The inspectors identified a finding associated with
TS 5.7.1.1 requirements for procedure adherence which resulted in pressurizer power-operated relief valve (
PORV) actuations. The finding is unresolved pending significance determination assessment. The inspectors determined that procedural noncompliances had a credible impact on safety involving the challenge of
reactor coolant system (
RCS) integrity by
PORV actuations and the challenge of
RCS inventory through the loss of inventory via the open
PORVs. The finding was more than minor because it impacted the
Barrier Integrity Cornerstone objective to provide reasonable assurance that the
RCS physical design barrier protects the public from radionuclide releases caused by accidents or events and the associated cornerstone attributes of human performance and procedure quality. The inspectors reviewed
MC 0609, Appendix G, and determined that the finding required quantitative assessment consisting of a Phase 3 analysis because it affected the cold over-pressure mitigation or low temperature over-pressure system required by TS. The cause of the finding impacts the cross-cutting area of human performance. (Section 1R20.2)
