A NRC-identified non-cited violation (
NCV) of
10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified for the licensees failure to implement the requirements of their modification program. Surface grading work for the nuclear
service water (RN) piping replacement modification was not reviewed to ensure it did not impact the CMH-2
sump pump function to eliminate accumulated water. Licensees corrective actions included unclogging the
sump pump discharge outlet, replacing the
sump pump, and extending the height of the discharge outlet. The performance deficiency was more than minor because it was associated with the
Mitigating Systems cornerstone attribute of Protection Against External Factors - Flood Hazard and adversely affected the cornerstone objective in that the design modification activities affected the CMH-2
sump pump function to prevent water accumulation in the safety-related manhole structure. The inspectors determined that the finding was of very low safety significance because the accumulated water in CMH-2 did not result in the loss of operability or functionality of safety-related structures, systems, and components (
SSCs). The finding was associated with the aspect of appropriate and timely corrective actions of the Corrective Action Program component in the Problem Identification and Resolution cross-cutting area in that the licensee identified in August 2011 (
PIP C-11-6342) that the
sump pump discharge outlet needed to be raised; however, corrective actions were not implemented that would have prevented the blockage during the grading activities.
