Technical Specification 5.4.1, Procedures, requires that procedures be established, implemented, and maintained covering the applicable procedures in
Regulatory Guide 1.33.
Regulatory Guide 1.33, Appendix A, Section 9 requires, in part, that maintenance that can affect the performance of safety-related equipment be properly preplanned and performed in accordance with written procedures. Contrary to the above, prior to October 1, 2015, licensee work management personnel failed to perform an activity affecting quality in accordance with written procedures. Specifically, the licensee did not conduct an adequate review of technical specification LCO implications of a planned Unit 2 essential
spray pond outage in accordance with procedure
51DP-9OM08, Look Ahead Process. Work planners did not recognize that the removal of two
spray pond piping spool pieces was an activity required to restore
spray pond system operability and therefore did not establish a tracking mechanism to ensure that the spool pieces were removed before the Unit 2 essential
spray pond A was declared operable. Consequently, the Unit 2 essential
spray pond A would not have been able to provide cooling to the essential cooling water heat exchanger following a seismic event. The inspectors evaluated the significance of the issue under the
Significance Determination Process, as defined in
Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and 0609 Appendix A, The
Significance Determination Process (
SDP) for Findings at-Power, dated June 19, 2012. Inspectors concluded the finding was of very low safety significance (Green) because all questions in Exhibit 2 could be answered no. The licensee entered the issue into the corrective action program as CR 15-08352. The licensee now plans and controls the removal and re-installation of
spray pond spool pieces using the stations
temporary modification process.
