TS 5.4.1(a) requires the licensee to establish, implement, and maintain applicable written procedures for the safety-related systems and activities recommended in
Regulatory Guide (RG) 1.33, Revision 2, Appendix A. Section 9.a, Procedures for Performing Maintenance, of
RG 1.33, Revision 2, Appendix A, further states, in part, that: Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to this requirement, on January 26, 2012, licensee personnel failed to properly connect a strip chart recording device needed to support a planned TS surveillance on
EDG No. 2. Specifically, the improper connection on the recording equipment caused test data essential to the completion of the TS surveillance to be lost, which resulted in the need to perform the surveillance a second time. This additional performance of the surveillance added significant time to the periods of inoperability and unavailability for
EDG No. 2, and caused the licensee to make an unplanned entry into an elevated (i.e., Orange) plant risk awareness state. Upon investigation into the matter, the licensee identified that the applicable maintenance procedure controlling the connection of the strip chart recording equipment only contained detailed connection instructions for the test connections on the
EDG itself; the proper configuration for the test connections on the recording equipment was not specified within the procedure, but instead was left to the skill and knowledge of the technician performing the equipment setup. The objective of the
Mitigating Systems Cornerstone of Reactor Safety is to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). A key attribute of this objective is human performance, and specifically, procedure quality. In accordance with NRC
IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, the inspectors determined that the violation was of more than minor significance in that it had a direct impact on this cornerstone objective. The licensees failure to provide technically adequate written procedures and instructions for the connection of the strip chart recording device needed for the
EDG No. 2 TS surveillance resulted in the need to perform that surveillance a second time and added significant time to the periods of inoperability and unavailability for
EDG No. 2. The licensee had entered this issue into their
CAP as CR 2012-01367. Corrective actions planned or completed by the licensee include revision to the
EDG TS surveillance procedure to provide enhanced details on the proper connection of the strip chart recording device.
