05000280/FIN-2013003-01
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | The Surry Operating License, section 3.I Fire Protection requires, in part, that the licensee shall implement and maintain in effect the provisions of the approved fire protection program as-described in the Updated Final Safety Analysis Report (UFSAR). The UFSAR requires, in part, that the fire protection programs (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 B.3 of Appendix A to BTP APCSB 9.5-1 requires, in part, that Normal and abnormal conditions or other anticipated operations such as modifications (e.g., breaking fire stops, impairment of fire detection and suppression systems) and refueling activities should be reviewed by appropriate levels of management and appropriate special actions and procedures such as fire watches or temporary fire barriers implemented to assure adequate fire protection and reactor safety. Contrary to the above, on May 3, 2013, the licensee discovered a failure to establish an adequate fire watch in the Emergency Diesel Generator Room #2 with the heat detection and low pressure carbon dioxide systems out of service while performing upgrades to the fire protection system. Specifically, when fuses were pulled on April 28, 2013, for relay replacement, the heat detection and low pressure carbon dioxide systems were rendered non-functional. The configuration occurred due to procedure 0-ECM-0903-01, Cardox Hazard Control Panel Isolation and Restoration, not being adequate in complying with the Technical Requirements Manual (TRM). The TRM section 3.3.1, Fire Detection Instrumentation, requires a fire watch to be established within an hour. Additionally, TRM section 5.2, Appendix R and Fire Protection Compensatory Measures/Fire Watch Requirements, requires a fire watch to be established with a frequency of one hour with both systems being non-functional. The licensee established a shiftly fire watch due to the low pressure carbon dioxide system being non-functional, however the heat detection system was not recognized as being out of service and the appropriate hourly fire watch was not established. Review of the work determined that a period of four days was the exposure period. Significance Determination Process (SDP) screening of the finding in accordance with NRC IMC 0609.04 determined that the finding required evaluation per IMC 0609 Appendix F, Fire Protection Significance Determination Process, because the condition had an adverse effect on the Fixed Fire Protection Systems element of fire watches posted as a compensatory measure for fixed fire protection system outages or degradations. A high degradation rating was assigned to this finding. A bounding phase 3 risk evaluation was performed for this finding by a regional SRA using the guidance of IMC 0609 Appendix F and input from the NRC latest Surry model. The major assumptions of the analysis were: a 4 day exposure period, an ignition frequency for the diesel room from the Surry Individual Plant Examination of Non-Seismic External Events and Fires, a probability of non-suppression of 1.0 due to the performance deficiency, and a conditional core damage probability determined using a transient initiator and loss of equipment in the diesel room. The risk was mitigated by the short exposure period and the availability of alternate equipment to achieve safe shutdown. The risk evaluation result was an increase in core damage frequency of <1E-6/year which makes this GREEN finding of very low safety significance. The licensee has documented this issue in in its corrective action program as CR 514296. |
| Site: | Surry  |
|---|---|
| Report | IR 05000280/2013003 Section 4OA7 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | R Hamilton J Nadel R Cureton G Mccoy R Kellner |
| Violation of: | License Condition - Fire Protection |
| INPO aspect | |
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Finding - Surry - IR 05000280/2013003 | ||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Surry) @ 2013Q2
Self-Identified List (Surry)
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