NRC inspectors identified a Green non-cited violation of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for a failure to correct a
condition adverse to quality. The licensee identified that the ability to test the Eagle 21 was degraded but failed to take adequate corrective actions to correct the condition. The licensee entered the issue into their
CAP as
ARs 2023314 and 02145155. The performance deficiency 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 of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, not using core operating limits report (
COLR) specified time-constants in surveillance requirement (SR) tests to demonstrate operability of the Eagle 21 system adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the Thermal Over-Power (OPT) and Thermal Over-Temperature (OTT)
reactor trip algorithms. The finding was determined to be of very low safety significance (Green) because defense in depth of the
reactor protection system (
RPS) existed to trip the unit via alternate and diverse means. The inspectors determined the finding was indicative of present licensee performance and was associated with the cross-cutting aspect of human performance, in the area of conservative bias, because individuals failed to evaluate a proposed action to determine if it was safe in order to proceed, rather than unsafe in order to stop (H.14).
