05000336/FIN-2013010-01
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Finding | |
|---|---|
| Title | Inadequate Alternative Shutdown Procedure |
| Description | The team identified an apparent violation of Millstone Unit 2 Operating License Condition 2.C. (3) for failure to implement and maintain all aspects of the approved Fire Protection Program (FPP). Specifically, Dominion had not adequately implemented an alternative shutdown procedure, as required by 10 CFR 50 Appendix R Section III.L.3 and the approved FPP. The procedure for a Unit 2 fire which could lead to control room abandonment did not ensure the electrical distribution system was correctly configured prior to re-energizing AC buses. As a result, an over-current condition could occur and trip the 4kV supply breaker complicating safe shutdown operations and delaying AC bus recovery. In response to this issue, Dominion promptly revised their fire safe shutdown operating procedure prior to the end of the inspection to correct this deficiency. This finding was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The team performed a Phase 1 Significance Determination Process (SDP) screening in accordance with NRC Inspection Manual Chapter 0609, Appendix F, and Fire Protection Significance Determination Process. This finding affected the post-fire safe shutdown category, and was determined to have a high degradation rating because the alternative shutdown procedure lacked adequate instructions to ensure correct equipment alignment. Therefore, the team concluded that a more appropriate and accurate characterization of the risk significance of this issue would be obtained by performing a Phase 3 SDP analysis because the Phase 2 SDP analysis does not explicitly address alternative safe shutdown fire scenarios. The Phase 3 SDP analysis cannot be accurately calculated until additional cable routing and ignition source information is presented by Dominion and is necessary to develop the fire scenarios that would require the alternative shutdown procedure to be implemented. This finding did not have a cross-cutting aspect because it was a legacy issue and was considered to not be indicative of current licensee performance. |
| Site: | Millstone |
|---|---|
| Report | IR 05000336/2013010 Section 1R05 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | AV: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | J Richmond D Werkheiser J Lilliendahl W Schmidt K Young R Fuhrmeister D Orr J Radyj Richmondp Presby R Mckinley R Rolph S Barr B Haagensen D Silk J Ambrosini J D'Antonio J Krafty |
| INPO aspect | |
| ' | |
Finding - Millstone - IR 05000336/2013010 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2013Q3
Self-Identified List (Millstone)
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