ML20012E010

LER 90-009-00:on 900224,failure to Meet Action Requirement Re Tech Spec 3.7.12.Caused by Personnel Error.Cables Removed from Doorway in Charging Pump Room & Not Allowed to Be Placed in doorway.W/900326 Ltr

ML20012E010
Person / Time
Site:	Calvert Cliffs
Issue date:	03/26/1990
From:	Denton R, Milbradt M BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-009, LER-90-9, NUDOCS 9003290211
Download: ML20012E010 (6)

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. SALTIMORE

'M OAS AND ELECTRIC 6

CHARLES CENTER e P.O.- BOX 1475 e BALTIMORE, MARYLAND 21203 1475 CALVERT CLIFF 8 NUCtLAR POWER PLANT DEPARTRIENT

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. March.26, 1990

'U./S. Nuclear Regulatory Commission Docket No. 50 317.

Document Control Desk License No. DPR'53 Washington, D. C. 20555

Dear Sirs:

The' attached LER 90 09, 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, yours, f(E.Denton R.

Manager MDM/1rr cc: William T. Russell Director, Office of Management Information and Program Control Messrs: -G..C. Creel C. H. Cruse J. R. immons L. B. Russell R. P. Heibel

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On February 24, 1990, at approximately 0700, and again on March 9, 1990, at approximately 0200, it was discovered that Calvert Cliffs Unit 1 failed to meet an ACTION requirement associated with Technical Specification (TS) 3.7.12 " Penetration Fire Barriers". At the time of discovery in both cases, Unit I was shutdown in l

MODE 5, with a reactor coolant temperature of 130 degrees Fahrenheit. )

1 The cause of the events-has been determined to be personnel errors. In both cases personnel blocked open fire doors that are normally open and are held open by fusible link closure devices. No adverse safety consequences resulted from this event.

Immediate corrective action was taken to restore both doors to OPERABLE status.

This placed the Unit in compliance with the TSs. To prevent recurrence of these events, safety meetings were held with personnel to discuss the events.

Additionally, the placards identifying the doors will be re-written and placed in locations that will clearly indicate how the doors work.

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On February 24, 1990, at approximately 0700, and again on March 9, 1990, at approximately 0200, it was discovered that Calvert Cliffs Unit 1 failed to meet an ACTION requirement associated with Technical Specification (TS) 3.7.12 " Penetration Fire Barriers". Specifically,- firc doors in #11 and

1. 12 Charging Pump rooms were blocked open, mak'.ng them inoperable. At the time of discovery in _ both cases, Unit 1 was shutdown in MODE 5, with- a

-reactor coolant temperature of 130 degrees Fahrenheit.

The ACTION requirement in TS 3.7.12 lists the actions required in the event that one or more fire barrier penetrations become inoperable. The ACTION requirement states that within one hour either:

1. Establish a continuous fire watch on at least one side of the penetration; or-

2. Verify the operability of fire detectors on at least one side of the inoperable fire barrier and establish an hourly fire watch patrol; or Verify the operability of automatic sprinkler systems (including the' 3.

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

inoperable fire barrier.

TS Fire Door 115-12 L On February 24, a Fire and Safety Technician (FAST) found electrical 1 l- cables on the floor running through the doorway to #12 Charging Pump room.

The cables were used in support of maintenance performed on #12 Charging Pump. The door to the room. #115 12, is a TS fire door and is normally )

held open. Under normal conditions, if a fire were to occur, a fusible '

link in the door closure would nelt allowing the door to ,close -l automatically. The placement of cables in the doorway would not have allowed the door to shut completely thus creating the inoperable fire l barrier. l l

l' l Upon diocovering the cables, the Fire Protection Technician ordered the l i immediate removal of the cables until an approved Fire Barrier /Stop  ;

l Removal Request was obtained. Once the approved request was in place, a l continuous Fire Watch was posted while the door was inoperable, as required by Technical Specifications.

1 Further investigation into the event determined the cables had been in place at least 3 days prior to the discovery date. Thus, the subject fire  !

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barrier was inoperable for a period of at least 3 days without meeting any of the TS ACTION requirements. There were no other components or systems which were inoperable that contributed to this event nor vere any other . l components or systems affected. No operator action was required. I TS Fire Door 115-11 I

On March 9, 1990, a Fire and Safety Technician (FAST) found the TS fire. I door (115-11) to #11 Charging Pump room taped open. The door was taped to scaffolding being erected by contractor personnel near the doorway. This ,

door is of the same design as the door in #12 Charging Pump room and is normally open. By taping the door open, it would not have closed-immediately once the fus Ale link melted in the event a fire occurred.

After discovering the problem, the Technician immediately removed the tape and verified the operability of the door. The Technician also called the Shift Supervisor on duty and informed him of the event.

Investigation of this event revealed the door was taped open and inoperable for no longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The scaffolding was erected in one day and at some point an unidentified individual taped the door to- the scaffolding. The problem was discovered that same day. There were no other components or-systems which were inoperable that contributed to this event nor were any other corponents or systems affected. No operator action was required.

II. CAUSE OF EVENT The root cause of both events has been determined to be personnel error.

In both cases, personnel failed to obtain permits that would have allowed the impairment of each door. The contractor personnel involved in the first event were aware of the purpose and importance of maintaining fire doors operable, for fire doors in general. But due to the unconventionality of these doors (normally open, but closed during a fire) they did not realize the cables on the floor would impact the operability of a door that was normally open.

Contributing to the personnel error was a weakness in the training program. The proper use of fire doors is stressed during Calvert Cliffs General Orientation Training (GOT) but the doors with fusible link closure devices are not specifically addressed.

Additionally, a placard on the outside wall next to each door states the doors are Technical Specification doors and should not be held or blocked open. The personnel involved were confused by the placard since the door was already held open by the fusible link closure mechanism.

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von n , a .asm.w me n , a.aw nn III. ANALYSIS OF EVDIT These events _ are 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 requirements for TS 3.7.12, the fire barrier penetrations were-inoperable for greater than one hour without performance of any of the three ACTION requirement options as stated above.

Both events involved fire doors with fusible link closure devices, involving personnel who ' were not familiar with that type of door, an6 occurred within 13 days of each other. Since both events are related, with a similar cause, they are both being reported under the same LER.

It has been determined that no adverse safety consequences resulted from these events. During_ the periods in which each door was considered l

l inoperable, an operable automatic sprinkler system was in place . covering

.both sides of each fire barrier. Although the system was not verified OPERABLE during each period, as required by the ACTION requirements, the surveillance that verifies the system's operability was up to date. It is concluded that the potential of the inoperable fire doors to compromise plant safety, with the sprinkler system in place, is minimal.

IV. CORRECTIVE ACTIONS Immediate corrective action to make both fire doors OPERABLE was initiated upon discovery of each event. On February 24, 1990, the cables were-removed from the doorway in #12 Charging Pump room and were not allowed to be placed in the doorway until a Fire Barrier /Stop Removal Request was in I place. On March 9, 1990, the tape found on door 115-11 in #11 Charging Pump room was imesediately removed upon discovery.

The following additional corrective actions have been or will be initiated to prevent similar events from occurring in the future:

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1. Safety meetings were held with the contractor personnel to discuss these events and to stress the importance of ensuring fire barriers are maintained properly.

2. The placard on the wall outside of each Charging Pump room is being changed to indicate the doors are of a different type. The current placard warns personnel the doors should not be held or blocked open. The new placard will be more explicit and state the doors have auto-release mechanisms and their closure path should not be

,. blocked. Additionally, the placards will be placed in locations l that clearly identify and alert personnel of the special doors.

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i V. ADDITIONAL INFDRMATION I 1

There have been no previous similar events at Calvert Cliffs involving the blocking open of fire doors with fusible link closure devices resulting in Technical Specification violations. l IEEE 803 IEEE'805 COMPONENT EIIS FUNCT SYSTEM ID Fire Door DR NA

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