05000336/FIN-2010008-02
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Finding | |
|---|---|
| Title | Failure to Protect Safe Shutdown Equipment From the Effects of Fire |
| Description | The team identified a cited violation of 10 CFR Part 50, Appendix R, Section III.G.2 for the failure to protect required post-fire safe shutdown components and cabling to ensure one of the redundant trains of equipment remains free from fire damage. In lieu of providing the required separation, Dominion utilized unapproved operator manual actions to mitigate component malfunctions or spurious operations caused by a single fire induced circuit fault (hot short, open circuit or short to ground). Dominion has entered this issue into the corrective program for resolution. The team found the manual actions to be reasonable interim compensatory measures pending final resolution by Dominion. Dominion\'s failure to protect components credited for post-fire safe shutdown from fire damage caused by single spurious actuation is considered a performance deficiency. The performance deficiency was more than minor because it affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to an external event to prevent undesirable consequences in the event of a fire. Specifically, the use of operator manual actions during post-fire shutdown is not as reliable as normal systems operation which could be utilized had the separation requirements of 10 CFR 50, Appendix R, Section III.G.2 been met and therefore prevented fire damage to credited components and/or cables. The team used IMC 0609, Appendix F, Rre Protection Significance Determination Process (SDP), Phase 1 and an SRA conducted Phase 3 evaluation, to determine that this finding was of very low safety significance (Green). The team determined the finding had a low degradation rating because the manual actions were reviewed by the team and were found to be acceptable interim compensatory measures (pending licensee actions to resolve the non-compliances or obtain exemptions) because they did not require complicated actions, adequate time was available to accomplish the actions and the actions were properly included in the appropriate abnormal operating procedures. This finding had a cross cutting aspect in the area of problem identification and resolution associated with the corrective action program because Dominion did not completely and accurately identify deficiencies related to single spurious actuations of credited post-fire safe shutdown components. |
| Site: | Millstone  |
|---|---|
| Report | IR 05000336/2010008 Section 1R05 |
| Date counted | Sep 30, 2010 (2010Q3) |
| Type: | Violation: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | J Richmond L Scholl G Pick M Patel G Replogle W Schmidt R Fuhrmeister E Huang J Rogge J Rady D Frumkin G Cooper |
| CCA | P.1, Identification |
| INPO aspect | PI.1 |
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Finding - Millstone - IR 05000336/2010008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2010Q3
Self-Identified List (Millstone)
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