05000352/FIN-2013004-02
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Finding | |
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| Title | Failure to Perform Technical Specification Surveillance Requirements on the Unit 2 Primary Containment Instrument Gas System |
| Description | The inspectors identified a Green NCV of Technical Specification (TS) 6.8.1.a, Procedures and Programs, for Exelons failure to implement surveillance test procedures specified for the Primary Containment Instrument Gas (PCIG) system as required by Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements. Specifically, Exelons PCIG local leak rate procedures, ST-4-LLR-011-2 and ST-4-LLR-241-2, incorrectly credited the surveillance testing of the PCIG supply header B check primary containment isolation valve (059-2005B) in ST-6-059-201-2 PCIG Valve Test which resulted in entry into TS 4.0.3 for a missed surveillance. Exelons corrective actions included an extent of condition review and revising PCIG check valve surveillance testing to correct the crediting of the wrong check valves due to the successful completion of Local Leak Rate Testing (LLRT). Exelon has entered this issue into their CAP as IR 1554992 and 1569903. The failure to perform the surveillance requirements specified for the PCIG system, specifically, incorrectly crediting the surveillance testing of PCIG check valve 059-2005B which resulted in a missed surveillance, is a performance deficiency. The performance deficiency was determined to be more than minor, because it adversely affected the Procedure Quality attribute of the Mitigating Systems cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon failed to ensure that the PCIG system surveillance testing adequately tested and credited the successful completion of LLRT. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because the PCIG system was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time. The inspectors determined that the finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not thoroughly evaluate problems such that resolutions address causes and extent of conditions, including properly classifying, prioritizing, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their safety significance P.1(c). Specifically, Exelon personnel did not adequately address, thoroughly evaluate, and prioritize IR 1498740 which documented potential deficiencies with Unit 2 PCIG check valve testing, in a timely manner. |
| Site: | Limerick  |
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| Report | IR 05000352/2013004 Section 1R13 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | E Dipaolo J Laughlin R Nimitz F Bower J Hawkins D Aird |
| Violation of: | Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2013004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2013Q3
Self-Identified List (Limerick)
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