05000321/FIN-2017002-03
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Finding | |
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| Title | Noncompliance for Providing Inadequate Procedural Guidance for Post-Fire Safe Shutdown |
| Description | Introduction: The inspectors identified a noncompliance with Hatch Technical Specification 5.4.1.a for the licensees failure to provide adequate procedural guidance in post-fire safe shutdown abnormal operating procedure of Abnormal Operating Procedure (AOP) 34AB-X43-001-1, Fire Procedure. Specifically AOP 34AB-X43-001-1 directs operators to perform manual actions that may not be adequate to reopen a credited valve that has spuriously closed. Description: During the transition to NFPA 805, the licensee identified multiple instances of cables for equipment required to achieve SSD not meeting the separation requirements of the current licensing basis. The licensee determined that this condition existed for FA 1105, East Cableway Foyer. It was discovered that cables were identified in the current Safe Shutdown Analysis Report (SSAR) for HPCI Steam Supply Isolation motor operated valve 1E41-F002 . These cables were dispositioned by taking an Operator Manual Action (OMA) to open links BB-49 and BB-57 in panel 1H11-P622. Further evaluation showed that the OMA would prevent the valve from spuriously clos ing, but it would not re-open the valve after a spurious closure, due to the power supply for this valve being unavailable due to fire impacts. The licensee determined that these conditions were caused by methodology weaknesses in the sites fire safe shutdown analysis. Upon discovery, the licensee implemented compensatory measures in the form of posting a roving fire watch in fire areas of concern, and revised the affected procedure. 19 Analysis of the Problem Failure to adequately implement the requirements contained in 10 CFR Part 50.48(b)(1), and Hatch Renewed Operating License Condition 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 was a performance deficiency. This finding was more than minor because it was associated with the reactor safety mitigating system cornerstone attribute of protection against external events (i.e., fire). Because this issue relates to fire protection and this non-compliance was identified as a part of the sites transition to NFPA 805, this issue is being dispositioned in accordance with Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) of the NRC Enforcement Policy. In order to verify that this non-compliance was not associated with a finding of high safety significance (Red), inspectors revi ewed qualitative and quantitative risk analyses performed by the licensee. These risk evaluations took ignition source and target information from the ongoing Hatch fire PRA to demonstrate that the significance of the non-compliances were less-than-Red (i.e. core damage frequency (CDF) less than 1E-4/year). Inspectors determined that cables associated with some of the VFDRs were not located in the zone of influence (ZOI) of any credible ignition source. For cables that were located in the ZOI of a credible ignition source, inspectors were able to perform a calculation to determine the change in conditional core damage probability (CCDP), based on the postulated fire-affected equipment not being available. Based on these screenings, inspectors determined that the significance of this non-compliance was less- than-Red. A bounding risk assessment was performed by a regional SRA which included the review of the licensee and inspectors risk evaluations and confirmed the CDF risk increase due to this condition was less than 1E-4, and therefore less than RED. The inspectors determined that no cross-cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. Enforcement of the Problem 10 CFR Part 50.48(b)(1) requires that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of 10 CFR Part 50, Appendix R, Sections III.G, III.J, and III.O. Section III.G.2 requires, in part, that where cables and equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located in the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided: o separation of cables and equipment by a fire barrier having a 3-hour rating; or o separation of cables and equipment by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. Fire detection and automatic fire suppression shall be installed in the fire area; or o enclosure of cables and equipment of one redundant train in a fire barrier having a 1-hour fire rating. Fire detection and automatic suppression shall be installed in the fire area. 20 Section III.G.3 requires, in part, that alternative shutdown capability be provided where the protection of systems whose function is required for how shutdown does not satisfy the requirement of Section III.G.2. Additionally, Hatch Technical Specifications 5.4.1.a, Procedures for Unit 1 states that written procedures shall be established, implemented, and maintained covering activities listed in NRC Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Item 6.v of Appendix A lists Plant Fires as an activity that requires written procedures. Contrary to the above, the licensee failed to meet the requirements of its documented fire protection program since initial plant licensing, in that: The licensee did not meet the requirements of 10 CFR Part 50, Appendix R, Section III.G.2 in that the licensee did not ensure that one of the redundant trains was free of fire damage by providing one of the following means stated in Section III.G.2. The licensee did not ensure alternative shutdown capability be available for 2 fire areas where the guidelines for ensuring one redundant train for safe shutdown be free of fire damage, as required by 10 CFR Part 50, Appendix R, Section III.G.3. The licensee failed to provide adequate procedural guidance to ensure fire safe shutdown due to a fire in FA 1105. CRs generated for these issues are listed in the Documents Reviewed section. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), t he NRC is exercising enforcement and reactor oversight process (ROP) discretion (EA-17-120) for this issue in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, this issue was identified and will be addressed during the licensees transition to NFPA 805, it was entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, it was not likely to have been previously identified by routine licensee efforts, it was not willful, and it was not associated with a finding of high safety significance (Red) |
| Site: | Hatch  |
|---|---|
| Report | IR 05000321/2017002 Section 4OA3 |
| Date counted | Jun 30, 2017 (2017Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | No Cornerstone |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | D Hardage D Retterer J Montgomery P Braaten J Munday |
| Violation of: | 10 CFR 50 Appendix R 10 CFR 50 Appendix R Section III.G 10 CFR 50.48 |
| INPO aspect | |
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Finding - Hatch - IR 05000321/2017002 | |||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hatch) @ 2017Q2
Self-Identified List (Hatch)
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