Contrary to
TS 6.8.1, Procedures and Programs, the licensee failed to implement the written procedures recommended in Appendix A of
Regulatory Guide 1.33, Revision 2, dated February 1978, regarding
PM of safety-related equipment. Specifically,
Regulatory Guide 1.33 Appendix A Section 9.b states, in part, that system parts that have a specific lifetime should be replaced. The licensee implements this guidance in
Regulatory Guide 1.33 by following the
PM program,
ER-AA-204, Preventive Maintenance Program Strategy, Revision 5, which details how
PM should be developed and implemented for safety-related equipment. Section 3.2.9 of this procedure states, in part, that to ensure inclusion of vendor technical information, vendor maintenance recommendations should be included in
PM bases and frequency requirements. The ESI-EMD owners group recommends a 10-year life for
EDG speed switches based on electrolytic capacitor life expectancy. However, there is no evidence that the licensee considered vendor recommendations regarding the periodicity of
EDG speed switch replacement when implementing its
PM on the
EDG. As a result, the existing
PM for the speed switches was inadequate and led to the 1A
EDG being rendered
inoperable when the speed switch failed to function properly during manual local start of the
EDG. This violation was associated with the
Mitigating Systems Cornerstone and was determined to be of very low safety significance (Green) in accordance with Manual Chapter 0609 Appendix A, The
Significance Determination Process (
SDP) for Findings At-Power, because the finding did not result in a loss of system function or represent an actual loss of function of at least a single train for greater than its TS allowed outage time. The licensee entered this violation into its
CAP as
AR 2053060.
