05000382/FIN-2014002-03
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Finding | |
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| Title | Failure Implement a Fire Protection Program Procedure to Perform an Evaluation for Transient Combustibles |
| Description | The inspectors identified a non-cited violation of License Condition 2.C.9 because the licensee did not implement Procedure EN-DC-161, Control of Combustibles, which requires, in part, that a transient combustible evaluation shall be processed or compensatory actions shall be established if a flammable liquid exceeds one pint in an approved container. Specifically, the licensee did not implement Section 5.6 of Procedure EN-DC-161 after a fuel oil leak from the standby fuel oil pump for the train B emergency diesel generator exceeded one pint in an approved container which eventually failed to hold the fuel oil while in service. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-6020 and CR-WF3-2013-06123. The immediate corrective actions taken to restore compliance was to remove the leaking fuel oil from around the emergency diesel generator, implement an hourly fire watch, and repair the standby fuel oil pump leak and returned the emergency diesel generator to an operable status on January 3, 2014. The inspectors concluded that the failure to implement a fire protection program procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform a transient combustible evaluation when a flammable liquid above one pint in an approved container was present in the B emergency diesel generator room prevented the licensee from implementing required compensatory measures in response to the presence of transient combustibles surrounding and on the B emergency diesel generator. In addition, similar to NRC Inspection Manual Chapter 0612, Appendix E, Section 4, Example k, of a more than minor violation, the failure of the leak collection device resulting in fuel oil around the B emergency diesel generator represented a credible fire scenario involving transient combustibles that could affect equipment important to safety. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. Since this finding was related to controls for transient combustible materials, the initial screening directed the inspectors to use Appendix F, Fire Protection Significance Determination Process, to determine the significance of the finding. The inspectors categorized the finding under Task 1.4.1, Fire Prevention and Administrative Controls, and qualitatively screened it as very low safety significance (Green) because the impact of the fire finding was limited to no more than one train of equipment important to safety. The inspectors concluded that the finding reflected current licensee performance and involved a conservative bias cross-cutting aspect in the human performance area in that the licensee did not use decision making practices that emphasized prudent choices over those that are simply allowable. |
| Site: | Waterford  |
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| Report | IR 05000382/2014002 Section 1R15 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | C Speer G Werner J Brand M Davis P Elkmann R Latta S Hedger |
| Violation of: | License Condition - Fire Protection License Condition |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Waterford - IR 05000382/2014002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2014Q1
Self-Identified List (Waterford)
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