Green. The team identified a green non-cited violation (
NCV) of Title10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate requirements necessary for maintaining the environmental qualification of the pressurizer power-operat ed relief valve (
PORV) NAMCO EA-180 limit switches into maintenance procedures. The licensee evaluated the impact of the incorrect guidance and determined that the PO RV limit switches remained operable. The licensee plans to correct the affected procedures. The licensee entered this issue into the corrective action program as NCR 02095333. This performance deficiency was more than minor because it was associated with the
mitigating systems cornerstone attribut e of equipment performance 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 maintaining the
PORV limit switches in their qualified condition impacted their reliability. The team used
IMC 0609, Att. 4, Initial Characterization of Findings, issued October 7, 2016, for
Mitigating Systems, and
IMC 0609, App. A, The
Significance Determination Process (
SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design of a mitigating structure, system, or component (
SSC), and the
SSC maintained its operability or functionality. The team determined that no cross-cutting aspect was applicable because the finding was not indicative of current licensee performance.
