05000382/FIN-2017008-04
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Finding | |
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| Title | Potential Failure to Obtain a License Amendment for Changes to Diesel Generator Surveillance Test Interval |
| Description | The team identified an unresolved item for the licensees failure to perform a 10 CFR 50.59 safety evaluation and subsequently obtain a license amendment for changes to the surveillance testing frequency of the emergency diesel generators. The licensees process for changing surveillance test intervals is controlled by Technical Specification 6.5.18, Surveillance Frequency Control Program. The licensees changes to the surveillance test intervals are made in accordance with NEI 04-10, Risk Informed Method for Control of Surveillance Frequencies, Revision 1, as written in procedure EN-DC-355, Engineering Evaluation of Proposed Surveillance Test Interval Changes, Revision 2. The team reviewed the licensees changes to the surveillance test interval, as required by Technical Specification Surveillance Requirements 4.8.1.1.2.e, for emergency diesel generators. The licensee changed the surveillance test interval for the train A and B emergency diesel generators from both emergency diesel generators tested every 18 months to each emergency diesel generator tested every 36 months. The team determined that testing the emergency diesel generators once every 36 months was contrary to guidance in Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants, Revision 4. Specifically, Section 2.3.2.3, Refueling Outage Testing, requires the capability of the overall emergency diesel generator design should be demonstrated during every refueling outage not exceeding a period of 24 months. The team determined that the licensee did not correctly evaluate the change to the surveillance interval in accordance with surveillance frequency control program change process. Specifically, the licensee did not correctly evaluate NEI 04-10, step 1, Check for Prohibitive Commitments, and step 2, Can Commitments be Changed? of the change process. The team determined that this change would require a 10 CFR 50.59 safety evaluation and subsequent license amendment because it would result in more than a minimal increase in likelihood of a malfunction of a component important to safety as previously described in the final safety analysis report. Specifically, the test interval would no longer meet the applicable acceptance standard, Regulatory Guide 1.9, to which the licensee is committed. Planned Closure Action(s): The NRC inspectors will review the final corrective actions, pending NRC resolution of applicability of 10 CFR 50.59 to the surveillance frequency control program. Licensee Action(s): Prior to this inspection, the licensee identified this 10 CFR 50.59 issue in the corrective action program because of industry operating experience. At the time of this inspection, the licensee had not completed the final corrective action and 10 CFR 50.59 activities.These corrective actions will be completed once industry guidance on the NRC resolution of applicability of 10 CFR 50.59 to the surveillance frequency control program was available. Corrective Action Reference(s): Condition Reports CR-WF3-2017-05590 and CR-WF3-2017-5602 NRC Tracking Number: 05000382/2017008-04 |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2017008 Section 1R21 |
| Date counted | Dec 31, 2017 (2017Q4) |
| Type: | URI: |
| cornerstone | No Cornerstone |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21M |
| Inspectors (proximate) | J Braisted N Okonkwo G Callaway |
| INPO aspect | |
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Finding - Waterford - IR 05000382/2017008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2017Q4
Self-Identified List (Waterford)
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