05000483/FIN-2012007-02
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Finding | |
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| Title | No written procedures provided |
| Description | Technical Specification 5.4.1.d requires that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Contrary to this requirement, from March 16, 2006, to May 4, 2012, the licensee failed to establish, implement, and maintain written procedures covering fire protection program implementation. Specifically, the team identified three examples involving: 1) potential overfilling of the pressurizer; 2) potential draindown of the refueling water storage tank; and 3) potential overfilling of the steam generators, where the licensee failed to maintain an alternative shutdown procedure that ensured operators could safely shut down the plant in the event of a control room fire. Because the licensee committed to adopting National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, and has committed to changing their fire protection program license basis to comply with 10 CFR 50.48(c) by submitting a license amendment request to the NRC, this violation is eligible for enforcement discretion as described in Section 9.1 of the Enforcement Policy, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). Under this interim Enforcement Policy, the NRC will normally not take enforcement action for a violation of 10 CFR 50.48(b) (or the requirements in a fire protection license condition) involving a problem in an area such as engineering, design, implementing procedures, or installation if the violation is documented in an inspection report and meets all of the following criteria: The licensee identified the violation as a result of a voluntary initiative to adopt the risk-informed, performance-based fire protection program under 10 CFR 50.48(c), or, if the NRC identified the violation, the NRC found it likely that the licensee would have identified the violation in light of the defined scope, thoroughness, and schedule of its transition to 10 CFR 50.48(c). The licensee corrected the violation or will correct the violation after completing its transition to 10 CFR 50.48(c). Also, the licensee took immediate corrective action or compensatory measures or both within a reasonable time commensurate with the risk significance of the issue following identification; this action should involve expanding the initiative, as necessary, to identify other issues caused by similar root causes. Routine licensee efforts, such as normal surveillance or quality assurance activities, were not likely to have previously identified the violation. The violation was not willful. The violation is not associated with a finding of high safety significance. Specifically, the team determined that the licensee: (1) would have identified the violation in light of the defined scope, thoroughness, and schedule of its transition to 10 CFR 50.48(c) because the licensee had performed a new thermal hydraulic analysis and developed a new alternative shutdown procedure for the transition to NFPA-805; (2) the licensee will correct the violation after completing its transition to 10 CFR 50.48(c) and took immediate corrective action or compensatory measures or both within a reasonable time commensurate with the risk significance of the issue following identification. The licensee entered these issues into their corrective action program as CARS 201203377 and implemented appropriate compensatory measures, (3) routine licensee efforts (such as normal surveillance or quality assurance activities), were not likely to have previously identified the violation; (4) the violation was not willful; and (5) the team determined that this violation was not of high safety significance (Red). Since all the criteria for enforcement discretion were met, the NRC is exercising enforcement discretion for this issue. |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2012007 Section 1R05 |
| Date counted | Jun 30, 2012 (2012Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | S Graves G Miller S Alferink M Young E Uribe |
| INPO aspect | |
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Finding - Callaway - IR 05000483/2012007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2012Q2
Self-Identified List (Callaway)
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