05000244/FIN-2015008-01
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Finding | |
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| Title | Alternative Shutdown Procedure Deficiencies for Postulated Spurious Operations |
| Description | Failure to provide an adequate post-fire safe shutdown operating procedure to ensure the integrity of alternating current (AC) power availability was a performance deficiency (PD). This PD was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The team performed a Phase 1 Significance Determination Process (SDP) screening, in accordance with NRC Inspection Manual Chapter (IMC) 0609, Appendix F, Fire Protection Significance Determination Process. This deficiency affected the post-fire safe shutdown category because Exelon's fire response procedures were degraded. This issue was screened to very low safety significance (Green) because it was assigned a low degradation rating. The team determined this issue had a low degradation rating because the procedural deficiencies could be compensated by operator experience and system familiarity within sufficient time to maintain functionality of the A EDG. Cross-cutting aspects are not applicable to issues involving enforcement discretion. Ginna License Condition 2.C.(3), in part, required Exelon to implement and maintain in effect all fire protection features described in licensee submittals and as approved by the NRC. The Ginna FPP stated that the requirements of Appendix R,Section III.L were applicable for areas where alternative shutdown capability was selected and the B EDG Room and Vault was designated as an alternative shutdown area. Appendix R,Section III.L.3 required procedures to be in effect to implement the alternative shutdown capability. Contrary to the above, from 1983 (original Appendix R analysis) until present, Exelon had not implemented an adequate alternative shutdown procedure. Specifically, FRP-25.0 did not contain adequate instructions to ensure that postulated fire-damage to cables associated with A EDG auxiliary equipment, which were routed through the B EDG cable vault, would be mitigated prior to an adverse impact to the A EDG. As a consequence, an operator would have to recognize, diagnose, and correct a loss of power to MCC-H in sufficient time to prevent a loss of the A EDG. Exelon entered this deficiency into its CAP as CR 02563623. Exelon was in transition to NFPA 805 and, therefore, this NRC-identified issue was evaluated in accordance with the criteria established in NRC Enforcement Policy Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), and IMC 0305, Operating Reactor Assessment Program, Section 11.05, Treatment of Items Associated with Enforcement Discretion. Because all the criteria were satisfied, the NRC exercised enforcement discretion and did not issue a violation for this issue. |
| Site: | Ginna  |
|---|---|
| Report | IR 05000244/2015008 Section 1R05 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | Violation: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | J Richmond J Rogge L Dumont S Galbreath W Cook |
| Violation of: | License Condition - Fire Protection License Condition |
| INPO aspect | |
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Finding - Ginna - IR 05000244/2015008 | ||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2015Q4
Self-Identified List (Ginna)
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