The inspectors identified a Green
NCV of
Technical Specification (TS) 5.4.1.a after Exelon did not establish and implement procedures to adequately test the Unit 2 and Unit 3
remote shutdown panels (
RSPs). Specifically, Exelons surveillance procedure did not test all the control circuits, as required by
Surveillance Requirement (SR) 3.3.3.2.1, for the Unit 2 and Unit 3
RSPs. Exelons corrective actions included entering this issue into their
CAP, the development of
RSP testing procedures for the
reactor core isolation cooling (
RCIC),
control rod drive (
CRD), and emergency
service water (
ESW) system components, and a revision to the bases for
TS 3.3.3.2
The performance deficiency (
PD) was determined to be more-than-minor because it was associated with the Equipment Performance attribute of the
Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Additionally, examples 1.c, 4.l, and 4.m from
IMC 0612, Appendix E, detail that a
PD was more than minor if required TS surveillance testing is not performed and subsequent testing reveals that the equipment is out of specification or otherwise unable to perform a safety-related function. A detailed risk evaluation concluded that the issue was of very low safety significance (Green). This finding had a cross-cutting aspect in Human Performance, Avoid Complacency, because Exelon failed to recognize and plan for the possibility of latent problems.
