10 CFR 50, App. B, Criterion XVI, required in part that
conditions adverse to quality, such as non-conformances, are promptly identified and corrected. NSD-203, Operability/Functionality, required entry into the
operability determination process (
ODP) upon the discovery of circumstances that call into question the operability of any TS
SSC including degraded/non-conforming conditions. NSD-203 also requires that actions to confirm if the
SSC is degraded or non-conforming should be completed in a timeframe that is commensurate with its safety significance. Contrary to the above, a potential non-conforming condition was identified on December 30, 2012; however, the
ODP was not entered until November 26, 2013, and corrective actions generated to correct the non-conforming condition. The finding was not greater than Green because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction of
hydrogen igniters in containment. This violation was entered into the
CAP as
PIP O-13-14547.
