ML20197H727

Notice of Violation from Insp on 970908-18.Violations Noted: Licensee Failed to Provide Fire Barriers for Redundant Trains of Equipment in Same Fire Zones as Evidenced by Listed Examples

ML20197H727
Person / Time
Site:	Byron
Issue date:	11/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197H709	List: IR 05000454/1996019 ML20197H727
References
50-454-96-19, 50-455-96-19, EA-97-446, NUDOCS 9712310361
Download: ML20197H727 (3)

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NOTICE OF VIOLATION I

. Commonwealth Edison Company Docket Numbers 50-454; 50-455 Byron Station License Numbers NPF 37; NPF 66 EA 97-446 During an NRC inspection conducted on September 8 to 18,1997, one violation of NRC requirements was identified. Iri accordance with NUREG 1600,

• General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:

Byron Station Operating Lloenses. NPF-37 and NPFA6. Sections 2.C.(6) and  !

2E, respectively, required, in part, that the licensee stu! Implement and maintain in effect all provisions of the approved fire protection program as described in the licensee's Fire Protection Report.

Byron Updated Final Safety Analysis Report, Section 9.5.1, ' Fire Protection System," stated, in part, that the design bases; system descriptions; safety ,

evaluation, inspection and testing requirements; personnel qualification; and tralning are described in

• Byron /Byaldwood Stations Fire Protection Report in Response to Appendix A of Branch Technical Position APCSB 9.51.* ,

Appendix u.7,

• Appendix R - Fire Protection Program for Nuciear Power Facilities Operating prior to January 1,1979,* in the above mentioned Fire Protection Report, stated, in part, with exceptions not relevant here, that Byron complies with the requirements in 10 CFR 50, Appendix R, Section Ill.G,

• Fire Protection of Safety Shutdown Capability."

10 CFR 50, Appendix R. Section Ill.G required, in part, that one train of systems l necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station is free of fire damage.

10 CFR 50, Appendix R, Section Ill.G.2., required, with exceptions not relevant here, where cabies or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area, separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating or a 1-hour rating with fire detectors and an automatic fire suppression system shall be installed.

Contrary to the above, the licensee failed to provide fire barriers for reduhdant  !

treins of equipment in the same fire zones, as evidenced by the following ex1mples:

A. From initial Unit 1 startup in September 1985 to June 1996, and from initial Unit 2 startup in August 1987 to November 1996, the licensee failed to protect one train of Unit 1 auxiliary feedwater system, control room ventilation system, and miscellaneous electric equipment room (MEER) supply fans in Fire Zone 11.6-0 with rated fire barriers, in addition, the cables associated with system auxiliary transformer (SAT) cooling were 4

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'o Notice of Violation 2 unprotected and routed through the zone; therefore, offsite power would not be available to the main feedwater pumps. The aggregate effect of the damaged equipment during a postulated fire was that hot shutdown could not be maintained using the applicable equipment identified in the licensco's Fire Protection Report Sections 2.4.2.51 and 2.4.2.52.

B. From initial Unit 1 startup in September 1985 to May 1996, and from initial Unit 2 startup in August 1987 to November 1996, the licensee failed to protect one train of control room ventilation in '/ite Zone 11.4-0 with a three-hour rated fire barrier, in addition, the ca' ales associated with Units 1 and 2 fire hazard panels (FHPs) were unprott,cted in this zone. Upon exceeding the critical temperature in the main control room and the auxiliary electric room, hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Sections 2.4.2.43 and 2.4.2.42.

C. From initial Unit 1 startup in Septembsr 1985 to May 1997, the licensee failed to protect the 1 A diesel generator, one train of DC power, and control room ventilation system in Fire Zone 3.2A 1 with rated fire barriers. In addition, the cables associated with Unit 1 FHP and 4 kv power cable from Bus 141 to essential service water tower unit substation were unprotected in this zone. The aggregate effect of the damaged equipment during a postulated fire was that hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.7.

D. From initial Unit 2 startup in August 1987 to May 1997, the licensee failed to protect one train of DC power and control room ventilation in Fire Zone 3.2A 2 with rated fire barriers, in addition, the 4 kv power cable from Bus 242 to essential service water tower unit substation was unprotected in this zone. The aggregate effect of the damaged equipment Jring a postulated fire was that hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.6.

E. F rom initial Unit 1 stariup in September 1985 to June 1996, the licensee failed to protect one train of Unit 1 charging pumps with a one-hour rated fire barrier in Fire Zone 11.3-1. Hot shutdown could not be achieved and maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.3.2.38.

F. From initial Unit 1 startup in September 1985 to May 1996, the licensee failed to protect either Unit 1 motor operated valve 1RH8701 A or 1RH87018 with a three-hour rated fire barrit.r in Fire Zone 11.5-0. Hot shutdown could not be achieved and maintained using the applicable

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l Notice of Violation 3-equipment identified in the licensee's Fire Protection Report Section 2.4.3.2.1.3.

G. From initial Unit 1 startup in September 1985 to May 1996, the licensee failes' to protect one train of control room ventilation in Fire Zone 3.281 with a three hour rated fire barrier. In addition, the cables associated with the Unit 1 FHP were unprotected in this zone. Upon exceeding the critical temperature in the main control room and the auxiliary electric room, hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.8.

This is a Severity Level 111 violation (Supplement 1).

The NRC has concluded that information regarding the reason for these violations; the corrective actions taken and planned to correct the violations, and prevent recurrence; and the date when full compliance will be achieved is already adequately addressed on the docket in Inspection Report 50-454(455)/97019, LER 50-454/95005, and your October 29,1997 response to the apparent violations. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a ' Reply to a Notice of Violation,' and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region lil, and copy to the Byron NPJ Resident inspector Office, within 30 days of the date of the letter transmitting this Notice of Violation. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because the response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards inforrnation so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mull specifically identify the portions of your response that you seek to have withheld and provide in detall the bases for your claim of withholding (e.g., explain why the disclosure of information would create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financiat information). If safeguards information 5 necessa'y to provide an acceptable response, please provide the level of protect'^'t described h 10 CFR 73.21.

Dated at Usle, Illinois this 25th day of November 1997 L