05000313/FIN-2013009-02
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Finding | |
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| Title | Failure to Maintain Adequate Staffing for Operators to Perform a Simultaneous Alternative Shutdown of Both Units and Staff the Fire Brigade |
| Description | The team identified an Unresolved Item (URI) concerning the failure to implement and maintain in effect all provisions of the approved fire protection program as defined by License Conditions 2.C.(8) for Unit 1 and 2.C.(3)(b) for Unit 2. Specifically, the licensee failed to maintain adequate staffing for operators to perform a simultaneous alternative shutdown of both units and staff the fire brigade. Further NRC staff evaluations will be required to determine if this issue is more than minor. The licensee provided the minimum operations shift staffing requirements in Procedure EN-OP-115, Conduct of Operations, Revision 14. This procedure required that the Unit 1 shift be comprised of a shift manager, control room supervisor, shift technical advisor, two licensed control board operators, two non-licensed auxiliary operators, a waste control operator, and a communicator. This procedure required the same staffing for Unit 2, but it noted that the Unit 2 communicator could serve as the alternate shutdown operator (a Unit 2 specific position). The licensee would use Procedure 1203.002, Alternate Shutdown, Revision 24, to perform an alternative shutdown for Unit 1 and Procedure 2203.014, Alternate Shutdown, Revision 26, to perform an alternative shutdown for Unit 2. The alternative shutdown procedure for Unit 1 required actions from the shift manager, control room supervisor, shift technical advisor, two control board operators, and two auxiliary operators. The alternative shutdown procedure for Unit 2 required actions from the shift manager, control room supervisor, shift technical advisor, two control board operators, two auxiliary operators, and the alternate shutdown operator. The licensee only required one communicator to respond to the technical support center to make the required notifications. The licensee would use Procedure 1203.029, Remote Shutdown, Revision 10, to perform a remote shutdown for Unit 1. The remote shutdown procedure required actions from the shift manager, control room supervisor, and two control board operators. Unlike the alternative shutdown procedure, it did not require actions from the two auxiliary operators. The licensee delineated operator responsibilities for alternative and remote shutdowns for both units in Calculation CALC-85-E-0086-02, Manual Action Feasibility and Common Results, Revision 4. The team noted that this calculation was not consistent with the current staffing. The calculation had not been updated after the 2007 addition of an auxiliary operator position or the 2012 addition of an alternate shutdown operator position for Unit 2. The team determined through discussions with the licensee that the fire brigade was composed of four non-licensed operators and one security officer. The waste control operator from each unit was assigned to the fire brigade and designated as the potential fire brigade leader, depending on the unit affected. In the event of an alternative shutdown of Unit 2, the licensee credited the waste control operator from Unit 2 as the fire brigade leader and the waste control operator from Unit 1, two auxiliary operators from Unit 1, and the security officer as the remaining fire brigade members. The licensee discussed operator responsibilities for an alternative shutdown of Unit 2 coincident with a remote shutdown of Unit 1, but did not discuss operator responsibilities for a simultaneous alternative shutdown of both units. The team concluded that the licensee failed to maintain adequate staffing for operators to perform a simultaneous alternative shutdown of both units and staff the fire brigade. Specifically, the licensee required actions from all operators other than the two waste control operators during a simultaneous alternative shutdown of both units. This left the two waste control operators and the security officer as the only assigned fire brigade members that could respond to a potential control room fire. The team reviewed the fire protection licensing basis. Since the control rooms were located in the same fire area, the team concluded that the licensee must be able to perform a simultaneous alternative shutdown of both units and staff the fire brigade. The team noted that the licensee did not have an exemption from this requirement. The licensee identified this non-compliance in 2006 and documented this issue in Condition Report CR-ANO-C-2006-00048, Corrective Action 36. In response to this concern, the licensee performed a risk evaluation but failed to initiate any corrective actions or compensatory measures. In 2007 and 2012, the licensee subsequently added the auxiliary operator and alternate shutdown operator positions, respectively, for an alternative shutdown of Unit 2. During each addition, the licensee failed to ensure the adequate staffing for operators to perform a simultaneous alternative shutdown of both units and staff the fire brigade. The licensee determined that alternative shutdown of both units would not be required since a fire in one control room would not be capable of causing circuit damage in equipment located in the other control room. The licensee developed detailed fire models to demonstrate this position as part of the transition to NFPA-805. The licensees License Amendment Request for Unit 2, dated March 27, 2012 (ML12087A113) has been submitted to the NRC and is under review by the NRC staff. The result of the NRC staff review of this analysis will be required to determine if this issue is more than minor. This issue is being treated as an unresolved item: URI 05000313;05000368/2013009-002, Failure to Maintain Adequate Staffing for Operators to Perform a Simultaneous Alternative Shutdown of Both Units and Staff the Fire Brigade. |
| Site: | Arkansas Nuclear  |
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| Report | IR 05000313/2013009 Section 1R05 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | B Correll B Tindell G Pick J Choate J Dixon J Mateychick M Phalen M Tobin N Greene N O'Keefe P Jayroe R Deese S Money M Kirkg Millerj Mateychick L Willoughby N Okonkwo S Alferink |
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Finding - Arkansas Nuclear - IR 05000313/2013009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2013Q4
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