ML18093B197

LER 88-016-00:on 880909,twenty-nine Air Balance Model 119 Dampers in Units 1 & 2 Fire Areas Not Surveilled as Required by Tech Spec.Caused by Inadequate Administrative Controls. Engineers Counseled & Requirements reviewed.W/881004 Ltr

ML18093B197
Person / Time
Site:	Salem
Issue date:	10/04/1988
From:	MILLER L K, POLLACK M J Public Service Enterprise Group
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-88-016-02, LER-88-16-2, NUDOCS 8810120307
Download: ML18093B197 (6)

Text

• NllC Form311 IM3) U.I, NUCLEAll llEGULATOllY COflWllllON APl'AOVED OMI NO. 311111-4104 LICENSEE EVENT REPORT (LER) EXl'IRES:

11/31115 I DOCKET NUM9Ell (2) I """"' I'll 0 I 5 I 0 I 0 I 0 I 2 17 I 2 1 I OF 0 I 5 FACILITY NAME 111 Sa1em Generating Station -Unit 1 TITLE l*I T. s. Survei11ance 4.7.11 Ron-Comp1iance

-Fire Pampers Rot Survei11ed

-Inad. Admin. Con EVENT DATE (II) LEA NUMDEll Ill llEl'OAT DATE (7) OTHEll FACILITIES INVOLVED Ill MONTH QAY YEAR YEAR ]@

ft MONTH DAY YEAR FACILITY NAMES DOCKET NUMllERISI Sa1em -Unit 2 o 1 s Io I o I o 13 1 111 nlgolg a a ale -ol1IG-olo1lo ol4ala OPlRATING MODE tel THll llEl'OAT II IUIMITTED l'UlllUANT TO THE REQUlllEMENTI OF 10 CFll §: (Ch<<:lt one or man of Ill* followln11J (11) ..,.. ______ ............

__. 21U02(bl 20.-lcl I0,7311oll2llM

---I0.*1*1111 ll0.731oll21M LEVEL ----731.71lb) 73..71.lcl POWEii I N/A 20.G(1111 Ill) 1101 I I 20.ac.11111u1 11111=::::::::

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-OTHEll ($/>>c/fymAb,,,.,r l>>low ond In Toxr, NRC Fann 366A) --1111.731(11121(111 I0.731Cell211wfllllll

--1111.7:11(81121 (Ill) 1111.731(111211*1 LICENIEE CONTACT FOR THll LEI! (12) NAME AREA CODE M. J. _Po11ack -LER Coordinator COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DEICAllED IN THll llEl'OAT (1311 CAUSE SYSTEM COMPONENT I I I I I I I I TURER I I I SYSTEM I I -COMPONENT MANUFAC-TUR ER I I I I I I I I I I I I TELEPHONE NUMBER EXPECTED IUJIPLEMENTAL llEl'ORT EXl'ECTED 1141 MONTH DAY SUllMISSION DATE (151 kl NO n YES (If ya, comp-EXPECTED SU6MISSION DATE) I I On September 9, 1988, it was identified, by Site Protection personnel, that "twenty-nine ( 29) Air Balance Model #119 dampers, in several Unit 1 and Unit 2 fire areas, have never been surveilled as required by Technical Specification 4.7.11. The apparent root cause of this event has been attributed to inadequate administrative control. The dampers although shown on controlled mechanical arrangement drawings, did not have unique equipment identifier tag numbers. Consequently, the dampers were not identified on the equipment lists used as a reference to prepare surveillance procedures.

Subsequently, -the damper surveillance requirement was missed. The surveillance for the subject dampers was completed.

All dampers successfully passed. The Site Protection staff engineer(s) have been counseled on* the use of "Incident Report/Licensee Event Report Program".

Engineering is reviewing fire protection programmatic requirements to ensure timely dissemination of information to departments which may be affected.

As part of the Fire Protection Improvement -program, a design change will be made to have the appropriate P&ID-schematics identify and number (i.e., component I.D.) the dampers. NAC Form 311 (Ml) 8810120307" 881004 *>s .8 PDR ADOCK 05000272 PNU I

• LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station Unit 1 DOCKET NUMBER 5000272 LER NUMBER 88-016-00 PAGE 2 of 5 PLANT AND SYSTEM IDENTIFICATION:

Westinghouse

-

Water Reactor Energy Industry Identification System (EIIS) codes are identified in the text as {xx} IDENTIFICATION OF OCCURRENCE:

Technical Specification Surveillance 4.7.11 Non-compliance; Fire Dampers Not Surveilled Due To Inadequate Design Review Event Date: 9/09/88 Report Date: 10/04/88 This report was initiated by Incident Report Nos.88-379 and 88-380. CONDITIONS PRIOR TO OCCURRENCE:

N/A DESCRIPTION OF OCCURRENCE:

On September 9, 1988, it was identified, by Site Protection personnel, that twenty-nine (29) Air Balance Model #119 dampers, 1n several Unit 1 and Unit 2 fire areas, have never been surveilled as required by Technical Specification 4.7.11. Technical Specification 3 .. 7 .11 states: "All fire penetrations (including cable penetration barriers, fire doors and fire dampers), in fire zone boundaries, protecting safety related areas shall be functional." Technical Specification Action Statement 3.7.11.a states: "With one or more of the above required fire barrier penetrations non-functional, within one hour either establish a continuous fire watch on at least one side of the affected penetration, or

• verify* the OPERABILITY of fire detectors on at least one side of .the non-functional fire barrier and establish an hourly fire watch patrol. Restore the non-functional fire barrier penetration(s) to functional status within 7 days or, in lieu of any other report required by Specification 6.9.1, prepare and s_ubmi t a Special Report to the Commission pursuant to Specification

6.9.2 within

the next {30) days outlining the action taken, the cause of the 'non-functional penetration and . plans and schedule for restoring the fire barrier penetration (s) -; to functional status." Technical Specification Surveillance states: *"Each of the above required penetration fire barriers shall be

• LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station Unit 1 DOCKET NUMBER 5000272 LER NUMBER 88-016-00 PAGE 3 of 5 DESCRIPTION OF OCCURRENCE: (cont'd) verified to be functional:

a. At least once per 18 months by a visual inspection, and b. Prior to returning a penetration fire barrier to functional status following repairs or maintenance by the performance of a visual inspection of the affected penetration fire barrier(s}." Note -Unit 1 Technical Specification 3.7.11 differs from Unit 2. The Unit 1 words "functional" and "non-functional" are replaced by the words "OPERABLE" and "inoperable" respectively.

The fire areas in which the dampers were not surveilled include: Unit Area Number of Dampers 1 Battery Rooms 8 1 84' El. Switchgear Room 7 1 #11 Diesel Fuel Oil Storage Tank Room 1 1 #12 Diesel Fuel Oil Storage Tank Room 1 2 Battery Rooms 9 2 84' El. Switchgear Room 1 .2 #21 Diesel Fuel Oil Storage Tank Room 1 2 #22 Diesel Fuel Oil Storage Tank Room 1 APPARENT CAUSE OF OCCURRENCE:

-The apparent root cause of this event has been attributed to inadequate administrative control. The dampers although shown on controlled mechanical arrangement drawings, did not have unique equipment identifier tag numbers. Consequently, the dampers were not identified on the equipment lists used as a reference to surveillance'procedures.

Subsequently,:the damper surveillance requirement was missed. ANALYSIS OF OCCURRENCE:

The fire barrier penetration visual surveillance ensures the functional integrity of barrier penetrations, including dampers, is not violated.

The functional integrity of fire barriers ensures fires will be confined or adequately from spreading to adjacent portions of the facility.

• This design feature minimizes the ;,'

• LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station DOCKET NUMBER LER NUMBER PAGE 88-016-00 4 of 5 ANALYSIS OF OCCURRENCE: (cont'd) possibility of a single fire involving several areas of the facility prior to detection and extinguishment.

The penetration fire barriers are a passive element in the facility fire protection program. However, because the fire barrier dampers have not been inspected within the 18 month period as per Technical Specification Surveillance 4.7.11 this event is reportable in accordance with Code of Federal Regulations lOCFR 50.73(a) (2) (i) (B). An hourly fire watch patrol, for the fire barriers containing these dampers, had been previously established due to other fire protection and lOCFR 50, Appendix R concerns.

This fire watch complies with the action required per Technical Specification Action Statement 3.7.11.a.

Investigation of this event revealed that in August 1987, field walkdowns, conducted by engineering, were performed to evaluate fire area boundaries in support of revision to lOCFR 50 Appendix R exemption requests.

One of the results of this walkdown recognized these dampers as being a component of the fire barrier(s).

The scope of the review, however, did not include surveillance compliance thus the deficiency was not identified at that time. Coincidentally, in the spring of 1988 of procedure MlO-SST-031-1, "18 Month Fire Damper Visual Inspection", was initiated to address newly installed dampers. Other dampers (without a fusible link) have historically been functionally tested. The Site Protection staff engineer aware of the subject dampers through detailed review of the mechanical arrangement drawings.

The Site Protection staff engineer, however, did not recognize the_ potential reportability.

In August 1988, ,the procedure was approved by the Station Operations Review Committee At that SORC meeting, it was questioned whether these dampers have been surveilled historically*.

Investigation of the historical records indicated that these dampers have not been surveilled historically.

CORRECTIVE ACTION: The surveillance for the subject dampers was completed.

All dampers successfully passed. The Site Protection staff engineers have been counseled on the use of AP-6, "Incident Report/Licensee Evept Report.Progra*".

Engineering is reviewing fire protection programmatic requirements to ensure timely dissemination of information to departments which may be affected.

• LICENSEE EVENT REPORT (LER) TEXT CONTINUATION Salem Generating Station Unit 1 CORRECTIVE ACTION: (cont'd) DOCKET NUMBER 5000272 LER NUMBER 88-016-00 PAGE 5 of 5 As part of the Fire Protection Improvement Program, a design change will be made to have the appropriate drawings revised to identify and number (i.e., component I.D.) the dampers. MJP:pc SORC Mtg.88-082 General Manager -Salem Operations

• Public Service Electric and Gas Company P.O. Box E Hancocks Bridge, New Jersey 08038 Salem Generating Station U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Dear Sir:

SALEM GENERATING STATION LICENSE NO. DPR-70 DOCKET NO. 50-272 UNIT NO. 1 LICENSEE EVENT REPORT 88-016-00 October 4, 1988 This Licensee Event Report is being submitted pursuant to the requirements of the Code of Federal Regulations

• 1ocFR 50.73(a) (2) (i) (B). This report is required within thirty (30) days of*discovery.

MJP:pc Distribution The Energy People Sincerely yours, L. K. Miller General Salem Operations 95-2189 (11 M) 12-84