05000352/FIN-2016004-01
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Finding | |
|---|---|
| Title | Failure to Demonstrate Effective Preventive Maintenance Under 50.65(a)(2) for the Instrument Air System |
| Description | Green. The inspectors identified a Green NCV of 10 Code of Federal Regulations (CFR) 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Exelon did not demonstrate that the performance of the Unit 1 instrument air system had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor against licensee-established goals in accordance with 10 CFR 50.65(a)(1). Specifically, the inspectors identified that the instrument air system reliability performance monitoring did not properly account for instrument air compressor failures such that the system exceeded the performance criteria established by Exelons procedures. Exelon entered the issue into the corrective action program (CAP) as IR 3961244. This issue is more than minor because it adversely affected the equipment performance attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the instrument air system reliability performance monitoring did not accurately account for multiple functional failures that resulted in the system exceeding the performance criteria established by Exelons procedures. Additionally, this finding was similar to example 7.d of IMC 0612, Appendix E, in that appropriate preventive maintenance under 10 CFR 50.65 (a)(2) was not demonstrated. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelons staff did not adequately implement the procedures for reliability performance criteria evaluation. Specifically, Exelon did not verify that the established performance criteria for train reliability accurately monitored the scope of the function and demonstrated the effectiveness of maintenance when performing functional failure determinations and the periodic 10 CFR 50.65(a)(3) assessment. [H.8] |
| Site: | Limerick  |
|---|---|
| Report | IR 05000352/2016004 Section 1R12 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | D Schroeder J Deboer M Fannon M Orr P Boguszewski P Ott S Barr S Haney S Rutenkroger |
| Violation of: | 10 CFR 50.65 10 CFR 50.65(a)(1) 10 CFR 50.65(a)(2) 10 CFR 50.65(a)(3) Technical Specification |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Limerick - IR 05000352/2016004 | ||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2016Q4
Self-Identified List (Limerick)
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