05000368/FIN-2016009-03
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Finding | |
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Title | Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid |
Description | The team identified a non-cited violation of License Condition 2.C(3)(b), Fire Protection, for the failure to establish an appropriate monitoring program in accordance with National Fire Protection Association Standard 805, Section 2.6. Specifically, the licensee failed to set the action level for the availability of some plant components to ensure that the assumptions in the engineering analysis remained valid and also failed to establish a monitoring plan for the concurrent unavailability of one set of two components. The licensee entered the issues into their corrective action program as Condition Reports CR-ANO-2-2016-02355 and was in the process of developing corrective actions to address the monitoring of the components and work with industry organizations and Office of Nuclear Reactor Regulation to determine long-term resolution. The failure to adequately monitor unavailability of the plant components to ensure that the assumptions in the engineering analysis remained valid was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, the performance deficiency could adversely affect the acceptable level of availability of the components which are used to respond to fire initiating events, in that the action levels for availability in the monitoring program were greater than the assumptions in the fire probabilistic risk assessment. The finding was screened in accordance with Inspection IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, dated June 19, 2012. Because the finding affected the ability to reach and maintain safe shutdown conditions in case of a fire, the team reviewed the finding using IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013. The finding was screened as a Green finding of very low safety significance in accordance with Step 1.3, Ability to Achieve Safe Shutdown, B Question. Based on the criteria in Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various Fire Protection Program Elements, dated February 28, 2005, the finding was assigned a low degradation rating. Using Table A2.3, the inspectors assigned the low degradation rating because the issue involved monitoring of components that did not appreciably degrade below acceptable levels during the exposure period. This finding had a cross-cutting aspect associated with change management within the human performance area since leaders did not use a systematic process (e.g., assigning an overall owner) for evaluating and implementing change during the development of the monitoring program for the fire probabilistic risk assessment model for Unit 2 (H.3). |
Site: | Arkansas Nuclear |
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Report | IR 05000368/2016009 Section 1R05 |
Date counted | Jun 30, 2016 (2016Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.05 |
Inspectors (proximate) | G Pick G Werner H Barrett J Mateychick N Okonkwo R Deese S Alferink S Makor |
Violation of: | License Condition - Fire Protection |
CCA | H.3, Change Management |
INPO aspect | LA.5 |
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Finding - Arkansas Nuclear - IR 05000368/2016009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2016Q2
Self-Identified List (Arkansas Nuclear)
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