05000321/FIN-2016007-02
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Finding | |
|---|---|
| Title | Passive Fire Protection |
| Description | The NRC identified a Green NCV of Hatch Renewed Operating License Conditions (OLCs) 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 respectively, because the licensee failed to adhere to branch technical position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1. Specifically, the licensee failed to implement the NFPA 80, Fire Doors and Windows, requirements to ensure fire confinement, thus affecting the defense in depth (DID) aspects. Description: During walkdowns of the chosen fire areas, the inspectors assessed whether the passive fire protection features adhered to the NFPA code commitments specified in the current licensing basis. Based upon the walkdown of the West DC Switchgear Room 2A (FZ 2018) and the adjacent access corridor (FZ 2014), the inspectors observed what they determined to be inadequate fire protection program implementation which would result in a degraded fire confinement ability between two fire zones. The code states, in part, that when doors are installed on only one face of a fire wall, heat responsive units shall be located on each side of the wall and interconnected so that the actuation of any one of them will permit the door to close. In this case, the heat responsive units were fusible metallic links designed to melt at a specific temperature and initiate door closure. The fusible links were not installed as required on both sides of the credited fire door between FZ 2018 and FZ 2014. Specifically, a link was only on one side of door 2L482C10. No link was installed on the side of the door in FZ 2014. The door in question was considered to be a Class A fire door and was designed to provide at least 3-hours of fire resistance between adjacent fire zones for a postulated fire event. Neither of these fire zones were protected with automatic suppression capability. In addition, there were existing exemptions in place for not meeting the 10 CFR Appendix R, III.G.2 requirements as referenced by the FHA. This further supported the need for ensuring the DID measures were adequate for fire confinement. In the second example, on October 15, 2015, the NRC resident inspector observed that an issue existed with the installation of an electro-thermal link designed to close the 2C EDG rolling fire door which separated FA 2407 from FA 0401. Specifically, it was noted that the device was installed in an improper configuration and that the electro-thermal link was mounted directly to the wall and secured using a nut and washer. In this configuration, the washer overlapped the seam of the electro-thermal link and hampered the links ability to separate and automatically close the door. The licensee declared the electro-thermal link non-functional and performed a functionality assessment. The assessment concluded that additional links designed to release the door in the event of a fire would have eventually fused, releasing the door. In addition, the gaseous carbon dioxide (CO2) fire suppression system protecting the 2C EDG would have retained the required CO2 gas concentration using the air control louvers, which were installed in series with the rolling fire door. The degraded electro-thermal link was corrected on November 10, 2015. Analysis: The licensees failure to ensure the DID aspects of the FPP were implemented consistent with the NFPA 80 requirement as specified by the current fire protection licensing basis was a PD. The PD was more than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. Specifically, the lack of a required link above the fire door between the West DC Switchgear Room 2A and the adjacent access corridor fire zone and the improperly installed link between EDG Room 2C and the adjacent access corridor would have negatively impacted the expected response time of each of the fire doors to close. In addition, review of historical work orders and condition reports indicated problems with the air balance louvers coincident with the degraded ETL controlling the closure of the fire door would have impacted the likelihood of confining the CO2 gas at the required design concentration. In both these instances, the finding had a negative impact on the program DID aspects for the fire confinement category. In accordance with NRC IMC 0609, Significance Determination Process, Appendix F, the inspectors performed a Phase 1 analysis and determined the finding resulted in very low significance, Green, based on question 1.4.3-A since, in each case, the combustible loading on both sides of the barrier wall represented a fire duration less than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (i.e., less than 120,000 Btu/ft2). The team determined that no cross-cutting attributes were applicable based upon the issue being associated with meeting the original NFPA 80 design criteria at licensing. Enforcement: Hatch Operating License Condition (OLC) 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 respectively, stated, 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 (UFSAR) for the facility. The E. I. Hatch UFSAR, Unit 2, Section 9.5, stated in part the plant fire protection system is described in the Edwin I. Hatch Nuclear Plant Units 1 and 2 Fire Hazards Analysis and Fire Protection Program (incorporated by reference into the FSAR). FHA Section 9.0, Appendix A Compliance Matrix, stated the licensee complied with the applicable sections of BTP APCSB 9.5-1. The General Guideline for Plant Protection section stated that the NFPA 80, Fire Doors and Windows was applicable for fire doors. Contrary to the above, the team identified two instances that were not consistent with the stated commitments. The licensee documented this issue with condition reports CR10085883, CR 10135493, CR 10144100, and CR10022283. The team reviewed the DID and the fire confinement provisions of NFPA 805 as referenced by Sections A.4.4.6.4 and 7.3.7. In addition, Section 5.11.3.1, which states in part that passive fire protection devices such as doors and dampers shall conform to the following NFPA standards, as applicable unless otherwise permitted by 5.11.3.2. Because Hatch committed to adopt NFPA 805 and the aforementioned issues meet the criteria as stated in the NRC Enforcement Policy (Policy), Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), the NRC will disposition the violations in accordance with the Policy and grant enforcement discretion. The NRC will also disposition the associated findings in accordance with Inspection Manual Chapter 0305, Section 11.05, Treatment of Items Associated with Enforcement Discretion. |
| Site: | Hatch  |
|---|---|
| Report | IR 05000321/2016007 Section 1R05 |
| Date counted | Jun 30, 2016 (2016Q2) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | D Jones J Dymek M Singletary P Braaten R Fanner S Shaeffer |
| Violation of: | License Condition - Fire Protection |
| INPO aspect | |
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Finding - Hatch - IR 05000321/2016007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hatch) @ 2016Q2
Self-Identified List (Hatch)
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