The inspectors identified an
NCV of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for
FENOCs failure to implement adequate risk management actions (
RMAs) associated with maintenance on the alternate intake structure A bay. Specifically,
FENOC did not establish a contingency plan for the maintenance activity as required by
FENOCs risk management procedure.
FENOC entered the issue into their corrective action program as CR 2015-00267. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the
Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically,
FENOCs failure to implement a contingency plan resulted in an increase in the duration of an elevated risk condition and unavailability of equipment relied upon to mitigate the consequences of a loss of the main intake structure. The finding was determined to be of very low safety significance (Green) because the incremental core damage probability (
ICDP) for the event was less than 1.0 E-6. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance, Work Management, because the
FENOC work process failed to adequately manage the risk commensurate to the work [H.5].