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The failure to maintain adequate written pThe failure to maintain adequate written procedures covering fire protection program implementation was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A senior reactor analyst performed a hand calculation to bound the risk significance of this finding. The senior reactor analyst determined that the change in core damage frequency was less than 1E-4, so the finding was not of high safety significance (Red). Therefore, this finding qualified for enforcement discretion using Section 9.1 of the Enforcement Policy, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). This finding did not have a cross-cutting aspect because it qualified for enforcement discretion.e it qualified for enforcement discretion.  +
23:59:59, 31 December 2012  +
05000275  +  and 05000323  +
23:59:59, 31 December 2012  +
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17:27:46, 1 October 2017  +
23:59:59, 31 December 2012  +
Review of Operational Implementation  +