ML12269A188: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
Line 1: Line 1:
{{Adams
#REDIRECT [[IR 05000456/2012008]]
| number = ML12269A188
| issue date = 09/24/2012
| title = IR 05000456-12-008, 05000457-12-008; 07/25/2012 ?09/07/2012; Braidwood Station, Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection and Notice of Violation
| author name = Reynolds S
| author affiliation = NRC/RGN-III/DRS
| addressee name = Pacilio M
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000456, 05000457
| license number = NPF-072, NPF-077
| contact person = Dariusz Szwarc
| document report number = IR-12-008
| document type = Inspection Report, Letter, Notice of Violation
| page count = 30
}}
See also: [[see also::IR 05000457/2012008]]
 
=Text=
{{#Wiki_filter:UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                                              REGION III
                              2443 WARRENVILLE ROAD, SUITE 210
                                        LISLE, IL 60532-4352
                                        September 24, 2012
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:        BRAIDWOOD STATION, UNITS 1 AND 2
                TRIENNIAL FIRE PROTECTION INSPECTION REPORT
                05000456/2012008; 05000457/2012008 AND NOTICE OF VIOLATION
Dear Mr. Pacilio:
On September 7, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial
Fire Protection Inspection at your Braidwood Station, Units 1 and 2. The enclosed inspection
report documents the inspection results, which were discussed on August 24, 2012, with
Mr. D. Enright, and on September 7, 2012, with Ms. A. Ferko, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
The NRC has identified two findings of very low safety significance (Green) during this
inspection. One of these findings was determined to involve a violation of NRC requirements
and is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding this
violation are described in detail in the enclosed report. Although determined to be of very low
safety significance (Green), this violation is being cited in the Notice because you failed to
restore compliance within a reasonable time after the violation was identified in NRC Inspection
Report 05000456/2010002; 05000457/2010002, per Section 2.3.2 of the NRC Enforcement
Policy. The current Enforcement Policy is accessible from the NRC website at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider you may provide it in your response to the Notice. The
NRC will use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
If you contest the subject or severity of the violation you should provide a response within 30
days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with a
copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III,
 
M. Pacilio                                    -2-
2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U. S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector
office at the Braidwood Station. In addition, if you disagree with the cross-cutting aspect assigned
to any finding in this report, you should provide a response within 30 days of the date of this
inspection report, with the basis for your disagreement, to the Regional Administrator, Region III,
and the NRC Resident Inspector at the Braidwood Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any), will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records System (PARS) component of
NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
                                              Sincerely,
                                              /RA/
                                              Steven A. Reynolds, Director
                                              Division of Reactor Safety
Docket Nos. 50-456; 50-457
License Nos. NPF-72; NPF-77
Enclosure:      Inspection Report 05000456/2012008;
                05000457/2012008 and Notice of Violation
                  w/Attachment: Supplemental Information
cc w/encl:      Distribution via ListServ'
 
                                      NOTICE OF VIOLATION
Exelon Generation Company, LLC                                Docket Nos. 50-456; 50-457
Braidwood Station, Unit 1 and 2                                License Nos. NPF-72; NPF-77
During a U. S. Nuclear Regulatory Commissions (NRC) inspection conducted from July 25
through September 7, 2012, a violation of NRC requirements was identified. In accordance with
the NRC Enforcement Policy, 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 finding.
 
Notice of Violation                              -2-
Pursuant to the provisions of 10 CFR 2.201, Exelon Generation Company, LLC is hereby
required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region III, and a copy to the NRC Resident Inspector at the Braidwood
Station, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include:
(1) the reason for the violation, or, if contested, the basis for disputing the violation; (2) the
corrective steps that have been taken and the results achieved; (3) the corrective steps that will
be taken; and (4) the date when full compliance will be achieved. Your response may reference
or include previous docketed correspondence, if the correspondence adequately addresses the
required response. If an adequate reply is not received within the time specified in this Notice,
an Order or a Demand for Information may be issued as to why the license should not be
modified, suspended, or revoked, or why such other action as may be proper should not be
taken. Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public 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 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 will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information).
Dated this 24 day of September 2012.
 
          U. S. NUCLEAR REGULATORY COMMISSION
                          REGION III
Docket No:          50-456; 50-457
License No:          NPF-72; NPF-77
Report No:          05000456/2012008; 05000457/2012008(DRS)
Licensee:            Exelon Generation Company, LLC
Facility:            Braidwood Station, Units 1 and 2
Location:            Braceville, IL
Dates:              July 25 through September 7, 2012
Inspectors:          Dariusz Szwarc, Reactor Inspector, Lead
                    Benny Jose, Senior Reactor Inspector
                    Ronald Langstaff, Senior Reactor Inspector
Approved by:        Robert C. Daley, Chief
                    Engineering Branch 3
                    Division of Reactor Safety
                                                                Enclosure
 
                                              SUMMARY
IR 05000456/2012008, 05000457/2012008; 07/25/2012 - 09/07/2012; Braidwood Station,
Units 1 and 2; Routine Triennial Fire Protection Baseline Inspection.
This report covers an announced Triennial Fire Protection Baseline Inspection. The inspection
was conducted by Region III inspectors. Two findings were identified by the inspectors. One of
the findings was considered a violation (VIO) of NRC regulations. The significance of most
findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter
(IMC) 0609, Significance Determination Process (SDP). Cross-cutting aspects were
determined using IMC 0310, Components Within the Cross-Cutting Areas. Findings for which
the SDP does not apply may be Green or be assigned a severity level after NRC management
review. The NRCs program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated
December 2006.
A.      NRC-Identified and Self-Revealed Findings
        Cornerstone: Mitigating Systems
        Green. The inspectors identified a finding of very low safety significance associated with
        cited violation of License Condition 2.E for the licensees failure to implement the
        approved Fire Protection Program by failing to install foam-water sprinklers in
        accordance with the standard for installing sprinklers. Specifically, the licensee failed to
        correct significant obstructions to foam-water sprinklers in the Unit 2 2B diesel oil
        storage tank room that were previously identified by the NRC in a Non-Cited Violation in
        May 2010. The licensee entered this issue into their corrective action program and
        planned to survey each of the four diesel oil storage tank rooms for obstructions to
        determine the scope of physical changes needed to bring each room into compliance
        with the standard for installing sprinklers. The licensee will address corrective actions as
        part of their response to the Notice of Violation.
        The inspectors determined that the finding was more than minor because the significant
        obstructions to foam-water sprinklers in the 2B diesel oil storage tank room could
        adversely affect the application of foam or water suppressant in the event of a fire. The
        finding was of very low safety significance because a fire in the 2B diesel oil storage tank
        room would only affect the associated emergency diesel generator and no other
        equipment would be affected. This finding had a cross-cutting aspect in the area of
        Problem Identification and Resolution, Corrective Action Program because the issue had
        been previously identified by the NRC and the resolution did not address the cause of
        the issue, (i.e., the physical installation). [P.1(c)] (Section 4AO2b)
        Green. The inspectors identified a finding of very low safety significance for the
        licensees failure to properly address fire brigade drill performance deficiencies identified
        after completion of an unannounced fire drill. Specifically, the licensee failed to address
        the need to wait for the fire brigade leaders determination that it was safe to use
        elevators. The licensee entered this issue into their corrective action program and
        generated training requests to reinforce the proper use of elevators by the fire brigade.
        The inspectors determined that the finding was more than minor because the finding,
        if left uncorrected, would become a more significant safety concern. Specifically, the
                                                1                                          Enclosure
 
  improper use of elevators by the fire brigade during a fire could impact the ability of the
  brigade to fight a fire as smoke, heat, or flames could affect fire brigade members upon
  opening of elevator doors on the fire floor. The finding was of very low safety
  significance because the simulated fire was successfully suppressed by individuals who
  did not use the elevator. This finding had a cross-cutting aspect in the area of Human
  Performance, Work Practices because the licensee did not enforce expectations on not
  proceeding in the face of uncertainty or unexpected conditions. [H.4(a)] (Section 4AO5b)
B. Licensee-Identified Violations
  No violations of significance were identified.
                                        2                                            Enclosure
 
                                        REPORT DETAILS
1.  REACTOR SAFETY
    Cornerstones: Initiating Events and Mitigating Systems
1R05 Fire Protection (71111.05T)
    The purpose of the Fire Protection Triennial Baseline Inspection was to conduct a
    design-based, plant specific, risk-informed, onsite inspection of the licensees fire
    protection programs defense-in-depth elements used to mitigate the consequences of a
    fire. The fire protection program shall extend the concept of defense-in-depth to fire
    protection in plant areas important to safety by:
            preventing fires from starting;
            rapidly detecting, controlling and extinguishing fires that do occur;
            providing protection for structures, systems, and components important to safety
            so that a fire that is not promptly extinguished by fire suppression activities will
            not prevent the safe shutdown of the reactor plant; and
            taking reasonable actions to mitigate postulated events that could potentially
            cause loss of large areas of power reactor facilities due to explosions or fires.
    The inspectors evaluation focused on the design, operational status, and material
    condition of the reactor plants fire protection program, post-fire safe shutdown systems,
    and B.5.b mitigating strategies. The objectives of the inspection were to assess
    whether the licensee had implemented a Fire Protection Program that: (1) provided
    adequate controls for combustibles and ignition sources inside the plant; (2) provided
    adequate fire detection and suppression capability; (3) maintained passive fire
    protection features in good material condition; (4) established adequate compensatory
    measures for out-of-service, degraded or inoperable fire protection equipment, systems
    or features; (5) ensured that procedures, equipment, fire barriers and systems exist so
    that the post-fire capability to safely shutdown the plant was ensured; (6) included
    feasible and reliable operator manual actions when appropriate to achieve safe
    shutdown; and (7) identified fire protection issues at an appropriate threshold and
    ensured these issues were entered into the licensees problem identification and
    resolution program.
    In addition, the inspectors review and assessment focused on the licensees post-fire
    safe shutdown systems for selected risk significant fire areas. Inspector emphasis was
    placed on determining that the post-fire safe shutdown capability and the fire protection
    features were maintained free of fire damage to ensure that at least one post-fire safe
    shutdown success path was available. The inspectors review and assessment also
    focused on the licensees B.5.b related license conditions and the requirements of
    Title 10, Code of Federal Regulations (10 CFR) Part 50.54 (hh)(2). Inspector emphasis
    was to ensure that the licensee could maintain or restore core cooling, containment, and
    spent fuel pool cooling capabilities utilizing the B.5.b mitigating strategies following a
    loss of large areas of power reactor facilities due to explosions or fires. Documents
    reviewed are listed in the Attachment to this report.
                                            3                                            Enclosure
 
    The fire zones and B.5.b mitigating strategies selected for review during this inspection
    are listed below and in Section 1R05.13. The fire zones selected constituted five
    inspection samples and the B.5.b mitigating strategies selected constituted two
    inspection samples, respectively, as defined in Inspection Procedure 71111.05T.
      Fire Zone    Description
      3.1-1        Unit 1 Cable Tunnel
      5.5-2        Unit 2 Auxiliary Electrical Equipment Room
      9.2-1        Diesel Generator 1A Room
      9.3-1        Diesel Generator 1A Day Tank Room
      11.2-0        Auxiliary Building, General Area, 346 Foot Elevation
.2  Protection of Safe Shutdown Capabilities
  a. Inspection Scope
    For each of the selected fire areas, the inspectors reviewed the fire hazards analysis,
    safe shutdown analysis, and supporting drawings and documentation to verify that safe
    shutdown capabilities were properly protected.
    The inspectors also reviewed the licensees design control procedures to ensure that the
    process included appropriate reviews and controls to assess plant changes for any
    potential adverse impact on the fire protection program and/or post-fire safe shutdown
    analysis and procedures.
  b. Findings
    No findings of significance were identified.
.3  Passive Fire Protection
  a. Inspection Scope
    For the selected fire areas, the inspectors evaluated the adequacy of fire area barriers,
    penetration seals, fire doors, electrical raceway fire barriers, and fire rated electrical
    cables. The inspectors observed the material condition and configuration of the installed
    barriers, seals, doors, and cables. The inspectors reviewed approved construction
    details and supporting fire tests. In addition, the inspectors reviewed license
    documentation, such as NRC safety evaluation reports, and deviations from NRC
    regulations and the National Fire Protection Association (NFPA) standards to verify that
    fire protection features met license commitments.
    The inspectors walked down accessible portions of the selected fire areas to observe
    material condition and the adequacy of design of fire area boundaries (including walls,
    fire doors, and fire dampers) to ensure they were appropriate for the fire hazards in the
    area.
                                            4                                            Enclosure
 
    The inspectors reviewed the installation, repair, and qualification records for a sample of
    penetration seals to ensure the fill material was of the appropriate fire rating and that the
    installation met the engineering design.
  b. Findings
    No findings of significance were identified.
.4  Active Fire Protection
  a. Inspection Scope
    For the selected fire areas, the inspectors evaluated the adequacy of fire suppression
    and detection systems. The inspectors observed the material condition and
    configuration of the installed fire detection and suppression systems. The inspectors
    reviewed design documents and supporting calculations. In addition, the inspectors
    reviewed license basis documentation, such as NRC safety evaluation reports,
    deviations from NRC regulations, and NFPA standards to verify that fire suppression and
    detection systems met license commitments.
  b. Findings
    No findings of significance were identified.
.5  Protection from Damage from Fire Suppression Activities
  a. Inspection Scope
    For the selected fire areas, the inspectors verified that redundant trains of systems
    required for hot shutdown would not be subject to damage from fire suppression
    activities or from the rupture or inadvertent operation of fire suppression systems
    including the effects of flooding. The inspectors conducted walkdowns of each of the
    selected fire areas to assess conditions, such as the adequacy and condition of floor
    drains, equipment elevations, and spray protection.
  b. Findings
    No findings of significance were identified.
.6  Alternative Shutdown Capability
  a. Inspection Scope
    The inspectors reviewed the licensees systems required to achieve alternative safe
    shutdown to determine if the licensee had properly identified the components and
    systems necessary to achieve and maintain safe shutdown conditions. The inspectors
    also focused on the adequacy of the systems to perform reactor pressure control,
    reactivity control, reactor coolant makeup, decay heat removal, process monitoring, and
    support system functions.
    The inspectors conducted selected area walkdowns to determine if operators could
    reasonably be expected to perform the alternate safe shutdown procedure actions and
    that equipment labeling was consistent with the alternate safe shutdown procedure.
                                            5                                          Enclosure
 
    The review also looked at operator training, as well as consistency between the
    operations shutdown procedures and any associated administrative controls.
  b. Findings
    No findings of significance were identified
.7  Circuit Analyses
  a. Inspection Scope
    The inspectors verified that the licensee performed a post-fire safe shutdown analysis for
    the selected fire areas and the analysis appropriately identified the structures, systems,
    and components important to achieving and maintaining safe shutdown. Additionally,
    the inspectors verified that the licensee's analysis ensured that necessary electrical
    circuits were properly protected and that circuits that could adversely impact safe
    shutdown due to hot shorts, shorts to ground, or other failures were identified, evaluated,
    and dispositioned to ensure spurious actuations would not prevent safe shutdown.
    The inspectors' review considered fire and cable attributes, potential undesirable
    consequences, and common power supply/bus concerns. Specific items included the
    credibility of the fire threat, cable insulation attributes, cable failure modes, and
    actuations resulting in flow diversion or loss of coolant events.
    The inspectors also reviewed cable raceway drawings for a sample of components
    required for post-fire safe shutdown to verify that cables were routed as described in the
    cable routing matrices.
    The inspectors reviewed circuit breaker coordination studies to ensure equipment
    needed to conduct post-fire safe shutdown activities would not be impacted due to a lack
    of coordination. Additionally, the inspectors reviewed a sample of circuit breaker
    maintenance records to verify that circuit breakers for components required for post-fire
    safe shutdown were properly maintained in accordance with procedural requirements.
    The inspectors verified for cables that are important to safe shutdown but not part of the
    success path, and that do not meet the separation/protection requirements of Section
    III.G.2 of 10 CFR Part 50, Appendix R, that the circuit analysis considered the cable
    failure modes. In addition, the inspectors have verified that the licensee has either: (1)
    determined that there is not a credible fire scenario (through fire modeling); (2)
    implemented feasible and reliable manual actions to assure SSD capability; or (3)
    performed a circuit fault analysis demonstrating no potential impact on SSD capability
    exists.
  b. Findings
    No findings of significance were identified.
                                              6                                            Enclosure
 
.8  Communications
  a. Inspection Scope
    The inspectors reviewed, on a sample basis, the adequacy of the communication system
    to support plant personnel in the performance of alternative safe shutdown functions and
    fire brigade duties. The inspectors verified that plant telephones, page systems, sound
    powered phones, and radios were available for use and maintained in working order.
    The inspectors reviewed the electrical power supplies and cable routing for these
    systems to verify that either the telephones or the radios would remain functional
    following a fire.
  b. Findings
    No findings of significance were identified.
.9  Emergency Lighting
  a. Inspection Scope
    The inspectors performed a plant walkdown of selected areas in which a sample of
    operator actions would be performed in the performance of alternative safe shutdown
    functions. As part of the walkdowns, the inspectors focused on the existence of
    sufficient emergency lighting for access and egress to areas and for performing
    necessary equipment operations. The locations and positioning of the emergency lights
    were observed during the walkdown and during review of manual actions implemented
    for the selected fire areas.
  b. Findings
    No findings of significance were identified.
.10  Cold Shutdown Repairs
  a. Inspection Scope
    The inspectors reviewed the licensees procedures to determine whether repairs were
    required to achieve cold shutdown and to verify that dedicated repair procedures,
    equipment, and material to accomplish those repairs were available onsite. The
    inspectors also evaluated whether cold shutdown could be achieved within the required
    time using the licensee's procedures and repair methods. The inspectors also verified
    that equipment necessary to perform cold shutdown repairs was available onsite and
    properly staged.
  b. Findings
    No findings of significance were identified.
                                          7                                        Enclosure
 
.11  Compensatory Measures
  a. Inspection Scope
    The inspectors conducted a review to verify that compensatory measures were in place
    for out-of-service, degraded or inoperable fire protection and post-fire safe shutdown
    equipment, systems, or features (e.g., detection and suppression systems, and
    equipment, passive fire barriers, pumps, valves or electrical devices providing safe
    shutdown functions or capabilities). The inspectors also conducted a review of the
    adequacy of short term compensatory measures to compensate for a degraded function
    or feature until appropriate corrective actions were taken.
  b. Findings
    No findings of significance were identified.
.12  Review and Documentation of Fire Protection Program Changes
  a. Inspection Scope
    The inspectors reviewed changes to the approved fire protection program to verify that
    the changes did not constitute an adverse effect on the ability to safely shutdown. The
    inspectors also reviewed the licensees design control procedures to ensure that the
    process included appropriate reviews and controls to assess plant changes for any
    potential adverse impact on the fire protection program and/or post-fire safe shutdown
    analysis and procedures.
  b. Findings
    No findings of significance were identified.
.13  Control of Transient Combustibles and Ignition Sources
  a. Inspection Scope
    The inspectors reviewed the licensee's procedures and programs for the control of
    ignition sources and transient combustibles to assess their effectiveness in preventing
    fires and in controlling combustible loading within limits established in the fire hazards
    analysis. The inspectors performed plant walkdowns to verify that transient
    combustibles and ignition sources were being implemented in accordance with the
    administrative controls.
  b. Findings
    No findings of significance were identified.
.14  B.5.b Inspection Activities
  a. Inspection Scope
    The inspectors reviewed the licensees preparedness to handle large fires or explosions
    by reviewing selected mitigating strategies. This review ensured that the licensee
                                          8                                            Enclosure
 
      continued to meet the requirements of their B.5.b related license conditions and 10 CFR
      50.54(hh)(2) by determining that:
              Procedures were being maintained and adequate;
              Equipment was properly staged, maintained, and tested;
              Station personnel were knowledgeable and could implement the procedures; and
              Additionally, inspectors reviewed the storage, maintenance, and testing of B.5.b
              related equipment.
      The inspectors reviewed the licensees B.5.b related license conditions and evaluated
      selected mitigating strategies to ensure they remain feasible in light of operator training,
      maintenance/testing of necessary equipment and any plant modifications. In addition,
      the inspectors reviewed previous inspection reports for commitments made by the
      licensee to correct deficiencies identified during performance of Temporary Instruction
      (TI) 2515/171 or subsequent performances of these inspections.
      The B.5.b mitigating strategies selected for review during this inspection are listed
      below. The offsite and onsite communications, notifications/emergency response
      organization activation, initial operational response actions and damage assessment
      activities identified in Table A.3 1 of Nuclear Energy Institute (NEI) 06-12, B.5.b Phase II
      and III Submittal Guidance, Revision 2 are evaluated each time due to the mitigation
      strategies scenario selected.
        NEI 06-12,
      Revision 2, Licensee Strategy (Table)
        Section
          2.3.1    Spent Fuel Pool Spray - External Strategy (Table A.2-3)
          3.4.4    Manually Depressurize Steam Generators and Use Portable Pump (Table
                    A.4-4)
  b. Findings
      One finding was identified and is discussed in Inspection Report 05000456/2012404;
      05000457/2012404.
4.    OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems (71152)
  a. Inspection Scope
      The inspectors reviewed the licensees corrective action program procedures and
      samples of corrective action documents to verify that the licensee was identifying issues
      related to the Fire Protection Program at an appropriate threshold and entering them in
      the corrective action program. The inspectors reviewed selected samples of condition
      reports, design packages, and fire protection system non-conformance documents.
                                            9                                          Enclosure
 
b. Findings
  Failure to Install Foam-Water Sprinklers In Accordance With Sprinkler Standard:
  Introduction: The inspectors identified a finding of very low safety significance (Green)
  and associated cited violation (VIO) of License Condition 2.E for the failure to implement
  the approved Fire Protection Program by failing to install foam-water sprinklers in
  accordance with the standard for installing sprinklers. Specifically, the licensee failed to
  correct significant obstructions to foam-water sprinklers in the Unit 2 2B diesel oil
  storage tank room that were previously identified by the NRC in a Non-Cited Violation in
  May 2010.
  Description: The inspectors identified several obstructions to sprinkler heads in the 2B
  diesel oil storage tank room. Specifically, the two sprinklers located near Points A and
  B on Branch Lines 2 and 3, respectively, (from drawing M-603; Auxiliary Building,
  Viking Sprinkler Systems, Area 2T1 and 2T2; Floor El. 401-0) were located between
  two ventilation ducts. The sprinkler located near Point A was less than one foot from
  the ventilation duct to the east (towards the tank) and the deflector was approximately
  four inches above the bottom of the ventilation duct. The sprinkler head near Point B
  was approximately four inches from the ventilation duct to the east (towards the tank)
  and the deflector was over eight inches above the bottom of the ventilation duct. In
  addition to the two obstructed sprinklers heads, the room had a 60 inch x 75 inch
  platform almost directly below the sprinkler near Point B on the west side of the room.
  Section 2.3.10.2 of the Braidwood Station Fire Protection Report stated that the
  primary extinguishing system for the 2B diesel oil storage tank room was a manual
  protein foam-water system. The licensee stated in Section 3.6.c(7) of the Fire Protection
  Report that the foam suppression systems were installed in compliance with NFPA 16,
  Deluge Foam-Water Sprinkler and Spray Systems. Section 4.2.1 of NFPA 16 - 1980
  required compliance with applicable requirements of various NFPA standards, including
  standard NFPA 13, Standard for the Installation of Sprinkler Systems. 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.
  The ventilation ducts presented obstructions similar to that of beams and storage as
  discussed in Sections 4-2.4.6 and Section 4-2.5.1, respectively, of NFPA 13 - 1985.
  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. In addition,
  Section 4.2.5.1 of NFPA 13 - 1985 specified that a minimum of 18 inches clearance be
  maintained between top of storage and ceiling sprinkler deflectors. The ventilation ducts
  did not satisfy the 18 inch clearance requirement for the two sprinklers.
  These obstructions were previously identified. In 2009, the NRC-identified an
  Unresolved Item (URI) (URI 05000456/2009006-02; 05000457/2009006-02, Inspection
  Report 05000456/2009006; 05000457/2009006, ADAMS Accession Number
  ML090780881) concerning sprinkler obstructions in the diesel oil storage tank rooms.
                                        10                                          Enclosure
 
At the time, it was questioned whether the NFPA 13, Standard for Installation of
Sprinkler Systems, requirements for obstructions applied to NFPA 16, Deluge
Foam-Water Sprinkler and Spray Systems, such as the systems installed for the diesel
oil storage tank rooms. The NRC and the licensee agreed to seek a formal NFPA code
determination to address the issue.
In response to the request for a formal code interpretation, an NFPA fire protection
specialist responded by letter to the licensee dated June 2, 2009. The response stated:
          We cannot process a Formal Interpretation for text that clearly and
        decisively provides the requested information.
        In my opinion, Section 7.3.1 of NFPA 16 is clear. Sprinklers are required
        below open grate flooring if this flooring is wider than 4 feet. Additionally,
        the other obstruction rules of NFPA 13 apply. Unless the AHJ [Authority
        Having Jurisdiction] is considering the installation as an equivalent or
        alternative design in accordance with Section 1.5 of NFPA 16, the
        obstruction rules of NFPA 13 still apply. Nothing in NFPA 13 or NFPA 16
        allows these additional sprinklers to be omitted or the compliance with
        NFPA 13s obstruction rules to be waived based on an acceptable
        performance test.
In 2010, based on the response provided by NFPA, the NRC characterized the issue as
a Non-Cited Violation (NCV), (NCV 05000457/2010002-04, Inspection Report
05000456/2010002; 05000457/2010002, ADAMS Accession Number ML101340689),
due to sprinkler obstructions in the 2B diesel oil storage tank room and closed the URI.
In addition to the above NCV, a similar NCV was issued in 2008 for other sprinkler
obstructions in diesel oil storage tank rooms (NCV 05000456/2008004-01;
05000457/2008004-01, Inspection Report 05000456/2008004, ADAMS Accession
Number ML083190809).
During this inspection, the inspectors determined that no physical modifications had
been performed to address the sprinkler obstructions in the 2B diesel oil storage tank
room. The licensee performed an evaluation (Engineering Change 380157, GL
[Generic Letter] 86-10 Evaluation of Unit 1 an Unit 2 Diesel Fuel Oil Storage Tank
rooms Foam-Water System NFPA 13 Deviations, Revision 0) and concluded that the
overhead obstructions had a minimal impact on the foam-water systems ability to
operate and effectively provide a vapor barrier blanket in the room. In addition, the
licensee had changed their Fire Protection Report to reflect that the obstructions were
acceptable. The inspectors reviewed two previous Issue Reports (IRs) associated with
DOST foam-water sprinkler system obstructions (IR 00799972, NRC Questions
Scaffold Decking in DOST Rooms, dated July 24, 2008, and IR 00809865, NRC Issues
with DOST Foam Sprinkler System Design, dated August 22, 2008), and determined
that the licensee had closed the IRs with the corrective actions reflected as being
complete.
The inspectors disagreed with the conclusion documented for the evaluation associated
with Engineering Change (EC) 380157. The licensee had made the argument that the
obstructions would not affect the performance of a foam system. However, the
inspectors noted that NFPA 16 systems were intrinsically water systems, as well as
foam systems. The NFPA stated that the NFPA 13 criteria for obstructions applied to
                                      11                                            Enclosure
 
NFPA 16 systems, as well as NFPA 13 systems. No obstruction criteria existed for foam
only systems. The inspectors determined that classifying the diesel oil storage tank
room suppression systems as foam only systems would render the systems as non-
NFPA 16 systems, which was beyond the licensing basis for Braidwood Station. In
addition, the inspectors noted that the vendor data sheet for the foam-water sprinklers
used in the room specified that not less than two foam-water sprinklers were to be
installed in order to obtain pattern overlap. Based on the vendor data sheet information,
the inspectors concluded that obstructions were an important consideration for foam
systems, as well as water systems. The inspectors concluded that the licensee had
failed to restore compliance within a reasonable period of time after the 2010 NCV had
been identified.
In response to the inspectors concerns, the licensee initiated IR 01404288, Potential
Green NCV - Inadequate FP [Fire Protection] GL 86-10 Evaluation diesel oil storage
tank, dated August 23, 2012. As discussed in IR 01404288, the licensee planned to
survey each of the four diesel oil storage tank rooms for obstructions to determine the
scope of physical changes needed to bring each room into compliance with NFPA 13.
The issue report further noted that design changes would then be required to modify the
systems. The licensee will address corrective actions as part of their response to the
Notice of Violation.
Analysis: The inspectors determined that the failure to install foam-water sprinklers in
accordance with the standard for installing sprinklers was contrary to NFPA 13 and
License Condition 2.E. and was a performance deficiency. Specifically, the licensee
failed to correct significant obstructions to foam-water sprinklers in the 2B diesel oil
storage tank room that were previously identified by the NRC in a Non-Cited Violation in
May 2010.
The finding was determined to be more than minor because the failure to install
foam-water sprinklers in accordance with the standard for installing sprinklers was
associated with the Mitigating Systems cornerstone attribute of Protection Against
External Factors (Fire) and affected the cornerstone objective of ensuring the capability
of systems that respond to initiating events to prevent undesirable consequences (i.e.,
core damage). Specifically, the significant obstructions to foam-water sprinklers in the
2B diesel oil storage tank room could adversely affect the application of foam or water
suppressant in the event of a fire.
In accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination
Process, Attachment 0609.04, Phase I - Initial Screening and Characterization of
Findings, Table 3b, the inspectors determined the finding degraded the fire protection
defense-in-depth strategies. Therefore, screening under IMC 0609, Appendix F, Fire
Protection Significance Determination Process, was required. During the Phase I
evaluation, the finding was assigned to the finding category, Fixed Fire Protection
Systems. The finding was assigned a moderate degradation rating because less than
25 percent of the foam-water sprinkler heads were affected. The inspectors noted that a
fire in the 2B diesel oil storage tank room would only affect the associated emergency
diesel generator and no other equipment would be affected. Therefore, the inspectors
determined that a fire scenario involving a diesel oil storage tank room would be
equivalent to a Fire Damage State (FDS) of FDS0 as described in Step 2.2, Fire
Damage State Determination, of IMC 0609, Appendix F. As discussed in Step 2.2,
FDS0 scenarios are not analyzed in the fire protection Significance Determination
                                      12                                          Enclosure
 
    Process (SDP) as a risk contributor. Consequently, this issue screened as one of very
    low safety-significance (Green). This finding has a cross-cutting aspect in the area of
    Problem Identification and Resolution, Corrective Action Program. Specifically, the
    failure to install foam-water sprinklers in accordance with the standard for installing
    sprinklers was associated with the Corrective Action Program because the issue had
    been previously identified by the NRC and the resolution did not address the cause, (i.e.,
    the physical installation). [P.1(c)]
    As the licensee has not corrected the violation which was previously issued in May 2010,
    the conditions for making this issue Non-Cited as listed in Section 2.3.2a(2) of the
    Enforcement Policy are not met; therefore, the violation is being cited in the Notice of
    Violation.
4OA5 Other Activities
    Observation of Unannounced Fire Drill
  a. Inspection Scope
    On June 14, 2012, the inspectors observed the fire brigade activation and response to
    an unannounced fire drill in the turbine building (TB). The drill scenario that was used
    was 20.09.06.08, TB-369 Flammable Cabinet Fire, Revision 10. The inspectors
    evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified
    that the licensee staff identified deficiencies and openly discussed them in a self-critical
    manner during the drill debrief, and took appropriate corrective actions. Specific
    attributes evaluated were:
          proper wearing of turnout gear and self-contained breathing apparatus (SCBA);
          proper use and layout of fire hoses;
          employment of appropriate firefighting techniques;
          sufficient firefighting equipment brought to the scene;
          effectiveness of fire brigade leader communications, command, and control;
          search for victims and propagation of the fire into other plant areas;
          smoke removal operations;
          utilization of pre-planned strategies;
          adherence to the pre-planned drill scenario; and
          drill objectives.
  b. Findings
    Failure to Address Fire Brigade Performance Deficiencies
    Introduction: The inspectors identified a finding (FIN) of very low safety significance
    (Green) for the licensees failure to address fire brigade drill performance deficiencies
    identified after completion of an unannounced fire drill. Specifically the licensee failed to
    address the need to wait for the fire brigade leaders determination that it was safe to
    use elevators.
    Description: On June 14, 2012, an inspector observed an unannounced fire drill and the
    post drill critique. During the drill, the inspector was located across from the elevator on
    the 369 foot elevation of the turbine building. The inspector observed the elevator door
                                              13                                        Enclosure
 
open with three members of the fire brigade in the elevator. Two of the fire brigade
members were each dressed out in firefighting gear, including self-contained breathing
apparatus (SCBA), and the third was not. The individual not dressed out was performing
a supporting role and was not an active member of the brigade. At this time, the
inspector was the only observer located in the vicinity of the turbine building elevator.
When the elevator doors opened, the fire brigade members realized that the simulated
fire was located directly across from the elevator, remained on the elevator, and rode the
elevator back up to a higher floor. The remainder of the drill proceeded as expected and
the simulated fire was suppressed by two additional fire brigade members who entered
the area using a door from an adjoining area.
Following the drill, the licensee conducted a post drill critique during which the use of the
elevator by members of the fire brigade was not addressed. However, the use of
elevators was covered by two of the objectives of fire drill scenario 20.09.06.08, the drill
that was conducted. The fire drill scenario was located in Attachment 3 to Procedure
OP-AA-201-003, Fire Drill Performance, Revision 10. One objective stated, in part,
that, Access to fire scene is directed such that brigade members do not ride the TB-369
elevator to the fire floor unless determined to be safe by the Brigade Leader. Another
objective stated that, Access to the fire scene is of particular importance since this fire is
in close proximity to the TB elevator. That objective also referenced fire training module
FPB11. Section XV, Use of Elevators during Fires, of training module FPB11 stated
that, The use of the plant elevators during a fire is a determination made by the fire
brigade leader as part of his initial size up.
When questioned on the use of the elevator, the fire brigade members stated that they
did not exit the elevator once the doors opened on the 369 foot elevation as they
determined that the fire was located across from the elevator. They remained in the
elevator, rode the elevator up to a higher floor, and proceeded down the stairs through
an adjoining area. The fire brigade members had used the elevator to access the fire
floor during the drill without waiting for the fire brigade leaders determination that it was
safe to do so. In fact, the fire brigade leader had instructed the brigade members not to
use the elevators. However, the brigade members in the elevator did not receive this
communication until the elevator doors had closed and the elevator was on its way to the
369 foot elevation. It was not possible at that point to stop the elevator. The inspectors
concluded that the fire brigade members should have waited for instructions from the fire
brigade leader before using the elevator. The inspectors were concerned that the fire
brigade could be overcome by fire, heat, or smoke if they used an elevator during an
actual fire and that elevator opened near the fire. Such use could result in casualties
and complicate fire suppression efforts.
In response to the inspectors concerns, the fire marshal stated that the use of elevators
during fire drills was up to the individual fire brigade members. The fire drill evaluators
concluded that proper cues, such as signs indicating the presence of smoke or other fire
effects, were not located in the elevators to give warning to the fire brigade members.
The licensee captured this observation in IR 01378314, LL - NRC 6/14/12 Fire Drill
Observations, dated June 14, 2012, and revised the scenario to place a cue inside the
elevator so that the cue would be available no matter where the elevator was accessed.
The licensees corrective action program documented the resolution of IR 01378314 as
complete. The inspectors concluded that the corrective action of placing cues in the
                                        14                                          Enclosure
 
elevator did not address the need to wait for the fire brigade leaders determination that it
was safe to use elevators.
Section 4.2.5.1 of Procedure OP-AA-201-003, stated that performance deficiencies of
the Fire Brigade or of individual members should be addressed in the drill critique,
quarterly training sessions, or remedied by additional training or other actions, as
warranted. Therefore, the inspectors concluded that this corrective action did not
satisfy Section 4.2.5.1 of Procedure OP-AA-201-003. The licensee captured the
inspectors concerns in IR 01403621, Lessons Learned - 6/14/2012 Fire Drill Critique
Issues, dated August 22, 2012, generated training requests to reinforce the proper
use of elevators, and recommended that additional clarification be provided in procedure
OP-AA-201-003 regarding the meeting of drill objectives.
Following the drill the licensee completed Attachment 1, Fire Drill Record, of OP-AA-
201-003 and concluded that the overall response was effective and satisfactory because
the simulated fire was suppressed. Step 4.2.5.4 of OP-AA-201-003 allowed the drill
controller to determine that the overall drill performance had been satisfactory even
though individual performance deficiencies were identified provided the simulated fire
was suppressed.
During the inspection the licensee also initiated IR 01398598, NRC Identified Issues
with 6/14/2012 Fire Drill, dated August 8, 2012, and recommended that Operations
perform a work group evaluation and verify that training emphasized the practices
related to elevator usage as specified in training module FPB11.
Analysis: The inspectors determined that the failure to address fire brigade drill
performance deficiencies identified after the completion of an unannounced fire drill was
contrary to Step 4.2.5.1 of Procedure OP-AA-201-003 and was a performance
deficiency. Specifically, the licensee failed to address the need to wait for the fire
brigade leaders determination that it was safe to use elevators.
The finding was determined to be more than minor because the finding, if left
uncorrected, would become a more significant safety concern. Specifically, the improper
use of elevators by the fire brigade during a fire could impact the ability of the brigade to
fight a fire as smoke, heat, or flames could affect fire brigade members upon opening of
elevator doors on the fire floor. The inspectors concluded this finding was associated
with the Mitigating Systems cornerstone attribute of Protection Against External Factors
(Fire) and affected the cornerstone objective of ensuring the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences (i.e., core damage).
In accordance with IMC 0609, Significance Determination Process, Attachment
0609.04, Phase I - Initial Screening and Characterization of Findings, Table 3b the
inspectors determined the finding degraded the fire protection defense-in-depth
strategies. However, screening under IMC 0609, Appendix F, Fire Protection
Significance Determination Process, was not appropriate because it does not address
issues related to fire brigade performance. Therefore, the significance of the issue was
determined using IMC 0609, Appendix M, Significance Determination Process Using
Qualitative Criteria, and discussion with NRC regional management. Although fire
brigade performance was affected, the inspectors determined that the finding was of
very low safety significance (Green) because the simulated fire was successfully
suppressed by individuals who did not use the elevator.
                                    15                                            Enclosure
 
    This finding has a cross-cutting aspect in the area of Human Performance, Work
    Practices because the licensee did not enforce expectations on not proceeding in the
    face of uncertainty or unexpected conditions. Specifically, the licensees fire brigade
    members used elevators to arrive at the fire floor without waiting for the fire brigade
    leader to determine that it was safe to do so. [H.4(a)]
    Enforcement: The licensee established OP-AA-201-003, Fire Drill Performance as
    the implementing procedure for conducting fire drills. Section 4.2.5.1 of Procedure
    OP-AA-201-003, stated that, performance deficiencies of the Fire Brigade or of
    individual members should be addressed in the drill critique, quarterly training sessions,
    or remedied by additional training or other actions, as warranted.
    Contrary to the above, on June 14, 2012, the licensee failed to address fire brigade drill
    performance deficiencies identified after the completion of an unannounced fire drill.
    During the drill critique and in the proposed corrective actions, the licensee did not
    address the improper use of elevators by the fire brigade until prompted by the
    inspector. Specifically the licensees proposed corrective actions were to revise the
    scenario to place cues inside the elevator rather than address the need to wait for the
    fire brigade leaders determination that it was safe to use elevators.
    This finding does not involve enforcement action because no regulatory requirement
    violation was identified. This finding is identified as a FIN because it does not involve a
    violation, is of very low safety significance, and was entered into the licensees corrective
    action program as IRs 01378314, 01398598, and 01403621. (FIN 05000456/2012008-
    02; 05000457/2012008-02, Failure to Address Fire Brigade Performance Deficiencies)
4OA6 Management Meetings
.1  Exit Meeting Summary
    On September 7, 2012, the inspectors presented the inspection results to Ms. A. Ferko,
    and other members of the licensee staff. The licensee acknowledged the issues
    presented. The inspectors confirmed that none of the potential report input discussed
    was considered proprietary.
.2  Interim Exit Meeting
    On August 24, 2012, the inspectors presented the preliminary inspection results to
    Mr. D. Enright, and other members of the licensee staff.
ATTACHMENT: SUPPLEMENTAL INFORMATION
                                            16                                          Enclosure
 
                                SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee
D. Enright, Site Vice-President
M. Kanavos, Plant Manager
A. Ferko, Engineering Director
M. Marchionda-Palmer, Operations Director
P. Raush, Senior Manager, Design Engineering
T. Tierney, Operations Support Manager
C. VanDenburgh, Regulatory Assurance Manager
B. Finlay, Security Manager
D. Riedinger, Manager, Design Engineering
Nuclear Regulatory Commission
S. Reynolds, Director, Division of Reactor Safety
B. Dickson, Chief, Health Physics and Incident Response Branch
K. Riemer, Chief, Reactor Projects Branch 2
J. Benjamin, Senior Resident Inspector
A. Garmoe, Resident Inspector
                    LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed
05000457/2012008-01        VIO    Failure to Install Foam-Water Sprinklers In Accordance With
                                  Sprinkler Standard (Section 4OA2b)
05000456/2012008-02;      FIN    Failure to Properly Address Fire Brigade Performance
05000457/2012008-02                Deficiencies (Section 4AO5b)
                                            1                                        Attachment
 
                                  LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
ANALYSES AND EVALUATIONS
Number                    Description or Title                            Date or Revision
EC 380157                  GL 86-10 Evaluation of Unit 1 and Unit 2                  0
                          Diesel Fuel Oil Storage Tank Rooms
                          Foam-Water System NFPA 13 Deviations
CALCULATIONS
Number                    Description or Title                            Date or Revision
19-AN-3                    Protective Relay Settings for 4.16 kV ESF                16
                          Switchgear
19-AN-5                    Diesel Generator Protective Relay Settings                3
19-AU-4                    480V Unit Substation Breaker and Relay                  18
                          Settings
BRW-97-0473                Circuit Breaker Trip Settings-125V dc and                1
                          250V dc Distribution Centers
BRW-97-0475                125V dc Fuse Sizing and Coordination                      0
CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION
Number                    Description or Title                            Date or Revision
IR 01393564                NRC Triennial FP Inspection - Security            July 26, 2012
                          Training of B.5.b
IR 01394082                NRC Observations During Fire Protection            July 27, 2012
                          Triennial (B.5.b)
IR 01398030                NRC-Identified - Labeling Enhancement -          August 7, 2012
                          2AP05ES
IR 01398037                NRC-Identified - 2B D/G Output Breaker            August 7, 2012
                          Labeling Enhancement
IR 01398065                NRC-Identified - BWOP FP-100T35 has              August 7, 2012
                          Reference Error
IR 01398094                NRC-Identified Housekeeping Issue -              August 7, 2012
                          Ladder Storage
IR 01398598                NRC-Identified Issues with June 14, 2012          August 8, 2012
                          Fire Drill
IR 01398786                NRC-Identified - BWOP FP-100T35                  August 8, 2012
                          Enhancement
IR 01399021                NRC-Identified - BWOP FP-100T Series              August 9, 2012
                          Proc. Enhancements
                                              2                                          Attachment
 
CORRECTIVE ACTION PROGRAM DOCUMENTS ISSUED DURING INSPECTION
Number          Description or Title                        Date or Revision
IR 01402981      Safe Shutdown Analysis Requires            August 21, 2012
                Clarification
IR 01403387      MA-BR-726-633 Procedure Enhancement        August 22, 2012
IR 01403621      LL-6/14/2012 Fire Drill Critique Issues    August 22, 2012
IR 01404288      Potential Green NCV - Inadequate FP GL      August 23, 2012
                86-10 Evaluation DOST
IR 01404324      2012 NRC FP Inspection Observation          August 23, 2012
IR 01404336      2012 NRC FP Inspection Observation          August 23, 2012
                Stairwell Sprinklers
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number          Description or Title                        Date or Revision
IR 00799972      NRC Questions Scaffold Decking in DOST      July 24, 2008
                Rooms
IR 00809865      NRC Issues with DOST Foam Sprinkler        August 22, 2008
                Design
IR 01137149      Byron NRC FP Triennial Inspection          November 8, 2010
                Concern - 4 kV Bus Restoration
IR 01147300      Byron IR Applicable to Braidwood-DC        December 2, 2010
                Circuit Breakers
IR 01200231      NER 11-009 Identified Vulnerability with      April 9, 2011
                Radio Design
IR 01282334      Pre NRC Triennial Inspection Self-            June 1, 2012
                Assessment
IR 01300720      Radio Transmission Problem                December 10, 2011
IR 01326033      NRC Green NCV - Inadequate                February 13, 2012
                Maintenance Rule Evaluation of CQ
IR 01378314      LL - NRC 6/14/12 Fire Drill Observations    June 14, 2012
IR 01390780      Perform Formal Evaluation of Flammable      July 19, 2012
                Gas Bottles
IR 01395499      Maintenance Rule Performance Criteria        July 31, 2012
                CQ1 Exceeds CME Limit
DRAWINGS
Number          Description or Title                        Date or Revision
20E-0-3301      Electrical Installation Auxiliary Building        CH
                Plan Elevation 346-0
20E-0-3663      Cable Pans Routing Auxiliary Building              AV
                Plan Elevation 401-0
20E-0-4001      Station One Line Diagram                          AA
20E-0-4001B    Station Key Diagram                                AI
20E-0-4008AG    Tabulation of Trip Settings, 480V Turbine          Q
                                      3                                    Attachment
 
DRAWINGS
Number        Description or Title                          Date or Revision
              Building MCC 033W3
20E-1-3341    Electrical Installation Auxiliary Building          BJ
              Plan Elevation 415-0
20E-1-4002E  Single Line Diagram 120V AC ESF                      M
              Instrument Inverter Bus 111 and 113
20E-1-4010A  Key Diagram 125V DC Distribution Center              M
              Bus 111
BR-E-10      CT Gypsum with Sheet Metal Collar for                E
              Fire/Air Seals at Cable Tray/Cable
              Openings in Floors
M-603, Sh. 71 Auxiliary Building, Viking Sprinkler                D
              Systems, Area 2T1 and 2T2, Floor El.
              401-0
M-603, Sh. 94 Auxiliary Building, Viking Sprinkler                  B
              Systems, Area 1-KK6, Floor Elev. 346.0,
              Unit 1
PROCEDURES
Number        Description or Title                          Date or Revision
1BwOA ELEC-3  Loss of 4 kV ESF Bus Unit 1                        101
1BwOA ELEC-5  Local Emergency Control of Safe                    104
              Shutdown Equipment Unit 1
20.09.06.08    TB-369 Flammable Cabinet Fire                        10
BwAP 1100-21  Gaseous Suppression System Areas;                    9
              Special Precautions
BwAP 320-1    Shift Staffing                                      21
BwOP CO-5      Manual Actuation of the Carbon Dioxide                6
              Fire Suppression Systems
BwOP DC-7-111  125V DC ESF Bus 111 Cross-                          11
              Tie/Restoration
BwOP FP-100    Fire Response Guidelines                            10
BwOP FP-100T31 Fire Zones 3.1-1, 3.1-2 Unit 1/Unit 2 Cable          6
              Tunnels 1D-64, 1D-65, 2D-64, 2D-65, 2S-
              47
BwOP FP-100T35 Fire Zones 5.5-1 and 5.5-2 Unit 1/Unit 2              6
              Auxiliary Electrical Equipment Rooms 1D-
              69, 2D-69
BwOP FP-100T37 Fire Zones 9.1-1, 9.1-2, 9.2-2, 9.3-1, 9.3-2,        5
              9.4-1 Unit 1/Unit 2 Diesel Generator and
              Diesel Generator Day Tank Rooms 1D-71,
              1D-72, 1S-37, 1S-38, 1S-39, 1S-40, 2D-71,
              2D-72, 2S-37, 2S-38, 2S-39, 2S-40
BwOP FP-100T51 11.2-0 346 Auxiliary Building General Area          4
              2D-17, 2D-40
                                    4                                    Attachment
 
PROCEDURES
Number            Description or Title                    Date or Revision
BwOP MS-6        Local Operation of the Steam Generator          13
                  Power Operated Relief Valves
MA-AA-723-325    Molded Case Circuit Breaker Testing              10
MA-AA-723-350    Emergency Lighting Battery Pack                  11
                  Inspection and Test
MA-AA-725-102    Preventive Maintenance on Westinghouse            7
                  Type DHP 4 kV, 6.9 and 13.8 kV Circuit
                  Breakers
MA-AA-725-562    Preventive Maintenance on Westinghouse            6
                  Type DS 480 V Circuit Breakers
MA-BR-726-633    Installation of Post-Fire Cold Shutdown          2
                  Emergency Cable
MA-BR-773-501    Braidwood Unit 1 4 kV UAT, SAT and Bus            3
                  Tie Breakers Relay Routine
MA-BR-773-511    Braidwood Unit 1 480 V Unit Substation            1
                  Feed Breaker Relay Routine
OP-AA-201-001    Fire Marshall Tours                              5
OP-AA-201-003    Fire Drill Performance                          10
OP-AA-201-003    Fire Drill Performance                          12
OP-AA-201-004    Fire Prevention for Hot Work                      9
OP-AA-201-005    Fire Brigade Qualification                        8
OP-AA-201-008    Pre-Fire Plan Manual                              3
OP-BR-102-106    Operator Response Time Program at                0
                  Braidwood Station
OP-BR-201-009    Control of Transient Combustible Program          0
PRE-FIRE PLAN    FZ 11.2-0; AB 346 Aux. Bldg. General            0
#101              Area (South)
PRE-FIRE PLAN #98 FZ 11.2-0; AB 346 Unit 2 Aux. Bldg.              0
                  General Area (Center)
PRE-FIRE PLAN #99 FZ 11.2-0; AB 346 Unit 1 Aux. Bldg.              0
                  General Area (North)
REFERENCES
Number            Description or Title                    Date or Revision
FBP11              Emergency Response Training Fire                9
                  Brigade Program
WORK ORDERS
Number            Description or Title                    Date or Revision
01357192          Cable Tunnel Area 1DD Low Press CO2      May 29, 2012
                  Sys Actuation 18 M
01391113          18 Mo. Visual Inspection of SR Fire      April 3, 2012
                  Dampers (1A)
                                      5                                  Attachment
 
WORK ORDERS
Number      Description or Title                  Date or Revision
01391498    0B Fire Protection Pump Flow and        July 5, 2012
            Pressure Test
01393816    DG RM 1A Low Press CO2 Actuation        July 12, 2012
            Surveillance
01421457    U1 Diesel Fuel Oil Storage Tank Room    July 4, 2011
            Foam Sprinkler Hdr and Del Noz Air Flo
01449872    1A Lake Screen House Forebay          August 28, 2011
            Inspection Report
BwSD-CO-20  Carbon Dioxide Fire Protection Diesel  August 10, 1984
            Generator Rooms 1A and 1B and Diesel
            Generator Day Tank Rooms 1A and 1B
BwSD-CO-21  CO2 BOP Fire Protection                July 22, 1986
                              6                                Attachment
 
                        LIST OF ACRONYMS USED
AC    Alternating Current
ADAMS Agencywide Document Access Management System
AHJ  Authority Having Jurisdiction
CFR  Code of Federal Regulations
DC    Direct Current
DOST  Diesel Oil Storage Tank
EC    Engineering Change
El    Elevation
ESF  Essential Safety Feature
FDS  Fire Damage State
FIN  Finding
FP    Fire Protection
FSAR  Final Safety Analysis Report
GL    Generic Letter
IMC  Inspection Manual Chapter
IP    Inspection Procedure
IR    Inspection Report
IR    Issue Report
kV    Kilovolt
NCV  Non-Cited Violation
NEI  Nuclear Energy Institute
NFPA  National Fire Protection Association
NRC  U.S. Nuclear Regulatory Commission
PARS  Publicly Available Records
SCBA  Self-Contained Breathing Apparatus
SDP  Significance Determination Process
SSD  Safe Shutdown
TB    Turbine Building
TI    Temporary Instruction
URI  Unresolved Item
V    Volt
VIO  Violation
                                  7                Attachment
 
M. Pacilio                                                                -2-
If you contest the subject or severity of the violation you should provide a response within 30 days
of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with a copy to the
Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road,
Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U. S. Nuclear Regulatory
Commission, Washington, DC 20555-0001; and the NRC Resident Inspector office at the
Braidwood Station. In addition, if you disagree with the cross-cutting aspect assigned to any
finding in this report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your disagreement, to the Regional Administrator, Region III, and the
NRC Resident Inspector at the Braidwood Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any), will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records System (PARS) component of
NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
                                                                          Sincerely,
                                                                          /RA/
                                                                          Steven A. Reynolds, Director
                                                                          Division of Reactor Safety
Docket Nos. 50-456; 50-457
License Nos. NPF-72; NPF-77
Enclosure:                Inspection Report 05000456/2012008;
                          05000457/2012008 and Notice of Violation
                            w/Attachment: Supplemental Information
cc w/encl:                Distribution via ListServ'
DISTRIBUTION:
See next page
DOCUMENT NAME:G:\DRSIII\DRS\Work in Progress\-BRA 2012 008                                                  DXS.docx
Publicly Available                        Non-Publicly Available                    Sensitive              Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE                  RIII/EB3                  RIII/EB3                RIII/EICS                    RIII/DRS
NAME                    DSzwarc                    RDaley                  SOrth                        SReynolds
DATE                    09/17/12                  09/19/12                09/19/12                    09/24/12
                                                          OFFICIAL RECORD COPY
 
Letter to Mr. Michael J. Pacilio from Mr. Steven A. Reynolds dated September 24, 2012.
SUBJECT:      BRAIDWOOD STATION, UNITS 1 AND 2
              TRIENNIAL FIRE PROTECTION INSPECTION REPORT
              05000456/2012008; 05000457/2012008 AND NOTICE OF VIOLATION
DISTRIBUTION:
Silas Kennedy
RidsNrrDorlLpl3-2 Resource
RidsNrrPMBraidwood Resource
RidsNrrDirsIrib Resource
Chuck Casto
Cynthia Pederson
Steven Orth
Jared Heck
Allan Barker
DRPIII
DRSIII
Christine Lipa
Carole Ariano
Linda Linn
Patricia Buckley
Tammy Tomczak
ROPreports.Resource@nrc.gov
}}

Revision as of 03:13, 17 December 2019

Redirect to:

Retrieved from "https://kanterella.com/w/index.php?title=ML12269A188&oldid=2279500"