An NRC-identified non-cited violation of Vogtle Unit 1, Operating License Condition 2.G, was identified for the licensees failure to provide proper freeze protection for an 8 diameter above ground fire water line located alongside the Unit 1
Main Steam Valve Room. The
NCV was associated with exposed fire protection lines and piping that was not provided electrical freeze protection or insulated. Specifically, Design Basis Document DC-2301, Fire Protection Water System Section 3.3.6 stated, in part, that exposed lines shall be electrically freeze-protected and insulated. Vogtles
NFPA codes of record,
NFPA-14 (1983 Edition) and
NFPA-24(1984 Edition), required proper safeguards to be provided to prevent freezing for areas that were unheated and that exposed lines and equipment shall be electrically freeze protected and insulated. The licensee documented the deficiency in their corrective action program as CR482524. No immediate compensatory measures were needed because the temperature at the time of the discovery was well above freezing. The licensees failure to provide freeze protection for the Unit 1 fire protection piping, as required by the design bases document and applicable
NFPA codes, was a performance deficiency. The performance deficiency was more than minor because it adversely affected the
Mitigating Systems cornerstone attribute of Protection Against External Events 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 freeze protection for exposed sections of fire protection piping could result in the unavailability of fire suppression capability during a fire event. In accordance with NRC
IMC 0609, Appendix F, Fire Protection (
SDP) Phase 1 Worksheet, the inspectors conducted a screening and determined the finding to be of very low safety significance (Green) because temperatures at Vogtle are normally well above freezing and there was a low likelihood of complete loss of suppression capability; therefore, the deficiency was determined to be low degradation. No cross cutting aspect was assigned to this finding because the NRC concluded the finding did not reflect current licensee performance.
