The inspectors identified a Green non-cited violation (
NCV) of license condition
DPR-50 section 2.C.(4), Fire Protection, for Exelons failure to maintain
transient combustible loading within fire loading limits near the B condensate storage tank (
CST). Specifically, on January 9, the inspectors identified a Portable On-Demand storage (
POD) container staged within 50 feet of the B
CST. The
POD and its contents contained
transient combustible materials in excess of the allowed fire loading in accordance with the fire hazards analysis report (FHAR). Exelon promptly removed the
POD container and restored
transient combustible loading within allowable limits. Exelon entered this issue into their corrective action program under
issue report (IR) 1461029. Corrective actions included additional postings around the safety-related above-ground tanks, site-wide notifications and the performance of a root cause evaluation to address recent station fire protection issues. This performance deficiency is more than minor because it is associated with the Protection Against External Factors (Fire) attribute and adversely affected the
Mitigating Systems cornerstone objective to ensure availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. In addition, it was determined to be more than minor since it is similar to more than minor example 4.k of
IMC 0612, Power Reactor Inspection Reports, Appendix E because the fire loading was not within the FHAR limits. In accordance with
IMC 0609.04, Phase 1 Initial Screen and Characterization of Findings, the inspectors determined the finding affected the administrative controls for
transient combustible materials. Therefore, the inspectors conducted a phase 1
SDP screening using
IMC 0609, Appendix F, Fire Protection
Significance Determination Process, and the inspectors determined that the finding affected the category of Fire Prevention and Administrative Controls in that combustible material was not being properly controlled, the finding had a low degradation rating, and the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon failed to thoroughly evaluate and take appropriate corrective actions for similar
transient combustible loading issues such that the cause and extent of condition were fully addressed.
