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The inspectors identified a noncited viola … The inspectors identified a noncited violation of Facility Operating License Condition 2.C(41), involving the failure to ensure that manholes MH01, MH20 and MH21 were properly sealed to prevent the entry of flammable liquid. During the performance of the manhole/vault inspection, the inspectors were reviewing engineering change packages associated with solar sump pumps for MH20 and MH21. During their review, they determined that the licensee was not meeting the requirements of their license bases documents for MH20 and MH21, which contain safe shutdown cables for standby service water trains A and B. The licensees immediate corrective action included placing hazmat barricades around each manhole to prevent flammable fluids from entering the manholes. This issue was entered into the licensees corrective action program as Condition Report CR-GGN-2011-00562. This finding was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 3b, Item 1 directs the inspectors to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process. However, an NRC senior reactor analyst determined that the unique nature of this performance deficiency did not lend itself to analysis by the methods provided in Appendix F. Therefore, a Phase 3 analysis was performed. Based on a bounding analysis, the analyst determined that the change in core damage frequency was approximately 1.5E-7/yr. The result was low because of the relatively short periods of time that fuel was actually being transferred, the low probability of transfer system failures, and the low likelihood that a loss of normal service water initiator would occur following a fire in the subject manholes. This noncited violation was therefore determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of problem identification and resolution associated with corrective actions because licensee personnel failed to initiate a condition report when the issue was identified during the development of their engineering change package, which resulted in the failure to ensure the safety related manholes were sealed in accordance with their license based documents.rdance with their license based documents.

Discovered date

23:59:59, 30 June 2011 +

Docket

05000416 +

Event date

23:59:59, 30 June 2011 +

Finding integer

4 +

Finding type

Non-cited violation +

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INPO aspect

PI.1 +

Identified by

NRC identified +

Inspection Manual Chapter

NRC Inspection Manual 0609.04 + and NRC Inspection Manual 0609/Appendix F +

Inspection procedure

IP 71111.06 +

Inspection report

IR 05000416/2011003 +

Inspector

Vincent Gaddy +, James Drake +, E Uribe +, M Baquera +, A Fairbanks +, B Rice +, Jonathan Braisted +, Rich Smith + and Rayo Kumana +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

19:05:20, 30 September 2017 +

Person