The team identified a finding of very low safety significance involving a non-cited violation of
10 CFR 50, Appendix B, Criterion III, Design Control, in that Dominion did not ensure the adequacy of the recirculation spray system heat exchanger design. Specifically, Dominion had not performed analyses or testing to evaluate the potential of air entrapment in the recirculation spray system heat exchangers under post-accident conditions. In response, Dominion entered this issue into their corrective action program and performed analyses to demonstrate that this condition did not render associated equipment
inoperable. This finding is more than minor because it is associated with the design control attribute of the
Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in a loss of recirculation spray system operability or functionality. This finding did not have a cross-cutting aspect.