05000255/FIN-2018011-02
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Finding | |
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| Title | Failure to Set Action Levels to Ensure that the Assumptions in the Engineering Analysis Remain Valid |
| Description | The inspectors reviewed a sample of equipment located in the fire areas selectedfor inspection to determine if the licensee had established a proper method of monitoring that equipment as required by NFPA 805, Section 2.6. Section 2.6 of NFPA 805 required that, A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid. The licensee utilized Procedure EN-DC-357, NFPA 805 Monitoring Program, Revision 2,to ensure that, the assumptions in the NFPA 805 engineering analyses remain valid by executing an effective and ongoing monitoring program.The inspectors selected the high pressure air compressor (C-6B) and high pressure safety injection pump (P-66B), both of which were located in the West Safeguards Room. The licensee considered these components to be high-safety significant (HSS) structures, systems, or components (SSCs). The licensee chose to monitor the unavailability of these components utilizing the Maintenance Rule (10 CFR 50.65).The licensee set the Maintenance Rule allowable unavailability action level threshold for the high pressure air compressorat 5E-2 (5percent)whereas they assumed in their fire PRA an unavailability of 9.86E-3 (approximately 1percent). For the high pressure safety injection pump the licensee set the Maintenance Rule allowable unavailability at 1.5E-2 (1.5percent) whereas they assumed in their fire PRA an unavailability of 6.32E-3 (approximately 0.6percent). The inspectors believed that by relying on the less conservative action level thresholds in the Maintenance Rule the licensee failed to ensure that the assumptions in the engineering analysis (fire PRA) remained valid.The licensee stated in Procedure EN-DC-357, Section 1.0, Purpose, that, The NFPA 805 Monitoring Program ensures that the assumptions in the NFPA 805 engineering analyses remain valid by executing aneffective and ongoing monitoring program. Under Section 3.0, Definitions, the licensee defined, Action Level Threshold, as, When establishing the action level threshold for reliability and availability, the action level should be no lower than the Fire Probabilistic Safety Analysis [also called fire PRA] assumptions. The licensee stated in Section 5.3.3(c) that, If HSS SSCs have been identified in using the Maintenance Rule guidelines, the associated SSC specific performance criteria may be established as in the Maintenance Rule, provided the criteria are consistent with the Fire Probabilistic safety Analysisassumptions... The inspectors believed that Procedure EN-DC-357 required the licensee set the action level thresholds no lower than the fire PRA assumptions. Procedure section 5.3.4(b)(1) required that HSS equipment that is not sufficiently tracked in the Maintenance Rule be added to the NFPA 805 Monitoring Database. The licensee did not add the high pressure air compressor and the high pressure safety injection pump into the NFPA 805 Monitoring Database. In the SER 2015-2-27 dated February 27, 2015, in which the staff approved the licensee NFPA805 License Amendment Request, the staff noted that the licensee will develop an NFPA 805 Monitoring Program consistent with Frequently Asked Question (FAQ)10-0059. The staff also noted that the stated development of the Monitoring Program would include a review of existing surveillance, inspection, testing, compensatory measures, and oversight
8processes for adequacy. The staff concluded in SER 2015-2-27 that since the final values for availability and reliability, as well as the performance criteria for the SSCs being monitored, have not been established for the Monitoring Program as of the date of this SER, completion of the licensee's NFPA 805 Monitoring Program is an implementation item. Furthermore, the staff concluded that there is reasonable assurance that the licensee will develop a Monitoring Program that meets the requirements specified in Sections 2.6.1, 2.6.2, and 2.6.3 of NFPA 805Section 2.6 of NFPA 805 stated in part that, Monitoring shall ensure that the assumptions in the engineering analysis remain valid. The licensee interpreted this statement to mean that utilizing the existing Maintenance Rule unavailability values is consistent with its commitment in SER 2015-2-27 and would allow the site to appropriately monitor the availability and reliability of fire protection systems and features. The licensee also performed sensitivity studies on the differences in the unavailability values of fire protection systems and features between the Maintenance Rule criteria and the fire PRA values and determined that they were not risk-significant. The inspectors questioned the appropriateness of the licensees interpretation of assumptions as described in Section 2.6 of NFPA 805 above. The inspectors believed that the licensee should monitor the unavailability of fire protection systems and features utilizing the same values as thosedocumented in the fire PRA associated with the NFPA 805 License Amendment Request. The licensee further stated that they were waiting for guidance from the NRCs Office of Nuclear Reactor Regulation and the industry who were working on revising guidance in FAQ10-0059, NFPA 805 Monitoring, to determine if they needed to change their approach. That guidance document was in the process of being revised during the inspection. The inspectors needed to determine if the licensees approach to monitoring the availability and reliability of the fire protection systems and features using the Maintenance Rule monitoring values in order to ensure that the assumptions in the engineering analysis remained valid was an acceptable approach.Planned Closure Action(s): The inspectors will await clarification from the Office of Nuclear Reactor Regulation in order to determine if a performance deficiency exists.Licensee Action(s): The licensee plans to follow the resolution of FAQ 10-0059, Revision 6, and take the appropriate corrective actions based on the guidance provided in that FAQ. |
| Site: | Palisades  |
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| Report | IR 05000255/2018011 Section 1R05 |
| Date counted | Jun 30, 2018 (2018Q2) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | A Shaikh B Jose D Szwarc R Daley |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2018011 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2018Q2
Self-Identified List (Palisades)
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