05000395/FIN-2016001-01
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Finding | |
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| Title | Failure to Implement Adequate Administrative Controls Following a Departure from NFPA 80-1973 and Provide NRC Staff Complete and Accurate Information |
| Description | The inspectors identified a Severity Level IV, non-cited violation (NCV) of 10 CFR 50.9(a), Completeness and accuracy of information, and an associated Green non-cited violation of V.C. Summer, Operating License Condition 2.C.(18) for a NFPA 80-1973 code deviation that was not discussed in the licensees NFPA 805 license amendment request (LAR), and would adversely affect the ability to achieve and maintain safe shutdown in the event of fire. The associated engineering evaluation relied on inadequate administrative controls to ensure the associated replacement doors in the intermediate building, DRIB/105A&B, were kept closed as a basis for not following NFPA 80-1973 which required the fire doors be self-closing. The licensee entered the violations into their corrective action program as condition reports CR-15-04027 and CR-16-00242 respectively. The inspectors identified a reactor oversight process (ROP) performance deficiency (PD) for the failure to provide adequate administrative controls to allow departure from NFPA 80-1973 requirements, which resulted in replacement of a self-closing fire door with two non-self-closing fire doors, DRIB/105A&B, that adversely affected the ability to achieve and maintain safe shutdown in the event of fire since they were found open on multiple occasions. The inspectors reviewed Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, dated September 7, 2012, and determined the ROP PD was more than minor because it was associated with the mitigating systems cornerstone attribute of protection against external factors, such as fire, and adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors used IMC 0609, Significant Determination Process, Appendix F, Fire Protection Significance Determination Process, Attachment 1, dated September 20, 2013, to perform a Phase 1 analysis and determined that the ROP finding was of very low safety significance (Green) based on the response for Question 1.4.3.A in which the combustible loading on both sides of DRIB/105A&B was less than 120,000 BTU/ft2. Furthermore, the inspectors determined that the associated fire zone area (IB 7) with multiple equipment trains used a pre-action sprinkler system and automatic fire detection. The inspectors also determined that the licensees failure to include the departure from NFPA 80-1973 in their NFPA 805 license amendment request was a violation of 10 CFR 50.9(a). Because this violation of 10 CFR 50.9(a) had the potential to impact the NRCs ability to perform its regulatory function, the inspectors evaluated this violation using traditional enforcement (TE). Since the TE violation is associated with a Green ROP violation, and the misinformation was identified after the NRC relied on it for issuing a previous operating license amendment, the TE violation was determined to be a Severity Level IV violation, consistent with the language of the NRC Enforcement Policy, Section 2.3.11, Inaccurate and Incomplete Information. The inspectors reviewed IMC 0310, Aspects Within Cross Cutting Areas, dated December 14, 2014, and determined the cause of this finding involved the cross-cutting area of problem identification and resolution, P.3, because the licensee failed to ensure that adequate administrative controls were in place after the fire doors were found open multiple times. |
| Site: | Summer  |
|---|---|
| Report | IR 05000395/2016001 Section 4OA5 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Adams E Coffman J Reece M Franke R Fanner |
| Violation of: | 10 CFR 50.9 License Condition - Fire Protection License Condition |
| CCA | P.3, Resolution |
| INPO aspect | PI.3 |
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Finding - Summer - IR 05000395/2016001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Summer) @ 2016Q1
Self-Identified List (Summer)
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