The inspectors identified a noncited violation of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure of licensee personnel to correct a
condition adverse to quality - removal of rigid seismic restraint for valve
2CV-5672-1,
containment spray pump
2P-35B minimum recirculation valve, in the support of motor-operated valve actuator maintenance with an invalid engineering change to support the
containment spray systems seismic operability licensing basis. This condition should have caused Unit 2 to enter
Technical Specification 3.0.3 for 31 minutes on October 15, 2009. The inspectors had previously identified that the licensee was incorrectly applying
ASME Code,
Section III, Appendix F allowables to maintain operability for planned preventative maintenance. This issue was originally entered into the corrective action program as Condition Report CR-ANO-C-2009-1408. The licensee took action to cancel several engineering change documents, but did not review previously approved work orders to ensure that the removal of rigid seismic restraints would be prevented. This issue has been entered into the licensees corrective action program as Condition Reports CR-ANO-C-2009-2193, CR-ANO-2-2009-3356, and CR ANO-2-2009-3794. The failure to correct a
condition adverse to quality associated with the removal of motor-operated valve actuator seismic restraints without a valid engineering evaluation was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against external events attribute of the
Mitigating Systems Cornerstone and directly affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences and is therefore a finding. Specifically, the engineering change used to justify seismic operability was invalid and should not have been used to support continued operability and had been cancelled for future use. Using
NRC Manual Chapter 0609,
Significance Determination Process, Phase 1 Worksheets,
Mitigating Systems Cornerstone, the finding was determined to have very low safety significance because it did not represent an actual loss of safety function and did not screen as potentially risk significant due to a seismic initiating event. The cause of this finding was determined to have a crosscutting aspect in the area of human performance associated with resources
H.2(c) in that the licensee failed to have complete and accurate procedures to prevent engineering changes that had been cancelled from being used in work orders that had been previously planned and approved for work
