05000259/FIN-2012004-06
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Finding | |
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| Title | Unanalyzed Conditions Discovered During NFPA 805 Transition Review |
| Description | 10 CFR Part 50.48(b)(1) requires that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of 10 CFR Part 50, Appendix R, Section III.G. 10 CFR 50, Appendix R, Section III.G.2, states, in part, that where cables or equipment, that could prevent operation or cause mal-operation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided: separation of cables and equipment by a fire barrier having a 3-hour rating, separation of cables and equipment by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards and with fire detectors and an automatic fire suppression system in the fire area, and enclosure of cables and equipment in a fire barrier having a 1-hour rating and with fire detectors and an automatic fire suppression system in the fire area. Contrary to the above, the licensee failed to use one of means described in Appendix R,Section III.G.2.a, b, or c to ensure that one of the redundant trains of equipment necessary to achieve and maintain hot shutdown conditions was protected from fire damage. Specifically, on April 5, 2012, the licensee identified the failure to protect equipment that was required to mitigate fire events. The licensee determined that fire damage could prevent operation or cause mal-operation of the reactor pressure instrument loops, safety relief valve overpressure logic, automatic depressurization logic, RHR test return valves, drywell spray valves, suppression pool spray valves MSIVs, and a 4kV shutdown board due to hot shorts, open circuits, or shorts to ground. This condition has existed since initial plant startup for Units 1, 2 and 3. The licensee entered this issue into the corrective action program (PERs 229734, 259787 and 424389) and implemented compensatory actions in the form of fire watches for Units 1, 2, and 3. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and reactor oversight process (ROP) discretion for these issues in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, these issues were identified and will be addressed during the licensees transition to NFPA 805, they were entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, they were not likely to have been previously identified by routine licensee efforts, they were not willful, and they were not associated with a finding of high safety significance (Red). |
| Site: | Browns Ferry  |
|---|---|
| Report | IR 05000259/2012004 Section 4OA3 |
| Date counted | Sep 30, 2012 (2012Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | C Stancil D Dumbacher E Guthrie D Jones C Kontz P Niebaum J Montgomery L Pressley T Stephen |
| INPO aspect | |
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Finding - Browns Ferry - IR 05000259/2012004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Browns Ferry) @ 2012Q3
Self-Identified List (Browns Ferry)
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