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05000390/FIN-2013008-012013Q3Watts BarFailure to Validate Appendix R Abnormal Operating Instructions in accordance with Station ProceduresAn NRC identified Green NCV of Technical Specification 5.7.1, Procedures, was identified for the licensees failure to validate Appendix R abnormal operating instructions (AOI) in accordance with station procedures. The issue was entered into the licensees corrective action program as problem evaluation report (PER) 787990. The licensees failure to validate time critical operator actions for Appendix R AOIs as required by site procedures was a performance deficiency. The performance deficiency was considered more than minor because if left uncorrected, the issue had the potential to result in the failure to meet design bases operator action times during fire events. The significance of this finding was determined to be of very low safety significance (Green) because the identified deficiencies did not adversely affect the ability to reach and maintain safe shutdown. The cause of the finding involved the cross-cutting aspect of whether the licensee takes appropriate corrective actions to address safety issues within the Corrective Action Program component of the Problem Identification and Resolution area. Specifically, the licensee implemented inadequate corrective actions for PER 637443 which identified that Appendix R time critical actions were not performed as required by procedure TI-12.19.
05000390/FIN-2013008-022013Q3Watts BarInadequate Compensatory Actions to Minimize the Effects of Impaired Fire Protection Equipment on Fire Safe ShutdownAn NRC identified Green NCV of Operating License Condition (OLC) 2.F was identified for the licensees failure to ensure that established operating requirements (ORs) for the high pressure fire protection (HPFP) system accounted for affected and credited equipment as determined in the fire hazard analysis (FHA) and safe shutdown (SSD) analysis. The issue was entered into the licensees corrective action program as PER 786848, and implemented Shift Orders FPU-13-018 and 13-071 which required the establishment of fire watches for the affected areas. The licensees failure to ensure that established ORs for the HPFP water supply system were supported by the FHA and SSD analysis was a performance deficiency. The 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 was determined to be of very low safety significance (Green) because the affected fixed fire suppression systems would be able to suppress a fire such that no additional equipment important to safety would be affected by a fire. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance.
05000390/FIN-2013008-032013Q3Watts BarLicensee-Identified ViolationWatts Bar Operating License Condition 2.F requires that the licensee shall implement and maintain in effect all provisions of the approved fire protection program, as described in the Fire Protection Report for Watts Bar Unit 1, as approved in Supplements 18 and 19 of the SER (NUREG-0847). License Condition 2.F further states that the licensee may make changes to the approved fire protection program without prior NRC approval, only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Contrary to the above, on July 18, 2012, the licensee identified that the site failed to meet the requirements of Watts Bar OLC 2.F, and the approved FPP, in that, an evaluation performed for a change made to the approved FPP was not adequate to ensure that the change would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. Specifically, new OMAs that were added by DCN 52033 did not include all necessary heat loads on the component cooling system. The licensee initiated PER 787426 to address this issue. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated June 2, 2011, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, which determined that, an IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, review was required. The issue was determined to be of very low safety significance (Green) because, despite the performance deficiency, the reactor would be able to reach and maintain safe shutdown conditions (Step 1.3.A of IMC 0609, App. F, Attachment 1).