The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the
NRC Enforcement Policy for being dispositioned as an
NCV. Appendix R,
Section III.G.3 requires, in part, that an alternative dedicated shutdown capability and its associated circuits, independent of cables, systems, or components in the area, room, or zone under consideration should be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section. Compliance with
10 CFR Part 50, Appendix R, Section III.L is considered necessary to satisfy the requirements of
10 CFR Part 50, Appendix R, Section III.G.
Section III.L of
10 CFR Part 50, Appendix R, requires implementation of an alternative dedicated shutdown capability as required by Section III.G.3 of
10 CFR Part 50, Appendix R.
Section III.L.3 of
10 CFR Part 50, Appendix R, states, in part, that alternative shutdown capability shall be independent of the specific fire area and that procedures shall be in effect to implement this capability. Contrary to the above, from October 15, 2003, until present, the licensee failed to maintain in effect all provisions of
10 CFR Part 50, Appendix R, Section III.G.3 and Section III.L. Specifically, the licensee failed to ensure that systems that were required for alternative shutdown capability were not free of fire effects, therefore, were not independent of the specific fire area. The licensee credits the
HPCI system as the alternative to the isolation condenser for hot shutdown. Licensee procedures DSSP 0100C, Hot Shutdown Procedure Path C Revision 27 and DSSP 0100D, Hot Shutdown Procedure Path D Revision 26, inappropriately direct operators to lift
leads and install electrical jumpers in order to defeat
HPCI suction transfer from the condensate storage tank (
CST) to the torus on low
CST level or high torus level. Installation of jumpers and lifting
leads is considered a repair and is not permissible for systems required to achieve safe hot shutdown. In accordance with
Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (
SDP), Attachment 0609.04, Initial Characterization of Findings, Table 2 the inspectors determined the finding affected the
Mitigating Systems cornerstone. The finding degraded fire protection defense-in-depth strategies, and the inspectors determined, using Table 3, that it could be evaluated using Appendix F, Fire Protection
SDP. The inspectors determined that the finding impacted the ability to achieve
safe shutdown and, assigned the finding to the category of 1.4.5 Post-fire
Safe Shutdown using Table 1 in
IMC 0609, Appendix F, Attachment 1, Part 1: Fire Protection
SDP Phase 1 Worksheet, dated September 20, 2013. The inspectors answered no to Question 1.4.5B, Does the fire finding affect the ability to reach and maintain a stable plant condition within the first
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a fire event? in Task 1.4.5 of
IMC 0609, Appendix F. The repair actions already in place in procedures DSSP 0100C and DSSP 0100D, while not allowed by Appendix R, were determined to be a viable compensatory measure that would allow the plant to reach and maintain a stable hot shutdown condition. Therefore, the inspectors determined that the finding screened as having very low safety significance (Green). This issue was entered into the licensees
CAP as
IR 2651479.
