ML20042G917

LER 90-005-00:on 900410,control Bldg/Auxiliary Bldg Pressure Boundary Door Found Open W/O Continuous Watch Established. Caused by Inadequate Procedures.Fire Protection Impairment Control Procedure revised.W/900510 Ltr

ML20042G917
Person / Time
Site:	Wolf Creek
Issue date:	05/10/1990
From:	Bailey J, Mike Williams WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-005, LER-90-5, NO-90-0147, NO-90-147, NUDOCS 9005160281
Download: ML20042G917 (7)

Text

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l May 10, 1990 NO 90 0147 U. S. Nuclear Regulatory Conmission ATTN Document Control Desk '

Mail Station P1-157 Vanhington, D. C. 20555 Subject Docket No. 50-482: Licensee Event Report 90-005-00 Gentlemen The attached Licensee Event Report (LER) is being submitted pursuant to ,

10 CFR 50.75 (a) (2) (i) _ as a Technical Specification violation and 10 CFR 50.75 (a) (2) (ii) a condition that was outside the design basis of the plant. >

Very truly yours,

% O . A4-John A. Bailey ,'

t Vice President Nuclear Operations .

JAB /jra j Attachment L cc R. D. Martin (NRC), w/a l D. Persinko (NRC), w/a .

l D. V. Pickett (NRC), w/a M. E. Skow (NRC), w/a f

9005160281 T OM,10 FDR ADOCL 096694g;.

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"'' Improper Control 01 Pressure Boundary Doors Caused by Inadequate Procedures Adversely Ef f ects Control Room Energency Ventilation System Operability iVINT DAf t ill L t R NUMDt R .66 htPORT DAf t 17f OTHt M f ACILffit$ INVOLVf D 103 ,

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Ch April 10, 1990, at approximately 1100 CDr, a Control Building /Ataillary Building pressure boundary door uns found by Control Rom operators to be open without a continuous watch having been established. Subsequent evaluatim on April 13, 1990, concluded that the April 10 event as well as a ,

similar event discovered on March 28, 1990, potentially adversely effected Control Rom Bnergency Ventilation System q=vvihility. 'lhis evaluation also concluded that additional events of this nature may have occurred previously during refueling outages.

Subsequent review has detemined that the root cause of these events is inadequate g M ures which resulted in irg vrir control of pressure boundary doors during refueling outages. To prevent recurrence, the Fire Protection inipairment control gdure has been revised to ensure that Control Rom operators are notified prior to establishing a fire inraimant control pemit for any pressure boundary doors.

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nmunn'um On April 10, 1990, at approximately 1100 CDI', a Control Building

[NA)/ Auxiliary Building [NP) prossure boundary door (NA/NF-DR) was found by Control Rom operators to be open without a omtinuous watch having been established. Subsequent evaluation on April 13, 1990, concluded that this condition potentially adversely effected Control Hom anargency Ventilation Systen (CREYS) [VI) q=mb(14ty. Additionally, on April 13, 1990, it was concluded that a similar event had occurred on March 28, 1990, when a ,

Control Building pressure boundary door (NA-DR) was found open. '1his evaluation also ocncluded that additional events of this nature may have-  ;

occurred previously during refueling outages. 1 1

I E E RIPfE M CF M BRIS  !

l On March 28, 1990, at approximately 0700 CST, a Control Room operator )

discovered that Door 32201, the door between access control and the  ;

comunications corridor, was blocked open in support of work activities '

being perfomed. A fire 4n_ r=4mant control permit had been issued for Door 32201 on March 27, 1990, at approximately 1800 CST which established an hourly fire watch (aawyciate for fire protection considerations) while the door was blocked open. Control Room operators verified that Door 32201 is a i

Control Building pressure boundary door. At the time of this discovery, the plant was in a refueling outags with the core off-lNkwi. CREVS Train 'B' was operating in the recirculation mode while CREVS Train 'A' was inoperable for maintenance.

Following this discovery, Control Rom operators revoked the fire inrmimant control permit at 0718 CST and closed Door 32201 thus restoring the Control Building pressure boundary. Control Rom operators verified that no core alterations had buen parfonned while Door 32201 was open, thus ensuring that operating guidance had been satisfied.

Initial evaluation determined that this event may not have affected CREVS operability since previous tests had shown that the Technical Specification (T/S) Control Room pressurization requirunents could be met with certain Control Building pressure boundary doors blocked open. It was determined that a pressure test would have to be perfonned with Ibor 32201 open to- '

can:1usively prove or disprtne CREVS operability in this configuration.

Disc.ussions were initiated with various personnel to detemine the feasibility of performing this pressure test during the ongoing refueling outage. I_= adiato performance of this pressure test was not feasible. -

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010 Oi3 Of 0l 6 ms a m. u,u. n o.em u eso< r wrc r n mawm Ori April 10, 1990, at apprendmately 1100 CDr, a Control Room operator discovered that Door 15011, the door between the Atwiliary Building and the

, Control Building Train 'B' Heating, Ventilation, and Air Conditioning System (HVAC) (VI) Equipnent Rom, was blocked open. A fire inraimant control permit had been issued for Door 15011 on April 5, 1990, at approxinately 1545 CDr which established an hourly fire watch (apsvriate for fire  ;

protection considerations) while the door was blocked open. Control Rom operators verified that Door 15011 is a Control Building / Auxiliary Building pressure boundary door. At the time of this discovery, the plant was in Mode 6, Refueling, with oore alterations in progress. CREVS Train 'A' was operating in the recirculation mode while CREVS Train 'B' was irgarable.

Following this discovery, control Roam operators determined that Door 15011 ,

had been blocked open in conjunctico with a tanporary nodification. It  ;

appeared that with the tanmrary modification installed, in==wiiate restoration of the Control Building /Amiliary Building pressure boundary  ;

could not be accanplished as required by the administrative guidance. )

'Iherefore, at approximately 1235 CDP, Control Rom operators susp ded all -

core alterations as required by T/S. Control Room operators then initiated the restoration of the +aamrary modification, including closure of the door prior to resundng core alterations.

Because the Control Building pressure boundary doors are also marked as fire doors and therefore would require a fire inr=4mant control permit prior to blocking it open, Control Rom operators reviewed all outstanding permits to ,

ensure operators were aware of any other pressure boundary docirs tut are

• inpaired. Control Rom operators verified that imediate restoration of the '

pressure boundary in accordance with the administrative guidance could be acconplished should plant conditions regaire such action.

BASIS IM RERRmBIIJ'IY -

'Ihe CPJNS provides the Control Rom with a conditicned atnosphere following various design basis accidents (DBAs) such as loss of coolant accident (IOCA), fuel handling accident, rod ejection, main stmmline break and steam generator tube rupture. 'Ihe CREVS ensures that the ambient air tenperature does not exceed the allowable ta==rature for crntinuous-duty rating for the equipvent and instrumentation cooled by CREVS and the Control Room will reain habitable for Operations perennel during and-follcwing all credible accident conditicos. During the emergency made of oparation, the Control  :

Roca is maintained at a positive pressure of greater than or equal to .25 inch water gauge relative to the outside atmosphere to prevent infiltration i

from surrounding areas of unfiltered air. 1 N1C f orm 3esA (649) ,

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1. 1CILITV hAME tu DOCKf t NUMtta L28 Lth NUMSER IS) PAGE (31 vtan M %Q,'b ,N Wolf Creek Generating Station o l6 l0 l0 l0 l4 l 8l 2 9l0 0 l 0l 5 0l0 0l4 or 0 l6 i rsn a wee e ,-,< ,, no,s.awc r= saw nn

'Ihe CREVS consists of two separate and redundant trains which recirculate 1 i the Ccutrol Room air. 'Ihe CREVS Initiates filtered ventilation of the

! Control Rom following receipt of an actuation signal. 'Ihe CREVS design basis is established by the consequences of the limiting DBA which is a IICA 1 in Mode 1, Power Operation, through Mode 4, Hot Shutdown, and a fuel I handling accident in Modes 5 and 6. 'Ihe IICA analysis assumec that only one train of the CREVS is functional due to a sirgle failure which disables the other train. 'Ihe design basis is also established by the potential chlorine gas sources which would have the potential for incapacitating per m unal in l the Control Rom if mitigating actions were not taken. ,

Wolf Creek T/S 3.7.6, which is applicable in all nodes, requires two ,

Jndependent CREVS trains to be operable. For Mode 5, Cold shutdown, and l Node 6, Refueling, with me CREVS train inoperable, T/S 3.7.6 action statement 'a' requires restoring the ineparable CREVS train to rparable r status within 7 days or initiating and maintaining operation of the renaining rpamble CREVS train in the recirculation node. With both CREVS trains ineyarable in Modes 5 and 6, T/S 3.7.6 acticn statement 'b' requires suspending all operations involving core alterations or positive reactivity changes.

Administrative guidance initially provided to Cantrol Rom operators on January 12, 1989, requires that with pressure boundary doors blocked open, a person nust be assigned to the door as a continuous watch utder the direction of the Control Rom and nust be dedicated to closing the door when directed by Control Rom persconel to enable iWiate restoration of the -

boundary. 'Ihe administrative guidance indicates that any work activities requiring a pressure boundary to be branched that cannot meet the continuous watch and innaliate restoration restrictions nust be performed in Mode 5 or i Mode 6 and empliance with aa u.vpriate T/S action statanents nust be i ensured. During each of these events, the. Control Rocm operators were l unaware that these doors had been blocked open and no continuous watch had I been established. 'Iherefore, had plant conditions warranted restoration of the pressure boundaries, the Control Rom operators would not have been aware of the need to take action to restore the pressure bcxuidaries.

Additionally, during the April 10 event, core alterations were in pm,r-s  ;

while Door 15011 was blocked open thus violating T/S 3.7.6 action statment

'b'.

l During previous refueling outages, pressurizatica tests of the Control Rom were performed. As a result of these tests, it was determined that in.

order for the CREVS to be capable of performing its design function, the l

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C t OMM 306A U,8. NUCLl1H 6.L$ULATOJIY COdMIS$10N gg EXPIRES 4?30'92 LICENSEE EVENT REPORT (LER) 'i.'s^MA!?O,$8ErNO*'AIS",liti so*f'l* sis" FOa"d*'S i TEXT CONTINUATION  !?%"m'i%'S!*M20iUN'.* 1"c'"MMU"' $fMA T PAPER O RE 7 t'ON J ED O O IC OF MANAGEMENT AhD DVDGET.w ASHINGToet DC 23f,03 FiCILITV HAMS (t) DOCILEi NUMSE R (2) (th NUMhth ($1 PA06 (31 vnam "W,.w:' **2Y:

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0l0 0l5 OF 0l6 im m . % , w F.,,,,mu .m Control Building pressure boundary had to be maintained thus ensuring the introduction of unfiltered air into the Control Building would remain within the limits assumed in the design basis calculations. The achinistrative guidance provides a list of designated pressure boundary doors as identified

• by these tests to aid the Control Rom operators in maintaining the various boundaries including the Control Building pressure boundary.

As a result of the April 10 evet, on April 13, 1990, discussions were again  ;

held concerning the feasibility of performing pressure tests with various doors open. Following these discussions, it was determined that although ,

such pressure tests may prove operability, the testa performed during the previous refueling outages had already established that with either of these ,

doors open the limits assumed in the design basis calculaticms may be exoaartri . Therefore, these events are being reported pursuant to 10 CPR ,

50.73(a)(2)(1)(B) as conditions prohibited by T/S 3.7.6, and 10 CPR 50.73(a)(2)(ii)(B) as conditions outside the design basis.

RXFr CMBE AIO QEEEE' RIVE ACTIGE5

Subsequent review has detemined that the root cause of these events is L inadequate sucedures which resulted in inever control of pressure boundary doors during refueling outages. During nomal operations, fire '

iwmi mant control permits are prepared by Fire Protection personnel. 'Ihe fire inimimant control pemit is then discussed with control Rom operators prior to establishing the i==4mant. During this discussion, Control Rom '

operators review the pemit against the list of pressure boundary doors  ;

contained in the administrative guidance. If the door to be inpaired is a pressure boundary door, the Control Rom operators enter the am.vg.iate T/S action statements, establish the required continuous watch and are aware of the need to contact the continuous watch if restoration of the boundary is required. During refueling outages, although see fire ing=imant control pemits are discussed and reviewed by Control Rom operators, most of the pemits are filed in the Control Rom without discussion or review.

• Additionally, Fire Protection per cuuel were unaware of additicmal considerations for pressure boundary doors ccotained in the administrative guidance and therefore did not identify the need for a continuous watch on the pemits for these doors.

Review of the April 10 event has also identified inocmplete cmmunications during the preparation, review and inpleantation of the tymry  ;

NIC Feess 386A (649) .

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010l 5 - 0l 0 016 0F 0l6 TtXT W more apese e eeuweet, u.e enenenwet NMC 9erm Jann'alIth modification as a contributing factor. During the inplementation of the tanporary modificaticri, Licensed Operations personnel failed to recognize all the requjIanents in the safety evaluation and plan for innediate restoration of the pressure boundary in accordance with the administrative guidance.

To prevent recurrence of these events, Fire Protection personnel have been given a copy of the list of pressure boundary doors contained in the administrative guidance. '1he Fire Protection inraimant ocritrol sveadure has been revised to ensure that control Room operators are notified prior to establishing a fire inraimarit control permit for any of these doors. In addition, information will be provided to Training personnel by July 1, 1990, so that training on the design considerations and basis for the Control Building pressure boundary can be conducted for all Operatier.s piu..cirsel .

l ADDITIGEL IIEGOBH'IGt Because review of the events discussed in this report has shown that fire

-inraimant control permit processing during refueling outages may not have  !

included discussicris or reviews with Control Roan operators prior to establishing the inraimant, previous necurrences of this nature may have occurred during previous refueling ouLagos. In one case, during a previous refueling outage, on October 12, 1988, Control Rocan operators discovered Doors 32011 and 32013 (la-IR) open without a continuous watch having been established. Door 32011, the door between the southwest stairwell and access control, and Door 32013, the door between the southwest stairwell and outside, are Control Building pressure boundary doors. As a. result of this discovery, a Control Room pressurization test was conducted on October 22, 1988 with Doors 32011 and 32013 open. Because this test proved that the Control Roam was maintained at a positive pressure greater than or equal to

.25 inch water gauge with Doors 32011 and 32013 open, it was determined that i CREVS were operable. At the time, the potential inpact on the design basis of CREVS was not considered. 'Ihe training on the basis for the Control Building pressure boundary to be conducted as the result of the events discussed in this report will enable Control Rocan operators to recognize potential inpacts of this nature and thus preclude recurrence.

NAC 7eem se6A 16491