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The team identified two examples of a Seve … The team identified two examples of a Severity Level IV non-cited violation of License Condition 2.C(3)(b), Fire Protection, for the licensees failure to properly implement their risk-informed fire protection program and accurately capture component ignition frequencies in their fire probabilistic risk assessment. Specifically, the component ignition frequencies for air compressors and ventilation equipment were found to be lower than expected because the licensee misapplied the guidance in NUREG/CR-6850. The licensee entered this issue into their corrective action program as Condition Reports CR ANO-C-2016-2600, CR-ANO-C-2016-2528, and CR-ANO-2-2016-02356, with the intent to perform an extent of condition relating to other potential components that are misclassified in the fire ignition frequency analysis, correct the fire Ignition frequency report and the associated Fire Probabilistic Risk Assessment model calculations to incorporate the correct ignition frequency and the appropriate scenarios. The licensees failure to adequately implement the prescribed guidance in NUREG/CR-6850 to estimate the ignition frequencies for their risk-informed fire protection program was a performance deficiency. The performance deficiency was minor because the answer to all the IMC 0612, Appendix B, more than minor questions was No. The team determined that this issue was a traditional enforcement violation because it impacted the regulatory process when the only NRC-approved framework for conversion to NFPA 805 was not fully followed. The NRC determined that this violation was associated with a minor performance deficiency. The team determined that this violation was a Severity Level IV in the traditional enforcement process when comparing it to the violation examples in Section 6.1, Reactor Operations, of the NRC Enforcement Policy, specifically noting it was similar to Example 6.1.d.4 for failing to adequately assess the baseline risk of plant operations associated with implementation of a risk-informed program (NFPA 805) such that the program was implemented inappropriately. The finding did not have a cross-cutting aspect because traditional enforcement violations are not assessed for cross-cutting aspects.re not assessed for cross-cutting aspects.

Discovered date

23:59:59, 30 June 2016 +

Docket

05000368 +

Event date

23:59:59, 30 June 2016 +

Finding integer

4 +

Finding type

Traditional Enforcement Violation +

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Identified by

NRC identified +

Inspection Manual Chapter

NRC Inspection Manual 0612 Appendix B +

Inspection procedure

IP 71111.05 +

Inspection report

IR 05000313/2016009 +

Inspector

Greg Pick +, Rick Deese +, Greg Werner +, H Barrett +, J Mateychick +, Shiattin Makor +, Nnaerika Okonkwo + and Steven Alferink +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

17:26:47, 1 October 2017 +

NFPA

NFPA 805 +

NUREG

NUREG/CR-6850, To Propose an Alternative Methodology to Distribute Transient Ignition Frequencies (Bins 3, 5, 6, 7, 11, 24, 25, 31, 36, 37) That Contains a More Structured Approach to Accounting for Influence Factor Variations within a Pau +

Person