The team identified a noncited violation of License Condition 2.C.(10), Fire Protection, related to the licensee's failure to implement and maintain in effect all provisions of the approved
fire protection program. Specifically, during testing required by the approved
fire protection program the licensee failed to adequately test the
remote shutdown emergency transfer switch functions used to assure isolation of
safe shutdown equipment from the control room in the event of a control room evacuation due to fire. The switch functions had not been adequately tested since 1997. The failure to ensure isolation from the control room for
safe shutdown equipment controlled from the
remote shutdown panel during surveillance testing of emergency transfer switches is a performance deficiency. The finding was more than minor because it was associated with the procedure quality attribute of the
Mitigating Systems Cornerstone in that it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The team evaluated the finding using
Inspection Manual Chapter 0609, Appendix F, Fire Protection
Significance Determination Process, because it affected fire protection defense-in-depth strategies involving post fire
safe shutdown. Using Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various
Fire Protection Program Elements, the team determined that the finding constituted a low degradation of the
safe shutdown area since the control room isolation feature was expected to display nearly the same level of effectiveness and reliability as it would had the degradation not been present. This finding screened as having very low safety significance (Green). This violation was entered into the licensees corrective action program as
CR-RBS-2010-01783. Because the emergency transfer switch surveillance procedures had been in effect since 1997, there was no crosscutting aspect associated with the violation, in that it is not indicative of current licensee performance.
