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The team identified a non-cited violation … The team identified a non-cited violation of License Conditions 2.C.(8), Fire Protection, for Unit 1; License Condition 2.C.(3)(b), Fire Protection, for Unit 2; and the technical requirements manuals because the licensee did not properly test all portions of the underground fire piping. Specifically, the licensee did not determine the flow rates through two headers that provided water to the ring header supplying the Unit 2 auxiliary building as designed. The licensee entered this violation into their corrective action program as Condition Report CR-ANO-C-2016-02613 and initiated actions to conduct a flow test of the headers. The failure to implement an adequate procedure to test underground fire piping was a performance deficiency. Specifically, the licensee did not test two headers included and designed as part of their underground fire piping to demonstrate that no faults had occurred. This performance deficiency was more than minor because it was associated with the protection against external factors attribute (fire) and adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to test two underground fire piping headers failed to demonstrate the capability to deliver adequate flow and pressure to the fire suppression systems as designed. The finding was screened in accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Because the finding affected fixed fire protection systems or the ability to confine a fire, the team reviewed the finding using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013. The finding was screened as a Green finding of very low safety significance in accordance with Task 1.4.7, Fire Water Supply, Question A. Although the licensee failed to test all portions of the underground fire piping in accordance with their license and technical requirements manual, the team determined that at least 50 percent of required fire water capacity would be available based on the testing that is done. As a result, the finding was determined to be of very low safety significance (Green). The team determined that this finding did not have a cross-cutting aspect since it did not reflect current performance. Specifically, the licensee had not flow tested all underground fire piping headers since initial installation.piping headers since initial installation.

Discovered date

23:59:59, 30 June 2016 +

Docket

05000313 + and 05000368 +

Event date

23:59:59, 30 June 2016 +

Finding integer

1 +

Finding type

Non-cited violation +

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Identified by

NRC identified +

Inspection Manual Chapter

NRC Inspection Manual 0609 + and NRC Inspection Manual 0609/Appendix F +

Inspection procedure

IP 71111.05 +

Inspection report

IR 05000313/2016009 +

Inspector

Greg Pick +, Rick Deese +, Greg Werner +, H Barrett +, J Mateychick +, Shiattin Makor +, Nnaerika Okonkwo + and Steven Alferink +

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12:56:40, 25 September 2017 +

Person