05000445/FIN-2011007-01
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Finding | |
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Title | Failure to Implement Effective Corrective Actions for a Condition Adverse to Fire Protection |
Description | The team identified a noncited violation of License Condition 2.G for the failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the team identified two examples where the licensee failed to implement effective corrective actions to ensure that time-critical manual actions would be accomplished within analyzed times for alternative shutdown scenarios. The first example involved the failure to close a spuriously opened pressurizer power-operated relief valve within the time allowed by the postfire safe shutdown analysis. The second example involved the failure to restore station service water cooling before damage could occur to the credited emergency diesel generator in the event of a control room fire with a loss of offsite power. The licensee entered this issue into their corrective action program as Condition Reports CR-2011-001647, CR-2011-001742 and CR-2011- 001836. In response to this issue, the licensee re-ordered the procedure steps to isolate the power-operated relief valves and ensure the standby service water pump was running sooner. The licensee planned to perform a validation of the revised procedures. Failure to implement effective corrective actions to ensure that time-critical manual actions would be accomplished within analyzed times for alternative shutdown scenarios is a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding could not be evaluated using Inspection Manual Chapter 0609, Appendix F. Fire Protection Significance Determination Process, because the performance deficiency involved a control room fire that led to control room abandonment. A senior reactor analyst performed a Phase 3 evaluation bounding analysis that concluded this finding had very low safety significance (Green) because the number of electrical cabinets in the control morn and cable spreading room that contained circuits that could have a fire that could affect the power-operated relief valves or station service water system was a small fraction of the total. This performance deficiency had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program because the licensee did not take appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance. |
Site: | Comanche Peak |
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Report | IR 05000445/2011007 Section 1R05 |
Date counted | Jun 30, 2011 (2011Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.05 |
Inspectors (proximate) | J Bowen J Mateychick J Watkins N O'Keefe N Okonkwo S Alferink S Graves |
CCA | P.3, Resolution |
INPO aspect | PI.3 |
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Finding - Comanche Peak - IR 05000445/2011007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2011Q2
Self-Identified List (Comanche Peak)
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