The inspectors identified a Green non-cited violation of
10 CFR Part 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, because Exelon did not reassess and manage risk after the grid operator declared a maximum emergency generation action, prior to performing maintenance on the B
control rod drive pump on January 30, 2014. The inspectors identified that Exelon assessment of risk was green; however, if the emergency generation action had been included in the assessment, the risk would have been yellow requiring Exelon to perform compensatory actions to limit the risk to the unit. Exelon entered this issue into their corrective action program as issue report 1614625. The inspectors determined that Exelons failure to assess and manage risk prior to performing maintenance on the B
control rod drive pump after the grid operator declared a maximum emergency generation was a performance deficiency that was reasonably within Exelons ability to foresee and correct. This finding is more than minor because it is associated with the configuration control attribute of the
Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The inspectors used NRC inspection manual chapter 0609, appendix K, flowchart 2, Assessment of Risk Management Actions, to determine the significance of this finding. The inspectors determined that the finding is of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance because operators did not stop when faced with uncertain conditions and evaluate and manage risks before proceeding as scheduled. Specifically, the operators continued maintenance without reassessing risk after the inspectors questioned the rationale for not entering the grid emergency procedure [H.11].