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The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. Indian Point Unit 2 Technical Specification 5.4.1.k and Indian Point Unit 3 Technical Specification 5.4.1.d require written procedures shall be established, implemented, and maintained covering FPP implementation. Procedure 0-PT-M004, Fire Extinguisher Inspection, Revision 9 implements monthly inspections of portable fire extinguishers to verify hydrostatic testing and periodic maintenance was performed within the periodicity specified by NFPA 10-1990, Standard for Portable Fire 17 Extinguishers. Procedure 0-PT-M004 requires portable fire extinguishers to be removed from service and replaced if their periodic maintenance or hydrostatic testing are not current within the specified periodicity. Contrary to the above, from July 1, 2015, to August 25, 2017, approximately 200 portable fire extinguishers were not removed from service and replaced when they exceeded their specified periodicity for maintenance and/or hydrostatic testing. Specifically, plant staff did not properly implement procedure 0-PT-M004 to verify portable fire extinguishers were periodically maintained and hydrostatically tested at intervals specified by NFPA 10-1990. The application software used in conjunction with 0-PT-M004 to perform monthly fire extinguisher inspections was revised in June 2015 and plant staff did not set up the software to require verification that fire extinguisher maintenance and hydro tests were current. Fire protection engineers identified the issue in August 2017, evaluated the subject fire extinguishers, and determined they were acceptable for continued use until December 31, 2017, based on the relatively short period of untimely maintenance/testing, satisfactory monthly verifications of physical condition, and the availability of additional portable fire extinguishers in the affected fire areas. Additional corrective actions included initiation of an accelerated maintenance and hydro test program to ensure all portable fire extinguishers met NFPA-10 maintenance and test requirements by December 21, 2017, and revision of 0-PT-M004 and the associated application software. Entergy entered the issue into the CAP (CRs IP3-2017-04084 and IP3- 2017-02945). The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because the finding did not impact the frequency of a fire and did not involve a loss or degradation of equipment or function specifically designed to mitigate an external event.
|Report||IR 05000247/2017007 Section 4OA7|
|Date counted||Dec 31, 2017 (2017Q4)|
|Inspectors (proximate)||E Dipaolo|
|Violation of:||Technical Specification - Procedures|
Finding List (Indian Point) @ 2017Q4
Self-Identified List (Indian Point)