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The inspectors identified a NCV of 10 CFR … The inspectors identified a NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, due to Exelon staffs procedures for meeting Unit 2 Technical Specification (TS) Surveillance Requirement (SR) 3.5.3.4 being inadequate since they did not test all required functions over the pressure range they were required since the start of plant operation. Specifically, inspectors identified that reactor core isolation cooling (RCIC) was being started with the flow controller in manual during the 165 pounds per square inch gauge (psig) reactor pressure test as opposed to automatic, which is its normal lineup. As a result, the RCIC system has not been adequately tested to develop flow at low reactor pressures to ensure that the surveillance had been met and that the RCIC system met its design basis. This finding is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding is similar to Example 3.d in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues. Specifically, the inadequate testing of the RCIC system with reactor pressure 165 psig has led to uncertainty in the reliability and capability of the system to perform at low reactor pressures. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the deficiency affects only the design or qualification of a mitigating SSC; and the design or qualification issue is not currently impacting its operability. The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency is not indicative of present performance because Exelons incorrect interpretation for conducting TS SR 3.5.3.4 did not occur within the last 3 years.3.4 did not occur within the last 3 years.
23:59:59, 30 June 2014 +
23:59:59, 30 June 2014 +
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12:58:08, 25 September 2017 +
23:59:59, 30 June 2014 +
Inadequate Surveillance Testing of Reactor Core Isolation Cooling during 165 psig Reactor Pressure Test for Surveillance Requirement 3.5.3.4 +