The inspectors identified a non-cited violation of
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the failure to promptly correct a
condition adverse to quality associated with the sharing of the nuclear
service water system between units in abnormal operating procedures (
APs). Specifically, the licensee had neither developed a safety analysis to demonstrate the safety of this activity nor revised the procedural steps that allowed sharing. This finding is more than minor because it affected the availability, reliability, and capability of the Nuclear
Service Water (RN) system (
ultimate heat sink) and was related to the design control and procedure quality attributes of the
Mitigating Systems cornerstone. In addition, this finding could be reasonably viewed as a precursor to a significant event (i.e., loss of RN on both units). The issue was determined to be of very low safety significance in
IMC 0609 SDP Phase 1 screening based on the fact that it did not represent an actual loss of system safety function nor a loss of a single train of RN for greater than its Technical Specification allowed outage time, because the subject procedural steps of the
APs had never been used. This finding has a cross-cutting aspect of corrective action in the area of Problem Identification and Resolution (
P.1.d), because the licensee failed to take appropriate corrective action in a timely manner. The licensee plans to revise the procedure, complete a calculation to support the donating of one train of nuclear
service water to the other unit when two trains are available from the donor unit, and perform an associated
10 CFR 50.59 review