Technical specification 3.2.12.1, "
LTOP Protection", requires when the reactor vessel head is installed and indicated
reactor coolant system temperature is 313F, high pressure injection pump breakers shall not be racked in unless injection valves (MU-V16A/B/C/D and MU-V217) are closed with their associated breakers open and that pressurizer level is maintained 100 inches, or restore pressurizer level to 100 inches within
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Contrary to
technical specification 3.2.12.1, during
reactor coolant system filling with the vessel head installed and temperature < 313F, high pressure injection pump breakers were racked in while pressurizer level was >100 inches for greater than
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The condition existed for
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 49 minutes until recognized by the operating crew when questioned by a senior reactor operator trainee, at which time the crew took immediate actions to reduce pressurizer level <100 inches within
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Additional corrective actions included crew remediation, additional main control room supervisory oversight, and procedure changes. Exelon entered this issue into the corrective action program as issue report 3949713. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC
IMC 0609, Appendix G, Shutdown Operations, Attachment 1, Exhibit 4, since the finding did not represent an inadvertent safety injection and did not render the power-operated relief valve (
LTOP Protection) unavailable or degraded.
