05000327/FIN-2014007-05
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Finding | |
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Title | Failure to Perform the Required Reviews when Adding Fire Watches to the Fire Protection Program |
Description | An NRC-identified Green non-cited violation of Sequoyah Operating License Conditions 2.C.(16) and 2.C.(13), for Units 1 and 2 respectively, was identified for the licensee's failure to perform the required reviews when adding fire watches to the fire protection program. The licensee entered the issue into their corrective action program as Problem Evaluation Report 845593. The licensees failure to perform the required evaluation and review prior to revising the fire hazards analysis was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events (fire) to prevent undesirable consequences. Specifically, the sole use of fire watches as a mitigation measure for the unavailability of the credited pressurizer power operated relief valve would adversely affect the capability to achieve and maintain safe shutdown during a fire event. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, which determined that an IMC 0609, Appendix F, Fire Protection Significance Determination Process, review was required as the finding affected fire protection defense-in-depth strategies involving post-fire SSD. Using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, the issue screened as having very low safety significance (Green) at Task 1.5.3 because the change in core damage frequency (delta CDF) was less than 1E-6 (i.e., delta CDF calculated to be 6.6E-7). The cause of this finding was determined to have a crosscutting aspect of Evaluation (P.2) in the Problem Identification and Resolution crosscutting area, because the licensee did not thoroughly evaluate the issue to ensure that resolutions addressed causes commensurate with their safety significance. Specifically, the establishment of effective corrective actions was adversely affected by the failure to perform an evaluation prior to revising the fire hazards analysis. |
Site: | Sequoyah ![]() |
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Report | IR 05000327/2014007 Section 1R05 |
Date counted | Mar 31, 2014 (2014Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.05 |
Inspectors (proximate) | D Jones D Terry Ward J Dymek M Thomas S Shaeffer |
Violation of: | License Condition - Fire Protection License Condition |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Sequoyah - IR 05000327/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Sequoyah) @ 2014Q1
Self-Identified List (Sequoyah)
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