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Green. The inspectors identified a findingGreen. The inspectors identified a finding of very low safety significance and a non-cited violation of 10 CFR 50.65(a)(2), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to demonstrate that the condition of flood seals was being effectively controlled through the performance of appropriate preventive maintenance such that the seals remained capable of performing their intended function. Specifically, the licensee failed to visually inspect more than 700 flood seals per procedure ERAA450, Structures Monitoring, and procedure ERCL4501007, Clinton Surveillance Inspection Program for Seals. As corrective actions, the licensee visually inspected all accessible flood seals and evaluated the acceptability of the inaccessible seals. In addition, the licensee planned to modify ERAA450 to clarify the frequency of the flood seal inspection. The inspectors determined the licensees failure to demonstrate that the condition of flood seals was being effectively controlled through the performance of appropriate preventive maintenance was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected it could become a more significant safety concern. Specifically, the failure to monitor the condition of the flood seals could result in unrecognized flood seal degradation and result in seals being incapable of performing their intended function. The inspectors screened this finding against the Mitigating Systems cornerstone and concluded the finding was of very low safety significance because it did not involve the loss or degradation of equipment or a function specifically designed to mitigate a seismic, flooding or severe weather initiating event. This finding affected the cross-cutting area of Problem Identification and Resolution, in the aspect of identification, where the organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee failed to identify the flood seals still had not been inspected when they performed the Maintenance Rule ProgramStructures Monitoring Assessment which credited ERCL4501007 in early 2014. (P.1) credited ERCL4501007 in early 2014. (P.1)  
23:59:59, 31 December 2016  +
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23:59:59, 31 December 2016  +
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00:55:25, 21 February 2018  +
23:59:59, 31 December 2016  +
Failure to Demonstrate the Condition of Flood Seals Was Being Effectively Controlled  +