A self-revealing
NCV of
10 CFR 50 Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure take prompt corrective actions to preclude repetition of the failure of the temporary auxiliary building
secondary containment envelope (
ABSCE) boundary doors installed to facilitate Unit 2 construction. Following the previous failure of temporary
ABSCE boundary doors R002 and R003 during auxiliary building ventilation changes, the licensee initiated PER 172301 to determine the cause of the door failure. In accordance with licensee procedure PIDP-4, Corrective Action Program Screening and Oversight, PER levels are assigned based on the consequences of the identified condition and also on the frequency or probability of issue occurrence. Based on the condition classification guidance in Appendix A of PIDP-4, the door failures were considered by the licensee to be a Significant
Condition Adverse to Quality (
SCAQ), which required the associated PER to be designated as an A-level PER. Accordingly, PER 172301 was assigned as an A-level (highest category) requiring a root cause analysis and corrective actions to prevent recurrence. Corrective actions to prevent recurrence developed by the root cause team were not incorporated into plant procedures, and as a result, temporary doors (R002 and R003) failed during auxiliary building ventilation changes on June 27, 2009. The licensee entered the issue into the corrective action program as PER 175160, made door repairs to re-establish the
ABSCE boundary, and shut the Unit 2 reactor building access doors to provide an additional ventilation barrier. The licensees failure to take corrective actions to preclude the temporary door failure repetition was a performance deficiency. The inspectors reviewed
IMC 0612 and determined that the finding was more than minor because, if left uncorrected, it would have the potential to
lead to a more significant safety concern, specifically for loss of the
secondary containment boundary. Additionally, the finding was associated with the design control attribute of the
Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers, such as the
secondary containment boundary, protect the public from radionuclide releases caused by accidents or events. Using the phase I screening worksheet of
IMC 0609, the inspectors determined that the finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the auxiliary building. The cause of the finding had a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component. It was directly related to the licensee thoroughly evaluating problems such that resolutions address the problems causes
P.1(c). Specifically, during the investigation of the May 27, 2009,
ABSCE door failures, the licensee failed to address the inadequate design of temporary doors R002 and R003
