATE (7) OTHER F ACILITIES INVOLVED ISI SE O eAL f ACILIT V N AMES MONTH DAY YEAR vtAR g p ss, MONTH DAv YEAR DOCKE T NUM9ERISI N/A 0l51010]0l l l

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ARE A CODE L. W. Moffatt Nuclear Safety Supervisor 9l0l4 7l9l5l-l6l4 6 16 COMPLETE ONE LINE FOR E ACH COMPONENT F AILURE DESCRISED IN THl3 REPORT (131 CAUSE System MA AC REPORiA Lt MA AC- P T E COMPON E NT pn g C AUSE SYSTEM COMPONENT O PR B Kl P Dl MI P l Al h 2l4 NO l l l l l [ t I l l I i l l I l l l l l l f $UPPLEMENTAL REPORT E XPECTED (14) MONTH Day YEAR SU8 MIS $10N sxPrcrro suswssiO= o4Tri

Tl vEs tie , . < -l NO 12 11 5 91 0 AeswC, u ~, w uoo -c., . . . .oore. ,.wwr .ra a ,,v. ac. nP..r.n. i.e.,> v s, 1 On February 16,1990, at 1132, Crystal River Unit tree determined that fire dampers may not be operable urder expected ventilation flw con
11tions due to a design error. Eis conclusion was based on the results of testing and evaluation of plant fire dampers and ventilation flws performed as a result of Information Notice 89-52. Roving fire watch patrol routes were reviewed and I. revised to assure 100 percent coverage of the fire areas. Continuous fire I watches were posted in areas where fire detectors were inoperable. The root cause of this event is the failure of the original design criteria to address l the need to close the dampers under ventilation flow conditions. Eis I

condition had been identified in 1985 by an internal contractor evaluation but, due to p r ennel error, had not been pursued and resolved. Ehmpers which are installed in locations with excessive ventilation fl ws will be modified to l assure closure. Design basis documents will be updated to reflect the need for fire dampers to close under ventilation flow conditions.

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l NRC Form 364 (6-89i

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On February 16,1990, at 1132, Crystal River Unit 'Ihree (CR-3) determined that fire dagers [KP, EMP] may not be operable under expected ventilation flow conditions due to a design error. Several curtain-type fire day may not fully close with ventilation air flow.

On August 30, 1989, Florida Power (FPC) evaluated NRC Information Notice 89-52,

" Potential Fire Dampn Operational Problems" and determined the concerns identified by this notice may apply to CR-3. On November 10, 1989, FPC cmpleted a review of damper flow rates and identified a representative sample of sirgle section dampers corresponding to approximately 10% of the dampers to drop test under actual flow conditions. On January 26, 1990, CR-3 began drop testing the selected dag ers.

On February 6, 1990, when three out of five dampers tested failed, an action plan was developed and a Nonconforming Operations Report was initiated. At this time, CR-3 was in } ODE 1(IOWER OPERATION), 97% power. 'Ihe action plan included:

1. Perform a root cause evaluation of the fire damper failures, ii. Assure the hourly fire watch patrol route included all areas associated with the Technical Specification required fire dampers.

iii. Assure a continuous fire watch is posted in areas with inoperable fire detectors [IC,28].

iv. Begin repair of the failed fire dampers.

v. Continue testing the selected dampers.

At 1132, on February 16, 1990, the root cause evaluation concluded the damper failures were caused by design deficiency. At the time, CR-3 was in MODE 5(00LD S1K7fDOWN) with Reactor Coolant System temperature 95 degrees and at atmospheric pressure. CR-3 had been shutdown since February 12 to repair RCV-8, Pressurizer Code Safety / Relief valve [AB,RV). At 1235, the NRC Operations Center was notified of this event per 10CFR50.72(a)(2)(1) . 'Ihis written report is being made per the requirements of 10CFR50.73(a)(2)(ii)(B) for operation outside the plant design basis.

CAIEE:

'Ihe root cause of this event is the failure of the original plant design to consider the need to close the dampers urrier ventilation flow conditions. At the time the plant was designed, this was the standard practice since closure urxler air flow is not required by the NFPA code. 'Ihe fire dampers are designed with several interlockiry slats which are retracted in a configuration similar to a raised venetian blind. 'Ihe fire dampers are actuated by fusible links. When the damper is released, the damper is pulled into position by retractirg springs and may be assisted by gravity. As the damper attempts to close, the increasing air velocity induced pressurn can lock up the dampers and NIC Form 386A (649)

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Op 0l3 of 0 l5 TEKT M more apose 4 #eviast .,ar oslis.wi./ 48 C Aem W 'er (176 prevent them frun fully closity. For same damers, this my cause the closity sprirg to break.

In June 1985, durity an DASCO cvaluation of CR-3 fire protection featums contracted by MC, the nood to verify the ability of damers, ocpocially multi-se: tion danpers, to closo urder ventilation flow corditions was identifio.l. A sumary of exinun noooptable velocitics through Air Ihlance type 319 fire damers was providcd by the contractor. As a result of the D%S00 firdirg, a study was perfomod to actemino the ability of multi-soction danpers to close. M11s study concluded several danpers should havo the larger 9 pourd sprirgs. Additionally, ono ntlti-section danper required modifications to automatically trip the ventilation fans to ensure the danper would closo.

Duo to MC enginocrity personnel error, the recuss.Sations in tho study woro not pursued. 'Ihis was a violation of cryinocrity prtoedams khich were in offoct at the time of the attdy.

'Iho fitu danpers affectcd are various sizes ard nanufacturtd by Air Iblanco, Inc. , }bdol Hos. N319ALV (vertical) ard N319AUI (horizontal), throo hour Ulr rated.

LYLNP INA11RTICH:

Um purpose of those fire danpers is to help assure a fire is limited to a sirglo area. By limitiry the spread of the fitu ard by protectify ocrtain trains of equipment, availability of altermto equi nent t locatcd in adjacent areas, which my be nooded for safe shutdwn, is assured.

1ho design error affects less than ten of approximately 120 total fire dampers.

Several danper designa includo an automatic trip of the associated operatiry fans. Mat of the dampers tested to dato satisfactorily completed the closure test ur&:r ventilation flow corditions. 1ho dampers khich have failed are those installed in areas khcru the ventilation ficw is very largo. Attachod is a list of the danpers affocted, their location ard a general doncription of the areas prutocttd by the danpor. Miin IIR will be supplemented to include additional norconfomiry danpers, if nocessary.

Sinoo 1985, CR-3 has maintained an hourly rovirg fire watch. 'Iho roviry fire watch is required to walk an established routo each hour ard observo for fires.

If a fire is observed, the watch reports the firu immediately ard extirguishes tho fire if pocsible. Dio route (s) establishcd sinco 1985 cover approximtoly 90 percent of the plant fire areas. In addition, the operability of fire detectors on at least one side of each fire barrier has bocn mintained ard monitored.

Considerirg the safety aspects derived from the rovity fire watch, existiry fire detection ard suppression systems is the areas of concern, the failure of somo danpers to close urder flow cordition.s oocs not creato urdue risk to the safety of the public.

N.iC ,em 3m6A (6491

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Each fire danpcr flw rate has bocn ccrpared to test data khich raflects the maxinum f1w rate urder khich the danper will successfully close. ITC is continuirg to inspect sirgle ard multi-section danpers to verify sprirg ocrifiguration. Darpers, incluilty those identified by the 1985 study, which fail the flow rate criteria or need new or larger sprirgs, will be modified to assure closure urder air f1w corditions.

Design basis documents will be updated to reflect the nood for fire dampers to cloce under ventilatien flw conditions.

Since 1985, several prtcodural and organizational charges have occurred khich should prevent recurrence of the personnel error associated with the 1985 Innper Study. 'Ihese charges incitdo strergthenirg enginocrire procedures by addity requirements for management review ard apprwal of studies, improvirg and proceduralizirg erginocrirg prob 1cm reportirg, ard establishirg a Design Basis Engineerirg Group.

IREVIOLE SIMIIAR EVIWISt

'Ihere have been three prior events related to fire danpers. 'No of these events were related to design errors. 'Ihis is the first event involving a design failure conocrnirg danper closure strder ventilation f1w corditions.

NRC Feen 3e6A (6896

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FD-239 mis Itulti-section dager is lccated in the floor of the 164 elevation of the Control Omplex (IM). Wey separate the Vontilation Equipment Ro:xn (CC-164-121A) frun the Main control Roam (CC-134-118B) . In the event of a fire that spreads betwoon those areas, control of safe shutdown equipment will be transferred to the Renote Shutdown Panol.

ard the dodicated contrul Canplex HVAC will be used. 20 dodicated HVAC should not be affectal by a fire in this area.

FD-266 Wis damer is located in the floor of the 119 elevation of the Auxiliary Bailding (IE). It separates the Reactor Coolant Purp Seal Injection Filter Roam (AB-95-3Y) from the 119 elevation llallway (AB-119-6Q) . A fire could affect the safe shutdown equipment on the 95 elevation and then move upwartl through this danper to the 119 clevation. Should a design basis fire spread to both of theco aruas, then Docay lloat (BP) and liuclear Servloo Closed Cycle Cooling Water (CC) systems my not be available for shutdown.

IT)-271 Wis danpar is located in the floor of the 119 elevation of the Auxiliary Building (IE) . It separates the Miscellaneous Radioactive Waste Roms (AB-95-31<) frun the 119 clevation Central llallway (AB-119-6J). Should a design basis fire spread to both of these areas, then Ihkoup Injection (DG) and Docay lleat (BP) systems my not be available for shutdown.

PD-273 mis danper is located in floor of the 119 elevation of the Auxiliary Duilding (IE). It separatos the 119 elevation Central llallway (AB-119-GT) frun the 95 elevation Central llallway (AB-95-3G) . Should a design basis fire spread to both of these areas, then lukeup Injoction and Docay Heat systems may not be available for shutdcun.

11)-278 mis danpor is located in the wall between the Intemodiate ard Auxiliary (!E) Buildings on the 95 elevation. Wis danper separates the 95 elevation 11 orth llallway,11uclear Sanple Room (AB-95-3B) frun the Intemcdiate Duilding Penetration and Fan area (ID-95-200C) . Should a design basis fire spread to both of these areas, at least one train of safe shutdown equipnent will still be available.

  • Evaluation is based on the Crystal River Unit 'Hu oo, Updated Firo llazartis Analysis, Revision 2,11ovember 1989.

NRC .enn 3tSA 16491