ML20043C680

LER 89-025-01:on 891221,identified That Portion of Wall Located in Auxiliary Bldg Had Not Been Previously Identified as Tech Spec Fire Barrier.Caused by Personnel Error.Wall Being Upgraded to Tech Spec status.W/900531 Ltr

ML20043C680
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/31/1990
From:	Ewing E, Millar D ARKANSAS POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2CAN059016, 2CAN59016, LER-89-025, LER-89-25, NUDOCS 9006060048
Download: ML20043C680 (4)

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Arkr.nsas Powsr & Ught Comp 2ny o 3[ 137 G HussolMito AR 72t01 Tel 501904 3100 May 31, 1990 2CAN059016 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, D.-C. 20555

SUBJECT:

" Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Licensee Event Report No. 50-368/89-025-01 Gentlemen:

In accordance with 10CFR50.73(a)(2)(i)(B), attached is the subject report concerning a personnel error which resulted in not properly identifying Technical Specification fire barriers which rendered the fire barrier penetrations inoperable due to failure to perform surveillance requirements within the appropriate time interval. This report is being supplemented to provide a revised schedule for the completion of corrective actions.

Very truly yours, g

' E. C. Ewing General Manager, Technical Support and Assessment ECE/0M/sgw attachment cc: Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 INP0 Records Center 1500 Circle 75 Parkway Atlanta, GA 30339-3064 g 9006060048 900531 DR ADOCK 0500 8 An E nterav cortpany

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Form 1062,01A NRC Fom 366 U.S. Nuclear Regulatory Commission (9 B3) Approved OMB No. 3150-0104 Expires: 8/31/85 LICENSEE EVENT REPORT (L E R)

' FACILITY NAME (1) Arkansas Nuclear One Unit Two lDOCALT NUMBER (2) (PAGE (3) r 10151010101 31 6! 81110Fl013 TITLE (4) Personnel Error Resulted in Not Properly Identifying Technical Specification Fire Barriers Rencering the Fire Barrier Penetrations Inoperable Out to failure to Perform Surveillance Requirements Within L the Appropriate Time Interval EVENT DATE (b) LFR NUMBER (6) REPORT OATE (7) OTHER FAtlLITIES INVOLVED (8) i i 1 5equentiali IRevision -1 i l

Month Day Year (Year l Number i Number Month Day Year Facility Names Docket Number (s)_

l l l AND 1 0 5 0 0 0 3 11 3 -

_11 2 21 11 8 9! 81 91-- 01 21 5 --I 01 1 01 5 31 11 91 01 0 5 0 0 0 1 OPERA"ING l THIS REPORT.15 5UBMITTED PUR5UANT "O THE REQUIREMENTS OF A0 CFR 5:

MODE (9) I1 (Check one or more of the followino) (11)

POWER l l 20.402(b) l l-l 50.73(a)(2)(iv) ~{ 73.71(b)

LEVELI l~1 20.405(a)(1)(1) l i 20.405(c) l 50.36(c)(1)

QO)1110101 l 20,405(a)(1)(ii) l l 50.36(c)(2) l[l50.73(a)(2)(v) l I 50.73(a)(2)(vii) [l73.71(c)

I Other (Specify in 1~! 20.405(a)(1)(iii) l l 50.73(a)(2)(1) l _I 50.73(a)(2)(viii)(A)1 Abstract below and l_I 20.405(a)(1)(iv) l l 50.73(a)(2)(ii) l _l 50.73(a)(2)(viii)(B)l in Text NRC Form

,, I i 20.405(a)(1)(v) l l 50.73(a)(2)(iii) 1 l 50.73(a)(2)(x) l 366A)

LICEN5EE CONTACT FOR THIS LER (12)

Name i Telephone Number Dana N111er, Nuclear Safety and Licensing Specialist i Area Codel 510111916141-13111010 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (L3)

I j j  ; Reportable { l l l JReportable Causelsystem Component IManufacturer to NPRDS Causelsystem Component IManufacturer to NPRDS l 1 l 1 i l I i ! I I I I I l l 1 I I I i i L1 e I i l i l I i l n i I I i ! I I I l i,ea r SUPPLEMENT REPORT EXFECTED (14) EXPECTED Month Day i SUBMIS$10N i l'l Yes (If yes, complete Expected Submission Date) lil No l DATE (15) i I I I I I ABSTRACT (Limit to 1400 spaces, i.e., approximately fifteen single-space typewritten lines) (16)

On December 21, 1989, it was identified that a portion of a wall located in the auxiliary bulloing between the 354 and 360 foot elevations had not been previously identified as a Technical Specification fire barrier. As a result, two piping penetrations located in the barrier had not been surveilled as required by Technical Specifications. A visual inspection of one side of the penetrations was performed with no discrepancies identified. It is reasonable to believe since no discrepancies were identified that the penetration fire barriers had previously been functional. Therefore, no safety concerns existed. The root cause of this event was personnel error. During the initial review of plant areas the design configuration on different elevations was not considered. A review of the drawings for ANO-1 and ANO-2 is being performed to ensure any other barriers that exist on different plant elevations have been properly accounted for as Technical Specification barriers. Several barriers have been identified which are located on different plant elevations and a walkdown of these barriers is in progress. A fire watch has been posted when necessary as required by Technical Specifications. The fire barriers which p eviously have not been identified as Technical Specification fire barriers will i be upgraded and a Anet hspection of the fire barrier penetrations has been performed. This event is l reportable pursuaM to 1MiR50.73(a)(2)(1)(B).

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.. .c Fom 1062.01Lt NRC Form 366A U.S. Nuclear Regulatory Commission (9-83) Approved OMB No. 3150 0104 Expirest 8/31/85 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAE (1) i DOCKET NUMBER (2) l LER NUMBER (6) l PAGE (3) l l Sequentiall (Revision]

Arkansas Nuclear One, Unit Two l l Year Number Number l 1 0151010101 31 61 81 86 9 --

01 21 5 --

01 1101210Fl013 TEK1 (If more space is required, use additional NRC Form 366A's) (17)

A. Plant Status At the time of discovery of this condition Arkansas Nuclear One, Unit Two (ANO-2) was in Mode 1 (Power Operation) operating at 100 percent of rated thermal power. Reactor Coolant System (RCS) [AB) pressure was approximately 2250 psia and RCS temperature about 580 degrees Fahrenheit.

B. Event Description On December 21, 1989, whH e reviewing fire barrier design drawings and a log which lists fire barrier penetrations, it was identified that a portion of a well (wall 24 5 24) located in the auxiliary building between the 354 and 360 foot elevations had not been previously identified as a Technical Specification fire berrier. As a result, two piping penetrations located in the fire barrier had not been surveilled as required by Technical Specifications. A visual inspection of one side of the penetrations was performed with no discrepancies identified. The other side of the fire barrier penetrations was not inspected due to ALARA concerns.

C. Safety Significance Following the discovery that two penetrations had not been inspected within the required Technical Specification time interval, a visual inspection of the penetrations on one side was performed and no significant discrepancies noted. Therefore, it is reasonable to believe that the penetration fire barriers had previously been functional. Based on this, no significant safety concerns existed.

D. Root Cause The root cause of this event was personnel error in that during the initial-review to identify Technical Specification fire barriers of ANO-1 and ANO 2 plant areas the design configuration on different elevations was not considered. After initially identifying the Technical Specifi-cation required fire barriers, each barrier was surveyed on one side to identify penetrations which existed. In some instances a fire barrier was surveyed from one side of the barrier where the floor slab was at a higher plant elevation than the floor slab on the other side of the barrier. Therefore, a portion of that fire barrier on the other side of the barrier which was being inspected may not have been documented or surveyed.

Additionally, it would be reasonable to assume that a comparison between architectural sectional and fire zone floor plan prints was not performed which could have aided in identifying those po'tions of fire barriers which need to be surveyed.

E. Basis for Reportability The' ANO-2 Technical Specifications require that all penetration fire barriers protecting safety related areas shall be functional at all times. Technical Specification 4.0.3 states that failure to perform a surveillance requirement within the specified time interval shall constitute a failure to meet the operability requirements for a limiting condition for operation. For the purpose of complying with Technical Specifications, the terms functional and operable are considered the same for penetration fire barriers. By failing to inspect the penetration fire barriers within the surveillance interval, the identified penetration fire barriers were technically inoperable, and therefore, the Technical Specification limiting condition for operation was not satisfied. Therefore, this event is reportable pursuant to 10CFR50.73(a)(2)(i)(B), operation prohibited by Technical Specifications.

F. Corrective Actions The portion of wall 24-5 24 which was not identified as a lechnical Specification fire barrier and the piping penetrations located in the wall are being upgraded to Technical Specification status.

A review of the drawings (i.e., architectural sectional and fire Zone floor plan prints) for both AND-1 and ANO-2 is being performed to ensure that other barriers which may not have been identified during the initial review due to the design configuration (i.e. , exist on dif ferent plant elevations) have been properly accounted for as Technical Specification barriers. Several barriers have been

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Form 1062.018 NRC Fore ,366A U.S. Nuclear Regulatory Commission

'(9-83)' Approved OMB No. 3150-0104 ,

LICENSEE EVENT REPORT (LER) TEXT CONTINUATION

. FACILITY NAME (1) l DOCKET NUPEER (2) l .ER NUMBER (6) l PAGE (3) l l l Jequential. lRevisioni Arkansas Nuclear One, Unit Two l l Year Number Number l 10151010101 31-61 81 81 9 --

01 21 5 --

01 Il01310Fl013 TEXT (If more space is required, use additional NRC Fore 366A's) (17) identified which are located on different plant elevations and a walkdown of these barriers is ,

being performed to identify any existing fire barrier penetrations. A fire watch has been posted when necessary as required by the Technical Specifications. A visual inspection of the penetrations located in these barriers which have not previously been identified as Technical Specificaton fire i barrier penetrations has been completed.

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The identified fire barriers and penetrations which previously have not been identified as Technical Specification fire barriers will be upgraded. The documentation which is required to upgrade the .f fire barriers to Technical Specification status has been completed. The compl6 tion of the physical changes necessary to implement the upgrade will be accomplished by September 4,1990. The proce: e governing the inspection of Technical Specification fire barrier penetrations will be revised to include any additional barriers which have been identified prior to the performance of the next required surveillance inspections (for ANO-2, August 6,1990). The procedure revision for AN0*1 ,

has been completed.

G. Additional Information  !

Previous similar events where fire barrier penetrations were not surveilled within the required time interval allowed by Technical Specifications were reported in LER 50-368/86 008 00, 50-313/89-026-00 and 50-368/86-015-00.

Energy Industry Identification System (EIIS) codes are identified in tho text as (XX).

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