05000443/FIN-2011008-01
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Finding | |
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| Title | Failure to Test Fire Detectors as Required by the Approved Fire Protection Program |
| Description | The team identified a non-cited violation of Seabrook Operating License Condition 2.F for the failure to implement all provisions of the approved Fire Protection Program (FPP). Specifically, the FPP required fire detectors to be tested in accordance with National Fire Protection Association (NFPA) 72E (1987 edition), which required the application of smoke or heat to initiate an alarm response. Since about 1990, NextEra\'s test procedures for Simplex fire detectors did not use smoke or heat to verify detector funciionality, and instead relied on an internal self test feature and a magnetic trip test feature for detector testing (i.e., an alternate test method). NextEra\'s preliminary evaluation concluded that detector functionality was adequately checked by the alternative test method, but the alternate test method did not comply with the approved FPP, which required testing to be performed in accordance with NFPA requirements. The team determined that the failure to verify the adequacy of design was a performance deficiency. The change in the detector test method represented a de facto change to the approved FPP, in that the FPP required a different test method. This issue was more than minor because it was similar to NRC IMC 0612, Appendix E, Examples of Minor lssues, Example 3.k, which stated that an analysis to verify the adequacy of design contained incorrect assumptions. The example concluded that the issue would be more than minor if the error resulted in a condition where there was a reasonable doubt on the operability of the component. For this issue, a knowledgeable engineer could not independently determine whether the fire detectors had been adequately tested since initial installation (about 20 years ago) to demonstrate that they would respond to smoke or heat and initiate an alarm. The team determined that the failure to verify the adequacy of design was a performance deficiency. The change in the detector test method represented a de facto change to the approved FPP, in that the FPP required a different test method. This issue was more than minor because it was similar to NRC IMC 0612, Appendix E, Examples of Minor lssues, Example 3.k, which stated that an analysis to verify the adequacy of design contained incorrect assumptions. The example concluded that the issue would be more than minor if the error resulted in a condition where there was a reasonable doubt on the operability of the component. For this issue, a knowledgeable engineer could not independently determine whether the fire detectors had been adequately tested since initial installation (about 20 years ago) to demonstrate that they would respond to smoke or heat and initiate an alarm. The team performed a Phase 1 SDP screening, in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding affected the fixed fire protection systems category, and was screened to very low safety significance (Green) because the fire detector test deficiency was determined to have a low degradation rating. This finding did not have a cross-cutting aspect because it was determined to be a legacy issue and was not considered to be indicative of current licensee performance. |
| Site: | Seabrook  |
|---|---|
| Report | IR 05000443/2011008 Section 1R05 |
| Date counted | Sep 30, 2011 (2011Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | J Lilliendahl C Cahill R Fuhrmeister J Rogge J Rady J Richmond |
| INPO aspect | |
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Finding - Seabrook - IR 05000443/2011008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Seabrook) @ 2011Q3
Self-Identified List (Seabrook)
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