The NRC identified a non-cited
Severity Level IV violation of the Unit 1 and 2
CNS Facility Operating License, Condition 2.C.5, for the failure to implement and maintain in effect all provisions of the approved
fire protection program (
FPP). Specifically, the licensee made a change to the approved
FPP which involved the de-rating of a credited three hour
fire barrier between the control room and the cable spreading room(s) to only a pressure and smoke barrier. The licensee entered the issue in its corrective action program as
AR 01932211 and it was added to existing fire watches for the area. The failure to comply with the
CNS Operating License Condition 2.C.5 for a change to the approved
FPP involving the de-rating of a credited three hour
fire barrier between the control room and the cable spreading room(s) was a performance deficiency. The performance deficiency was more than minor because it was associated with the
Mitigating Systems Cornerstone attribute of protection against external events (i.e. Fire.) The performance deficiency negatively affected the cornerstone objective in that the change to the
FPP had the potential to adversely affect the availability of the control room to achieve and maintain stable plant conditions due to the increased likelihood of control room abandonment in the event of a fire in the cable spreading rooms. The licensees failure to submit the
FPP change to the NRC was determined to impede the regulatory process because the
FPP change required NRC review and approval prior to implementation. The finding was screened as Green because based upon inspection of the affected barriers, the inspectors determined that the barriers would provide a 1-hour or greater fire endurance rating. This violation was determined to be a
Severity Level IV violation because the associated finding was evaluated by the
SDP as having very low safety significance (i.e., Green finding). No cross cutting aspect was assigned because the finding was not indicative of current licensee performance.