05000498/FIN-2017009-01
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Finding | |
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| Title | Failure to Implement Written Procedures Covering the Fire Protection Program |
| Description | During NRC investigations conducted March 25, 2015 through February 24, 2017, two violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below: A. 10 CFR 50.48(a)(1 )(iv) requires, in part, that a licensee must have a fire protection plan that outlines the plans for fire protection, fire detection, suppression capability, and limitation of fire damage. STP Nuclear Operating Company's Technical Specification 6.8.1.d requires, i n part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 10, Step 4.2, requires, in part, that each hourly fire watch shall be responsible for inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards, which includes looking behind all accessible areas, behind panels and components that may obscure the fire watches' view. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 6.0, requires, in part, that a condition report shall be written for a missed fire watch. Procedure OPGP03-ZX-0002, "Condition Reporting Process," Revision 50, Step 3.7, requires, in part, that condition report owners are responsible for proper resolution of the condition, including ensuring that the condition report description is accurate and actions are initiated to address the condition. Contrary to the above, the licensee failed to implement written procedures covering the fire protection program, as evidenced by the following two examples: 1. On May 8-15, 2014, hourly fire watches failed to follow Procedure ZFG-0001 and inspect all areas of the room for possible indications of smoke, fire, or potential fire hazards. Specifically, 20 fire watches, 17 in Unit 1, and 3 in Unit 2, were improperly performed as a result of improper written instructions provided by a supervisor that directed the hourly fire watches to only look at areas of impairments or transient fire loads instead of inspecting all areas of the room, as required by fire protection program requirements. 2. On March 4, 2015, a supervisor fa iled to follow Procedure OPGP03-ZX-0002 when the supervisor closed a condition report and failed to ensure that the condition report description was accurate and actions were initiated to address the condition. Specifically, the supervisor documented inaccurate information in Condition Report 15-4871 that stated, in part, that when a fire watch for Unit 2, Mechanical Auxiliary Building, Room 67 was inadvertently closed, fire watch personnel routinely traversed through the area while performing rounds, and once identified the round was performed immediately with no issues identified. However, no fire watch personnel traversed the area because the room was locked and it was not part of their normal route. Therefore, no fire watch personnel entered the room as documented in the condition report closure. B. 10 CFR 50.9 requires, in part, that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. STP Nuclear Operating Company Technical Specification 6.8.1.d requires, in part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 10, Step 4.2, requires, in part, that each hourly fire watch shall be responsible for inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards, which includes looking behind all accessible areas and behind panels and components that may obscure the fire watches' view. Step 4.2.12 requires, in part, that after completing the inspection of the assigned area, scan the appropriate "Fire Watch Scan Point" above the fire watch posting. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 6.0, requires, in part, that a condition report shall be written for a missed fire watch. Procedure OPGP03-ZX-0002, "Condition Reporting Process," Revision 50, Step 3.7, requires, in part, that condition report owners are responsible for proper resolution of the condition, including ensuring that the condition report description is accurate and actions are initiated to address the condition. Contrary to the above, the licensee failed to ensure that information required by the Commission's regulations, orders, or license conditions maintained by the licensee are complete and accurate in all material respects, as evidenced by the following three examples: 1. On May 8-15, 2014, the licensee failed to maintain complete and accurate records associated with hourly fire watches. Specifically, a total of 20 fire watch records, 17 in Unit 1, and 3 in Unit 2 were recorded (scanned) as being completed without inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards. This information was material to the NRC because the performance of fire watches enables the rapid detection, control, and suppression of a fire in accordance with the fire protection program requirements. 2. On March 4, 2015, the licensee failed to maintain complete and accurate records associated with a condition report. Specifically, a supervisor willfully documented inaccurate information in Condition Report 15-4871 that stated, in part, that when a fire watch for Unit 2, Mechanical Auxiliary Building, Room 67, was inadvertently closed, fire watch personnel routinely traversed through the area while performing rounds, and once identified the round was performed immediately with no issues identified. However, no fire watch personnel traversed the area because the room was locked and it was not part of their normal route. Therefore, no fire watch personnel entered the room, as documented in the condition report. This information was material to the NRC because condition reports associated with missed fire watches provide evidence of compliance with licensee procedures and NRC requirements. 3. On April 14, 2015, the licensee failed to maintain complete and accurate records associated with a condition report. Specifically, a supervisor deliberately documented inaccurate information in Condition Report 15-9793 that stated, in part, that field interviews with a fire watch manager and a fire watch lead indicated that the Unit 2 fire watches (FW8934) were properly performed. However, the supervisor did not confirm with the fire watch manager or a fire watch lead that the fire watches had been properly performed. This information was material to the NRC because condition reports associated with missed fire watches provide evidence of compliance with licensee procedures and NRC requirements. This is a Severity Level Ill problem (NRC Enforcement Policy Section 2.2.1.d) . |
| Site: | South Texas  |
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| Report | IR 05000498/2017009 Section 1R05 |
| Date counted | Mar 31, 2017 (2017Q1) |
| Type: | TEV: Severity level III |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | K Kennedy |
| Violation of: | 10 CFR 50.9 10 CFR 50.48 Technical Specification - Procedures |
| INPO aspect | |
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Finding - South Texas - IR 05000498/2017009 | |||||||||||||||||
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Finding List (South Texas) @ 2017Q1
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