The licensee identified examples of a failure to meet the requirements of the Facility Operating License (
FOL) condition C.16 and C.13 for units 1 and 2 respectively. The license condition states, in part, that
TVA shall implement and maintain in effect all provisions of the approved
fire protection program referenced in the
UFSAR and as approved by the NRCs Safety Evaluation Report (
SER). Updated Final Safety Analysis Report (
UFSAR), Section 9.5.1, Fire Protection System, states in part that the Fire Protection System and fire protection features are described in the Fire Protection Report (
FPR). Contrary to the above, the licensee failed to maintain the requirements prescribed in the
fire protection program. Specifically, on February 7, 2017, the licensee identified numerous discrepancies and errors in the Fire Hazards Analysis, including multiple instances of inaccurate and non-conservative manual action time requirements. The deficiencies were associated with inaccurate assumptions based on loop-stagnation, head vent flow rates, and containment cooling which was inconsistent with
FPR, Part III, Section 1.1, Design Basis Evaluation. The finding was screened in accordance with
IMC 0609 Appendix F,
Significance Determination Process, and determined to be Green, by answering Yes on Task 1.3.1, Question 1.3.1. The issue into the
CAP as CR 11 1259493, CR 1224829, and CR 1261866. Additionally, adequate compensatory actions have been implemented.
