ML20012B812

LER 90-008-00:on 900203,discovered That Insulation Removed from Main Steam Auxiliary Equipment Piping to Auxiliary Feedwater Pump Turbine.Caused by Design Oversight Due to Unanticipated Interaction of sys.W/900309 Ltr

ML20012B812
Person / Time
Site:	Catawba
Issue date:	03/09/1990
From:	Glover R, Owen T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-008, LER-90-8, NUDOCS 9003160345
Download: ML20012B812 (10)

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1 -Document':Controi Desk i U. . S. : Muclear Regulatory CommissiGn

. Washington, D. C.' 20555-N '

Subject:

Catawba Nuclear Station Docket No.,50-413 LER 413/90-08

- Gentlemen

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Attached'is Licensee Event Report 413/90-08, concerning TECHNICAL SPECIFICATION VIOLATION.FOR INOPERABILITY OF A FIRE BARRIER-

. PENETRATION DUE TO DESIGN OVERSIGHT.

cThis event'was considered to be of no significance with respect'to the

. health and' safety of the public.

m _Very truly yours,

+ Tony B.-Owen Station Manager g,

keb\LER-NRC.TBO

=xc: Mr. S. D. Ebneter American Nuclear Insurers

+ Regional Adminintrator, Region 11 c/o Dottie Sherman, ANI Library U..S. Nuclear Regulator Commission The. Exchange, Fu.ite 245

101 Marietta Stroet, NW, Suite 2900 270 Farmington Avenue

' Atlanta, GA 30323 Farmington,- CT 06032 Mr. K. Jabbour )

M & M Huclear Consultants I 1221 Avenues of the Americas U. S. Nuclear Regulatory Commission New York,-NY 10020 Office of Nuclear Reactor Regulation Washington, D C. 20555 INPO Records Center Suite 1500 Mr. W. T. Orders

-1100 Circle 75 Parkway NRC Resident Inspector f Catawba Nuclear Station J Atlanta, GA 30339

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"'' Technical Specification Violation For Inoperability Of A ,

Fire Barrier Penetration Due To Design Oversight tytNT DATE (Si Ltn NUMetRtel REPORT DAf t 171 OTHER F ACILiflES INVOLVED let MONTH DAY YEAR YEAR **NNh*' ",'Jf,$ MONTM DAY YEAR **Ciut v Names DOCatf NUMetRtsi N/A 0l5l0l0l0; i l

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NiME TELEPHONE NUU8tR ARE A QQQE R.M. Glover, Compliance Manager 810 13 ft 3111- l 3121 31-7 COMPLif t ONE LINE FOR E ACM COMPONENT F AILURE OtsCatetD IN TMit REPORT l131 At' "' ##E CAust sYsitM COMPONE NT Ma% AC. TO NPR CAU48 SY$ TEM COMPONENT g "fC NPR 1 1 1 I I I I I I i i 1 I I I I I I I I I I I I I i l I SUPPLEMialTAL REPORT EXPECTED tt46 MONTH DAY YEAR l 4tS 450 yes, eennooere fM9fCTRO SUO60l$$ TON QA Til NO l l l ASSTX ACT (& amer to I400 speces i e , soproverewy Mmen senrespece typeentree hees/ (16e ,

On February 3, 1990, at 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, Mechanical Maintenance firestop technicians noticed that insulation had been removed from the Main Steam to Auxiliary _

l Equipment (SA) piping to the Auxiliary Feedwater Pump Turbine (CAPT). A 3/4 -

inch annular gap between the SA pipe and the calcium silicate insulation installed through firestop C-AX-217-F-26 was also noted. The firestop technicians recognized that the firestop was rendered inoperable and promotly installed cerafiber bulk material in the opening to return the fire barrier to

! operable status per Work Request 4859 SWR. The firestop was rendered inoperable when insulation removal began on January 31, 1990, to support replacement of the Electrical Heat Tracing on the SA pipe. Unit I was in Mode 5, Cold Shutdown, from the time of occurrence of the degraded firestop until the firestop was discovered to be inoperable. Previous repair and alteration of the firestop allowed the penetration to be rendered inoperable by removal of insulation adjacent to the firestop ;2netration. This incident is attributed to design oversight due to unanticipated interaction of systems and components. The Firestop Installation Specification and/or Maintenance procedure will be revised to prevent recurrence.

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0 j0 0l2 oF 0l9 BACKGROUND Technical Specification 3.7.11 states that all fire barrier _ penetrations

[EIIS: PEN] separating safety related areas shall be operable at all times. With ,

any of the required fire barrier penetration or sealing devices inoperable, l

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'[EIIS:XT]

on at least one side of the inoperable penetration and establish an hourly fire l

~ watch patrol.

The Fire Detection [EIIS:IC] (EFA) System monitors unattended areas of the plant for smoke or fire, and alerts personnel of the existence and location of a fire.

The EFA System is equipped with a' Central Fire Detection Panel that alerts Operators, via an alarm [EIIS: ANN], for specific zones within the plant.

Specification number CNS-1206.03-01-0002, Installation Specification-for Mechanical Piping Penetration Firestops, specifies installation methods and 8 approved materials for the construction of fire barriers for mechanical penetrations. Typically, piping [EIIS: PSP], duct, conduit,-etc. that penetrates i walls, floors and ceilings of fire barriers is smaller in diameter than the .

penetration opening. The void between the penetrating pipe conduit or duct and the penetration opening is filled with an approved silicone foam sealant' material (see Figure 1). Temporary dam materials are utilized to form the firestop during' application of the silicone foam and removed following curing.

The manufacturer of the Dow Corning RTV silicone foam used at Catawba Nuclear Station states that degradation of the foam may occur if it is exposed to temperatures greater than 400 degrees F for long term (greater than 10 days).

The' manufacturer also states that surfaces contacting the foam must be maintained between 50 and 100 degrees F for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following disbursement of the RTV silicone foam. These temperature parameters were added to Specification CNS-1206-03-01-0002-following the issuance of Problem Investigation Report (PIR) 0-C88-0263 per exempt variation notice CE-2364.

Firestop C-AX-217-F-26 is located in the floor / ceiling fire boundary between the Unit 1 Auxiliary Feedwater (CA) [EIIS:BA] Pump [EIIS:P] Room and the Auxiliary Feedwater Pump Turbine [EIIS:TRB] (CAPT) #1 Pit. Firestop C-AX-200-W-33 is located in the fire barrier wall between the Unit 1 Mechanical Penetration Room and the Unit 1 CA Pump Room. These firestops allow penetration of the Main Steam to Auxiliary Equipment [EIIS:SA) (SA) System piping to the CAPT #1. The CAPT is a part of the Emergency Core Cooling System to supply sufficient feedwater to the Steam Generators [EIIS:HX] to maintain decay heat removal to place the plant in shutdown conditions following loss of normal feedwater and essential power to the Motor [EIIS:M0] Driven CA pumps. The SA lines to the CAPT are insulated and equipped with Electrical Heat Trace [EIIS:FD] (EHT) elements arranged 90 degrees apart on the outside of the SA pipe under the insulation. The purpose of the EHT is to prevent condensate accumulation in the m , n u. . ,,, ,,

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'Cztawba Nuclear Station, Unit 1 0 ls l0 j o l0 l 4l1 l 3 9 l0 Oj 0l 8 0 j0 0 l3 oF 0l9 TEXT W more gnose As segwest ass, : _ _ NMC /ome MCsAilh

- normally depressurized SA line that might cause damage or trip of the CAPT on'an g automatic start. The EHT controllers are set at 550 degrees F to maintain the

pipe at the normal steam supply temperature to prevent thermal stresses. The SA EHT is required to maintain SA line temperature above 220 degrees F to consider the CAPT operable.

On August 24, 1988, with Unit 1 in Mode 4, Hot Shutdown, smoke was discovered in the CA Pump Room. .The smoke was originating from the Dow Corning 3-6548

- silicone foam firestop material in fire barrier penetration number C-AX-217-F-26. Mechanical Maintenance firestop personnel were contacted to

' investigate and repair the firestop per the penetration and firestop standing  !

work request 4859 SWR. The Maintenance personnel found that the firestop foam  ;

would flame up when the firestop dam board was removed. The dam board was replaced and the fire brigade was dispatched to extinguish the burning foam so- l that removal of the firestop could proceed. After the fire brigade extinguished the burning foam, a fire watch was established and the firestop material was removed. The problem was determined to be caused by excessive EHT temperature at the penetration _during the curing of the firestop material that was replaced nine days earlier on August 15, 1989 per 4859 SWR. After consulting with Design Engineering, it was decided to insulate the SA line through the penetration with .

calcium silicate insulation material which had previously stopped at the l firestop boundaries. This was accomplished using an exempt variation notice modification to allow insulation to penetrate the firestop. The firestop specification was revised to allow insulation to pass through the firestop on ,

piping with temperatures greater than 400 degrees F. (Firestop C-AX-217-F-26 l' was the only firestop modified in this manner prior to February 1990.) By August 25, the SA line had been insulated through the penetration and RTV  ;

L silicone foam was applied in the remainder of the penetration (around the l insulation) per Work Request 4859 SWR. The fire watch was secured following the  ;

curing of_the foam in the penetration, f I

On August 24, 1988, Problem Investigation Report (PIR) 0-C88-0263 was originated L -by_ Maintenance Engineering Services (MES) Production Specialist A, responsible l-for fire barrier penetrations, to investigate the problem with firestop C-AX-217-F-26 burning. The corresponding firestop on Unit 2 was inspected and i

l i no problem was found. A follow-up investigation by DE was documented on the PIR '

j' resolution on September 20, 1988, following discussions with the silicone RTV l foam manufacturer. DE indicated that Specification CNS-1206.03-01-0002 would be  !

l revised to require that surfaces contacting the foam be within 50-100 degrees F during and at least 12-hours following the disbursement of the foam. The foam i

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manufacturer also stated that degradation of the foam could occur if the foam l was exposed to temperatures greater than 400 degrees F for an extended period (greater than 10 days). The PIR resolution recommended the initiation of a ,

l design study to identify all foamed penetrations that are affected by this temperature limit and propose a solution. Based on the information the MES Production Specialist A perceived this problem to be restricted to excessive l

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0 [0 0l4 -0l9 f a ncro-> m ren m heat present during the curing of the penetration on August 15,'1988. Tho 400 ^

degrees F temperature limit was not considered to be a problem since the SA-piping isometric drawings indicated the piping at this penetration was

'L electrically heat traced to maintain the pipe. surface temperature at 220 degrees F.' The MES Production Specialist A was not aware that the EHT drawings specify

' a 550 degrees F EHT controller setpoint on the SA line at this penetration.

Also,_since previous problems of this nature had not been experienced with the.

SA line firestops, the problem was attributed to the temperature of the SA piping during cure time. PIR-0-C88-0263 was not evaluated to be reportable to ,

the NRC since the action requirements of Technical Specification 3.7.11 was complied with. +

r -EVENT DESCRIPTION E

u On January 31,:1990, Unit I was in Mode 5, Cold Shutdown, for the End of Cycle 4 (E004) refueling outage. At 0736 hours0.00852 days <br />0.204 hours <br />0.00122 weeks <br />2.80048e-4 months <br />, vendor insulation craft personnel  ;

entered the CA Pump Room to begin insulation removal from the SA lines per Work Request 5088 SWR, The insulation removal was required in order to complete Work

, Request 3276 PLN to replace EHT elements on the SA lines to the CAPT. Fire barrier penetration C-AX-217-F-26 became technically inoperable when the insulation removal began due to an approximately 3/4 inch annular opening >

between the SA pipe and the calcium silicate insulation at the fire barrier penetration. This opening was made necessary due to the diameter of the four heat trace elements that are spaced 90 degrees apart around the circumference of the pipe (see Figure 2). After contacting MES Production Specialist A, the vendor insulation craft supervisor was instructed to leave the insulation in-penetration C-AX-217-F-26 and was told the firestop technicians would remove the

-insulation and foam in the firestop later. The insulation crew followed these-instructions, however they did not recognize that the fire barrier was rendered inoperable due to the removal of the insulation-up to the fire barrier penetration. The insulation removal was completed on February 2, 1990.

L On February 3, 1990, at 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, with Unit 1 in Mode 5, firestop technicians 1-working in the CA Pump Room noticed that insulation had been removed from the SA piping'and~that there was a 3/4 inch annular gap between the SA pipe and the l

' calcium silicate insulation installed in the firestop. The firestop technicians recognized the fire barrier penetration as inoperable and promptly installed cerafiber bulk in the opening per Work Request 4859 SWR to return the fire barrier to operable status. The fire barrier was subsequently removed and i-reinstalled on February 14, 1990, to facilitate the replacement of the EHT element. During the reinstallation, cerafiber bulk was installed between the L insulation and the SA pipe to prevent recurrence of the problem due to insulation removal. This problem was documented on PIR 1-C90-0041 on February 9, 1990, and was evaluated to be reportable to the NRC since a fire watch was not established when the insulation was removed.

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0 l0 0l5 0l9 On February 23, 1990, Unit I was in Mode 0, Defueled, when firestop technicians P discovered damaged firestop foam at penetration C-AX-200-W-33 during removal of e the firestop for EHT replacement. A fire watch was established and a Technical c Specification Operability Notification Sheet was issued to Operations for the ,

inoperable fire barrier penetration. The damaged firestop foam had become hard >

and brittle due to the high EHT temperature. The fire barrier penetration was subsequently repaired by-installing 4 inches of calcium silicate insulation and cerafiber bulk in the penetration between the EHT element and the foam. This is not a reportable event as corrective action was taken upon discovery of the problem. However, to incorporate the necessary corrective actions for both events, it was included in this report.

CONCLUSION This incident is attributed to unanticipated interaction of system or component to design oversight in that the Installation Specification for Mechanical Piping Penetration firestops did not include allowable, sustained temperature limits for' the materials used in Mechanical Firestop penetrations nor teaiperature limits for foam installation and curing. These temperature limits were added to the specification on September 17, 1989, per Exempt Variation Notice CE-2364 following the issuance of PIR 0-C88-0263. It should be noted that the firestop material is capable of withstanding much greater short term temperature which are induced during testing for the required 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating. The remaining SA'line fire barrier penetrations are being reinstalled with insulation and cerafiber bulk extending through the penetration. A design study is being initiated to determine if any other mechanical firestop penetrations are L exceeding the 400 degrees F long term temperature limitation.

L In addition to the original Design oversight involving the long term temperature l

limits of the RTV Silicone foam material, Design oversight was involved in the L subsequent alteration on August 24, 1988, of the fire barrier to correct the temperature problem at firestop C-AX-217-F-26. The annular space between the calcium silicate insulation and the SA line, which was caused by the interference'of the EHT elements, was not recognized by DE or MES Production Specialist A as a potential problem if the insulation was removed adjacent to the firestop. This discrepancy was also not noted by the firestop technicians since after vendor insulation personnel insulated the line through the penetration the discrepancy was not visible when the firestop was sealed with  !

foam. The Firestop Installation Specification and/or the Firestop Maintenance Procedure will be revised to specifically address the installation of insulated pipes through firestops. Also, other penetrations had not been identified as having the potential for high, long term temperature leading to degradation of sealant foam.

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0 l0 0l 6 oF 0l9 rm e --. .- a --< - ,w =c w as.ml The insulation crew responded properly by consulting MES about who would be f responsible for insulation removal in the penetration because the discrepancy was not identified ~by the insulators during insulation removal up to the fire boundary, vendor insulation personnel have received instruction on

-identification and reporting of fire barrier discrepancies.

A review of the Operating Experience Program Database during the preceeding 24 months shows that four previous Technical Specification violations have occurred ,

due to missed' fire watches (see.LER 413/88-001,413/88-021,413/89-008, 413/89-024). These LERs, with the exception of LER 413/89-024, were attributed to' inappropriate action and management deficiencies. LER 413/89-024 was  ;

attributed to design deficiency due to the design selection of a fire door latch bolt mechanism that was not capable of withstanding the frequent use encountered in the door application. This design deficiency is not related to this incident, therefore this design deficiency is not considered to be a recurring.

problem.

McGuire and Oconee Nuclear Stations have been advised of this event.

CORRECTIVE ACTION SUBSEQUENT

1) The discrepancy in-firestop C-AX-217-F-26 was repaired using cerafiber bulk firestop material per Work Request 4859 SWR. 1 After the discovery of the discrepancy in firestop C-AX-200-W-33, a  :

2) '

fire watch was' established and the EHT in the penetration was insulated and-the firestop was reinstalled. l

-3) The insulation' supervisor discussed this incident with the insulation-crew to report indication of fire barrier discrepa'ncies and re-emphasized the need to contact MES when working around fire-barrier- i penetrations. .

PLANNED

1) All four remaining heat traced SA penetrations on Units 1 and-2 will be insulated through the penetrations to prevent sustained temperature damage. q

2) Steam Generator Blowdown [EIIS:WI] and Nuclear Sampling [EIIS:KN]

System penetrations in the Mechanical Penetration Room will be evaluated to determine if firestop temperature limitations are affecting these penetrations.

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.3) A design study will be initiated to determine if other firestop penetrations are affected by the 400 degrees F sustained temperature limit due to system design temperature or EHT temperature and propose resolution to any problem found.

4) Revision of Specification CNS-1206.03-01-0002, Installation Specification for Mechanical Piping Penetration Firestops, to provide specific information regarding the installation of insulated high temperature firestops particularly with regard ~to filling of voids between the insulation and the pipe will be evaluated.

5)  : Revision of MP/0/A/7650/09, Installation and Maintenance of Fire Boundaries ~, to provide more specific instruction with regard to installation of insulated high temperature firestops will be evaluated.

SAFETY ANALYSIS.

With respect to the fire impairment caused by insulation removal from the SA line which affected firestop C-AX-217-F-26, the firestop is conservatively assumed to be inoperable from the beginning of insulation removal on January 31, 1990,-until impairment discovery and repair on February 3, 1990. During this time,' Unit I was in Mode 5 and Mode 6 where operability of.the CA components is not required, Also the fire detection and monitoring were operational during

-this period.in the affected rooms as well as the carbon dioxide fire extinguishing system. For these reasons the likelihood of fire spread through this firestop discrepancy was small. With respect to firestop C-AX-200-W-33 a fire watch _was established upon discovery of the degraded firestop, therefore the_ Technical Specification action was complied with. Therefore, the health and safety of_the public were unaffected by this incident.

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