The inspectors identified a non-cited violation of
10 CFR Part 50, Appendix B, Criteron V, Instructions, Procedures, and Drawings, for the failure to follow Procedure
0PGP04-ZA-0002, Condition Report Engineering Evaluation, Revision 18. On February 25, 2013, cavitation damage was discovered during a scheduled inspection of train C essential cooling water return throttle valve to the component cooling water heat exchange valve 2-EW-0101. A reportability review was performed by civil and mechanical design engineering personnel using Procedure
0PGP04-ZA-0002. Step 3.0 of this procedure stated that the engineering supervisor and the preparer are responsible for ensuring that the evaluation is technically and administratively correct. The inspectors determined that the evaluation was not technically correct because nonconservative values were used for
carbon steel, and there was no discussion on
aluminum bronze. The licensee entered this issue into the corrective action program as Condition Report 13-3170. Corrective actions included revising the original evaluation, generating a lessons learned for the engineering department, and creating an action item to evaluate revising the procedure to more clearly define roles and responsibilities for cross discipline evaluations. This finding was more than minor because it affected the
Mitigating Systems Cornerstone attribute of Human Performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, using non-conservative values in a reportability evaluation which resulted in significant calculational errors requiring the evaluation be revised. The inspectors performed the significance determination using NRC
Inspection Manual Chapter 0609 because the finding affected the
Mitigating Systems Cornerstone while the plant was at power. Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, evaluates the finding using Appendix A. Using Appendix A, Exhibit 2,
Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it was not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; and did not result in the loss of one or more trains of nontechnical specification equipment. In addition, the NRC determined the finding had a human performance cross-cutting aspect, associated with work practices, because error prevention techniques such as self and peer checking were not performed commensurate with risk of the assigned task
