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10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that
conditions adverse to quality are promptly identified and corrected. Contrary to this requirement, the licensee did not promptly identify on July 1, 2009, that a measured flow rate outside of the acceptance criteria of surveillance test 0253-01 rendered the A standby gas treatment (
SBGT) system
inoperable. Due to the failure to promptly identify this
condition adverse to quality, the A
SBGT system was not declared
inoperable until July 20, 2009, after the operations duty shift manager became aware of the test results from July 1, 2009. The inspectors determined that this issue was a performance deficiency because it was the result of the failure to meet a requirement, and the cause was reasonably within the licensees ability to foresee and correct and should have been prevented. The inspectors determined that the finding was more than minor because it involved the configuration control attribute of the
Barrier Integrity Cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. The licensee entered the issue into the corrective action program as
CAP 01189968.The inspectors applied
IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings to this finding. Under Column 4 of the Table 4a worksheet, the inspectors answered Yes to Question 1, since the finding only represented a degradation of the radiological barrier function provided by the
SBGT system. Therefore, the finding was considered to be of very low safety significance.
