ML17279A256

LER 87-004-00:on 870407 & 14,discovered Two Fire Seal Penetrations That Were Not Sealed Properly & One Fire Door Not Included in Surveillance Procedures.Caused by Inadequate Communication.Engineering Review underway.W/870507 Ltr

ML17279A256
Person / Time
Site:	Columbia
Issue date:	05/07/1987
From:	Arbuckle J, Powers C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-87-004, LER-87-4, NUDOCS 8705130234
Download: ML17279A256 (7)

Text

REQUL~)lghINFORMATIQN DISTRIBUT~ TEN (R IDS)

C~E~~ ION,NBR: 8705 130234 DOC. DATE: 87 '05/07 NQTAR I 7.ED: D~.!z;:T li P

FACIL: 50-397 WPPSS Nucleav Pro Jecti Unit Zi Washington Pub c Po:.Ie 05000397 AUTH. NAME AUTHOR AFFILIATION

• RBUCKLE, J. D. Washington Public Pouer Supply System POWER. C. M.

RECIP. NAME li Washington Pub c Pouer Supply System

'ECIPIENT AFFILIATION SUB JECT: LER 87-004-00: on 870407-14I discovered two fiv e seal penetv'ations that were not sealed pv operlg 5 one fire door not included in surveillance pv oceduv es. Caused bg inadequate DISTRIBUTION CODE: IE22D COPIEB RECEIVED: LTR ENCL TITLE: 50. 73 Licensee Event Repov t (LFR)i Incident Rpti etc.

j communication. Eng ineev ing v evi ex comp dieted. W/870507 I tr.

/ SIZE:

NOTES:

RECIP IENT CQP IES REC IP I ENT COPIES ID CODE/NAI'1E LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA .1 PD5 PD SAMWORTHi R 1 INTERNAL: ACRS MICHELSQN 1 *CRS MOELLER 1 1 AEQD/DOA 1 1 AEOD/DSP/RQAB AEQD/DSP/TPAB 1 DEDRO 1 1 NRR/DEST/ADE 0 NRR/DEST/ADS 1 0 NRR/DEBT/CEB 1 NRR/DEST/ELB 1 1 NRR/DEBT/ICSB 1 NRR/DEBT/MEB 1 1 NRR/DEST/MTB 1 1 NRR/DEST/PSB 1 NRR/DEST/RSB 1 1 h!RR/DEST/SGB 1 1 NRR/DLPG/HFB 1 NRR/DLPG/GAB 1 1 NRR/DOEA/EAB j 1 NRR/DREP/EPB 1 1 NRR/DREP/RAB 1 NRR/DREP/RPB 2 NRR/PMA ILRB 1 h!RR/PMAS/PTSB 1 1 EC F 02 1 RES SPEISI T 1 1 CN5 FILE 01 1 EXTERNAL: EC8(Q QRQHi M 5 5 H ST LOBBY WARD LPDR 1 1 NRC PDR NSIC HARRIS' 1 1 NSIC NAYS> Q TOTAL NUI'1BER QF COPIES REQUIRED: LT I R '42 ENCL 40

NRC Form 3ddA (8431 i I( ENSEE EVENT PiEPORT (L"<<'p".,I EXT CON":iro J<<<<T<<3r

'.S. NUCLEAR REOULATORY COMMISSION AFP/IGUEO OMC NO,EINSWr M EXPIRES: 8/31/85 FACILITY NAME ill OOCKET NUMSER IEI LER NUMSER Idl PACE 131 YEA/I N/I sdovdNTIAL rl8 v IS IO N NUM drl NVMSSA Washington Nuclear Plant Unit 2 o s o o o 8 7 0 000 2 OF 0 4 TEXT /I/ rrroro d/rsco /s rsdodorL oss aAFN'or<<s/ F//IC Forrrr 3/FSA3/ IITI Plant Conditions a) Power Level - OX b) Plant Mode - 4 (Cold Shutdown)

Event Descri tion In November, 1986 during a review of the Fire Protection Plan, the Plant System Engineer noted some apparent discrepancies. Accordingly, to determine the validity of those potential discrepancies the System Engineer requested a formal engineering review. In the process of performing this review, it was discovered that the drawings the Supply System had been using as the base design docunents were incomplete. The drawings were incomplete because of an apparent lack of communication between two separate Architect Engineer (Burns and Roe, Inc.) groups responsible for performing 10CFR50, Appendix R reviews, and Fire Barrier analyses. The drawings used by the Supply System were provided by the Fire Barrier Analysis Group. The assunption was made by the Supply System that the Fire Barrier Analysis Group properly communicated with the 10CFR50, Appendix R, Review Group during the preparation of those drawings. However, the assumption was incorrect and, as a result, the base drawings uere incomplete. Also, during this review process it was determined that the original interpretation of Technical Specification fire rated assemblies and seals was incorrect. This was confirmed in discussions with the Nuclear Reactor Regulation (NRR) Branch of the NRC and resulted in a new clarification of the definition which was subsequently incorporated into the ongoing engineering review.

As the engineering review progressed, the following items were identified through surveillance and review as meeting the new interpretation of Technical Specification fire barriers, but were not being surveilled as such:

a) On April 7, 1987 fire seal penetrations P027-1052 (Reactor Building-522 Elevation) and C405-5019 (Radwaste Building-507 Elevation) were identified as not being sealed as required by the Plant Technical Specifications.

b) On April 14, 1987 it was discovered that Fire Door C-.322 (Radwaste Building-487 Elevation: Post Accident Sampling System Room) had not been included in Technical Specification surveillance procedures.

The independent .engineering review is nearing completion, at which time a supplemental report will be submitted.

Immediate Corrective Action a) Fire penetrations seals P027-1502 and C405-5019 were placed on an hourly fire tour.

8705130234 870507 PDR ADOCK 05000397 S PDR NAC FOAM SddA ISA/

NRC FOIIII.ESSA U.S. NUCLEAR REGULATORY COMMISSION ISA) LI .":."C l-:~J"=.'3T REPORT (LER) TE)~T COST!.""';TION 'PP'YEO O'IS ';O. SI59-0184 EXPIRES: SISI/85 FACILITY NAME Ill DOCKET NUMSER IEI LER NUMSER ISl ~ AOE ISI II:.I SEOVENTIAL zX; IIEYISION YEAR NVM tll .++ NVMttA Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 8 7 0 4 0 0 0 3 OF 0 4 TEXT IN mme NWCF lI Ittuied, vFF ARSt'VANE NRC %%dnII SRlATU Illl b) Fire Door C-322 was incorporated (by means of a procedure deviation) into Plant Procedures 7.4.7.7.2.1, "Fire Door Operability," and 7.4.7.7.2.3, "Locked Fire Door Operability." The door was verified to be locked and operable.

c) Maintenance Work Requests (MWRs) were written to:

o Grout fire penetration seal P027-1502 o Seal fire penetration seal C405-5019 Further Evaluation and Corrective Action a) Further Evaluation o Fire seal penetration P027-1502 is located in an area containing Appendix R, Division 2, Safe Shutdown components (specifically, Reactor level and pressure control instrumentation). However, as stated in the FSAR, loss of all unprotected equipment in this fire area is not considered a credible event due to the low fire loading and geometrical configuration of the Reactor Building.

o Fire seal penetration C405-5019 is located in a corridor floor.

Located below this penetration is Fire Area RC-XX (Radwaste Building

- Elevation 487). Although this area contains safety-related equipment, there are no components or cabling in the area required for operation of the Appendix R, Division 1, Safe Shutdown System.

o Due to the fact that several years have passed since the original drawing omissions occurred and that Burns and Roe is no longer acting in the capacity of the WNP-2 Architect Engineer, it is not possible (nor constructive) to positively identify the cause of this event.

However, all indications at this time point to a lack of complete comunication between the two separate groups responsible for the review process. It has been determined that the original Appendix R design basis is correct and has not changed.

o Internal Engineering Program controls have already been incorporated into the Plant Modification process to ensure that resealing instructions are in the design package for each modification affecting the integrity of any fire seal. In addition, the Fire Protection Engineer reviews each design modification prior to issuance to determine program impact. These controls complement the seal inspections required by Technical Specifications and the additional efforts presently on-going to verify the integrity of all non-Technical Specification fire seals.

NIIC FOIIM 90$ A I988I

ICOSI NAC FoIIR 3SSA U.S. NUCLEAR REQULATORY COMMISSION

'APPROYEO OMS N3,3!A IiIG'XPIRES:

8/31/85 FACILITY NAME Ill OOCKET NUMSER ISI LER NUMSER ISI PAOE ISl YEAR SCQVSNSIAL ~<iY: REVISION NVM NVM SR Washington Nuclear Plant - Unit 2 OS OOO 8 7 0 4 0 0 4 OF 0 4 TEXT //F IIRSO NMCO ie IOSMied, vss oISEOSN/H/IC Fons/ 3/SSA>/ I IT/

b) Further Corrective Action o An independent engineering review that applies the new definition of fire-rated assemblies and seals is currently being performed to ensure that all fire doors, barriers and penetrations are properly identified on Plant drawings and in Plant procedures.

o At the completion of the review, all associated drawings and documentation will be updated as required. In addition, a supplemental report describing any further deficiencies discovered will be submitted.

Saf et Si nificance There is no safety significance associated with this event in that 1) the fire door was verified to be locked and operable, and 2) the two penetrations were located in areas which either were considered to be low-risk with respect to fire occurrences, or did not contain components or cabling required for the operation of the 10CFR50, Appendix R, Division 1, Safe Shutdown System.

Similar Events None ElIS Information Text Reference EIIS Reference System Component Fire Door C322 Door Miscellaneous Buildings and Structures Fire Seal Penetrations P027-1502 and C405-5019 KP Penetration Fire Protection System KP NRC SORM 3OOA IS83l

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George 'l1'ashington l1'ay ~ Richland, 11'ashinglon 99352 Docket No. 50-397 May 7, 1987 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSEE EVENT REPORT NO.87-004

Dear Sir:

Transmitted herewith is Licensee Event Report No.87-004 for WNP-2 Plant.

This report is submitted in response to the report requirements of 10CFR50.73 and discusses the item of reportability, corrective action taken, and action taken to preclude recurrence.

Very truly yours, C.M. Powers (M/D 927M)

WNP-2 Plant Manager CMP;db

Enclosure:

Licensee Event Report No. '87-004 cc: Mr. John B. Martin, NRC - Region V Mr. R. T. Dodds, NRC Site (M/D 901A)

Hr. B. Hi lbrot, BPA (M/D 399)

INPO Records Center - Atlanta, GA Hs. Dottie Sherman, ANI Mr. C. E. Revell, BPA (H/D 399)

U.'S. NUCLEAR hEOULATORY COSNSISSION NRC F<<rm $ 50 (Se$ ) A- R )VED OME NO. $ 150M10<<

EXPIRES: SJSI JSS LlCENSEE EVENT REPORT (LERl fACILITYNAME III DOCKET NUMSEh (21 Washin ton Nuclear Plant Unit 2 0 5 0 0 0 1 OF TITLE ICl Missed Fire Door Surveillance and Im ro er Identification of Fire S P EVENT DATE (Sl LFR RUIN)Eh (51 REPORT OATK (7( OTHER FACILITIES INVOLVED (Sl SSQVSNYIAL ASYtQON OAY YEAR FACILITYNAMES DOCKET NUMSER(SI MONTH DAY YEAR YEAR NVMSSR:FM NVMSSII MONTH 0 5 0 0 0 0 4 7 8 7 8 7 0 0 4 0 0 5 0 7 8 7 0 5 0 0 0 THIS REPORT IS SUSMITTED PURSUANT 7 0 THS REOVIREMENTS OF 10 CFR (It JCnectt one or more of tne lotto<<tint) I'III OPS RATI NO MOOS (Sl 4 20A02(5) 20A05(<<l 50,724) (21(I<<) 7$ .7((SI (TIKI

~ OPISR 20AOS(<<l(1)(0 SOM(<<) (1) 50.7241(21(rl 7$ .71(<<l LEVEL fspectfy ln Apt<<rect 0 20A054)(l 1(S) SOW(<<) (2) 50.7$ 4)(2)(<<SI CTHE R Oetow entf ln Text, HRC Form 20AOH ~ )(1)(SII 50.7$ (<<l(2)(II 50.724((2)(<<NI) IA) SFEAJ 20AOS(<<)ill()el 50.7$ (el(2)(SI 50,724 H2) (S) 20AOS 4)(1) (<<I 50.734) (21(IS) 50.7$ (<<l 12) 4)

LICENSEE CONTACT FOR THIS LER l12)

HAMS TELKPHONE NVMSER AREA CODE J.D. Arbuckle Com liance En ineer 50 93 77-COMPLETE ONE LINE FOR EACH COMPONENT fAILURE DESCRI ~ EO IN THIS REPORT 11$ )

MAHUFAC. ~~@8/

CAUSE SYSTEM COMPONENT MAHUFAC.

TURER EPORTASLE TO NPRDS K~J% CAUSE SYSTEM COMPONENT TURER KPORTASL TO NPRDS e ex SUPPLEMENTAL REPORT EXPECTED (ISI MONTH DAY YSAII EXPECTED SVSMISSION DATE II5)

YES llfyet, complete fXPECTEJJ Stld<<IISSIOH DATE) NO AssTRAcT lLlmlt to Jedt) toe<<et, l.e., eppntxlmetely lift<<en tlnple epee<< typeerntten flnNJ (ISI As the result of performing a Technical Specification surveillance and subsequent review, during the period of April 7-14, 1987, a Plant System Engineer discovered that 1) two fire seal penetrations were not sealed as required by the Plant Technical Specifications, and 2) one fire door had not been included in Technical Specification surveillance procedures.

The two unsealed penetrations were immediately placed on the hourly fire tour and Maintenance Work Requests (MWRs) were written to have the penetrations sealed. The fire door was incorporated into plant surveillance procedures and verified to be locked and operable.

The cause of this event has been determined to be inadequate communication between two Architect Engineer (Burns and Roe, Inc.) groups during the design and construct'ion phase of the plant. This led to incorrect design basis information being used in procedure preparation.

Accordingly, an independent engineering review by the Supply System is currently being completed to ensure that all Technical Specification fire doors, barriers and penetrations are properly identified. At the completion of this review, a supplemental report will be submitted.

NRC Penn $ 05 (Se2)

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