The inspectors identified a Non-Cited Violation of
10 CFR 50.71, Maintenance of Records, Making of Reports, associated with the licensees failure to correctly update the
Updated Final Safety Analysis Report (
UFSAR) when modifying TS requirements for the Control Room ventilation system during implementation of Improved Standard Technical Specifications. Specifically, the licensee failed to change the specified safety function description for the system to maintain positive pressure within the
Control Room envelope with respect to adjacent areas during all operating modes, except when the system is in the recirculation mode or when the system is in the maximum outside air purge mode. This directly contributed to the licensees failure to correctly evaluate the operability of Control Room ventilation system Train B when the system was unable to maintain the
Control Room envelope at a positive pressure relative to adjacent areas while operating in the normal mode. Subsequent evaluation by the inspectors determined that the safety function description in the
UFSAR was inaccurate and the system was
operable with the degraded/ nonconforming condition. The licensee entered this violation into its
CAP to investigate the cause and to identify appropriate corrective actions. Because the issue affected the NRCs ability to perform its regulatory function, the violation was reviewed under the traditional enforcement process. In addition, the underlying technical issue was evaluated using the
Significance Determination Process. The finding was determined to be a
Severity Level IV violation because it was similar to a
Severity Level IV violation example in the
NRC Enforcement Policy, Supplement I--Reactor Operations. The finding would become a more significant safety concern if left uncorrected and was therefore more than a minor concern. Specifically, the failure to correctly evaluate a degraded/nonconforming condition potentially affecting the operability of a system, structure, or component (
SSC) required to be
operable by TS could reasonably result in an unrecognized condition of an
SSC failing to fulfill a safety-related function. Because the Control Room ventilation system supports the radiological barrier function to protect operators inside the Control Room following certain design basis accidents, the inspectors concluded that this issue was associated with the
Barrier Integrity Cornerstone. The finding was of very low safety significance because it involved only a degradation of the radiological barrier function provided for the Control Room. The inspectors did not identify a cross-cutting aspect related to this finding
