05000259/FIN-2009009-03
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Finding | |
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Title | Failure to Protect Cables of Systems Necessary to Achieve and/or Maintain Post-Fire Safe Shutdown Conditions for Fire Areas Subject to the Requirements of 10 CFR Part 50, Appendix R, Section III.G.2 |
Description | The team identified an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix R,Section III.G.2, for the licensees failure to ensure one of the redundant trains of cables and equipment required for safe shutdown and located in the same fire area was free of fire damage. Specifically, cables associated with equipment required for safe shutdown had not been protected by one of the methods specified in 10 CFR Part 50, Appendix R, Section III.G.2 (i.e., use of spatial separation, passive barriers, and fire detection and an automatic fire suppression system). This apparent violation applies to Browns Ferry Units 1, 2, and 3, and resulted from review and closure of two unresolved items which were opened in previous inspections. The licensee entered this apparent violation into their corrective action program and posted additional compensatory measures while long term corrective actions are being implemented. Failure to protect one train of cables and equipment necessary to achieve post-fire safe shutdown from fire damage, as required by 10 CFR Part 50, Appendix R, Section III.G.2, is a performance deficiency. This finding is more than minor because it is associated with the reactor safety mitigating system cornerstone attribute of protection against external events (i.e., fire). Failure to protect safe shutdown cables and equipment from fire damage affects the reactor safety mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team performed a significance determination process Phase 1 screening. Given the likely impact of the risk contribution arising from the assessment of multiple fire areas, Region II senior reactor analysts performed a Phase 3 significance determination, which resulted in a preliminary risk of Greater Than Green. The team determined that this apparent violation did not present an immediate safety concern because the licensee implemented compensatory measures while long-term corrective actions are being implemented. The compensatory measures included operator manual actions to mitigate or prevent damage to equipment necessary for safe shutdown in the event of a fire. The licensee also implemented fire watches as additional compensatory measures to mitigate the safety hazard. Subsequent to the onsite inspection, the licensee evaluated the most critical operator manual actions, and revised selected safe shutdown instructions to include steps for independent confirmation of operator manual actions in order to improve the likelihood of success of these steps, and thus reduce the risk associated with this apparent violation. The cause of this finding has a cross-cutting aspect in the Corrective Action Program component of the Problem Identification and Resolution area, in that the licensee did not take appropriate corrective actions to address the issue in a timely manner, commensurate with the safety significance (P.1 (d)) |
Site: | Browns Ferry |
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Report | IR 05000259/2009009 Section 4OA5 |
Date counted | Dec 31, 2009 (2009Q4) |
Type: | Violation: Yellow |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | |
Inspectors (proximate) | G Pick K Miller L Suggs M Thomas P Fillion P Qualls R Neaser Neasev Mccree W Rogers C Evans E Guthrie J Hanna K Kennedy L Reyes M Thomas |
CCA | P.3, Resolution |
INPO aspect | PI.3 |
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Finding - Browns Ferry - IR 05000259/2009009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Browns Ferry) @ 2009Q4
Self-Identified List (Browns Ferry)
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