05000261/FIN-2007007-01
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Finding | |
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| Title | Inadequate Separation and Protection of CST Level Instrument Cables and Equipment Required for SSD in Fire Area G1, FZ 25A |
| Description | The team identified a noncompliance with 10 CFR 50, Appendix R, Section III.G.2, for the licensees failure to ensure that one train of redundant Condensate Storage Tank (CST) level indication was free of fire damage in FA G1, FZ 25A. Additionally, the team identified the lack of full area coverage of automatic fire detection and suppression systems for Fire Area G1. The violation meets the criteria of NRC Enforcement Policy, Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for enforcement discretion. For a fire in FA G1, FZ 25A, procedure DSP-015, Hot Shutdown From the Control Room with a Fire in the Turbine Building, would be utilized to safely shutdown the plant from the MCR. Step 35 directs the operator to check CST level less than 10%. The licensees SSA credits instrument LT-1454A, CST level indication, as being available to the operators in the MCR for a fire in FA G1, FZ 25A. This provides an indication to the operators of when to align Service Water (SW) backup to Auxiliary Feedwater (AFW) water supply. This alternate alignment needs to be performed because the inventory in the CST could be depleted in approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The team identified that instrument LT-1454A was not protected for a fire in FA G1, FZ 25A and would not be available as specified in operator response procedure DSP-015. Once this issue was identified, it was entered into the licensees corrective action program (CAP) as NCR 00252232. Compensatory measures were put in place prior to the inspectors leaving the site. DSP-015 was later revised to align SW backup to AFW water supply 105 minutes into the event if CST level indication is not available. Additionally, the team identified the lack of full area coverage of automatic fire detection and suppression systems for FA G1, Turbine Building, Fire Zones 25 A, B, C, E, F, and G. In Supplemental Safety Evaluation Report (SSER) dated September, 17, 1986, the NRC granted the licensee an exemption from the technical requirements of 10 CFR 50, Appendix R Section III.G.3, for six FZs located in this FA where fire detection and fixed suppression systems had not been installed throughout the area under consideration. Each of the fire zones under consideration at that time (1986) contained redundant trains of normal safe shutdown systems; however, alternative safe shutdown capability electrically independent from the zones would be available to be used to achieve and maintain safe shutdown. In a letter dated May 31, 2001, Carolina Power and Light (CP&L) notified the NRC that the completion of an analysis in 1998, had resulted in re-designation of Fire Area G1 from a 10 CFR 50, Appendix R Section III.G.3 area to Section III.G.2 area. Consequently, NRC-granted exemptions to 10 CFR 50, Appendix R Section III.G.3, were no longer necessary for the re-designated areas which now met the requirements of 10 CFR 50, Appendix R Section III.G.2. The inspectors review of the licencees safety evaluation screening associated with the plant area re-designation (ESR 00- 00042, Revision 0) found that the licensee reviewers inappropriately determined that no new exemptions were required to satisfy Appendix R requirements. In a letter dated September 5, 2001, the NRC acknowledged the intent of the May 31, 2001 CP&L letter to share review findings. According to CP&L, HBR2 were now in compliance with 10 CFR 50, Appendix R, Section III.G.2 and no additional licensing action was anticipated from NRC. During walk downs of Fire Area G1, the team identified that Fire Zones 25B, C, E, F, and G of the Turbine Building lacked full area fire detection and automatic fire suppression. A portion of Fire Zone 25A had fire detection located on a suspended ceiling but, no automatic fire suppression was installed within this area. This portion of Fire Zone 25A is the Radiologically Controlled Area Entry during plant outages but is utilized as a security operations and locker area during normal plant operation. A large portion of FA G1 lacked full area automatic fire detection and automatic fire suppression capability as required by 10 CFR 50, Appendix R, Section III.G.2, nor had the licensee requested exemptions from any technical requirements of the fire protection rule. This issue was entered into the licensees CAP as NCR 252199. |
| Site: | Robinson  |
|---|---|
| Report | IR 05000261/2007007 Section 1R05 |
| Date counted | Dec 31, 2007 (2007Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | D Merzke D Payne G Wiseman P Braxton R Fanner R Rodriguez |
| INPO aspect | |
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Finding - Robinson - IR 05000261/2007007 | |||||||||||||||||||||
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Finding List (Robinson) @ 2007Q4
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