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05000369/FIN-2018011-012018Q2Mcguire
McGuire		Question about treatment of well-sealed, robustly secured cabinets in the Fire PRAInspectors identified an unresolved item (URI) associated with how the site calculated fire frequencies of electrical cabinets in the fire PRA. The site retained floor-mounted electrical cabinets characterized as well-sealed and robustly-secured as ignition sources in the fire PRA. The guidance of NUREG-6850, which the site is committed to, instructs that electrical cabinets housing voltages less than 400V, and that are characterized as well-sealed and robustly secured not be counted as ignition sources. This is because the fire PRA should only consider fires that can propagate to other combustibles and targets, and by including ignition sources that cannot propagate to other combustibles and targets, the frequency of fires in other electrical cabinets that can actually propagate could be erroneously lowered. Inspectors noted that retaining floor-mounted cabinets characterized as well-sealed and robustly-secured appeared to not be in alignment with the sites NFPA 805 submittal, and associated SE, which each contain information specific to the question about how well-sealed robustly secured cabinets were treated in the fire PRA. The SE states, Regarding the counting of well-sealed, robustly-secured electrical cabinets having circuits less than 440V, the licensee stated in its response to PRA RAI 03.b.01 that it updated the FPRA to remove cabinets meeting this definition. The site has asserted that this statement in the SE is incorrect, and does not align with what the site submitted on the docket as a part of their NFPA 805 submittal. Planned Closure Action(s): This issue is being characterized as a URI, pending a decision from NRR as to the interpretation of the sites submittal regarding treatment of floor-mounted well-sealed and robustly-secured cabinets, and the accuracy of the associated SER
05000280/FIN-2018010-012018Q1SurryFailure to implement the 10 CFR, Part 50, Appendix R, III.G.3 requirements consistent with fire protection license condition 3I.The NRC identified a Green finding and associated non-cited violation (NCV) of the requirements consistent with license condition 3.I, Surry Units 1 and Unit 2. Specifically, the licensee failed to adequately protect fiberglass pipe that is susceptible to fire damage and required for safe shutdown. By not protecting the pipe, the licensee did not ensure the alternative shutdown methodology was implemented with the independence as defined by the 10 CFR 50 Appendix R section III.G.3 requirements.
05000321/FIN-2017002-032017Q2HatchNoncompliance for Providing Inadequate Procedural Guidance for Post-Fire Safe ShutdownIntroduction: The inspectors identified a noncompliance with Hatch Technical Specification 5.4.1.a for the licensees failure to provide adequate procedural guidance in post-fire safe shutdown abnormal operating procedure of Abnormal Operating Procedure (AOP) 34AB-X43-001-1, Fire Procedure. Specifically AOP 34AB-X43-001-1 directs operators to perform manual actions that may not be adequate to reopen a credited valve that has spuriously closed. Description: During the transition to NFPA 805, the licensee identified multiple instances of cables for equipment required to achieve SSD not meeting the separation requirements of the current licensing basis. The licensee determined that this condition existed for FA 1105, East Cableway Foyer. It was discovered that cables were identified in the current Safe Shutdown Analysis Report (SSAR) for HPCI Steam Supply Isolation motor operated valve 1E41-F002 . These cables were dispositioned by taking an Operator Manual Action (OMA) to open links BB-49 and BB-57 in panel 1H11-P622. Further evaluation showed that the OMA would prevent the valve from spuriously clos ing, but it would not re-open the valve after a spurious closure, due to the power supply for this valve being unavailable due to fire impacts. The licensee determined that these conditions were caused by methodology weaknesses in the sites fire safe shutdown analysis. Upon discovery, the licensee implemented compensatory measures in the form of posting a roving fire watch in fire areas of concern, and revised the affected procedure. 19 Analysis of the Problem Failure to adequately implement the requirements contained in 10 CFR Part 50.48(b)(1), and Hatch Renewed Operating License Condition 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 was a performance deficiency. This finding was more than minor because it was associated with the reactor safety mitigating system cornerstone attribute of protection against external events (i.e., fire). Because this issue relates to fire protection and this non-compliance was identified as a part of the sites transition to NFPA 805, this issue is being dispositioned in accordance with Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) of the NRC Enforcement Policy. In order to verify that this non-compliance was not associated with a finding of high safety significance (Red), inspectors revi ewed qualitative and quantitative risk analyses performed by the licensee. These risk evaluations took ignition source and target information from the ongoing Hatch fire PRA to demonstrate that the significance of the non-compliances were less-than-Red (i.e. core damage frequency (CDF) less than 1E-4/year). Inspectors determined that cables associated with some of the VFDRs were not located in the zone of influence (ZOI) of any credible ignition source. For cables that were located in the ZOI of a credible ignition source, inspectors were able to perform a calculation to determine the change in conditional core damage probability (CCDP), based on the postulated fire-affected equipment not being available. Based on these screenings, inspectors determined that the significance of this non-compliance was less- than-Red. A bounding risk assessment was performed by a regional SRA which included the review of the licensee and inspectors risk evaluations and confirmed the CDF risk increase due to this condition was less than 1E-4, and therefore less than RED. The inspectors determined that no cross-cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. Enforcement of the Problem 10 CFR Part 50.48(b)(1) requires that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of 10 CFR Part 50, Appendix R, Sections III.G, III.J, and III.O. Section III.G.2 requires, in part, that where cables and equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located in the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided: o separation of cables and equipment by a fire barrier having a 3-hour rating; or o separation of cables and equipment by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. Fire detection and automatic fire suppression shall be installed in the fire area; or o enclosure of cables and equipment of one redundant train in a fire barrier having a 1-hour fire rating. Fire detection and automatic suppression shall be installed in the fire area. 20 Section III.G.3 requires, in part, that alternative shutdown capability be provided where the protection of systems whose function is required for how shutdown does not satisfy the requirement of Section III.G.2. Additionally, Hatch Technical Specifications 5.4.1.a, Procedures for Unit 1 states that written procedures shall be established, implemented, and maintained covering activities listed in NRC Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Item 6.v of Appendix A lists Plant Fires as an activity that requires written procedures. Contrary to the above, the licensee failed to meet the requirements of its documented fire protection program since initial plant licensing, in that: The licensee did not meet the requirements of 10 CFR Part 50, Appendix R, Section III.G.2 in that the licensee did not ensure that one of the redundant trains was free of fire damage by providing one of the following means stated in Section III.G.2. The licensee did not ensure alternative shutdown capability be available for 2 fire areas where the guidelines for ensuring one redundant train for safe shutdown be free of fire damage, as required by 10 CFR Part 50, Appendix R, Section III.G.3. The licensee failed to provide adequate procedural guidance to ensure fire safe shutdown due to a fire in FA 1105. CRs generated for these issues are listed in the Documents Reviewed section. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), t he NRC is exercising enforcement and reactor oversight process (ROP) discretion (EA-17-120) for this issue in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, this issue was identified and will be addressed during the licensees transition to NFPA 805, it was entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, it was not likely to have been previously identified by routine licensee efforts, it was not willful, and it was not associated with a finding of high safety significance (Red)
05000366/FIN-2017002-022017Q2HatchPerformance of Operations with Potential to Drain the Reactor Vessel (OPDRV) Without Secondary ContainmentThe inspectors reviewed this LER for potential performance deficiencies and/or violations of regulatory requirements. In February 2017, during the Unit 2 refueling outage, operations with the potential to drain the reactor vessel (OPDRV) activities were performed while in Mode 5 (Refueling Mode) contrary to Technical Specification (TS) 3.6.4.1. Enforcement Guidance Memorandum (EGM) 11-003, Revision 3, provided required interim actions which were incorporated into procedure 31GO-OPS-025-0 Operations with the Potential to Drain the Reactor Vessel. This procedure was used during the OPDRV activities for the Unit 2 refueling outage. LER 05000366/2017-001- 00 is closed. Description: The inspectors reviewed the plants implementation of Enforcement Guidance Memorandum 11-003 during maintenance activities which had the potential to drain the reactor vessel during the Unit 2 refueling outage. The activities were: Local power range monitors removal and replacement February 10, 2017; Control rod drive insert / recouple activity February 11, 2017; and Hydraulic Control Unit Venting February 12-13, 2017. 15 These activities took place without secondary containment being operable. Inspectors verified compliance with the guidelines of Enforcement Guidance Memorandum 11-003 prior to and during these activities. This condition was documented in the licensees corrective action program as CR 10329405, 10329857, 10330152, and 10330153. Enforcement: Unit 2 TS 3.6.4.1 required, in part, that activities that had the potential to drain the reactor vessel be conducted only with secondary containment operable. Contrary to that requirement, the licensee conducted activities that could cause the reactor vessel to drain while secondary containment was inoperable. The NRC is exercising enforcement discretion (Enforcement Action (EA)-17-124) in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy because the violation was identified during the discretion period described in Enforcement Guidance Memorandum 11-003. Therefore, the NRC will not issue enforcement action for this violation, subject to the license amendment request which was submitted on April 20, 2017.
05000327/FIN-2017007-022017Q2SequoyahLicensee-Identified ViolationThe licensee identified examples of a failure to meet the requirements of the Facility Operating License (FOL) condition C.16 and C.13 for units 1 and 2 respectively. The license condition states, in part, that TVA shall implement and maintain in effect all provisions of the approved fire protection program referenced in the UFSAR and as approved by the NRCs Safety Evaluation Report (SER). Updated Final Safety Analysis Report (UFSAR), Section 9.5.1, Fire Protection System, states in part that the Fire Protection System and fire protection features are described in the Fire Protection Report (FPR). FPR, Part III Safe Shutdown Capabilities, Section 3.0, Analysis of Safe Shutdown Systems, stated that a minimum set of plant systems and components are selected to ensure the plant is capable of reaching and maintaining the applicable safe shutdown state. Contrary to the above, the licensee failed to maintain the requirements prescribed in the fire protection program. Specifically, on February 13, 2017, the licensee identified non- conservative times for repair actions to achieve cold shutdown. The finding was screened in accordance with IMC 0609 Appendix F, Fire Protection Significance Determination Process, and determined to be Green, by answering Yes on Task 1.3.1, Question 1.3. The issue has been entered into the licensees corrective action program as CR 1261868, and CR 11261881. Additionally, adequate compensatory actions have been implemented.
05000327/FIN-2017007-012017Q2SequoyahLicensee-Identified ViolationThe licensee identified examples of a failure to meet the requirements of the Facility Operating License (FOL) condition C.16 and C.13 for units 1 and 2 respectively. The license condition states, in part, that TVA shall implement and maintain in effect all provisions of the approved fire protection program referenced in the UFSAR and as approved by the NRCs Safety Evaluation Report (SER). Updated Final Safety Analysis Report (UFSAR), Section 9.5.1, Fire Protection System, states in part that the Fire Protection System and fire protection features are described in the Fire Protection Report (FPR). Contrary to the above, the licensee failed to maintain the requirements prescribed in the fire protection program. Specifically, on February 7, 2017, the licensee identified numerous discrepancies and errors in the Fire Hazards Analysis, including multiple instances of inaccurate and non-conservative manual action time requirements. The deficiencies were associated with inaccurate assumptions based on loop-stagnation, head vent flow rates, and containment cooling which was inconsistent with FPR, Part III, Section 1.1, Design Basis Evaluation. The finding was screened in accordance with IMC 0609 Appendix F, Significance Determination Process, and determined to be Green, by answering Yes on Task 1.3.1, Question 1.3.1. The issue into the CAP as CR 11 1259493, CR 1224829, and CR 1261866. Additionally, adequate compensatory actions have been implemented.
05000321/FIN-2017002-042017Q2HatchLicensee-Identified ViolationTS 3.6.4.1 requires secondary containment be operable in Mode 1 and during movements of irradiated fuel assemblies in the secondary containment. Contrary to the above, on February 8 at 1035, with Unit 1 operating at 100 percent RTP and Unit 2 conducting refueling operations, secondary containment was made inoperable when Unit 2 reactor building containment was breached for a scheduled refueling outage and a configuration control error on the Unit 2 standby gas treatment system provided a uncontrolled opening into the secondary containment for the Unit 1 reactor building and the common refueling floor. A temporary blind flange had been incorrectly installed on the upstream side vice downstream side of the Unit 2 standby gas treatment inlet isolation valve when the valve had been removed from the system for testing. This configuration rendered secondary containment for the Unit 1 reactor building and the common refueling floor inoperable. A senior reactor operator performing a plant tour noted the incorrect flange configuration and at 2017 on February 17, the blind flange was moved to the downstream side of the Unit 2 standby gas treatment inlet isolation valve to restore compliance. Inspectors screened the finding in accordance with IMC 609 Appendix A The Significance Determination Process (SDP) for Findings at-Power. The finding screened as very low safety significance (Green) because the questions in Appendix A Exhibit 3 for Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building, were answered no. This issue was documented in the licensees corrective action program as CR 10332592.
05000321/FIN-2017002-012017Q2HatchHardened grease prevents 1RHRSW pump breaker operationGreen. A self-revealing, Green, non-cited violation (NCV) of Hatch Unit 1 Technical Specification 5.4 Procedures, was identified when procedures to rejuvenate grease in the 1C' residual heat removal service water (RHRSW) Pump breaker were not implemented resulting in failure of the pump to start. The violation was entered into the licensees corrective action program as condition report (CR) 10263236 and the breaker was replaced to restore compliance. Failure to rejuvenate the lubricating grease on 4kv DHPVR breakers in accordance with vendor guidance was a performance deficiency. Specifically, the hardened grease prevented the 1C RHRSW pump breaker from closing resulting in the inoperability of the 1C RHRSW pump. The performance deficiency was associated with the Mitigating Systems cornerstone and was more than minor because it adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors screened this finding using IMC 0609, Appendix A, The Significant Determination Process (SDP) For Findings At-Power, dated June 19, 2012. Because all four questions in Section A of Exhibit 2, Mitigating Systems Screening Questions, were answered no, the finding screened as Green. The inspectors determined that this finding did not have an associated cross cutting aspect because this finding is not reflective of current licensee performance.
05000395/FIN-2016010-032016Q4SummerFailure to ensure credited equipment to support the 50 54hh requirements were adequateThe NRC identified a Green, non-cited violation (NCV) of the 10 CFR 50.54(hh)(2) requirements. Specifically, the team identified aspects of the implementation strategy that were inconsistent to support the stated commitments. The licensees failure to ensure that credited components needed to implement the strategy were adequate for circumstances consistent with the stated commitments was a performance deficiency (PD). This PD was determined to be more than minor because of the adverse impact to the Mitigating Systems cornerstone objective. Specifically, the PD had the ability of impacting the availability and reliability of the credited strategy in response to conditions postulated to meet the 10 CFR 50.54hh requirements. The team screened the issue as Green using IMC 0612, Appendix B, Issue Screening, dated September 7, 2012, and determined that further screening was necessary consistent with IMC 0612, Appendix L, B.5.b Significance Determination Process. Dated December 24, 2009. In this instance, the finding was determined to be of Green significance since no additional strategies were impacted. The licensee initiated CR-16-05266 to address the NRC concerns.
05000395/FIN-2016010-042016Q4SummerFailure to seek or gain approval for risk-informed changes constituted a self-approved change which is inconsistent with the NFPA 805 requirementsThe NRC identified a SL IV, non-cited violation (NCV) of the 10 CFR 50.48(c), NFPA 805, requirements. Specifically, a Risk Informed Change was made that was inconsistent with Transition License Condition 2.C.18.(c).1 which stated in part: Before achieving full compliance with 10 CFR 50.48(c), ...risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval. In this instance, the team identified the licensee failed to seek or gain NRC approval for riskinformed changes that had a more than minimal risk impact to the fire protection program during the post-safety evaluation issuance period date of February 11, 2015. The licensees failure to obtain NRC approval prior to making any changes to the 2.C.18 license requirements was a performance deficiency (PD). This PD was determined to be more than minor because it impacted the regulatory process. Specifically, the team determined that risk-informed changes made to a commitment specified by license condition 2.C.18.(c).1, which was based upon docketed correspondence from the licensee, required NRC approval. The licensee deviated from the stated commitments without NRC approval which formed the basis for the team decision to evaluate the finding using traditional enforcement (TE) based upon the guidance in NRC Enforcement Policy. The team reviewed NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to assess the significance of the issue and determined the issue to be a SL IV. The licensee initiated CR-16-01490 and CR-16-05291.
05000395/FIN-2016010-012016Q4SummerFailure to Meet the Quality Requirements Specified By NFPA 805The NRC identified a SL IV, non-cited violation (NCV) of the 10 CFR 50.48(c), National Fire Protection Association Standard (NFPA) 805, requirements. Specifically, the team identified the licensees inability to ensure licensing basis information was maintained consistent with administrative procedures to support the NFPA 805 Section 2.2(j) and NFPA 805, Section 2.7 requirements. The licensees failure to meet the quality requirements specified by NFPA 805 Section 2.2. (j) and NFPA 805, Section 2.7, Program Documentation, Configuration Control and Quality was a performance deficiency (PD). This PD was determined to be more than minor because it affected the regulatory process. In this instance, the licensee failed to ensure information to support the NFPA 805 licensing commitments was controlled in the manner specified by the requirement. This information served as the basis for the NRC to perform its regulatory function and had the ability to impact the credited analysis relied upon to reach and maintain safe and stable conditions in case of a fire. As a result, the team evaluated the finding using the traditional enforcement (TE) process based upon the guidance in NRC Enforcement Policy and NRC Enforcement Guidance. The team reviewed the NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to aid assessing the significance of the issue and determined the issue to be a SL IV. A cross cutting aspect was not assigned based upon the TE determination. The licensee initiated CR-16-05060, CR-16-05074, CR-16-05160, CR-16-05276, and CR-16-05278 to address the NRC concerns.
05000395/FIN-2016010-062016Q4SummerLicensee-Identified ViolationThe licensee identified an example of a failure to meet the 2.C.18 commitments. The licensee was required to implement applicable aspects of the NFPA 805 requirements in order to achieve the risk reductions specified in RG 1.174, An Approach for Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis. To accomplish this, the licensee committed to various changes to the facility. In this instance, the licensee committed to ensure the PRA developed to meet the 2.C.18 requirements was completed consistent with Table S-2, Implementation Item 22 and SER Section 2.7.2. Contrary to the above, the licensee failed to implement the stated requirement specified by license condition 2.C.18 and docketed correspondence from the licensee to the NRC. Specifically, the licensee deviated from the stated commitment without NRC approval by which formed the basis for the team to evaluate the finding using traditional enforcement (TE) based upon the guidance in NRC Enforcement Policy. The team reviewed the NRC Enforcement Guidance, Part II, Section 2.2, Actions Involving Fire Protection, to aid assessing the significance of the issue and determined the issue to be a SL IV. A cross cutting aspect was not assigned based upon the TE determination. Based upon the identification by the licensee, the issues have been entered into the licensees corrective action program as CR-16-00321, CR-16-01132, CR-16-01602, CR- 16-04828, and CR-16-04829.
05000395/FIN-2016010-052016Q4SummerFailure to meet corrective action requirements consistent with NFPA 805 Section 2.6.3The NRC identified a Green non-cited violation (NCV) of the V.C Summer Nuclear Station, Unit 1, Renewed Facility Operating License (FOL) Condition 2.C.18 requiring the licensee to implement and maintain in effect all provisions of the approved FPP that complied with 10 CFR 50.48 (c), National Fire Protection Association Standard NFPA 805. The NRC safety evaluation report (SER) dated February 11, 2015, relied upon an adequate corrective action program to implement the NFPA 805 requirements. NFPA 805 Section 2.6.3, Corrective actions. Specifically, the team identified a failure to adequately classify and correct conditions adverse to quality (CAQ) in a timely manner. The licensees failure to properly assign an action level commensurate to ensure corrective actions were addressed consistent with the NFPA 805, Section 2.6.3 was a PD. The PD was more than minor because, if left uncorrected, it could lead to more significant safety concern. Specifically, the inadequate application of the corrective action program can lead to deficiencies degrading SSCs which can adversely impact the FPP requirements and lead to a more significant safety concern. The finding was screened in accordance with IMC 0612, Appendix B, Issue Screening, dated September 7, 2012, and IMC 0609, Attachment 4, Characterization of Findings dated October 7, 2016. A determination was made using IMC 0609, Significance Determination Process, dated April 29, 2015. Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012 was applicable since the administrative controls in this instance were not associated with transient or hot work activities. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because it did not represent an actual loss of safety function. The team assessed the finding against the IMC 0310, Cross-cutting Aspects, dated December 4, 2014, requirements and determined that cross-cutting was applicable. In this instance, the cause of this finding was determined by the team to have a cross-cutting aspect of the Resolution component (P.3) of the Problem Identification and Resolution (PI&R) area. This was selected based upon the inability organization to adequately identify and take effective corrective actions to address issues in a timely manner commensurate administrative procedures to meet the NFPA 805, Section 2.6.3 requirements. The licensee initiated CR-16-05306 and CR-16-05160, Action 1 related to this issue.
05000395/FIN-2016010-022016Q4SummerFailure to identify unsealed cabinet Specified by NFPA 805 Section 3.3.1.2(1)The NRC identified a Green, non-cited violation (NCV) for the failure to include potentially high-risk fire scenarios in the current fire protection program. In this instance, the team identified unsealed electrical cabinets credited as being sealed. The licensees failure to identified and assess the applicable electrical cabinet as a firescenario in its FSA database was a performance deficiency (PD). This PD was determined to be more than minor because of the adverse impact to the Mitigating Systems cornerstone objective. Specifically, the PD resulted in an incomplete fire risk model. The licensee performed an analysis of the performance deficiency using their fire probabilistic model and the results were that the PD represented a risk increase of <1.0E-6/year in core damage frequency and <1.0E-7/year in large early release fraction. The licensees results were reviewed by a regional senior reactor analyst (SRA). Additionally, a bounding analysis was performed by the regional SRA in accordance with NRC IMC 0609 Appendix F which concluded that the core damage frequency risk increase due to the PD was <1.0 E-6/year, a GREEN finding of very low safety significance. The team assessed the issue consistent with IMC 0310, Aspects Within Cross Cutting Areas, dated December 4, 2014, and determined the finding to have a cross-cutting aspect of Field Presence (H.2) in the Human Performance area because the licensee did not ensure that senior managers and supervisory staff maintained the proper amount of oversight of contractors and supplemental personnel in the performance work activities relevant to fire protection program implementation. The licensee has fire watches in place as a compensatory measure and has entered this issue into their corrective action program as CR-16-05287.
05000335/FIN-2016011-012016Q2Saint LucieFailure to Meet the Quality Requirements Specified By NFPA 805Inspectors identified a Severity Level IV violation of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, for failing to maintain adequate documentation and quality of analyses. Specifically, the NRC identified multiple examples when the licensee failed to comply with site quality assurance procedures. The issue was entered into the sites corrective action program as ARs 2139768, 2139986, and 2139993. The licensees failure to maintain adequate documentation and quality of analyses to maintain configuration control, such that they could be checked for adequacy and accuracy, was a performance deficiency (PD). The inspectors determined that the issue was more than minor because the ability of the NRC to verify aspects of the licensees NFPA 805 program was impacted. The inspectors determined that the Fire Protection Significance Determination Process (IMC 0609, Appendix F) was not suitable for screening this issue. Traditional enforcement was applied because the PD impacted a regulatory oversight function. In accordance with the NRC Enforcement Manual, Part II, Section 2.2, Actions Involving Fire Protection, the inspectors evaluated this finding to be a Severity Level IV violation. A cross-cutting aspect was not applicable because the issue was associated with a traditional enforcement violation.
05000335/FIN-2016011-022016Q2Saint LucieFailure to modify the Diesel Oil Storage Tank Overflow Line as Required by a Fire Protection License RequirementInspectors identified a Severity Level IV violation of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, for the licensees failure to modify the Unit 2A and 2B diesel oil storage tank (DOST) overflow lines as required by a fire protection license requirement. The issue was entered into the sites corrective action program as AR 2140024. The licensees failure to notify the NRC of changes to a licensed activity that was stipulated in the fire protection license condition (Table S-1) was a performance deficiency. The inspectors determined the PD was more than minor because the licensee failed to notify the NRC that the Unit 2 DOSTs overflow lines would not be modified; and, subsequently failed to request an exemption from the requirements of NFPA 30. Traditional enforcement was applied because the PD impacted the ability of the NRC to perform its regulatory oversight function. In accordance with the NRC Enforcement Manual, Part II, Section 2.2, Actions Involving Fire Protection, the inspectors evaluated this finding to be a Severity Level IV violation. The inspectors determined that a cross-cutting aspect was not applicable because the issue was associated with a traditional enforcement violation.
05000335/FIN-2016007-012016Q2Saint LucieIntake Cooling Water Pump House Transient Combustible Fire Loading CalculationThe inspectors identified an unresolved item (URI) associated with the transient combustible heat load calculation for both Units ICW pump houses and the basis for exclusion of treated or fire retardant wood. The URI is being opened to review the licensees evaluation and determine if a performance deficiency exist. Three ICW pumps and motors are located in each house. Each pump motor is 600 horsepower. During a walkdown of both units ICW pump houses, inspectors noted that the scaffolding around the ICW pumps consisted of metal and wood planks. The inspectors determined that the wood was not included in heat load calculation for the respective pump houses. The licensee stated that the wood was treated or fire retardant and did not need to be included in the sites transient combustible heat load calculations. The inspectors questioned the licensee on the basis for not including the treated wood in the transient combustible heat load calculation. The licensee entered this issue into the CAP as 2133079 and 2134308, and initiated corrective actions to evaluate the basis for not performing a combustible heat loading calculation for fire retardant wood. The licensee also took corrective actions to replace the wood with a non-combustible material. Additional inspection time is required to review the licensees evaluation and determine if a performance deficiency exist. This issue will be tracked as URI 05000335,389 / 2016007-01, Intake Cooling Water Pump House Transient Combustible Fire Loading Calculation.
05000321/FIN-2016007-012016Q2HatchFailure to provide reasonable assurance that Appendix R time critical operator actions (TCOAs) can be completed in a timely mannerThe NRC identified a Green non-cited violation (NCV) violation of Hatch Technical Specifications 5.4.1.d, Procedures, for Units 1 and 2, for not ensuring manual action feasibility for actions in fire area (FA) 0024. Specifically, the licensee failed to provide reasonable assurance that a credited manual action to ensure emergency power was both feasible and reliable in response to a fire event. The licensee plans to assess the issue and entered this violation into their Corrective Action Program (CAP) based upon CR10209664, CR10213119, & CR10212821. The licensees failure to provide reasonable assurance that Appendix R time critical operator actions (TCOAs) associated with fire events can be completed in a timely manner was a performance deficiency (PD). The PD was more than minor because if left uncorrected, it could to lead to a more significant safety concern. Specifically, the exclusion of TCOAs from a validation process could lead to plant or program changes that prohibit the completion of actions required to meet the licensing basis. Using the guidance of IMC 0609, App. F, the finding was screened as Green because the finding did not affect the ability to reach and maintain a stable plant condition within the first 24 hours of a fire event. The deficiency was screened with IMC 0310, Aspects Within Cross Cutting Areas, to determine if any cross-cutting areas were applicable. The team concluded cross-cutting was applicable to the problem identification and resolution (PI&R) area, evaluation attribute due the licensees failure to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (P.2).
05000335/FIN-2016011-032016Q2Saint LucieFailure to Meet the Combustible Control Requirements Specified By NFPA 805 for Work Platforms Located in the Intake Cooling Water Pump HouseInspectors identified a Green, non-cited violation (NCV) of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, for the licensees failure to comply with the combustible control requirements for work platforms that were located in the Intake Cooling Water (ICW) Pump House. The issue was entered into the sites corrective action program as AR 2137088. The licensees failure to adequately implement combustible material control requirements in procedures ADM-27.11 and Procedure 0010434 was a performance deficiency (PD). The (PD) adversely impacted the Initiating Events cornerstone attribute of Protection Against External Factors (Fire) and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations. Additionally, if left uncorrected, the deficiencies in the combustibles control program could result in wood platforms being staged in other areas of the plant. The finding was screened in accordance with NRC IMC 0609, Significance Determination Process, dated June 19, 2012, 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 because it was a fire prevention finding. The finding was determined to be of very low safety significance (Green), at Step 1.4.1.B because the impact of a fire would be limited to no more than one train of equipment important to safety. The inspector identified a cross-cutting aspect in work management because the licensee failed to ensure that the sites combustible control requirements were met during the installation and use of wood platforms in the ICW pump house (H.5).
05000321/FIN-2016007-022016Q2HatchPassive Fire ProtectionThe NRC identified a Green NCV of Hatch Renewed Operating License Conditions (OLCs) 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 respectively, because the licensee failed to adhere to branch technical position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1. Specifically, the licensee failed to implement the NFPA 80, Fire Doors and Windows, requirements to ensure fire confinement, thus affecting the defense in depth (DID) aspects. Description: During walkdowns of the chosen fire areas, the inspectors assessed whether the passive fire protection features adhered to the NFPA code commitments specified in the current licensing basis. Based upon the walkdown of the West DC Switchgear Room 2A (FZ 2018) and the adjacent access corridor (FZ 2014), the inspectors observed what they determined to be inadequate fire protection program implementation which would result in a degraded fire confinement ability between two fire zones. The code states, in part, that when doors are installed on only one face of a fire wall, heat responsive units shall be located on each side of the wall and interconnected so that the actuation of any one of them will permit the door to close. In this case, the heat responsive units were fusible metallic links designed to melt at a specific temperature and initiate door closure. The fusible links were not installed as required on both sides of the credited fire door between FZ 2018 and FZ 2014. Specifically, a link was only on one side of door 2L482C10. No link was installed on the side of the door in FZ 2014. The door in question was considered to be a Class A fire door and was designed to provide at least 3-hours of fire resistance between adjacent fire zones for a postulated fire event. Neither of these fire zones were protected with automatic suppression capability. In addition, there were existing exemptions in place for not meeting the 10 CFR Appendix R, III.G.2 requirements as referenced by the FHA. This further supported the need for ensuring the DID measures were adequate for fire confinement. In the second example, on October 15, 2015, the NRC resident inspector observed that an issue existed with the installation of an electro-thermal link designed to close the 2C EDG rolling fire door which separated FA 2407 from FA 0401. Specifically, it was noted that the device was installed in an improper configuration and that the electro-thermal link was mounted directly to the wall and secured using a nut and washer. In this configuration, the washer overlapped the seam of the electro-thermal link and hampered the links ability to separate and automatically close the door. The licensee declared the electro-thermal link non-functional and performed a functionality assessment. The assessment concluded that additional links designed to release the door in the event of a fire would have eventually fused, releasing the door. In addition, the gaseous carbon dioxide (CO2) fire suppression system protecting the 2C EDG would have retained the required CO2 gas concentration using the air control louvers, which were installed in series with the rolling fire door. The degraded electro-thermal link was corrected on November 10, 2015. Analysis: The licensees failure to ensure the DID aspects of the FPP were implemented consistent with the NFPA 80 requirement as specified by the current fire protection licensing basis was a PD. The PD was more than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and the related attribute of protection against external factors such as fire. Specifically, the lack of a required link above the fire door between the West DC Switchgear Room 2A and the adjacent access corridor fire zone and the improperly installed link between EDG Room 2C and the adjacent access corridor would have negatively impacted the expected response time of each of the fire doors to close. In addition, review of historical work orders and condition reports indicated problems with the air balance louvers coincident with the degraded ETL controlling the closure of the fire door would have impacted the likelihood of confining the CO2 gas at the required design concentration. In both these instances, the finding had a negative impact on the program DID aspects for the fire confinement category. In accordance with NRC IMC 0609, Significance Determination Process, Appendix F, the inspectors performed a Phase 1 analysis and determined the finding resulted in very low significance, Green, based on question 1.4.3-A since, in each case, the combustible loading on both sides of the barrier wall represented a fire duration less than 1.5 hours (i.e., less than 120,000 Btu/ft2). The team determined that no cross-cutting attributes were applicable based upon the issue being associated with meeting the original NFPA 80 design criteria at licensing. Enforcement: Hatch Operating License Condition (OLC) 2.C.(3) and 2.C.(3)(a), for Units 1 and 2 respectively, stated, in part, that Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report (UFSAR) for the facility. The E. I. Hatch UFSAR, Unit 2, Section 9.5, stated in part the plant fire protection system is described in the Edwin I. Hatch Nuclear Plant Units 1 and 2 Fire Hazards Analysis and Fire Protection Program (incorporated by reference into the FSAR). FHA Section 9.0, Appendix A Compliance Matrix, stated the licensee complied with the applicable sections of BTP APCSB 9.5-1. The General Guideline for Plant Protection section stated that the NFPA 80, Fire Doors and Windows was applicable for fire doors. Contrary to the above, the team identified two instances that were not consistent with the stated commitments. The licensee documented this issue with condition reports CR10085883, CR 10135493, CR 10144100, and CR10022283. The team reviewed the DID and the fire confinement provisions of NFPA 805 as referenced by Sections A.4.4.6.4 and 7.3.7. In addition, Section 5.11.3.1, which states in part that passive fire protection devices such as doors and dampers shall conform to the following NFPA standards, as applicable unless otherwise permitted by 5.11.3.2. Because Hatch committed to adopt NFPA 805 and the aforementioned issues meet the criteria as stated in the NRC Enforcement Policy (Policy), Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), the NRC will disposition the violations in accordance with the Policy and grant enforcement discretion. The NRC will also disposition the associated findings in accordance with Inspection Manual Chapter 0305, Section 11.05, Treatment of Items Associated with Enforcement Discretion.
05000369/FIN-2015008-012015Q4Mcguire
McGuire		Failure to Completely and Accurately Translate the Safe Shutdown Analysis to ProceduresThe NRC identified a Green non-cited violation (NCV) of McGuire Technical Specification 5.4.1.a, for Unit 1, for having an inadequate procedure to support safe shutdown for a fire in fire area (FA) 15/17. Specifically, the licensees deterministic safe shutdown analysis identified the need for a procedural action to de-energize PORV 1NC- 34A at power supply 1EVDA, breaker 8. This action was not translated to Enclosure 15 of McGuire fire safe shutdown procedure AP-45. This item was entered into the corrective action program (CAP) as action requests (ARs) 1979875 and 1983360, and the licensee initiated a procedure change to incorporate the missing action. The performance deficiency (PD) was more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of protection against external factors (i.e. fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the guidance of IMC 0609, App. F, the finding was screened as Green because the finding did not affect the ability to reach and maintain a stable plant condition within the first 24 hours of a fire event (Task 1.4.5-B). No cross cutting aspect was assigned because the finding did not represent current licensee performance.
05000280/FIN-2015008-042015Q2SurryMultiple Design Deficiencies in the Fire Protection ProgramThe inspectors identified a Green NCV of Surrys Operating License, Condition 3.I, Fire Protection, for design control deficiencies in the fire protection program. The licensee entered this issue into their corrective action program as condition report CRs 581390. The licensees failure to adequately implement the design control requirements in the fire protection program as required by Topical Report, DOM-QA-1, Dominion Nuclear Facility Quality Assurance Program Description, Section 3.2, Design Control Program was a performance deficiency. The finding was more than minor because it was associated with the design control attribute and affected the Mitigating Systems cornerstone. Specifically, design control deficiencies resulted in a lack of assurance that the design control requirements were being adequately implemented within the fire protection program. The finding was screened in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined to be of low safety significance (Green) because it finding did not affect the ability to reach and maintain a stable plant condition within the first 24 hours of a fire event. No cross cutting aspect was assigned because the performance deficiency did not occur within the last three years.
05000280/FIN-2015008-022015Q2SurryFailure to Implement In-service Testing and Inservice Inspections for Charging Cross-tie ComponentsThe inspectors identified a Green NCV of 10 CFR 50.55(a) for the licensees failure to implement in-service testing (IST) and in-service inspections (ISI) for charging cross-tie components. The licensee entered this issue into their corrective action program as CRs 581385 and 581386. The licensee failed to scope the charging cross-tie manual isolation valves and piping into the ISI and IST programs. This was a performance deficiency that resulted in the subsequent failure to perform ISI and IST activities required by the ASME OM Code-2004 and 10 CFR 50.55a(f) and (g). The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone. Specifically, the sites failure to perform required inspections and testing for charging cross-tie components, since 1989, resulted in a lack of reasonable assurance that the charging cross-tie function could perform its required function. The finding was screened in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined to be of low safety significance (Green) because it did not affect the ability to reach and maintain a stable plant condition within the first 24 hours of a fire event. No cross cutting aspect was assigned because the performance deficiency did not occur within the last three years.
05000280/FIN-2015008-012015Q2SurryFailure to Ensure a Functional Alternate Shutdown System Alignment during Appendix R Fire Events EventsThe inspectors identified a Green non-cited violation (NCV) of Surrys Operating License, Condition 3.I, Fire Protection, for the licensees failure to ensure a functional alternate safe shutdown flow path during an Appendix R fire. The licensee entered this issue into their corrective action program as condition report (CR) 580928. The licensees failure to ensure a functional alternate shutdown system alignment during an Appendix R fire event was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone. Specifically, Surry failed to implement appropriate corrective actions to mitigate the spurious closure and subsequent damage of more than one motor operated valve as identified in an engineering evaluation. The failure to re-open credited Appendix R MOV(s) would result in the loss of secondary heat removal and/or RCS make-up capability during Appendix R fire events. The finding was screened in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined to be of low safety significance (Green). A Region II senior risk analyst performed a bounding phase 3 analysis that determined the finding represented an increase in core damage frequency of < 1 E-6 /year. No cross cutting aspect was assigned because the performance deficiency did not occur within the last three years.
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.
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.
05000280/FIN-2015008-032015Q2SurryFailure to Perform Required 50.59 Evaluations and Failure to Update the UFSAR for Plant Changes Associated with RCP Seal Cooling During Fire EventsThe inspectors identified a Green NCV of 10 CFR 50.59 and 10 CFR 50.71(e) for the licensees failure to perform 50.59 evaluations; and failure to update the UFSAR for plant changes associated with reactor coolant pump (RCP) seal cooling during fire events. The licensee entered this issue into their corrective action program as condition report CRs 5813388. The licensees revision of fire safe shut down procedures; and the installation of a different reactor coolant pump seal package without completing the required 50.59 evaluations was a performance deficiency. Additionally, the licensees failure to update the UFSAR as required by 10 CFR 50.71(e) was a performance deficiency. The UFSAR did not adequately describe the charging cross-tie function; and did not adequately describe the fire protection programs procedural isolation of the RCP seals for the entire duration of an Appendix R event. In accordance with the Reactor Oversight Process, the performance deficiencies were more than minor because they were associated with the design control attribute of the Mitigating Systems Cornerstone. The performance deficiencies were also assessed using traditional enforcement because the NRCs ability to perform its regulatory function such as, license amendment reviews and inspections was affected. The finding was screened in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined to be of low safety significance (Green) because it did not affect the ability to reach and maintain a stable plant condition within the first 24 hours of a fire event. No cross cutting aspect was assigned because these performance deficiencies did not occur within the last three years.
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