05000348/FIN-2013004-02
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Finding | |
|---|---|
| Title | Failure to Implement Fire Protection Program Requirements |
| Description | A self-revealing NCV of TS 5.4.1.c, Fire Protection Program Implementation, was identified, because the licensee failed to implement written procedures to cover activities of the Fire Protection Program as documented in Appendix 9B of the updated final safety analysis report (UFSAR). As a result, an inadvertent carbon dioxide (CO2) discharge occurred on August 3, 2013 which required evacuation of the Unit 1 auxiliary building and an Alert Emergency declaration. The licensee completed the low pressure (LP) CO2 system maintenance, replaced the hazard pilot valve and verified it was left in the correct position. Performance of licensee procedure FNP-0-FSP-57.0 was planned for completion per technical evaluation (TE) 704305. This issue was captured in the licensees CAP as CR 682967. This violation is applicable to Unit 1. Failure to verify proper operation of hazard pilot valve N1V43G076 following maintenance as required in work order (WO) SNC 54604 was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against external events (fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadvertent discharge of CO2 into the Unit 1 auxiliary building resulted in an atmosphere that was determined to be an immediate danger to life and health (IDLH). Respirators would be required in this area which would cause an undue burden on the operators ability to respond to events requiring manual operator actions. The inspectors evaluated this finding using the NRCs SDP and IMC 0609 Attachment 4, Initial Characterization of Findings. Because the finding involved a fixed fire protection system, an evaluation using IMC 0609 Appendix F, Attachment 1, Fire Protection SDP Worksheet, was required. The finding screened to Green because it would not affect the ability to reach and maintain safe shutdown conditions. The inspectors concluded that the time critical operator actions needed to support safe shutdown could be achieved with the use of respirators and operators are properly trained and qualified to use respirators. The cause of this finding was directly related to the cross-cutting aspect of maintenance scheduling in the work control component of the human performance area, because the licensee deferred the performance of procedure FNP-0-FSP-57.0 which would have identified the hazard pilot valve was partially open following completion of maintenance on the valve. |
| Site: | Farley  |
|---|---|
| Report | IR 05000348/2013004 Section 4OA2 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | D Dumbacher F Ehrhardt P Niebaum J Sowa |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Farley - IR 05000348/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Farley) @ 2013Q3
Self-Identified List (Farley)
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