05000244/FIN-2015008-03
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Finding | |
|---|---|
| Title | Unanalyzed Condition due to postulated hot short fire event involving direct current (DC) control circuits affecting multiple fire areas |
| Description | Failure to ensure that one train of equipment necessary to achieve and maintain safe shutdown would remain free of fire damage was a licensee-identified 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). Exelon evaluated this issue with Ginna's fire PRA analysis and determined that the change in CDF attributed to this issue was estimated to be 4E-5 per reactor year. A review of the dominant scenarios indicated that the risk from a large early release was bounded by the core damage assessment. A Region I Senior Reactor Analyst reviewed Exelon's evaluation and concluded that the risk estimate was bounded by conservative assumptions and that this issue would be of no greater than substantial safety significance (Yellow). 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 required Exelon to maintain one train of equipment necessary to achieve and maintain safe shutdown free of fire damage. Contrary to the above, from 1967 (original construction) until April 11, 2014, Exelon postulated that fire damage to unprotected DC circuits could have resulted in secondary fires and, as a consequence, adversely affected equipment necessary to achieve and maintain safe shutdown. Exelon entered this issue into their CAP as CR-2014-001346, and subsequently corrected the condition. Exelon was in transition to NFPA 805 and, therefore, this licensee-identified issue was evaluated in accordance with the criteria established in NRC Enforcement Policy Section 9.1 and IMC 0305 Section 11.05. 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 4OA3 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | Violation: Yellow |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | IP 71153 |
| 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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