The inspectors identified a non-cited violation (
NCV) of very low safety significance of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for not ensuring that the adequacy of
PBAPS emergency diesel generator (
EDG) lubrication oil (
LO) supply was designed to withstand the effects of natural phenomena. Specifically, additional
LO, evaluated by
PBAPS to meet their
EDG technical specification (TS)
mission time of seven days of continuous operation, was housed in a non-class I structure that would be unable to withstand the effects of natural phenomena.
PBAPS entered the issue into the correction action program (
CAP) as
issue report (IR) 02603369 and took immediate corrective actions to relocate the
LO reserve inventory from their warehouse to the 135 elevation of the
PBAPS radwaste building, which is a seismic class I structure The finding is considered more than minor because it is associated with the Protection Against External Factors attribute of the Reactor Safety
Mitigating Systems cornerstone and adversely affected the cornerstones objective of ensuring reliability and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). The inspectors evaluated the significance of this finding using
IMC 0609 Appendix A, The
SDP for Findings at Power, Exhibit 2,
Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the finding is a design deficiency which did not result in an actual loss of functionality of the
EDGs. This finding did not have a cross-cutting aspect because the most significant contributor of the performance deficiency (
PD) occurred during the 1994 conversion to improved technical specifications (
ITS) and, thus, was not reflective of current plant performance. Specifically,
PBAPS current engineering change request (
ECR) process would evaluate for natural phenomena considerations such as seismic, tornado, flood, etc.
