05000443/FIN-2011008-02
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Finding | |
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Title | Failure to Maintain a Sufficient Number of Fire Pumps lnservice to Ensure 100 percent Capacity |
Description | The team identified a non-cited violation of Seabrook Operating License ConOition 2.F for the failure to implement all provisions of the approved FPP. Specifically, the FPP required a sufficient number of fire water pumps to be functional to ensure that 100 percent capacity would be available. NextEra\'s design analysis of the fire water system required the capacity of two 50 percent pumps to satisfy the largest single water suppression demand. In addition, the Seabrook Station Fire Protection Mahual stated that the FPP, in part, consisted of the Fire Protection Technical Requirements (i.e., the fire protection sections of the Technical Requirements Manual (TRM). ln 2001, Seabrook engineering revised the fire water supply functionality requirements in the TRM and, in error, unintentionally revised the fire pump functionality requirements. Since 2001, the TRM allowed the fire water system to remain functional with only one 50 percent pump available for up to 30 days. ln response to this issue, NextEra issued an Operations Standing Order to allow only one fire water pump to be removed from service at a time, with an administrative limit of seven days. The team determined that the failure to evaluate, review, and approve a change to the approved FPP was a performance deficiency. This issue was more than minor because it was similar to NRC IMC 0612, Appendix E, Examples of Minor lssues, Example 3.a which stated that a modification\'s design adequacy had less than adequate design control measures applied. The example concluded that the issue would be more than minor if the error resulted in a condition where the modification required revision to correct the concern. For this issue, an unintended, and unevaluated, change was made to the TRM. The error was significant enough that the entire change, regarding the pumps, would either have to be reversed (i.e., undone), or a new TRM change request prepared and approved, with a corresponding licensing basis change. 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 pump availability 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 ![]() |
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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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