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Contrary to Technical Specification 5.5.1. … Contrary to Technical Specification 5.5.1.1.a, and Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Procedure SO23-3-3.23.1, SSD Second Point of Control Tests HS-1669A1, G002 Governor & Exciter Control, and HS- 1670A1, G002 D/G Control, Revision 37 was inadequate in that it contained technical errors, resulting in inadequately performed surveillance tests on both units emergency diesel generators since 2002. The licensee invoked Licensee Controlled Specification 3.0.100.3 for the missed surveillances, and initiated Nuclear Notifications NNs 201085898 and NN 201088541 to place an administrative hold on the procedure and perform an extent of condition review. The licensee performed a risk evaluation and determined the surveillances could be performed within the specified Licensee Controlled Specification 3.7.113.1.11 frequency of 48 months. The licensee initiated Nuclear Notification NN 201094554 to perform a formal evaluation of the issue. The performance deficiency is more than minor, and therefore a finding, because, if left uncorrected, it would have the potential to lead to a more significant safety concern by having technically inaccurate procedures being used on important plant systems. This finding is associated with the procedure quality attribute of the Mitigating Systems Cornerstone. Using Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Attachment 2, Degradation Rating Guidance Specific to Various Fire Protection Program Elements, the inspectors determined that the finding constituted a high degradation of the safe shutdown area since the surveillance procedure could not be performed as written. The finding screened to a phase 3 analysis. The Phase 3 results determined this finding to have very low safety significance because the fire scenarios that would have resulted in a loss of control of the emergency diesel generator would not have caused a loss of offsite power. Therefore, the only scenario that would have resulted in a risk impact is a consequential loss of offsite power (grid-centered, caused by the plant trip itself), for which the conditional probability is 8E-3 per plant trip. Combined with the fire ignition frequency, severity factor, and suppression capability, the frequency of the scenario of interest fell below 1.0E-6/yr.the scenario of interest fell below 1.0E-6/yr.

Discovered date

23:59:59, 31 December 2010 +

Docket

05000361 + and 05000362 +

Event date

23:59:59, 31 December 2010 +

Finding integer

5 +

Finding type

Non-cited violation +

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Identified by

Licensee-identified +

Inspection report

IR 05000361/2010005 +

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15:41:00, 30 May 2018 +