ML20196E523

Provides Response to Allegation RIII-A-88-0086 Re Operation of Vital Area Door

ML20196E523
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/29/1988
From:	Bliss H COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20196E521	List: ML20196E515 ML20196E523
References
NUDOCS 8812120026
Download: ML20196E523 (9)

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/ ^ *N Comm:nwrith Edisin V One First N1tional Plaza. Chicago Ul4ros Address Reply to: Post 06ce Boe 767~

Chicago,1:hnois 60690 0767 September 29, 1988 tw Mr. A. Bert Davis '

Regional Administrator ' -

W.10 U.S. tiuclear Regtalatory' Commission

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__ , p Region III , 7 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion tiuclear Power Station Units 1 and 2 Response to Allegation (RIII-A-88-0086)

Licenso llos. DPR-39 and DPR-48 tiRC Docket tios. 50-295 and 50-304

Reference:

August 8, 1988 letter from C. tiorelius to Cordell Reed.

Dear Mr. Davist This letter provides a response to i II-A-88-0086 j

conc ning the operation of Vital Area Door @J11,egat on tio. RIf(incorrectly identified Door in the Allegation). A 15-day extension was granted on September 9, 1988 via a telephone conversation between J. Crood and P. Laird.'

The Attechment to this lotter contains Safeguards Information as defined in 10 CFR 73.21. Accordingly, the information in the Attachment should be withhold from public disclosure.

If you have any further questions regarding this matter, please direct them to Commonwealth Edison's fluclear T,1 censing Depart nent.

Very truly yours,

/ N

[ 11. T. . Bliss tiuclear Licensing Administrator la .n Attachment OTTERISSEPARATEFROMTIG 5184K GG121200;'6 891201 PDR ADOCK 0U000293 Q F D F" r dj sa t.H in.

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ATTACIDfENT l ' ,"

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NESPONSE TO ALLEGATION RIIIr882h2008'6-~ ~

Inttoduction l

1 Vital Area Door h (actually notp1 as Door h n the allegat'on summary) l 1s the south r of the Zion Statior(6 This door 1 cads from the doors open into this vestibule h o a small vesti ule. Three ot  ;

which provi access to th j All doors leading into this vestibule provide passage to locations within the vital area of the plant and are not protected area to vital area portals.

of the four doors leading into this vestibule, only Door M ]is equipped with The other doors are normally closed and unlocked.

a Door of bullet resistant construction. Both sections o thedo$)sadoubledoo or re alarmed with ]alarmsandequippedwith 7

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alarm. All alarms generated from these devices are annunciated i in The normally passi.yo half of Door % is secured in place by

! nd a be u1 opened by the user upon receipt of*a signal that the door is unlocked.

T security computer has been programmed to establish a This is consistent with the door tablished for all l cardreader controlled doors at Zion Stat n. A programmed l

establish ' the time If this time the computer generates a door alarm.

If the door fails to lock or if the door is not closed within ( h )

an alarm is received. The computer does not distinguish between these types of alarms during the annunciation and recording process.

Details:

1. provide determination of whether or not Door ( closes all the way automatically.

After each use, Door h is designed, through the assistance of a '

ydraulic closure, to return to the closed position whereby the secures the door.

In m instances, especially during April, May and June of 1988 '

Door did not al ays close wit n the allocated door delay of

h. Once the

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is exceeded, an alarm is received. Mechanical failure also contributed to the number of alarms received on DoctM llowever, in all cases, when Doothl did not perform within specifications, an alarm was received and a i security officer was dispatched to respond to the alarm and investigate the situation.

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TheanalysisonalarmsreceivedonDoor( from January through June of 1988, reveals the preponderance of alarms occurred because the door not b ause the door failed Jo ,close and lock automatically. In fact, of the time, Door N jwas locked and the alarm had reset by the t me the responding guard arrived.

2. If you find the door does not close automatically, provide the reason for the malfunction.

Du n9 the period from January through June 1988, records reveal Door was used approximately 94,290 times. (The alarm history for Door is documented under section 4 of this response.)

throughout the first The number six months of alarms of 1988 associated and especially duringwith Ap DoorM'ril, May and June was a concern to the station security staff. From January t;hrough June 1988, members of the security staff logged approximate'. 25 visits to Door $ 1n order to determine the cause of the extrao Jinary number of alarms, security Management also measured the existing air pressure forcos acting on Door $

Investigation revealed Door @ would close properly without an alarm when testod by the station soYurity staff. The condition causing the alarm could not be identified to duplicate the alarm during the test sequenco. When an equipment malfunction caused an alarm condition, a work request was written and repairs were completed in a timely fashion.

The following is a list of work requests written to repair Door security related equipment:

Date of Work Request _Date of Repair Work Done January 11, 1988 January 12, 1988 Replaced January 21, 1988 January 22, 1988 Replaced March 5, 1988 March 5, 1988 Replaced March 13, 1988 March 15, 1988 Replaced March 24, 1988 March 31, 1988 Replaced

( --------- April 14, 1988 Re laced June 13, 1988 June 14, 1988 Repair June 17, 1988 June June 29, 22, 1988 1988 Ajusted; Re laced

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June 28, 1988 June 28, 1988 Tepair An analysis of the problem fixes the root cause of the repetitive alarms on Door $ to be excessive air pressure. The air pressure acting on the door against the force exerted b l

caused two types of recurring alarms on Doo@y D the hydraulic closure l

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A. The air pressure slowing the closing of the door beyond the allocated ( )appearstobethemost frequent cause of the door alarms and comprised W of this problem. By the time the responding security officer arrived on the scene, the door closure.had overcome the air pressure, the door was secure and the alarm reset. .

Air pressure was a variable factor and the amount of pressure at any given time was dependent upon the INAC system alignment, operation of Auxiliary Building supply fans, outside wind speed and direction, Turbine Building window position, the position of Turbine Building and Auxiliary Building roll-up and missile doors and the open_or closed condition of other plant doors adjacent to Door B. Once Door h was closed and locked, air, pressure would at times cause the door to vibrate, which would be sensed by the limit switches and created an alarm condition, even though the door was fully secure. This condition W1s confirmed through visual observation.

There was another generic cause of alarms on Door h The openings and closings associated with the daily traf fic through Door @

(approximately 525 per day), caused wear and tear on various door parts and components. The failure of this hardware also contributed to the number of alarms received at Door g

[ 14ost of ten, these failures were quickly diagnosed and timely repairs were made. Other failures were intermittent or gradual deterior'.tions that were not readily evident when the door was inspected to determine the cause of the alarms.

Of the 94,290 recorded uses of Door during the January-June 1988 time period, alarms occurred approximately G of the time.

3. (provide) a description of measures being taken to correct the problem.

Excessive air pressure which resisted the ability of the hydraulic in a timely manner was the cause of the '

excessive alarms on Door closuretoshutthedoor{$

This was an abnormal condition caused in part by work being done on the INAC system and the ensuing re-alignment of air handling equipment and vent dampers.

Once the !!VAC system alignment was completed during t e first week of July, the jnordinate air pressures acting on Docr abated and the repetitive alarm problem was resolved. Evidence o is is the reduced number of alarms received in July (81) and August (23).

The foi owing corrective actions were taken in recponse to the alarms on Door ,

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A. Veather stripping to reduce air flow through other adjacent and remote closed doors (which could affect Doorp} was repaired and/or replaced.

B. Rubber door bumpers were replaced on Door Dumpers are utilized to assist in holding the door firmly in place and inhibit door vibration once the door is closed. The vibration no longer exists.

C. The supplier of the door hardware was contacted on several occasions and verified the door closure currently installed on Doorp s the proper model for this application.

D. The station is arranging to install a special "spring assist" closure device to overcome any potential air pressure problem which may be encountered in the future. This spring assist is designed to operato in conjunction with the existing closure in order to close the door in a timely manner.

It should be noted that once an 6 failure was identified which caused excessive door alarms, the repair was punctual.

4. (provide) an analysis of your review of alarms received for Door g} for the period Jar.uary 1,1988 - June 20,1988.

This analysis was compiled by a Aanual review of computer generated alarm history for Vital Door %(refer to attachment 'B').

This review ind cates that all alarms received during this time period for Door M were received, acknowledged, dispatched, responded to and properly documented.

All alarms received woro processed in less than five minutes. In como in'Jtances, soveral alarms may have been received from one device before the arrival of the responding guard. An texample of this would be a locked door where air pressure would cause the door to vibiate.

An alarm device would sense the vibration as one or more alarms, roset and repeat this process.

5. (provide) a description of compensatory measures required to be implemented when the door fails to close autceatically.

S "al or (ection7.3.7oftheZionStationSecurityplanstates,ith g atmanumme

}at The repetitive alarms associated with Door M especially during April, May and June, were attributed to the fqct that the dcx>r was not closing in less than =) once the door closed, it was properly secure.

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The Zion Station Security Plan does not contain specific compensatory measures to be implemented for a door which alarms due to the fact that the door did not close prior to the allocated door delay time.

Ilowever during the period of time in question, a security officer responded to each alarm received. The door alarm was c1 cared, verified secure and the alarm reset prior to the guard 1 caving the door.

ZionpostedahighlyvisiblesignonDoo( instructing personnel not to leave the door until a closed and secure status is verified.

6. (provide) a description of training given to employes regarding their responsibilities on ensuring that security doors are properly closed.

The Nuclear General Employe Training booklet, which is made available annually to all badsd.1.dividualr. at the plant, instructs all personnel entering and exiting vital area to promptly close doors to prevent alarms. The booklet also states that if a security door is held open too long, an audible and visual alarm will be activated in the Eacurity Control Room.

A spe"clal instruction to all plant personnel, signed by the Station Managt*r, stipulates that an individual us ng a vital door should not leave the door until the door is verified closed and secure. This instruction is given to an individual when they receive a photo I.D. badge and whenever a new badge

, is issued.

conclusion There was an extraordinary number of door alarms received on Doo during the first. six months of 1988.

l The cause of the overwhelming majority of these alarms was an inordinate amount of air pressure which delayed the closing of the door within the allocated or which caused the closed and locked door to vibrate in place.

Once the evasive air pressure problem was overcome, the number of door alarms decreased significantly.

All alarms received on Door were received, acknowledged, responded to in a timely manner and properly documented. Even during the periods of highest alarm activity, all door responses were accomplished within five minutes.

Of the 3,'190 alarms recorded during the six month period January-June 1988, the door was closed, locked and alarmed when the guard artived at the door D of the time, an additional h of he alarms occurred during supervised tests of the door and another of the alarms occurred while a guardwaspostedatDoor(

'.- . . x ._ .: . _ ,y Control Room personnel could have ensured that Door % was closed behind them, however, if more than 6 had clasped since the electric strike opened, the door would still alarm. These alarms could have occurred one or two dozen times per shift, but in each case, response to the alarm was timely and proper.

Since Vital Door M was a vital door well within and surrounded by the vital area and the Station Security Force quickly responded to each alarm, appropriate compensatory measures were enacted.

Investigation failed to identify any inconsistencies in implementing established security procedures at Zion Station.

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_. _ _ _ _ ._ j ALARM ANALYSIS VITAL AREA 000R Alams Jan. Feb. March April May June ,

TOTAL Door locked and alam reset before 300 15 119 976 577 662 2,649 arrival of guard Supervised door tests 50 60 29 56 19 37 251 Alams while guard posted 81 16 40 122 51 79 3t,9 Alam reset in M 52 1 8 56 43 75 235 (r: set af ter arrival of guard)

Alarm reset in 6 31 0 8 56 55 47 197 (r: set after arrival of guard) i Alarm reset in @

(r: set af ter arrival of guard) 7 0 2 13 18 17 57 Alam reset in@

(reset af ter arrival of guard) 1 0 0 0 2 4 7 l

l Alarm reset 1 0 0 0 0 3 2 5 (reset after arrival of guard)

TOTAL 522 92 206 1,279 768 923 3,790 7 g ah 4 EO h

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