05000400/FIN-2008008-02
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Finding | |
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| Title | Post-Fire Safe Shutdown From Outside the Main Control Room (Alternative Shutdown) |
| Description | The team identified a noncompliance of very low safety significance with Shearon Harris Technical Specification 6.8.1.a, for inadequate procedural guidance which directed usage of instruments that were not protected from fire damage in FZ 12- A-6-PICR1. Specifically, procedure AOP-004, Remote Shutdown, directed the operators to verify emergency service water (ESW) header flows were above the minimum flow requirement of 7500 gpm using flow indicators (FI) FI-9101A2 and FI-9101B2. These instruments would be unreliable during operation from the ACP because their cables were routed through the FZ of concern and the cables were not protected from fire damage. The violation meets the criteria of NRC Enforcement Policy, Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) for enforcement discretion. The team noted that procedure AOP-004, Remote Shutdown, would be used to safely shut down the plant from the ACP (utilizing Train B equipment) for a fire in FZ 12-A-6-PICR1. The procedure directed operators to verify ESW header (HDR) flows using FI-9101A2, A HDR Flow and FI-9101B2, B HDR Flow. The team reviewed cable routing data and noted that FI-9101A2 and FI-9101B2 may not provide reliable ESW flow indication for the operators at the ACP because the cables were routed through FZ 12-A-6-PICR1 and were not protected from fire damaged. This may potentially delay operator actions required to bring the plant to SSD conditions. Based on discussions with operations personnel and review of service water system simplified flow diagrams, the team determined that the ESW system was flow balanced to ensure that the 7500 gpm minimum flow would be provided to ESW HDR A and ESW HDR B. During walkdowns of the ACP, the team noted that valve position indication (i.e., open/close) was provided at the ACP for various ESW valves, including 1SW-270, HDR A to Auxiliary Reservoir and 1SW-271, HDR B to Auxiliary Reservoir. These valves were required to be opened (from the ACP) to ensure adequate ESW header flow. Review of cable routing data for valve 1SW-271 showed that this valve was not routed through FZ 12-A-6-PICR1 and would not be affected by a postulated fire in this FZ. The team determined that, based on operator experience, training, and indication of the position of ESW valve 1SW-271 at the ACP, it was likely plant operators would be able to determine that sufficient ESW flow was available and they would take the appropriate actions required to ensure post-fire SSD conditions. The licensee initiated NCR 298072 to address this issue in the CAP. |
| Site: | Harris  |
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| Report | IR 05000400/2008008 Section 1R05 |
| Date counted | Dec 31, 2008 (2008Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | N Merriweather N Staples B Melly M Thomas L Suggs K Miller O Lopez |
| INPO aspect | |
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Finding - Harris - IR 05000400/2008008 | ||||||||||||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2008Q4
Self-Identified List (Harris)
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