The NRC identified a non-cited violation of
Technical Specification 5.4.1.d,
Fire Protection Program, for the licensees failure to adequately implement Limiting Conditions For Operation in accordance with Fire Protection Report Volume 1, Fire Protection Plan. Specifically, the licensee failed to adequately implement impaired
fire barrier and detector controls which resulted in the failure to establish a
continuous fire watch for an impaired
fire barrier having smoke detection identified as unavailable to protect either side of the
inoperable barrier. The licensee subsequently returned the impaired fire door and smoke detection to service. The licensee entered this event into their corrective action program as PERs 529543 and 527311. The finding was determined to be more than minor because it was associated with the
Mitigating Systems cornerstone attribute of Protection Against External Events, and adversely affected the cornerstone objective to ensure the availability of systems that respond to
initiating events to prevent undesirable consequences (i.e. core damage). Specifically, inadequate implementation of the licensees FPIP and LCO processes resulted in the licensee missing a LCO entry condition and not establishing a
continuous fire watch for an impaired fire door. The significance of this finding was evaluated in accordance with the
IMC 0609 Appendix F, Attachment 01, Part 1, Fire Protection
SDP Phase 1 Worksheet. The finding was determined to be of very low safety significance (Green) because the condition represented a low degradation of fire prevention and administrative controls. Specifically, a smoke detection system on one side of the impaired fire door was discovered functional. The cause of this finding was directly related to the cross cutting aspect of Procedural Compliance in the Work Practices component of the Human Performance area, because licensee expectations were ineffectively communicated and fire protection procedures inadequately implemented to maintain a site understanding of
fire barrier and detector configuration
