ML20011D464

LER 89-014-01:on 890818,four Fire Barrier Penetration Seals in Bldg 10 Did Not Meet Foam Seal Structure Criteria of Seal Spec.Caused by Improper Curing During Installation.Fire Watch Established & Seals repaired.W/891220 Ltr

ML20011D464
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/20/1989
From:	Burns L, Chesnutt S, Fuller C PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-014, LER-89-14, P-89488, NUDOCS 8912270289
Download: ML20011D464 (5)

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'16805 WCR 19 1/2, Platteville, Colorado 80651 3 . c, p

December 20, 1989~-

3 Fort St. Vrain b ;r , Unit No. 1 P-89488 U. S.' Nuclear ~ Regulatory Commission-O,, ATTN: ' Document Control Desk g Washington,'D.C. 20555 Docket No. 50-267 l .

SUBJECT:

Licensee Event Report '

If 014-01,- Revised ,

l' Final Report 1;

REFERENCE:

Facility Operating l< License No. DPR-34 ,

l- . Gentlemen:

Enclosed, please' find a . copy of Licensee- Event- Report No. 50-267/89-014-01, Revised Final, submitted per the requirements  !

y of 10 CFR 50.73(a)(2)(1)(B).

-If :you have any. questions, please contact Mr. M. H. Holmes at (303) 480-6960.

incerely, .c C ^

C. H. Fuller i Manager, Nuclear Production and Station Manager

, Enclosure 1

cc:' Regional Administrator, Region IV l

, , . ATTN: Mr. T. F. Westerman, Chief I Projects Section B Mr. R. E. Farrell Senior Resident Inspector, FSV ,

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MONTH DAY YEAR YEAR "u"M , "'fu",$ MONTM DAY vtAt F ACILITv h AMts DOCKET NUMBERl58 N/A 0 1510 l 0 l 0 l l l 0l 8 1l8 8 9 8l9 0l 1 l4 0l1 1l 2 2l 0 8l 9 0 1 5 to 1 0 1 0 I i pgggy g TMit REPORT IS SUOMITTED PURSUANT TO TME RtOUIREMENTS OF 10 CFR {. (Ctsca one e, more of the fo/searrapi till M004 te' N 80 ao*(*)

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< 30 40S!sH1Hvl 60.736sl(2Hisil 90.73(al(2Hal LICEN$tt CONTACT FOR THIS LER (121 NAME TE'. tPHONE NUMetR I, Amt A CODE S. W. Chesnutt, Supervisor, Nuclear Licensing-Compliance 91011 61210 1-l D 01217 COMPLETE ONE LINE FOR SACH COMPONENT F AILURE DESCRittO IN TMts REPORT H31 CAUSE SYSTEM COMPONENT "^ @l ^ c- "5'Oo",'t!!'

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-On August 18, 1989, with the reactor shutdown, four fire barrier penetration seals (BT11, BT21, BT27, and BT125) were determined to be deficient as found l during routine maintenance activities. .The seals are located in Building 10 and were found not to meet the foam " cell structure" criteria of the seal specification. These impairments were the result of improper curing during installation.

Compensatory measures in each case included immediately establishing a firewatch and-initiating repairs on each of the impaired fire barrier penetration seals.

This event constitutes operation in violation of Technical Specification LCO 4.10.4, Fire Barrier Penetration Seals, and is being reported per 10 CFR 50.73(a)(2)(1)(B).

l This LER supplement is provided to correct the identification of the impaired l fire penetration seals.

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EVENT DESCRIPTION:

I On August 18; 1989, with the reactor shutdown, a total of four fire barrier  ;

penetration seals in Building.10 were found to be impaired. -They were discovered following a routine inspection when personnel performing maintenance activities on fire barrier penetration seals stripped away the upper layer of  ;

seal BT11 to apply a new layer of retardant material and noticed that the inner layers were not completely cured. Further investigation of similar seals l indicated that- three other seals, BT21,- BT27, and BT125 were not properly cured. t l All four seals are located in the same corner of Building 10 and are not .

associated with any safe shutdown equipment. These seals were installed by the ,

I same vendor and were the only seals of this type installed in rated fire i l barriers at FSV. The seals have been inoperable since'their installation in

• 1983.

Although.the seals were installed to the correct thickness (10.5") and configuration, these seals were determined to be impaired by the Fire Protection ';

Engineer as they did not mt.et the " cell structure" criteria of the seal .

specification. . A continuous firewatch was immediately established and repair work initiated.

l In the first submittal of this LER, seals BT126 and BT127 were also listed as l fire barrier penetration seals that were found to be impaired.. Upon further l evaluation, it is concluded that BT126 and BT127 are located in the roof of l Building 10 which is not a rated fire-barrier. -Also these seals are not l associated with any-safe shutdown equipment- Therefore, the impairment of BT126 l and BT127 does not constitute operation in violation-of the FSV Technical l Specifications and they have been deleted from.this LER discussion.

CAUSE:

l It is believed that seals BT11, BT21, BT27, and BT125 did not' meet the " cell structure" criteria of the fire barrier seal specification as these: seals were installed per an inadequate procedure that did not include proper criteria for curing and cell structure.

SAFETY ANALYSIS:

Since FSV Technical-Specification LC0 4.10.4 requires that all fire barrier penetration seals remain intact or a continuous firewatch shall be posted, this event constitutes operation in violation of the Technical Specifications and is being reported herein per 10 CFR 50.73(a)(2)(1)(B).

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The effect of the inadequate " cell structure" of the fire barrier penetration seals reduced the seal's fire rating. -However, PSC has concluded that there was

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no significant safety hazard to the plant as a result of this event for the following reasons: .

Based upon an evaluation by the rire Protection Engine'er, the plant was still in compliance with Appendix 'R' guidelines, as the cables in this area that serve Safe Shutdown Cooling (SSC) equipment are contained within cable trays that have a 1. hour fire rated barrier wrapping.

There is no SSC equipment in protected areas.

There is no significant fire loading to propagate a fire.

The " defense in depth" appr.oach to fire protection (cable wraps, operable ,

detection, automatic suppression, fire brigade) provide more than adequate protection of SSC equipment.

PSC further concludes that in .the unlikely event that a fire'were to affect the SSC trains, as is postulated for a three room control complex fire, the Alternate Cooling Method (ACM) is provided as an independent shutdown /cooldown system.

In conjunction with the fire barrier penetration seal upgrade program in 1985, PSC revised its procedures and configuration details to ensure that all future penetration seals would be installed or repaired to meet Appendix 'R' requirements.

CORRECTIVE ACTION:

A firewatch was immediately established on al1~ deficient fire barrier penetration seals.

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l l Repairs or replacements have been completed for the deficient seals. The L l deficient seals were replaced in accordance with approved and appropriately I detailed procedures.

Similar events were reported on LER's77-045, 85-006,85-009, and 87-006.

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