05000313/FIN-2007006-03
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Finding | |
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| Title | Potential for actuation of high/low interface valves. |
| Description | License Conditions 2.c.(8) and 2.C.(3)(b) for Units 1 and 2, respectively, specifies, "EOI shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in Appendix 9A to the SAR and as approved in the Safety Evaluation dated March 31, 1992." Further, as required by 10 CFR 50.48(b), "With respect to all other fire protection features covered by Appendix R, 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."Section III. G.3.a specifies that aalternative or dedicated shutdown capability and its associated circuits in the area under consideration should be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirements of Section III.G.2. Generic Letter 81-12, "Fire Protection Rule," provided guidance on implementing Section III. G. of 10 CFR Part 50 Appendix R. The licensee did not meet the guidance and failed to adequately protect high/low pressure interfaces from the effects of a fire in order to prevent a loss-of-coolant accident. Additionally, the NRC response to Generic Letter 86-10, "Implementation of Fire Protection Requirements," Question 5.3.10, specified that the safe shutdown capability in an alternative shutdown system should not be adversely affected by a fire in any plant area, which results in spurious actuation of the redundant valves in any high/low pressure interface line. Contrary to the above, the licensee failed to provide alternative shutdown capability in the control room for circuits related to high/low interface valves as required specified by 10 CFR Part 50, Appendix R, Sections III. G and III. L. Specifically, the licensee failed to evaluate the impact of numerous pairs of high/low pressure interface valves and determine whether operators had time to respond or whether modifications would be required to correct the failure to adequately protect these valve combinations. Because the licensee committed to adopting NFPA 805 and changing their fire protection program license basis to comply with 10 CFR 50.48, this issue is covered by enforcement discretion in accordance with the NRC Enforcement Policy. Specifically, the licensee: (1) would have identified and addressed this issue during the conversion to NFPA 805, (2) had entered this issue into their corrective action program and implemented appropriate compensatory measures, (3) demonstrated the finding would not be categorized under the Reactor Oversight Process as Red or a Severity Level I violation, and (4) submitted their letter of intent prior to December 31, 2005. The inspector determined that this violation meets the criteria for enforcement discretion for plants in transition to a risk-informed, performance-based fire protection program as allowed per 10 CFR 50.48. Since all the criteria were met, the NRC is exercising enforcement discretion for this issue. |
| Site: | Arkansas Nuclear  |
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| Report | IR 05000313/2007006 Section 1R05 |
| Date counted | Dec 31, 2007 (2007Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | G Pick S Alferink J Mateychick R Mullikin |
| INPO aspect | |
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Finding - Arkansas Nuclear - IR 05000313/2007006 | |||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2007Q4
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