05000282/FIN-2017001-02
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | Title 10 CFR Part 50, Appendix R,Section III.G.2 requires, in part, that where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one means of ensuring that one of the redundant trains is free of fire damage shall be provided. Contrary to the above, up until April 21, 2016, the licensee failed to ensure that where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions we re located within the same fire area outside of primary containment, one means of ensuring that one of the redundant trains is free of fire damage was provided. Specifically, the requirement was to provide separation of cables and equipment and associated non -safety circuits of redundant trains by a fire barrier having a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating. However, fire barriers with unsealed combustible pathway penetrations existed between FA 85 (Holdup Tank Area/Demineralizer Area) and adjacent FAs 59 (Auxiliary Building Mezzanine Level Unit 1) and FA 74 (Auxiliary Building Mezzanine Level Unit 2) for Units 1 and 2 respectively. 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 noncompliances 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. The licensee is in transition to NFPA 805, and therefore, the licensee- identified violation was evaluated in accordance with the criteria established by Section 9.1(a) of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for a licensee in NFPA 805 transition. The inspectors determined that for this violation: (1) the licensee identified the violation during the scheduled transition to 10 CFR 50.48(c); (2) the licensee had established adequate compensatory measures within a reasonable time frame following identification and would correct the violation as a result of completing the NFPA 805 transition; (3) the violation was not likely to have been previously identified by routine licensee efforts; and (4) the violation was not willful. The finding also met additional criteria established in section 12.01.b of IMC 0305, Operating Assessment Program. In addition, in order for the NRC to consider granting enforcement discretion the violation must not be associated with a finding of high safety significance (i.e., Red). The licensee provided the Fire PRA Multi -Compartment Analysis Notebook (FPRA PIMCA) for review, and concluded that this issue was not associated with a finding of high safety significance. An NRC Region III Senior Reactor Analyst (SRA) reviewed the evaluation and discussed it with licensee staff. The evaluation documents the results of fire modeling that concludes the fire 29 scenarios screen from further consideration because a damaging hot gas layer that could affect both compartments is not generated. The SRA concluded that the licensees result was reasonable and that the finding was less than Red and eligible for Enforcement Discretion. In addition, the licensee entered this issue into their CAP as 1519659. As a result, the inspectors concluded that the violation met all four criteria established by Section 9.1(a) of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues and that the NRC was exercising enforcement discretion to not cite this violation in accordance with the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues. |
| Site: | Prairie Island  |
|---|---|
| Report | IR 05000282/2017001 Section 4OA7 |
| Date counted | Mar 31, 2017 (2017Q1) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | No Cornerstone |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | J Bozga K Riemer L Haeg P Laflamme S Bell |
| Violation of: | 10 CFR 50 Appendix R Section III.G |
| INPO aspect | |
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Finding - Prairie Island - IR 05000282/2017001 | ||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2017Q1
Self-Identified List (Prairie Island)
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