05000353/FIN-2012008-01
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Finding | |
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| Title | |
| Description | The inspectors identified a SL-IV non-cited violation (NCV) of 10 CFR Part 50.73, Licensee Event Report System, because violations of Technical Specifications (TS) 3.5.1 and 3.0.3 for the condition of the high pressure coolant injection (HPCI) and RCIC systems being simultaneously inoperable were not reported to the NRC within 60 days of discovery. After this was identified by the inspectors, the issue was entered into Exelons Corrective Action Program (CAP) as IR 1377559. The inspectors determined that the failure to revise Licensee Event Report (LER) 05000353/2011-003-00 within 60 days of initial issuance on July 21, 2011 to include the violations of TS 3.5.1 and 3.0.3 in accordance with 10 CFR Part 50.73 was a performance deficiency that was reasonably within Exelons ability to foresee and correct, and should have been prevented. Because the issue impacted the regulatory process, in that a violation of Technical Specifications was not reported to the NRC within the required timeframe and the NRCs opportunity to review the matter in its entirety was delayed, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined the performance deficiency was a SL-IV violation, because Exelon personnel did not make a report required by 10 CFR Part 50.73. The significance of the associated performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, and the inspectors determined it to be minor because it was not similar to Appendix E examples, was not a precursor to a significant event, did not cause a performance indicator (PI) to exceed a threshold, did not adversely affect cornerstone objectives, and if left uncorrected would not have lead to a more significant safety concern. As such, no ROP finding was identified and no cross-cutting aspect was assigned. |
| Site: | Limerick  |
|---|---|
| Report | IR 05000353/2012008 Section 4OA4 |
| Date counted | Jun 30, 2012 (2012Q2) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 95001 |
| Inspectors (proximate) | P Finney D Roberts E Bonney |
| INPO aspect | |
| Finding closed by | |
| IR 05000352/2012008 (2 August 2012) | |
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Finding - Limerick - IR 05000353/2012008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2012Q2
Self-Identified List (Limerick)
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