ML20236B507

Special Rept 89-001:on 890216,fire Door Not Restored to Operable Status within 14 Days.Caused by Use of Structural Grouting Procedure Instead of Cosmetic Grouting Procedure. Grouting Placed Underneath Door & Individuals Counseled

ML20236B507
Person / Time
Site:	Hatch
Issue date:	03/14/1989
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0602I, 602I, 89-001, 89-1, HL-366, NUDOCS 8903210120
Download: ML20236B507 (5)

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-1 March'14, 1989 U. S. Nuclear Regulatory Commission. ~,

ATTN: Document Control Desk' e Hashington, D. C. 20555 /

PLANT HATCH - UNIT 2 NRC DOCKET 50-366  !

OPERATING LICENSE NPF-5 SPECIAL REPORT 89-001 FIRE 000R INOPERABLE FOR LONGER THAN 14 DAYS RESULTS IN SPECIAL REPORT AS-REQUIRED BY FIRE HAZARDS ANALYSIS Gentlemen:

f In accordance with ~the requirements of. the Plant Hatch Unit 2

. Technical Specifications Section 6.9.2, and the Fire Hazards Analysis (FHA) Appendix B, Georgia Power-Company is submitting the enclosed'Special Report (SR) concerning an event where a- fire door was inoperable longer than 14 days. This event occurred at Plant Hatch - Unit 2. -!

i Sincerely, f.d< h H. G. Hairston, III l SJB/lc- l l

Enclosure:

SR 50-366/1989-001 c: (See next page.)

Y 8903210120 890314 A6 I\

PDR ADOCK 0500 g S

+ _ __ . __ _ _ _ _ __ - _ __________________-_-____-____D

l" U. S. Nuclear Regulatory Commission l March 14, 1989-Page1Two r

c: G2oraia-Power ComDADY-Mr. H. C. Nix, General Manager'- Plant Hatch Mr. L. T. Gucwa, Manager Nuclear Engineering and= Licensing '

GO-NORMS-U. S. Nuclear Reaulatory Commission. Washinaton. D. C.

Mr. L.-P. Crocker, Licensing Project Manager - Hatch U. S. Nuclear Regulatory Commission. Reaion II l Mr. S. D.-Ebneter, Regional Administrator-Mr. J. E. Henning, Senior Resident Inspector - Hatch

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ENCLOSURE PLANT HATCH - UNIT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 SPECIAL REPORT 89-001 FIRE DOOR NOT RESTORED TO OPERABLE STATUS HITHIN THE REOUIRED 14 DAYS A. REQUIREMENT FOR REPORT This report is required by the Unit 2 Technical Specifications (TS) section 6.9.2 which states that Special Reports for fire protection equipment operation and surveillance requirements shall be submitted, as required, by the Fire Hazards Analysis (FHA) and its Appendix B requirements.

The FHA Appendix B, section 1.1.1 states that all sealing devices in >

fire-rated assembly penetrations (i .e. , fire doors, fire dampers, cable, piping and ventilation duct penetration seals) shall be operable at all times. The action statement allows for the sealing devices to be inoperable for up to 14 days. If this time period is exceeded, a special report is required. J B. UNIT (s) STATUS AT TIME OF EVENTS On 2/16/89, Unit 2 was in the run mode of operation at approximately 2436 MWT ( approximately 1007. rated thermal power).

C. DESCRIPTION OF EVENT As part of Plant Hatch's Procedure Upgrade Program (PUP), fire barrier surveillance procedure 42SV-FPX-032-0S, AUTOMATIC SLIDING FIRE D0OR SURVEILLANCE, was revised in August,1988. The procedure was revised to include actual measurement of interfacing surfaces as described in the National Fire Protection Association standards, section 80 (NFPA-80), Fire Doors and Hindows. The previous revision of the surveillance procedure was deficient in that acceptance criteria for air gap dimensions were not specified.

The upgraded procedure was first performed as a scheduled i

surveillance on February 2, 1989. At that time, seven sliding fire doors in the Control Building were found to be deficient, including door 2L48-2C07. In compliance with plant administrative controls, maintenance personnel wrote Deficiency Cards to document the deficient conditions and initiate corrective actions. An hourly fire watch was initiated in accordance with the FHA Appendix B, Section 1.1.1, Action statement a. A Limiting Condition for Operation (LCO) was issued to track corrective action. In addition, high priority l 0602I HL-366 E-1

ENCLOSURE (Continued) j FIRE DOOR NOT RESTORED TO OPERABLE STATUS WITHIN THE 14 DAYS I

" walk-thru" Maintenance Work Orders (HH0's) were written to repair the doors. Since sliding fire door inspections performed prior to February,1989, used earlier, deficient revisions of the procedure, it is conservatively assumed that fire doors found deficient during the February 1989 inspection have been deficient since installation.

Six sliding fire doors (excluding door 2L48-2C07 to the 2D switchgear room on the 130ft. elevation of the Control Building) were repaired and declared operable by 2/16/89 by adjusting the doors and by fabricating new steel door facings .

Door -2L48-2C07 was repaired by fabricating a new steel door facing and grouting underneath the door to bring clearances within required limits. The final repair, inspection, and sign-offs were completed on the 15th day following discovery of the deficiency, 2/17/89.

I D. CAUSE OF EVENT

1. The root cause of door 2L48-2C07 being inoperable longer than 14 days was the use of the structural grouting procedure rather than the cosmetic grouting procedure. In this event, either procedure I could have been used; however, the structural procedure was selected. The LC0 was exceeded due to the more stringent cure time and testing requirements for structural grouting versus )

cosmetic grouting.

2. The root cause of the seven sliding fire doors having excessive clearances between interfacing surfaces was inadequate installation. Also, previous revisions of 42SV-FPX-032-0S, Automatic Sliding Fire Door Surveillance, did not require door clearances to be measured in order to verify compliance with i NFPA-80 standards.  !

E. ANALYSIS OF EVENT Plant Hatch is protected against significant fire damage (i.e.,

damage that would prevent the performance of necessary safe plant shutdown functions or would significantly increase the risk of radioactive releases to the environment) by design features which locate redundant safe shutdown circuits and components in distinct areas separated by fire barriers. The barriers, which include fire doors with automatic hold-open and release mechanisms, are designed to contain a fire that totally involves the combustibles in a given area. Other fire protection measures include fire detection and suppression equipment.

0602I HL-366 E-2

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ENCLOSURE (Continued)

FIRE DOOR NOT RESTORED TO OPERABLE STATUS HITHIN THE 14 DAYS Fire door 2L48-2C07 was declared inoperable because the maximum air gap between the door and door facing exceeded the NFPA-80 standard of 3/4-inch, and because the gap between the bottom of the door and the t floor exceeded the NFPA-80 standard of 3/8-inch. Fire protection engineers believe that the operability of the fire door was only slightly degraded, since air gaps exceeded standards by only 1/4-inch. Fire door 2L48-2C07 has a three-hour rating. Fire brigade response time to a fire, however, is required to be 30 minutes or less. Fire protection engineers concluded that even though the door was degraded, the limited extent of the degradation coupled with the low combustible loading in the area would have enabled the door to withstand a design basis fire for significantly longer than the 30  ;

minutes required for fire brigade response. '

The Safe Shutdown Analysis Report (SSAR) contains detailed analyses of the effects of a fire in the 2D switchgear room, as well as for the adjoining corridor. The analyses show that a design basis fire in either area would not prevent trained operators from being able to shut down the reactor and maintain it in a safe condition. Manual ,

actions which would be required to be performed by the plant  :

operations personnel are explicitly stated in the analyses, and have  !

been incorporated into the applicable plant procedures as well as operator training.

Based on the above analysis, it is concluded that this event had no adverse impact on nuclear safety. Additionally, since the size of and damage from a fire are independent of power level, it is believed that the consequences of this event would not be more severe under other power conditions.

F. CORRECTIVE ACTIONS

1. Individuals responsible for the delay in the work process (i.e.,

use of the structural grouting procedure rather than the cosmetic grouting procedure) have been counseled.

2. Grouting was placed underneath door 2L48-2C07 to reduce the bottom side air gap to within the NFPA-80 Standard of 3/8 inch.

A new steel door facing was fabricated and the door was adjusted such that the air gap between the door and facing was reduced to within the NFPA-80 standard of 3/4 inch. Similar adjustments and door facing repairs were accomplished on the other five sliding fire doors before the expiration of the LCO. Additionally, all sliding fire doors at Plant Hatch have been satisfactorily inspected using the more stringent standards of the improved inspection procedure.

0602I HL-366 E-3 L- __ ___