ML18334A114
| ML18334A114 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18334A114 (2) | |
Text
1 Inspection Procedure (IP): 71111.05XT, Fire Protection - NFPA 805 (Triennial)"
Inspector Procedure Lead: Stephen Campbell Estimated Hours to Complete Review: 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Date Review Completed: October 29, 2018
- 1. Results and assessment of review of IMC 0308, ROP basis document review Verbiage in the bases section of the IP will be removed and a reference to IMC 0308 will be incorporated so the IP is consistent with the bases.
- 2. Results and assessment of review of any applicable changes to PIs A three-year review by the PI lead did not identify any significant changes to PIs that would result in a reduction or unintended gap in the key safety attributes of each safety cornerstone.
- 3. Results and assessment of review of any applicable changes to Rules and STSs Revisions to rules and Standard Technical Specifications within the last three years did not indicate a need for revision.
- 4. Results and assessment of review of recent Operating Experience A review of recent Operating Experience Notes did not identify any issues warranting revisions to IP 71111.05XT.
- 5. Results and assessment of review based on RRPS data.
Adverse trends or outliers noted: No adverse trends or outliers noted.
The actual samples and hours charged per sample are consistent with the estimated inspection hours. IP trends are stable (see explanation of trends in Section 8), and no significant findings or traditional enforcement violations have been identified in the last three to five years. No revisions to IP is recommended based on this review.
- 6. Feedback Forms FBFs Closed Last three years Withdrawn Feedback Form 71111.05XT-2057 (ML14252A005) incorporating inspection guidance regarding when and how to specifically assess age-related degradation issues at plants.
2 Open FBFs Currently, there are three open Feedback Forms.
71111.05XT-2216 recommends eliminating an inspection of the Combustible Control Program.
71111.05XT-2293 recommends addressing issues listed in OIG-17-A-10, Audit of NRCs Fire Protection Oversight for Operating Reactors, April 11, 2017, ADAMS Accession No. ML17101A737 71111.05XT-2334 recommends including a requirement to review the licensees control of transient combustibles and ignition sources or eliminate inspection objective if the review is not needed.
- 7. Other Considerations None
- 8. Results of discussions with regions The IP lead held a call with regional points of contact (POC) on October 25, 2018. The POC stated the IP contained appropriate requirements, level of detail, and appropriate inspection hour allocations. The regional feedback explained several discrepancies with the Findings trends. Most regions mentioned that they did not receive IP 71111.05XT inspections in 2017, which skewed the Findings trend. Several regions stated that plants transitioning to NFPA 805, the regions used the 71111.05T IP instead of the 71111.05XT IP. Also, Enforcement discretion was given for Findings and Violations for those plants. Consequently, those were not counted in the Findings trend.
Regions also mentioned that B.5.b sample should not be counted with the Fire Area sample since the B.5.b. sample takes less time to complete. When the NRC transitioned to using IP 71111.05XT, the number of IP 71111.05T inspections decreased.
Recommendations No revisions to IP recommended. Maintain awareness of NEI 18-03 to determine potential impact to IP.