05000266/FIN-2010008-02
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Finding | |
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| Title | Failure to Correctly Install Component Cooling Water Area Sprinkler System |
| Description | The following finding that affects 10 CFR 50.48 was identified by the NRC and is a violation of NRC requirements. This finding has been screened and determined to warrant enforcement discretion per the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues. A finding of very low safety significance and associated violation of license Condition 4.F was identified by the inspectors for the failure to correctly install the component cooling water (CCW) area sprinkler system. Specifically, four sprinkler heads were installed with distances below the ceiling in excess of those permitted by the applicable standard. The inspectors reviewed Corrective Action Program (CAP) Document 540164, CCW Pump Room Ceiling Level Sprinklers Potentially Non-Compliant with NFPA 13, dated October 17, 2003. As part of this review, the inspectors noted that several sprinklers in the CCW pump area were not installed in accordance with the applicable NFPA code, NFPA 13 - 1978, Standard for the Installation of Sprinkler Systems. Specifically, two upright sprinklers above the CCW pumps were installed at 23 and 34 inches below the ceiling. In addition, two sidewall sprinklers located along the east wall were located 16 and 25 inches below the ceiling. The ceiling in the CCW pump area was smooth and was constructed of concrete. Section 4-3.1.1 of NFPA 13 - 1978 specified that sprinklers in bays shall be installed 1 to 12 inches below noncombustible ceilings for smooth ceiling construction. This issue was originally identified by the NRC in October 2003 and documented as an Unresolved Item (URI) in Inspection Report 05000266/2003009; 05000301/2003009. The URI was subsequently closed in Inspection Report 05000266/2004002; 05000301 when the issue was dispositioned as a Non-Cited Violation. The licensee did not contest the violation. In reviewing the issue during the 2004-2005 timeframe, the licensee mistakenly believed that compliance with NFPA 13 requirements for the sprinkler system in the CCW pump area was not required due to a July 3, 1985, exemption for partial suppression for the fire area. Consequently, the licensee failed to correct the issue in response to the violation. The inspectors noted that the fire area encompassing the CCW pump area (fire area A01-A at the time of this inspection, originally Fire Zone 3) included most of the 8-foot elevation of the auxiliary building, much of which was unsprinklered, as permitted by the exemption. However, the exemption credited the sprinkler system installed in the area of the CCW pumps for protecting cables required for safe-shutdown. The licensee noted that licensing correspondence in support of the exemption identified that CCW area sprinkler system probably would not meet NFPA 13 requirements. However, the licensing correspondence did not identify any NFPA 13 non-compliances other than the lack of full area coverage (which is an NFPA 13 requirement). Additionally, the August 2, 1979, safety evaluation report, which pre-dated the licensing correspondence in support of the exemption, stated that the sprinkler systems conformed to the applicable provisions of NFPA 13. During this inspection, the licensee presented information that the CCW pump area sprinkler system nonconformances had been justified by internal correspondence dated February 26, 1987, for purposes of avoiding obstructions. The justification had been accepted in Inspection Report 05000266/1987007(DRS); 05000301/1987007(DRS). The inspectors noted that inspection reports do not constitute licensing bases and, as discussed by Generic Letter 86-10, Implementation of Fire Protection Requirements, evaluations of code non-conformances are subject to inspection review. During this inspection, the licensee initiated Condition Report 1174162, NRC Triennial - Concerns with CC pump area sprinklers, dated May 26, 2010, and initiated hourly fire watches. The licensee planned to address the sprinkler system as part of their transition to NFPA 805. |
| Site: | Point Beach  |
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| Report | IR 05000266/2010008 Section 4OA2 |
| Date counted | Jun 30, 2010 (2010Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | R Daley R Langstaff A Dahbur C Moore D Passehl L Jones |
| INPO aspect | |
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Finding - Point Beach - IR 05000266/2010008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Point Beach) @ 2010Q2
Self-Identified List (Point Beach)
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