The inspectors identified a
NCV of
Technical Specification 6.8.1, Administrative Controls-Procedures, because Exelon did not maintain adequate maintenance procedures associated with work performed on the Unit 2 Nuclear Steam Supply Shutoff System (NSSSS). Specifically, the procedures, which performed system relay replacements, did not contain adequate post-maintenance testing (
PMT) to demonstrate that the Technical Specification required response times of all circuits affected by the maintenance were satisfied. The inspectors determined that this finding was more than minor because it was associated with the procedure quality attribute of the Mitigating System cornerstone, and affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. As a result of the inadequate
PMT, additional unavailability was accrued, and an engineering evaluation was required to demonstrate satisfactory response times. The finding was determined to be of very low safety significance(Green) because it did not represent a loss of safety function. The inspectors determined this finding had a cross-cutting aspect in Human Performance, Resources, because Exelon did not provide complete and accurate work packages to assure nuclear safety. Specifically, the NSSSS was returned to service without all the required post-maintenance testing being performed to demonstrate operability. [IMC 0305 aspect:H.2(c)] (Section 1R19
