TS 3.6.2.3, Reactor Building Cooling System, and
TS 3.6.3, Particulate
Iodine Cleanup System, requires, in part, that two independent groups of RBCUs and their associated high efficiency particulate air (
HEPA) filter banks shall be
operable in Modes 1-4. Contrary to this, due to the use of a non-conservative
HEPA filter filtration area factor in the calculation of air flow rates, on April 28, 2010, the licensee identified that RBCUs XAA0001A and XAA0002A had air flow rates slightly below the TS range required for operability between Refuel 16 and 18, and RBCUs XAA0001B and XAA0002B had air flow rates slightly below the TS range for operability between Refuel 16 and 17. The violation was determined to be of very low safety significance because the RBCUs remained capable of performing their design functions with the slight reduction in air flow rates. The licensee replaced the filters and corrected the filtration area factor prior to the end of Refuel 18. The licensee addressed this issue in their corrective action program as CR-09-05126 and CR-10-01783