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The inspectors identified a finding of verThe inspectors identified a finding of very low safety-significance and associated Non-Cited Violation (NCV) of Technical Specifications, Paragraph 5.4.1.d, for the failure to identify an adverse trend in performing fire watches required as compensatory spurious operations vulnerabilities and an unanalyzed condition in Appendix R analysis. would have ensured the proper implementation of the Fire Protection Program in resulted in numerous instances in which the licensee failed to issue and implement Fire discovery, the licensee initiated an Apparent Cause Evaluation after entering this finding into their corrective action program as CAP 069822. The finding was determined to be more than minor because the finding was associated (fire) and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to implement fire protection procedure requirements could have complicated plant safe shutdown in the event of a fire. The issue was of very low safety-significance based on the relatively short duration involved and that only one defense-in-depth element (barriers) was affected by the impairments for which the fire watches had been the NRC Enforcement Policy.This finding has a cross-cutting aspect in the area of Problem Identification and Resolution (PI&R) for the CAP component because the licensees trending program failed to ensure that information from the CAP and other assessments in the aggregate are periodically trended and assessed to identify adverse trends. The Licensees Apparent Cause Evaluation (ACE) 001984, dated September 23, 2009, attributed the licensees trending program, which failed to assign the responsibility for reviewing potential adverse trend issues to a specific position or individual. Consequently, the licensee failed to identify the aggregate trend which was identified by the inspectors. (Example P1.(b)), (Section 1R05.11b)spectors. (Example P1.(b)), (Section 1R05.11b)  +
23:59:59, 30 September 2009  +
05000331  +
23:59:59, 30 September 2009  +
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03:08:52, 30 May 2018  +
23:59:59, 30 September 2009  +
Failure to Identify and Address an Adverse Trend in Performing Required Fire Watches  +