TMI License Condition 2.C.(4) and the Fire Hazards Analysis Report (FHAR) require administrative breaker position restrictions for Appendix R valves needed for
safe shutdown, including reactor coolant pump #1 seal bypass valve (MU-V-38).
TMI procedure AP-1038 is the implementing procedure for License Condition 2.C.(4) and the FHAR. On November 28, 2013, the licensee identified the breaker for MU-V-38 to be in the ON position contrary to the required OFF position. It was determined that the breaker was in the incorrect position for six (6) days of the seven (7) days allowed by the AP-1038 time clock. In that, compensatory measures and a risk assessment were not in place for this out-of-position breaker, in the event of a postulated fire and fire-induced spurious operation of MU-V-38, and the inspectors determined the issue was more than minor. The cause of the mispositioned breaker was determined by Exelon to be auxiliary operator distraction from multiple work activities and failure to restore the breaker to its expected position following post-maintenance testing during the fall refueling outage. Exelon entered this issue into their
CAP as
IR 1591314 and promptly positioned the breaker to the correct OFF position, including validation of the position of the remaining Appendix R breakers. The inspectors determined that the finding was of very low safety significance (Green) in accordance with
IMC 0609, Appendix F, Fire Protection
Significance Determination Process, based upon this Fire Prevention and Administrative Controls issue having a low degradation category.
