05000335/FIN-2013007-01
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Finding | |
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| Title | Failure to Demonstrate Feasibility of All Omas Used as Compensatory Measures |
| Description | An NRC-identified non-cited violation of St. Lucie Unit 1 and Unit 2 operating license conditions 3.E was identified for the licensees failure to comply with the requirements of the St. Lucie Fire Protection Program for verifying the feasibility of unapproved operator manual actions (OMAs). Specifically, the licensees process for determining OMA feasibility did not include performing in-plant walk-downs to verify the feasibility of all the unapproved OMAs that were entered in the corrective action program (CAP) in 2006 and designated as alternate compensatory measures during the transition to National Fire Protection Association (NFPA) Standard 805. The licensee entered this issue in their CAP as Action Request (AR) 01860866 and performed in-plant walk-downs to verify feasibility of the OMAs which had not been previously field verified. Failure to comply with the requirements of the St. Lucie Fire Protection Program for verifying the feasibility of unapproved OMAs designated as compensatory measures is a performance deficiency. This finding was determined to be more than minor because it was associated with the reactor safety mitigating systems cornerstone attribute of protection against external events (i.e. fire), and it affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The licensees process for determining OMA feasibility could have resulted in non-feasible OMA compensatory measures not being identified which had the potential to adversely affect SSD in the event of a fire. The finding was screened in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), 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 safe shutdown. The inspectors evaluated this finding using the guidance in IMC 0609, Appendix F, Attachment 2, Degradation Rating Guidance, and assigned a low degradation rating to this finding because the licensee verified that the OMAs were feasible through in-plant walk-downs. Therefore, this finding was determined to be of very low safety significance (Green). The cause of this finding was determined to have a cross-cutting aspect in the Corrective Action Program (CAP) component of the Problem Identification and Resolution area in that the licensee did not thoroughly evaluate the problem such that the resolution addressed extent of condition. |
| Site: | Saint Lucie  |
|---|---|
| Report | IR 05000335/2013007 Section 1R05 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | M King M Thomas G Wiseman K Ellis T Fanelli M Singletary |
| Violation of: | License Condition - Fire Protection License Condition |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Saint Lucie - IR 05000335/2013007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Saint Lucie) @ 2013Q1
Self-Identified List (Saint Lucie)
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