ML20024G978

LER 90-004-01:on 900531,discovered Degraded Fire Barrier Penetration During Insp Per Generic Ltr 86-10.Caused by Failure to Identify Adequate Fire Barrier Seal During 1983 Plant Walkdown.Fire Watch posted.W/910510 Ltr

ML20024G978
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/10/1991
From:	James Fisicaro, Tracy Scott ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1CAN059101, GL-86-10, LER-90-004, NUDOCS 9105160074
Download: ML20024G978 (7)

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tiny 10, 1991 1CAN059101 U. S. Nuclear Regulatory Conimisnion Document Control Desk Hail StatJon PI-137 Washington, D. C. 20555 SUllJECT: Arkansas Nuclear One - Unit 1 Docket No. 50-313 1icense No. DPR-51 1.icensee Event Report 50-313/90-004-01 Centlemen:

In accordance with 10CFR50.73(a)(2)(1)(B), attached is a supplemental report concerning a degraded ilte barrier penetration as the result of personnel oversight.

Very truly yours, e, ,.:)I+i.e w James J Fisicato i Director. Licensing JJF/TFS/mmg Attachment cc Regional Administrator

. Region IV U. S. Nuclear Regulat cory Commission  !

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On Hay 31, 1990 at 1330, while conducting a fire barrior penetration seal inspection as part of a comprehensivo inspection program initiated as part of a Generic Letter ,

86-10 cvaluation, a degraded ffre barrier was discovered by personnel within the fire protection group at Arkansas Nuclear one. Tho deficient. seal consisted of a 2 inch metal sleeve through a floor slab and a 1) inch conduit contained within the ,

sleeve. A review of past documentation revealed this condition has existed prior to a general fire barrier inspection walk down conducted in 1983. Since this condition was not identified during this walk down or subsequent Technical Specification surveillances, the root. cause of this condition has been determined to be personnel error and oversight regarding incorrect procedure identification of penetration-number 97-0038. Upon discovery of this condition, the corresponding firn detection system was verified operable, a fire watch was posted in accordance with Technical Specification requirements, the fire barrier was scaled, and the applicable fire print and penetration log updated. In addition, the fire barrier inspection l proceduro will be revised and a t raining program will bo implemented for firo l barrier inspectors. This supplemental report extends applicability to Unit 2 by documenting a similar event discovered as part of the samo inspection program.

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A. plant Status At the timo this condition was discovered, Unit 1 (ANO-1) was in power operat ions at 80 percent. Reactor Coolant. System (RCS) [AB] temperature was 519 degrees Fahrenholt and reactor coolant system pressure was approximately 2155 psig.

At the time discovery of the second condition, Arkansas Nuclear One Unit 2 (ANO-2) was in startup conditions (Hodo 2) with RCS temperature at 545 degrees Fahrenheit, pressure at 2250 psia, and zero percent reactor power.

B. Event Description On May 31, 1990 at 1330, while conducting a fire barrier penetration seal inspection as part of a comprehensivo inspection program initiated to ensure installed snals are in accordance with tested configurations or have adequate basis for installation (l.c., Generic Letter 86-10 cvaluation), a degraded fire barrior was discovered by personnel within the fire protection group at Arkansas Nuclear One (AN0). The degraded fire barrier consisted of a 2 inch metal sleeve extending approximately 3 inches above the floor slab to approximately 22 inches below the floor slab between the cable spreading room and the solid waste filler storage room. A lj inch conduit passing through the 2 inch metal slenvo was surrounded by an open annulus which did not contain a fire retardant seal. The sloove appears to have been used as an equipment drain line, at ono time, with the portion of t.he drain line extending through the floor slab modified into a sleeve and subsequently utilized for the routing of conduit through the fire batrier. The slenvo and conduit pass through penetration number 97-0038 in room

97. The sleeve passing through the floor slab was surrounded by an adequate seal and was properly identified in the fire barrier inspection proceduro. The conduit within the sleeve was not surrounded by a seal nor was it identified in the inspection proceduro. Documentation portaining to installation of the conduit indicates that the conduit was routed prior to a major fire barrier walk down effort, conducted in 1983, which served to field verify the adequacy of penetration seals located in either an NRC required fire barrier or insurance required fire barrier. The results of the firo barrior walk down effort were used to supply baselino data for future inspections of fire barrier penetration seals.

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NRb Tom 3f4A U. S. Nuclear Regulatwy Omnissim (6-89) A;ptwul (im tb. 3150-0104 F.xp h es: 4/30/92 LIONSIT. ITINT RDRT (ITR) 'ilXT GriflNUATI(N FACibrIY NAME (1) IIIKl!r NltiHII (2) 11R NMR (6) FAT. (3)

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A second degraded fire barrier was discovered by ANO fire protectio! -

• on April 17, 1991 at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> during a continuation of the comprr' inspect Jon program, fire barrier FB-2081-03 is located between tb penetration room and the heat exchanger equipment area at elevnt' Unit 2 Auxiliary Building [NF]. A small through void was discov, around piping at penetration 2081-03-0029. The through void was c a steady flow of air was dntected flowing into the penetration room On the same barrier air flow was detected at two conduits, penetratiot 2081-0033 and 0034, at t.he condulet covers. The condulet covers are approximately two inches from the barrier.

C. Root Cause Fire barrier penetration seals inspected during the walk down efforc of 1983, including penetration number 97-0038, were ett.her found containing a satisfactory fire barrier seal or were modified to conform with approved fire barrier scalant standards. Hist orical documentation of penetrat ion number 97-0038 indicates that no deficiencies were found with this fire barrier seal during the 1983 walk down. Since existing documentation indicates that the routing of conduit was performed prior to the 1983 walk down, the condition should have been identified during these inspections since inspectlon guidance was availabic to the inspector, llowever, the s leeve configuration was such that it could have misled the inspector to overlook the gap and accept the fire barrier penetration as satisfactory. Additionally, several Technical Specification surveillance procedures for fire barrier penetrations have boon performed since 1983 and also have failed to identify the deficient fire barrier penetration seal. Therefore, the root cause of this condition has been determined to be personnel error and oversight related to the failure to identify an inadequate fire barrier seal during the 1983 walk down effort. A contributing factor associated with this condition may be attributed to the fact that the sleeve through which penetration number 97-0038 passes was not correctly identified in the procedure used to perform Technical Specification inspections. Technical Specification surseillances were conduced by maintenance personnel; whereas, the current fire barrier penetration seal inspection program is being conducted by the ANO fire protection group.

Fire barrier FB-2081-03 was also inspected during the walk down effort of 1983 and documented to be satis factory. The condit ion is believed to have existed prior to the 1983 inspection and should have been identifled during these inspections since adequate guidance was available to the inspector.

Additionally, several Technical Specification surveillances of fIro barrier penetrations have been performed since 1983 and also have failed to identify the deficiencies. Therefore the root cause of this condition is personnel error related to the failure to idnntify an adequate fire barrier seal during the 1983 walk down effort.

Ni[CIbiu366A U. S. Nuclear Rg;ulatory Cuelsshu (6-W) A;pmvol (UB No. 3150-0104 f>pires: 4/30/92 1.lC17NT. IMNT KPJWF (IIR) 'l1XT QNflNDATilN fW:llJIY fWE (1) l lIIKl?f NtM10R (2) U2LtMREIA) pNE E S<rpot f al Revision Arkansas Nacimr Gie, Unit Om _hnt _ _N&r _Nmb.L 0l5l0j0[0l 3j 1[3 9Lo -

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D. Corrective Actions Upon discovery of this condition, the fire det ection system for the cable spreading room was verified operable and a fire watch was posted in accordanco with Technical Specification req'tirements. The fire barrier was scaled through a job request Jr.itiated to ensure the annulus between the sleeve and conduit was adequntely enclosed. In responsn to identifying the ftre barrier penetration for future inspections, the new fire barrier penetration designation for sloove (97-0127) has been listed on flic print 97-1 and entered in penetrat. ion 1.og fB-00-bl. This should be e f fect ive in providing a cue to inform the fire barrier inspector t bat. t his penet rat.f on exists and requires inspection during future inspactions.

Add i t ional ly , fire barrier inspection procedure (1405.016) will be revised to correctly identify the new designated fire barrier pennt. ration. This action will bn complet.ed by August 1, 1991. These actions are in addition to the current ftre barrier seal inspectton program which is part of the AND Busines;.

plan ( Act ion D.5.C) scheduled for complet ion pr ior to December 31, 1991. The objectives of thn assessment program are to verify the physical configuration of Technical Specification penetrat ion seals, per form evaluations of seal designs when deviations arn identified, develop a data base and procedures for seal configuration management, and the correction of identified deficiencies.

To providn addit on t guidance to the fire barrier penetration seal inspector on the correct methc 1 inspect ing firn barrier penetrations , a training program will be developed addressing the identification of defic ient conditions. The training program also will present a discussion of penetration scalant material and possibin conditionn rendering particular sealant materials deficient. This program is schedulod for Jovolopment by September 1, 1991.

Upon discovery of the second degraded fire tarrier, the firn detection system for the area wa= verified to be operable and a fire watch was posted in accordance with Technical SpecificnLion requirements. A job request was init iated t n repair the deficiencies.

E. Sa fety Signi ficance This condition has pot ential safety significance considering that the deficient firn barrier seal provides protect.fon for the cable spreading room. A fire spreading to the cable spreading room could result in degraded plant cont.rol due to possible conductor damage associated with Control Roam i ns t.rumen t a t ion . The degree of dnmage to Control Room instrumentation is dependent on the naturn and extent of the ftre within the cable spreading area. plant control in the event of a fire in the cable spreading room is addressed through abnormal operating procudure 1203.02.

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In nr.tuality, the firn proventativo measures currently available make the spread of fire in these areas only remotoly possible. Theso measures include a fixed fire detection system in the cable spreading room which provides alarm annunciation in the ANO-1 Control Room, fire suppression equipment in the form of firo extinguishers, fire water hose rnols, and an automatically actuated system. Fire Brigado personnel, specifically trained in fire fighting, are available at all times in the unlikely event a fire worn to occur. Although the seal was degradod, tho ava11ah111ty of detection instrumentation, suppression equipment, and Firo Brigado pnrsonnel prmido adequate protection against firo propagation. Thereforo, thoro la not a safety concern related to the degraded seal.

The second degraded fire barrior had less safety significanco because the areas on either side of the barrier did not contain as much potentially combustible material and a large number of cables associated with Instrumentation and control were not involved. Firo detection instrumentation and Fire Brigado personnel were also available if a fire worn to have occurred in the area of the second degraded barrior.

At the ANO sito there are approximately 8600 total penetrations through plant firo barriers. Approximately 5,000 penetrations have already boon reverified with only the two barriors addressed in this report being identified as deficient. Therefore, considering the small population of deficient penetrations which have been identified, the safety concerna as they relate to potentially existent conditions are relatively small for thu remaining number of seals.

F. Basis For Reportability Technical Specifications require that all penetration fire barriors protecting safety related areas shall be operable. With onn or more of the required penetration fire barriors inoperable, a continuous fire watch must be established in the affected area within one hour. Although the fire watch was established within one hour of discovering the deficient fire barrior, investigation of the cordition revealed that it had most likely existed for greater than one hour iithout a fire watch established. Therefore, this event is reportable pursuant to 10CFR50.73(a)(2)(1)(B) as a condition prohibited by-Technical Specifications.

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hM: Pom 3(M U. S. Ntclear Rmilatory Osn(ssim

'(6-89) Al pttun! 01B No. 3150-0104

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G. Additional information Condillons involving inadequate fire barrier seals in conjunction with personnel related nrror were previously reported in Licensen Event Reports 50-368/88-018, and-50-368/90-013.

A revision to this Licensco Event Report will be submitted by January 31, 1992 to document additionr.1 inadequate fire barrier seals identified as part. of thn current 11ro Larrict inspect ion J. rop, ram.

Energy Industry Identification System (Ells) codes are identified I. the text as (XX].

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