An NRC-identified Apparent Violation (
AV) was identified for the licensees failure to comply with the requirements of
10 CFR 50.48(c) and National Fire Protection Association Standard 805 (
NFPA 805). The Oconee fire
probabilistic risk assessment (Fire
PRA) failed to address the risk contributions associated with all potentially risk significant fire scenarios. This finding does not represent an immediate safety concern because the licensee entered the issue in the corrective action program as Problem Investigation Program (
PIP) O-13-08059 and
PIP O-13-08061 and implemented fire watches as compensatory measures. Failure to comply with the requirements of
10 CFR 50.48(c) and
NFPA 805 to address the risk contributions associated with all potentially risk significant fire scenarios was a performance deficiency. This performance deficiency was determined to be more than minor because it was associated with the
Mitigating Systems cornerstone objective of protection against external events (i.e., fire), and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The finding was determined to be potentially greater than Green. Therefore, further analysis is required to assess the significance of the finding. The cause of this finding was determined to have a crosscutting aspect of
H.4(c) in the Work Practices component of the Human Performance area because the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported.
