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05000390/FIN-2015010-012015Q3Watts Bar420 Minute Operator Manual Action to Provide Source Range Monitoring CapabilityThe inspectors identified an unresolved item associated with a fire protection safe shutdown OMA that established a time requirement of 420 minutes to provide a functional source range monitor. The inspection team noted that procedure 1-AOI-30.2 C36, Fire Safe Shutdown Room 737-A1A, Rev. 0005 included a 420 minute operator manual action (OMA) to establish a functional source range monitor. The OMA was listed as OMA 649 in Calculation EDQ00099920090016, Appendix R Unit 1 & 2 Manual Action, Rev. 4. The inspectors also noted the following: - Westinghouse Owners Group letter, WOG-05-36 (dated 01/28/2005), Section 6.2, Long Term Cold Shutdown Capability, stated that typical instrumentation to achieve a shutdown condition during Appendix R event included the source range monitors. - Technical Specification 3.3.1.L required an operable source range neutron flux channel in Modes 3, 4, and 5; and stipulated that positive reactivity additions (such as plant cooldown) be suspended when the instrument was inoperable. - Procedure 1-AOI-30.2, Fire Safe Shutdown, Rev. 0005, Step 5.3.15, stated that at least one channel of nuclear instrumentation indication must be available to monitor shutdown neutron population. - Procedure 1-AOI-30.2 C36 included a note that stated that RCS cooldown should not be initiated until source range monitoring capability can be assured. - Procedure 1-AOI-30.2 C36 directed operators to depressurize and cooldown an action that was typically required at 60 75 minutes. The 420 minute OMA would allow shutdown and subsequent cooldown of the reactor plant without operators having the ability to monitor neutron population. The licensee contended that OMA 649 was part of the sites licensing bases and thus the capability to monitor source range was not required until 420 minutes. The inspection team determined that this issue required additional inspection because the licensee did not provide an alternative method to monitor neuron population and did not provide adequate restrictions to prevent cooldown activities until monitoring capability was restored. Additionally, the OMA conflicted with the technical specification requirements for source range availability. The issue is unresolved pending additional review to determine if a performance deficiency exists. Required actions to resolve this issue include a detailed review of applicable docketed licensing bases correspondence; consultation with NRRs fire protection and technical specification branches; and an assessment to determine the applicable fire areas if the issue is to be determined to be a more-than-minor performance deficiency. This issue will be tracked as URI 05000290/2015010-01, 420 Minute Operator Manual Action to Provide Source Range Monitoring Capability.
05000413/FIN-2015012-012015Q2CatawbaFailure to Analyze the Spurious Operation of Control Room Area Ventilation Valves and the Adverse Impact on Control Room HabitabilityThe NRC identified an NCV of the Unit 1 and 2 Catawba Nuclear Station (CNS) Facility Operating License, Condition 2.C.5, for the failure to analyze the spurious operation of two motor operated valves (MOVs) in the control room area ventilation system (CRAVS) and the adverse impact on control room habitability. The licensee entered the issue in its correction action program as action request (AR) 01930126 and a continuous fire watch was already in place due to deficiencies identified during the sites ongoing NFPA 805 licensing activities. The failure to analyze the spurious operation of two MOVs in the CRAVS and the adverse impact on control room habitability was a performance deficiency (PD). The performance deficiency was more than minor because it was associated with the protection against external events (i.e. Fire) attribute of the Initiating Events Cornerstone and it adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the finding could be reasonably viewed as a precursor to a significant event based on smoke migration into the control room that could challenge control room habitability and lead to an evacuation of the control room. This PD was the result of degraded defense-in-depth features that limit the effects of a fire to one fire area. The finding was screened as Green because the reactors would be able to reach and maintain safe shutdown utilizing the standby shutdown facility. No cross cutting aspect was assigned because the finding was not indicative of current licensee performance.
05000413/FIN-2015012-022015Q2CatawbaFire Protection Program Change did not meet CNS License Condition Requirement 2.C.5 for Units 1 and 2The NRC identified a non-cited Severity Level IV violation of the Unit 1 and 2 CNS Facility Operating License, Condition 2.C.5, for the failure to implement and maintain in effect all provisions of the approved fire protection program (FPP). Specifically, the licensee made a change to the approved FPP which involved the de-rating of a credited three hour fire barrier between the control room and the cable spreading room(s) to only a pressure and smoke barrier. The licensee entered the issue in its corrective action program as AR 01932211 and it was added to existing fire watches for the area. The failure to comply with the CNS Operating License Condition 2.C.5 for a change to the approved FPP involving the de-rating of a credited three hour fire barrier between the control room and the cable spreading room(s) was a performance deficiency. The performance deficiency was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of protection against external events (i.e. Fire.) The performance deficiency negatively affected the cornerstone objective in that the change to the FPP had the potential to adversely affect the availability of the control room to achieve and maintain stable plant conditions due to the increased likelihood of control room abandonment in the event of a fire in the cable spreading rooms. The licensees failure to submit the FPP change to the NRC was determined to impede the regulatory process because the FPP change required NRC review and approval prior to implementation. The finding was screened as Green because based upon inspection of the affected barriers, the inspectors determined that the barriers would provide a 1-hour or greater fire endurance rating. This violation was determined to be a Severity Level IV violation because the associated finding was evaluated by the SDP as having very low safety significance (i.e., Green finding). No cross cutting aspect was assigned because the finding was not indicative of current licensee performance.