05000280/FIN-2012002-03
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Finding | |
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Title | Licensee-Identified Violation |
Description | 10 CFR Part 50.48 states, in part, that each operating nuclear power plant . . . must have a fire protection plan that satisfies Criterion 3 of Appendix A to this part. The Surry Unit 1 Updated Facility Operating License DPR-32, and Unit 2 Updated Facility Operating License DPR-37, Condition 3.I, specify, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the UFSAR and as approved in the Safety Evaluation Report (SER) and subsequent supplements. The UFSAR requires, in part, that the fire protection program (FPP) meet Appendix A to Branch Technical Position (BTP) APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976, dated August 23, 1976. Section D.2.a of Appendix A to BTP APCSB 9.5-1 requires, in part, that safety related systems should be isolated or separated from combustible materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Examples of such combustible materials that may not be separable from the remainder of its system are: (3) Reactor coolant pump lube oil system. Additionally, 10 CFR 50, Appendix R, Section III.O requires, in part, that The oil collection system shall be so designed, engineered, and installed that failure will not lead to fire during normal or design basis accident conditions. Leakage shall be collected and drained to a vented closed container that can hold the entire lube oil system inventory. Contrary to the above, on November 23, 2011, the licensee identified that the reactor coolant pump (RCP) oil collection tanks for all the RCPs on both units were full of water and would not be able to contain the entire lube oil system inventory. The tanks were full of water due to a design change oversight that resulted in pre-existing RCP stator condensation being directed into the oil collection tanks. The inspectors determined the finding was more than minor because it was associated with the initiating events cornerstone attribute of protection against external factors and it adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, the failure to meet Appendix R resulted in the non-functionality of the oil collection systems on all Unit 1 and Unit 2 RCPs, increasing the risk of fire from an RCP oil leak. The inspectors reviewed IMC 0609, Appendix F, and determined the finding was of very low safety significance (Green), because the finding was assigned a low fire degradation rating. Specifically, the RCP oil inventory would be expected to rise to the top of the collection tank and spill out the tank vent on to the loop room floor, causing it to spread out and be directed to the containment sump through the floor drains. The loop room floor and components in the vicinity do not reach oil ignition temperatures and safe shutdown capability would not be affected. The licensee has entered this issue in their CAP as CR 453867. |
Site: | Surry |
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Report | IR 05000280/2012002 Section 4OA7 |
Date counted | Mar 31, 2012 (2012Q1) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | Licensee-identified |
Inspection Procedure: | |
Inspectors (proximate) | J Nadel S Sanchez G Mccoy A Sengupta |
INPO aspect | |
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Finding - Surry - IR 05000280/2012002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Surry) @ 2012Q1
Self-Identified List (Surry)
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