05000456/FIN-2012002-01
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Finding | |
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| Title | Failure to Maintain Approved Fire Protection Program Regarding Safe Shutdown Fire Damper Qualification |
| Description | The inspectors identified a finding of very low safety significance and an associated NCV of License Condition 2.E when licensee personnel failed to adequately maintain the approved fire protection program after receiving information that adversely affected the qualification of fire dampers credited in the safe shutdown analysis. Specifically, the licensee inadvertently removed an action to secure ventilation upon the confirmation of a fire following a revision to the stations Pre-Fire Plans in 2010. This action was established after the licensee received NRC Information Notice (IN) 89-52, Potential Fire Damper Operational Problems, which notified the licensee that these dampers were not qualified to shut with air flow through them. A significant contributor to this error was a failure of the licensee to adequately incorporate this action into the appropriate procedures and clearly document this requirement and basis for this requirement into the approved fire protection program. The licensee entered this issue into their corrective action program (CAP) as IR 1309949. Corrective actions included the implementation of Operations Standing Order 11-027 requiring manual operator action until a procedure change to the Fire Hazardous Materials Spill and/or Injury procedure (BwAP 1100-16), and Fire Response Guidelines (BwOP FP-100) was performed. Additionally, the licensee created an assignment to provide training to the fire brigade leaders for these planned procedure revisions. The finding was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to ensure that ventilation systems were secured upon the confirmation of a fire could affect the ability of fire dampers to shut and perform their safety function. The inspectors evaluated this finding using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase I - Initial Screening and Characterization of Findings, Table 3b for the Mitigating Systems Cornerstone, which directed this finding be reviewed using IMC 0609, Appendix F, Fire Protection Significance Determination Process, since the finding affected fire barriers. The inspectors assigned this issue a low degradation rating based upon the high likelihood that ventilation would be secured upon the onset of a fire due to numerous ionization detectors that automatically trip ventilation systems upon the detection of smoke. Based on this assigned rating, the inspectors determined that this finding was of very low safety significance (Green). The inspectors determined that the most significant causal factor related to this finding was a failure to adequately incorporate the requirement into the current licensing basis (CLB) in 1989, and therefore this finding was not indicative of current performance and a cross-cutting aspect was not assigned. |
| Site: | Braidwood  |
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| Report | IR 05000456/2012002 Section 1R05 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | A Garmoe B Jose E Duncan J Benjamin J Gilliam M Holmberg M Perry |
| INPO aspect | |
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Finding - Braidwood - IR 05000456/2012002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Braidwood) @ 2012Q1
Self-Identified List (Braidwood)
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