05000313/FIN-2013009-04
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Finding | |
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| Title | Violation of Unit 2 Technical Specification 6.4.1.c for failure to implement and maintain adequate written procedures |
| Description | Unit 2 Technical Specification 6.4.1.c states that written procedures shall be established, implemented, and maintained covering fire protection program implementation. Contrary to this requirement, prior to June 28, 2013, the licensee failed to establish, implement, and maintain written procedures covering fire protection program implementation. Specifically, the licensee failed to maintain an alternative shutdown procedure that successfully mitigated the spurious opening of an atmospheric dump valve block valve. Because the licensee committed to adopting National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, and has submitted a license amendment request to the NRC to change their fire protection program license basis to comply with 10 CFR 50.48(c), this violation is eligible for enforcement discretion as described in Section 9.1 of the Enforcement Policy, Enforcement Discretion for Certain Fire Protection Issues (10 CFR 50.48). Under this interim Enforcement Policy, the NRC will normally not take enforcement action for a violation of 10 CFR 50.48(b) (or the requirements in a fire protection license condition) involving a problem in an area such as engineering, design, implementing procedures, or installation if the violation is documented in an inspection report and meets all of the following criteria: The licensee identified the violation as a result of a voluntary initiative to adopt the risk-informed, performance based fire protection program under 10 CFR 50.48(c), or, if the NRC identified the violation, the NRC found it likely that the licensee would have identified the violation in light of the defined scope, thoroughness, and schedule of its transition to 10 CFR 50.48(c); The licensee corrected the violation or will correct the violation after completing its transition to 10 CFR 50.48(c). Also, the licensee took immediate corrective action or compensatory measures or both within a reasonable time commensurate with the risk significance of the issue following identification; this action should involve expanding the initiative, as necessary, to identify other issues caused by similar root causes; Routine licensee efforts, such as normal surveillance or quality assurance activities, were not likely to have previously identified the violation; and The violation was not willful. The violation was not associated with a finding of high safety significance. Specifically, the team determined that: (1) the licensee would have identified the violation in light of the defined scope, thoroughness, and schedule of its transition to 10 CFR 50.48(c) because the licensee was performing new analyses and developing a new alternative shutdown procedure for the transition to NFPA-805; (2) the licensee will correct the violation after completing its transition to 10 CFR 50.48(c) and took an immediate corrective action within a reasonable time commensurate with the risk significance of the issue following identification; (3) routine licensee efforts (such as normal surveillance or quality assurance activities) were not likely to have previously identified the violation; (4) the violation was not willful; and (5) the team determined that this violation was not of high safety significance (Red). The licensee entered this issue into their corrective action program as Condition Report CR-ANO-2-2013-01329 and implemented appropriate compensatory measures. Since all the criteria for enforcement discretion were met, the NRC is exercising enforcement discretion for this issue (EA-13-242). |
| Site: | Arkansas Nuclear  |
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| Report | IR 05000313/2013009 Section 1R05 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | G Miller J Mateychick L Willoughby N Okonkwo S Alferink |
| Violation of: | Technical Specification Technical Specification - Procedures 10 CFR 50.48 License Condition - Fire Protection License Condition |
| INPO aspect | |
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Finding - Arkansas Nuclear - IR 05000313/2013009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2013Q4
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