The inspectors identified a non-cited violation of
10 CFR 50.65(a)(4) because the licensee did not assess and manage the increase in online risk involved with maintenance activities that lifted heavy loads over safety related equipment. Specifically, the licensee did not assess and manage the integrated plant online risk prior to performing heavy load lifts in the train B dry
cooling tower fan area when installing a temporary work platform to support the
steam generator replacement project. As a result, the licensee did not implement additional risk management actions as required by their procedure
EN-WM-104, OnLine Risk Assessment. The licensee entered this condition into the corrective action program as
CR-WF3-2012-4195 and
CR-WF3-2012-4489. The immediate corrective action taken to restore compliance was to re-evaluate and change the integrated risk classification from a normal risk to a high-risk level and implement the required risk management actions. The failure to adequately assess and manage overall plant risk prior to performing maintenance activities that lifted heavy loads over the train B dry
cooling tower fan area was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the
Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensees failure to identify non-standard lifts over safety related equipment as high risk prevented the licensee from taking additional risk management actions to limit the likelihood of an event that would upset plant stability. The inspectors used NRC Inspection Manual 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. The initial screening directed the inspectors to use Appendix K Maintenance Risk Assessment and Risk Management
Significance Determination Process to determine the significance of the finding. In accordance with NRC
Inspection Manual Chapter 0609, Appendix K, a senior reactor analyst determined that the finding was very low safety significance (Green) because the bounding risk deficit was approximately
1E-7/year. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in the decision making component of the human performance area because the licensee did not make safety significant or risk significant decisions using a systematic process to ensure safety was maintained
