05000277/FIN-2012003-01
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Finding | |
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Title | Inadequate Test Control to Demonstrate RCIC System Design Basis Start-up Response Time |
Description | The inspectors identified a NCV of very low safety significance of Title 10 Code of Federal Regulation (CFR) 50, Appendix B, Criterion XI, Test Control, because Exelon conducted unacceptable pre-conditioning of the reactor core isolation cooling (RCIC) system during response time testing. The performance deficiency was related to Exelons surveillance test (ST) procedure which required cold startup of RCIC to reach the rated pump discharge pressure and flow rate within 50 seconds. Exelon procedures required a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> standby period between pump starts to ensure the pump cold start design criteria are satisfied without pre-conditioning. On numerous occasions, when the pump design parameters were not reached in less than 50 seconds on the first attempt, control room operators would routinely perform a second start attempt within a short period of time, typically less than one hour, to adjust the RCIC pump controls and attain the design values in less than or equal to 50 seconds. Exelon performed an extent of condition review of Units 2 and 3 RCIC cold start test data to ensure the current pump, valve, and flow results satisfied the response time testing requirements. The violation was entered into the corrective action program (CAP) as issue report (IR)1364066. The performance deficiency was more than minor because it was similar to IMC 0612, Appendix E, Examples of Minor Issues, example 2.a. Specifically, the RCIC cold start ST procedure was not implemented adequately to ensure that the RCIC pump design discharge pressure and flow were reached within the 50 second requirement on the first attempt. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Screening and Characterization of Findings, and determined the finding was of very low safety significance (Green) because all of the mitigating system barrier questions in Table 4.a resulted in a no response. The finding included a cross-cutting aspect in the area of Work Practices, Human Performance component, because Exelon did not effectively communicate expectations regarding procedural compliance and personnel following procedures. Specifically, Exelon took credit for the Unit 2 ST performed on April 7, 2011, which started and shutdown RCIC three times in less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to satisfy the response time testing acceptance criteria. On January 20, 2011, the same test was performed for Unit 3, when the RCIC system was run two times prior to satisfying the acceptance criteria. Exelon did not identify the unacceptable pre-conditioning of the RCIC system start-up time for either test because personnel did not follow the In-service Testing (IST) Program Corporate Technical Position procedure. |
Site: | Peach Bottom |
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Report | IR 05000277/2012003 Section 1R22 |
Date counted | Jun 30, 2012 (2012Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.22 |
Inspectors (proximate) | A Rao A Rosebrook A Ziedonis D Roberts J Caruso J Furia J Laughlin P Presby S Barr S Hansell T Hedigan |
CCA | H.8, Procedure Adherence |
INPO aspect | WP.4 |
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Finding - Peach Bottom - IR 05000277/2012003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Peach Bottom) @ 2012Q2
Self-Identified List (Peach Bottom)
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