The inspectors identified a finding of very low safety significance and an associated non-cited violation of
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the failure to identify a
condition adverse to quality. Specifically, the licensee failed to identify the installation of the
low pressure coolant injection (
LPCI) loop-select differential pressure indicating switches (
DPISs) on both units beyond their performance-centered maintenance template recommended replacement frequency and beyond their environmental qualification (
EQ) service life established in
EQ binder EQ-83Q as
conditions adverse to quality (
CAQ) in their corrective action program (
CAP). The licensees corrective actions included entering the non-conforming conditions into the
CAP (
Issue Report 2663100) and evaluating the
CAQs for operability. The licensee determined the current
DPISs were operable but non-conforming, and replaced all remaining
LPCI loop-select
DPISs. The failure to identify
CAQs within the
CAP was determined to be more than minor because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to identify when safety-related structures, systems, or components (
SSCs) are beyond their qualified life could lead to an
SSC not being able to perform its specified safety function. The finding was screened against the
Mitigating Systems Cornerstone and determined to be of very low safety significance because the
SSC maintained its operability. The inspectors determined this finding affected the cross-cutting area of problem identification and resolution, in the aspect of Identification, which states, The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee failed to document a
condition adverse to quality related to the
LPCI loop select
DPISs on both units in the
CAP in a timely manner [P.1].
