The inspectors identified a Green finding and
Severity Level III violation of
10 CFR 50.9, Completeness and Accuracy of Information, after Pacific Gas and Electric failed to submitted complete and accurate information in response to
Generic Letter 2003-01, Control Room Habitability.
Generic Letter 2003-01 requested that the licensee submit information demonstrating that the control room habitability system was in compliance with the current licensing and design bases. The licensee was specifically requested to verify that the most limiting unfiltered in-leakage into the
control room envelope was no more than the value assumed in the design basis radiological analyses for control room habitability. On April 22, 2005, the licensee reported to the NRC that testing performed in the most limiting configuration for operator dose demonstrated that there was no unfiltered in-leakage into the
control room envelope. This was material because the NRC used this information to close out
Generic Letter 2003-01. In September 2011, the inspectors identified that the control room test results were greater than the value assumed in the design basis radiological analysis and that the licensees testing was not performed in the most limiting configuration for operator dose. Using the actual control room in-leakage rates, the inspectors concluded that the resultant operator dose could have exceeded the limit established by current licensing and design bases during an accident. The inspectors concluded that the failure of Pacific Gas and Electric to provide complete and accurate information in response to
Generic Letter 2003-01 was a performance deficiency. The finding was more than minor because the information was material to the NRCs decision making processes. The inspectors screened the issue through the Reactor Oversight Process because the finding included a performance deficiency that was reasonably within the licensees ability to control. The inspectors concluded that the finding was of very low safety significance (Green) because only the radiological barrier function of the control room was affected. The inspectors also screened the issue through the traditional enforcement process because the violation impacted the regulatory process. The inspectors concluded that the violation was a
Severity Level III because had the licensee provided complete and accurate information in their letter dated April 22, 2005, the NRC would have likely reconsidered a regulatory position or undertaken a substantial further inquiry. The inspectors did not identify a cross-cutting aspect because the performance deficiency was not reflective of present performance.
