The inspectors identified a
Severity Level IV Non-Cited Violation of the Certificate of Compliance, No. 1004, Condition 1.1.3, Quality Assurance and
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to correct a
condition adverse to quality. Specifically, the licensee failed to remove
transient combustible material within 50 feet from the Horizontal Storage Modules (HSMs) to restore compliance with the NRC issued
10 CFR Part 72 license and its fire protection procedure. After the issue was identified, the licensee took immediate corrective actions to remove all
transient combustible material inside the 75-foot zone around the HSMs and generated a condition report to enter this issue into the corrective action program. This finding was more than minor because the lack of adequate corrective actions resulted in a more significant safety concern since the prolonged presence of combustible materials within 50 feet of HSMs for approximately 10 months increased the vulnerability of the HSMs to a fire. In addition, the lack of adequate corrective actions had the potential to become a programmatic issue and could have adversely affected NRC regulatory oversight and enforcement processes, as the agency relied on the licensees adequacy of corrective actions to correct an NRC identified violation. The inspectors determined that the finding was not suitable for
SDP evaluation because the noncompliance involved
10 CFR Part 72 dry fuel storage activities. Therefore, this finding was reviewed by Regional Management and dispositioned using traditional enforcement. The finding was determined to be of very low safety significance. The combustible material was contained within metal containers which could have mitigated the spread of a potential fire. Also, the plant fire brigade could have been dispatched to extinguish a fire involving the
transient combustible material before the HSMs incurred significant damage. The primary cause of this finding was related to the cross-cutting area of problem identification and resolution because licensee personnel failed to thoroughly evaluate the problem (
P.1(c)).
