05000244/FIN-2013002-01
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Finding | |
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| Title | Failure to Identify, Account for, and Properly Evaluate Non-Fire Retardant Treated Combustibles in the Screen House |
| Description | The inspectors identified a NCV of Ginna Operating License Condition 2.C.(3), Fire Protection, for failure to implement and maintain in effect all fire protection features described in licensee submittals referenced in and as approved or modified by the NRCs Safety Evaluation Report, dated February 1979 and subsequent supplements. Specifically, Constellation did not identify, account for, or evaluate 250 pounds of non-fire retardant treated plywood that has likely been installed in the screen house building (fire zone SH-2) since original construction and 434 pounds of other combustible material in the screen house. Immediate corrective actions included entering this issue into the corrective action program (CR-2013-001507 and CR-2013-001714). Additional planned corrective actions include revising the combustible loading analysis and replacing the installed plywood with a non-combustible material. The inspectors determined that the failure to treat all wood with fire retardant and maintain its combustible loading analysis accurate and up-to-date was more than minor, because it was associated with the protection against external factors attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Constellation did not identify non-fire retardant treated wood and accurately account for the amount of combustibles present in the screen house and was required to recalculate the areas combustible loading to assure the assumptions made in Ginnas exemption request from the technical requirements of Section III.G.3 of 10 CFR 50, Appendix R, were still met. Additionally, this issue is similar to example 3I described in IMC 0612, Appendix E, Examples of Minor Issues. The inspectors evaluated the finding using IMC Attachment 0609.04, Initial Characterization of Findings, and IMC 0609 Appendix F, Fire Protection Significance Determination Process, because the finding involved a failure to adequately implement fire prevention and administrative controls. A low degradation rating was assigned to this finding because the combustible loading of the screen house remained within its current LOW range, and the fire protection program element was expected to display nearly the same level of effectiveness as it would have without the degradation. Therefore, the inspectors determined the finding is of very low safety significance (Green). In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency likely occurred during original plant construction and is not reflective of present plant performance. |
| Site: | Ginna  |
|---|---|
| Report | IR 05000244/2013002 Section 1R15 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | T Moslak D Schroeder B Fuller T Fish N Perry D Dodson |
| Violation of: | 10 CFR 50 Appendix R License Condition - Fire Protection License Condition |
| INPO aspect | |
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Finding - Ginna - IR 05000244/2013002 | |||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2013Q1
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