ML20209D976
| ML20209D976 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/27/1987 |
| From: | Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20209B481 | List: |
| References | |
| 230.1(B), 230.1(B)-R02, 230.1(B)-R2, NUDOCS 8702040580 | |
| Download: ML20209D976 (14) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 2 TITLE:
HVAC DESIGN Fire Damper Latching Test PAGE 10F 13 i
REASON FOR REVISION:
1.
Revised to incorporate TACF No. 1-84-039-31 and to add chronology.
2.
Revised to incorporate Senior Review Panel and Technical Assistance Staff comments of 12/08/86; to comply with current report format; and to add Section 10, Corrective Action.
PREPARATION PREPARED BY:
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P SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
M(A0ed t-e n 7 ul8 ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files, l
TVA EMPLOYEE CONCERNS REPORT NLMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 13 1.
CHARACTERIZATION OF ISSUE (S):
Issues:
Concern:
EX-85-027-001 a.
Fire dampers would not latch when "HVAC dampers in the auxiliary tested under actual operating and control buildings (one conditions.
location given west end of control building - Elev. 713' b.
Test was changed to release
(?) were tested under actual dampers by hand.
operating conditions (use of fuse link to release dampers),
c.
Original intent of test to demonstrate and the dampers would not latch.
operability under actual conditions Manufacturer (Ruskin) was may not have been met, contacted, and reconmended changing of test to use a hand release of dampers, which was done, and dampers latched. CI is concerned that original intent of test (to demonstrate operability under actual conditions) was not met."
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by TVA Engineering Date 12/06/82 Documentation Identifiers:
NCR SQNMEB8207 3.
DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STAltu IN ELEMENT:
This concern originated at WBN but is generic to all Ruskin Manufacturing Company brand fire dampers. Ruskin fire dampers were originally purchased for SQN by Contract 77K71-822493 and 72C55-92762-2.
Concern refers to curtain type fire dampers manufactured by Ruskin and installed in the HVAC systems of the Auxiliary and Control Duildings.
No document or tag number was l
l 032fD - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.l(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 13 included in the employee concern.
It does mention a specific WBN l
location of one fire damper - at the west end of the control building at elevation 713 fe t.
4.
INTERVIEW FILES REVIENED:
EX-85-027-001 The working and expurgated ECTG files for this concern were reviewed.
No additional unreviewed information was contained in the files.
5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltu TO ELEMENT:
See Appendix A.
P.
EVALUATION PROCESS:
a.
Reviewed purchase orders and related documents to ascertain manufacturer and models of fire dampers used at SQN.
b.
Reviewed relevant documents for same concern on WBN and determined if WBN findings are applicable to SQN.
c.
Verified that the SQN design basis for fire dampers and the appropriate system operating instructions have been changed to reflect as-built dampers.
l 03?fD - 01/15/87 j
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 13 9.
DISCUSSION, FINDINGS, AND CONCt.USIONS:
Chronology:
i Souner 1982:
Problem discovered at WBN 12/06/82:
TVA Technical Specification for HVAC Dampers, MEB-SS-10.3, revised to require negator springs 03/17/84:
Fire damper modification, replacement, and full flow drop tests completed, and temporary alteration control fonn (TACF) issued 11/06/84:
Ruskin infonned TVA of NRC 10CFR21 report regarding fire damper testing discrepancy 08/85:
Concern received by TVA 08/12/85:
TVA General Design Guidelines DG-M18.2.15 revised to prevent recurrence of problems Discussion:
l
}
The concerned individual (CI) referred to a stssner 1982 time frame when Ruskin brand fire dampers failed to latch when tested at WBN by fusible link release.
In a telephone conversation (App. A, 7.g) T. Arnold of Ruskin agreed that the type of fire camper release itself (fuse link or I
l manual) does not have an affect on the closing and latching operation. This cor.cern may therefore be discussed as two separate subjects: a) failure of the fire dampers to release by fusible link, and b) failure of the fire dampers to close and latch, a.
Fusible Link Failure:
Single purpose fire dampers are released by melting of a fusible link under external heat (nonna11y at 160*F). Dual i
purpose smoke / fire dampers are released by melting of an electrothennal link (ETL) either under external heat or by an electric current from a smoke control Nuclear Power Experience reports up to August 1986 (panel.
App. A, 5.y) do not i
report any generic fusible link failures on Ruskin fire 03260 - 01 /15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B) i SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 13 dampers. A few release failures were attributed to mechanical interference or binding of cables, corrosion, or, in one case,' to an unexplained melted fusible link.
The latter problem resulted in damper closure. WBN ECh No. 4297,, ( App. A, 5.dd) was issued to resolve NCR 5035 and addressed the fire damper installation problems, including recommendations for replacement of dampers which did not fully close when the fusible link was removed. Test procedures or reports on fusible links are not available.
TVA memo ( App. A, 5.u) declared NCR5036 not applicable to SQH.
Proper SQN fire damper installation clearances were verified by the Division of Construction Quality Control inspector, as reported in a TVA memo (App. A, 5.'b) on 05/06/85.
b.
Closure Failure:
TVA memo ( App. A, 5.t) reported that preoperational test TVA-24 at WBN discovered that curtain-type gravity-operated fire dampers from Ruskin were not closing completely against air flow. Therefore, NCR WBNMEB8203 ( App. A, 5.c) was issued, as was NCR SQNMEB8207 ( App. A, 5.e), following determination of generic applicability.
The latter NCR resulted in the addition of Ruskin supplied negator springs and positive blade latching mechanisms to 100 fire dampers, and replacement of 15 dampers which would not accept springs at SQN.
To prevent recurrence, TVA General Design Guidelines, " Fire Damper Application, Selection and Installation" ( App. A, 5.f) and TVA Standard Specification for "HVAC System Dampers," ( App. A, 6.b) were also revised accordingly. _ Except for one damper, corrective modifications and full drop tests were completed in March 1984.
Workplan 10483 of ECN L5847, Attachment A ( App. A, 5.g) reports that one of the 15 replacement dampers did not fit the penetration sleeve and a temporary alteration control fonn (TACF) No. 1-84-039-31 was issued for resizing the damper.
This damper 0-31C-1744, however, was never reinstalled and, per telephone call of 11/20/86
( App. A, 7.j), may have been lost and is on reorder.
The originally installed damper was destroyed when removed. Past experience indicates that damper 10-31C-1744 and its companion (0-31C-1743) will fail the full flow drop test.
03200 - 01 /15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 13 t
In 1984 Ruskin found that its test methods for damper closure capability did not correspond with the actual installed positions of'the dampers. Ruskin',s test configuration was essentially a wall mounting as shown in Air Movement and Control Association (AMCA) Standard 500 (App. A, 5.1)
Figure 5.5 instead of duct installation per Figure 5.3 as l
stated in Ruskin'.s catalog. The wall mounted configuration did not account for the dynamic flow effects.
Since Ruskin dampers are installed in the majority of U.S. nuclear power plants, Ruskin then issued a 10CFR21 notice to the NRC, and a letter (App. A, 5.j) to TVA. This Ruskin letter recommended retesting of all fire dampers with closure springs under air flow, to verify proper operation.
Workplan 10483 of ECN L5847 (App. A, 5.g) records post-modification test data of the SQN fire dampers with closure springs under full flow. A TVA memo of 04/30/85 (App. A, 5.k) lists 12 SQN dampers of concern that either failed the full flow drop test or were untested but were
[
expected to fall based on tests at WBN. For nine of these 12 dampers, the proposed corrective action was to institute adninistrative operating procedures for ventilation flow shutdown to assure their closure.
The remaining three fire dampers were detennined to be in systems operating less than 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year or in nonfire-rated walls and were therefore acceptable as is.
SQN System Operating Instruction, " Fire Interaction Manual,"
(App. A, 5.p) gives instructions for either shutdown of area supply and exhaust fans, or closure of isolation dampers, or Auxiliary Building isolation; the appropriate action depends l
on the specific location for interrupting air flow to the nine fire dampers of concern.
This procedure however does i
not provide a fire alarm or notification criteria requirement, nor control designation and location for the fire brigade leader for shutting off a specific air flow.
A meeting between TVA and NRC was held on March 27,1985 to discuss the Ruskin fire damper concerns for WBN. Following L
this meeting, a TVA letter to the NRC (App. A, 5.m) clarified I
the adninistrative procedures proposed for shutting off the ventilation flow in areas where fire dampers may not close under air flow. For WBN, Abnonnal Operating Instruction,
" Plant Fires," (App. A, 5.n) and System Operating l
l Instruction, " Fire Detection System," (App. A, 5.0) give l
detailed 0326D - 01/15/87 L.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.l(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 13 instructions for the sequence to be followed in shutting off the area fan (s), and specific locations of their controls.
These instruc'tions also incorporate NRC's requirement for restricting the fire brigade leader's judgment in deciding if fans should be shut down.
The fire brigade leader may, instead, request restart of fans after fire scene assessment.
The SQN System Operating Instruction ( App. A, 5.p) is not as explicit as the above instructions for WBN.
Findings:
a.
Since summer 1982, when this concern arose, fi'rb dampers at WBN and SQN have undergone extensive evaluations, testing, modifications, replacement, and retesting to assure their proper functioning under actual operating conditions.
This process was monitored by NRC on various occasions (App. A, 5.m and 5.r).
The fire damper manufacturer (Ruskin) and TVA also performed independent tests, b.
Nuclear Power Experience reports ( App. A, 5.y) do not l
indicate a generic problem with fusible links. The CI's statement is, therefore, considered inaccurate as to the cause of damper closure failure. The type of curtain release mechanism (fusible link or manual) does not affect the closure and latching process of the fire dampers.
)
c.
For nine of the 12 fire dampers at SQN that failed the post-negator spring modification test under actual operating flow conditions or that could not be tested, system operating instructions were instituted for ventilation air flow interruption in the fire zones.
The remaining three fire dampers were acceptable as is because of their limited time in use or their location in nonfire rated walls.
d.
Damper 0-31C-1744 has not been installed and successfully tested or included in the system operating procedure for dampers expected to fail the full flow drop test.
s 0326D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 13
==
Conclusions:==
The concern is not' valid as to fire damper closure tests not representing actual operating conditions. Such tests have been performed since summer 1982, and the necessary damper modifications have been made. One damper which could not be modified was removed and no replacement has been installed yet. For dampers that failed postmodification tests, system operating instructions have been instituted to interrupt the air flow in the ducts in case of a fire, thus assuring damper closure. The missing damper is not expected to close under full flow and is not included in the system operating instructions. These instructions do not give the fire brigade leader the fire alann and verification criteria for shutting down the ventilation flow. Specific fan and damper control designations and locations are missing.
- 10. CORRECTIVE ACTION:
TVA has submitted a corrective action plan (App. A, 5.kk) which includes the following commitments:
a.
to revise SQN A0I-30 (App. A, 5.jj) so that, in case of fire, operators will take ventilating system actions necessary to assure fire damper closure; and b.
to install a new 0-31C-1744 damper after the next Unit 2 refueling outage.
The corrective action is satisfactory to the evaluation team.
0326D - 01/15/87 i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 13 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
NRC IE Infonnation Notice No. 83-69, " Improperly Installed Fire Dampers at Nuclear Power Plants," ( A02 831027 002),
(10/21/83) b.
TVA memo from Rankin to Vineyard, SQN 10CFR50 Appendix R -
Fire Dampers, (501 850501843), (05/06/85)
TVA NCR, Watts Bar, WBNMEB8203, (MEB 821015 015), (10/13/82) c.
d.
TVA NCR, Watts Bar, WBNMEB8513, (844 850301014), (02/28/85)
TVA NCR, Sequoyah, SQtNEB8207, (MEB 821206 018), (12/06/82) e.
f.
TVA General Design Guidelines, " Fire Damper Application, Selection and Installation," DG-M18.2.15, R1, (B4285823512),
(08/12/85) g.
ECN No. L5847 including Workplan 10483 and TACF 1-84-039-31, (SWP 830318 801), (03/04/83) h.
TVA memo from H. J. Green to M. N. Sprouse, "SQ-DCR-1835,"
(DES 830121 009), (01/19/83) 1.
Air Movement and Control Association (AMCA) Standard 500-83 j.
Ruskin Manufacturing Division letter to TVA, (MEB 841113 517), (11/06/84) k.
TVA memo from J. H. Sullivan to Appendix R Project Files,
" Appendix R - Fire Dampers," (S01850430 833), (04/30/85)
Meeting minutes by(T. J. Kenyon, "WBN-Ruskin Fire Dampers,"
1.
(L44 850429 597), 04/18/85) m.
Letter from D. K. McCloud, TVA, to K. Adensam, NRC, (L44 850328 806), (03/28/85)
WBN Abnormal Operating Instruction, A0I-30, R6, " Plant Fires" n.
o.
WBN System Operating Instruction, S01-13.1, R3, " Fire Detection System" p.
SQN System Operating Instruction, S01-26.2, R3, " Fire Interaction Manual" 0326D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 230.1(B)
SPECIAL PROGRAM REVISION NLMBER: 2 PAGE 10 0F 13 l
APPENDIX A (Cont'd) q.
NCR WBNMEB8513 " Determination of Reportability Infonnation Worksheet for 10CFR50.55(e)," (B45 850307 269), (03/04/85) r.
TVA memo from J. P. Vineyard to H. B. Rankin, "SQN - Ruskin l
Fire Dampers 10CFR21 Report," (B44 850313 008), (03/14/85) s.
TVA memo from G. A. Silver to MEB Files, "SQN - Minutes of a Telecon to Discuss Fire Damper Inspection Program,"
(B44 850906 011), (09/06/85) t.
TVA memo from C. A. Chandley to J. C. Standifer, "SQN and I
WBN - Fire Damper Negator Spring Kits," (MEB 830217 018),
(02/17/83) u.
TVA memo from J. P. Vineyard to J. A. Raulston, "NRC-0!E Reportability Infonnation Distribution - WBN NCR 5036 -
Applicability to SQN," (PWP 831018 006), (10/18/83) v.
Ruskin Manufacturing Division letter transmitting Generic Test Reports (01/08/85 and 02/11/85) for Horizontal and Vertical Mounted Fire Dampers, (MEB 850215 522), (02/12/85) 4 w.
TVA memo from J. Hutton to C. C. Mason, "NCR SQM4EB8207,"
j (L33 821220 801), (12/21/82)
TVA memo from C. A. Chandley)to J. P. Yineyard, "NCR l
x.
SQNMEB8207," (B44 851212 008, (12/12/85) 4 y.
Nuclear Power Experience, Voline PWR-2, Experience, published by The S. M. Stoller Corp., (through 08/86) 3 z.
WBN ECN 5523 (B26 850305 520), (02/26/85) 4 aa.
NCR WBNMEB8510 (MEB 850222011), (02/22/85) l bb.
NCR W-210-P (WBN 850118110), (11/28/84) cc.
NCR W-220-P (WBN 850218103), (01/29/85) dd.
ECN 4297 (WBP 831128 518), (09/26/83) i ee.
Purchase Contract No. 72C55-92762-2, Grilles, Ceiling i
Diffusers and Dampers, (02/28/72) ff.
Purchase Contract No. 77K71-822493, Fire Dampers, (08/19/77) 1 03260 - 01 /15/87 i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 11 0F 13 APPENDIX A (Cont'd) gg.
TVA Standard 3pecification, " Technical Specification for Heating, Ventilating, and Air-conditioning System Dampers for TVA Projects," MEB-SS-10.3, R1 hh.
Review of ECTG files - Documentation for Concern EX-85-027-001 by H. Van Straalen, 10/16/86.
ii.
TVA WBN Preop Test Instruction TVA-24, Fire Dampers, R0, (09/08/78) jj.
SQN Abnormal Operating Instruction, A01-30, R4"'
kk.
Corrective Action Plan for Element Report 230.01(B) transmitted by TCAB-036, (12/19/86), and revision transmitted by TCAB-058, (01/15/87) 6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
a.
TVA General Design Guidelines DG-M18.2.15, " Fire Damper Application, Selection and Installation," R1, (B42 85 823 512), (08/12/85) b.
TVA Standard Specification for " Technical Specification for Heating, Ventilating, and Air-conditioning System Dampers for TVA Projects," MEB-SS-10.3, R1 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltu TD ELEMENT:
a.
RFI SQN-586, (09/23/86) b.
RFI SQN-635, (10/15/86) c.
RFI SQN-666,' (10/28/86) i d.
Telephone call from H. A. Mahlman/G. Silver, TVA, to W. Blumer, Bechtel, IOM 309, (10/10/86) e.
Telephone call from H. A. Mahlman, TVA, to W. Blumer, Bechtel, IOM 301, (10/09/86) i f.
Telephone call from H. A. Mahlman, G. Silver, TVA, to W. Blumer, Bechtel, IOM 349, (10/24/86) i 0326D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NtNBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 12 0F 13 APPENDIX A (Cont'd) g.
Telephone call fra W. Bluer, Bechtel, to T. Arnold, Ruskin, IOM 351, (10/27/86) h.
Review of ECTG Files - Docuentation, H. VanStraalen, (10/16/86) 1.
Telephone call fra W. Blumer, Bechtel, to H. A. Hahlman, TVA, IOM 396, (11/10/86) j.
Telephone call fra W. Blumer, Bechtel, to J. T. Herd, TVA Sequoyah, IOM 417, (11/20/86) k.
Telephone call from H. A. Mahlman/R. Denny/J. Anthony, TVA, to W. Blumer, Bechtel, IOM 476, (12/29/86) 03260 - 01 /15/87
k TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 13 0F 13 CATD LIST The following CATb' identifies and provides corrective actions for the findings included in this report:
230.01 SQN 01 (12M7/86) (CAP revised 01M3/87) l I
03260 - 01MS/87
=
nn REFERENCE
- ECPSI20J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 121 FREQUENCY
- REQUEST OFFICE OF NUCLEAR P0HER RUN TIME - 12:57:19 I
DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 12/02/B6 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 25001 ISOLATION DAMPER LATCHING TEST I
S GENERIC KEYNORD A H
APPL STC/NSRS P
KEYNORD B CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYNORD D 3
)
EX 027-001 EN 25001 N HBN YYYY SR HVAC DAMPERS IN THE AUXILLIARY AND C T ESTING T50118 REPORT ONTROL BUILDINGS CONE LOCATION GIVEN NONCONFORMANCE
-HEST END OF CONTROL BUILDING-ELEV 7 HVAC 3
3 15' (T) HERE TESTED UNDER ACTUAL OPE DUCT HORK RATIONG CONDITIONS (USE OF FUSE LINK TO RELEASE DAMPERS), AND THE DAMPER S HOULD NOT LATCH. MANUFACTURER (RU g'
)
SKIN) HAS CONTACTED, AND RECOMMENDED CHANGING OF TEST TO USE A HAND RELE ASE OF DAMPERS, NHICH HAS DONE, AND DAMPERS LATCHED. CI IS CONCERNED TH
.I
)
AT ORIGINAL INTENT OF TEST (TO DEMON STRATE OPERABILITY UNDER ACTUAL COND ITIONS) HAS NOT MET. CONSTRUCTI
)
1 CONCERNS FOR CATEGORY EN SUBCATEGORY 25001 3
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