10 CFR Part 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, states, in part, Before performing maintenance activities (including but not limited to surveillance, post maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to this, on August 21, 2008, Constellation removed the Unit 2 motor driven
AFW flow path trains to the No. 21 and No. 22
SGs without conducting an adequate risk assessment. Constellation entered this issue in their
CAP as CR- 2009-000979. This finding is of very low safety significance based on a
SDP Phase 1 screening utilizing
IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management
Significance Determination Process. Specifically, the
incremental core damage probability deficit was less than
1E-6 