05000321/FIN-2013009-02
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Finding | |
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| Title | Failure to Meet Section IV.C, Fire Detection and Suppression of Appendix D of the Fire Hazards Analysis |
| Description | Introduction: The NRC identified a non-compliance of Hatch OLCs 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 respectively, for the failure to locate fire extinguishers in the cable spreading room (CSR) in accordance with NFPA 10 and for the failure to locate manual hose stations in or near the CSR, such that an effective hose stream could be directed to any area in the room. Description: The FHA stated that the CSR (FZ 0024A) was equipped with a hose station and a fire extinguisher located in the adjacent room (FA 0025 mezzanine) for manual firefighting. The FHA stated that the area had mostly Class A (cable insulation) combustibles with a fire duration of greater than three hours. As a result, the licensee designated the CSR as having a high combustible loading. The FHA stated that manual firefighting equipment was fully adequate to extinguish the fire if the automatic suppression system failed. The requirements for manual firefighting capabilities were described in Section IV.C, Fire Detection and Suppression of Appendix D of the FHA.Section IV.C.6 required the licensee to provide portable fire extinguishers in the plant in accordance with NFPA 10, Standard for Portable Fire Extinguishers. For Class A hazards (such as cable insulation), NFPA 10 required fire extinguishers to be located such that the maximum travel distance to an extinguisher was 75 feet. The team identified that there were no fire extinguishers located in the CSR. The closest fire extinguisher to the CSR was located in an adjacent room (FA 0025 mezzanine). Based on the physical dimensions of the CSR, and physical obstructions in the room due to cable trays, the team determined that the travel distances from at least half of the CSR to the closest fire extinguisher exceeded the 75 foot maximum travel distance specified in NFPA 10. Section IV.C.3.d of Appendix D of the FHA required the licensee to provide manual hose stations throughout the plant to ensure that an effective hose stream could be directed to any area in the plant. The team observed that there was one hose station (HS-C20) inside the CSR and another hose station (HS-C21) in the adjacent room (FA 0025 mezzanine). However, the team noted that the licensee had deemed HS-C20 as not usable because cable trays blocked access to the hose. On July 20, 2011, the licensee implemented LDCR 2011-024 to remove the regulatory requirements for this hose station. Hose station HS-C21 was selected to serve the CSR. Additional fire hose was staged at HS-C21 to ensure that area wide coverage of the CSR was available with the fire hose stream. The team noted that the licensee did not consider physical obstructions presented in the room due to cable trays and the torturous path that responders would have to take to cover the entire CSR. Therefore, the team determined that the additional fire hose staged at HS-C21 was not sufficient to provide an effective hose stream to all areas in the CSR. In response to these issues, the licensee initiated CR 740396 for the deficiency related to fire extinguisher placement; and CR 741521 for the deficiency related to the CSR fire hose coverage. The licensee also began evaluating potential locations in the CSR where fire extinguishers could be installed to facilitate firefighting efforts in the CSR. Analysis: The team determined that the licensees failure to locate fire extinguishers in the CSR, and failure to locate manual hose stations in or near the CSR such that an effective hose stream could be directed to any area in the room were performance deficiencies. The performance deficiencies were determined to be more than minor because they were associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e. fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiencies could adversely impact timely manual fire suppression capability of a fire. The finding was screened in accordance with IMC 0609, Significance Determination Process (SDP), Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609 Appendix F, Fire Protection Significance Determination Process, review was required because the finding affected manual firefighting. Using the Fire Protection SDP Phase 1 Screening, the finding was assigned a category of Manual Firefighting. The team used step 1.3 Ability to Achieve Safe Shutdown, task 1.3.1 Screen Fire Finding for Ability to Achieve Safe Shutdown of IMC 0609, Appendix F, Attachment 1 to determine the finding to be of very low safety significance (i.e., Green) because the finding was assigned a low degradation rating. Using IMC 0609, Appendix F, Attachment 2, the finding was assigned a low degradation rating because the CSR was equipped with pre-action sprinkler system and fire detection that would alarm in the control room. Additionally, a hose station and fire extinguisher located outside the room would provide partial coverage for the CSR. The team determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. Enforcement: Hatch Renewed OLCs 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 respectively, states, in part, that Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program for the Edwin I. Hatch Nuclear Plant, Units 1 and 2, which was originally submitted by letter dated July 22, 1986.Section IV.C, Fire Detection and Suppression of Appendix D of the FHA, contains requirements for the licensees manual suppression capability.
Contrary to the above, the licensee failed to meet the requirements of Section IV.C. of Appendi D of the FHA, with the following examples: 1.Section IV.C.3.d, Water Sprinkler and Hose Standpipe Systems, of Appendix D of the FHA states, in part, that manual hose stations are located throughout the plant. An effective hose stream can be directed to any area in the plant. Contrary to the above, the licensee failed to locate manual hose stations in or near the CSR such that an effective hose stream could be directed to any area of the CSR. This issue has existed since 2011, when the licensee completed a plant change to take credit for hose HS-C21 to combat a fire in the CSR 2.Section IV.C.6, Portable Extinguishers, of Appendix D of the FHA states that portable fire extinguishers are provided in the plant in accordance with NFPA 10. NFPA 10 (1975 Edition), requires that fire extinguishers serving Class A hazards (such as cable insulation) be located such that the maximum travel distance to extinguisher is 75 feet. Contrary to the above, the licensee failed to locate fire extinguishers in an area serving Class A hazards such that the maximum travel distance to an extinguisher was not greater than 75 feet. Specifically, the licensee failed to locate portable fire extinguishers in the CSR, which contained Class A hazards such as cable insulation. This issue has existed since initial plant startup. Because the licensee committed to adopt NFPA 805 and change their fire protection licensin bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and reactor oversight process (ROP) discretion for this issue in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, this issue was identified and will be addressed during the licensees transition to NFPA 805, was entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, was not likely to have been previously identified by routine licensee efforts, was not willful, and it was not associated with a finding of high safety significance (i.e., Red). |
| Site: | Hatch  |
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| Report | IR 05000321/2013009 Section 1R05 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | Violation: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | J Montgomery M Thomas O Lopez P Braxton S Shaeffer W Monk |
| Violation of: | 10 CFR 50.48 License Condition - Fire Protection |
| INPO aspect | |
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Finding - Hatch - IR 05000321/2013009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hatch) @ 2013Q4
Self-Identified List (Hatch)
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