05000382/FIN-2006010-01
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Finding | |
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| Title | Protection of Safe Shutdown Capabilities |
| Description | The team identified an apparent violation of License Condition 2.C.9, "Fire Protection (Section 9.5.1, SSER 8)," for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The licensee credited unapproved manual actions to mitigate the effects of fire damage in lieu of providing physical protection consistent with the technical requirements of 10 CFR Part 50, Appendix R, Section III.G.2. The team considered the manual actions to be reasonable, therefore, the finding was determined to be of very low safety significance. License Condition 2.C. 9 states, "EOI shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility thru Amendment 36 and as approved in the SER through Supplements 9, subject to the following provision: EOI may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdowns in the event of a fire." In NUREG-0787, "Safety Evaluation Report Related to the Operation of Waterford Steam Electric Station, Unit No. 3," Supplement No. 5, the NRC staff evaluation of Safe Shutdown Capability noted, "In SSER No. 3, the staff reported that the one of the redundant trains needed for safe shutdown would be kept free of fire damage by providing separation, fire protection (fire detection, suppression, fire barriers), repairs for cold shutdown equipment, and/or an alternate shutdown capability." The NRC staff also stated in the conclusion of SSER N0. 5, "The technical requirements set forth in Appendix R, as well as the criteria of BTP 9.5-1, have been used as guidelines in the fire protection evaluation above. By letter dated November 10, 1981, the applicant committed to meet the technical requirements of Appendix R to 10 CFR Part 50. The staff evaluated this commitment, along with specific commitments described in this SSER. Subsequently, the staff concluded that the fire protection program, with the accepted deviations listed below is in conformance with the guidelines of Appendix A to BTP 9.5-1, the requirements of Appendix R, and GDC 3, and is, therefore, acceptable." At the time of the inspection, the fire protection program relied on manual actions for fires outside of the control room for achieving and maintaining hot shutdown as documented in calculation EC-F00-026, "Appendix R Revalidation Project Post Fire Safe Shutdown," and Procedure OP-901-524, "Fire in Areas Affecting Safe Shutdown." An example is establishing a charging flow path for the case of a fire in Fire Area RAB 8 (Switchgear Room). If a fire occurred in Fire Zone RAB 8B (Train B Switchgear Room), operators are required to manually close valve CVC-183 in Fire Area RAB 31 to isolate the Volume Control Tank and open breaker CVCEBKRAB 38 in Fire Zone RAB 8C to fail air operated valve CVC-209 (Charging Header Isolation) in the required open position. |
| Site: | Waterford  |
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| Report | IR 05000382/2006010 Section 1R05 |
| Date counted | Sep 30, 2006 (2006Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | D Livermore J Mateychick L Smith R Mullikin |
| INPO aspect | |
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Finding - Waterford - IR 05000382/2006010 | |||||||||||||||||
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Finding List (Waterford) @ 2006Q3
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