05000413/FIN-2016003-01
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | The licensee identified a non-compliance with Operating License Condition 2.C.(5), for Units 1 and 2, for the failure to protect one of the redundant trains of equipment needed to achieve post-fire SSD from fire damage. Specifically, the licensee failed to use one of the means described in Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1, Item C.5.b.2 to ensure that one of the redundant trains of equipment necessary to achieve and maintain hot shutdown conditions was protected from fire damage. Description: On June 2, 2014, the licensee submitted LER 413/2014-002-00 with Revision 01 submitted on December 1, 2014, which documented discovery of cable routing issues and postulated fire-induced circuit failures that could prevent operation or cause maloperation of equipment required to achieve SSD in the event of a fire. This condition was identified during the licensees transition to National Fire Protection Association Standard 805 (NFPA 805). During the transition to NFPA 805, the licensee identified multiple instances of cables for equipment required to achieve SSD not meeting the separation requirements of the current licensing basis. The licensee determined that this condition existed for 22 fire areas (FAs) across both units. The licensee characterized these issues as variance(s) from deterministic requirements (VFDRs). The conditions identified in the LER are related to VFDRs that met the following criteria: 1) VFDRs that required a plant modification to meet the fire risk criteria of NFPA 805, or 2) VFDRs where a potential concern existed with respect to NRC Information Notice (IN) 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire, dated February 28, 1992. The licensee determined that the deficiencies existed because of latent design deficiencies in the cable routing and circuit design. This LER was applicable to Units 1 and 2. Upon discovery, the licensee entered this issue into their corrective action program as PIP C-1401427, and implemented compensatory actions in the form of fire watches and/or control of transient combustible material for the affected FAs. Analysis. Failure to protect one redundant train of cables and equipment necessary to achieve post-fire SSD from fire damage was a performance deficiency. This finding was more than minor because it was associated with the reactor safety mitigating system cornerstone attribute of protection against external events (i.e., fire). Specifically, failure to protect safe shutdown cables and equipment from fire damage negatively affected the reactor safety mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because this issue relates to fire protection and this noncompliance was identified as a part of the sites transition to NFPA 805, this issue is being dispositioned in accordance with Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) of the NRC Enforcement Policy. In order to verify that this non-compliance was not associated with a finding of high safety significance (Red), inspectors reviewed qualitative and quantitative risk analyses performed by the licensee. These risk evaluations took ignition source and target information from the licensees fire probabilistic risk assessment to demonstrate that the significance of the non-compliances were less-than-Red (i.e. CDF less than 1E-4/year). Inspectors determined that cables associated with some of the VFDRs were not located in the zone of influence (ZOI) of any credible ignition source. For cables that were located in the ZOI of a credible ignition source, inspectors were able to perform a calculation to determine the change in conditional core damage probability (CCDP), based on the postulated fire-affected equipment not being available. Based on these screenings, inspectors determined that the significance of this non-compliance was lessthan-Red. A bounding risk assessment performed by a regional Senior Risk Analyst (SRA) reviewed the licensee and inspector risk evaluations and confirmed the CDF risk increase due to this condition was less than 1E-4, and therefore less than RED. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. Enforcement. Operating License Condition 2.C.(5), for Units 1 and 2, requires that the licensee implement and maintain in effect all provisions of the approved FPP as described in the UFSAR, as amended, for the facility and as approved in the SER through Supplement 5. BTP CMEB 9.5-1, which incorporated the guidance of Appendix A to BTP ASB 9.5-1 and the technical requirements of Appendix R to 10 CFR 50, established the regulatory and licensing requirements for the FPP at Catawba Nuclear Station (CNS). The CNS FPP was reviewed against and approved for conformance with BTP CMEB 9.5-1 in the SER through Supplement 5. BTP CMEB 9.5-1, Item C.5.b.1, requires that fire protection features be provided that are capable of limiting fire damage so that one train of systems necessary to achieve and maintain hot standby conditions from either the control room or emergency control station(s) is free from fire damage. BTP CMEB 9.5- 1, Item C.5.b.2 requires one redundant train to be protected from fire damage by one of the following specified methods: (a) separation of cables and equipment by a fire barrier having a 3-hour rating, (b) separation of cables and equipment by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards and with fire detectors and an automatic fire suppression system in the fire area, or (c) enclosure of cables and equipment in a fire barrier having a 1-hour rating and with fire detectors and an automatic fire suppression system in the fire area. Contrary to the above, the licensee failed to use one of the means described in BTP CMEB 9.5-1, Item C.5.b.2 to ensure that one of the redundant trains of equipment necessary to achieve and maintain hot shutdown conditions was protected from fire damage. Specifically, on April 2, 2014, the licensee identified the failure to protect equipment in accordance with the current licensing basis. The licensee determined that fire damage could prevent operation of, or cause maloperation of, components that were required to achieve and maintain SSD. This condition has existed since initial plant startup for Units 1 and 2. The licensee entered this issue into the corrective action program (PIP C-14-1427) and implemented compensatory measures in the form of fire watches and/or control of transient combustible material for the affected FAs. Because the licensee committed to adopt NFPA 805 and change their fire protection licensing bases to comply with 10 CFR 50.48(c), the NRC is exercising enforcement and reactor oversight process (ROP) discretion for this issue in accordance with the NRC Enforcement Policy, Section 9.1, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48) and Inspection Manual Chapter 0305. Specifically, this issue was identified and will be addressed during the licensees transition to NFPA 805, it was entered into the licensees corrective action program, immediate corrective action and compensatory measures were taken, it was not likely to have been previously identified by routine licensee efforts, it was not willful, and it was not associated with a finding of high safety significance (Red). |
| Site: | Catawba  |
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| Report | IR 05000413/2016003 Section 4OA3 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | C Dykes C Scott F Ehrhardt J Austin J Montgomery J Panfel M Toth R Kellner R Williams |
| Violation of: | License Condition - Fire Protection |
| INPO aspect | |
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Finding - Catawba - IR 05000413/2016003 | |||||||||||||||||||||||||||
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Finding List (Catawba) @ 2016Q3
Self-Identified List (Catawba)
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