05000445/FIN-2011007-03
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Finding | |
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Title | Failure to Ensure Emergency Lights in Safe Shutdown Areas had an 8-Hour Capacity |
Description | The team identified a noncited violation of License Condition 2.G for failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to establish a maintenance and/or test program that demonstrated that emergency lighting had an 8-hour capacity in areas required for safe shutdown. When inspectors questioned the licensee\'s practice of replacing the emergency light batteries without ever testing to confirm that the replacement interval was appropriate to ensure an 8-hour capacity, the licensee conducted tests that showed that 22 percent of the batteries on a 3-year replacement interval failed in less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The licensee entered this issue into their corrective action program as Condition Report CR-2011-001821. The licensee created action items to CR-2011-001821 for additional testing on a broader sample of emergency lights to aid in determining the correct replacement interval to ensure operability, and shortened the 3-year replacement interval for lights which failed to meet operability requirements as a result of testing to a more conservative 2-year replacement interval which had no demonstrated testing failures. The failure to establish a maintenance and/or test program that demonstrated operability for 8-hour emergency lighting required for operator manual actions at safe shutdown equipment is a performance deficiency. The performance deficiency was more than minor because it is 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. Specifically, the failure of the emergency lights to last 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> could adversely affect the ability of operators to perform the manual actions required to support safe shutdown in the event of a fire. The significance of this finding was evaluated using Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because the performance deficiency affected fire protection defense-In-depth strategies involving post-fire safe shutdown systems. Using Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various Fire Protection Program Elements, the finding was assigned a low degradation rating because the finding minimally impacted the performance and reliability of the fire protection program element. The team also noted that operators were required to obtain and carry flashlights. Therefore, the finding screened as having very low safety significance (Green). This finding did not have a crosscutting aspect because it was not indicative of current licensee performance, in that the replacement program had been used for longer than 3 years. |
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 |
INPO aspect | |
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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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