05000280/FIN-2013002-02
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section 2.3.2 of the NRC Enforcement Policy, for disposition as a NCV. FnSurry Technical Specification 6.4.A.2 requires, in part, that detailed written procedures with appropriate instructions shall be provided for conditions which include: calibration and testing of components involving nuclear safety of the station. These requirements are implemented, in part, by Dominion procedure 0-ECM-0704- 03, EDG Data Acquisition System (DAS), Rev. 34. Contrary to the above, since 1998, Dominion procedure 0-ECM-0704-03 has been inadequate to ensure the continued operability of the emergency diesel generators. Specifically, the level of detail in the procedure steps was not consistent with the complexity of the installation and removal of the DAS equipment to ensure the as-left condition of the EDG automatic voltage regulator (AVR) control cabinet was acceptable following disconnection of the EDG DAS such that the EDG would remain operable. Specifically, EDG No. 3 was inoperable for 33 days due to a lifted lead in the AVR cabinet that was inadvertently removed from its landed position during the disconnection of the DAS on November 3, 2012. The inspectors determined that the finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Because EDG No. 3 is the swing diesel, this issue affects both Surry Unit 1 which was operating at full reactor power during this period, as well as Surry Unit 2 which was in a refueling outage. The finding was to have impact to short term and long term decay heat removal and required further risk evaluation in accordance with IMC 0609 Appendix A Significance Determination Process (SDP) for Findings At-Power for Unit 1 and 0609 Appendix G Shutdown Operations Significance Determination Process for Unit 2. A detailed SDP risk evaluation was performed by a regional SRA per NRC IMC 0609 Appendix A and G guidance using the NRCs SPAR risk model for Surry and the Saphire 8 risk code. Input was also used from the licensees full scope Surry risk model and the Surry Individual Plant Examination of External Events and Fires. The analysis used a 33 day exposure period and no recovery credit was assumed for EDG No. 3. The dominant core damage sequences included Loss of Offsite Power (LOOP) leading to a Loss of Reactor Coolant Pump Seal Cooling and Failure of High Pressure Injection and a LOOP leading to Station Blackout. The risk was mitigated by the availability of the alternate EDG and the Station Blackout Diesel. The result of the risk evaluation was an increase in core damage frequency of <1E-6 per year for both Unit 1 and 2. The finding was determined to be of very low safety significance (Green) finding and has been entered into the licensees CAP as CR 499318. |
| Site: | Surry  |
|---|---|
| Report | IR 05000280/2013002 Section 4OA7 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | J Nadel G Mccoy P Capehart J Heath K Schaaf |
| Violation of: | Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Surry - IR 05000280/2013002 | |||||||||||||||||||||||||||||||||||||||||
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Finding List (Surry) @ 2013Q1
Self-Identified List (Surry)
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