ML17284A484

LER 88-026-00:on 880715,determined That Sensing Line Support Hangers Would Not Withstand Design Basis Fire W/O Mod or Protection.Caused by Inadequate Design by Architect Engineer.Areas Placed on Hourly Fire tour.W/880815 Ltr

ML17284A484
Person / Time
Site:	Columbia
Issue date:	08/15/1988
From:	Arbuckle J, Powers C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
LER-88-026, LER-88-26, NUDOCS 8808230413
Download: ML17284A484 (7)

Text

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'ACCESSION NBR:8808230413 DOC.DATE: 88/08/15 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION ARBUCKZE,J.D. Washington Public Power Supply System POWERS,C.M. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 88-026-00:on 880715,determined that sensing line support hangers would not withstand design basis fire.W/880815 ltr.

ltr.

DZSTRZBUTZON CODE: ZE22D COPZES RECEZVED:LTR / ENCL TITZE: 50.73 Licensee Event Report (LER), Incident Rpt, etc./ W/8 SIZE: &

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 SAMWORTH,R 1 1 INTERNAL: ACRS MICHEZSON 1 1 ACRS MOELLER 2 2 ACRS WYLIE 1 1 AEOD/DOA 1 1 AEOD/DSP/NAS 1 1 AEOD/DSP/ROAB , 2 2 AEOD/DSP/TPAB 1 1 ARM/DCTS/DAB 1 1 DEDRO 1 1 NRR/DEST/ADS 7E 1 0 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB 7 1 1 NRR/DEST/MEB 9H 1 1 NRR/DEST/MTB 9H 1 1 NRR/DEST/PSB 8D 1 1 NRR/DEST/RSB 8E 1 1 NRR/DEST/SGB 8D 1 1 NRR/DLPQ/HFB 10 1 1 NRR/DLPQ/QAB 10 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/RAB 10 1 1 NRR/DREP/RPB 10 2 2 NRR/DRIS/SIB 9A 1 1 NUDOCS-ABSTRACT 1 1 REG FILE 02 1 1 RES TELFORD,J 1 1 RES/~DR~DE 1 1 RES/DSIR/EIB 1 1 RGN5 FILE 01 1 1 EXTERNAL: EG&G WILZ IAMS,S 4 4 FORD BZDG HOY,A 1 1 H ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC HARRISiJ 1 1 NSIC MAYSiG 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 46 ENCL 45

ARC F)rrm 36S U.S. NUCLEAR REQULATOAY COMMISSION (84)7) .

APPROVED OMB NO, 319)4104 EXPIRES: 8/31/88 LICENSEE EVENT REPORT (LER)

FACILITY NAME (I) DOCKET NUMBER (2) PACE 3

r. Plant - U it 2 0 5 0 0 0 1 OF

"'""'Technical Specification Appendix R, Division II, Instrument Sensing Line Support Han ers Re uire Modification Protection Due to Inade uate Desi n b the Archit En ineer EVENT DATE (5) LER NUMBER (6) R E PO RT DATE (7) OTHFR FACILITIES INVOLVED (Sl r 2 SEQUENTIAL MONTH OAY YEAR YEAR e;

..S, NUMBER NUMBER MONTH OAY YEAR FACILITYNAMES DOCKET NUMBER(S) 0 5 0 0 0 071 58 888 0 2 6 000 81 5 88 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR (): IChrch onr or mori ol the foffowinp) (11)

OPERATINO MODE (8) 73.71(b) 1 20.405(c) 60,73(e) (2) (iv)

POWE R 20A05(i(ill(i) 50.35(c) (1) 60.73(e) (2) (v I 73.71(cl LEY EL 0 0 20.405(e l(1) (Ii) 50.36(c)(2) 50.73(e) (2) (vii) OTHER ISprclfy ln Ahstrict hilow rnd ln Text, NRC Form 20.4054) (1)(iii) 50.73(el (2) (I) 60.73(el(2) (viiil(A) SSSAI

>N~XA>k~.?k..":.'0.402((s) 20A05(e l(1) (iv) 50.73(e l(2) (ii) 50.73(e) (2) (vit i) I 8) 20A05(el(1) (v) 50.73(e) l2) (iii) 60.73(e) (2) (el LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER AREA CODE COMPLETE ONE LINE FOR EACH COMPONENT FAILURE OESCRIBEO IN THIS REPORT (13)

MANUFAC EPORTABLE MANUFAC REPORTABLE CAUSE SYSTEM COMPONENT TO NPRDS CAUSE SYSTEM COMPONENT TURER TVRER TO NPRDS kVAN osx)/Xv644 SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR EXPECTED SUBMISSION DATE 05)

YES IlfyrL complete EXPECTED SV8htlSSIDN DATEI NO ABSTRACT ILlmlt to tr00 sprcrr, I e.. rpproximirrly liftrrn rlnple spice typewrittrn linrrl (16)

On July 15, 1988 as a result of an engineering calculation, sensing line support hangers associated with the following 10CFR50, Appendix R, Division it was determined that II instruments would not withstand the effects of a Design Basis Fire (DBF), without modification or protection:

~ CMS-LT-2 (Suppression Chamber Water Level Monitor)

~ MS-LT-26D (Reactor Vessel Level Monitor)

~ MS-PT-51B (Reactor Vessel Pressure Monitor)

~ RHR-FT-15B (Residual Heat Removal, Loop B, Flow Monitor)

Although the sensing lines for the instrument are stainless steel, the scope of the problems identified by the 'calculation includes 1) 100 hangers which have carbon steel tubing block clamp bolts that need to be replaced with stainless steel bolts, and 2) 55 hangers which require protection (e.g. Thermolag) from the effects of a DBF. In addition, the calculation also identified the need to perform operability verifications (in accordance with the Plant Technical Specifications) of fire-rated assemblies associated with two non-safe shutdown instrument racks.

The calculation was performed in response to an open item identified in a Nuclear Regulatory Commission Safety Evaluation Report on Amendment 37 to the WNP-2 Final Safety Analysis Report. The cause of this event is inadequate design by the Architect Engineer (AE-Burns and Roe, Inc.). The AE analysis addressed only the stainless steel tubing, and not the associated support hangers for fire protection requirements.

88082304i3 8808i5 050003'7)7 yg PDR ADOCK I 8 PNU NRC Form 368 (9 83 I

NRC form SSSA U.S. NUCLEAR REGULATORY COMMISSION IB4)3)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVEO OMB NO 3150&104 EXPIRES: 5/31/BS PACII.ITY NAME (II OOCKET NUMBER 13) LER NUMBER IS) PACE 13)

VEAR ..S: SECVENTIAL REVISION NVM ER NVMSER Washington Nuclear Plant - Unit 2 0 5 0 0 0 3 9 7 8 8 026 00 02oF 0 5 TEXT ///more 4/roco /4 /rr/ror/ ooo rf//ooo/A/Rc frerrr 3//rs43) l)T)

Abstract (cont'd)

As required by the Plant Technical Specifications, the areas were placed on an hourly fire tour. Further corrective actions include 1) initiating a Plant Modification record to change the tubing block clamp bolts to stainless steel and provide Thermolag protection on the affected hangers, and 2) modifying appropriate procedures and the Plant Seal Tracking System.

This event did not affect the Pealth and safety of either the public or Plant Personnel.

Plant Conditions a) Power Level - 100%

b) Plant Mode - 1 (Power Operation)

Event Descri tion On July 15, 1988 as a result of an engineering calculation, it was determined that sensing line support hangers associated with the following 10CFR50, Appendix R, Division II instruments would not withstand the effects of a Design Basis Fire (DBF),

without modification or protection:

~ CMS-LT-2 (Suppression Chamber Water Level Monitor) o MS-LT-26D (Reactor Vessel Level Monitor)

~ MS-PT-51B (Reactor Vessel Pressure Monitor)

~ RHR-FT-15B (Residual Heat Removal, Loop B, Flow Monitor)

Although the sensing lines for the instruments are stainless steel, the scope of the problems identified by the calculation includes 1) 100 hangers'hich have carbon steel tubing block clamp bolts that need to be replaced with stainless steel bolts, and 2) 55 hangers which require protection (e.g. Thermolag) from the effects of a DBF.

The following is a description of the instrument sensing line locations within the Plant:

~ Instruments MS-LT-26D and MS-PT-51B are connected to the same instrument tubing. Both instruments are located in a fire-shield-wall;enclosed instrument rack (H22-P027: Reactor Building - Elevation 522'). The fire shield wall enclosed area is a Division II Fire Area and; therefore, hangers within this area below the top of the walls are not threatened by a fire in Multi-Divisional General Reactor Building Fire Area R-I. (Should a fire occur in either a Division I or Multi-Divisional fire area, WNP-2 ha's committed to use Division II for safe shutdown.)

NRC PORM 3444 o U.S.OPO:10554).534 535/455 104LT)

NRC Form 388A U.S. NUCLEAR REOULATORY COMMISSION (94)3)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVEO OMB NO. 3150M)04 EXPIRES: 8/31/88 fACILITYNAME ll), DOCKET NUMBER l2) LER NUMBER (8) PACE (3) yEAR QIE SEQUENTIAL r>@,. AEvrsrQN NUMEErr NUM E rl Washington Nuclear Plant - Unit 2 o s o o o 39 788 026 00 03 oF TEXT //I'more Epeoe /T eorr4keI( Iree ~ /r/oee/ /VAC /oem XClBJ (17)

The instrument tubing runs from Instrument Rack H22-P027, up through Fire Area R-I, and then thrqugh the ceiling into the Division II Residual Heat Removal (RHR) pipe chase area (Fire Area R-IV). The tubing to these instruments also has two branch lines. One branch tees off the instrument line in Fire Area R-I above the instrument rack and runs continuously through Fire Area R-I until reaches another fire-shield-wall-enclosed instrument rack (H22-P009:

it Reactor Building - Elevation 471'). This branch is connected to MS-LT-44B (Reactor Vessel Level Monitor). The second branch tees off the instrument line in the Division II RHR pipe chase area, close to the point where the tubing enters the containment. The branch line exits the Division II area and runs through Fire Area R-I until it (IR-73: Reactor Building - Elevation 522').

terminates at a fire-shield-wall-enclosed instrument rack This branch is connected to MS-PS-8A-D (Main Condenser Low Vacuum Monitors). Tubing hangers on these three lines are in multi-divisional fire areas.

o Instrument CMS-LT-2 is located in the RHR UBU Pump Room which is a Division II Fire Area (R-IV). The instrument line runs up to Fire Area R-I on the Reactor Building 471'levation, and then into containment.

e Instrument RHR-FT-15B is located in a Divison II fire-shield-wall-enclosed rack (H22-P021: Reactor Building - 501'levation). Before the tubing leaves the fire-shield-wall-enclosed area, it branches off to RHR-FT-1 (RHR UBR Flow Monitor - Remote Shutdown). RHR-FT-1 and the hangers on this branch line remain in the Divison II fire-shield-wall-enclosed area. After branching, the line from RHR-FT-15B exits to Fire Area R-I. The line runs along the west side of the Reactor Building up to the 522'levation. On the 522'levation, the line runs through the RHR-B pipe chase (Fire Are'a R-IV). After exiting the pipe chase, the line then runs through'ire Area R-I. The 'line runs up to the and into the RHR-B valve room and pipe chase (Fire Area R-IV), and 548'levation then into containment.

In addition to the sensing line support hanger problems, the calculation also identified the need to perform operability verifications (in accordance with the Plant Technical Specifications) of fire-rated assemblies associated with Instrument Racks H22-P009 and IR-73. Instrument Racks H22-P009 and IR-73 support MS-LT-44B and MS-PS-8A-D respectively and, while these instruments are not required for shutdown, they do constitute part of the pressure boundary for the sensing lines which run to MS-LT-26D and MS-PT-51B. Both racks are enclosed in fire shield walls which were constructed to meet fire protection requirements when the Supply System utilized the High Pressure Core Spray (HPCS) and Reactor Core Isolation Cooling (RCIC) Systems for a safe shutdown method. When the current safe shutdown'ethod (Automatic Depressurization System and RHR) was implemented, Technical Specification fire protection surveillances of the two instrument racks (//ere no longer required.

NRC FORM ESSA *U,S,GPO:(98B 0 824 53S/455 (943)

NRC form 35SA II U.S. NUCLEAR REOULATORY COMMISSION OHD)

LICENSEE EVENT REPORT ILER) TEXT CONTINUATION APPROVEO OMS NO. 3150M) 04 EXPIRES: 8/31/88 PACILITY NAME (11 DOCKET NUMSER (2) LER NUMSER (5) PACE (3)

/N?I SEQUENTIAL:.PÃ$ REVISION

...0 NUMBER NUMSER Washington Nuclear Plant Unit 2 0 5 0 0 0 3 9 7 8 8 026 0 0 OF TEXT ///moro IPoco /Iroookrr/ Iroo //I/orN///RC fomr 35543/ (IT)

The engineering calculation was performed in response to an open item identified in a Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER, dated November 11, 1987) on Amendment 37 to the WNP-2 Final Safety Analysis Report'(FSAR). Included in the amendment (dated September 22, 1986) was a revision of the fit'e protection program to meet the objectives of NRC Generic Letter 86-10, UImplementation of Fire Protection Requirements," and to also meet the criteria of Appendix A to BTP APCSB 9.5-1 and the intent of 10CFR50, Appendix R, Items III.G and III.L.

The open item identified in the SER was a concern that instrument and sensing lines remain free of fire damage in the absence of fire protection features stipulated in 10CFR50, Appendix R. The Supply System stated in the amendment to the FSAR that stainless steel instrument and sensing line protection is not required since the areas that contain Appendix R related instrument sensing lines have less than a one-half hour fi re loading. The analysis was based upon the design assumption that stainless steel instrument sensing lines will not rupture when exposed to a DBF in an area that has less than a one-half hour fire loading.

The cause of this event is inadequate design by the Architect Engineer (AE - Burns and Roe, Inc.). The AE analysis addressed only the stainless steel tubing, and not the associated support hangers for fire protection requirements.

Immediate Corrective Action As requi red by the Plant Technical Specifications, the areas were placed on an hourly fire tour.

Further Corrective Action A Plant Modification Record (PMR) has been initiated to change the tubing block clamp bolts to stainless steel and provide Thermolag protection on the the affected hangers.

2. Regarding Instrument Racks H22-P009 and IR-73:

a) Doors and walls in the areas have been added to the appropriate Technical Specification surveillahce procedures.

b) The Plant Seal Tracking System will be updated to identify the seals and walls in the areas as Technical Specification fire-rated assemblies.

Safety Si nificance Although there were no fires during the event period, the consequences of a Design Basis Fire are that unprotected equipment and cabling in the areas would assumed to be lost. However, as stated in the FSAR, loss of all unprotected equipment in Fire Area R-I is not considered a credible event due to the low fire loading and geometrical configuration of the Reactor Building. The area is configured such that it has low combustibles spread out over a large area. Fire Area R-I is a General Equipment Area consisting of all open space and equipment rooms within secondary containment (Elevations 442', 441', 471', 501',

NIIC PORM 3OOA 522'48'72'nd 606').

• U.S.GPO;)0854-524 538/455 (083)

NRC form SSEA U.S. NUCLEAR REOULATORY COMMISSION (04)3)

LICENSEE EVENT REPORT ILERI TEXT CONTINUATION APPROVEO OMS NO. 3(50M)OS EXPIRES: 8/31/88 fACILITYNAME ll) COCKET NUMBER (1) LER NUMSER le) PACE (3) jÃP. SEQVENTIAL I'OI REVISION R. ( NVMSER NVM ER Washington Nuclear Plant - Unit 2 o s o o o 39 788 026 00 05 oF 0 5 TEXT ///mrue EPece /o nqukaf. u>> ///Oroe/HRC frurrr 3///)AS/ OT) r Safety Si nificance (cont'd)

Fire Area R-IV also has a low 'fire loading and, as a result,'he probability of a fire spreading is considered remote. Fire Area R-IV consists of the RHR Pump Room Rl, Pipe Chase and RHR Heat Exchanger "B" Equipment Room (Elevations 422', 444',

471', 501', 522', 548'nd 572').

In addition, had a fire occurred in either area, smoke or flame from the fire would activate either an ionization (Fire Areas R-I and R-IV) or ultraviolet (Fire Area R-I) detector which would alarm in the Control Room. The fire brigade would be dispatched which would take appropriate action in accordance with pre-fire plans and emergency response procedures. Manual fire fighting equipment is available in both areas.

Accordingly, this event did not affect the health and safety of either the public or Plant personnel.

Simliar Events LERs84-031 (Revisions 0, 1, 2 and 5),85-043 and 88-022.

EIIS Information Text Reference EIIS Reference System Component CMS-LT-2 (Suppression Chamber Water Level Monitor) IK LT MS-LT-26D (Reactor Vessel Level Monitor) SB LT MS-PT-51B (Reactor Vessel Pressure Monitor) SB PT RHR-FT-15B (Residual Heat Removal, Loop B, Flow Monitor) BO ~

FT Instrument Rack H22-P027 SB RK Instrument Rack H22-P009 SB RK MS-LT-44B (Reactor Vessel Level Monitor) SB LT Instrument Rack IR-73 SB RK MS-PS-8A-D (Main Condenser Low Vacuum Monitors) SB PS Instrument Rack H22-P021 BO RK RHR-FT-1 (RHR "BN Flow Monitor - Remote Shutdown BO FT Residual Heat Removal (RHR) System BO

,High Pressure Core Spray (HPCS) System BG Reactor Core Isolation Cooling (RCIC) System BN Automatic Depressurization System (ADS) SB NRC f OIIM ESSA *V.S.OPO.'1088 0824.538/455 (083)

WASHINGTON PUBLIC POWER SUPPLY SYSTEM F.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 Docket No. 50-397 August 15, 1988 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSEE EVENT REPORT NO.88-026

Dear Sir:

Transmitted herewith is Licensee Event Report No.88-026 for the WNP-2 Plant.

This report is submitted in response to the report requirements of 10CFR50.73 and discusses the items 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:lg

Enclosure:

Licensee Event Report No.88-026 cc: Mr. John B. Martin, NRC - Region V Mr. C.J. Bosted, NRC Site (M/D 901A)

INPO Records Center - Atlanta, GA Ms. Dottie Sherman, ANI Mr. D.L. Williams, BPA (M/D 399)