05000313/FIN-2016007-13
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Finding | |
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| Title | Failure to Update Probabilistic Risk Assessment Model in a Timely Manner Results in Failure to Submit Complete and Accurate Information |
| Description | The team identified a Green finding for the licensees failure to update the Level 1 probabilistic risk assessment model as required by procedure EN-DC-151, Probabilistic Safety Assessment (PSA) Maintenance and Update, Revision 5. This finding also involved a Severity Level IV, non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, because the licensee failed to submit complete and accurate model maintenance information in their license amendment request for the extension of the integrated leak rate testing for the Unit 1 reactor building. Procedure EN-DC-151 established requirements to ensure that ANOs models represent the as-built, as-operated plant in a manner sufficient to support the applications for which they are used, including performing periodic updates within four years of the previous update. The licensee had not updated the internal events model for Unit 1 since July 2009 and for Unit 2 since 2008. The licensees corrective actions included completing the model update for Unit 1 on April 15, 2016, for Unit 2 on February 29, 2016, and documenting the issue in the corrective action program as condition report CR-ANO-C-2016-01573. The failure to perform probabilistic risk assessment updates as required by procedure EN-DC-151 was a performance deficiency and therefore a finding. An NRC-identified violation of 10 CFR 50.9 was associated with this finding because it impacted the regulatory process in that inaccurate information was provided to the NRC that was material in making a licensing decision. Therefore, in accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, this issue was evaluated using both the finding and traditional enforcement processes. This violation is associated with a finding that has been evaluated by the significance determination process and communicated with a significance determination process color reflective of the safety impact of the deficient licensee performance. The significance determination process, however, does not specifically consider the regulatory process impact. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding. The performance deficiency was determined to be more than minor because it was associated with the equipment performance and procedure quality attributes of the Mitigating Systems cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the lack of a formal process to ensure that probabilistic risk assessment model updates were performed as scheduled impacted license amendment requests, performance indicator accuracy, and daily maintenance risk evaluations for planned and emergent maintenance activities since the internal events model was not reflective of current plant conditions. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because it did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. Consistent with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV violation because inaccurate information was provided, but it would not have likely caused the NRC to reconsider its regulatory position or undertake substantial further inquiry. This finding had a human performance cross-cutting aspect of Resources because the licensee did not ensure that sufficient personnel resources were available to perform all probabilistic risk assessment duties, including model maintenance [H.1]. |
| Site: | Arkansas Nuclear  |
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| Report | IR 05000313/2016007 Section 4OA4 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 95003 |
| Inspectors (proximate) | B Correll C Osterholtz D Betancourt D Lackey D Willis E Duncan G Hansen J Brand J Dixon J Mateychick L Mckown M Holmberg M Keefe M Phalen N O'Keefe P Mckenna R Alexander R Deese R Kopriva R Kumana S Graves S Morrow S Rich S Smith T Hartman W Sifre Z Hollcraft |
| Violation of: | 10 CFR 50.9 |
| CCA | H.1, Resources |
| INPO aspect | LA.1 |
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Finding - Arkansas Nuclear - IR 05000313/2016007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2016Q1
Self-Identified List (Arkansas Nuclear)
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