05000352/FIN-2011002-01
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Finding | |
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Title | Failure to Address Repeat TS Response Time Test Failures |
Description | The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVl, Corrective Action Program, because Exelon did not adequately evaluate and correct a condition adverse to quality regarding repeat failures of a Technical Specification (TS) surveillance test (ST). Specifically, on July 13,2010, Exelon generated issue report (lR) 1091132to document that ST-2-041-909-2,the Unit 2 Main Seam Line (MSL) Flow - High Response Time Test, had failed its past two performances. In both instances, in October 2008 and July 2010, multiple response time values exceeded the TS requirements, and Exelon had to replace several relays to bring the values back into compliance. After the 2008 failure Exelon performed an apparent cause evaluation (ACE) and generated one corrective action (CA) and several action items (AClTs) to address the causes. Following the 2010 failure, Exelon did not evaluate the repeat failure or generate any additional actions. The inspectors determined that the CA and ACITs from 2008 did not thoroughly address the MSL Flow - High test failure, and the repeat test failure in 2010 was an opportunity for Exelon to re-evaluate the issue and pursue more appropriate and timely corrective actions. Exelon\'s failure to evaluate and correct a condition adverse to quality regarding repeat failures of a TS surveillance test was determined to be a performance deficiency (PD). The PD was determined to be more than minor because it was associated with the System, Structure, and Component & Barrier Performance attribute of the Reactor Safety - Barrier lntegrity cornerstone. The PD adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was determined to be of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, because it did not represent an actual open pathway in the physical integrity of reactor containment. The inspectors determined this finding had a cross-cutting aspect in the area of Problem ldentification and Resolution, Corrective Action Program, because Exelon did not thoroughly evaluate the repeat MSL response time test failures to ensure the underlying causes were identified and resolved. |
Site: | Limerick |
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Report | IR 05000352/2011002 Section 4OA2 |
Date counted | Mar 31, 2011 (2011Q1) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | E Dipaolo T Moslak N Sieller |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Limerick - IR 05000352/2011002 | ||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2011Q1
Self-Identified List (Limerick)
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