05000416/FIN-2014002-01
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Finding | |
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Title | Failure to Ensure Scaffold Activity Would not Interfere with Fire Brigade Response |
Description | The inspectors identified a non-cited violation of License Condition 2.C(41), Fire Protection Program, for the failure to adhere to procedural requirements to ensure that scaffold installed in the plant would not prevent or restrict the fire brigade from accessing a certain route used for response to a fire in the area. On February 4, 2014, the licensee installed a scaffold in the containment building for an inspection. The licensees procedure required a walkdown of proposed scaffold to determine if the scaffold would prevent or restrict fire brigade access. The initial reviewer identified that the ladder to access the scaffold would restrict fire brigade access, thus the ladder was not installed until it was required. On March 1, 2014, the ladder was installed for the four hour inspection. Once completed, the licensee failed to remove the scaffold ladder to restore normal access to the area. On March 4, 2014, the inspectors identified that the scaffold ladder was still installed. The inspectors brought their concern to the licensee, who determined that the scaffold would adversely affect the response of fire brigade members to that area of containment. As an immediate corrective action, the licensee removed the scaffold ladder to allow adequate access for the fire brigade members. The licensee documented this issue in Condition Report CR-GGN-2014-02363. The failure to ensure fire brigade members had adequate access passed a scaffold installed in the containment building was a performance deficiency. The performance deficiency was more than minor and therefore a finding because it adversely impacted the protection against external factors attribute of the Mitigating System Cornerstone in that the fire brigades inability to gain access to certain areas in containment could result in preventing prompt extinguishing of fires. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the issue affected the Mitigating Systems Cornerstone and that the finding pertained to a degraded condition while the plant was shutdown for refueling outage RF19. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, dated February 28, 2005. The inspectors determined that Appendix G did not address fire brigade issues and solicited input from the senior reactor analyst. The senior reactor analyst performed a detailed risk evaluation and determined that Inspection Manual 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, June 19, 2012, Exhibit 2, Mitigating System Screening Questions, adequately bounded the performance deficiency. The inspectors determined that the finding involved the response time of the fire brigade to a fire, and the finding was of very low safety consequence (Green) because the fire brigades response time was mitigated by other defense-in-depth elements such as area combustible limits were not exceeded, installed fire detection systems were functional, and alternate means of safe shutdown were not impacted. Specifically, there were no combustibles in the area beyond limits, all fire detectors for the area were functional, and the plant was in a shutdown condition with the cavity flooded at the time. The apparent cause of this finding was the work groups involved did not communicate the significance of the impact the scaffold ladder had on fire brigade access to the area and the importance of having the ladder removed upon completion of the work. Therefore, the finding has a cross-cutting aspect in the human performance area associated with team work, in that the individuals and workgroups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. |
Site: | Grand Gulf ![]() |
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Report | IR 05000416/2014002 Section 1R05 |
Date counted | Mar 31, 2014 (2014Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.05 |
Inspectors (proximate) | R Smith B Rice D Allen J Drake N Greene P Hernandez R Azua |
Violation of: | License Condition - Fire Protection License Condition |
CCA | H.4, Teamwork |
INPO aspect | PA.3 |
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Finding - Grand Gulf - IR 05000416/2014002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2014Q1
Self-Identified List (Grand Gulf)
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