05000498/FIN-2011006-01
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Finding | |
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Title | Failure to Timely Correct Conditions Adverse to Fire Protection |
Description | The team identified a noncited violation of License Condition 2.E for the failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the team identified two examples of failure to implement timely corrective actions to correct conditions adverse to fire protection. The first example related to making Procedure OPOP04-Z0-0001, Control Room Evacuation, Revision 33, consistent with the post-fire safe shutdown analysis in order to ensure the actions met critical time requirements. The second example related to not correcting a condition that could disable all three fire pumps simultaneously as a result of fire damage. Failure to implement timely corrective actions in two instances for conditions adverse to fire protection is a performance deficiency. Both examples of this finding are of greater than minor significance because they impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events (fire) to prevent undesirable consequences. A senior reactor analyst performed Phase 3 significance determination for both examples. The analyst calculated the risk associated with the first example for the actions taken outside the control room as 2.702E-7. For the second example, the analyst assumed that a fire in Fire Area 67 would damage the electrical control cables for all three fire pumps and require manually starting a fire pump at the fire pump house. However, it was determined that a delay in fire suppression because of the need to use a fire hose would not result in a plant transient, require evacuation of the control room, or result in damage to any systems and components required for post-fire safe shutdown. Therefore, the senior reactor analyst determined that both examples of this finding are of very low safety significance (Green). The licensee entered this deficiency into the corrective action program as Condition Record 11-10905. These examples of the performance deficiency had a crosscutting aspect in the area of human performance associated lvith resources because the licensee did not ensure that resources assigned to correct these deficiencies were adequate to assure nuclear safety. Specifically, the licensee failed to ensure adequate design margins by (1) failing to ensure that operators could perform all necessary manual actions prior to exceeding the regulatory requirements and (2) failing to modify the control circuits for the fire pumps to protect them against fire damage. |
Site: | South Texas |
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Report | IR 05000498/2011006 Section 4OA2 |
Date counted | Sep 30, 2011 (2011Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | G Pick S Graves N O'Keefe S Alferink J Mateychick S Makor |
CCA | H.6, Design Margins |
INPO aspect | WP.2 |
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Finding - South Texas - IR 05000498/2011006 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (South Texas) @ 2011Q3
Self-Identified List (South Texas)
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