License Condition 2.C(10), "Fire Protection," requires the licensee to "...comply with the requirements of the
fire protection program as specified in Attachment 4 (of the license)." Provision 1 of Attachment 4 states in part: "
EOI shall implement and maintain in effect all provisions of the approved
fire protection program as described in the Final Safety Analysis Report for the facility through Amendment 22 and as approved in the
SER dated May 1984 and Supplement 3 dated August 1985 subject to provisions 2 and 3." Section 9.5.1 of the
Updated Final Safety Analysis Report (
UFSAR), "Fire Protection System," Subsection 9.5.1.4., "Inspection and Testing Requirements," states that "Periodic operational checks, inspections, and servicing required to maintain fire protection systems that protect equipment that is important to safety, including the alarm and detection systems, conform with the
RBS Technical Requirements Manual." Technical Requirements Manual, Section
TRM 3.7.9.2, Action A.2, states that if "One or more of the...required spray or sprinkler systems (are)
inoperable," the licensee would be required to "Establish a
continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged," and "Establish an
hourly fire watch patrol for other areas," within a completion time requirement of one hour. Contrary to the above, on May 20, 2014, the licensee failed to establish fire watches within the one hour requirement, specified in
TRM 3.7.9.2., after it was determined that the fire protection ring
header was
inoperable. The failure to adhere to the requirements of
TRM 3.7.9.2 action A.2, to ensure that all required hourly fire watches are posted within one hour from the time of entry into the
TRM, is a performance deficiency. The performance deficiency was more than minor and, therefore, a finding because it adversely impacted the protection against external factors attribute of the Mitigating System Cornerstone, in that the failure to post fire watches, in a timely manner, could result in preventing prompt detection and extinguishing of fires. Using NRC
Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," dated June 19, 2012, the inspectors determined that the issue affected the
Mitigating Systems Cornerstone and that the finding pertained to a degraded condition while the plant was in operation. As a result, the inspectors were directed to
Inspection Manual Chapter 0609, Appendix F, "Fire Protection
Significance Determination Process," dated September 20, 2013. Since the finding affected many fire areas, the inspector consulted with a senior reactor analyst. The analyst determined that Appendix F was not a suitable tool to process this finding, and that a detailed risk evaluation needed to be performed. Although the exposure period for this finding was just a few hours, the risk analyst determined that the detailed risk evaluation performed for the finding described above (Section 4OA2.3.b.) fully bounded this finding as well. As a result of the referenced evaluation, the finding was found to be of very low safety significance (Green). The dominant core damage sequences included a fire-induced loss of offsite power, failure of operators to suppress the fire, and damage to Division I, II, and III components. The
reactor core isolation cooling system and the short exposure period helped to minimize the risk. This violation is being treated as a non-cited violation (
NCV), consistent with Section 2.3.2.a of the
Enforcement Policy because it was of very low safety significance (Green) and it was entered into the licensee's corrective action program as Condition Report
CR-RBS-2014-02489 to address recurrence.
