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The inspectors identified a Green NCV of T … The inspectors identified a Green NCV of Technical Specification (TS) 5.4.1.a for Exelons failure to adequately establish and maintain procedures as required by Regulatory Guide (RG) 1.33, Appendix A, Section 3, Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems. The inspectors determined that Exelons failure to adequately establish and maintain a procedure for the operation of the diesel fuel oil (DFO) supply system was a performance deficiency. Exelon entered this issue into their corrective action program (CAP) as issue report (IR) 02541107. Exelons immediate corrective actions included halting of opening of 0-DFO-108, 21 Fuel Oil Storage Tank (FOST) to Auxiliary Boilers Isolation, and initiating an evaluation to determine the seismic adequacy of the piping downstream of 0-DFO-108. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the protection against external factors attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to adequately establish and maintain procedure Operating Instruction (OI)-21D, Fuel Oil Storage and Supply, Revision 10, for the operation of the DFO supply system resulted in the alignment of the safety-related 21 FOST to nonsafety-related/non-seismically qualified piping thus rendering the 21 FOST inoperable. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, and Exhibit 4, External Events Screening Questions, issued on June 19, 2012, the inspectors determined that a detailed risk evaluation was necessary to disposition the significance of this finding because the loss of the 21 FOST would degrade two or more trains of a multi-train system or function. A regional Senior Reactor Analyst (SRA) performed a detailed risk evaluation and determined the finding to be of very low safety significance (Green). The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, because Exelon failed to adequately evaluate relevant external operating experience. Specifically, Exelon failed to evaluate for systems where non-seismically qualified piping could be connected to safety-related tanks as was described in Information Notice (IN) 2012-01, Seismic Considerations Principally Issues Involving Tanks. (P.5).Principally Issues Involving Tanks. (P.5).
23:59:59, 30 September 2015 +
23:59:59, 30 September 2015 +
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12:57:49, 25 September 2017 +
23:59:59, 30 September 2015 +
Failure to Establish and Maintain Procedures for the Operation of the Diesel Fuel Oil System +