05000445/FIN-2008003-01
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Finding | |
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| Title | Inadequate Fire Protection Compensatory Actions During Refueling Outage |
| Description | The inspectors identified a noncited violation for failure to establish adequate compensatory measures for inoperable containment fire hose stations as required by the fire protection program as defined in Unit 2 License Condition 2.G. This resulted in a period of eighteen days during a refueling outage where inadequate compensatory measures were established to fight a fire in containment with hoses. Specifically, fire protection water to hose stations inside containment was isolated and the established compensatory measure was for the fire brigade to connect hoses from an operable outside containment hose station in order to reach the postulated fire in containment or to pressurize another hose station inside of containment. This compensatory measure would have required that fire hose be run through the personnel airlock and then pressurized. The fire preplan for a fire in containment on the 905 elevation, states keep airlock access closed to prevent release, This guidance conflicts with the compensatory measure provided. In addition, other procedures such as a loss of inventory or loss of shutdown cooling may require the personnel airlock to be closed, preventing the fire brigade from running fire hose through the personnel airlock. Therefore, the inspectors determined that the licensee failed to provide adequate compensatory actions during the time that fire protection water to containment was isolated. The licensee entered the finding into their corrective action program for resolution. This finding is more than minor because it is associated with the Protection Against External Factors attribute of the Mitigating Systems Cornerstone and affected the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Characterization and Screening of Findings, the inspectors determined that this finding should be evaluated using NRC Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because it affects fire protection defense-in-depth strategies involving manual suppression equipment. However, Appendix F, Assumptions and Limitations states that the fire protection significance determination process does not address the potential risk significance of fire protection inspection findings for shut down reactors. Therefore, the significance of this finding was assessed using Manual Chapter 0609 Appendix M, Significance Determination Process Using Qualitative Criteria. The finding is of very low safety significance because there were a limited number of postulated fires that could affect shutdown cooling, a single fire could not credibly affect both residual heat removal system loops, and a postulated fire could not have formed a hot-gas layer affecting the equipmen |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2008003 Section 1R05 |
| Date counted | Jun 30, 2008 (2008Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | D Allen B Tindell M Young S Makor P Goldberg L Ricketson P Elkmann C Johnson |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2008003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2008Q2
Self-Identified List (Comanche Peak)
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