05000220/FIN-2017004-01
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Finding | |
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Title | Main Control Room Annunciators 10 CFR 50.65(a)(2) Demonstration Not Met |
Description | An NRC-identified Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2), was identified because Exelon did not adequately demonstrate that the performance of the Unit 1 main control room (MCR) annunciators was effectively controlled through performance of appropriate preventive maintenance. Specifically, Exelon did not identify and properly account for functional failures of the MCR annunciators in June 2017, and therefore did not recognize that the annunciator system exceeded its performance criteria and required a Maintenance Rule (a)(1) evaluation. On December 7, 2017, Exelon entered the issue into their CAP as IR 04081698 and performed a review of the events identified by the inspectors that were applicable to the maintenance rule annunciator system. Corrective actions included Exelon determining that the events were functional failures, and initiated an (a)(1) evaluation based on the MCR annunciator system functional failures exceeding the designated performance criteria of an allowable one functional failure per 24 months.This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, following the two failures of the main control annunciator panel in June 2017, Exelon did not identify the failures as functional failures, and consequently, did not establish goals and monitoring criteria in accordance with 10 CFR 50.65(a)(1). In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating structure, system, or component (SSC), did not represent a loss of system and/or function, did not involve an actual loss of a function of at least a single train or two separate safety systems for a greater time than allowed by technical specifications (TS), and did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. T his finding has a cross-cutting aspect in the area of Human Performance, Consistent Process, in that Exelon failed to use a consistent, systematic approach to make decisions. Specifically, Exelon did not ensure their review process for issues entered into the CAP was effectively implemented to ensure proper evaluations for all applicable maintenance rule systems affected by a n SSC failure. [H.13] |
Site: | Nine Mile Point |
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Report | IR 05000220/2017004 Section 1R12 |
Date counted | Dec 31, 2017 (2017Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | M Catts B Sienel P Presby M Patel K Mangan M Hardgrove J Bream F Arner R Rolph G Stock E Miller H Lynn |
Violation of: | 10 CFR 50.65 10 CFR 50.65(a)(2) Technical Specification |
CCA | H.13, Consistent Process |
INPO aspect | DM.1 |
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Finding - Nine Mile Point - IR 05000220/2017004 | ||||||||||||||||||||||||||||||||||||||||||
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Finding List (Nine Mile Point) @ 2017Q4
Self-Identified List (Nine Mile Point)
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