The team identified a non-cited violation of
10 CFR Part 50, Appendix B, Criteria III, Design Control, for the licensees failure to update calculations to account for non safety-related loads supplied by the
emergency diesel generator through non-qualified isolation devices and the cumulative impact on diesel fuel oil consumption. Specifically, prior to April 1, 2013, Calculation EA-FC-92-072, Diesel Generator
Transient Loading Analysis Using EDSA Design Base 3.0, Revision 6, failed to account for the additional diesel fuel oil consumption that would occur due to the loads that would be supplied from the
emergency diesel generators through non-CQE isolation devices. The licensee modified Calculation EA-FC-92-072 to address the teams concerns. This issue has been entered into the corrective action program as Condition Report CR 2013-09817. The performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the
Mitigating Systems Cornerstone 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 this performance deficiency affected the calculation used to determine the required diesel fuel oil inventory for an accident or a loss of offsite power occurring from at power conditions, the team used Manual Chapter 0609, Appendix A, The
Significance Determination Process for Findings At-Power, and determined the finding to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees
maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and - 11 - resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate the condition identified in Condition Report CR 2013-04594 to determine its impact to
emergency diesel generator fuel oil consumption
