05000352/FIN-2018010-01
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Finding | |
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Title | Minor Violation |
Description | During this inspection, the team reviewed the details and status of Exelons corrective actions. Relative to EDG voltage, the TSs specified a lower limit of 4160 Vac; however, Exelons existing analysis determined the lower EDG voltage limit should be 4235 Vac. Exelon determined that this higher voltage value was necessary in order to ensure full EDG operability and qualification when considering a specific criteria (voltage drop during the loading sequence) as per NRC Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants. The team determined that there was not an operability concern because Exelon determined that, although the voltage drop during the starting of the largest electrical load was slightly below the Regulatory Guide 1.9 value, all required loads would, in fact, successfully start and run as designed when started at the 4160 Vac level. Further, the EDG voltage regulators are designed and calibrated to operate the EDGs at 4235 Vac. Notwithstanding, the team identified that the associated EDG surveillance procedures did not contain the higher, administrative limit of 4235 Vac as an acceptance criterion (4160 Vac was specified). The team reviewed this issue using Inspection Manual Chapter 0612, Appendix B, Issue Screening, and determined that the use of non-conservative acceptance criterion was a minor procedure violation because the EDGs were controlled and operated to maintain voltage at 4235 Vac (and 4160 Vac does not render the EDGs inoperable), and EDG reliability or availability were not adversely affected. Exelon entered this minor violation in their corrective action program as IR 4164579 to document and correct this deficiency. For EDG frequency, the TSs allowed an acceptance band (58.8 61.2 Hertz), which is a range typical of EDG transient loading conditions. However, as described in WCAP-17308-NP, and as determined by Exelon engineering staff, a more narrow band (59.9 60.2 Hertz) is the appropriate operating range for steady state EDG operation. Exelon has appropriately maintained the narrow band as the acceptance criteria in the associated EDG surveillance procedures (compensatory action until TSs are revised). However, during this inspection, the team identified that in 2016, Exelon had slightly widened the acceptable band a one-tenth hertz to 59.8 60.2 Hertz. Further review by the team identified that this change was not properly evaluated in accordance with Exelons procedure change process. In particular, the procedure change received a less rigorous review than a 10 CFR 50.59 screen would have provided; and the team concluded that this screen should have been performed. In response, Exelon evaluated past surveillance results and analyzed the lower frequency value of 59.8 Hertz, and determined there to be no adverse consequence at 59.8 Hertz. The team reviewed Exelons analysis and similarly concluded that there was no adverse safety impact. The team reviewed this issue using Inspection Manual Chapter 0612, Appendix B, Issue Screening, and determined that the improper procedure change was a minor procedure violation because there were no adverse consequences and EDG reliability or availability were not adversely affected. Exelon entered this minor violation in there corrective action program as IR 4160819 and IR 4161542 to document and correct this deficiency. |
Site: | Limerick |
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Report | IR 05000352/2018010 Section 1R21 |
Date counted | Sep 30, 2018 (2018Q3) |
Type: | Violation: Severity level Minor |
cornerstone | No Cornerstone |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21M |
Inspectors (proximate) | S Pindale J Ayala E Burket L Mckown S Kobylarz M Yeminy M Gray |
Violation of: | Technical Specification |
INPO aspect | |
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Finding - Limerick - IR 05000352/2018010 | |||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2018Q3
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