05000298/FIN-2010005-01
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Finding | |
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| Title | Failure to Implement Fire Protection Plan Requirements Related to Hot Work Activities |
| Description | The inspectors identified two examples of a finding for the failure of contract personnel to properly implement the requirements of the station procedure for control of hot work activities, where one instance resulted in a fire. Specifically, between November 9 and December 4, 2010, two examples were identified where contractor personnel failed to properly implement the requirements of station Procedure 0.39, Hot Work, Revision 42, Step 5.17.3 which required that all combustible material within 35 feet of the hot work area was removed, protected or additional fire watches stationed. Consequently, on December 4, 2010, during torch cutting activities on the central alarm station upgrade project, combustible material that had been introduced into the area was ignited by the hot work. These issues were entered into the corrective action program as Condition Reports CR-CNS-2010-8364, and CR-CNS-2010-9015. The failure of contract personnel to follow the requirements of the stations control of hot work procedure was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against external factors attribute and directly affected the Initiating Events Cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations, and is therefore a finding. Additionally, if left uncorrected, the practice of conducting hot work in a manner that results in unintended combustion of uncontrolled combustible material within the procedurally specified exclusion area would have the potential to lead to a more significant safety concern, in that, it could result in a fire in or near risk important equipment. Using NRC Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 worksheet, the finding was determined to have very low safety significance because the condition represented a low degradation of a fire prevention and administrative control. This finding had a crosscutting aspect in the area of human performance associated with decision making, in that, the licensee failed to use conservative assumptions in their decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action when allowing combustible material to be introduced into the procedurally specified exclusion area for hot work activities. |
| Site: | Cooper  |
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| Report | IR 05000298/2010005 Section 1R05 |
| Date counted | Dec 31, 2010 (2010Q4) |
| Type: | Finding: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | G Guerra P Elkmann J Josey V Gaddy M Chambers E Ruesch |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Cooper - IR 05000298/2010005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2010Q4
Self-Identified List (Cooper)
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