ML20214U415
| ML20214U415 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/18/1986 |
| From: | Murphy M, Russell J, Touchstone C TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214G966 | List:
|
| References | |
| 306.01-SQN, 306.01-SQN-R04, 306.01-SQN-R4, NUDOCS 8612090263 | |
| Download: ML20214U415 (9) | |
Text
r-TVA EMPLOYEE CONCERNS REPORT NUMBER:
306.01-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER:
4 I
TITLE: Fire Protection Equipment Works Improperly REASON FOR REVISION:
l Revised to incorporate SRP and TAS comments Revision 1 Revised to incorporate SRP comments and SQN corrective action Revision 2 1
Revised to incorporate SRP comments Revision 3 Revised to incorporate SQN action Revision 4 PRRPARATION PREPARED BY:
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ECSP NANA4tR DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG l
SubcateEory: Fire Protection Element: Fire Protection Equipment Works Improperly l
Report Number:
306.01-SQN Revision 4 IN-85-311-008 Evaluator:
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I.
Fire Protection Equipment Works Improperly This report examines issues related to fire door closure at Sequoyah Nuclear Plant (SQN).
Concern IN-85-311-008 was found valid at Watts Bar Nuclear Plant (WBN) and was determined by the Employee Concern Task Group (ECTG) to be generically applicable to SQN.
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II.
Specific Methodology I-WBN specific concern IN-85-311-008 was evaluated for applicability to SQN.
Interviews with personnel in SQN Mechanical Maintenance (NM)
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Architectural Branch, DNE Regulatory Engineering, and SQN Licensing were conducted.
Reference to historical information reviewed during this evaluation such as Maintenance Requests (MRs), Potential i
Reportable Occurrences (PR0s) and Significant Condition Reports (SCRs) is listed in Section VI.
Applicable Technical Specifications, surveillance instructions (sis), and WBN 306.01 concern report are also listed in Section VI.
Concern IN-85-311-008 reads as follows:
IN-85-311-008 The fire door A143, 20 feet outside control room entrance is habitually open despite safety signs that l
require door to be closed at all times. Installing a self-closing mechanism was expressed as being the I
solution to this concern.
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Watts Bar ECTG Report 306.01 (Reference 1) was reviewed to determine information that may be relevant to concern evaluation at SQN.
The L
root cause problem at WBN had been a failure to adequately address the L
requirement for closure mechanisms to close doors against airflow and 8
to accurately specify the equipment to be installed in applicable outp'ut documents. This root cause was identified also in a report to the NRC (Reference-2).
Using this root cause as a basis, the evaluation was performed at SQN.
III. Findings A review of seventy-four (74) MRs written on door closer mechanisms over the past 1.5 years was conducted. Sixty-eight (68) of these MEs addressed closers on fire doors, many of which were written to resolve i
deficiencies or satisfy criterion in Surveillance Instruction (SI)-261 (Reference 3), " Visual Inspection of Technical Specification Fire Doors on a Periodic Basis." Proper operation of the door was usually achieved with adjustment of the closer mechanism or in a few cases,
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replacement of the closer' mechanism.
No work was required for three MRs on fire doors due to satisfactory completion of SI-261 requirements. The MR search revealed no mention of incorrectly installed door checks.
However, in three cases, the MRs specified a t
replacement closer with model number different from that perscribed by door schedule (Reference 4).
Page 1 of 6 v
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Revision 4 Door A143 was coincidently, one of these situations. MR A231170 (Reference 5) installed a Russwin model 500 HM-4-R11 (strength 4) closer mechanism for door A143 yet the door schedule requires model 1-2820.
Information fror design personnel indicates the latter closer mechanism is adjustable with eteength range from one to six.
The requirement for' adjustable closer mechanisms is that the field should adjust for best operation; hence, a strength four door closer mechanism is adequate since the door functions properly.
Door A167 work request (WR) B112025 (Reference 6) installed a model 2820 closer mechanism where door schedule requires model 1-2810-6.
Door A92, MR A231168 (Reference 7) specifies a door closer mechanism with strength size "4" yet door schedule indicates model 500N2R which is a size "2".
Door A42, WR B131299 (Reference 8) specifies a door closer mechanism l
"500 Mark III" but falls to state model number, hence conformance with
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door schedule could not be verified.
These configuration deficiencies appear to be in the conservative direction as closer mechanisms with greater strength than specified by schedule were installed.
Interviews with an engineer and engineering associate in SQN NR revealed no known problems with door A143 concerning incorrect door closer installation. However, one individual did realize the possibility of installed closer mechanisms which are not specified on drawings, yet believed that such non-conformances would always be in the conservative direction - he knew of no examples in the plant.
Discussion with a former employee in SQN MN revealed that non-conformances with door schedules have occurred in the past at SQN.
He noted that door schedules depict key numbers, but frequently these j.
do not match actual keys held by plant personnel. He felt items on the door schedule should be either complied with or removed from the schedule if not important.
Both SQN MM persons interviewed noted door closure problems because of i
l differential air pressure (d/p) across doors frequently occurs at SQN. Transients such as removing fans from service and alteration of flow paths can result in many variations in plant ventilation. They were aware of no current efforts in Division of Nuclear Engineering (DNE) to address such problems but felt this issue needed some attention.
MM noted that presently problems are examined on a case by case basis usually initiated at the MR level. Problems which are not resolved at the MR level are pursued with aid of design persoiral using the field change request (FCR) process. The Potential Reportable Occurrence (PRO) 1-86-157, (Reference 9), is one example.
Fire door A-194 failed to meet acceptance criteria in SI-261 (Reference 3) by not closing against a differential pressure that occurs during a correct ventilation lineup. An FCR was written to change the swing of the door and thus correct the problem. PRO 1-86-185 (Reference 10) documents a similiar problem with fire door A-159.
Corrective action taken was to Page 2 of 6
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h Revision 4 order and install a different model door closer mechanism as coordinated by DNE. The MM ent?neer noted that problems with door closure would likely persist based on past performance. He commented that SQN is bound to fire codes, National Fire Protection Association (NFPA) - 80, to ensure doors are self-closing.
An individual in the. architectural branch (DNE) was contacted on the above matters and agreed ventilation variation can cause problems.
However, closer mechanisms are designed for different strengths and may even be coupled for greater power but not to exceed fifty pounds as measured at the door knob for life safety reasons. He noted that i
closers may usually be adjusted for small variations-in strength requirements. However, changes in ventilation lineup and non-steady conditions may result in door closure difficulties. A significant condition report (SCR)-SQNAB8601 RO (Reference 11) documents failure of some fire doors to close against differential pressure stating that i
sizing of door closer mechanisms during design phase did not consider the force on doors due to actual pressures which may vary from design pressures. According to design personnel, forces due to design pressures were also not considered when sizing door closer mechanisms.
The architect agreed that DNE should perform an analysis to. determine closer strength for doors which have a d/p across them by design. This analysis should be similar to that completed for WBN (Reference 12).
The engineering report (Reference 13) which addresses the SCR states that adequate procedures are in effect (Physi-13, SI-261) to identify i
fire doors unable to close and latch after each use.
For these j
problems once identified, the action statement of the Technical Specification limiting condition for operation (LCO)-3.7.12 j
(Reference 14) will be compiled with. The engineering report suggests the following corrective action:
t SI-261 should be revised to require a normal ventilation lineup and a building pressure in the required range prior to and during performance. This will ensure a consistent i
baseline each time the SI is performed. Any fire door closure problems due to off-normal lineups should be promptly reported, and the action requirement of LCO 3.7.12 should be complied with. An NR should be written anytime a fire door is nonfunctional to correct the problem.
Prior to working the MR, vintilation should again be verified to be in a normal lineup with auxiliary building pressure in the required range. If the problem cannot be corrected by closure adjustment, Engineering Test should be notified to determine if excessive d/p, due to either a ventilation imbalance or design deficiency, is the root cause.
If a ventilation labalance exists Engineering Test should correct I
this, otherwise a DCR should be written to ensure door
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closure.
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t Revision 4 According to DNE, the SCR (Reference 11) will be revised to agree with the above corrective action. A review of the Tech Spec requirements at SQN for fire doors (Reference 14) indicates SI-261 is to be performed once per 18 months.
Fire doors are to be functionh_1 at all times.
f This SI presently requires a check of the general condition and appearance of the door closer mechanism. It also requires a functional test, and a check of the fusible link.
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Conclusion L
m.
'4 The scope of the concern evaluation as stated in section Ifor this yn I
report was limited to fire door closer mechanismc. Using this basis l
the concern is not valid at SQN since door A143 has an adequate i
self-closing mechanism and no specific closure problems'with door A143 lR1 could be found.
Evidence of non-conformity with. drawings was found and I
4 thus SQN may need to perform a survey cimiliar to that done at'WBN to '
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determine actual closer mechanisms in place (Reference 15).
Though some i doors may have closers installed which differ from door hardware l
specifications, deviations appear in the conservative direction.
For I
some plant doors, closure is a problem due to differential presisure.
' l R1 Implementation of the corrective action specified in Refe*;ence 13 and,
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discussed above will identify doors with d/p closure problems.
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should perform an analysis to determine closer strength for doors which I
are designed to have a differential pressure across them. No nuclear i
i safety-related deficiencies were found during this investigation.
l IV.
Root Cause 1
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No root cause is identified for the specific concern.
- However, l'
regarding d/p closure problems, the evaluation indicates design
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y personnel did not address the requirement for the closer mechanism to close fire doors against airflow.
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I No attempt was made to evaluate drawing non-conformities hene no root I
cause is given for this deficiency.
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V.
Generic Applicability l
Reference 1 evaluates concern IN-85-311-00.8 at'WBN.
Similar evaluation should be performed at Browns Ferry and Bellefonte Nuclear Plants, l
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9 Revision 4 VI.
References' 1.
TVA - Watts Bar Nuclear Plant (WBN) - ECTG Report Number 306.01, lR1
" Fire Protection Equipment Works Improperly," Operations CEG, Draft 2.
Memorandum to J. W. Hufman, Manager Licensing and Risk Protection, from J. A. Raulston, Chief Nuclear Engineer, "10 CFR 50.55(e) Report No. 1 (Final) - NCR-6306," January 3, 1986, B45'860103 258 3.
SQN Surveillance Instruction (SI) - 261, " Visual Inspection of Technical Specification Fire Doors on a Periodic Basis,"
Revision 9, July 16, 1986 4.
SQN Drawing Series 46W454-1 (R29), -2 (R13), -3 (R26), -4 (R37),
-5 (R15)
-6 (R30), -7 (R34), " Architectural Door and Hardware Schedule" 5.
SQN Maintenance Request (MR) - A231170 Fire Door - A143, May 22, 1986 6.
SQN Work Request (WR) - B112025 Fire Door - A167 May 6, 1986 7.
SQN Maintenance Request (MR) - A231168 Fire Door - A92, August 24, 1985 8.
SQN Work Request (WR) - B131299, Fire Door A42, July 18, 1986 9.
SQN Potential Reportable Occurrence (PRO) 1-86-157, July 8, 1986 10.
SQN Potential Reportable Occurrence (PRO) 1-86-185 July 28, 1986 11.
SQN Significant Condition Report (SCR) - SQNAB8601 Revision 0, February 7, 1986, RIMS B61 860210 003 12.
OR Calculations, " Fire Door Closer Strength Calculations Where Room Air Pressure Resists Closing," WBN, February 11, 1986, RIMS B26 860211 083 i
13.
SQN Ragineering Report for SCR-SQNAB8601 R0, February 12, 1986, RIMS S01 860219 857 14.
SQN Technical Specifications, 3/4.7.12 " Fire Barrier Penetrations," Ul, Amendment 36, November 23, 1984 15.
WBN Maintenance Request (MR) - A477939 Page 5 of 6
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i Revision 4 VII.
Inmediate and Long-Term Corrective Actions SQN wiil track drawing deviationseon 46W454 series hardware 1.
i schedules under AI-25, "As Constructed" Drawing Deviation.
l Attachment D, Deviation No. 86DD688. A comparison of existing i
hardware [ DOOR CLOSERS) and' key codes to drawings to correct IR2 additional discrepancies will be done under this same deviation.
I P2 classification is 222211062 and 222211134. Corrective Action lR4
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Tracking Document (CATD) 30601-SQN-002 tracks this item.
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l CATD-OP 30601-001-SQM has been issued to track I
completion / implementation of SQN Significant Condition Report (SCR)
SQNAB8601 which addresses issues related to differential air
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REFEREllCE
- ECPS120J-ECPS121C FREQUENCY
- REQUESI TENNESSEE VALLEY AUTHORITY e
ONP - ISSS - RHM CFFICE OF NUCLEAR P0HER PAGE EMPLOYEE CONCERJ PROGRAM SYSTEM (ECPS)
RUN " TIME * '
LIST OF EMPLOYEE CONCERN INFORMATION RUN DATE CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30601 FIRE PROTECTION EQUIPMENT HORKS IMPROPERLY S
GENERIC H
APPL QTC/NSRS P
KEYNORD A CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD B NUMBER CAT CAf D LOC FLQB REPORT R
DESCRIPTION KEYHORD C KEYHORD IN 311-008 OP 30601 N HBN YYYY IN-85-311-008 THE FIRE DOOR A143,-20' OUTSIDE CONT SAFETY PROGRAI T50021 REPORT ROL ROOM EN1RANCE IS HABITUALLY OPEN PROCEDURES DESPITE SAFETY SIGNS THAT REQUIRE D GENERAL 00R TO BE CLOSED.ST ALL TIMES.
INST FIRE PR(
ALLING A SELF-CLOSING MECHANISM HAS EXPRESSED AS BEING THE SOLUTION TO T HIS CONCERN.
1 C0!!CERNS FOR CATEGORY OP SUBCATEGORY 30601 l
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