05000293/FIN-2009005-02
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Finding | |
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| Title | Procedure change to allow disabling HPCI during transients |
| Description | The inspectors identified an Unresolved Item (URI) involving10 CFR 50.59, Changes, Tests and Experiments, due to a failure to properly implement a procedure change which may have resulted in a more than minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component (SSC)important to safety.... Pilgrim incorrectly allowed an existing 50.59 evaluation to support a High Pressure Coolant Injection (HPCI) procedure change that allowed actions that were beyond the scope of the existing 50.59 evaluation. In February 2000, Pilgrim revised procedure 2.2.21.5, HPCI Injection and Pressure Control, to provide procedural direction when shutting down the HPCI system. One of the changes that were made in this revision was the addition of a new section, Section 8, Preventing HPCl lnjection, to the procedure. These changes were evaluated using NOP83E5, 10 CFR 50.59 Process, to evaluate whether this change was allowed per 10 CFR 50.59 regulations. Pilgrim concluded that the change to the facility could be made without a safety evaluation or license amendment. During the performance of a simulator exam scenario, the examiners observed the HPCI system being defeated as drywell pressure approached the automatic initiation setpoint for the HPCI system (2.2 pounds per square inch gage (psig. The system was defeated by a Reactor Operator placing the HPCI oil pump in Pull-to-Lock (PTL). This action prevents HPCI from starting in response to Emergency Safeguards Feature (ESF) .automatic initiation signals. The order to defeat HPCI was made before the automatic initiation setpoint was reached, which is also the required entry into the Emergency Operating Procedures (EOPs). The examiners requested the procedural guidance that directed this action, since the Emergency Operating Procedures (EOPs) had not yet been entered when HPCI was defeated. The examiners reviewed the revised procedure as well as the procedure change paperwork and 50.59 preliminary evaluation checklist developed to support the revised procedure. The examiners concluded that the 50.59 preliminary evaluation checklist developed to support the revision to procedure 2.2.21.5 was incorrect and did not support the procedure revision. The basis for the procedure change was to provide enhanced instructions for the operation of the HPCI System under various emergency operating modes. Several of these operations, such as pressure control and placing HPCI to 'inhibit' are required to be performed during the execution of various EOPs. These evolutions are analyzed in Emergency Procedure Guidelines (EPGs) Rev. 4 and have been approved by the NRC per SER 1.88.196.Since the procedure change can be used outside the EOPs, the EPGs and SER 1.88.196 do not fully support the conditions under which the HPCI system may be secured. Therefore, the 50.59 preliminary evaluation checklist was incorrect, and a separate safety evaluation was required to allow the HPCI system to be secured .outside the EOPs. This issue remains unresolved until the facility completes their development of a new safety evaluation to determine whether prior NRC's approval would have been required before implementing the described procedure change. URI05000293/2009005-02, Procedure change to allow disabling HPCI during transients. |
| Site: | Pilgrim |
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| Report | IR 05000293/2009005 Section 1R11 |
| Date counted | Dec 31, 2009 (2009Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.11 |
| Inspectors (proximate) | G Johnson D Jackson S Barr B Smith M Schneider D Everhart M Halter S Rich D Moltenij Richmond D Jackson S Pindale J Schoppy R Rolph B Smith M Schneider M Balazik S Rich D Molteni C William |
| INPO aspect | |
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Finding - Pilgrim - IR 05000293/2009005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2009Q4
Self-Identified List (Pilgrim)
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