ML20198K398

Notice of Violation from Insp on 961013-970814.Violation Noted:Licensee Failed to Provide Barriers for Redundant Train of Equipment in Same Fire Zones

ML20198K398
Person / Time
Site:	Braidwood
Issue date:	10/02/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198K390	List: IR 05000456/1996016 ML20198K398
References
50-456-96-16-01, 50-456-96-16-1, 50-457-96-16, NUDOCS 9710240012
Download: ML20198K398 (3)

Text

. _ . _ __ _ . - - - _.

NOTICE OF VIOLATION Commor, wealth Edison Company Docket Numbers50-45G; 50-457 Braidwood Station License Numbers NPF 72; NPF 77 EA 97110 During an NRC inspection conducted on October 13,1996, to August 14,1997, two violatiors of NRC requirements were identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,' NUREG 1600, the violations are listed below:

Braidwood Station Operating Licenses, NPF-72 and NPF 77, Section 2.E, required in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as describedin the Final Safety Analysis Report, as supplemented and amended, and as approved in the NRC safety evaluation report dated November 1983 and its supplements.

Braldwood Undated 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 requirement, personnelqualification,and training are described in

• Byron /Braldwood Stations Fire Protection Report in Response to Appendix A of Branch Technical Position APCSB 9.5-1,"

Appendix 5.7, ' Appendix E - Fire Protection Program for Nuclear Power Facilities Operating prior to January 1,1979,* in the above mentioned Fire Protection Report, stated in part that Byron /Braldwood 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, specified in part that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s)is free of fire damage.

10 CFR 50, Appendix R. Section Ill.G.2 specified, except as provided in Section Ill.G.3, where cables of equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are in the same fire area, separation of cables of redundant trains by a fite barrier having a 3-hour rating, or 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rating with fire detector and an automatic suppression system, shall be provided.

1. Contrary to the above, the licensee failed to provide fire barriers for redundant trains of equipment in the same fire zones, as evidenced by the following examples: (01013)

A. From initial Unit 1 startupin July 1988 to July 1996, the licensee failed to protect one train of control room ventilation (VC) system and two control cables associated with 1 A diesel generator (DG) with rated fire barriersin Fire Zone 3.2A-1. In addition, the power cable to Unit i fire hazard panel (FHP), nonsegregated bus ducts, control cables to the ESF bus breakers, and the cables associated with an alternate source from Unit 2 cross-tie were unprotected in this zone. Aggregate effect of the equipment being damaged during a postulated fire was that hot 9710240012 971002 DR ADOCK 0500 g4 '-

Notice of Violation 2-shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.5.

B. From initial unit 1 startup in July 1988 to July 1996, the licensee failed to protect one train of VC system with a rated fire barrier in Fire Zcne 3.281. In addition, the power cable to the Unit 1 FHP was unprotecte-l and routed through the zone. Upon exceeding the critical temperature in the main control room (MCR) and the auxiliary electric equipment room (AEER), hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Proleetion Report Section 2.4.2.6.

C. From initial Unit 2 startup in October 1988 to July 1996, the licensee failed to protect one train of VC systein with a rated fire barrier in Fire Zone 11.4 0. In addition, the power cabie to the Unit 2 FHP was unprotected in this zone. Upon exceeding the critical temperature in the MCR and the AEER, hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.42.

D. From Unit 1 initial startup in July 1988 to July 1996 and initial Unit 2 startup in October 1988 to April 1996, the licensee failed to protect one train of VC system, Unit 1 DGs, and miscellaneous electric equipment room (MEER) supply fans with rated fire barriers in Fire Zone 11.5-0.

In addition, '.he power cable to 'Jnit i FHP, cables associated with system auxiliary transformer (SAT) cooling fans were unprotected and routed through the same zone. The aggregate effect of the damaged equipment during a postulated fire is that hot shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.45.

E. From initial Unit i startup in July 1988 to December 1995, and from initial Unit 2 startup in October 1988 to April 1990, the licensee failed to protect one train of Unit i auxiliary feedwater (AF) system, VC system, r.nd MEER supply fans with rated fire barriers in Fire Zone 11.6-0. In addition, the cables associated with SAT cooling were unprotected and routed through the zone; inerefore, offsite power would not be available to the main feedwater pumps. The aggregate effect of the damaged equipment during a postulated fire was that not shutdown could not be maintained using the applicable equipment identified in the licensee's Fire Protection Report Section 2.4.2.50 and Table 2.41.

i This is a Severity Level lll violation (Supplement 1).

Notice of Violation 3-

2. Contrary to the above, from June 4,1990 to September 3,1996 for Unit 1 and from October 1988 to September 3,1996 for Unit 2, the 12 roll-up doors separcting Units 1 and 2 DGs, ESF switchgear, non ESF switchgear and MEERs from the turbine building, failed to meet the three-hour rated fire barrier requirement. Specifically, the doors failed to close completely when the ventilation system was operating in the outtide air mode. (02014)

This is a Severity Level IV 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 50456/457 96016, LER 50-456/95013-01, and LER 50-456/96011 01.

However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.2011f 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 Ill, and copy to the Braidwood NRC Resident inspector Office, within 30 days of the date of the letter Memitting this Notice of Violation. Under the authority of Section 182 of the Act 42 U.S.C. B2, 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,lt should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary informationis necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the informadon that sho Jid be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information would create an unwarranted invasion of personal privacy or provKle the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this day of October 1997

.-