05000382/FIN-2009006-02
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Finding | |
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| Title | Failure to provide area wide sprinkler coverage as required in an Appendix R,Section III.G.2.c fire area |
| Description | The team identified a violation of License Condition 2.C.9 for failure to protect post-fire safe shutdown equipment against fire damage, as required by 10 CFR Part 50, Appendix R, Section III.G.2. Specifically, in Fire Area RAB 39 the licensee failed to provide area-wide sprinkler coverage that complied with the requirements in National Fire Protection Association 13-1976. As required in Appendix R,Section III.G.2.c, redundant trains within the same fire area must be protected with detection and an automatic fire suppression system when redundant post-fire safe shutdown equipment is protected with 1-hour fire barriers. The team determined this violation met the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) conditions for receiving enforcement discretion (EA-09-171). During plant walk downs of Fire Area RAB 39 (-35-foot corridor area) to review compliance with National Fire Protection Association 13-1976, the team identified three examples of failures to provide the required area-wide sprinkler coverage. • Sprinkler heads installed closer than the allowed 6-foot minimum spacing. When the first sprinkler actuates this short span allows spray to contact an adjacent sprinkler keeping it cool enough to preventing actuation. • No sprinkler coverage for the area under a large ceiling equipment hatch. • Ceiling sprinklers were blocked in four separate locations by large ventilation ducts and cable trays that exceeded the 4-foot limit below obstacles and resulted in less than area-wide coverage. Because of offsetting heights of the obstructions, the team determined that a fire would not produce a plume or a ceiling jet that would activate the existing sprinklers in the following circumstances: o Two parallel cable trays and a large diameter pipe adjacent to the emergency feedwater pump rooms, o Piping, cable trays, ductwork, and structural support members in the narrow passageway in front of the elevator, o Six cable trays and one duct that outside of Stair 6, and o Two parallel cable trays outside of the Train B heat exchanger room and above an open storage locker containing plastic covered radiological protective blankets. As immediate corrective actions, the licensee initiated Fire Impairment 2009-145, which established a continuous fire watch in the fire area, and entered this issue into the corrective action program as Condition Report 2009-01986. The team determined that Fire Area RAB 39 had redundant post-fire safe shutdown trains routed through the area. As specified in 10 CFR Part 50, Appendix R, Section III.G.2.c, an area containing redundant post-fire safe shutdown trains has adequate protection so long as one train has a 1-hour rated fire barrier wrap with detection and fixed fire suppression. The team determined the licensee had not installed some sprinklers in Fire Area RAB 39 in accordance with National Fire Protection Association 13-1976, as required by Final Safety Analysis Report, Section 9.5.1.3.1.E.3.(c). The failure to provide area-wide sprinkler coverage in a fire area that contained redundant trains of post-fire safe shutdown equipment resulted in a failure to meet the requirements of their license. From review of the scope of their National Fire Protection Association 805 conversion, the team confirmed that the licensee had actions scheduled for evaluating each fire area for compliance with the National Fire Protection Association codes. Analysis. Failure to provide area-wide sprinkler coverage in accordance with National Fire Protection Association 13-1976 for a fire area with 1-hour fire barriers was a performance deficiency. The team determined that this finding was more than minor because it is associated with the protection against external factors attribute of the mitigating systems cornerstone and adversely affected the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because this violation meets the discretion criteria of the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for a noncompliance identified during the transition to National Fire Protection Association 805, the team determined that discretion to take no enforcement action is appropriate at this time, as described in the Enforcement Policy. The team reviewed the risk assessment for the fire area and determined that the licensee demonstrated that the risk was less than high safety significance (Red). Specifically, the team determined that the fixed and transient fire sources would not generate sufficient heat to cause fire damage that rendered the systems incapable of performing their safety function. License Condition 2.C.9 states that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility through and as approved in the Safety Evaluation Report. Final Safety Analysis Report, Section 9.5.1.3.1.E.3.(c) specified that the licensee would install sprinklers in accordance with National Fire Protection Association 13-1976. National Fire Protection Association 13-1976, Section 4-4.13 specified, in part, sprinklers shall be installed beneath ducts that create obstructions over 4 feet wide. The licensee committed to the technical requirements of 10 CFR Part 50, Appendix R, by letter dated November 10, 1981. Appendix R,Section III.G.2.c specifies that the licensee must provide detection and area-wide suppression when the separation requirements for redundant post-fire safe shutdown trains are being met using a 1-hour fire barrier. Contrary to the above, from initial licensing through May 22, 2009, the licensee failed to implement and maintain in effect all provisions of their approved fire protection program, as required by 10 CFR Part 50, Appendix R, Section III.G.2. Specifically, the team identified that the licensee failed to ensure a redundant post-fire safe shut train with a 1-hour fire wrap had adequate protection. The licensee failed to provide area-wide sprinkler coverage under obstructions, under a large ceiling equipment hatch and failed to prevent wetting of sprinkler heads as required by National Fire Protection Association 13-1976. Because the licensee committed to adopting National Fire Protection Association 805 and changing their fire protection program license basis to comply with 10 CFR 50.48(c), this issue is eligible for the enforcement discretion described in the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). Specifically, the team determined that the licensee: (1) would have evaluated this issue during the conversion to National Fire Protection Association 805, (2) had entered this issue into their corrective action program and implemented appropriate compensatory measures, (3) would not have likely identified this through routine licensee efforts, and (4) had not committed the error willfully. The team determined that this violation meets the criteria for enforcement discretion for plants in transition to a risk-informed, performance-based fire protection program as allowed per 10 CFR 50.48(c) (EA-09-171). Since all the criteria were met, the NRC is exercising enforcement discretion for this issue and documenting the issue as a finding: FIN 05000382/2009006-02, Failure to provide area wide sprinkler coverage as required in an Appendix R,Section III.G.2.c fire area |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2009006 Section 1R05 |
| Date counted | Jun 30, 2009 (2009Q2) |
| Type: | Finding: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | G Pick N O'Keefe S Alferink E Uribe B Correll Z Bailey |
| INPO aspect | |
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Finding - Waterford - IR 05000382/2009006 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2009Q2
Self-Identified List (Waterford)
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