BW120105, Reply to a Notice of Violation; 05000457/2012008-01
| ML12297A297 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/23/2012 |
| From: | Enright D Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| BW120105, IR-12-008 | |
| Download: ML12297A297 (4) | |
Text
October 23, 2012 BW120105 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457
Subject:
Reply to a Notice of Violation;05000457/2012008-01
Reference:
Letter from Steven A. Reynolds (U.S. NRC) to Michael J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2 Triennial Fire Protection Inspection Report 05000456/2012008; 05000457/2012008 and Notice of Violation," dated September 24,2012 In the referenced letter, based on the results of an inspection completed on September 7,2012, the NRC concluded that Braidwood Station was in violation of License Condition 2.E, which required, in part, the licensee to implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR). The NRC requested Exelon Generation Company, LLC (EGC) to respond to the Notice of Violation within 30 days of the date of the referenced letter. EGC does not contest the violation.
The attachment to this letter contains EGC's response to the Notice of Violation.
If you have any questions regarding this reply, please contact Mr. Chris VanDenburgh, Regulatory Assurance Manager, at (815) 417-2800.
RespectfUlly, Daniel J Enr~~j ~~
Site Vice President Braidwood Station
Attachment:
Reply to Notice of Violation cc: Regional Administrator - NRC Region III cc: NRC Senior Resident Inspector - Braidwood Station
Reply to Notice of Violation In a letter from Steven A. Reynolds (U.S. NRC) to Michael J. Pacilio (Exelon Generation Company, LLC), dated September 24, 2012, the NRC issued a Notice of Violation. The violation of NRC requirements was identified during an NRC inspection completed on September 7, 2012. The violation is listed below:
License Condition 2.E required, in part, the licensee to implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report (UFSAR). Section 9.5.1 of the UFSAR for Braidwood Station stated that the design bases, system descriptions, safety evaluation, inspection, and testing requirements, personnel qualification, and training are described in the Fire Protection Report. Section 2.3.10.2 of the Fire Protection Report stated that the primary extinguishing system for the Unit 2 2B diesel oil storage tank room was a manual protein foam-water system. Section 3.6.c(7) of the Fire Protection Report stated that the foam suppression systems were installed in compliance with National Fire Protection Association (NFPA) 16.
Section 4.2.1 of NFPA 16 - 1980 required compliance with applicable requirements of various NFPA standards, including standard NFPA 13. Chapter 3 of the Fire Protection Report further stated that NFPA 13 - 1985 and NFPA 16
- 1980 were the standards of record for sprinkler and foam-water sprinkler systems, respectively. Obstruction requirements for sprinklers were included in NFPA 13 - 1985 as follows: Section 4-2.4.6 of NFPA 13 -1985 specified that deflectors of sprinklers in bays shall be at sufficient distances from the beams, as shown in NFPA 13 -1985 Table 4-2.4.6 and NFPA 13 -1985 Figure 4-2.4.6, to avoid obstruction to the sprinkler discharge pattern. Table 4-2.4.6 of NFPA 13-1985 specified a maximum allowable distance above the bottom of the beam of zero inches for deflectors for sprinklers having a distance of less than one foot from beams. Section 4 4.11 of NFPA 13 -1985 specified that sprinklers be installed underneath decks or galleries, which are over four feet wide. Sections 4-2.4.6 and 4-4.11, Table 4-2.4.6, and Figure 4 2.4.6 of NFPA 13 - 1985 specified applicable requirements for NFPA 16 foam-water suppression systems.
Contrary to the above, from the time of original installation until September 7, 2012, the licensee failed to implement and maintain in effect all provisions of the approved Fire Protection Program by failing to ensure that two sprinklers in the 2B diesel oil storage tank room were free of Obstructions as required by NFPA 13
- 1985. In addition, the licensee failed to install a sprinkler under a deck or gallery over four feet wide. Specifically, the licensee located the two sprinklers less than one foot away from ventilation ducts with the deflectors located several inches above the bottom of the ventilation ducts. The configuration of the two sprinklers was similar to that of the beams discussed in Section 4-2.4.6 of NFPA 13 - 1985, in that the ventilation ducts provided obstructions similar to structural beams. In addition, the licensee failed to install a sprinkler under a 60 x 75 inch platform, which was a deck or a gallery, located on the west side of the 2B diesel oil storage tank room.
This violation is associated with a Green Significance Determination Process (SOP) finding.
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Response
Reason for the violation As documented in the Notice of Violation, the obstruction requirements of National Fire Protection Association (NFPA) 13 -1985, "Standard for the Installation of Sprinkler Systems," apply to the foam-water sprinklers located in the 2B Diesel Oil Storage Tank (OOST) room. It was previously discovered that some sprinklers from the original 2B OOST room construction deviated from the NFPA 13 - 1985 obstruction requirements.
These sprinklers and obstructions were entered into the Corrective Action Program and evaluated to verify NFPA standard compliance and determine if acceptable protection for the hazard was provided. The results of the previous engineering evaluation determined that the foam suppression capabilities in the 2B OOST room were acceptable as installed and no physical changes were required.
The engineering evaluation of the 2B OOST room fire protection system focused on evaluating compliance with NFPA 16 - 1980, "Deluge Foam-Water Sprinkler and Spray System," and failed to adequately disposition the sprinkler head obstructions considering the NFPA 13 - 1985 requirements.
This inadequate evaluation is the result of several factors; most notably the lack of familiarity with the NFPA 13 and NFPA 16 relationship as it applies to foam-water systems and associated obstructions. EGC's over reliance on external fire protection experts, not utilizing or performing additional technical reviews, and a lack of communications with the authority having jurisdiction also contributed to the failure to adequately address the sprinkler configuration in the 2B OOST room.
Corrective steps that have been taken and the results achieved Braidwood Station entered General Operation Condition Action Requirement (GOCAR)
BwAP 1110-1A3 compensatory actions on August 23, 2012 which requires verifying that automatic fire detection instrumentation is available for all four OOST rooms' fire suppression systems. If automatic detection is lost, hourly fire watches shall be implemented. Engineering and an independent Fire Protection Consultant performed extent of condition walkdowns on the four OOST rooms' fire suppression systems. A modification scoping study was completed on October 12, 2012 and determined the specific plant configuration changes necessary to eliminate/resolve the cited 2B OOST sprinkler obstructions and the extent of condition obstructions. This extent of condition review identified additional obstructions in the 1A, 1B, and 2A OOST rooms, similar to the heating ventilation and air conditioning (HVAC) obstructions in the 2B room. There were not any platform issues identified in the other rooms.
Corrective steps that will be taken Plant configuration change packages to resolve the concerns in the OOST rooms will be issued by December 28, 2012:
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a.
In the 28 DOST room, lower the two sprinklers located less than one foot away from ventilation ducts with the deflectors located several inches above the bottom of the ventilation ducts.
b.
Install one additional sprinkler under a 60 x 75 inch platform, which was a deck or a gallery, located on the west side of the 28 DOST room.
c.
Lower one sprinkler in the 1A and 18 DOST rooms and lower three sprinklers in the 2A DOST room.
Date when full compliance will be achieved Installation of the above configuration changes will be implemented by April 30, 2013.
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