ML20062F165

Special Rept 2-90-003 Re fire-rated Assemblies Inoperable W/O Hourly Fire Watch Maintained.Caused by Personnel Error. License Condition 2-90-332 Initiated

ML20062F165
Person / Time
Site:	Hatch
Issue date:	11/15/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2-90-003, 2-90-3, HL-1353, NUDOCS 9011270120
Download: ML20062F165 (7)

Text

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' Georg:a Po*w Company l

_, ., 333 Piedmord Avenue Atlanta Georg.a 30308

. Telephone 404 6?6 3195

. Matrig Address

'o 40 Irwriess Confer Pa4way Post Othce Don 1296 D,rmingham. Alabama 35201 Telephone 205 808-5%1 Iv sontvm en hc svstem W. O. Hairston, til Senior Vrce Present naciear operato" HL-1353 001282 November 15, 1990 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 SPECIAL REPORT 2-90-003 FIRE-RATED ASSEMBLIES IN0PERABLE WITHOUT AN HOURLY FIRE WATCH MAINTAINED RESULTS IN SPECIAL REPORT AS REGUIRED BY FIRE HAZARDS ANALYSIS Gentlemen:

In accordance with the requirements of the Unit 2 Technical Specifications and the Fire Hazards Analysis (FHA), Appendix B, Georgia Power Company is submitting the enclosed Special Report' concerning an event where a fire rated assembly was inoperable without a continuous fire watch.

This event occurred at Plant Hatch - Unit 2.

Sincerely, 1

I id.). V "

W.'G. Hairston, III l

l WTB/et

Enclosure:

SR 50-366/1990-003 c: (See next page.)

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PDR Acco: 05000366

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• Georgial)0Wel a U.S. Nuclear Regulatory Commission November 15, 1990 Page Two c: Georaia Power Company Mr. H. L. Sumner, General Manager - Nuclear Plant Mr. J. D. Heldt, Manager Engineering and Licensing - Hatch NORMS U.S. Nuclear Reaulatory Commission. Washinaton. D.C.

Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch o

i 001282

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ENCLOSURE PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 SPECIAL REPORT 2-90-003 l FIRE-RATED ASSEMBLIES INOPERABLE WITHOUT AN HOURLY L FIRE WATCH MAINTAINED RESULTS IN l i

SPECIAL REPORT AS RE0VIRED BY FIRE HAZARDS ANALYSIS 1 A. REQUIREMENT FOR REPORT L

This special report is required by the Plant Hatch Unit 2 Technical Specifications (TS), Section 6.9.2, and the Plant Hatch Fire Hazards  !

Analysis, Appendix B, Section 1.1.1. Specifically, TS Section 6.9.2  !

states:

! l "Special reports for fire protection equipment operating and surveillance requirements shall be submitted, as required, by the Fire Hazards Analysis (FHA). and its Appendix B requirements."

FHA Appendix B, Section 1.1.1 states:

" Fire-rated assemblies and sealing devices in fire-rated assembly penetrations separating safety-related fire areas or separating portions of reduadant systems important to safe shutdown within a '

fire area shall be OPERABLE."

Furthermore, Section 1.1.1, Table 1.1-2, lists the Unit 2 fire doors and identified doors to which the specification applies. Action Statement (a) of Appendix B, Section 1.1.1, allows the fire. rated assembly and/or sealing devices to be. inoperable for up to 14 days provided, within_ one hour, a continuous fire watch on at least one side  !

of the affected assembly (s) and/or sealing device (s) is established, or the operability of fire detectors on at least one side of the inoperable barrier is verified and an hourly fire. watch patrol is established.

Action Statement (b) states that, if the 14-day time limit is exceeded, a special report must be submitted to the NRC within 30 days.

This special report describes a condition in which two Unit 2 fire doors q were inoperable without the required hourly fire watch being maintained.-

B. UNIT STATUS AT TIME OF EVENT On 10/18/90, at approximately 0730 CDT, Unit I was in the Run mode at an approximate power level of 2436 MWt (approximately 100 percent of rated thermal power), and Unit 2 was in the Run mode at an approximate power level of 2436 MWt (approximately 100 percent of rated thermal power).

001282 HL-1353 E-1

. ENCLOSURE (Continued) 1 SPECIAL REPORT 2-90-003 FIRE-RATED ASSEMBLIES INOPERABLE WITHOUT AN FIRE WATCH MAINTAINED RESULTS IN SPECIAL REPORT AS RE0VIRED BY FIRE HAZARDS ANALYSIS C. DESCRIPTION OF EVENT On 10/18/90, at approximately 0730 COT, fire doors 2005 and 2005A were blocked open to allow use of a portable filtration and de-watering unit to clean the oil in the main turbine lube oil storage tanks 2N34-A001A and B. Fire doors 2005 and 2005A are UL class A sliding fire doors located on the inside and outside, respectively, of the wall separating the Unit 2 oil storage room, Control Building elevation 112, and the working floor, Control Building elevation 112. FHA Appendix B, Section 1.1.1 and Table 1.1-2 do not require the establishment of a fire watch when fire doors 2005 and 2005A are inoperable. However, licensed plant operations personnel on shift at that time initiated Limiting Condition for Operation (LCO) 2-90-323 and began an hourly fire watch.

On 10/19/90_ at approximately 0510 CDT, the same licensed plant operations personnel realized that the requirements or' FHA Appendix B, Section 1.1.1 and Table 1.1-2 were not applicable to fire doors 2005 and 2005A. Consequently, LC0 2-90-323 was terminated and the fire watch discontinued.

On 10/24/90, plant Safety Audit and Engineering Review personnel questioned an apparent discrepancy between the FHA requirements for fire doors 2005 and 2005A and comparable Unit 1 fire doors. The portable filtration and de-watering unit had been in-service and fire doors 2005 and 2005A blocked open without a fire watch established since LC0 2-90-323 was terminated on 10/19/90, in response to the concern, LC0 2-90-332 was initiated and the fire watch was re-established at approximately 1135 CDT. An engineering review of FHA Appendix B, Section 1.1.1 requirements was also initiated.

On 10/24/90 at approximately 1530 CDT, engineering personnel determined that the LC0 and fire watch requirements were, in fact, applicable to fire doors 2005 and 2005A. Consequently, fire doors 2005 and 2005A had been inoperable from 0510 CDT on 10/19/90 to 1135 CDT on 10/24/90 without an hourly fire watch as required per-FHA Appendix B, Section 1.1.1, Action Statement a, thereby necessitating this report.

The continuing engineering review indicated that there were other discrepancies in FHA Appendix B, Table 1.1-2, and the problem also extended to the Unit I and common fire door listing in Table 1.1-1.

Therefore, on 11/1/90 Operating Order Number 00-02-1090S was issued requiring that all fire doors listed in Tables 1.1-1 and 1.1-2, whether designated as Appendix B fire doors or not, be considered subject to the 001282 HL-1353 E-2

ENCLOSURE (Continued)

SPECIAL REPORT 2-90-003 FIRE-RATED A%EMBLIES INOPERABLE WITHOUT AN HOURLY FIRE WATCH MAINTAINED RESULTS IN SfLC.JAL REPORT AS RE0VIRED BY FIRE HAZARDS ANALYSIS operating requirements of FHA Appendix B, Section 1.1.1. The engineering review, completed on 11/2/90, showed that approximately 60%

of the fire doors on Tables 1.1-1 and 1.1-2 had been removed from the operating and surveillance requirements of FHA Appendix B, Sect,on 1.1.1 without adequate justification.

D. CAUSE OF EVENT

!. The root cause of this event is cognitive personnel error by the

': preparers of a revision to FHA Appendix B in interpreting FHA Appendix B, Section 1.1.1 requirements. In February, 1989, Document Change Request (DoCR) 89-04 was initiated for a general revision to FHA Section 9.2, Appendix 8. This boCR' improperly revised Section 1.1.1 text, and Tables 1.1-1 and 1.1-2, to add indication by an asterisk (*)

and so designate specific doors to which the requirements of FHA Appendix B, Section 1.1.1 apply. This was done in an attempt to reduce unnecessary surveillances. Fire doors 2005 and 2005A were among those

-doors for which this specification was not identified as applicable (i.e., no asterisk).

E. ANALYSIS OF EVENT In this event, the fire doors separating the Control Building elevation 112 working floor from the Unit 2 oil storage room were inoperable without the required compensatory measures taken.

The FHA provides the analysis for safe shutdown of Unit I and 2 for a fire in the working area of the Control Building, elevation 112. There are'no' safe shutdown components or circuits for Unit 1 or 2 in the Unit 2 oil storage room.. . The Unit 2 oil storage room is-provided with a full coverage dry pilot activated, auto deluge system. The only significant fire which can be postulated for this area would be as a i ' result of the rupture of the oil storage tank or piping. The full l coverage auto deluge system provides for rapid extinguishment of any fire which would occur.

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ENCLOSURE (Continued)

SPECIAL REPORT 2-90-003 FIRE-RATED ASSEMBLIES IN0PERABLE WITHOUT Ah  !

I P^URLY FIRE WATCH MAINTAINED RESULTS IN SPECIAL REPORT AS RE0VIRED BY FIRE HAZARDS ANALYSIS l l

The auto deluge system was operable during the time that the l compensatory requirements for the fire doors were not met. Activation of the deluge system results in an alarm locally and in the Main Control Room, providing for a rapid response of the plant fire brigade to l protect sensitive equipment located in the working area of the Control Building elevation 112.

The working floor of the Control Building elevation 112 is equipped with smoke detection in the west half of the area, which is adjacent to the Unit 2 oil storage room. Fire fighting equipment includes hose stations, portable CO2 and dry chemical fire extinguishers located throughout the area, and a portable foam unit.

The detection system and fire fighting equipment were operable during the time that the surveillance requireinents for the fire doors were not l met. The detection system will detect a fire and alert the Main Control l Room to ensure prompt response by the plant fire brigade. The available l fire fighting equipment is adequate to extinguish the fire.

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It is likely that other fire doors on Table 1.1-1 and 1.1-2 of FHA Appendix B, which were improperly designated as not subject to the 3'

Section 1.1.1 requirements may have been blocked open during the time l since the FHA revision (implemented in July, 1989). However it is l likely that the doors would have been blocked open during the course of normal maintenance or outage related activities. Personnel involved in the activities would probably have been present during the majority of the time any doors were blocked open-to detect and respond to any incidence of fire.

Therefore, it can be concluded that this event had no adverse impact on nuclear safety. The above-analysis is applicable at all power levels.

i .F. -CORRECTIVE ACTIONS The corrective actions for this event include the following:

1. LC0 2-90-332 was initiated and the required fire watch was in place for the remaining duration that fire doors 2005 and 2005A were blocked open.

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, ENCLOSURE (Continued)

SPECIAL REPORT 2-90-003 FIRE-RATED ASSEMBLIES INOPERABLE WITHOUT AN HOURLY FIRE WATCH MAINTAINED RESULTS IN SPECIAL REPORT AS RE0VIRED BY FIRE HAZARDS ANALYSIS

2. Operating Order Number 00-02-1090S was issued on 11/1/90 to the Unit I and 2 Shift Supervisors requiring that all fire doors on Table 1.1-1 for Unit I and Table 1.1-2 for Unit 2 in FHA Appendix B be considered subject to the operating requirements of FHA Appendix B, Section 1.1.1.

3. The individuals responsible for initiating the revision no longer work at Plant Hatch and consequently no counseling was required.

The individuals responsible for development and review of the Document Change Request have been counseled.

4. An engineering review of the-requirements in FHA Appendix B,.

Section 1.1.1, and applicability to all fire doors in Tables 1.1-1 and 1.1-2, was completed on 11/2/90.

5. Revision 6B of the FHA will correctly identify all fire doors subject to the operating requirements of FHA Appendix B, Section 1.1.1 and will, be issued by the end of January 1991.

6.14 sampling of DoCRs generated over the last three years which affected the FHA will be reviewed by 1/16/91 for correctness and to confirm that this is an isolated occurrence.

7. Procedures will be changed by 1/11/91 to .eauire an. architect /

engineer review of any future-FHA Appendix B 6;;nment Cha,'qe Request (DoCRs) prior to the Plant Review Board submittal.

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