The following issue of very low safety significance (Green) was identified by the licensee and was a violation of NRC requirements. This issue met the criteria of Section VI of the
NRC Enforcement Policy,
NUREG-1600, for being dispositioned as a non-cited violation. Improved Technical Specification (
ITS) 3.7.1 states that
MSSVs shall be
operable as specified in
ITS Table 3.7.1-1 in Modes 1, 2 and 3. Contrary to the above, on September 22, 2009, while performing
SP-650,
ASME Code Safety Valves Test, on the A
OTSG in Mode 1, the as-found set points of three
MSSVs were found outside the
ITS 3.7.1 acceptance criteria of +/- 3 percent of the nominal set point. The valves were returned to
operable status by adjusting their set point to within +/- 1 percent. The licensee concluded that the three
MSSVs were
inoperable for a period longer than allowed by plant
ITS. The licensee determined that this
ITS violation was a result of a failure, in past years when
MSSVs were found out of tolerance, to provide adequate instructions to the vendor refurbishing the valves to determine the root causes of the out of tolerance condition. This lack of adequate vendor instructions was the result of the licensees failure to follow Corrective Action Program procedures which require that physical evidence and important information that is essential to identifying cause(s) be preserved. The finding was evaluated using Phase 1 of the At-Power
SDP, and was determined to be of very low safety significance (Green) because the inspectors responded no to all questions in the
mitigating systems cornerstone column of Table 4a, Manual Chapter 0609, Attachment 0609.04. This issue was documented in the licensees corrective action program as NCR 356521
