The team identified a Green non-cited violation of
10 CFR Part 50, Appendix B, Criterion XI, Test Control, consisting of two examples. In one example, the licensee failed to scope some Class 1E
molded case circuit breakers (
MCCBs) into the Class 1E
MCCB testing program. In the second example, the licensees test procedure preconditioned the Class 1E
MCCBs before testing their safety function. The licensee initiated Action Request (
AR) 1936760 and
AR 01934403, which determined the systems were
operable because an engineering review of previous TED breaker testing and
PM's has not shown a trend of degradation of the breakers ability to perform its function. In addition, the licensee planned develop a more extensive and adequate testing program. The licensees failure to perform adequate
MCCB testing in accordance with
IEEE 308- 1971, Section 6.3, Periodic Equipment Tests, was a performance deficiency. The team determined that the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the
Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance (Green) because the deficiency affected the design or qualification of a mitigating structure, system, or component (
SSC), but the
SSC maintained its operability or functionality. No cross-cutting aspect was applicable because the finding was not indicative of current licensee performance.
