The inspectors identified a Green
NCV of the
FPP required by
10 CFR 50.48and License Condition 2.C.4 for failing to take adequate design control measures associated with the addition of the standby shutdown system (
SSS) for both Units. Specifically, the licensee failed to include a fire hazards analysis (
FHA) in the
FPP for the
SSS, and failed to enter the
SSS into the quality assurance program (
QAP).The licensee performed a
functionality assessment for the area where the
SSS is located. The licensee intends to add the
SSS to the
FHA and the
QAP. In addition, any previous modifications made to the
SSS will be reviewed and corrective action taken as appropriate. The performance deficiency was greater than minor because it affected the
Mitigating Systems Cornerstone objective of availability, reliability, and capability of the post-fire
safe shutdown (SSD) systems and is associated with the design control and protection against external factors (fire) attributes. Specifically, there was no
FHA that demonstrated the availability and capability that at least one SSD train would be free of fire and capable of performing
safe shutdown as required by
10CFR 50.48, (a)(2)(iii). The issue was determined to be of very low safety significance (Green) using
IMC 0609, Appendix F, Attachment 1, based on the fact that the categories of Fire Prevention and Administrative Controls, and post-fire SSD, were evaluated as having low degradation. There was no cross-cutting aspect associated with this performance deficiency because it was not representative of current licensee performance.
