10 CFR Part 50.48 states, in part, that each operating nuclear power plant . . . must have a fire protection plan that satisfies Criterion 3 of Appendix A to this part. The Surry Unit 1 Updated Facility Operating License
DPR-32, and Unit 2 Updated Facility Operating License
DPR-37, Condition 3.I, specify, in part, that the licensee implement and maintain in effect all provisions of the approved
fire protection program as described in the
UFSAR and as approved in the Safety Evaluation Report (
SER) and subsequent supplements. The
UFSAR requires, in part, that the
fire protection program (
FPP) meet Appendix A to Branch Technical Position (
BTP) APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976, dated August 23, 1976. Section D.2.a of Appendix A to
BTP APCSB 9.5-1 requires, in part, that safety related systems should be isolated or separated from combustible materials. When this is not possible because of the nature of the safety system or the combustible material, special protection should be provided to prevent a fire from defeating the safety system function. Examples of such combustible materials that may not be separable from the remainder of its system are: (3)
Reactor coolant pump
lube oil system. Additionally,
10 CFR 50, Appendix R, Section III.O requires, in part, that The oil collection system shall be so designed, engineered, and installed that failure will not
lead to fire during normal or design basis accident conditions. Leakage shall be collected and drained to a vented closed container that can hold the entire
lube oil system inventory. Contrary to the above, on November 23, 2011, the licensee identified that the
reactor coolant pump (
RCP) oil collection tanks for all the
RCPs on both units were full of water and would not be able to contain the entire
lube oil system inventory. The tanks were full of water due to a design change oversight that resulted in pre-existing
RCP stator condensation being directed into the oil collection tanks. The inspectors determined the finding was more than minor because it was associated with the
initiating events cornerstone attribute of protection against external factors and it adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, the failure to meet Appendix R resulted in the non-functionality of the oil collection systems on all Unit 1 and Unit 2
RCPs, increasing the risk of fire from an
RCP oil leak. The inspectors reviewed
IMC 0609, Appendix F, and determined the finding was of very low safety significance (Green), because the finding was assigned a low fire degradation rating. Specifically, the
RCP oil inventory would be expected to rise to the top of the collection tank and
spill out the tank vent on to the loop room floor, causing it to spread out and be directed to the containment
sump through the floor drains. The loop room floor and components in the vicinity do not reach oil ignition temperatures and
safe shutdown capability would not be affected. The licensee has entered this issue in their
CAP as CR 453867.
