05000352/FIN-2015001-02
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Finding | |
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| Title | Startup Procedure Considered High Pressure Coolant Injection Operable with High Reactor Water Level Trip Actuated Preventing High Drywell Pressure Automatic Actuation |
| Description | The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Exelon prescribed a procedure affecting quality with instructions which were not appropriate to the circumstances. Specifically, procedure GP-2, Normal Plant Startup, contained a note that stated high pressure coolant injection (HPCI) systems have been determined operable by engineering evaluation with a high level trip setpoint actuated. The inspectors determined that the note was inconsistent with Units 1 and 2 technical specifications (TS) and was not supported by an adequate engineering basis. Exelons corrective actions included briefing staff to ensure HPCI system operability is appropriately assessed when implementing GP-2, initiating condition report IR 2464416, completing a procedure revision to reference an interim evaluation contained in the condition report, and initiating an action to complete an engineering evaluation. This finding is more than minor because it is associated with the procedure quality attribute of the mitigating systems cornerstone and affected the objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, procedure GP-2 stated that the HPCI system was operable with a Level 8 trip present without the ability to automatically actuate upon a high drywell pressure without an engineering evaluation which was inconsistent with the existing safety analysis performed at normal operating reactor pressure and temperature. Using IMC 0609, Significance Determination Process, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not represent an actual loss of the HPCI system or function to inject high pressure emergency core cooling water. Specifically, the note in GP-2 allowed considering the HPCI system operable at normal operating reactor pressures with the HPCI system tripped. However, the HPCI system was not tripped at normal operating reactor pressures. The inspectors determined that the finding did not have cross-cutting aspect because the procedure development performance deficiency did not occur within the last three years, and the inspectors did not conclude that the causal factors represented present Exelon performance. |
| Site: | Limerick  |
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| Report | IR 05000352/2015001 Section 1R20 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.2 |
| Inspectors (proximate) | F Bower M Fannon R Montgomery R Nimitz S Rutenkroger B Lin E Burket E Dipaolo |
| Violation of: | Technical Specification - Procedures Technical Specification 10 CFR 50 Appendix B Criterion V |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2015001 | |||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2015Q1
Self-Identified List (Limerick)
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