License Conditions 2.C.(5) for Unit 1 and 2.C.(4) for Unit 2 state, in part, that the licensee shall implement and maintain all provisions of the approved
fire protection program that comply with
10 CFR 50.48(a) and
10 CFR 50.48(c), as specified in the license amendment request, dated June 26, 2013, and as approved in the safety evaluation, dated April 14, 2016. Section 3.2.3 of Attachment A of the license amendment request states, in part: Procedures shall be established for implementation of the
fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established: Inspection, testing, and maintenance for fire protection systems and features credited by the
fire protection program. Equipment Control Guideline 18.1, Fire Suppression Systems/Fire Suppression Water Systems, provided the requirements to demonstrate the operability of the fire suppression water system. Equipment Control Guideline Surveillance Requirement 18.1.10 required the licensee to perform a flow test of the fire suppression water system in accordance with Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition. Chapter 5, Section 11, of the Fire Protection Handbook, 14th Edition, stated, in part, that tests should be conducted in such a way that the available flow and pressure at high value or hazardous areas can be determined readily. Contrary to the above, prior to October 20, 2016, the licensee failed to implement all provisions of the approved
fire protection program. Specifically, during the flow tests, the licensee failed to establish surveillance test procedures that measured pressure values for one of the three fire suppression water subsystems using the methodology in Chapter 5, Section 11 of the Fire Protection Handbook, 14th Edition. The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the
Mitigating Systems Cornerstone and adversely affected the
Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The finding was screened in accordance with
Inspection Manual Chapter 0609, Appendix F, dated September 20, 2013. The finding was determined to be of very low safety significance (Green) in Task 1.4.7, Fire Water Supply, Question A. Although the licensee did not measure and record fire main pressure, they did measure flow and it was greater than 50 percent of the required capacity. The finding was entered into the licensees corrective action program as Notifications NN 50853684 and NN 50863322.
