05000327/FIN-2011006-01
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Finding | |
|---|---|
| Title | Use of Operator Manual Actions in Lieu of Protecting Cables and Equipment Required for POST-FIRE Safe Shutdown |
| Description | The inspectors identified an unresolved item (URI) related to the licensees failure to protect cables and equipment required to achieve hot shutdown to ensure that one train was free of fire damage in accordance with the requirements of the approved fire protection program as described in SQN Operating License Conditions (OLCs) 2.C(16) and 2.C(13) for Units 1 and 2 respectively. The inspectors reviewed the licensees post-fire SSD methodology for a fire in FA FAA-054/Room A01 or FA FAA-081/Room A24. Post-fire SSD for either of these FAs would be achieved from the MCR using AOP-N.01, Plant Fires, and AOP-N.08, Appendix R Fire Safe Shutdown. During this review the inspectors noted that in lieu of protecting the cables of equipment identified by the licensee as being required for post-fire SSD (i.e., provide barriers and spatial separation with detection and suppression), the SQN SSD methodology (for the above two FAs and numerous other FAs) also credited the use of OMAs. These new OMAs were not submitted to the NRC for review and/or approval prior to incorporation into the plant AOPs. Sequoyah added these new OMAs to their FPP in 2002 without seeking prior NRC approval because they believed their current OLCs (approved by NRC SER dated August 12, 1997 and applicable to plants licensed after January 1, 1979) allowed them to make these changes without prior NRC approval if they could demonstrate that the changes had no adverse impact on SSD. Sequoyah Units 1 and 2 were both licensed to operate after January 1, 1979. The SQN evaluation (dated March 2002) which added the OMAs concluded that adding the OMAs did not adversely affect SSD because the licensee determined at that time that the OMAs were feasible. The inspectors concluded that the licensees methodology of allowing fire damage to occur (instead of protecting SSD cables and equipment) and relying on OMAs to achieve post-fire SSD would adversely affect the ability to achieve and maintain SSD in the event of a fire. The inspectors reviewed the SQN evaluation which added the OMAs and concluded that the evaluation was not adequate to support the conclusion that adding the OMAs did not adversely affect post-fire SSD because the evaluation did not address defense-in-depth. During this inspection, SQN personnel stated that there were no plans at the time to implement modifications or submit the OMAs added in March 2002 for NRC review and approval. Subsequent to the onsite inspection, the licensee submitted additional information to the inspectors in support of their conclusion that the OMAs added in 2002 did not affect SSD. Additionally, the licensee initiated Problem Evaluation Report (PER) 324757 to address this issue. The inspectors are reviewing this information relative to the SQN licensing basis. This issue is identified as unresolved item (URI) 05000327, 328/2011006-01, Use of Operator Manual Actions in Lieu of Protecting Cables and Equipment Required for Post-Fire Safe Shutdown. This issue is unresolved pending further NRC review of this information and the Sequoyah fire protection licensing basis |
| Site: | Sequoyah  |
|---|---|
| Report | IR 05000327/2011006 Section 4OA5 |
| Date counted | Mar 31, 2011 (2011Q1) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | N Merriweather M Thomas R Fanner R Nease L Suggs J Dymekm Thomasc Young M Speck B Collins A Vargas P Braxton A Alen W Deschaine S Shaeffer |
| INPO aspect | |
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Finding - Sequoyah - IR 05000327/2011006 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Sequoyah) @ 2011Q1
Self-Identified List (Sequoyah)
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