A violation of Unit 1
Technical Specification 3.8.1,
AC Sources - Operating, was identified for the licensees failure to satisfy Limiting Condition for Operation 3.8.1 in that painting activities conducted on the Unit 1 Train B
EDG 1-02 resulted in paint being deposited and left in a location that caused the
EDG to become
inoperable. As a result,
EDG 1-02 failed to start on demand during the subsequent monthly surveillance test. Following the discovery of the condition, the required actions were satisfied; however, the time period between the occurrence of the condition and the discovery of the condition exceeded the allowed outage time. This issue was entered into the licensees corrective action program as SMF-2007-03253. The finding was greater than minor because it was associated with the human performance attribute of the
mitigating systems cornerstone, and it affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The Phase 1 Worksheets in Manual Chapter 0609,
Significance Determination Process, were used to conclude that a Phase 2 analysis was required because the performance deficiency affected the emergency power supply system that is a support system for both mitigating and containment barrier systems. Based on the results of the Phase 2 analysis, the finding was determined to have low to moderate safety significance (White). The senior reactor analyst determined that a more detailed Phase 3 analysis was needed to fully assess the safety significance. Based on the results of the Phase 3 analysis, the finding was determined to have low to moderate safety significance (White). The Phase 1, 2, and 3
Significance Determination Process analyses associated with this finding, including assumptions and limiting core damage sequences, is included as Attachment 3 to this report. The cause of this finding was determined to have a crosscutting aspect in the area of human performance associated with work practices in that the licensee failed to provide adequate supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported
H.4(c). Specifically, the actions planned and taken to assess and control the operational impact of the painting activities on the functionality of the
emergency diesel generator were not reflective of adequate supervisory and management oversight of the activities (Section 2.1).
