This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the
Enforcement Policy. Sequoyah Unit 1 Operating License Condition 2.C(16) and Sequoyah Unit 2 Operating License Condition 2.C(13) require in part that
TVA shall implement and maintain in effect all provisions of the approved
fire protection program. The Sequoyah fire protection report describes how the licensee complies with applicable sections of
10 CFR 50, Appendix R, including Section III.L.1 which states in part that alternative or dedicated shutdown capability provided for a specific fire area shall be able to achieve cold shutdown conditions within
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and maintain cold shutdown conditions thereafter. Contrary to the above, since implementation of the Sequoyah
Fire Protection Program, the licensee failed to maintain all aspects of the approved program. Specifically, in August 2018, the licensee discovered that the sites ability to achieve cold shutdown conditions within
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> would be challenged due to an inadequate evaluation of the
RHR pumps functionality during certain Appendix R fire scenarios.
