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Green. The team identified a finding withGreen. The team identified a finding with three examples for the licensee failing to assure that FLEX procedures were adequate for implementation of the strategies credited in the licensees Final Implementation Plan. This issue was entered into the licensees corrective action program as Condition Reports CR -ANO -C-2017- 00341, CR- ANO -C 2017- 00344, CR- ANO -1-2017 -00250, and CR -ANO -C-2017 00295. The failure to provide adequate procedures for responding to an extended loss of all AC power due to a flooding or high wind event was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems Cornerstone and adversely affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of the finding was evaluated using NRC Inspection Manual Chapter 0609, Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA -12-049 and EA -12-051), dated October 7, 2016, and Appendix M , Significance Determination Process Using Qualitative Criteria, dated April 12, 2012. A bounding evaluation was performed using the exposure time, frequency of random failure of both emergency diesel generators , and tornado frequency or flood frequency . The licensees compliance date wit h the order was January 12, 2016, so an exposure time of one year was used. The random failure frequency of both units emergency diesel generators (3.15E -3/year) was selected since the emergency diesel generators are protected from damage during high wind and flood events. For the two examples impacted by flood events, t he flood frequency selected was for a flood exceeding the site grade elevation (8.47E -5/year). The change in core damage frequency for the se examples was determined to be 2.67E -7/year. For t he example which would only impact the licensee s response to a high wind event , the tornado frequency selected was for an F2 or greater tornado striking the site (5.31E -5/year). The change in core damage frequency for th is example was determined to be 1.67E -7/year. Therefore, the three examples of the finding were determined to of very low risk significance. The findi ng had a cross-cutti ng aspect in the Procedure Adherence co mponent of Human Performance becau se the lice nsee failed to adequately perform reviews required by the licensees procedure control program to confirm that : (1) instructions for implementing the strategies in the licensees Final Implementation Plan were complete and appropriate; and (2) reviews for affected procedures relat ed to other procedure revisions identified impacts on the implementing strategies and revised them appropriately (H.8).ies and revised them appropriately (H.8).  
23:59:59, 30 June 2017  +
05000313  +  and 05000368  +
23:59:59, 30 June 2017  +
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04:25:26, 22 February 2018  +
23:59:59, 30 June 2017  +
Inadequate FLEX Procedures  +