Information Notice 1999-07, Failed Fire Protection Deluge Valves & Potential Testing Deficiencies in Preaction Sprinkler Systems: Difference between revisions

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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


===OFFICE OF NUCLEAR REACTOR REGULATION===
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001 March 22, 1999 NRC INFORMATION


NOTICE 99-07: FAILED FIRE PROTECTION
WASHINGTON, D.C. 20555-0001 March 22, 1999 NRC INFORMATION NOTICE 99-07: FAILED FIRE PROTECTION DELUGE VALVES AND


DELUGE VALVES AND POTENTIAL
POTENTIAL TESTING DEFICIENCIES IN PREACTION


TESTING DEFICIENCIES
SPRINKLER SYSTEMS
 
IN PREACTION SPRINKLER
 
SYSTEMS


==Addressees==
==Addressees==
All NRC licensees.
All NRC licensees.


Purvose The U.S. Nuclear Regulatory
Purvose
 
Commission (NRC) is issuing this information
 
notice (IN) to alert addressees
 
to test methodologies
 
for fire protection
 
deluge valves that may not adequately
 
demonstrate
 
valve operability.
 
It is expected that recipients
 
will review the information
 
for applicability
 
to their facilities
 
and consider actions, as appropriate, to avoid similar problems.However, suggestions
 
contained
 
in this information
 
notice are not NRC requirements;
therefore, no specific action or written response Is required.Backaround
 
Valves for sprinkler
 
system automatic
 
control (SSAC) are used In fire protection
 
systems that protect areas housing both safety-related
 
and non-safety-related
 
equipment
 
used for fire safe shutdown (FSSD). Many of these systems are used to provide primary fire protection
 
and to meet the requirements
 
of 10 CFR Part 50, Appendix R, Section III.G. Poor design, deficient maintenance, or inadequate
 
testing of SSAC valves and associated
 
solenoid valves can lead to a common-mode
 
failure of the valves to perform their design function of providing
 
adequate and reliable fire protection.
 
This, in turn, can result In fire damage to safe shutdown equipment
 
in the event of a fire.The Model A-4 Multimatic
 
Valve manufactured
 
by Grinnell Is a deluge valve designed specifically
 
for use In fire protection
 
systems. It Is used as a system control valve in deluge, preaction, and special types of fire protection
 
systems and may also provide for actuation
 
of fire alarms when the systems operate.Preaction
 
valves contain connections
 
for monitoring
 
pressure In the diaphragm
 
chamber and in the main water supply, for providing
 
valve drainage and for supplying
 
water to the diaphragm chamber. All required components
 
for these connections
 
are typically
 
supplied by the valve manufacturer
 
as "trim packages'
and are included as part of the Underwriters
 
Laboratories, Inc., (UL) and Factory Mutual, Inc., (FM) certifications
 
of the valves.plt ec' dor i w q9.qojOX 5p03;L ,A/ark Tok 1 K>~K-)IN 99-07 March 22, 1999 Description
 
of Circumstances
 
In the week of March 4, 1996, during surveillance
 
testing of preaction
 
sprinkler
 
systems in the Farley Unit I fire protection
 
system, 5 of 11 SSAC valves (Grinnell
 
Model A4 deluge valves)failed to trip open when water pressure was vented out of the diaphragm
 
chamber. Upon additional
 
testing, the licensee found that several other SSAC valves failed. The licensee's
 
root-cause
 
team, formed after the Initial valve failures, concluded
 
that the diaphragm
 
was sticking to its retainer and push rod disk, that the push rod assembly showed wear (pits and eroded plating), and that the associated
 
solenoid valves were not properly bleeding water pressure out of the diaphragm
 
area.The licensee's
 
root-cause
 
team found that plant personnel
 
were using an abrasive cleaning pad to clean the chrome-plated
 
push rod and the push rod guide in the diaphragm
 
retainers.
 
The team theorized
 
that this activity may have created rust particles
 
that caused the sticking.
 
In like manner, abrasives
 
used to clean the solenoid valves could cause the plunger assembly to stick.Grinnell does not recommend
 
using any abrasives, lubricants, or solvents because they may damage metallic surfaces such as valve seats, and may also damage elastomeric
 
seals.Grinnell recommends
 
cleaning the push rods, guides, and solenoid valves with only soap, water, and clean cloths.The root-cause
 
team also found that the solenoid valves were designed for operating
 
pressures of approximately
 
150 psig (UL maximum rated pressure Is 175 psig), whereas the actual operating
 
pressures
 
often exceeded 150 psig (the licensee determined
 
that fire protection
 
system pressures
 
sometimes
 
went as high as 225 psig). The NRC staff theorizes
 
that the valves may not be able to open against this pressure.Although the root-cause
 
team did not conclusively
 
determine
 
the root cause of the valve failures, the team recommended
 
(1) replacing
 
the diaphragms
 
and solenoid valves, (2) Installing
 
new solenoid valves with a design pressure of 200 psi (and factory tested to 300 psi), (3) flushing the solenoid valve piping and diaphragm
 
chamber when cleaning the solenoids, (4) requiring
 
the use of only soap, water, and a clean cloth when cleaning the solenoid valves, (5) cleaning the solenoid and SSAC valves more frequently, and (6) testing the valves more often -every 12 months Instead of 18 months (in the short term, the licensee Increased
 
testing to every 2, 6, and 12 months after resetting
 
the valves to improve reliability).
 
In subsequent


walkdowns, the team found that the piping for the deluge valve control drain lines had a 318-inch diameter In lieu of the %-Inch diameter line typically
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert


supplied by the manufacturer
addressees to test methodologies for fire protection deluge valves that may not adequately


as part of the trim package listed by the independent
demonstrate valve operability. It is expected that recipients will review the information for


testing laboratory (i.e., UL or FM). The use of the smaller drain line could potentially
applicability to their facilities and consider actions, as appropriate, to avoid similar problems.


inhibit the bleedoff of water from the diaphragm
However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response Is required.


chamber, resulting
Backaround


In Increased
Valves for sprinkler system automatic control (SSAC) are used In fire protection systems that


pressure In the chamber. The staff notes that this restriction, in turn, could prevent the valve from opening.In mid-February
protect areas housing both safety-related and non-safety-related equipment used for fire safe


1998, the licensee performed
shutdown (FSSD). Many of these systems are used to provide primary fire protection and to


a scheduled
meet the requirements of 10 CFR Part 50, Appendix R, Section III.G. Poor design, deficient


surveillance
maintenance, or inadequate testing of SSAC valves and associated solenoid valves can lead to


test on several deluge valves In preaction
a common-mode failure of the valves to perform their design function of providing adequate and


sprinkler
reliable fire protection. This, in turn, can result In fire damage to safe shutdown equipment in


systems. One valve failed to trip, and its push rod had to be forced back manually after completely
the event of a fire.


isolating
The Model A-4 Multimatic Valve manufactured by Grinnell Is a deluge valve designed


and draining the diaphragm
specifically for use In fire protection systems. It Is used as a system control valve in deluge, preaction, and special types of fire protection systems and may also provide for actuation of fire


chamber, closing the main Isolation
alarms when the systems operate.


valve, opening the main drain, and opening the valve faceplate.
Preaction valves contain connections for monitoring pressure In the diaphragm chamber and in


Inspection
the main water supply, for providing valve drainage and for supplying water to the diaphragm


of the rubber diaphragm
chamber. All required components for these connections are typically supplied by the valve


showed a "dimple* near the diaphragm
manufacturer as "trim packages' and are included as part of the Underwriters Laboratories, Inc., (UL) and Factory Mutual, Inc., (FM) certifications of the valves.


chamber supply inlet. The valve had been left in the tripped condition
plt          ec' dor iw q9.qojOX 5p03;L                                ,A/
                        ark                                                                      Tok 1


for about 22 days in May 1997, then It was reset to the
K>~                                      K-)
                                                                            IN 99-07 March 22, 1999


IN 99-07 March 22, 1999 operable, ready position until this surveillance (for about 9 months). As a result of this failure, the licensee tested a sample of six additional
==Description of Circumstances==
In the week of March 4, 1996, during surveillance testing of preaction sprinkler systems in the


valves that had been left In a tripped condition
Farley Unit I fire protection system, 5 of 11 SSAC valves (Grinnell Model A4 deluge valves)
failed to trip open when water pressure was vented out of the diaphragm chamber. Upon


for long periods.One of these valves failed to trip electrically.
additional testing, the licensee found that several other SSAC valves failed. The licensee's


Inspection
root-cause team, formed after the Initial valve failures, concluded that the diaphragm was


of this valve Indicated
sticking to its retainer and push rod disk, that the push rod assembly showed wear (pits and


that the push rod appeared to be misaligned
eroded plating), and that the associated solenoid valves were not properly bleeding water


in the retainer ring slot and some corrosion
pressure out of the diaphragm area.


had formed where the rod slides through the ring. Also, the diaphragm
The licensee's root-cause team found that plant personnel were using an abrasive cleaning pad


was stuck to the face of the push rod. In total, five of the six sample valves and one other valve failed to operate properly.In June 1998, as part of the ongoing testing program, one of the deluge valves was manually actuated from its pull station; It failed to operate. An Investigation
to clean the chrome-plated push rod and the push rod guide in the diaphragm retainers. The


Indicated
team theorized that this activity may have created rust particles that caused the sticking. In like


that the pull station housing had rotated and was preventing
manner, abrasives used to clean the solenoid valves could cause the plunger assembly to stick.


complete travel (i.e., fully open) of the valve handle.After adjusting
Grinnell does not recommend using any abrasives, lubricants, or solvents because they may


the pull station housing, the handle was actuated again and the deluge valve successfully
damage metallic surfaces such as valve seats, and may also damage elastomeric seals.


tripped.The team commissioned
Grinnell recommends cleaning the push rods, guides, and solenoid valves with only soap, water, and clean cloths.


by the licensee to study the problems with the Grinnell A-4 valves concluded
The root-cause team also found that the solenoid valves were designed for operating pressures


that, although the cause and effect are not known, It appears that the failure occurred within a tripped open valve exposed to pressure over time. This exposure appears to cause the valve to fail after being reset. The team noted that the manufacturer
of approximately 150 psig (UL maximum rated pressure Is 175 psig), whereas the actual


does not recommend
operating pressures often exceeded 150 psig (the licensee determined that fire protection


leaving the tripped-open
system pressures sometimes went as high as 225 psig). The NRC staff theorizes that the


valves pressurized
valves may not be able to open against this pressure.


for a significant
Although the root-cause team did not conclusively determine the root cause of the valve


length of time. The root-cause
failures, the team recommended (1) replacing the diaphragms and solenoid valves, (2) Installing


team is also exploring
new solenoid valves with a design pressure of 200 psi (and factory tested to 300 psi),
(3) flushing the solenoid valve piping and diaphragm chamber when cleaning the solenoids,
(4) requiring the use of only soap, water, and a clean cloth when cleaning the solenoid valves,
(5) cleaning the solenoid and SSAC valves more frequently, and (6) testing the valves more


other potential
often - every 12 months Instead of 18 months (in the short term, the licensee Increased testing


failure mechanisms
to every 2, 6, and 12 months after resetting the valves to improve reliability).


of the Grinnell A-4 valve.The staff is continuing
In subsequent walkdowns, the team found that the piping for the deluge valve control drain lines


to monitor the licensee's
had a 318-inch diameter In lieu of the %-Inch diameter line typically supplied by the


investigation
manufacturer as part of the trim package listed by the independent testing laboratory (i.e., UL


into the valve failures.Discussion
or FM). The use of the smaller drain line could potentially inhibit the bleedoff of water from the


The staff noted several potential
diaphragm chamber, resulting In Increased pressure In the chamber. The staff notes that this


problems as a result of this event. First, as discussed
restriction, in turn, could prevent the valve from opening.


above, when deluge valves are left in the tripped condition
In mid-February 1998, the licensee performed a scheduled surveillance test on several deluge


for long periods, the rubber diaphragm
valves In preaction sprinkler systems. One valve failed to trip, and its push rod had to be


is forced against the Inlet side of the diaphragm
forced back manually after completely isolating and draining the diaphragm chamber, closing


chamber. When the valves are reset, the diaphragm
the main Isolation valve, opening the main drain, and opening the valve faceplate. Inspection of


may then bond to the push rod flange, or pinch between the push rod flange and retainer ring, thus keeping the valve from operating
the rubber diaphragm showed a "dimple*near the diaphragm chamber supply inlet. The valve


properly.
had been left in the tripped condition for about 22 days in May 1997, then Itwas reset to the


In the set condition, the rubber diaphragm
IN 99-07 March 22, 1999 operable, ready position until this surveillance (for about 9 months). As a result of this failure, the licensee tested a sample of six additional valves that had been left In a tripped condition for


Is held by water pressure against the flange and retainer and bonding may possibly occur then. Bonding may be more probable In systems using well water or raw river water rather than potable water supplies.The staff also notes that it is a common practice for many plants to keep their preaction sprinkler
long periods.


system deluge valves in a tripped condition
One of these valves failed to trip electrically. Inspection of this valve Indicated that the push rod


for long periods, usually during outages when welding or other activities
appeared to be misaligned in the retainer ring slot and some corrosion had formed where the


are taking place, which Increases
rod slides through the ring. Also, the diaphragm was stuck to the face of the push rod. In total, five of the six sample valves and one other valve failed to operate properly.


the likelihood
In June 1998, as part of the ongoing testing program, one of the deluge valves was manually


of spurious system actuation.
actuated from its pull station; It failed to operate. An Investigation Indicated that the pull station


Grinnell recommends
housing had rotated and was preventing complete travel (i.e., fully open) of the valve handle.


that the valve be reset within 24 hours of any valve operation
After adjusting the pull station housing, the handle was actuated again and the deluge valve


and that the Internal components
successfully tripped.


of valves be cleaned and inspected
The team commissioned by the licensee to study the problems with the Grinnell A-4 valves


after any valve operation.
concluded that, although the cause and effect are not known, It appears that the failure


Second, the use of plant-supplied
occurred within a tripped open valve exposed to pressure over time. This exposure appears to


or plant-designed
cause the valve to fail after being reset. The team noted that the manufacturer does not


trim packages Instead of the UL- or FM-certified
recommend leaving the tripped-open valves pressurized for a significant length of time. The


packages and designs supplied by the valve manufacturer
root-cause team is also exploring other potential failure mechanisms of the Grinnell A-4 valve.


may result In Issues such as undersized
The staff is continuing to monitor the licensee's investigation into the valve failures.


drain lines, which may restrict the bleedoff from the diaphragm
Discussion


chamber and further Inhibit valve actuation.
The staff noted several potential problems as a result of this event. First, as discussed above, when deluge valves are left in the tripped condition for long periods, the rubber diaphragm is


IN 9907 March 22, 1999 Third, an evaluation
forced against the Inlet side of the diaphragm chamber. When the valves are reset, the


by Grinnell concluded
diaphragm may then bond to the push rod flange, or pinch between the push rod flange and


that the valve release mechanism
retainer ring, thus keeping the valve from operating properly. In the set condition, the rubber


may be jamming from the high pressure and surging conditions
diaphragm Is held by water pressure against the flange and retainer and bonding may possibly


In the fire protection
occur then. Bonding may be more probable In systems using well water or raw river water


water supply system. The jamming may be related to deep indentations
rather than potable water supplies.


on the valve latch. Cleaning and Inspection
The staff also notes that it is a common practice for many plants to keep their preaction


of the valves' internal components
sprinkler system deluge valves in a tripped condition for long periods, usually during outages


should reveal these potential
when welding or other activities are taking place, which Increases the likelihood of spurious


problems.While reviewing
system actuation. Grinnell recommends that the valve be reset within 24 hours of any valve


this event, the staff noted that the licensee performs full-flow
operation and that the Internal components of valves be cleaned and inspected after any valve


testing. It is the staff's understanding
operation.


that many plants isolate the deluge valves from the main fire protection
Second, the use of plant-supplied or plant-designed trim packages Instead of the UL- or FM-
certified packages and designs supplied by the valve manufacturer may result In Issues such as


water supply during individual
undersized drain lines, which may restrict the bleedoff from the diaphragm chamber and further


system valve testing. This practice is a potential
Inhibit valve actuation.


testing weakness and may mask the actuation
IN 9907 March 22, 1999 Third, an evaluation by Grinnell concluded that the valve release mechanism may be jamming


problems discussed
from the high pressure and surging conditions Inthe fire protection water supply system. The


herein. With the deluge valve isolated, a limited volume of water is trapped in both the main line and the diaphragm
jamming may be related to deep indentations on the valve latch. Cleaning and Inspection of the


chamber supply line. The water In the diaphragm
valves' internal components should reveal these potential problems.


chamber is slowly bled off until the valve opens. If the diaphragm
While reviewing this event, the staff noted that the licensee performs full-flow testing. It is the


has bonded to the flange, the inlet to the diaphragm
staff's understanding that many plants isolate the deluge valves from the main fire protection


chamber could be partially blocked, Inhibiting (but not preventing)
water supply during individual system valve testing. This practice is a potential testing
valve actuation.


However, during normal operation
weakness and may mask the actuation problems discussed herein. With the deluge valve


with full flow from the diaphragm
isolated, a limited volume of water is trapped in both the main line and the diaphragm chamber


chamber supply line, the primary flow path would follow the supply line to the drain, thus trapping water In the diaphragm
supply line. The water Inthe diaphragm chamber is slowly bled off until the valve opens. If the


chamber and preventing
diaphragm has bonded to the flange, the inlet to the diaphragm chamber could be partially


valve actuation.
blocked, Inhibiting (but not preventing) valve actuation. However, during normal operation with


Note the following
full flow from the diaphragm chamber supply line, the primary flow path would follow the supply


statement
line to the drain, thus trapping water In the diaphragm chamber and preventing valve actuation.


in National Fire Protection
Note the following statement in National Fire Protection Association (NFPA) Standard 25
("Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection


Association (NFPA) Standard 25 ("Standard
Systems," 1995 edition, section 94.3.2.2): lEach deluge or preaction valve shall be trip tested


for the Inspection, Testing, and Maintenance
annually at full flow [emphasis added] In warm weather and In accordance with the


of Water-Based
manufacturer's Instructions.' The valve manufacturer may also have special requirements for


===Fire Protection===
inservice testing. The A-4 valve manufacturer recommends partial flow testing where full-flow
Systems," 1995 edition, section 94.3.2.2):
lEach deluge or preaction


valve shall be trip tested annually at full flow [emphasis
testing is undesirable.


added] In warm weather and In accordance
Another event involving the failure of automatic deluge valves took place at Grand Gulf in 1983, and is discussed in IN 84-16, "Failure of Automatic Sprinkler System Valves to Operate." While


with the manufacturer's
the licensee was performing an operational test of the emergency diesel generator (EDG), a fire


Instructions.'
occurred in the diesel. The automatic deluge valve (6-inch Model C valve manufactured by the
The valve manufacturer


may also have special requirements
Automatic Sprinkler Company of America (ASCO)) failed to open. Approximately 3 months


for inservice
later, a Model C valve In a preaction sprinkler system for the EDG room at Grand Gulf failed to


testing. The A-4 valve manufacturer
operate during a test. In both cases, scoring was found in the actuation weight upper guide


recommends
collar and in the box that encloses the weight guide bushing.


partial flow testing where full-flow testing is undesirable.
Another Instance of repeated failures of a preaction deluge valve occurred In 1997 at Limerick


Another event involving
Unit 1. A Model AD 6-inch deluge valve manufactured by Star Sprinkler, Inc., did not actuate


the failure of automatic
during a surveillance test. The frequency of testing had been increased because of earlier


deluge valves took place at Grand Gulf in 1983, and is discussed
failures caused by suspected mechanical problems. Continued troubleshooting of the valve


in IN 84-16, "Failure of Automatic
failures uncovered a potential voltage mismatch between the deluge valve and the Chemetron


Sprinkler
release control panel, resulting in marginal power available to operate the valve. The Model AD


System Valves to Operate." While the licensee was performing
valves were subsequently replaced with Model AGO valves, also manufactured by Star Sprinkler.
 
an operational
 
test of the emergency
 
diesel generator (EDG), a fire occurred in the diesel. The automatic
 
deluge valve (6-inch Model C valve manufactured
 
by the Automatic
 
Sprinkler
 
Company of America (ASCO)) failed to open. Approximately
 
3 months later, a Model C valve In a preaction
 
sprinkler
 
system for the EDG room at Grand Gulf failed to operate during a test. In both cases, scoring was found in the actuation
 
weight upper guide collar and in the box that encloses the weight guide bushing.Another Instance of repeated failures of a preaction
 
deluge valve occurred In 1997 at Limerick Unit 1. A Model AD 6-inch deluge valve manufactured
 
by Star Sprinkler, Inc., did not actuate during a surveillance
 
test. The frequency
 
of testing had been increased
 
because of earlier failures caused by suspected
 
mechanical
 
problems.
 
Continued
 
troubleshooting
 
of the valve failures uncovered
 
a potential
 
voltage mismatch between the deluge valve and the Chemetron release control panel, resulting
 
in marginal power available
 
to operate the valve. The Model AD valves were subsequently
 
replaced with Model AGO valves, also manufactured
 
by Star Sprinkler.


IN 99-07 March 22, 1999 Related Generic Communications
IN 99-07 March 22, 1999 Related Generic Communications


* IN 84-16, OFailure of Automatic
*       IN 84-16, OFailure of Automatic Sprinkler System Valves to Operate," Issued March 2,
        1984.


Sprinkler
*      IN 92-28, 'inadequate Fire Suppression System Testing,' Issued April 8, 1992.


System Valves to Operate," Issued March 2, 1984.* IN 92-28, 'inadequate
*       IN 97-22, 'Potential for Failure of the OMEGA Series Sprinkler Heads," issued


Fire Suppression
September 22, 1997.


System Testing,'
This information notice requires no specific action or written response. However, addressees
Issued April 8, 1992.* IN 97-22, 'Potential


for Failure of the OMEGA Series Sprinkler
are reminded that they are required to consider Industry-wide operating experience (including


Heads," issued September
NRC information notices) where practical, when setting goals and performing periodic


22, 1997.This information
evaluations under 10 CFR 50.65, 'Requirement for Monitoring the Effectiveness of


notice requires no specific action or written response.
Maintenance at Nuclear Power Plants.! If you have any questions about the information in this


===However, addressees===
notice, please contact one of the technical contacts listed below or the appropriate Office of
are reminded that they are required to consider Industry-wide


operating
Nuclear Reactor Regulation (NRR) project manager.


experience (including
David B. Matthews, Director


NRC information
Division of Regulatory Improvement Programs


notices) where practical, when setting goals and performing
Office of Nuclear Reactor Regulation


periodic evaluations
Technical contacts:    Mark H. Salley, NRR              Robert Caldwell, RII


under 10 CFR 50.65, 'Requirement
301-415-2840                    334-899-3386 E-mail: mxs36-nrc.aov            E-mail: rkcl(&nrc.ciov


for Monitoring
William F. Burton, NRR


the Effectiveness
301-415-2853 E-mail: wfbS-nrc.aov


of Maintenance
Attachment: Ust of Recently Issued NRC Information Notices


at Nuclear Power Plants.! If you have any questions
I
 
about the information
 
in this notice, please contact one of the technical
 
contacts listed below or the appropriate
 
Office of Nuclear Reactor Regulation (NRR) project manager.David B. Matthews, Director Division of Regulatory
 
Improvement
 
===Programs Office of Nuclear Reactor Regulation===
Technical
 
contacts:
Mark H. Salley, NRR Robert Caldwell, RII 301-415-2840
334-899-3386 E-mail: mxs36-nrc.aov
 
E-mail: rkcl(&nrc.ciov
 
William F. Burton, NRR 301-415-2853 E-mail: wfbS-nrc.aov
 
Attachment:
Ust of Recently Issued NRC Information
 
Notices I


IN 99-07 March 22, 1999 Related Generic Communications
IN 99-07 March 22, 1999 Related Generic Communications


* IN 84-16, "Failure of Automatic
*         IN 84-16, "Failure of Automatic Sprinkler System Valves to Operate," issued March 2,
 
                        1984.
Sprinkler
 
System Valves to Operate," issued March 2, 1984.* IN 92-28, "Inadequate
 
Fire Suppression
 
System Testing," issued April 8, 1992.* IN 97-22, "Potential
 
for Failure of the OMEGA Series Sprinkler
 
Heads," issued September
 
22, 1997.This information
 
notice requires no specific action or written response.
 
===However, addressees===
are reminded that they are required to consider industry-wide
 
operating
 
experience (including
 
NRC information


notices) where practical, when setting goals and performing
*          IN 92-28, "Inadequate Fire Suppression System Testing," issued April 8, 1992.


periodic evaluations
*          IN 97-22, "Potential for Failure of the OMEGA Series Sprinkler Heads," issued


under 10 CFR 50.65, "Requirement
September 22, 1997.


for Monitoring
This information notice requires no specific action or written response. However, addressees


the Effectiveness
are reminded that they are required to consider industry-wide operating experience (including


of Maintenance
NRC information notices) where practical, when setting goals and performing periodic


at Nuclear Power Plants." If you have any questions
evaluations under 10 CFR 50.65, "Requirement for Monitoring the Effectiveness of


about the information
Maintenance at Nuclear Power Plants." If you have any questions about the information in this


in this notice, please contact one of the technical
notice, please contact one of the technical contacts listed below or the appropriate Office of


contacts listed below or the appropriate
Nuclear Reactor Regulation (NRR) project manager.


Office of Nuclear Reactor Regulation (NRR) project manager.Original signed by S.F. Newberry FOR David B. Matthews, Director Division of Regulatory
Original signed by


Improvement
S.F. Newberry


===Programs Office of Nuclear Reactor Regulation===
FOR David B. Matthews, Director
Technical


contacts: Mark H. Salley, NRR 301-415-2840
Division of Regulatory Improvement Programs
E-mail: mxs3(&nrc.aov


Robert Caldwell, RII 334-899-3386 E-mail: rkc1a)nrc.aov
Office of Nuclear Reactor Regulation


William F. Burton, NRR 301-415-2853 E-mail: wfbtfinrc.oov
Technical contacts:        Mark H. Salley, NRR                 Robert Caldwell, RII


Attachment:  
301-415-2840                        334-899-3386 E-mail: mxs3(&nrc.aov                E-mail: rkc1a)nrc.aov
List of Recently Issued NRC Information


Notices DOCUMENT NAME: S:MDRPMSEC%9907.IN
William F. Burton, NRR


To receive a copv of this document.
301-415-2853 E-mail: wfbtfinrc.oov


Indicate In the box C=Copy wlo attachment/enclosure
Attachment: List of Recently Issued NRC Information Notices


E=Copy with attachmentlenclosure
DOCUMENT NAME: S:MDRPMSEC%9907.IN


N = No copy OFFICE PECB I j TECHEDITOR
To receive a copv of this document. Indicate In the box C=Copy wlo attachment/enclosure E=Copy with attachmentlenclosure N = No copy


l SPLB II uSPLB lI NAME -WFBurton* .RSanders*
OFFICE          PECB                I          jTECHEDITOR            l       SPLB     II                     uSPLBlI
MHSalley*
I KSWest*DATE I I1QIQQ 1114 /99 3/9/99 319l99-".- I ....--__I__ _-__-_ -... 11 --J OFFICE IC:SPLIB I D:DSSA l (A)C:PECB


I D:DRI II 1 NAME LMarsh* GHolahan*  
NAME         -WFBurton*                       .RSanders*                        MHSalley*            I KSWest*
RDennig* DMatdhlwsr
  DATE


DATE 3/8/99 3/11/99 j 3/15/99 al 1V99 ]OFFICIAL RECORD COPY
- ".-        II I1QIQQ


IN 99-xx March xx, 1999 Related Generic Communications
__I__      _-__-_
                                                    1114 /99
                                                    ....--                    .  3/9/99
                                                                                    .. -
                                                                                                          319l99
                                                                                                        11 - -J


* IN 84-16, "Failure of Automatic
OFFICE                        IC:SPLIB


Sprinkler
I        D:DSSA                    l      (A)C:PECB          I        D:DRI        II      1 NAME              LMarsh*                    GHolahan*                        RDennig*                      DMatdhlwsr


System Valves to Operate," issued March 2, 1984.* IN 92-28, "Inadequate
DATE              3/8/99                    3/11/99                      j 3/15/99                      al1V99                ]
                                                            OFFICIAL RECORD COPY


Fire Suppression
IN 99-xx


System Testing," issued April 8, 1992.* IN 97-22, "Potential
March xx, 1999 Related Generic Communications


for Failure of the OMEGA Series Sprinkler
*        IN 84-16, "Failure of Automatic Sprinkler System Valves to Operate," issued March 2,
                      1984.


Heads," issued September
*        IN 92-28, "Inadequate Fire Suppression System Testing," issued April 8, 1992.


22, 1997.This information
*        IN 97-22, "Potential for Failure of the OMEGA Series Sprinkler Heads," issued


notice requires no specific action or written response.
September 22, 1997.


===However, addressees===
This information notice requires no specific action or written response. However, addressees
are reminded that they are required to consider industry-wide


operating
are reminded that they are required to consider industry-wide operating experience (including


experience (including
NRC information notices) where practical, when setting goals and performing periodic


NRC information
evaluations under 10 CFR 50.65, 'Requirement for Monitoring the Effectiveness of


notices) where practical, when setting goals and performing
Maintenance at Nuclear Power Plants." If you have any questions about the information in this


periodic evaluations
notice, please contact one of the technical contacts listed below or the appropriate Office of


under 10 CFR 50.65, 'Requirement
Nuclear Reactor Regulation (NRR) project manager.


for Monitoring
David B. Matthews, Director


the Effectiveness
Division of Reactor Program Management


of Maintenance
Office of Nuclear Reactor Regulation


at Nuclear Power Plants." If you have any questions
Technical contacts:        Mark H. Salley, NRR              Robert Caldwell, RII


about the information
301-415-2840                      334-899-3386 E-mail: mxs3(&'nrc.gov            E-mail: rkcl (&nrc.gov


in this notice, please contact one of the technical
William F. Burton, NRR


contacts listed below or the appropriate
301-415-2853 E-mail: wfb(nrc.aov


Office of Nuclear Reactor Regulation (NRR) project manager.David B. Matthews, Director Division of Reactor Program Management
Attachment: List of Recently Issued NRC Information Notices


===Office of Nuclear Reactor Regulation===
DOCUMENT NAME: G:\WFB\INDELUG
Technical


contacts: Mark H. Salley, NRR 301-415-2840
To receive a coDY of this document. indicate in the box C=Conv wio attachment/enclosure E=Coov with attachment/endosure N = No codv
E-mail: mxs3(&'nrc.gov


Robert Caldwell, RII 334-899-3386 E-mail: rkcl (&nrc.gov William F. Burton, NRR 301-415-2853 E-mail: wfb(nrc.aov
OFFICE      IPECB                            IT        EDITORlII          SPLBIIISPLB


Attachment:
I      I                      I
List of Recently Issued NRC Information


Notices DOCUMENT NAME: G:\WFB\INDELUG
NAME           WFBurton        HA              RSanders*                  MHSalley    41,/7        Kswest      it),          L-
    DAT ll ,
:D:A:TE              .i .&  4    i~                1/14
                                                    1/49 /99              1 .Iq199
                                                                            1          -Ax"            Il IA E.....................


To receive a coDY of this document.
go./99                          l


indicate in the box C=Conv wio attachment/enclosure
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E=Coov with attachment/endosure
NAME            f IMarsh W        1W          GHolahan                    .j RDeigA-'                    l DMatthews


N = No codv OFFICE IPECB I T EDITOR lII SPLB I I I IISPLB I NAME WFBurton HA RSanders*MHSalley 41,/7 Kswest it ), L-:D:A:TE ll , 4 1/14 /99 1 Iq199 -Ax" go./99 DAT .i .& i~ .1/49 1 I IA E.....................
DATE            _      _1_99              ?I /L199 OFFICIAL RECORD COPY


l l OFFICE C:SPLB lI[ D:DSSA (A)C D:DRPM I NAME f IMarsh W 1W GHolahan .j RDeigA -' l DMatthews DATE _ _1_99 ?I /L199 J13/ 99 1 / /99 OFFICIAL RECORD COPY}}
J13/ 99                       1/ /99}}


{{Information notice-Nav}}
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Latest revision as of 04:49, 24 November 2019

Failed Fire Protection Deluge Valves & Potential Testing Deficiencies in Preaction Sprinkler Systems
ML031040487
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 03/22/1999
From: Matthews D
Division of Regulatory Improvement Programs
To:
References
IN-99-007, NUDOCS 9903180104
Download: ML031040487 (7)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 March 22, 1999 NRC INFORMATION NOTICE 99-07: FAILED FIRE PROTECTION DELUGE VALVES AND

POTENTIAL TESTING DEFICIENCIES IN PREACTION

SPRINKLER SYSTEMS

Addressees

All NRC licensees.

Purvose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert

addressees to test methodologies for fire protection deluge valves that may not adequately

demonstrate valve operability. It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response Is required.

Backaround

Valves for sprinkler system automatic control (SSAC) are used In fire protection systems that

protect areas housing both safety-related and non-safety-related equipment used for fire safe

shutdown (FSSD). Many of these systems are used to provide primary fire protection and to

meet the requirements of 10 CFR Part 50, Appendix R, Section III.G. Poor design, deficient

maintenance, or inadequate testing of SSAC valves and associated solenoid valves can lead to

a common-mode failure of the valves to perform their design function of providing adequate and

reliable fire protection. This, in turn, can result In fire damage to safe shutdown equipment in

the event of a fire.

The Model A-4 Multimatic Valve manufactured by Grinnell Is a deluge valve designed

specifically for use In fire protection systems. It Is used as a system control valve in deluge, preaction, and special types of fire protection systems and may also provide for actuation of fire

alarms when the systems operate.

Preaction valves contain connections for monitoring pressure In the diaphragm chamber and in

the main water supply, for providing valve drainage and for supplying water to the diaphragm

chamber. All required components for these connections are typically supplied by the valve

manufacturer as "trim packages' and are included as part of the Underwriters Laboratories, Inc., (UL) and Factory Mutual, Inc., (FM) certifications of the valves.

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IN 99-07 March 22, 1999

Description of Circumstances

In the week of March 4, 1996, during surveillance testing of preaction sprinkler systems in the

Farley Unit I fire protection system, 5 of 11 SSAC valves (Grinnell Model A4 deluge valves)

failed to trip open when water pressure was vented out of the diaphragm chamber. Upon

additional testing, the licensee found that several other SSAC valves failed. The licensee's

root-cause team, formed after the Initial valve failures, concluded that the diaphragm was

sticking to its retainer and push rod disk, that the push rod assembly showed wear (pits and

eroded plating), and that the associated solenoid valves were not properly bleeding water

pressure out of the diaphragm area.

The licensee's root-cause team found that plant personnel were using an abrasive cleaning pad

to clean the chrome-plated push rod and the push rod guide in the diaphragm retainers. The

team theorized that this activity may have created rust particles that caused the sticking. In like

manner, abrasives used to clean the solenoid valves could cause the plunger assembly to stick.

Grinnell does not recommend using any abrasives, lubricants, or solvents because they may

damage metallic surfaces such as valve seats, and may also damage elastomeric seals.

Grinnell recommends cleaning the push rods, guides, and solenoid valves with only soap, water, and clean cloths.

The root-cause team also found that the solenoid valves were designed for operating pressures

of approximately 150 psig (UL maximum rated pressure Is 175 psig), whereas the actual

operating pressures often exceeded 150 psig (the licensee determined that fire protection

system pressures sometimes went as high as 225 psig). The NRC staff theorizes that the

valves may not be able to open against this pressure.

Although the root-cause team did not conclusively determine the root cause of the valve

failures, the team recommended (1) replacing the diaphragms and solenoid valves, (2) Installing

new solenoid valves with a design pressure of 200 psi (and factory tested to 300 psi),

(3) flushing the solenoid valve piping and diaphragm chamber when cleaning the solenoids,

(4) requiring the use of only soap, water, and a clean cloth when cleaning the solenoid valves,

(5) cleaning the solenoid and SSAC valves more frequently, and (6) testing the valves more

often - every 12 months Instead of 18 months (in the short term, the licensee Increased testing

to every 2, 6, and 12 months after resetting the valves to improve reliability).

In subsequent walkdowns, the team found that the piping for the deluge valve control drain lines

had a 318-inch diameter In lieu of the %-Inch diameter line typically supplied by the

manufacturer as part of the trim package listed by the independent testing laboratory (i.e., UL

or FM). The use of the smaller drain line could potentially inhibit the bleedoff of water from the

diaphragm chamber, resulting In Increased pressure In the chamber. The staff notes that this

restriction, in turn, could prevent the valve from opening.

In mid-February 1998, the licensee performed a scheduled surveillance test on several deluge

valves In preaction sprinkler systems. One valve failed to trip, and its push rod had to be

forced back manually after completely isolating and draining the diaphragm chamber, closing

the main Isolation valve, opening the main drain, and opening the valve faceplate. Inspection of

the rubber diaphragm showed a "dimple*near the diaphragm chamber supply inlet. The valve

had been left in the tripped condition for about 22 days in May 1997, then Itwas reset to the

IN 99-07 March 22, 1999 operable, ready position until this surveillance (for about 9 months). As a result of this failure, the licensee tested a sample of six additional valves that had been left In a tripped condition for

long periods.

One of these valves failed to trip electrically. Inspection of this valve Indicated that the push rod

appeared to be misaligned in the retainer ring slot and some corrosion had formed where the

rod slides through the ring. Also, the diaphragm was stuck to the face of the push rod. In total, five of the six sample valves and one other valve failed to operate properly.

In June 1998, as part of the ongoing testing program, one of the deluge valves was manually

actuated from its pull station; It failed to operate. An Investigation Indicated that the pull station

housing had rotated and was preventing complete travel (i.e., fully open) of the valve handle.

After adjusting the pull station housing, the handle was actuated again and the deluge valve

successfully tripped.

The team commissioned by the licensee to study the problems with the Grinnell A-4 valves

concluded that, although the cause and effect are not known, It appears that the failure

occurred within a tripped open valve exposed to pressure over time. This exposure appears to

cause the valve to fail after being reset. The team noted that the manufacturer does not

recommend leaving the tripped-open valves pressurized for a significant length of time. The

root-cause team is also exploring other potential failure mechanisms of the Grinnell A-4 valve.

The staff is continuing to monitor the licensee's investigation into the valve failures.

Discussion

The staff noted several potential problems as a result of this event. First, as discussed above, when deluge valves are left in the tripped condition for long periods, the rubber diaphragm is

forced against the Inlet side of the diaphragm chamber. When the valves are reset, the

diaphragm may then bond to the push rod flange, or pinch between the push rod flange and

retainer ring, thus keeping the valve from operating properly. In the set condition, the rubber

diaphragm Is held by water pressure against the flange and retainer and bonding may possibly

occur then. Bonding may be more probable In systems using well water or raw river water

rather than potable water supplies.

The staff also notes that it is a common practice for many plants to keep their preaction

sprinkler system deluge valves in a tripped condition for long periods, usually during outages

when welding or other activities are taking place, which Increases the likelihood of spurious

system actuation. Grinnell recommends that the valve be reset within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any valve

operation and that the Internal components of valves be cleaned and inspected after any valve

operation.

Second, the use of plant-supplied or plant-designed trim packages Instead of the UL- or FM-

certified packages and designs supplied by the valve manufacturer may result In Issues such as

undersized drain lines, which may restrict the bleedoff from the diaphragm chamber and further

Inhibit valve actuation.

IN 9907 March 22, 1999 Third, an evaluation by Grinnell concluded that the valve release mechanism may be jamming

from the high pressure and surging conditions Inthe fire protection water supply system. The

jamming may be related to deep indentations on the valve latch. Cleaning and Inspection of the

valves' internal components should reveal these potential problems.

While reviewing this event, the staff noted that the licensee performs full-flow testing. It is the

staff's understanding that many plants isolate the deluge valves from the main fire protection

water supply during individual system valve testing. This practice is a potential testing

weakness and may mask the actuation problems discussed herein. With the deluge valve

isolated, a limited volume of water is trapped in both the main line and the diaphragm chamber

supply line. The water Inthe diaphragm chamber is slowly bled off until the valve opens. If the

diaphragm has bonded to the flange, the inlet to the diaphragm chamber could be partially

blocked, Inhibiting (but not preventing) valve actuation. However, during normal operation with

full flow from the diaphragm chamber supply line, the primary flow path would follow the supply

line to the drain, thus trapping water In the diaphragm chamber and preventing valve actuation.

Note the following statement in National Fire Protection Association (NFPA) Standard 25

("Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection

Systems," 1995 edition, section 94.3.2.2): lEach deluge or preaction valve shall be trip tested

annually at full flow [emphasis added] In warm weather and In accordance with the

manufacturer's Instructions.' The valve manufacturer may also have special requirements for

inservice testing. The A-4 valve manufacturer recommends partial flow testing where full-flow

testing is undesirable.

Another event involving the failure of automatic deluge valves took place at Grand Gulf in 1983, and is discussed in IN 84-16, "Failure of Automatic Sprinkler System Valves to Operate." While

the licensee was performing an operational test of the emergency diesel generator (EDG), a fire

occurred in the diesel. The automatic deluge valve (6-inch Model C valve manufactured by the

Automatic Sprinkler Company of America (ASCO)) failed to open. Approximately 3 months

later, a Model C valve In a preaction sprinkler system for the EDG room at Grand Gulf failed to

operate during a test. In both cases, scoring was found in the actuation weight upper guide

collar and in the box that encloses the weight guide bushing.

Another Instance of repeated failures of a preaction deluge valve occurred In 1997 at Limerick

Unit 1. A Model AD 6-inch deluge valve manufactured by Star Sprinkler, Inc., did not actuate

during a surveillance test. The frequency of testing had been increased because of earlier

failures caused by suspected mechanical problems. Continued troubleshooting of the valve

failures uncovered a potential voltage mismatch between the deluge valve and the Chemetron

release control panel, resulting in marginal power available to operate the valve. The Model AD

valves were subsequently replaced with Model AGO valves, also manufactured by Star Sprinkler.

IN 99-07 March 22, 1999 Related Generic Communications

  • IN 84-16, OFailure of Automatic Sprinkler System Valves to Operate," Issued March 2,

1984.

  • IN 92-28, 'inadequate Fire Suppression System Testing,' Issued April 8, 1992.
  • IN 97-22, 'Potential for Failure of the OMEGA Series Sprinkler Heads," issued

September 22, 1997.

This information notice requires no specific action or written response. However, addressees

are reminded that they are required to consider Industry-wide operating experience (including

NRC information notices) where practical, when setting goals and performing periodic

evaluations under 10 CFR 50.65, 'Requirement for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants.! If you have any questions about the information in this

notice, please contact one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

David B. Matthews, Director

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contacts: Mark H. Salley, NRR Robert Caldwell, RII

301-415-2840 334-899-3386 E-mail: mxs36-nrc.aov E-mail: rkcl(&nrc.ciov

William F. Burton, NRR

301-415-2853 E-mail: wfbS-nrc.aov

Attachment: Ust of Recently Issued NRC Information Notices

I

IN 99-07 March 22, 1999 Related Generic Communications

  • IN 84-16, "Failure of Automatic Sprinkler System Valves to Operate," issued March 2,

1984.

  • IN 92-28, "Inadequate Fire Suppression System Testing," issued April 8, 1992.
  • IN 97-22, "Potential for Failure of the OMEGA Series Sprinkler Heads," issued

September 22, 1997.

This information notice requires no specific action or written response. However, addressees

are reminded that they are required to consider industry-wide operating experience (including

NRC information notices) where practical, when setting goals and performing periodic

evaluations under 10 CFR 50.65, "Requirement for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants." If you have any questions about the information in this

notice, please contact one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

Original signed by

S.F. Newberry

FOR David B. Matthews, Director

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contacts: Mark H. Salley, NRR Robert Caldwell, RII

301-415-2840 334-899-3386 E-mail: mxs3(&nrc.aov E-mail: rkc1a)nrc.aov

William F. Burton, NRR

301-415-2853 E-mail: wfbtfinrc.oov

Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: S:MDRPMSEC%9907.IN

To receive a copv of this document. Indicate In the box C=Copy wlo attachment/enclosure E=Copy with attachmentlenclosure N = No copy

OFFICE PECB I jTECHEDITOR l SPLB II uSPLBlI

NAME -WFBurton* .RSanders* MHSalley* I KSWest*

DATE

- ".- II I1QIQQ

__I__ _-__-_

1114 /99

....-- . 3/9/99

.. -

319l99

11 - -J

OFFICE IC:SPLIB

I D:DSSA l (A)C:PECB I D:DRI II 1 NAME LMarsh* GHolahan* RDennig* DMatdhlwsr

DATE 3/8/99 3/11/99 j 3/15/99 al1V99 ]

OFFICIAL RECORD COPY

IN 99-xx

March xx, 1999 Related Generic Communications

  • IN 84-16, "Failure of Automatic Sprinkler System Valves to Operate," issued March 2,

1984.

  • IN 92-28, "Inadequate Fire Suppression System Testing," issued April 8, 1992.
  • IN 97-22, "Potential for Failure of the OMEGA Series Sprinkler Heads," issued

September 22, 1997.

This information notice requires no specific action or written response. However, addressees

are reminded that they are required to consider industry-wide operating experience (including

NRC information notices) where practical, when setting goals and performing periodic

evaluations under 10 CFR 50.65, 'Requirement for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants." If you have any questions about the information in this

notice, please contact one of the technical contacts listed below or the appropriate Office of

Nuclear Reactor Regulation (NRR) project manager.

David B. Matthews, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Mark H. Salley, NRR Robert Caldwell, RII

301-415-2840 334-899-3386 E-mail: mxs3(&'nrc.gov E-mail: rkcl (&nrc.gov

William F. Burton, NRR

301-415-2853 E-mail: wfb(nrc.aov

Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:\WFB\INDELUG

To receive a coDY of this document. indicate in the box C=Conv wio attachment/enclosure E=Coov with attachment/endosure N = No codv

OFFICE IPECB IT EDITORlII SPLBIIISPLB

I I I

NAME WFBurton HA RSanders* MHSalley 41,/7 Kswest it), L-

DAT ll ,

D:A:TE .i .& 4 i~ 1/14

1/49 /99 1 .Iq199

1 -Ax" Il IA E.....................

go./99 l

OFFICE C:SPLB lI[ D:DSSA (A)C D:DRPM I

NAME f IMarsh W 1W GHolahan .j RDeigA-' l DMatthews

DATE _ _1_99 ?I /L199 OFFICIAL RECORD COPY

J13/ 99 1/ /99


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