ML20062G801
| ML20062G801 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/15/1990 |
| From: | Robinson W PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WRR-148-90SR#9, NUDOCS 9012030009 | |
| Download: ML20062G801 (11) | |
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I portland General Electric Company
' Trojan Nuclear plant I
71760 Columbia River llwy.
Rainier. Oregon 97048 November 15, 1990 (503) $$6 3713 WRR-148-90SRl9-1 l<
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U.S. Nuclear Regulatory Commisolon Document Centrol Desk l
Washington DC 20555 l
f Gentlement Special Report Revision l
Limiting Condition for 0,)eration 3.7.9, " penetration Fire Barriers", of the Trojan Technical Specifications (TTS) requires the submittal of a l
Special Report within 30 days if a 3-hour fire barrier is non-functional.
l for greater than seven days.
i previously, Portland General Electric Company (pGE) had identified, in St.ecial Reports dated September 16, 1988; September 27, 1989; December 1, k
l 1989; and December 21,-1989 that 29 fire dampers could not be confirmed-
.to meet all design specifications and were thus inoperable. These problems were identified during the course of a program to identify deviations f rom the manuf acturer's installation details for fire dampers. Upon completin6 the initial portion of the program, which focused on those fire dampers identified as fire barriors per TTS 3.7.9,
.a review of the remaining fire dampers.was conducted.
As a result of this review, completed on July 10, 1990, 99 fire dampers were classified as TTS fire barriors.
Since pCE uses the same surveillance program and action statements for isoth TTS and non-TTS fire barriers, including fire dampers, the only concern from a TTS viewpoint is reportability if a fire damper was out-of-service for greater than seven days.
One damper, FD-318, was declared inoperable on November 27, 1989 due to a broken latQ. FD-318 was not classified as a TTS fire damper at that time.
On July 10, 1990 FD-318 was reclassified as a TTS ftre damper. The scheduled replacement date is shown in Table 2.
Problems identified with previously reported fire dampers fall into the categories defined in Table 1.
Additionally, a Quality. Assurance audit had identified, in the Fall of 1989, that existing installation arrangements for fire dampers did not necessarily permit testing to ensure the closure of the dampers under full airflow conditions. Based on the review completed on July 10, 1990, problems identified with fire dampers fall into the categories defined in Table 2.
9012030009 9011ty3 j//
P, DR ADOCK 050003g PDC
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November 15, 1990 Special Report 1
Eato _ 2 On October 9, 1990 Damper FD-424 failed its 18-month surveillance test when it failed to close under airflow and was declared inoperable.
The subsequent Invcatigation detennined that FD-424 had inadvertently not been identified, in the review completed on July 10, 1990, as a damper whose installation arrangement did not permit testing under full airflow conditions. Additionally, the investigation identiflod that Dampers FD-449, FD-450, FD-451, FD-452, and FD-453 had not been identified as not being tested under full airflow conditions. Although installation arrangements would permit testing under full airflow, personnel safety concerns did not permit a dynamic test, past testing of those dampers (FD-424, FD-449 through FD-453), under static or partial airflow conditions, may have contributed to the reviews not correctly identifying that these dampers were inoperable.
A summary of inoperable fire dampers is given in Tnble 2.
Immediate l
corrective action, upon identifying those problems, was to dociare the affected fire dampers inoperable, and to comply with the action statement l
for TTS 3.7.9 which requires verifying the operabillty of fire detection devices and the establishing of a roving fire patrol for the af fected dampers.
These fire dampers have been inoperable for more than seven days.
The.cause for not previousiy identifying that the fire dampers were TTS fire barriers was a difference in.how two design groups (civ11 and Mechanical) applied the TTS in determining what constituted a TTS fire barrier..The Hochanical design group, responsible for fire dampers, determined that fire dampers which separated ono safety-related train's equipment.from the opposite safety-related train's equipment were TTS fire' barriers. The Civil design group, responsible for identification of fire areas and fire barriers other than fire dampers, determined that a firo barrier was any barrier (wall, penetration seal, etc.) which protected a safety-related area from a fire.
The cause for not meeting the manufacturor's installation details for the fire dampors was that PGE's Engineering Instructions for installing the fire dampers contained conflicting instructions regarding the Esp between the fire damper frame and the wall in-which the fire damper is installed.
personnel involved in the design modification to w*i the fire dampers did not identify that conflicting instruct 1ons existed regarding
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a gap around the fire damper.
The gap allows for thermal expansion of the fire damper when exposed to fire temperatures.
Lack of the gap does not prevent the fire damper from closing, but w1thout the gap the fire damper may bucklo during a fire and create an opening which could allow propagation of the fire.
The cause of not testing fire dampers under full airflow was that the design did not adequately provide for testing under full airflow.
In some cases testing under full flow with the existing design would subject personnel to a safety hazard in observing the test, or the opening of an access door to observe damper movement during the test would divert a portion of the airflow from flowing through the flee damper and thus a full-flow test would not be achieved.
In some other cases equipment l
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November 15, 1990 Special Report-Page 3 7
damage -could-result from performance of the test. These-conditions led to a. decision not to test these dampers under flow, but rather to statically test them.
Long-term corrective actions to restore the fire dampers to-an operable status will include replacement, engineering evaluation', design modifications, or a combination of these actions. The schedule for-I restoring the fire dampers is given in Table 2.
l Fire Dampers which were identified as being TTS fire barriors have been so designated on the design drawing (Fp-900).
To avoid future differences in the application of the TTS criteria on what constitutes a fire barrier only the Civil design group will make such determinations in the future.
Sincerely, W. R. Robinson General Manager-Trojan Nuclear Plant f
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ci-Mr. John B. Martin-
, Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr.1 David Stewart-Smith State r Oregon
-Depart at of Energy Mr..R. G. Barr USNRC Resident Inspector l
Trojan-Nuclear Plant
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Trojan Nuclear Plant Document Control Desk Docket 50-344 November 15, 1990 i
Licbnce NPF-1 Table 1 Page 1 of 3 TABLE I PREVIOUSLY REPORTED INOPERABLE TROJAN TECHNICAL SPECIFICATION (TTS) FIRE DAMPERS Fire Damper Type of Restore to Number Building Room Deviation Operable Status 49 Control East Battery 1
December 31, 1990 49A Control East Battery 1
December 31, 1990 50 Control West Battery 1, 3 December 31, 1990 52 Turbine Turbine-Driven Auxiliary 1, 2 1991 Refueling Feedwater (AFW) Pump outage 57 Turbine West Emergency Diesel 1
December 31, 1990 Generator (EDG) 58 Turbine.
West EDG 1
December 31, 1990 59 Turbine East EDG 1
December 31, 1990 60 Turbine East EDG 1
December 31', 1990 61 Turbine East EDG 4
1991 Refueling Outage 62 Turbine East EDG 4
December 31, 1990 63 Turbine East EDG A
December 31, 1990-90 Turbine Diesel-Driven AFW Pump 1
1991 Refueling Outage 90A Turbine Diesel-Driven AFW Pump 1
1991 Refueling Outage 94
- Turbine Electrical Switchgear 1
December 31, 1990 95 Control Electrical Switchgear 1
December 31, 1990 96 Control Mechanical 1
Restored l
-l NOTE: The dampers listed above are from September 16, 1988; September 27, 1989; December 1, 1989; and December 21, 1989 Special Reports.
Trojan Nuclear Plant Document Control Desk Docket 50-344 November 15, 1990
. License NPF-1 Tabic 1 Page 2 of 3 TABLE 1 Fire Damper Type of Restore to Number Buildinz Room Deviation Operable Status 98 Control Electrical Switchgear 1
Restored 99 Control Electrical Switchgear 1
Restored 104 Control Mechanical 1, 2 December 31, 1990 13/A.
Control Electrical Switchgear 1, 3 Restored 137B Control Electrical Switchgear 1, 3 Restored 139 Turbine Diesel-Driven AFW Pump 1
1991 Refueling Outage 56 Turbine Turbine-Driven Aux 111ary 1
1991 Refueling Feedwater (AFW) Pump outage 380 Turbine West Emergency Diesel 1
1991 Refueling Generator (EDG)
Outage 011 Control Cable Spreading 1
Restored l-93L Control Train B Electrical 1
.1991 Refueling Switchgear Outage 97 Control Train B Electrical 1
Restored Switchgear 308 Control West Battery 1
Restored 309 Control West Battery 1
. Restored NOTE: The dampers listed above are from September 16, 1988; September 27, 1989;
. December 1, 1989; and December 21, 1989 Special Reports.
Trojan Nuclear Plant Document Control Desh Docket 50-344 November 15, '990 License NPF-1 Table 1 page 3 of 3 TABLE 1 Types of Deviation Deviation possible Effect 1.
Inadequate or unknown mounting Damper frame may bind during fire open-sleeve to structure clearance.
ing a larger than acceptable gap, therefore not meeting UL 555 criteria.
2.
No approved.breakway connection Damper may open larger than acceptable where required.
gap during fire due to failure of attached duct work, therefore not meet-UL 555 criteria.
3.
Insufficient or missing
. Gaps may be present between the fire retaining angles.
damper assembly and the structure, therefore not meeting UL criteria. The fire damper assembly may fall out of the wall.
4.
Missing fire damper sleeve or Missing sleeve may cause damper to fall missing UL label, out of wall during a fire. Missing UL 1abel questions listing of damper.
'5.- Closure under full airflow not Damper may not close during a fire, tested.
therefore not meeting'UL 555 criteria.
JDG/bsh/5358W.0890 i
Trojan Nuc1 car Plant Document Control Desk Docket 50-344 November 15, 1990
- 1.icense NPF-1 Tabic 2 Page 1 of 5 TABLE 2 INOPERABLE TROJAN TECHNICAL SPECIFICATION DAMPERS b
Fire Damper Type of Restore to Number Buildinr.
Room Deviation Operable Status 21 Auxiliary Stairwell 12 1, 5 12/31/93 22 Auxiliary Stairwell 12 1, 5 12/31/93 24 Control Radiation Chemistry Lab 1, 5 12/31/93 28 Auxiliary Valve Gallery 1, 5 12/31/93 29 Auxiliary Valve Gallery 1, 5 12/31/93 33 Auxiliary Valve compartment 1, 5 12/31/93 34
' Auxiliary
. Valve Compartment 1, 5 12/31/93 37 Auxiliary Valve Gallery 1, 5 12/31/93 51 Turbine Acid Tank Area 1, S End of 1991 Outage 84 Fuel Concentrate Holding 1, 5 12/31/93 Tank T-318A 105 Control Mechanical 1, 5 12/31/91 106 Control Mechanical 1, 5 12/31/91 107 Control Mechanical 1, 5 12/31/91 108' Control Mechanical 1, 5 12/31/91 109 Control Mechanical 1, 5 End of 1993 Outage 110 Control Mechanical 1, 5 End of 1993 Outage 111 Control Mechanical 1, 5 End of 1993 Outage 120 Control Shift Supervisor Office 1, 5 End of 1992 Outage NOTE: The dampers listed above are not installed in accordance with the manufacturer's requirements, and their associated access doors will not permit testing of the dampers under full airflow condition.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 November 15 1990 laconse NPF-1 Table 2 Page 2 of 5 TABLE 2 INOPERABLE TROJAN TECHNICAL SPECIFICATION DAMPERS Fire Damper Type of Restore to Number Buildint Room Deviation Operable Status 121 Control Shift Supervisor Office 1, S End of 1992 Outage 122 control Vestibule Area 1, 5 End of 1912 Outage 123 Oontrol Vestibule Area 1, 5 End of 19'*2 Outage 125 Control Vestibule Area 1, S End of 1932 Outage 128 Control Mechanical 1, S End of l'J92 Outage t
NOTE:
The dampers listed above are not installed in accordance with the manufacturer's requirements, and their associated access doors will not permit testing of the dampers under full airflow condition.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 November 15, 1990 ticense NPP-1 Tabic 2 Page 3 of 5 TABLE 2 INOPERABLE TROJAN TECHNICAL SPECIFICATION DAMPERS Fire Damper Type of Restore to Number Building Room Deviation Operablo Status 26
' Auxiliary Letdown Heat Exchanger 1
12/31/93 53 Turbine Acid Tank Area 1
12/31/91 54 Turbine Acid Tank Area 1
12/31/91 83 Fuel Clothes Change 1
12/31/93 85 Fuel Chemical and Volume Con-1 12/31/93 trol System (CVCS) Hold-ing Tank T-223 92 Control Mechanical 1
12/31/91 100 Control Elevator Machine 1
12/31/91 102 Control Computer 1
12/31/91 103 Control Computer 1
12/31/91 118 Control Viewing Gallery 1
End of 1993 Outage 119 Control Stair 4 1
End of 1993 Outage 316
-Control Mechanical 1
12/31/91 e
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1, NOTE: The dampers above are 'not installed per the manufacturer's specifications.
(The ability to test these dampers under full airflow conditions is not a concern )
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Trojan Nuclear Plant Document Control Desk Docket 50-344 November 15, 1990 License NPF-1 Table 2 Page 4 of 5 TABLE 2 i
IWOPERABLE TROJAN TECHNICAL SPECIFICATION DAMPERS Fire Damper Type of Restore to Number-Building _
Room Deviation Operable Status 410 Control Mechanical 5
12/31/91 424 Auxiliary Controlled Area Corridor 5
12/31/92 428 Auxiliary General 5
12/31/92 429 Auxiliary General 5
12/31/92 435 Fuel Railroad Bay 5
12/31/92 439 Fuel General Area 5
12/31/92 440 Fuel Boric Acid Tanks and Pumps 5
12/31/92 442 Fuel Valve Compartment 5
12/31/92 444 Fuel-Corridor 5
12/31/92 448 Fuel Laydown Area 5
12/31/92 449 Auxiliary Ventilation Filter 5
12/31/92 450 Auxiliary Ventilation Filter 5-12/31/92 451
-Auxiliary Ventilation Filter 5
12/31/92 452 Auxiliary Ventilation Filter 5
12/31/92 453 Auxiliary-Ventilation Filter 5
12/31/92 454
-Auxiliary Ventilation Filter 5
12/31/92 455 Auxiliary-Valve Gallery 5
12/31/92 36 Auxiliary Controlled Area Corridor 5
12/31/92 NOTE: The dampers above have -access doors that will not pennit testing of fire dampers under full airflow conditions, or whose testing presents a personnel safety hazard.
(The installation of these dampers is in accordance with-the manufacturer's requirements.)
318 Control Mechanical Broken 12/31/91 latch
f Trojan Nuclear Plant Document Control Desk l
s Docket 50-344J November 15, 1990 1
License NPF-1 Tabic 2
.o i
page 5 of 5 L
I TABLE 2 l
Types of Deviation Deviation Possible Effect 1.
Inadequate or unknown mounting Damper frame may bind during fire open-sleeve to structure clearance.
ing a larger than acceptable gap,.
i therefore not meeting UL 555 criteria.
]
2.
No approved breakway connection Damper may open larger than acceptable l
where required.
gap during fire'due to failure of attached duct work, therefore not meet-UL 555 criteria.
3.
Insufficient or missing
, Gaps may be present between the tire retaining angles, damper essambly and the structure, i
therefore not meeting UL criteria.
The fire damper assembly may fall out of the wall.
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4.
Missing. fire damper sleeve or Missing sleeve may cause damper to fall missing UL label, out of wall during a fire. Missing UL label questions listing of damper.
5.
Closure under full airflow not Damper may not close during a fire, tested'.
therefore not meeting UL 555 criteria.
JDG/bsh/5358W.0890 l
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