05000366/FIN-2013009-03
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Finding | |
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| Title | Review and Documentation of Fire Protection Program Changes |
| Description | Introduction: The NRC identified a non-compliance of Hatch Unit 2 Renewed OLC 2.C.(3)(a), Fire Protection, for making a change to the FPP that adversely affected the licensees ability to achieve and maintain safe shutdown. Specifically, the licensee removed the installed Unit 2 RSDP halon suppression system that was required to meet an approved exemption. The licensee failed to submit the FPP change to the NRC for review and approval prior to implementing the modification, which impacted the ability of the NRC to perform its regulatory oversight function. Description: In an SER dated April 18, 1984, the NRC allowed an exemption request from 10 CFR 50, Appendix R, Section III.G.2 for the Unit 2 Reactor Building elevation 130. In this SER, the NRC documented that the licensee committed to several modifications, which included the installation of an automatic halon fire suppression system for the Unit 2 RSDP. The halon suppression system would limit the consequences of a fire internal to the RSDP. The NRC concluded that the existing fire protection measures, with the proposed modifications, would achieve a level of safety equivalent to that provided by 10 CFR 50, Appendix R, Section III.G.2. During a plant walkdown of FA 2203 to support the review of LER 2013-004, the team noted that the halon suppression system had been abandoned in place. Discussions with the licensee revealed that the system had been abandoned since 1999. Additionally, in 2006, the licensee initiated a design change (DCP 2009001901) to completely remove the halon system, along with its associated piping and support, from the Unit 2 RSDP. The team noted that the licensees FPP is based on the defense-in-depth concept, and that this approach includes promptly detecting and extinguishing fires that occur. The condition of not having the committed suppression system was a degradation of the defense-in-depth concept. Specifically, the lack of a suppression system would adversely affect the ability to control and promptly extinguish a fire. The licensee entered the deficiency into their CAP as CR 736483. An hourly fire watch was already in place for the affected FA, because of LER 2013-004. Analysis: The team determined that the failure to obtain NRC approval prior to making a change to the FPP that was adverse to safe shutdown was a performance deficiency. This performance deficiency was determined to be more than minor because it was associated with the reactor safety Mitigating Systems cornerstone attribute of protection 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. Specifically, the licensee removed the halon suppression system for the RSDP, which degraded the ability to suppress a fire that originated in the panel. The finding was screened in accordance with IMC 0609, Significance Determination Process (SDP), Attachment 4, Initial Characterization of Findings, dated June 19, 2012, which determined that an IMC 0609 Appendix F, Fire Protection Significance Determination Process review was required because the finding affected fixed fire protection systems. Using the Fire Protection SDP Phase 1 Screening, the finding was assigned a category of Fixed Fire Protection Systems. The team used step 1.3 Ability to Achieve Safe Shutdown, task 1.3.1 Screen Fire Finding for Ability to Achieve Safe Shutdown, of IMC 0609, Appendix F, Attachment 1 to determine the finding to be of very low safety significance (i.e., Green) because the reactor would have been able to reach and maintain safe shutdown conditions. The reactor would be able to reach and maintain safe shutdown conditions because photoelectric detectors were installed inside the RSDP and linear heat detection was installed along the sides of the cable raceways located directly above the RSDP. The installed detectors would aid in preventing the growth and spread of a fire by allowing sufficient time for the fire brigade to intervene. The team determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. Additionally, the licensees failure to submit the adverse FPP change to the NRC for review was screened under the traditional enforcement criteria, because it impacted the ability of the NRC to perform its regulatory oversight function. In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation was characterized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance (Green). Enforcement: Hatch Unit 2 Renewed OLC 2.C.(3)(a) states, in part, that the licensee may make changes to the fire protection program without prior Commission approval only if the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. This license condition also states that the Hatch Fire Protection Program is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program for the Edwin I. Hatch Nuclear Plant Units 1 and 2, which was originally submitted by letter from GPC to the Commission dated July 22, 1986. Contrary to the above the licensee made a change to the FPP, without prior Commission approval, that adversely affected the ability to achieve and maintain SSD in the event of a fire. Specifically the licensee completed a 10 CFR 50.59 evaluation that erroneously concluded that the halon suppression system installed for the RSDP was not required to meet Appendix R requirements and, therefore, could be removed without prior Commission approval. The removal of the halon suppression system degraded the ability to suppress a fire and challenged the ability to achieve and maintain SSD in the event of a fire. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and reactor oversight process (ROP) discretion for this issue in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48), and Inspection Manual Chapter 0305. Specifically, this issue was identified and will be addressed during the licensees transition to NFPA 805, was entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, was not likely to have been previously identified by routine licensee efforts, was not willful, and it was not associated with a finding of high safety significance (i.e., Red). |
| Site: | Hatch  |
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| Report | IR 05000366/2013009 Section 1R05 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | Violation: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | J Montgomery M Thomas O Lopez P Braxton S Shaeffer W Monk |
| Violation of: | 10 CFR 50 Appendix R 10 CFR 50.48 10 CFR 50.59 License Condition - Fire Protection |
| INPO aspect | |
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Finding - Hatch - IR 05000366/2013009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hatch) @ 2013Q4
Self-Identified List (Hatch)
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