05000255/FIN-2011004-07
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Finding | |
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| Title | Incorrect Instructions to Operators in Appendix R, Post-Fire Alternate Safe Shutdown Procedure |
| Description | Title 10 CFR 50.48(b)(2) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III.G, III.J, and III.O. Compliance with 10 CFR Part 50, Appendix R, Section III.L is considered necessary in order to satisfy the requirements of 10 CFR Part 50, Appendix R, Section III.G.Section III.L of 10 CFR Part 50, Appendix R, specifies measures to implement alternative and dedicated shutdown capability required by Section III.G.3 of 10 CFR Part 50, Appendix R.Section III.L.3 of 10 CFR Part 50, Appendix R, states, in part, that alternative shutdown capability shall be independent of the specific fire area and that procedures shall be in effect to implement this capability. Off Normal Procedure ONP-25.2 is used to safely shutdown the plant in event of a fire in any of the alternate shutdown areas. Contrary to the above, from 1995 to May 2007, the licensee failed to provide adequate procedural instructions to implement an alternative shutdown capability. Specifically, Attachments 3 and 5 of ONP-25.2 failed to provide the correct electrical power supply distribution cabinet number for the power feeds to 13 post-fire safe shutdown CVs. The procedure instructed the operators to open Circuit Breaker 72-229 at DC Distribution Panel D21-1 to de-energize the affected CVs in order to mitigate potential spurious operations of these valves. However, Circuit Breaker 72-229 was actually located at DC Distribution Panel D21-2. In May 2007, the licensee revised the affected procedure including ONP-25.2 based on the inspector finding and corrected all identified discrepancies. The licensee is in transition to NFPA 805; and therefore, the NRC-identified violation was evaluated in accordance with the criteria established by Section A of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for a licensee in NFPA 805 transition. The inspectors determined that for this violation: (1) the licensee would have identified the violation during the scheduled transition to 10 CFR 50.48(c); (2) the licensee had established adequate compensatory measures within a reasonable time frame following identification and has corrected the violation; (3) the violation was not likely to have been previously identified by routine licensee efforts; and (4) the violation was not willful. The finding also met additional criteria established in Section 12.01.b of IMC 0305. In addition, in order for the NRC to consider granting enforcement discretion the violation must not be associated with a finding of high safety significance (i.e., Red). Therefore, the licensee performed a risk-evaluation and determined that this issue was not associated with a finding of high safety significance. In addition, the licensee entered this issue into their CAP and revised the procedure to reflect the correct panel number. As a result, the inspectors concluded that the violation met all criteria established by Section A and the NRC was exercising enforcement discretion to not cite this violation in accordance with the Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues. The inspectors review of this issue was considered to be a part of the original inspection effort, and as such, did not constitute any additional inspection samples. |
| Site: | Palisades  |
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| Report | IR 05000255/2011004 Section 4OA5 |
| Date counted | Sep 30, 2011 (2011Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | C Zoia A Dahbur J Cassidy J Ellegood T Taylor A Scarbeary |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2011004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2011Q3
Self-Identified List (Palisades)
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