The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the
NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation. Since June of 1999, the licensee cross-tied the two starting air receivers for a given
EDG when performing maintenance on one of the air start compressors.
TS 3.8.3 required that the starting air subsystem for each
EDG be within limits when the associated
EDG was required to be
operable.
TS 3.8.3 Condition D applied if one or more
EDGs had one of two starting air receiver pressures < 210 psig. The cross-tied starting air receivers reduced the number of air receivers from two to one which placed the subsystem outside the licensing basis for
TS 3.8.3 Condition D. If Condition D was not met, then Condition E required that the associated
EDG be declared
inoperable.
TS 3.8.1 Condition B required that when an
EDG was
inoperable, it should be restored to
operable status within
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If Condition B was not met, Condition G required that the unit be in Mode 3 in
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 in
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Contrary to the above, between June 29, 1999, and August 13, 2010, on multiple occasions the starting air receivers were cross-tied resulting in an
EDG being
inoperable for greater than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and the licensee not placing the unit in Mode 3 within
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or Mode 5 within
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This violation is of very low safety significance (Green) because the cross-tied air receivers remained pressurized greater than or equal to 210 psig. This violation is in the licensees corrective action program as
PIP M-10-5299.