05000272/FIN-2017001-02
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Finding | |
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Title | Inadequate Fire Risk Assessment and Management |
Description | Inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4) when PSEG did not adequately assess and manage the risk of online maintenance activities associated with the 13 and 23 charging (CV) positive displacement pumps (PDPs) and the 16 service water (SW) pump. Consequently, this resulted in the approval of hot work and the introduction of unaccounted for transient combustibles into a restricted fire area. PSEG wrote notifications (NOTFs) 20758370, 20759221, and 20761411 to document the observations and fire risk program gaps. On March 9, a roving fire watch was implemented as previously planned by PSEG. The finding was more than minor given its similarity to IMC 0612, Appendix E, example 7.e, in that had an adequate risk assessment been performed, it procedurally would have required additional risk management actions (RMAs). Additionally, this finding was more than minor because it adversely impacted the protection against external factors (fire) attribute of the Initiating Events cornerstone objective to limit the likelihood of events that upset plan stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the finding in accordance with IMC 0609, Attachment 4 and Appendix K, since it involved a maintenance rule (MR) risk assessment. Since the performance deficiency was related to maintenance activities affecting structures, systems, and components (SSCs) needed for fire mitigation, Appendix K directed the significance to be determined by an internal NRC management review using risk insights. A Senior Reactor Analyst used risk insights from IMC 0609, Appendix F and its Attachment 2, to inform the significance and determined the issue screened to Green given that the combustible conditions and quantities were predominantly representative of a Low degradation rating. |
Site: | Salem |
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Report | IR 05000272/2017001 Section 1R13 |
Date counted | Mar 31, 2017 (2017Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71111.13 |
Inspectors (proximate) | A Ziedonis F Bower J Furia J Schoppy P Boguszewski P Finney S Pindale |
Violation of: | 10 CFR 50.65 10 CFR 50.65(a)(4) |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Salem - IR 05000272/2017001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Salem) @ 2017Q1
Self-Identified List (Salem)
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