05000445/FIN-2017008-01
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Finding | |
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| Title | Failure to Implement and Maintain Adequate Inspection Procedures for Penetration Sealing Devices |
| Description | Green. The team identified a non-cited violation of Operating License Condition 2.G related to the licensees failure to maintain adequate procedures for the inspection of required penetration sealing devices as required by the licensees Fire Protection Report, Section IV-2.1.c.1. Specifically, the Fire Protection Report required, in part, that fire-rated assemblies and penetration sealing devices be confirmed operable by visually inspecting the exposed surfaces using a site approved sampling plan every 18 months. Fire Protection Manual Procedure FIR-310, Penetration Seal Inspection, Revision 3, did not appropriately capture all penetration sealing devices for inspection. In 2009, guidance was added to the procedure restricting inspections to equipment accessible from the floor (8 feet or below). Also, the licensees automated random sampling process did not ensure that all penetration seal s would be inspected within the licensees 15-year sampling plan interval. The licensee entered these issues into their corrective action program as Condition Reports CR-2017-007745 and CR-2017-007746 to revise the surveillance procedure and sampling plan to ensure all required penetration seals were included and inspected within the 15-year sampling plan interval. The failure to ensure that fire protection program procedures used to establish inspection criteria for penetration sealing devices appropriately captured all required penetration sealing devices for visual inspection using a site approved sampling plan every 18 months was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of prot ection against external factors (i.e., fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated October 7, 2016, the finding was determined to require additional evaluation under Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 30, 2013. The finding was screened as a Green finding of very low safety significance in accordance with Task 1.4.3, Fire Confinement, Question B. Based on the analysis performed, the team concluded that the degradation of the fire barrier penetration seals represented a low 3 degradation of the fire confinement element. No inspected barriers were identified as degraded, and all inspected barriers provided at least a 1-hour or greater fire endurance rating. The team did not assign a cross-cutting aspect because the performance deficiency was not reflective of present performance in that the inspection procedure changes occurred in 2009. |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2017008 Section 1R05 |
| Date counted | Jun 30, 2017 (2017Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | S Alferink J Watkins |
| Violation of: | License Condition - Fire Protection |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2017008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2017Q2
Self-Identified List (Comanche Peak)
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