05000416/FIN-2013003-01
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Finding | |
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| Title | Failure to Properly Implement a Compensatory Fire Watch per Station Fire Protection Procedures |
| Description | The inspectors identified a non-cited violation of Facility Operating License Condition 2.C(41) for the failure to properly implement a compensatory fire watch per the station fire protection program. Following an inadvertent release of carbon dioxide from the Cardox automatic fire suppression system into a division 2 safety related switchgear room located in the auxiliary building, the operators isolated the auxiliary building from the Cardox system to prevent any future inadvertent releases. The inspectors accompanied the fire watch patrol, which was required due to the isolation of the Cardox system to the auxiliary building, and they noted that during the patrol, none of the 10 rooms requiring a fire watch were checked. The inspectors brought this concern to the shift manager who confirmed that each room was required to be checked per the established fire watch criteria and that the fire watch patrol misunderstood the requirement. The licensee took immediate corrective action to direct the fire watch to check all the rooms to restore compliance with the fire watch requirements. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2013-04058. The failure to perform a fire watch in accordance with the fire protection program is a performance deficiency. The performance deficiency is more than minor and therefore a finding because it is associated with the protection against the external factors attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to perform the fire watch correctly adversely impacted the plants capability to detect and suppress a fire in a timely manner. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the inspectors determined that the issue affected the Mitigating Systems Cornerstone. Using NRC Inspection Manual Chapter 0609, Attachment 4, Table 3, the inspectors were directed to NRC Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process. The inspectors determined that the finding had an adverse affect on the fixed fire protection systems element of fire watches posted as a compensatory measure for outages or degradations. The inspectors assigned a high degradation rating due to the automatic fire suppression system being tagged out of service. Because the system was degraded without compensatory actions for less than three days, the inspectors used a duration factor of 0.01. The inspectors used 2E-2 for a generic fire frequency area for a switchgear room. The resulting change in core damage frequency was 2E-4, which was greater than the high degradation Phase 1 Quantitative Screening Criteria of 1E-6. Therefore, a senior reactor analyst performed a detailed risk evaluation. The analyst performed a bounding analysis of the performance deficiency (See Table 1R05-1). For each of the 10 affected fire areas, the analyst determined the probability of a fire occurring by multiplying the fire ignition frequency from the licensees fire hazards analysis by the 9.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that the performance deficiency impacted the plant. Because each fire area had a functional fire detection system throughout the exposure period, the analyst determined the nondetection probability by multiplying the fire probability by the generic failure probability for a detection system. The analyst made the bounding assumption that all fires postulated to initiate that were not detected would proceed to core damage. The sum of all the non-detection probabilities was 9.1 x 10-7 (See Table 1R05-1). Therefore, the bounding analysis indicates that this finding is of very low safety significance (Green). The inspectors determined the apparent cause of this finding was that the security officers performing the fire watch patrols did not understand the requirement to visually check the affected rooms. Therefore, the finding has a cross-cutting aspect in the human performance area associated with the work practices component because the licensee did not communicate human error prevention techniques such as pre-job briefings and proper documentation of activities commensurate with the risk of the assigned task. |
| Site: | Grand Gulf  |
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| Report | IR 05000416/2013003 Section 1R05 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | B Rice C Hale J Braisted J Quichocho R Kopriva R Smith |
| Violation of: | License Condition - Fire Protection License Condition |
| CCA | , |
| INPO aspect | QA.4 |
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Finding - Grand Gulf - IR 05000416/2013003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2013Q2
Self-Identified List (Grand Gulf)
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