The inspectors identified a non-cited violation (
NCV) of very low safety significance (Green) of
10 CFR Part 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Exelon did not include certain flood indication functions into the scope of the maintenance rule (
MR). Specifically, level switches used to indicate flood levels in the Unit 2 and Unit 3
emergency core cooling system (
ECCS) rooms were not included in the scope of the
MR as required by
10 CFR 50.65 (b)(2)(i) as non-safety related components that are used in plant emergency operating procedures (
EOPs).
PBAPS entered the issue into their corrective action program (
CAP) as issue reports (IRs) 02433897 and 02437502 and scoped the level switches into the
MR. The finding is determined to be more than minor because it is associated with the protection against external factors attribute of the
Mitigating Systems cornerstone and affected the cornerstones objective to ensure the reliability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). In the case of this finding, monitoring of components that provide alarm indication to operators during a flood hazard were not incorporated into the
MR. The inspectors also reviewed
IMC 0612, Appendix E, Examples of Minor Issues, and determined the issue was similar to example 7.d; in that, flood detection was not within the scope of the
MR and that one of the flood detectors had experienced performance problems during preventive maintenance (
PM) testing . The inspectors conducted a Phase 1 screening in accordance with
IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its Technical Specification (TS) allowed outage time, and did not screen as risk significant due to external
initiating events. The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Change Management because
PBAPS did not use a systematic process for evaluating and implementing a change. Specifically, during
PBAPSs MR database update and monitoring criteria development for new functions,
PBAPS did not ensure that certain level switches that provide alarms for flooding used in plant
EOPs were scoped into the
MR despite identifying that it was required. [H.3]
