An NRC-identified Green
NCV of
Technical Specification (TS) 5.4.1.d, Procedures, was identified for failure to evaluate and establish adequate compensatory measures for an impaired fire protection automatic water sprinkler system. Specifically, a solid deck scaffold platform was erected below a sprinkler system spray nozzle that would have obstructed the nozzle spray pattern protecting
safe shutdown equipment involving the 2B2 component cooling water pump/motor. The licensee entered the issue into the corrective action program (
CAP) as nuclear condition report (NCR) 01931412 and implemented immediate corrective actions to remove the
scaffolding obstructing the sprinkler nozzle. The failure to evaluate
scaffolding obstruction of a sprinkler system spray nozzle and implement required fire protection compensatory actions was a performance deficiency (
PD). The
PD was more than minor because it was associated with the
mitigating systems cornerstone attribute of protection against external factors (fire) and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, the failure to provide adequate compensatory actions for an obstructed sprinkler nozzle would have reduced the licensees ability to quickly extinguish fires in the area. The finding was screened in accordance with NRC
IMC 0609,
Significance Determination Process, Attachment 4, Initial Characterization of Findings. Using the guidance in
IMC 0609, Appendix F, Attachment 1, Fire Protection
SDP Phase 1 Worksheet, the finding was assigned a category of fixed fire protection systems. The inspectors determined the finding to be of very low safety significance (Green), because it was assigned a low degradation rating that was based upon meeting the criteria described in
IMC 0609, Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various
Fire Protection Program Elements. Specifically, less than ten percent of the sprinkler nozzles were nonfunctional, there were functional nozzles within five feet of the combustibles of concern, and the system was nominally code compliant. The finding had a cross-cutting aspect of procedure adherence in the human performance area, because the licensee failed to follow
scaffolding erection procedures which explicitly required not erecting
scaffolding that could obstruct sprinkler nozzles unless approved by a fire protection engineer and necessary compensatory actions were implemented.
