On February 5, 2014, Mechanical Maintenance Department was performing a bi-annual Fire Protection Walkdown, and identified that the fire protection coating was missing on an I-beam that was a recently installed pipe support in the turbine building. This pipe support was installed by a licensee contractor as part of an engineering change to install above ground piping for safety-related
service water. The licensees investigation discovered that the work instructions did not provide steps to replace the coating or to initiate the
fire impairment in accordance with the licensees work planning process.
Technical Specification 5.4.1.c. states that written procedures shall be established, implemented, and maintained covering the
Fire Protection Program. The licensee established procedure QCAP 1500-01, Revision 32; Administrative Requirements for Fire Protection, as their implementing procedure for the
Fire Protection Program. Step D.7.a.(1)(e) states, in part, that
fire barriers (structural steel fire coating) protecting safety related or
safe shutdown areas SHALL be intact when in Mode 1, 2, & 3. Additionally, Step D.7.a.(3) states, IF
fire barrier inoperable, THEN compensatory and reporting requirements SHALL be followed per steps D.7.c and D.7.d. Contrary to the above, the licensee failed to have an intact
fire barrier while in Mode 1 without implementing any compensatory measures or reporting requirements. This was a violation of
Technical Specification 5.4.1.c. This finding is more than minor because it is associated with the Reactor Safety Mitigation Systems Cornerstone attribute of protection against external factors (fire) and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). The finding was determined to be of very low safety significance (Green) because the reactor would be able to reach and maintain a
safe shutdown condition. The licensee documented this issue in their corrective action program in
IR 1617549, Fire Protection Coating Missing on Steel I-Beam.
