05000282/FIN-2015002-06
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | Title 10 CFR Part 50, Appendix R, requires, in part, that fire protection features shall be provided for SSCs important to safe shutdown. These features shall be capable of limiting fire damage so that one train of systems needed to achieve and maintain hot shutdown from either the control room or emergency control station(s) is free of fire damage and that equipment needed to achieve and maintain cold shutdown can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In addition, where cables and equipment located outside of containment could prevent equipment operation or cause miss-operation due to hot shorts, open circuits or shorts to ground of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, separation of cables and equipment must be maintained through the use of a fire barrier with a three-hour rating to ensure one train of redundant equipment remains free of fire damage. On October 13, 2011, the licensee failed to provide fire protection features for SSCs important to safe shutdown that limited fire damage such that one train of systems remained free from fire damage, in accordance with 10CFR Part 50, Appendix R. Specifically, the licensee identified that Rodofoam material present in the auxiliary building seismic joint seals failed to provide a three hour fire barrier to ensure that one train of redundant safe shutdown equipment remained free from fire damage following a fire due to Rodofoam being a combustible material. The inspectors reviewed this issue and determined that the Rodofoam material was part of the initial plant design. In addition, these seals were not identified as fire penetration seals. As a result, the seals were not considered to be part of the fire protection program. Once the Rodofoam material was found, the licensee initiated periodic fire watches in the impacted areas and initiated CAP 1308129. The fire watches remained in place until the Rodofoam seals were replaced with a non-combustible seal material. The inspectors determined that the failure to ensure that equipment was protected from fire, such that one train of equipment remained free from fire damage was a performance deficiency and a violation of 10 CFR 50, Appendix R. However, Section 9.1 of the NRC Enforcement Policy allows the NRC to exercise enforcement discretion for certain fire protection related non-compliances identified as a result of a licensees transition to the new risk-informed, performance-based fire protection approach included in 10 CFR 50.48(c) and for certain existing non-compliances that reasonably may be resolved by compliance with 10 CFR 50.48(c) as long as certain criteria are met. This risk-informed, performance-based approach is referred to as NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants. In 2005, the licensee began the process of transitioning from the requirements of 10 CFR 50, Appendix R to NFPA 805. This process included submitting a licensing amendment to the NRC for review and approval in September 2012. The inspectors reviewed the criteria included in Section 9.1 of the NRC Enforcement Policy and concluded that the licensee had met the criteria for enforcement discretion. Specifically, the licensee entered the noncompliance into the CAP as CAP 1308129 and implemented compensatory fire watches in the area until the seals were replaced with an appropriate material. Additionally, this issue would not have been identified under normal surveillance or QA activities. This issue was not willful since the seismic gap seals were installed prior to the development of the fire protection requirements. The inspectors evaluated the significance of this finding in accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Finding, dated June 19, 2012, and determined that the finding affected the Mitigating System cornerstone. The inspectors determined that the finding degraded fire protection defense-in-depth strategies so IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, was used to determine the safety significance. The inspectors concluded that this issue was of very low safety significance because the credited safe shutdown equipment was located more than ten feet horizontally or vertically away from the flammable seal material. As a result, a credible fire on either side of the flammable seal material would not result in damage to the redundant safe shutdown equipment on the other side. Because there were no redundant cables or equipment penetrating the seal area, the inspectors concluded that hot gases, which could penetrate the seal, would cool and disperse, such that redundant cables and equipment would not have been damaged. Therefore, no credible fire could affect the ability to achieve and maintain safe shutdown. Because each of the criteria listed in Section 9.1 of the NRC Enforcement Policy was met, the NRC concluded that enforcement discretion should be granted for this issue. No enforcement action will be documented unless the licensee fails to address this non-compliance after completing their transition activities. |
| Site: | Prairie Island  |
|---|---|
| Report | IR 05000282/2015002 Section 4OA7 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Shaikh J Corujo-Sandin K Riemer K Stoedter L Haeg L Kozak M Jeffers M Phalen N Feliz-Adomo P Laflamme |
| Violation of: | 10 CFR 50.48 10 CFR 50 Appendix R |
| INPO aspect | |
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Finding - Prairie Island - IR 05000282/2015002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2015Q2
Self-Identified List (Prairie Island)
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