The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements, which meets the criteria of the
NRC Enforcement Policy for being dispositioned as a non-cited violation.
Technical specification 4.1.4, Operational Safety Review, requires each
remote shutdown system function shown in Table 3.5-4 shall be demonstrated
operable by the performance of the following check, test, and calibration. The technical specification
surveillance requirement 4.1.4.b states that the licensee shall verify each required control circuit and transfer switch is capable of performing the intended function in accordance with the licensees
surveillance frequency control program, in this caseevery refueling interval. Contrary to
SR 4.1.4.b, from January, 1987, until September 2017, Exelon did not verify that each required control circuit on the Unit 1
remote shutdown panel was capable of performing the intended function. Specifically, Exelon did not test four of the required six relays for the B
EDG either by operation of the components or by performance of a continuity check. Exelons corrective action included entering this issue into the
CAP as issue reports 4020064 and 4047426, developing a
remote shutdown system testing procedure for the B
EDG system, and the completion of a risk evaluation as required by
surveillance requirement 4.0.2. The inspectors determined that the finding was more than minor because it is associated with the equipment performance attribute of the
Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability of systems that respond to
initiating events to prevent undesirable consequences. It is of very low safety significance (Green) in accordance with NRC
IMC 0609, Appendix F, Fire Protection
Significance Determination Process, since the
missed surveillance did not impact the ability to reach
safe shutdown.
