The team identified a Green, Non-Cited Violation (
NCV) of License Condition 2.C(7) of the Hope Creek operating license, in that the procedures for shutting down the plant in response to a fire in the cable spreading room, control equipment room, or control room were not adequate. Specifically, the alternative (remote) post-fire
safe shutdown procedures were not adequate 1) to prevent overfilling of the reactor vessel following a spurious, fire-induced start of
High Pressure Coolant Injection (
HPCI) or 2) to ensure that cooling water is provided to the
Emergency Diesel Generators (
EDG) prior to overheating. Corrective actions included initiating revisions to the
safe shutdown procedures and entering this issue into the corrective action program (
CAP) as notifications 20600413 and 20601659. The finding was more than minor because it affected the procedure quality attribute associated with the
mitigating systems cornerstone as related to the objective of ensuring the reliability and availability of
mitigating systems under postulated fire
safe shutdown conditions. The finding screened as very low safety significance (Green) based upon
IMC 0609, Appendix F, Fire Protection
Significance Determination Process, Attachment 1, Fire Protection
SDP Phase 1 Worksheet, because the procedural inadequacies would not have prevented the ability of the operators to safely shutdown the plant in a fire event. The team determined that operators had adequate operator training, there was
operable detection/suppression systems in the fire areas of concern, there was no/limited ignition sources in the fire areas of concern, there was adequate administrative controls of
transient combustibles and ignition sources, and the control room was continually manned. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Resources, because
PSEG did not provide complete and accurate procedures. Specifically the
safe shutdown procedures were not adequate to prevent overfilling the reactor vessel or overheating the
EDGs.