05000282/FIN-2017003-02
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Finding | |
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Title | Licensee-Identified Violation |
Description | Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O. Appendix R,Section III.G.3 of 10 CFR Part 50, requires, in part, that alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, or zone under consideration should be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section. In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration. Contrary to the above, on December 21, 2015, the licensee failed to provide an alternative or dedicated shutdown capability for 17 MOVs credited in the licensees Appendix R Safe Shutdown Analysis that did not satisfy the requirements of 10 CFR Part 50, Appendix R, Section G.2. Specifically the MOVs could have been rendered unavailable for manual operator action following a postulated fire in the control or relay rooms. These manual actions were required to achieve and maintain safe shut down in the event of a fire that resulted in functional loss and/or evacuation of the control and/or relay rooms. 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
25 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 National Fire Protection Association (NFPA) 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants. At the time of discovery, the licensee was 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 performed risk evaluation V.SPA.16.001, Revision 0, dated March 27, 2017, and determined that this issue was not associated with a finding of high safety significance. A Region III Senior Reactor Analyst (SRA) reviewed the evaluation and concluded that the result was reasonable and that the finding was less than Red and eligible for enforcement discretion. The dominant core damage sequence from the licensees evaluation was a fire in the Control Room or Cable Spreading Room which could cause spurious operation of several MOVs necessary for safe shutdown. The SRA used IMC 0609, Appendix F, Fire Protection Significance Determination Process, to review the results of the licensees evaluation. The SRA validated the licensees calculations through a series of walkdowns, reviews of the calculation and verification of the values used were consistent with NUREG-6850 and IMC 0609, Appendix F. The licensees results were approximately 1E6 deltaCDF and 2E8 deltaLERF for this finding and hence were significantly lower than the 1E4 deltaCDF threshold for a finding of high safety significance. In addition, the licensee entered this issue into their corrective action program as CAP 1506561. As a result, the inspectors concluded that the violation met all four criteria established by Section 9.1(a) 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 |
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Report | IR 05000282/2017003 Section 4OA7 |
Date counted | Sep 30, 2017 (2017Q3) |
Type: | NCV: Green |
cornerstone | Physical Protection |
Identified by: | Licensee-identified |
Inspection Procedure: | |
Inspectors (proximate) | L Haeg P Laflamme P Zurawski S Bell D Reeser R Baker B Dickson |
Violation of: | 10 CFR 50 Appendix R 10 CFR 50.48 |
INPO aspect | |
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Finding - Prairie Island - IR 05000282/2017003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2017Q3
Self-Identified List (Prairie Island)
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