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{{#Wiki_filter:('A.'l'EQO8.2REGULATIO INFQRMATIQN DIBTRIBUTIor~sTEM (RIDE)!ACCESSION NBR:9707150008 DOC.DATE:
{{#Wiki_filter:('A.'l'E QO8.2 REGULATIO INFQRMATIQN DIBTRIBUTIor~sTEM (RIDE)!ACCESSION NBR:9707150008 DOC.DATE: 97/07/11 NOTARIZED:
97/07/11NOTARIZED:
NO FACIL'.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION FREHA:ER,K.W.
NOFACIL'.50-389 St.LuciePlant,Unit2,FloridaPower&LightCo.AUTH.NAMEAUTHORAFFILIATION FREHA:ER,K.W.
Florida Power&Light Co.STALL,J.A.
FloridaPower&LightCo.STALL,J.A.
Florida Power 6 Light Co.RECIP.NAME RECIPIENT AFFILIATION DOCKET¹05000389  
FloridaPower6LightCo.RECIP.NAME RECIPIENT AFFILIATION DOCKET¹05000389


==SUBJECT:==
==SUBJECT:==
LER97-004-00:on 970611,discovered incorrect originalcabletrayfirestopassemblyinstallation outsideAppRdesignbasis.Causedpersonnel error.Postedhourlyfirewatchpatrols.W/970711 ltr.DISTRIBUTION CODE:IE22TCOPIESRECEIVED:LTR
LER 97-004-00:on 970611,discovered incorrect original cable tray fire stop assembly installation outside App R design basis.Caused personnel error.Posted hourly fire watch patrols.W/970711 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR
'NCLSIZE:TITLE:50.73/50.9 LicenseeEventReport(LER),IncidentRpt,etc.NOTES:RECIPIENT IDCODE/NAME PD2-3PDINTERNAL:
'NCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EIB EXTERNAL: L ST LOBBY WARD NOAC POOREFW.NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME WIENSFL~AEOD/SPD/RAB E T~KRONE NRR/DRCH/HHFB NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN2 FILE 01 LITCO BRYCE,J H NOAC QUEENERFDS NUDOCS FULL TXT COPIES LTTR'ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
ACRSAEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EIB EXTERNAL:
PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD"5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON T NEEDr FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQJIRED: LTTR 25 ENCL 25 Florida Power&Light Company, 6501 South Ocean Drive, Jensen Beach, FL34957 July 11, 1997 L-97-179 10 CFR 50.73 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Unit 2 Docket No.50-389 Reportable Event: 97-004 Date of Event: June 11, 1997 Incorrect Original Cable Tray Fire Stop P~The attached Licensee Event Report is being submitted pursuant to the requirement's of 10 CFR 50.73 to provide notification of the subject event.Very truly yours, J.A.Stall Vice President St.Lucie Plant JAS/KWF Attachment l/(W)cc: Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St.Lucie Plant'Ir707150008 9707iX PDR ADOCK 0500038'P S PDR an FPL Group company iliillllllllllllllllllllllllIlls lllllll NRC FORM 366 (4.95)U.S.NUCLEAR REGULATORY COMMISSION LZCENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVED SY OMS No.3160%I 04 Exp)RES 04)3 ore 6 ESTIMATED BURDEN PER RESPONSE To COMPLY WITH THIS M ANDATO INFORMATION COLLECTION REGUEST: 60.0 HRS.REPORTED LESSON LEARNED ARE INCORPORATED INTO THE UCENSING PROCESS AND FE BACK TO INDUSTRY.FORWARD COMMENTS REGARDING BURDEN ESTIMAT To THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT%F33)U.S.NUCLEAR REGIAATORY COMMISSION.
LSTLOBBYWARDNOACPOOREFW.NRCPDRCOPIESLTTRENCL111111111111111111111111RECIPIENT IDCODE/NAME WIENSFL~AEOD/SPD/RAB ET~KRONENRR/DRCH/HHFB NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN2FILE01LITCOBRYCE,JHNOACQUEENERFDS NUDOCSFULLTXTCOPIESLTTR'ENCL112211111111111111111111NOTETOALL"RIDS"RECIPIENTS:
WASHINGTON, OC 206664KO)AND TO THE PAPERWORK REDUCTION PROJECT I3160<104), OFFICE 0 MANAGEMENT AND BUDGET, WASHINGTON, DC 20603.FACIUTY NAME (1)ST LUCIE UNIT 2 DOCKET NUMBER 12)05000389 PAGE 13 I 1 OF4 TITLE I4)Incorrect Original Cable Tray Fire Stop Assembly Installation Outside Appendix R Design Bases MONTH DAY YEAR 11 97 SEQUENTIAL REVISION NUMBER NUMBER 97-004-0 MONTH DAY YEAR 97 FACIUTY NAME FACILITY NAME DOCKET NUMBER 05000 DOCKETNUMBER 05000 OPERATING MQDE (9)POWER LEVEL (10)100 20.2201(b) 20.2203(a)(2)(i)20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203 (a)(2)(v)20.2203(a)
PLEASEHELPUSTOREDUCEWASTEICONTACTTHEDOCUMENTCONTROLDESK,ROOMOWFNSD"5(EXT.
(3)(n)50.36(c)(1)50.36(c)(2)50.73(a)(2)(1) 50.73(a)(2)(iii)50.73(a)(2)(v)50.73(a)(2)(vii)50.73(a)(2)(viii)73.71 OTHER Specify in Abstract below or in NRC Form 3BSA NAME K.W.Frehafer, Licensing Engineer TELEPHONE NUMBER Seclude Aree Code)(5611 468-4284 CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS , x:,t,;4(..Nk&#xc3;"'9):A cAusE sYsTEM coMpoNENT MANUFACTURER REPORTABLE To NPRDS YEs (If yes, complete EXPECTED SUBMISSION DATE).X No EXPECTED SUBMISSION DATE (15)MONTH OAY YEAR ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)(16)On June 11, 1997, St, Lucie Unit 2 was in Mode 1 at 100 percent power.Inspection results indicated that, generically, two sided cable tray fire stop assemblies lacked the installation of ceramic fiber between cables within the fire barrier.FPL determined that the as-built configuration of two sided cable tray fire stop assemblies did not meet the tested configuration for a three hour fire rated assembly.All the St.Lucie Unit 2 two sided cable tray fire stop assemblies were declared inoperable.
415-2083)
The apparent cause of this event was due to personnel error during the implementation of design drawings or insufficient design guidance during initial installation.
TOELIMINATE YOURNAMEFROMDISTRIBUTION LISTSFORDOCUMENTS YOUDONTNEEDrFULLTEXTCONVERSION REQUIREDTOTALNUMBEROFCOPIESREQJIRED:
Corrective actions include the posting of hourly fire watch patrols that were established to compensate for the inoperable fire stop assemblies.
LTTR25ENCL25 FloridaPower&LightCompany,6501SouthOceanDrive,JensenBeach,FL34957July11,1997L-97-17910CFR50.73U.S.NuclearRegulatory Commission Attn:DocumentControlDeskWashington, D.C.20555Re:St.LucieUnit2DocketNo.50-389Reportable Event:97-004DateofEvent:June11,1997Incorrect OriginalCableTrayFireStopP~TheattachedLicenseeEventReportisbeingsubmitted pursuanttotherequirement's of10CFR50.73toprovidenotification ofthesubjectevent.Verytrulyyours,J.A.StallVicePresident St.LuciePlantJAS/KWFAttachment l/(W)cc:RegionalAdministrator, USNRCRegionIISeniorResidentInspector, USNRC,St.LuciePlant'Ir707150008 9707iXPDRADOCK0500038'P SPDRanFPLGroupcompanyiliillllllllllllllllllllllllIlls lllllll NRCFORM366(4.95)U.S.NUCLEARREGULATORY COMMISSION LZCENSEEEVENTREPORT(LER)(Seereverseforrequirednumberofdigits/characters foreachblock)APPROVEDSYOMSNo.3160%I04Exp)RES04)3ore6ESTIMATED BURDENPERRESPONSEToCOMPLYWITHTHISMANDATOINFORMATION COLLECTION REGUEST:60.0HRS.REPORTEDLESSONLEARNEDAREINCORPORATED INTOTHEUCENSINGPROCESSANDFEBACKTOINDUSTRY.
Repairs or plant modifications will be implemented to restore the affected fire stop assemblies to their required three hour fire rating.NAC FOAM 366 (4.95)
FORWARDCOMMENTSREGARDING BURDENESTIMATToTHEINFORMATION ANDRECORDSMANAGEMENT BRANCHIT%F33)U.S.NUCLEARREGIAATORY COMMISSION.
NRC FORM 366A I4-9SI LICENSEE EVENT REPORT (LER)Tf XT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSIO ST LUCIE UNIT 2 05000389 YEAR SEQUENTIAL REVISION 97-004-0 2 OF 4 TEXT Ilf more spaceis required, use additional copies of iVRC Form 366Ai (17l On June 11, 1997, St.Lucie Unit 2 was in Mode 1 at 100 percent power.FPL was investigating discrepancies of two sided cable tray fire stop assemblies identified during previous field surveillances.
WASHINGTON, OC206664KO)
Intrusive inspections of the remaining population of fire stop assemblies of this design were in progress to determine the extent of the issue.Preliminary inspection results indicated that, generically, the as-built configuration of two sided cable tray fire stop assemblies lacked the installation of ceramic fiber between cables within the fire barrier.The configuration did not conform to the design drawings and FPL ascertained that the identified field conditions were not previously evaluated during initial construction.
ANDTOTHEPAPERWORK REDUCTION PROJECTI3160<104),
Therefore, the two sided cable tray fire stop assemblies did not meet the tested configuration for a three hour fire rated assembly, as required by the plant 10 CFR 50 Appendix R commitments.
OFFICE0MANAGEMENT ANDBUDGET,WASHINGTON, DC20603.FACIUTYNAME(1)STLUCIEUNIT2DOCKETNUMBER12)05000389PAGE13I1OF4TITLEI4)Incorrect OriginalCableTrayFireStopAssemblyInstallation OutsideAppendixRDesignBasesMONTHDAYYEAR1197SEQUENTIAL REVISIONNUMBERNUMBER97-004-0MONTHDAYYEAR97FACIUTYNAMEFACILITYNAMEDOCKETNUMBER05000DOCKETNUMBER 05000OPERATING MQDE(9)POWERLEVEL(10)10020.2201(b) 20.2203(a)(2)
As a conservative measure, all the St.Lucie Unit 2 two sided cable tray fire stop assemblies were declared inoperable based on the preliminary inspection results.Hourly fire watch patrols were established as compensatory measures as required by plant administrative procedures.
(i)20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203(a)(2)(v)20.2203(a)
St.Lucie Unit 1 does not utilize cable tray fire stops of this design, so this condition is only applicable to Unit 2.A review of the original installation and inspection documentation for the construction of the two sided cable tray fire stop assemblies suggests that the apparent cause of this event was due to personnel error during the implementation of design drawings or insufficient design guidance during initial installation.
(3)(n)50.36(c)(1)50.36(c)(2)50.73(a)(2)(1) 50.73(a)(2)
A contributing cause was that the installation drawings were not clear in specifying that ceramic fiber needed to be installed around each cable in the fire stop assembly.This condition was discovered during a recent fire stop surveillance.
(iii)50.73(a)(2)
Consistent with the Industry, normal fire barrier inspection criterion is a visual inspection of exposed surfaces checking for voids, gaps, and holes.No intrusive inspections or disassembling of fire barriers are performed.
(v)50.73(a)(2)(vii)50.73(a)(2)(viii)73.71OTHERSpecifyinAbstractbeloworinNRCForm3BSANAMEK.W.Frehafer, Licensing EngineerTELEPHONE NUMBERSecludeAreeCode)(5611468-4284CAUSESYSTEMCOMPONENT MANUFACTURER REPORTABLE TONPRDS,x:,t,;4(..Nk&#xc3;"'9):A cAusEsYsTEMcoMpoNENT MANUFACTURER REPORTABLE ToNPRDSYEs(Ifyes,completeEXPECTEDSUBMISSION DATE).XNoEXPECTEDSUBMISSION DATE(15)MONTHOAYYEARABSTRACT(Limitto1400spaces,i.e.,approximately 15single-spaced typewritten lines)(16)OnJune11,1997,St,LucieUnit2wasinMode1at100percentpower.Inspection resultsindicated that,generically, twosidedcabletrayfirestopassemblies lackedtheinstallation ofceramicfiberbetweencableswithinthefirebarrier.FPLdetermined thattheas-builtconfiguration oftwosidedcabletrayfirestopassemblies didnotmeetthetestedconfiguration forathreehourfireratedassembly.
One of the fire stops was located such that a visual inspection was difficult to perform, so the inspector ran his hand around the fire stop to check for voids, gaps,'and holes.The inspector noted air flow between cables through the assembly.Although air flow was noted during that inspection, routine detection of air flow through a discrepant fire stop is problematic in nature and highly dependent on the existence of a differential pressure across the fire barrier.Even if previous inspections were performed in a hands on manner, a differential pressure could not be assured because of Reactor Auxiliary Building ventilation lineup or door configurations in effect during the inspection.
AlltheSt.LucieUnit2twosidedcabletrayfirestopassemblies weredeclaredinoperable.
This condition is reportable under 10 CFR 50.73(a)(2)(ii)(B) because the as found condition of the Unit 2 two sided cable tray fire stop assemblies do not meet three hour fire barrier requirements.
Theapparentcauseofthiseventwasduetopersonnel errorduringtheimplementation ofdesigndrawingsorinsufficient designguidanceduringinitialinstallation.
The fire barriers are discussed in the Unit 2.UFSAR in chapter 9.5A.The principal design objective of the fire barrier and associated penetration seals is to protect personnel and redundant equipment from the effects of postulated fires in the reactor auxiliary building, to assure the capability to achieve safe shutdown in accordance with 10 CFR 50 Appendix R and BTP 9.5-1 Appendix A.The barriers and associated penetration seals are passive devices and are part of the plant fire protection system.NRG F0AM 366A I4-95I C, 4 NRC FORM 366A I4-9SI LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSIO ST LUCIE UNIT 2 05000389 YEAR SEQUENTIAL REVISION 97-004-0 3 OF 4 TEXT/If more spece is required, use edditionel copies of NRC Form 366AJ l17)The ceramic fiber between the cables is an extension of the Marinite board (ceramic fiber board)fire stop face.This ceramic fiber serves to resist heat, flame, and smoke propagation through the fire stop.In conjunction with the flame retardant this is an effective three hour fire rated assembly.(See Figure 1 for typical design details).However, without the ceramic fiber between the cables a path for heat and smoke propagation is provided.This is a small and tortuous path in that the space between the cables is typically small.The heat would still need to travel at least one foot down the tray where the flame retardant is applied, then would enter a large open space in the wall, and would then need to exit through another foot of confined space between cables on the non-fire side of the assembly.Localized hot spots would exist.The IEEE-383 cables will resist the effects of the increased temperatures and help to prevent the ignition of cable in the non-fire side of the assembly.The two sided cable tray fire stop deficiencies were evaluated and determined to be not safety significant.
Corrective actionsincludethepostingofhourlyfirewatchpatrolsthatwereestablished tocompensate fortheinoperable firestopassemblies.
Although'the as-found condition of these cable tray fire stops was not in accordance with the tested and design conditions, and would probably not meet a three hour fire rating without the ceramic fiber between the cables, the installation does provide resistance to fire propagation.
Repairsorplantmodifications willbeimplemented torestoretheaffectedfirestopassemblies totheirrequiredthreehourfirerating.NACFOAM366(4.95)
In addition, fire protection defense in depth provides an integrated means for mitigating the consequences of a fire, such as the existing smoke detection systems, automatic water fire suppression systems, hose stations, administrative programs that control combustible loading, and operator actions.Based on the above, it is concluded that the health and safety of the public were not adversely affected by the condition of the St.Lucie Unit 2 two sided cable tray fire stop assemblies.
NRCFORM366AI4-9SILICENSEEEVENTREPORT(LER)TfXTCONTINUATION U.S.NUCLEARREGULATORY COMMISSIO STLUCIEUNIT205000389YEARSEQUENTIAL REVISION97-004-02OF4TEXTIlfmorespaceisrequired, useadditional copiesofiVRCForm366Ai(17lOnJune11,1997,St.LucieUnit2wasinMode1at100percentpower.FPLwasinvestigating discrepancies oftwosidedcabletrayfirestopassemblies identified duringpreviousfieldsurveillances.
The hourly fire watch patrols were established to compensate for the inoperable two sided cable tray fire stop assemblies as required by plant administrative procedures.
Intrusive inspections oftheremaining population offirestopassemblies ofthisdesignwereinprogresstodetermine theextentoftheissue.Preliminary inspection resultsindicated that,generically, theas-builtconfiguration oftwosidedcabletrayfirestopassemblies lackedtheinstallation ofceramicfiberbetweencableswithinthefirebarrier.Theconfiguration didnotconformtothedesigndrawingsandFPLascertained thattheidentified fieldconditions werenotpreviously evaluated duringinitialconstruction.
FPL will either rework the associated fire stop assemblies to their original design or develop and implement a new design to restore the degraded barriers to a three hour fire barrier rating.None.
Therefore, thetwosidedcabletrayfirestopassemblies didnotmeetthetestedconfiguration forathreehourfireratedassembly, asrequiredbytheplant10CFR50AppendixRcommitments.
NRC FORM 366A I4 95I LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSIO ST LUCIE UNIT 2 05000389 YEAR SEQUENTIAL REVISION 97-004-0 4 OF 4 TEXT (if more spoce is required, uso additional copies of NRC Arm 3MAl I17)TWO-SIDED CABLE TRAY SEAL IN FLOOR/WALL OPENING FIRESTOP 2" CERAMIC FIBER PLUGS FLAME RETARDANT MARINITE-I BOARD FLAME RETARDANT (MJOWO!ee Rot Figure 1 Typical Two Sided Cable Tray Fire Stop Assembly}}
Asaconservative measure,alltheSt.LucieUnit2twosidedcabletrayfirestopassemblies weredeclaredinoperable basedonthepreliminary inspection results.Hourlyfirewatchpatrolswereestablished ascompensatory measuresasrequiredbyplantadministrative procedures.
St.LucieUnit1doesnotutilizecabletrayfirestopsofthisdesign,sothiscondition isonlyapplicable toUnit2.Areviewoftheoriginalinstallation andinspection documentation fortheconstruction ofthetwosidedcabletrayfirestopassemblies suggeststhattheapparentcauseofthiseventwasduetopersonnel errorduringtheimplementation ofdesigndrawingsorinsufficient designguidanceduringinitialinstallation.
Acontributing causewasthattheinstallation drawingswerenotclearinspecifying thatceramicfiberneededtobeinstalled aroundeachcableinthefirestopassembly.
Thiscondition wasdiscovered duringarecentfirestopsurveillance.
Consistent withtheIndustry, normalfirebarrierinspection criterion isavisualinspection ofexposedsurfacescheckingforvoids,gaps,andholes.Nointrusive inspections ordisassembling offirebarriersareperformed.
Oneofthefirestopswaslocatedsuchthatavisualinspection wasdifficult toperform,sotheinspector ranhishandaroundthefirestoptocheckforvoids,gaps,'andholes.Theinspector notedairflowbetweencablesthroughtheassembly.
Althoughairflowwasnotedduringthatinspection, routinedetection ofairflowthroughadiscrepant firestopisproblematic innatureandhighlydependent ontheexistence ofadifferential pressureacrossthefirebarrier.Evenifpreviousinspections wereperformed inahandsonmanner,adifferential pressurecouldnotbeassuredbecauseofReactorAuxiliary Buildingventilation lineupordoorconfigurations ineffectduringtheinspection.
Thiscondition isreportable under10CFR50.73(a)(2)(ii)(B) becausetheasfoundcondition oftheUnit2twosidedcabletrayfirestopassemblies donotmeetthreehourfirebarrierrequirements.
Thefirebarriersarediscussed intheUnit2.UFSARinchapter9.5A.Theprincipal designobjective ofthefirebarrierandassociated penetration sealsistoprotectpersonnel andredundant equipment fromtheeffectsofpostulated firesinthereactorauxiliary
: building, toassurethecapability toachievesafeshutdowninaccordance with10CFR50AppendixRandBTP9.5-1AppendixA.Thebarriersandassociated penetration sealsarepassivedevicesandarepartoftheplantfireprotection system.NRGF0AM366AI4-95I C,4NRCFORM366AI4-9SILICENSEEEVENTREPORT(LER)TEXTCONTINUATION U.S.NUCLEARREGULATORY COMMISSIO STLUCIEUNIT205000389YEARSEQUENTIAL REVISION97-004-03OF4TEXT/Ifmorespeceisrequired, useedditionel copiesofNRCForm366AJl17)Theceramicfiberbetweenthecablesisanextension oftheMariniteboard(ceramicfiberboard)firestopface.Thisceramicfiberservestoresistheat,flame,andsmokepropagation throughthefirestop.Inconjunction withtheflameretardant thisisaneffective threehourfireratedassembly.
(SeeFigure1fortypicaldesigndetails).
However,withouttheceramicfiberbetweenthecablesapathforheatandsmokepropagation isprovided.
Thisisasmallandtortuouspathinthatthespacebetweenthecablesistypically small.Theheatwouldstillneedtotravelatleastonefootdownthetraywheretheflameretardant isapplied,thenwouldenteralargeopenspaceinthewall,andwouldthenneedtoexitthroughanotherfootofconfinedspacebetweencablesonthenon-firesideoftheassembly.
Localized hotspotswouldexist.TheIEEE-383cableswillresisttheeffectsoftheincreased temperatures andhelptopreventtheignitionofcableinthenon-firesideoftheassembly.
Thetwosidedcabletrayfirestopdeficiencies wereevaluated anddetermined tobenotsafetysignificant.
Although'the as-foundcondition ofthesecabletrayfirestopswasnotinaccordance withthetestedanddesignconditions, andwouldprobablynotmeetathreehourfireratingwithouttheceramicfiberbetweenthecables,theinstallation doesprovideresistance tofirepropagation.
Inaddition, fireprotection defenseindepthprovidesanintegrated meansformitigating theconsequences ofafire,suchastheexistingsmokedetection systems,automatic waterfiresuppression systems,hosestations, administrative programsthatcontrolcombustible loading,andoperatoractions.Basedontheabove,itisconcluded thatthehealthandsafetyofthepublicwerenotadversely affectedbythecondition oftheSt.LucieUnit2twosidedcabletrayfirestopassemblies.
Thehourlyfirewatchpatrolswereestablished tocompensate fortheinoperable twosidedcabletrayfirestopassemblies asrequiredbyplantadministrative procedures.
FPLwilleitherreworktheassociated firestopassemblies totheiroriginaldesignordevelopandimplement anewdesigntorestorethedegradedbarrierstoathreehourfirebarrierrating.None.
NRCFORM366AI495ILICENSEEEVENTREPORT(LER)TEXTCONTINUATION U.S.NUCLEARREGULATORY COMMISSIO STLUCIEUNIT205000389YEARSEQUENTIAL REVISION97-004-04OF4TEXT(ifmorespoceisrequired, usoadditional copiesofNRCArm3MAlI17)TWO-SIDED CABLETRAYSEALINFLOOR/WALL OPENINGFIRESTOP2"CERAMICFIBERPLUGSFLAMERETARDANT MARINITE-IBOARDFLAMERETARDANT (MJOWO!ee RotFigure1TypicalTwoSidedCableTrayFireStopAssembly}}

Revision as of 16:50, 7 July 2018

LER 97-004-00:on 970611,discovered Incorrect Original Cable Tray Fire Stop Assembly Installation Was Outside App R Design Basis.Caused by Personnel Error.Hourly Fire Watch Patrols Will Be posted.W/970711 Ltr
ML17229A397
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 07/11/1997
From: FREHAFER K W, STALL J A
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-97-179, LER-97-004-02, LER-97-4-2, NUDOCS 9707150008
Download: ML17229A397 (7)


Text

('A.'l'E QO8.2 REGULATIO INFQRMATIQN DIBTRIBUTIor~sTEM (RIDE)!ACCESSION NBR:9707150008 DOC.DATE: 97/07/11 NOTARIZED:

NO FACIL'.50-389 St.Lucie Plant, Unit 2, Florida Power&Light Co.AUTH.NAME AUTHOR AFFILIATION FREHA:ER,K.W.

Florida Power&Light Co.STALL,J.A.

Florida Power 6 Light Co.RECIP.NAME RECIPIENT AFFILIATION DOCKET¹05000389

SUBJECT:

LER 97-004-00:on 970611,discovered incorrect original cable tray fire stop assembly installation outside App R design basis.Caused personnel error.Posted hourly fire watch patrols.W/970711 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR

'NCL SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EIB EXTERNAL: L ST LOBBY WARD NOAC POOREFW.NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME WIENSFL~AEOD/SPD/RAB E T~KRONE NRR/DRCH/HHFB NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN2 FILE 01 LITCO BRYCE,J H NOAC QUEENERFDS NUDOCS FULL TXT COPIES LTTR'ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD"5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON T NEEDr FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQJIRED: LTTR 25 ENCL 25 Florida Power&Light Company, 6501 South Ocean Drive, Jensen Beach, FL34957 July 11, 1997 L-97-179 10 CFR 50.73 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Unit 2 Docket No.50-389 Reportable Event: 97-004 Date of Event: June 11, 1997 Incorrect Original Cable Tray Fire Stop P~The attached Licensee Event Report is being submitted pursuant to the requirement's of 10 CFR 50.73 to provide notification of the subject event.Very truly yours, J.A.Stall Vice President St.Lucie Plant JAS/KWF Attachment l/(W)cc: Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St.Lucie Plant'Ir707150008 9707iX PDR ADOCK 0500038'P S PDR an FPL Group company iliillllllllllllllllllllllllIlls lllllll NRC FORM 366 (4.95)U.S.NUCLEAR REGULATORY COMMISSION LZCENSEE EVENT REPORT (LER)(See reverse for required number of digits/characters for each block)APPROVED SY OMS No.3160%I 04 Exp)RES 04)3 ore 6 ESTIMATED BURDEN PER RESPONSE To COMPLY WITH THIS M ANDATO INFORMATION COLLECTION REGUEST: 60.0 HRS.REPORTED LESSON LEARNED ARE INCORPORATED INTO THE UCENSING PROCESS AND FE BACK TO INDUSTRY.FORWARD COMMENTS REGARDING BURDEN ESTIMAT To THE INFORMATION AND RECORDS MANAGEMENT BRANCH IT%F33)U.S.NUCLEAR REGIAATORY COMMISSION.

WASHINGTON, OC 206664KO)AND TO THE PAPERWORK REDUCTION PROJECT I3160<104), OFFICE 0 MANAGEMENT AND BUDGET, WASHINGTON, DC 20603.FACIUTY NAME (1)ST LUCIE UNIT 2 DOCKET NUMBER 12)05000389 PAGE 13 I 1 OF4 TITLE I4)Incorrect Original Cable Tray Fire Stop Assembly Installation Outside Appendix R Design Bases MONTH DAY YEAR 11 97 SEQUENTIAL REVISION NUMBER NUMBER 97-004-0 MONTH DAY YEAR 97 FACIUTY NAME FACILITY NAME DOCKET NUMBER 05000 DOCKETNUMBER 05000 OPERATING MQDE (9)POWER LEVEL (10)100 20.2201(b) 20.2203(a)(2)(i)20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 20.2203 (a)(2)(v)20.2203(a)

(3)(n)50.36(c)(1)50.36(c)(2)50.73(a)(2)(1) 50.73(a)(2)(iii)50.73(a)(2)(v)50.73(a)(2)(vii)50.73(a)(2)(viii)73.71 OTHER Specify in Abstract below or in NRC Form 3BSA NAME K.W.Frehafer, Licensing Engineer TELEPHONE NUMBER Seclude Aree Code)(5611 468-4284 CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS , x:,t,;4(..NkÃ"'9):A cAusE sYsTEM coMpoNENT MANUFACTURER REPORTABLE To NPRDS YEs (If yes, complete EXPECTED SUBMISSION DATE).X No EXPECTED SUBMISSION DATE (15)MONTH OAY YEAR ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines)(16)On June 11, 1997, St, Lucie Unit 2 was in Mode 1 at 100 percent power.Inspection results indicated that, generically, two sided cable tray fire stop assemblies lacked the installation of ceramic fiber between cables within the fire barrier.FPL determined that the as-built configuration of two sided cable tray fire stop assemblies did not meet the tested configuration for a three hour fire rated assembly.All the St.Lucie Unit 2 two sided cable tray fire stop assemblies were declared inoperable.

The apparent cause of this event was due to personnel error during the implementation of design drawings or insufficient design guidance during initial installation.

Corrective actions include the posting of hourly fire watch patrols that were established to compensate for the inoperable fire stop assemblies.

Repairs or plant modifications will be implemented to restore the affected fire stop assemblies to their required three hour fire rating.NAC FOAM 366 (4.95)

NRC FORM 366A I4-9SI LICENSEE EVENT REPORT (LER)Tf XT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSIO ST LUCIE UNIT 2 05000389 YEAR SEQUENTIAL REVISION 97-004-0 2 OF 4 TEXT Ilf more spaceis required, use additional copies of iVRC Form 366Ai (17l On June 11, 1997, St.Lucie Unit 2 was in Mode 1 at 100 percent power.FPL was investigating discrepancies of two sided cable tray fire stop assemblies identified during previous field surveillances.

Intrusive inspections of the remaining population of fire stop assemblies of this design were in progress to determine the extent of the issue.Preliminary inspection results indicated that, generically, the as-built configuration of two sided cable tray fire stop assemblies lacked the installation of ceramic fiber between cables within the fire barrier.The configuration did not conform to the design drawings and FPL ascertained that the identified field conditions were not previously evaluated during initial construction.

Therefore, the two sided cable tray fire stop assemblies did not meet the tested configuration for a three hour fire rated assembly, as required by the plant 10 CFR 50 Appendix R commitments.

As a conservative measure, all the St.Lucie Unit 2 two sided cable tray fire stop assemblies were declared inoperable based on the preliminary inspection results.Hourly fire watch patrols were established as compensatory measures as required by plant administrative procedures.

St.Lucie Unit 1 does not utilize cable tray fire stops of this design, so this condition is only applicable to Unit 2.A review of the original installation and inspection documentation for the construction of the two sided cable tray fire stop assemblies suggests that the apparent cause of this event was due to personnel error during the implementation of design drawings or insufficient design guidance during initial installation.

A contributing cause was that the installation drawings were not clear in specifying that ceramic fiber needed to be installed around each cable in the fire stop assembly.This condition was discovered during a recent fire stop surveillance.

Consistent with the Industry, normal fire barrier inspection criterion is a visual inspection of exposed surfaces checking for voids, gaps, and holes.No intrusive inspections or disassembling of fire barriers are performed.

One of the fire stops was located such that a visual inspection was difficult to perform, so the inspector ran his hand around the fire stop to check for voids, gaps,'and holes.The inspector noted air flow between cables through the assembly.Although air flow was noted during that inspection, routine detection of air flow through a discrepant fire stop is problematic in nature and highly dependent on the existence of a differential pressure across the fire barrier.Even if previous inspections were performed in a hands on manner, a differential pressure could not be assured because of Reactor Auxiliary Building ventilation lineup or door configurations in effect during the inspection.

This condition is reportable under 10 CFR 50.73(a)(2)(ii)(B) because the as found condition of the Unit 2 two sided cable tray fire stop assemblies do not meet three hour fire barrier requirements.

The fire barriers are discussed in the Unit 2.UFSAR in chapter 9.5A.The principal design objective of the fire barrier and associated penetration seals is to protect personnel and redundant equipment from the effects of postulated fires in the reactor auxiliary building, to assure the capability to achieve safe shutdown in accordance with 10 CFR 50 Appendix R and BTP 9.5-1 Appendix A.The barriers and associated penetration seals are passive devices and are part of the plant fire protection system.NRG F0AM 366A I4-95I C, 4 NRC FORM 366A I4-9SI LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSIO ST LUCIE UNIT 2 05000389 YEAR SEQUENTIAL REVISION 97-004-0 3 OF 4 TEXT/If more spece is required, use edditionel copies of NRC Form 366AJ l17)The ceramic fiber between the cables is an extension of the Marinite board (ceramic fiber board)fire stop face.This ceramic fiber serves to resist heat, flame, and smoke propagation through the fire stop.In conjunction with the flame retardant this is an effective three hour fire rated assembly.(See Figure 1 for typical design details).However, without the ceramic fiber between the cables a path for heat and smoke propagation is provided.This is a small and tortuous path in that the space between the cables is typically small.The heat would still need to travel at least one foot down the tray where the flame retardant is applied, then would enter a large open space in the wall, and would then need to exit through another foot of confined space between cables on the non-fire side of the assembly.Localized hot spots would exist.The IEEE-383 cables will resist the effects of the increased temperatures and help to prevent the ignition of cable in the non-fire side of the assembly.The two sided cable tray fire stop deficiencies were evaluated and determined to be not safety significant.

Although'the as-found condition of these cable tray fire stops was not in accordance with the tested and design conditions, and would probably not meet a three hour fire rating without the ceramic fiber between the cables, the installation does provide resistance to fire propagation.

In addition, fire protection defense in depth provides an integrated means for mitigating the consequences of a fire, such as the existing smoke detection systems, automatic water fire suppression systems, hose stations, administrative programs that control combustible loading, and operator actions.Based on the above, it is concluded that the health and safety of the public were not adversely affected by the condition of the St.Lucie Unit 2 two sided cable tray fire stop assemblies.

The hourly fire watch patrols were established to compensate for the inoperable two sided cable tray fire stop assemblies as required by plant administrative procedures.

FPL will either rework the associated fire stop assemblies to their original design or develop and implement a new design to restore the degraded barriers to a three hour fire barrier rating.None.

NRC FORM 366A I4 95I LICENSEE EVENT REPORT (LER)TEXT CONTINUATION U.S.NUCLEAR REGULATORY COMMISSIO ST LUCIE UNIT 2 05000389 YEAR SEQUENTIAL REVISION 97-004-0 4 OF 4 TEXT (if more spoce is required, uso additional copies of NRC Arm 3MAl I17)TWO-SIDED CABLE TRAY SEAL IN FLOOR/WALL OPENING FIRESTOP 2" CERAMIC FIBER PLUGS FLAME RETARDANT MARINITE-I BOARD FLAME RETARDANT (MJOWO!ee Rot Figure 1 Typical Two Sided Cable Tray Fire Stop Assembly