05000445/FIN-2017003-02
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Finding | |
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| Title | Programmatic Failures to Control Transient Combustible Material in Accordance with a Fire Protection Procedure |
| Description | The inspectors identified 51 examples of a non- cited violation of Operating Licenses NPF -87 and NPF -89, License Condition 2.G, Fire Protection Program, for the failure to control transient combustibles in accordance with the station s Fire Protection Report . Specifically, Fire Protection Report, Revision 29, identifies areas that require strict control o f transient combustible materials such that they are not introduced into these areas without compensatory measures in place prior to introduction. Contrary to this, the licensee allowed storage of combustible materials in 51 areas without compensatory measures. This issue does not represent an immediate safety concern because the licensee removed the combustible materials when they were identified. The licensee entered this issue into its corrective action program as Condition Report CR -2017- 008728. The failure to control transient combustible material s in accordance with the approved Fire Protection Report is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against the external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the introduction of transient combustible materials decreased the external event mitigation for fire prevention. Furthermore, the inspectors determined that this was a programmatic issue since multiple departments were responsible for t he inappropriate introduction of combustible materials into the exclusion areas . Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the finding pertained to a failure to adequately implement fire prevention and administrative controls for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Sept ember 20, 2013 , and determined that the finding was of very low safety consequence (Green) because the fire prevention and administrative controls finding would not prevent the reactor from reaching and maintaining a safe shutdown condition because none of the examples impacted both trains of safe shutdown equipment . The finding has a human performance cross -cutting aspect associated with procedure adherence, in that station personnel failed to follow procedure requirements when introducing transient combustible materials into exclusion areas [H.8] |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2017003 Section 4OA2 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Josey R Kumana M Chambers P Elkmann S Hedger B Correll M Haire |
| Violation of: | License Condition - Fire Protection |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
| ' | |
Finding - Comanche Peak - IR 05000445/2017003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2017Q3
Self-Identified List (Comanche Peak)
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