A finding of very low safety significance and an associated
NCV of
10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, was identified by the inspectors when licensee personnel removed both the 2B and 2D Reactor Containment Fan Coolers (
RCFCs) from service without entering an elevated on-line risk status (Yellow) as required by licensee procedure WC-BY-101- 1006, On-Line Risk Management and Assessment. The licensee entered this issue into their Corrective Action Program (
CAP) as
Issue Report (IR) 01519964, 2B and 2D
RCFC OLR [On-Line Risk] Not Communicated. As part of the licensees corrective actions, on-line risk was revised to accurately reflect the removal of the 2B and 2D
RCFCs from service. The inspectors determined that the performance deficiency was more than minor because it was similar to
IMC 0612, Appendix E, Examples of Minor Issues, Example 7(e) that identified a failure to perform an adequate risk assessment when required by
10 CFR 50.65(a)(4) was not minor if the overall elevated plant risk placed the plant into a higher risk category established by the licensee. The inspectors determined the finding could be evaluated using the
Significance Determination Process (
SDP) in accordance with
IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management
Significance Determination Process. In accordance with
IMC 0609, Appendix K, and because the calculated
Incremental Core Damage Probability Deficit (
ICDPD) was not greater than
1E-6, the finding was determined to be of very low safety significance. This finding had a cross-cutting aspect in the Work Control component of the Human Performance cross-cutting area because coordination efforts between the departments responsible for evaluating and communicating on-line risk failed to identify and communicate a risk increase associated with maintenance on the 2B and 2D
RCFCs.
