05000298/FIN-2007008-03
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Finding | |
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| Title | Reliance On Unapproved Manual Actions |
| Description | The Cooper Nuclear Station License Condition 2.C.4 requires that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report. The Updated Safety Analysis Report, Section X-18, Appendix R Safe Shutdown, states The Safe Shutdown Systems shall be physically separated and protected in accordance with the requirements of 10 CFR Part 50, Appendix R, Section III.G.2, such that a single postulated fire will not disable redundant systems and prevent the achievement of a safe shutdown.Section III.G.2 of Appendix R lists three options for satisfying the requirements for separation and protection of equipment needed to ensure safe shutdown remains free of fire damage. The requirements of this section do not allow using manual actions in lieu of protection and separation. Contrary to this, the team concluded that, since original construction, the licensee failed to protect and separate cables and equipment necessary to ensure safe shutdown in the event of a fire in multiple fire areas. Specifically, the licensee relied on manual actions to overcome the effects of spurious operations or circuit damage due to the effects of fire for the equipment required to achieve and maintain hot shutdowns in the event of a fire. The licensee entered this issue into their corrective action program under Condition Report CNS-2004-03034. Because the licensee committed, prior to December 31, 2005, to adopting NFPA Standard 805 and changing their fire protection program license basis to comply with 10 CFR 50.48(c), this violation is eligible for enforcement discretion in accordance with the NRC Enforcement Policy. Specifically, this issue would have been expected to be identified and addressed during the licensee's conversion to NFPA Standard 805, was entered into the licensee's corrective action program and will be corrected, and was of very low safety significance. The manual actions are to remain in effect as compensatory measures until the issue is resolved and compliance restored. Since this violation meets the criteria for enforcement discretion for plants in transition to a risk-informed, performance-based fire protection program as allowed in accordance with 10 CFR 50.48(c), the NRC is exercising enforcement discretion to refrain from taking any enforcement action. |
| Site: | Cooper  |
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| Report | IR 05000298/2007008 Section 1R05 |
| Date counted | Dec 31, 2007 (2007Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | H Abuseini |
| INPO aspect | |
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Finding - Cooper - IR 05000298/2007008 | |||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2007Q4
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