The NRC identified a Green non-cited violation of
10 CFR 50.49(e)(5) for failing to base the qualified life of structures, systems, and components (
SSCs) (i.e. Nordel O-rings) on the known limits of extrapolation in accordance with
IEEE 323 Sections 6.5.3, Extrapolation, and 6.5.4 Determination of Qualification. In response, the licensee determined that the affected components remained
operable because the age of the O-rings in question was within the original qualification. The licensee entered this into their corrective action program as CR 1065957. The performance deficiency was determined to be more than minor because if left uncorrected, the performance deficiency would have the potential to
lead to a more significant safety concern. Specifically, the failure to properly determine the qualified life and replace the O-rings at the required time interval would adversely affect the reliability of that equipment when called upon to respond to
initiating events and prevent undesirable consequences. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance.
