The team identified a noncited violation of License Condition 2.C.(5), Fire Protection (Section 9.5.1,
SER; Section 9.5.1.8, SSER #5), for failure to ensure that redundant trains of
safe shutdown systems in the same fire area were free of fire damage. The licensee credited manual actions to mitigate the effects of fire damage in lieu of providing the
physical protection required by
10 CFR Part 50, Appendix R, Section III.G.2
SNUPPS FSAR Appendix 9.5E provided the design comparison between the plants fire protection program and 10 CFR Part 50, Appendix R. The comparison to Section III.G, Fire Protection of Safe Shutdown Capability, states, Redundant trains of systems required to achieve and maintain hot standby are separated by 3-hour-rated fire barriers, or the equivalent provided by III.G.2, or else a diverse means of providing the safe shutdown capability exists that is unaffected by the fire. Wolf Creek has interpreted diverse means as by any reasonable means including local valve and breaker operations as long as they are within the scope of normal operator duties. The team disagrees with this interpretation. The NRC staff does not recognize the use of manual actions as meeting the technical requirements of Appendix R,Section III.G.2. The components being operated are identified as required for operation of safe shutdown systems or are subject to potential spurious operation impacting the shutdown. The local manual actions are being performed because of fire damage to electrical cables related to those components and are meant to compensate for damage or maloperation of safe shutdown equipment caused by fire
This finding is greater than minor because it impacted the
mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences (i.e., core damage). The team found that the
manual operator actions implemented to mitigate the effects of fire damage were reasonable (as defined in Enclosure 2 of NRC
Inspection Procedure 71111.05T, Fire Protection (Triennial)), and could be performed within the analyzed time limits. Therefore, in accordance with Enclosure 2 of NRC
Inspection Procedure 71111.05T, the finding was determined to be of very low safety significance (Green), and the
significance determination process was not entered.
