ML20215D866
| ML20215D866 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/26/1986 |
| From: | Mcnutt G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215D785 | List: |
| References | |
| 230.1-(B), 230.1-(B)-R01, 230.1-(B)-R1, NUDOCS 8612170071 | |
| Download: ML20215D866 (12) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT
Q- REVISION NUMBER: 1 TITLE: HVAC DESIGN Fire Damper Latching Test PAGE 10F 11 REASON FOR REVISION:
Rev.1: Incorporation of TACF No. 1-84-039-31, addition of summary chronology.
h PREPARED BY:
ti k A M SIGNATURE kh a
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' DATE REVIEWS
- M: REVIEW COMMITT JM_ '
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6 TlfRE' DATE /
TAS:
SIGNATURE DATE CONCURRENCES Y // / //
CEG-H:
< Elvd n-zi-K SRP:
SIGNATURE DATE SIGNATURE D/3 L h APPROVED BY:
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OCk 0 0 27 PDR ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
.. TVA ENPLOYEE CONCERNS REPORT NUNBER: 230.l(8)
SPECIAL PROGRAM
-g REVISION NUMBER: 1
' V' '
PAGE 2 0F 11
- 1. CHARACTERIZATION OF ISSUE (S):
Concern: Issues:
EX-85-027-001 a. Fire dampers would not latch when "HVAC dampers in the auxiliary tested under actual operating and control buildings (one conditions.
location given west end of control building - Elev. 713' b. Test was changed to release
(?) were tested under actual dampers by hand.
operating conditions (use of fuse link to release dampers), c. Original intent of_ test to demonstrate and the dampers would not latch. operability under actual conditions Manufacturer (Ruskin) was may not have been met, contacted, and recommended changing of test to use a hand release of dampers, which was done, and dampers latched. CI is concerned that original intent of test (to demonstrate operability under actual
-(fk conditions) was not met.
Construction concern - Units 1
& 2. Time frame - summer of 1982. CI has no further information."
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by TVA Engjneering
' Date 12/06/82 Documentation Identifiers:
NCR SQNNE88207
- 3. DOCUMENT NOS.. TAG NOS.. LCCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
This concern originated at WBN but is generic to all Ruskin Manufacturing Company brand fire dampers. Ruskin fire dampers were originally purchased for SQN by Contract 77K71-822493 and 72C55-92762-2. Concern refers to curtain type fire dampers
'(]) manufactured by Ruskin and installed in the HVAC systems of the auxiliary and control buildings. No document or tag number was 0326D -11/25/86 l
.. TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1
'~
PAGE 3 0F ll included in the EC. It does mention a specific WBN location of one fire damper - at the west end of the control building at elevation 713 feet.
- 4. INTERVIEW FILES REVIEWED:
EX-85-027-001 The working and expurgated ECTG files for this concern were reviewed. No additional unreviewed information was contained in the files.
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
- 6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REOUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST RE'00ESTS FOR INFORMATICN. MEETINGS. TEl.EPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appenoix A.
- 8. EVALU,ATION PROCESS:
- a. Reviewed purchase orders and related documents to ascertain manufacturer and models of fire dampers used at SQN.
- b. Reviewed relevant documents for same concern on Watts Bar and l determined if WBN findings are applicable to SQN.
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- c. Verified that the SQN design basis for fire dampers and the appropriate system operating instructions have been changed to reflect as-built dampers.
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l Q
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. i 1
' TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.l(B)
SPECIAL PROGRAM REVISION NUMBER: 1 p em
~E" PAGE 4 0F 11 i
- 9. DISCUSSION. FINDINGS. AND CONCLUSIONS:
Chronoloav:
Time frame cited in concern when problem was discovered at WBN:
Summer 1982 NCR issued for SQN: 12/06/82 TVA Technical Specification for HVAC Dampers MEB-SS-10.3, R1
- revised to require negator springs: 12/16/82 Fire damper modification, replacement, and full flow drop tests I completed, and tenoorary alteration control form (TACF) issued:
03/17/84 Ruskin informed TVA of NRC 10CFR21 report regarding fire damper testing discrepancy: 11/06/84 Concern received by TVA: 08/13/85 TVA General Design Guidelines DG-M18.2.15, R1 revised to prevent recurrence of problems: 08/12/85 Discussion:
The concerned individual (CI) refers to a summer 1982 time frame f([h when Ruskin brand fire darpers failed to latch when tested at WBN 3 by fusible link release.
In a telephone conversation (App. A, 7.g) T. Arnold of Ruskin i agreed that the type of fire damper release itself (fuse link or
, manual) does not have an affect on the closing and latching
'- operation. This concern may therefore be discussed as two separate
. subjects; a. Failure of the fire dampers to release by fusible l link, and b. Failure of the fire dampers to close and latch.
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- a. Fusible Link Failure:
Single purpose fire dampers are released by melting of a fusible link under external heat (normally at 160*F). Dual purpose smoke / fire dampers are released by melting of an 3 electrotherwel link (ETL) either under external heat or by an
{
electric current from a smoke control panel. Nuclear
, Operating Experience, Inc. publication up to August 1986 (App. A, 5.y) does not report any generic fusible link failures on Ruskin fire dampers. A few release failures were
, attributed to mechanical interference or binding of cables, corrosion, or one case to an unexplained melted fusible
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link. The latter problem resulted in damper closure. WBN ECN No. 4297, Attachment 1, ( App. A, 5.dd) was issued to
( problems, including recommendations for replacement of L t I 0326D - 11/25/86 1 h
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TVA EMPLOYEE CONCERNS
.SPECIAL PROGRAM REPORT NUM8ER: 230.l(8) -
A - - REVISION NUM8ER: 1 PAGE 5 0F 11 s. n dampers'which did not fully close when the fusible link was removed. Test procedures or reports on fusible links _are not available. TVA memo (App. A, 5.u) declared NCR5036 not [ a applicable to SQN. Proper SQN fire damper installation clearances were verified by the Division of Construction h Quality control inspector, as reported in a TVA memo W (App. A, 5.b) on 05/06/85. I' , b. Closure Failure: TVA memo .( App. A, 5.t) reported that preoperational test TVA-24 at W8N discovered that curtain-type gravity-operated fire dampers from Ruskin were not closing completely against air flow. Therefore, NCR WBNME88203 (App. A, 5.c) was issued, as was NCR SQNME88207 (App. A, 5.e), following determination of generic applicability. The latter NCR t resulted in the addition of Ruskin supplied negator springs {' and positive blade latching mechanisms to 100 fire dampers, [ and replacement of 15 dampers which would not accept springs at SQN. To prevent recurrence, TVA General Design lt ! - t Guidelines, " Fire Damper Application, Selection and j'_ ' hy Installation" (App. A, 5.f) and TVA Standard Specification L for "HVAC System Dampers," (App. A, 6.b) were also revised F accordingly. Except for one damper, corrective modifications
! and full drop tests were completed in March 1984.
L Workplan 10483 of ECN L5847, Attachment A ( App. A, 5.g) reports that one of the 15 replacement dampers did not fit the penetration sleeve and a temporary alteration control t form (TACF) No. 1-84-039-31 was issued for resizing the 9 , damper. This damper 0-31C-1744, however, was never y ' reinstalled and, per telephone call of 11/20/86 ( App. A, 7.j), may have been lost and is on reorder. The {- originally installed damper was destroyed when removed. Past 5 ' experience indicates that damper 10-31C-1744 and its companion (0-31C-1743) will fail the full flow drop test. j In 1984 Ruskin found that its test methods for damper closure ,; capability did not correspond with the actual installed l positions of the dampers. Ruskin's test configuration was j essentially a wall mounting as shown in Air Movement and 1 Control Association (AMCA) Standard 500 ( App. A, 5.1) Figure 5.5 instead of duct . installation per Figure 5.3 as stated in Ruskin's catalog. The wall mounted configuration
, did not account for the dynamic flow effects. Since Ruskin L. , dampers are installed in the majority of U.S. nuclear power o
I
!? 03260 - 11/25/86
a 4 p,
, TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.l(8)
SPECIAL PROGRAM I REVISION NUMBER: 1 I 7 '-gy; - PAGE 6 0F 11 o plants, Ruskin then issued a 10CFR21 notice to the NRC, and a letter ( App. A, 5.j) to TVA. This Ruskin letter recomended j retesting of all fire dampers with closure springs under air p flow, to verify proper operation. Workplan -10483 of ECN L5847 (App. A', 5.g) records j (F- post-modification test data of the SQN fire dampers with [ . closure springs under full flow. A TVA memo of 04/30/85 7 (App. A, 5.k) lists 12 SQN dampers of concern that either failed the full flow drop test or were untested but were expected to fail based on tests at WBN. For nine of these
, 12 dampers, the proposed corrective action was to institute ; administrative operating procedures for ventilation flow ' shutdown to assure their closure. The remaining three fire ,^ dampers were determined to be in systems operating less than 1,000 hours per year or in nonfire-rated walls and were L
therefore acceptable as is. } SQN System Operating Instruction, " Fire Interaction Manual," (App. A, 5.p) gives instructions for either shutdown of area [. s supply and eyhaust fans, or closure of isolation dampers, or L ke auxiliary building isolation; the appropriate action depends on the specific location for interrupting air flow to the nine fire dampers of concern. This procedure however does not provide a fire alarm or notification criteria 3 requirement, nor control designation and location for the [ fire brigade leader for shutting off a specific air flow. A meeting between TVA and NRC was held on Ma ch 27, 1985 to f discuss the Ruskin fire damper concerns for WBN. Following I this meeting, a TVA letter to the NRC ( App. A, 5.m) clarified j the administrative procedures proposed for shutting off the [ ventilation flow in areas where fire dampers may not close under air flow. For W8N, Abnormal Operating Instructions , AOI-30, " Plant Fires" (App. A, 5.n) and System 0perating Instruction, " Fire Detection System," (App. A, 5.0) give J i detailed instructions for the sequence to be followed in shutting off the area fan (s), and specific locations of their l , controls. These instructions also incorporate NRC's a requirement for restricting the fire brigade leader's j : judgment in deciding if fans should be shut down. The fire ~
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brigade leader may, instead, request restart of fans af ter fire scene assessment. The SQN System Operating Instructions ( App. A, 5.p) are not as explicit as the above instructions for WBN. l (). 03260 11/25/86 f' 1 ___ - __ _ _ _ _ _ ._ _
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TVA EMPLOYEE. CONCERNS REPORT NUMBER: 230.l(B) SPECIAL PROGRAM REVISION NUMBER: 1 -p h, PAGE 7 0F 11 Findings:
- a. Since summer 1982, when this concern arose, fire dampers at WBN and SQN have undergone extensive evaluations, testing, modifications, replacement, and retesting to assure their proper functioning under actual operating conditions. This process was monitored by NRC aon various occasions (App. A, 5.m and 5.r). The fire damper manufacturer (Ruskin) and TVA also performed independent tests,
- b. App. A, S.y does not indicate a generic problem with fusible links. The CI's statement is, therefore, considered inaccurate as to the cause of damper closure failure. The type of curtain release mechanism (fusible link or manual) does not affect the closure and latching process of the fire dampers.
- c. For nine of the 12 fire dampers at SQN that failed the post-negator spring modification test under actual operating flow conditions or that could not be tested, system operating instructions were instituted for ventilation air flow l(hf' interruption in the fire zones. The remaining three fire dampers were acceptable as is because of their limited time in use or their location in nonfire rated walls,
- d. Damper 0-31C-1744 has not been installed and successfully tested or included in the system operating procedure for I dampers expected to fail the full flow drop test.
Conclusions:
' T'he concern is not valid as to fire damper closure tests not representing actual operating conditions. Such tests have been performed since scmmer 1982, and the necessary damper modifications have been made. One damper which could not be modified was removed j and no replacement has been installed yet. For dampers that failed postmodification tests, system operating instructions have been instituted to interrupt the air flow in the ducts in case of a fire, thus assuring damper closure. The missing damper is not expected to close under full flow and is not included in the system I operating instructions. These instructions do not give the fire brigade leader the fire alarm and verification criteria for shutting down the ventilation flow. Specific fan and damper control designations and locations are missing.
0 0326D - 11/25/86
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. .TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM ! [ ' REVISION NUM8ER: 1 v ( -. . (4'"
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PAGE 8 0F 11 N t - L - APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELFMENT:
E1
- a. NRC IE Information Notice No. 83-69, " Improperly Installed i : Fire Dampers at Nuclear Power Plants,"-(A02 831027 002),
- v. (10/21/83)
I i b. TVA memo from Rankin to Vineyard, SQN 10CFR50 Appendix R - Fire Dampers, (501 850501 843), (05/06/85)
- c. TVA NCR, Watts Bar, WBNMEB8203, (MEB 821015 015), (10/13/82)
- d. TVA NCR, Watts Bar, WBNMEB8513, (844 850301 014), (02/28/85)
- e. TVA NCR, Sequoyah, SQNMEB8207, (MEB 821206 018), (12/06/82)
- f. TVA General Design Guidelines, " Fire Damper Application, b Selection and Installation," DG-M18.2.15, R1, (84285823512),
! (08/12/85) ! !h g. ECN No. LS847 including workplan 10483 and TACF 1-84-039-31 (SWP 830318 801), (03/04/83)
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- h. TVA memo f rom H. J. Green to M. N. Sprouse, "SQ-DCR-1835,"
i t (DES 830121 009), (01/19/83) 5 .
- i. Air Movement and Control Association (AMCA) Standard 500-83 f J. Ruskin letter to TVA, (MEB 841113 517), (11/06/84)
- k. TVA memo f rom J. H. Sullivan to Appendix R Project Files,
" Appendix R - Fire Dampers," (S01 850430 833), (04/30/85)
- 1. Meeting minutes by T. J. Kenyon, "WBN-Ruskin Fire Dampers,"
4 (L44 850429 597), (04/18/85) [ m. Letter from D. K. McCloud, TVA, to K. Adensam, NRC, "WBN," l (L44 850328 806), (03/28/85)
- n. WBN Abnormal Operating Instructions, A01-30. R6, " Plant Fires"
- o. W8N System Operating Instructions, S01-13.1, R3, " Fire Detection System"
! p. SQN System Operating Instruction, 501-26.2, R3, " Fire h Interaction Manual" l
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a
i TVA EMPLOYEE CONCERNS REPORT NUM8ER: 230.1(B) SPECIAL PROGRAM REVISION NUMBER: 1
, .'5/T PAGE 9 0F 11 APPENDIX A (Cont'd)
- q. NCR WBNMEB8513. " Determination of Reportability Info'rmation Worksheet for 10CFR50.55(e)," (B45 850307 269), (03/04/85)
- r. TVA memo f rom J. P. Vineyard to H. B. Rankin, "SQN - Ruskin Fire Dampers 10CFR21 Report," (B44 850313 008), (03/14/85)
- s. TVA memo from G. A. Silver to MEB Files, "SQN - Minutes of a '
Telecon to Discuss Fire Damper Inspection Program," (844 850906 011), (09/06/85)
- t. TVA memo from C. A. Chandley to J. C. Standifer "SQN and WBN - Fire Damper Negator Spring Kits," (MEB 830217 018),
(02/17/83)
- u. TVA memo from J..P. Vineyard to J. A. Raulston, "NRC-01E Reportability Information Distribution - WBN NCR 5036 -
Applicability to SQN," (PWP 831018 006), (10/18/83)
- v. Ruskin letter transmitting Generic Test Reports (01/08/85 and h/ 02/11/85) for Horizontal and Vertical Mounted Fire Dampers (MEB 850215 522), (02/12/85)
- w. . TVA memo from J. Hutton to C. C. Mason, "NRC SQNMEB8207,"
(L33 821220 801), (12/21/82)
- x. TVA memo f rom C. A. Chandley to J. P. Vineyard, "NCR j SQNMEB8207," (B44 851212 008), (12/12/85)
- y. Nuclear Power Experience Inc., reports for PWR (August 1986) l
' z. WBN ECN 5523 (826 850305 520), (02/26/85) aa. NCR WBNMEB8510 (MEB 850222011), (02/22/85) bb. NCR W-210-P (WBN 850lla 110), (11/28/84) l j- cc. NCR W-220-P (WBN 850218103), (01/29/85) j dd. ECN 4297 (W8P 831128 518), (09/26/83) l l ee. Purchase contract No. 72C55-92762-2, Grilles, Ceiling <
Diffusers and Dampers (02/28/72) ff. Purchase Contract No. 77K71-822493, Fire Dampers (08/19/77) 0326D 11/25/86
TVA EMPLOYEE CONCERNS REPORT NUMBER: 230.l(B) SPECIAL PROGRAM REVISION NUMBER: 1 (5 PAGE 10 0F 11 APPENDIX A (Cont'd) gg. TVA Standard Specification for " Technical Specification for Heating, Ventilating, and Air-conditioning System Dampers for TVA Projects," MEB-SS-10.3, R1 hh. Review of ECTG files - Documentation for concern EX-85-027-001 ( by H. Van Straalen, 10/16/86.
- 6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. TVA General Design Guidelines DG-M18.2.15. " Fire Damper Application, Selection and Installation," R1, (B42 85 823 512), (08/12/85)
- b. TVA Standard Specification for " Technical Specification for Heating, Ventilating, and Air-conditioning System Dampers for TVA Projects," MEB-SS-10.3, R1 0 2. tIST REOUESTS FOR 1Nr0RMATION. MEETINGS. TEtEPu0NE CAttS. AND OTaER DISCUSSIONS RELATED TO ELEMENT.
- a. . RFI SQN-586, (09/23/86)
- b. RFI SQN-635, (10/15/86)
- c. RFI SQN-666, (10/28/86)
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- d. Telephone call from H. A. Mahlman/G. Silver, TVA, to
, . W. Blumer, Bechtel, (10/10/86)
- e. Telephone call from H. A. Mahlman, TVA, to W. Blumer, Bechtel, (10/09/86)
- f. Telephone call from H. A. Mahlman, G. Silver, TVA, to W. Blumer, Bechtel, (10/24/86)
! g. Telephone call from W. Blumer, Bechtel, to T. Arnold, Ruskin, l (10/27/86)
- h. Review of ECTG Files - Documentation, H. VanStraalen, (10/16/86)
- 1. Telephone call from W. Blumer, Bechtel, to H. A. Mahlman, l
( h TVA, (11/10/86) I
- j. Telephone call from W. Blumer, Bechtel, to J. T. Herd, TVA Sequoyah, (11/20/86) 0326D - 11/25/86
( _ , __-- __ _ . __
.TVA ENPLOYEE CONCERNS REPORT NUMBER: 230.1(B)
SPECIAL PROGRAM
._ ._ _ REVISION NUMBER: 1 . . (2,,T: . . _ , _ . - _ . . . - _ . ~ . _ PAGE 110F 11 CATD L.LSI The following CATD forms are included as part of this report:
l 230.01 SQN 01 (revised 11/25/86)
~ .' f')^
v 9 9 J O 03260 -11/25/86
D ECTG C.3 Attachment A Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Action Tracting Document (CATD) INITIATION
- 1. Imediate Corrective Action Required: % Yes O No
- 2. Stop Wort Recomended: O Tes O No
- 3. CATD No. 23 0. l (B)-5 GN-/ a. INITIATION DATE // [25 [M
- 5. RESPONSIBLE ORGANItaTION: '
/
- 6. PROBLEMDESCRIPTION:%QR O NQR 7%e Sus /em OperaHna /ns/ rue / ions are no/ esolicna.1 fo sewknce ef Ree Mco/km rerifiuJion, rekfi/alion //ow s/fu/dewrt scent asse.cfmen/ ond res/br/ of ven// 4/ ion -
//oW. // r& ired. Loca/ ion and Misrubess of confro/1 for VrifbYa/iod Sbu/t/dWn are no/ s/rown. HVAC Sur/e>+1 cribhdn may no/ re// eel sor "
t/fs-ffee danrar 0-3/d - 17% is no/ mx/s//e/andi%ehnW ih f/18 ,Sd.</ent Cotrn/iNa veocet/cfre_r. 3 O ATTACHMENTS 7. PREPARED BT: NA.ME 4V. B/eMeder _ DATE: N /2 f/,F6
- 8. CONCURRENCE: CEG-H '7+f/# 'DW ///h VW 9.
DATE: //-2 6- M APPROVAL: ECTG PROGRAM MGR. DATE: CORRECTIVE ACTICN
- 10. PROPOSED CORRECTIVE ACTION PLAN:
6 O ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MGR:
- 12. CONCURRENCE: CEG-H:
DATE. _ DATE: SRP: DATE: ECTG PROGRAM RGR: DATE: VERIFICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE IITLE DAIE C}}