A non-cited violation of License Condition 2.C.4,
Fire Protection Program (
FPP), was identified for inadequate design control measures associated with the downgrading of a3-hour rated
fire barrier between the electrical penetration room and essential switch gearroom for each train in both Units. The licensee failed to update the fire strategy plans and the design basis documents, including the
fire protection program plan, the fire hazards analysis, and the
safe shutdown analysis, to reflect the new fire confinement configurations. The licensee intends to perform the fire hazards analysis and revise the design documents and the fire strategy plans. This finding is more than minor because it affected the
Mitigating Systems Cornerstone objective of availability, reliability, and capability of the fire confinement and fire suppression systems and was associated with the design control and protection against external factors(fire) attribute in that this failure could affect the ability to respond to a fire. The issue was determined to be of very low safety significance (Green) based on the fact that the categories of Fire Prevention and Administrative Controls, and Fire Confinement, were evaluated as having low degradation because the failure to adequately perform design control measures in support of the modification was mitigated by the fact that the
fire barrier was not actually removed; would likely have performed its intended function; and that the inspectors review of the equipment and actions for each of the combined areas indicated that
safe shutdown for a fire in the combined areas could be accomplished from either the other redundant train or the alternate
safe shutdown facility (both located in other fire areas).There is no cross cutting aspect with this performance deficiency because it was not representative of current licensee performance in that it was a human performance error that occurred 10 years ago.
