The inspectors identified a non-cited violation (
NCV) of
10 CFR 50.65(a)(4) for the licensees failure to provide sufficient details for equipment protection in the approved Critical Activity Plan. In addition, the risk mitigation actions contained in the plan intended to manage and minimize the increased plant risk associated with work on the Unit 2 A Train of Component Cooling Water (KC) were not effectively implemented. The finding was more than minor because the risk mitigation strategies in the Critical Activity Plan were not effectively implemented. In addition, the plan lacked specific guidance on what components were to be posted to provide adequate protection of the 2B train of KC. As a result, work activities were allowed to take place that could have adversely affected the remaining train of KC. This finding was determined to be of very low safety significance because the resulting magnitude of the calculated Incremental Core Damage Probability was less than
1E-5 and the licensees implementation of more than three Risk Management Actions. The finding directly involved the cross-cutting area of Human Performance under the Work Activity Coordination aspect of the Work Control component
H.3.b]. This issue has been entered into the licensees corrective action program as Problem Investigation Process report (
PIP) C-08-6133. (Section 1R13
