05000440/FIN-2009004-01
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Finding | |
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| Title | Failure to Perform an Adequate POST-MAINTENANCE Test Following Installation of New Emergency Diesel Generators Carbon Dioxide System Control Panels |
| Description | A finding of very low safety significance (Green) and associated non-cited violation of license condition 2.C.(6), Fire Protection, was self-revealed for the licensees failure implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR). Specifically, the licensee failed to ensure that, ...the main floor [of the Diesel Generator Building] is protected by a total flooding carbon dioxide system for fire suppression. The licensee had installed a permanent modification to the carbon dioxide system for the diesel generator room, but had chosen not to conduct complete post modification testing. The failure to conduct a complete test resulted in a wiring error to go undetected. Testing after the system was placed in service identified that the system did not function as designed. Troubleshooting identified that Division 2 and 3 emergency diesel generators (EDG) pneumatic electric relays in the new control panel were cross-wired to Division 3 and 2 EDG fan relays, respectively, in the control box. As part of their corrective actions, the licensee re-labeled the wires correctly in the CO2 panels and landed them on their appropriate terminals. The licensee entered this issue into their corrective action program as CR 09-60866. The licensees immediate corrective actions included placing the system in lockout and notifying all fire team personnel of the manual actions required to initiate CO2 flow into the emergency diesel generator rooms. The finding was determined to be more than minor because, if left uncorrected, the inability of the EDG automatic fire suppression system to perform its function would become a more significant safety concern. Specifically, a fire in the Division 2 EDG room would not have been protected by adequate automatic fire suppression and it would render the Division 3 EDG inoperable. Similarly, a fire in the Division 3 EDG room would not have been protected by adequate automatic fire suppression and it would render the Division 2 EDG inoperable. The inspectors concluded this finding was associated with the Mitigating Systems cornerstone. In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 3b, the inspectors determined that the finding degraded the fire protection defense-in-depth strategies. Therefore, screening under IMC 0609, Appendix F, Fire Protection Significance Determination Process, was required. Using Part 1 of the Fire Protection SDP Phase 1 Worksheet in Manual Chapter 0609, Significance Determination Process, the performance issue was determined to be in the fixed fire protection systems category based on the fixed fire suppression systems being degraded. This finding did not screen as very low safety significance (Green) in the Phase 1 analysis and a Phase 2 analysis under IMC 0609 Appendix F was required. A regional senior reactor analyst evaluated this finding and assumed the fire frequency to be 3.0E-2 for the EDG rooms based on the licensees IPEEE (Individual Plant Examination External Events). Considering the fire frequency and remaining mitigating capability in the event of a plant transient, the senior reactor analyst determined that the risk associated with this finding was less than 1.0E-06. Therefore, this finding was determined to be best characterized as very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, decision making, per IMC 0609 H.1(b), because the licensees decisions did not demonstrate that nuclear safety was an overriding priority. Specifically, the licensee chose to minimize system unavailability time over performing a full and complete postmaintenance test on a newly installed EDG CO2 control system, a test that would have identified the wiring error |
| Site: | Perry  |
|---|---|
| Report | IR 05000440/2009004 Section 1R18 |
| Date counted | Sep 30, 2009 (2009Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | M Munir M Marshfield M Phalen G Wright J Bashore J Cameron P Voss R Murray |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Perry - IR 05000440/2009004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2009Q3
Self-Identified List (Perry)
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