The inspectors identified a non-cited violation (
NCV) of
10 CFR 50.65 (a)(2) for the licensees failure to categorize two failures of the condenser vacuum pump effluent radiation monitor (REM-3534) as maintenance rule functional failures and accordingly, failed to monitor the component as required by
10 CFR 50.65 (a)(1). The licensee entered this issue into the Corrective Action Program (
CAP) as Condition Report 283579. The finding is greater than minor because it is associated with the equipment performance attribute of the
Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems which responds to
initiating events to prevent undesirable consequences. In addition, Example 7.b provided in Manual Chapter 0612, Appendix E, states that violations of Paragraph
10 CFR 50.65 (a)(2), failure to demonstrate effective control of performance or condition and not putting the affected Systems, Structures, and Components (
SSCs) in (a)(1), are not minor because they necessarily involve degraded
SSC performance or condition. The inspectors determined this finding is of very low safety significance because the REM-3534 is not a risk-significant component and a back-up means of detecting a primary to secondary leak, the
steam generator blowdown radiation monitor, was functional during the time periods when REM-3534 was not functional. The finding occurred because of the two missed failures in 2005. All of the failures of REM-3534 since 2005 have been properly counted. Therefore, the cause of this finding was not associated with a cross-cutting area because it is not reflective of current licensee performance. (Section 1R12
