The inspectors identified a noncited violation for failure to expeditiously return to service a manual isolation valve for fire protection water to containment as required by the
fire protection program as defined in Unit 2 License Condition 2.G. This resulted in the Unit 2 containment fire hose stations to be out-of-service for thirteen additional days during a refueling outage following maintenance. The valve was closed in order to perform leak rate testing of the containment penetration, however, after the test was complete, the valve was left closed. The licensee entered the finding into their corrective action program for resolution. This finding is greater than minor because it was similar to Example 4.g in NRC
Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues and met the not minor if criteria because certain postulated fires would have restricted operator access to the valve for environmental reasons. Using NRC
Inspection Manual Chapter 0609, Attachment 4, Phase 1 Initial Characterization and Screening of Findings, the inspectors determined that this finding should be evaluated using NRC
Inspection Manual Chapter 0609, Appendix F, Fire Protection
Significance Determination Process, because it affects fire protection defense-in-depth strategies involving manual suppression equipment. However, Appendix F, Assumptions and Limitations states that the fire protection
significance determination process does not address the potential risk significance of fire protection inspection findings for shut down reactors. Therefore, the significance of this finding was assessed using Manual Chapter 0609, Appendix M,
Significance Determination Process Using Qualitative Criteria. The finding is of very low safety significance because there were a limited number of postulated fires that could affect
shutdown cooling, a single fire could not credibly affect both
residual heat removal system loops, and a postulated fire could not have formed a hot-gas layer affecting the equipment. The cause of the finding is related to the human performance cross-cutting component of work control, in that, the licensee did not appropriately coordinate work activities both because of lack of communication and a failure to plan work activities to limit fire protection system unavailability
H3.b