The inspectors identified a Green
NCV of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee failed to adequately correct a previously identified issue associated with the performance of OST-1081, Containment Visual Inspection when Containment Integrity is Required. Specifically, on June 3, 2012 during an independent containment closeout inspection by the NRC resident inspectors, cables were identified as not having been analyzed for the impact on the operation of the containment
sumps. The licensee did not identify or reconcile the unanalyzed cables in containment during the performance of OST-1081. The licensee removed a large portion of the cabling and then completed an operability evaluation, while in mode 3, on June 6, 2012 for the cables that remained. The evaluation concluded that the containment
sump was fully
operable, but with reduced margin because of the cables. The cables were further analyzed and recorded in
Engineering Change 87249, with a similar conclusion. The issue was placed into the corrective action program (
CAP) as action request (
AR) #566201. The licensees failure to adequately identify and take prompt corrective actions to evaluate temporary cables in containment during OST-1081, which had not been previously analyzed was identified as a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the
Mitigating Systems Cornerstone and it adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, it could potentially cause one or more
Residual Heat Removal (
RHR),
Containment Spray (
CT) pumps, and associated
Emergency Core Cooling Systems (
ECCS) trains to be
inoperable in the event that the containment
sump became clogged and lost the required Net Positive Suction Head (
NPSH) to the pump, during certain accidents. Using
IMC 0609,
Significance Determination Process, this finding was determined to be of very low safety significance because it was not a design or qualification deficiency, did not represent an actual loss of function of at least a single train for greater than the Allowed Out-of-service Time (
AOT) or two separate safety systems out-of-service for greater than the
AOT, did not result in a loss of safety function of one or more non-Technical Specification (TS) trains of equipment designated as risk significant for greater than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g., seismic
snubbers, flooding barriers, tornado doors). The finding had a cross-cutting aspect of Evaluation of Identified Problems, as described in the Corrective Action component of the Problem Identification and Resolution cross-cutting area, because the licensee did not implement adequate corrective actions to prevent recurrence of unanalyzed material left in containment following the performance of OST-1081
