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The following violation of very low safety … The following violation of very low safety significance (Green) was identified by FENOC and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV . TS 3.7.8, "Service Water System", requires two service water trains to be operable. There is no associated action provided for both trains inoperable. LCO 3.0.3 states, in part, that when an LCO is not met and an associated action is not provided, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Act ion shall be initiated within one hour to place the unit, as applicable, in M ODE 3 within 7 hours. Contrary to the above, on August 20, 2015 and August 31, 2015 , FENOC had both trains of service water inoperable for greater than 7 hours while performing the service water full flow test and did not place Unit 2 in Mode 3. FE NOC entered this issue into the CAP as CR 2017- 04023. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings . Because the finding represented a loss of function of a system, a detailed risk evaluation was performed. A Region I senior reactor analyst used the BVPS Unit 2 Standardized Plant Analysis Risk Model version 8.5 to perform the evaluation. A seismic initiating event frequency was obtained from the Risk Assessment of Operational Events Handbook Volume 2, External Events. A surrogate loss -of-offsite - power event was used applying the seismic initiating event frequency for BVPS with a train of service water being failed with no recovery assumed. The finding was determined to be of very low safety significance (Green) because the limited exposure time in this configuration resulted in a change in core damage frequency in the 1E -10/yr range. The dominant core damage sequence was a seismic event with failure of the EDG .a seismic event with failure of the EDG . +
23:59:59, 30 June 2017 +
23:59:59, 30 June 2017 +
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15:56:01, 30 May 2018 +
23:59:59, 30 June 2017 +