Technical Specification 6.8.1.g, Procedures and Programs, requires that written procedures shall be established, implemented, and maintained covering
fire protection program implementation. Contrary to this requirement, Exelon failed to establish an adequate
remote shutdown procedure to align
RCIC pump suction to the suppression pool as assumed and analyzed in the fire
safe shutdown analysis. Specifically, Exelon did not ensure that procedure
SE-1.
Remote Shutdown, contained the proper steps to align the
RCIC pump suction to the suppression pool while operating the system at the
remote shutdown panel for a fire in the main control room or the cable spreading room. The issue was entered into Exelons corrective action program as IR 843591. The finding was more than minor because it is associated with the procedural quality attribute of the
Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the availability and reliability of the
RCIC system under postulated fire safe-shutdown conditions. The inspectors determined that the finding was of very low safety significance (Green), based on
IMC 0609, Appendix F, Fire Protection
Significance Determination Process, Phase 2 screening, Task Number 2.3.5, because no credible fire ignition source scenarios were identified
