05000327/FIN-2016003-02
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Finding | |
|---|---|
| Title | Isolation of Fire Suppression System to a Significant Portion of the Plant Site |
| Description | A self-revealing non-cited violation (NCV) of the facility operating licenses DPR-77 and DPR-79 conditions 2.C.(16) and 2.C.(13), respectively, was identified for the licensees failure to properly implement the clearance process such that the fire suppression system was rendered non-functional for approximately 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br />. The licensee inappropriately expanded an existing clearance on March 29, 2016 in order to attempt to reduce boundary valve leakage affecting existing maintenance on the fire suppression system within a valve pit. Subsequently on March 30, 2016 during fire system testing, technicians noted a lack of system pressure and it was ultimately concluded the clearance expansion had inadvertently isolated fire suppression water to a significant portion of the site. Upon discovery of the clearance error, the system was restored to a functional status. The licensee entered the issue into their corrective action program (CAP) as CR 1155763. The licensees failure to properly assess the system impact of a clearance revision for the High Pressure Fire Protection (HPFP) suppression header and enter the required FPR Operating Requirement (FOR) Action was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inability to pressurize the HPFP system from either the electric or diesel-driven fire pumps rendered the fire suppression system inoperable. Based on the complexities of this particular event, the inspectors concluded that Appendix M, Significance Determination Process Using Qualitative Criteria, of IMC 0609 should be performed in lieu of a Phase 3 analysis. Under appendix M, the Senior Reactor Analyst (SRA) performed an initial bounding evaluation using qualitative methods. The licensee submitted a detailed analysis that estimated an upper bound for the risk of the finding which was less than 1E-6. The SRA performed a review of this screening analysis as part of this SDP evaluation. In addition to the SRA review, the resident inspectors performed an independent review of the licensees estimation of the success of actions used to recover the isolated fire header. To the extent reviewed, the methodology and results were determined to be acceptable for use in this SDP review of this Performance Deficiency. The SRA concurred with the submitted results of the licensees screening analysis, and has determined the finding to be GREEN. The inspectors determined that the finding had a cross cutting aspect of Procedural Adherence within the Human Performance area, because the licensee failed to consider the affect that changing a clearance order could have on the operability of the fire suppression system. |
| Site: | Sequoyah  |
|---|---|
| Report | IR 05000327/2016003 Section 4OA5 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | Self-revealing |
| Inspection Procedure: | |
| Inspectors (proximate) | A Blamey G Smith N Staples W Deschaine |
| Violation of: | License Condition - Fire Protection |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Sequoyah - IR 05000327/2016003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Sequoyah) @ 2016Q3
Self-Identified List (Sequoyah)
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