The team identified a noncompliance with
10 CFR 50, Appendix R, Section III.L.3 for the licensees failure to ensure that the Dedicated Shutdown (DS) Bus remains energized for a postulated fire in
FA A5, FZ 22. 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 A5, FZ 22, procedure DSP-002, Hot Shutdown Using the Dedicated/Alternate Shutdown System, would be utilized to safely shutdown the plant from the dedicated shutdown control stations. Step 4 of DSP-002 dispatches an operator to energize the DS Bus by performing Attachment 9. Step 2 of the attachment directs the operator to determine if the DS Bus is energized by offsite power. If the DS Bus is de-energized, then the operator is directed to energize the DS Bus by the Dedicated Shutdown Diesel Generator (DSDG). If the DS Bus is energized by offsite power, then the operator is directed to de-energize
4kV buses 1, 2 and 4 and 480V Bus 3 and then close the alternate feed to MCC-5. At this point in the procedure, performance of Attachment 9 would be complete and the operator would be free to leave the area and assist other operators. The team determined that if a
loss of offsite power occurred subsequent to the performance of Attachment 9, there was no continuing procedural guidance directing the operators to later energize the DS Bus with the DSDG. This issue was further complicated because there would be no indication of the subsequent
loss of offsite power to the operators absent someone checking the status of offsite power on the Ds bus.
