05000352/FIN-2017003-02
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | LGS Unit 1 Renewed Facility Operating License, NPF- 39, and LGS Unit 2 Renewed Facility Operating License, NPF- 85, License Condition 2.C.(3) requires , in part, that Exelon Generation Company shall implement and maintain all provisions of the approved Fire Protection Program as described in the UFSAR. LGS Unit 1 and Unit 2 UFSAR Chapter 9A requires compliance with Branch Technical Position, Chemical Engineering Branch 9.5- 1, guideline C.5.b(1), to limit fire damage so that one train of systems necessary to achieve and maintain cold shutdown conditions from either the control room or emergency control station can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Contrary to the above, from July 2014 to December 2016, an unanalyzed condition existed in which an abnormal ESW system alignment placed two Fire Areas in noncompliance with the FSSD analysis described in the UFSAR. Specifically, in July 2014, ESW to RHRSW flow return valve, HV -011 -015A was de- energized and tagged closed following ESW system testing. With on ly one RHRSW return path available to the A ESW loop, a postulated fire in Fire Area 12 or Fire Area 18 could cause a single spurious valve operation of either spray pond bypass valves HV -012- 031A or HV -012 -031C, when the ESW system is aligned in the spray pond winter bypass mode. This condition would result in no return flow path for the A loop of ESW, which would in turn result in loss of cooling water to EDGs aligned to the A ESW cooling loop. The affected EDGs would be inoperable until the ESW system could be realigned to provide cooling water flow. This condition coupled with a loss of offsite power assumed in FSSD analysis would result in a loss of power to SRVs needed to transition both LGS units from hot shutdown conditions to cold shutdown conditions. Following the depletion of station batteries after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, until offsite power is assumed to be restored after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, direct current power would be lost to SRVs that are necessary to reduce plant pressure low enough to place the shutdown cooling system into service and establish cold shutdown plant temperatures. The failure to have a cold shutdown repair that could be implemented within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in accordance with the FSSD analysis described in the UFSAR, was a performance deficiency. 24 The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance (Green ), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process , Attachment 1, Part 1: Fire Protection Significance Determination Process Phase 1 Worksheet, dated September 2013. The finding screened to Green based upon task 1.3.1 screening question A, since the inspectors determined that for conditions evaluated by Appendix F the reactors were able to reach and maintain hot shutdown. Specifically, LGS Units 1 and 2 would have been able to achieve and maintain hot shutdown during the period the unanalyzed condition existed. This would have been accomplished by using HPCI and SRVs for pressure and level control. Both units would have been capable of maintaining hot shutdown conditions with postulated fire damage until offsite power could be restored. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program as IR 3955705, this finding is being treated as a licensee identified NCV , consistent with Section 2.3.2.a of the Enforcement Policy. |
| Site: | Limerick  |
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| Report | IR 05000352/2017003 Section 4OA7 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | S Rutenkroger M Fannon H Anagnostopoulos K Mangan M Modes C Hobbs A Turilin D Schroeder |
| Violation of: | License Condition - Fire Protection |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2017003 | ||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2017Q3
Self-Identified List (Limerick)
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