05000346/FIN-2016002-05
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | Failure to Properly Assess and Implement Compensatory Measures for Fire Protection System Impairment Plant TS 5.4.1(d), requires, in part, the licensee to establish, implement, and maintain applicable written procedures covering fire protection program implementation. The fire protection program was implemented, in part, by Davis-Besse Procedure DBFP00009, Fire Protection Impairment and Fire Watch, Revision 21. Procedure DBFP00009, Step 6.1.2, states: Upon request, notification, or plant condition that indicates a fire protection system/component impairment exists or will exist, the Shift Manager shall ensure an Impairment Initiation Work Sheet Sections 1, 2A, 2B as needed, 2C and 3 is completed for each impairment to assess the need for compensatory measures. Contrary to this requirement, from 7:30 p.m. on June 26, 2016, to 2:30 p.m. on June 28, 2016, the licensee failed to implement and adequately assess the need for compensatory measures in multiple locations of the turbine building when an applicable fire impairment existed based on plant conditions. On June 26th, a section of underground fire protection piping was isolated for planned maintenance to repair FP355, South Underground Loop Sectionalizing Valve, due to the valve operator not functioning properly. A fire impairment initiation worksheet was completed for the pre-planned maintenance isolation boundary using the stations fire risk software program prior to the maintenance activity commencing. The assessment concluded that compensatory measures in the form of eight-hour roving fire watches were required for the SBODG building due to the sprinkler systems in those locations being isolated to support the FP355 maintenance activity. These compensatory measures were implemented at approximately 7:30 p.m. On June 28, while preparing for future fire protection maintenance on FP40, East Underground Loop Sectionalizing Valve, the licensee recognized that FP40 had a pre-existing maintenance condition since November 2015, such that the valve was stuck in the closed position (normally open). This condition, when combined with the already in-progress FP355 valve maintenance activity, was not previously assessed and extended the pre-planned FP355 isolation boundary. As a result, the sprinkler systems in the following locations in the turbine building were isolated with no compensatory measures established
Lube Oil Storage Room (Room 249 onehour fire watch required) Oil Drum Storage Room (Room 337 onehour fire watch required) Turbine Generator Lube Oil Room (Room 432 eight-hour fire watch required) Janitor Closet (Room 346 eight-hour fire watch required) Lube Oil Filter Room (Room 347 eight-hour fire watch required); an Main Tool Room (Room 341 eight-hour fire watch required) Upon identification and reassessment, the appropriate compensatory measures were immediately implemented around 2:30 p.m. on June 28. The inspectors reviewed this violation using the guidance contained in Appendix B, Issue Screening, of IMC 0612, Power Reactor Inspection Reports. The inspectors determined that the licensees failure to properly implement plant procedures for assessing and establishing compensatory fire watches was a performance deficiency that was reasonably within the licensees ability to foresee and correct and should have been prevented. This violation was associated with the Initiating Events cornerstone of reactor safety and was of more than minor significance because it was associated with the Initiating Events cornerstone attribute of Protection Against External Factors (Fire) and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during plant operations. Specifically, the licensee failed to implement and adequately assess the need for compensatory measures in multiple locations of the turbine building when an applicable fire impairment existed based on plant conditions. Required fire watch patrols established as compensatory measures should have been performed for the duration of the impairment so that the sites ability to promptly detect and suppress a fire would be maintained. The inspectors evaluated the violation using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. Because it involved fire protection, the inspectors transitioned to IMC 0609, Appendix F, Fire Protection Significant Determination Process. The violation was characterized according to IMC 0609, SDP, Appendix F, Attachment 1, "Fire Protection SDP Phase 1 Worksheet," dated September 20, 2013. The violation screened as of very low safety significance (Green), per Attachment 1, Question 1.3.1.A, because it did not affect the ability of the reactor to reach and maintain safe shutdown. The licensee had entered this issue into their CAP as CR 201608266. Corrective actions include but are not limited to immediately establishing required compensatory measures upon identification of the issue and the performance of an apparent cause evaluation. |
| Site: | Davis Besse  |
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| Report | IR 05000346/2016002 Section 4OA7 |
| Date counted | Jun 30, 2016 (2016Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | D Kimble J Cameron J Cassidy J Rutkowski N Valos T Bilik T Briley |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Davis Besse - IR 05000346/2016002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Davis Besse) @ 2016Q2
Self-Identified List (Davis Besse)
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