ML20196C287

Special Rept 88-004:on 880523,determined That Fire Doors W/ Automatic hold-open & Release Mechanisms Were Not Being Verified to Be Free of Obstructions at Least Once Per 24 H as Required.Caused by Inadequate Administrative Controls

ML20196C287
Person / Time
Site:	Hatch, 05003218
Issue date:	06/22/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-004, 88-4, SL-4832, NUDOCS 8807010052
Download: ML20196C287 (7)

Text

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's Georg a Power Company

, 333 Psedmont Avenue Atlanta. Georgia 30308 Te:ephone 404 526 6526 Po 1 Of t e x 4545 Atlanta, Georpa 30302 Georgia Power Nuclear Operations Department t. e soufNyn eimtre system SL-4832 0332I X7GJ17-H540 June 22, 1988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D. C. 20555 PLANT HATCH - UNIT 1 AND UNIT 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 SPECIAL REPORT 88-004 FIRE DOORS HITH AUTOMATIC HECHANISMS NOT CHECKED EVERY 24 HOURS AS REQUIRED RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT Gentlemen:

In accordance with the requirements of the Plant Hatch Unit 1 and Unit 2 Technical Specifications Section 6.9.2, and the Fire Hazards Analysis (FHA) Appendix B, Georgia Power Company is submitting the enclosed Special Report (SR) concerning an event where fire doors with automatic mechanisms were not checked every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required. This event occurred at Plant Hatch - Unit 1 and Unit 2.

Sincerely, y1. b. l$

l H. G. Hairston, III I

Senior Vice President JJP/lg l

Enclosure:

SR 50-321/1988-004 c: (see next page)  %

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lGeorgiaPower A U. S. Nuclear Regulatory Commission June 22, 1988 Page Two c: Georaia Power Comoany Mr. J. T. Beckham, Jr., Vice President.- Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Safety and Licensing GO-NORMS U. S. Nuclear Reaulatory Commission. HashingtqD&D. C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Region II Dr. J. N. Grace, Regional Administrator Mr. P. Holmes-Ray, Senior Resident Inspector - Hatch 0332I 7m"5 _ _ _ . _ _ . _

GeorgiaPower d ENCLOSURE PLANT HATCH - UNIT 1 AND UNIT 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 SPECIAL REPORT 88-004 FIRE DOORS HITH AUTOMATIC HECHANISMS NOT CHECKED EVERY 24 HOURS AS REQUIRED RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT A. REQUIREMENT FOR REPORT This report is required per the Unit 1 and Unit 2 Technical Specifications section 6.9.2. This section of the Technical Specifications states that special reports for fire protection equipment operating and surveillance requirements shall be submitted, as required, by the Fire Hazards Analysis (FHA) and its Appendix B requirements.

The FHA section 1.1.1 states that all sealing devices in fire rated assembly penetrations (fire doors, fire dampers, cable, piping and ventilation duct penetration seals) shall be operable at all times. The action statement allows for the sealing devices to be inoperable for up to 14 days. If this time period is exceeded, a special report is required.

B. UNIT (s) STATUS AT TIME OF EVENTS On 5/23/88, Unit 1 was in the shutdown mode of operation. The Unit 1 reactor parameters were as follows: thermal power was zero, pressure was approximately 96 psig, and reactor coolant I temperature was approximately 330 degrees Fthrenheit.

On 5/23/88, Unit 2 was in the run mode of operation. The Unit 2 reactor parameters were as follows: thermal power was approximately 1340 MWt, pressure was approximately 930 psig, and reactor coolant temperature was approximately 540 degrees Fahrenheit.

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GeorgiaPower d ENCLOSURE (Continued)

FIRE D0 ORS WITH AUTOMATIC HECHANISHS NOT CHECKED EVERY 24 HOURS AS REQUIRED RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT C. DESCRIPTION OF EVENT On 5/23/88 at approximately 1315 CDT, plant fire protection personnel determined that the fire doors with automatic hold-open and release mechanisms were not being verified to be free of obstructions at least once per' 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by the FHA, Appendix B, section 2.1.2.b. Deficiency Card 1-88-2255 was written as required by the plant's administrative control procedures to document the condition.

Appendix B of the FHA contains fire protection equipment operability and surveillance requirements. The FHA was effective 12/1/86 and replaced the operability and surveillance requirements contained in the plant's Technical Specifications.

The requirement to verify, once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the fire doors with automatic hold-open and release mechanisms to be free of obstructions was not in the Technical Specifications. This requirement, therefore, was not contained in any plant procedures when Appendix B of the FHA replaced the fire protection equipment Technical Specifications. This new surveillance requirement was not incorporated into plant procedures at this time, thus, it has not been performed, as required, since 12/1/86.

In May of 1988, plant Fire Protection personnel performed a complete review c.' Appendix B requirements against existing plant procedures. The review, initiated by Fire Protection l supervisory personnel, was performed to determine if existing l procedures completely and correctly implemented Appendix B requirements. It was during this review the event was discovered. No other problems with the implementation of Appendix B requirements were found.

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' Georgia Power d ENCLOSURE (Continued)

FIRE DOORS WITH AUTOMATIC MECHANISMS NOT CHECKED EVERY 24 HOURS AS REQUIRED RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT Plant operations personnel, upon notification of this event on 5/23/88, initiated actions to ensure doors were not blocked or obstructed. No obstructions were found upon the initial inspection. The requirement to verify the applicable fire doors were free of obstructions was added temporarily to the "Remarks" section of the daily Plant Equipment Operator (PEO) rounds procedures (34G0-0PS-030-IS, "Daily Inside Rounds,"

34GO-0PS-031-IS, "Daily Outside Rounds," and 34G0-0PS-030-2S, "Daily Inside Rounds") to ensure the surveillance is performed until the procedures can be revised permanently.

D. CAUSE OF EVENT The event occurred as a result of inadequate administrative controls. Specifically, no controls were in place to ensure new and revised requirements contained in Appendix B of the FHA were reviewed by the appropriate plant personnel for necessary procedure changes.

E. ANALYSIS OF EVENT In protecting Plant Hatch against significant damage from fire (i.e., damage that would prevent the performance of necessary safe plant shutdown functions or would significantly increase the risk of radioactive releases to the environment), primary design consideration has been given to locating redundant safe shutdown circuits and components in distinct areas separated by fire barriers. The fire barriers prevent the propagation of fire to adjacent areas. The barriers, which include fire doors l

with automatic hold-open and release mechanisms, are designed to contain a design basis fire which totally involves the combustibles in the given area.

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GeorgiaPower A l

l ENCLOSURE (Continued)

FIRE DOORS HITH AUTOMATIC MECHANISMS NOT CHECKED EVERY 24 HOURS AS REQUIRED RESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT In this event, 28 fire doors which close automatically were a fire to occur in their area were not checked once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to ensure they were not prevented from closing, i.e.,

obstructed. Although this surveillance was not performed, other required surveillances were performed on these doors as required by Appendix B of the FHA. Specifically, once per 18 months these 28 fire doors are functionally tested as required by section 2.1.2.b. of Appendix B. The functional test verifies

,the doors will close automatically upon receipt of the proper signal. At this time, they are verified to be free from obstruction.

The 28 automatic fire doors in question are not the only type of fire doors used to prevent the propagation of fires. In fact, they comprise only a small percentage of the total number of fire doors located within the plant. Further, the areas in which the 28 automatic fi re doors are located contain fire detectors. In the event of a fire, an alarm is received in the Main Control Room. The Fire Brigade would respond in. mediately to the alarm and extinguish the fire. Some of these areas are equipped with automatic sprinkler systems in addition to fire detectors. The sprinklers act to extinguish or limit the spread of the fire until the Fire Brigade responds.

In the unlikely event an automatic fire door failed to close due to an obstruction, other fire barriers would limit a fire's spread and damage. Non-automatic, normally closed fire doors, fire rated walls, and fire wrap are fire barriers which would limit a fire's spread and damage. These are passive barriers which require no automatic or manual action to perform their function.

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'1, GeorgiaPower A ENCLOSURE (Continued)

FIRE DOORS HITH AUTOMATIC HECHANISMS FOT CHECKED EVERY 24 HOURS AS REQUIRED rESULTS IN SPECIAL REPORT AS REQUIRED BY FIRE HAZARDS REPORT Based on the above analysis, it is concluded that this event had no adverse impact on nuclear safety. Additionally, since the size of and damage from a fire are independent of power level, it is believed that the consequences of this event would not be more severe under other power conditions.

F. CORRECTIVE ACTIONS Corrective actions for this event included:

1. Immediately verifying the 28 automatic fire doors were not obstructed.

2. Temporarily adding a note to the remarks section of the PE0 rounds procedures 34G0-0PS-030-1S, 34G0-0PS-030-2S, and 34GO-0PS-031-IS to ensure the inspection is performed until the procedures can revised permanently. It is anticipated these procedures will be revised permanently by approximately 8/1/88.

3. As stated previously, this event was discovered by Fire Protection personnel during a complete review of Appendix B requirements. No other problems were found during this review. However, to ensure future revisions to Appendix B requirements are reviewed for necessary procedure changes, existing administrative controls covering review of Technical Specification Amendments will be revised to include reviews of revisions to Appendix B of the FHA. It is anticipated the existing administrative controls will be revised by approximately 9/1/88.

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