Technical Specification 5.4.1 requires, in part, that written procedures shall be implemented covering the applicable procedures Appendix A of
Regulatory Guide 1.33, Revision 2. Appendix A of
Regulatory Guide 1.33 includes, in part, TS surveillance test procedures. Contrary to this requirement, the licensee did not properly implement TS surveillance test 0253-01; Standby Gas Treatment A Train Quarterly Test, on July 1, 2009. Specifically, the licensee did not satisfactorily complete Step 10b of 0253-01 when the measured flow rate was found outside of the acceptance criteria band (Step 10b implements
Surveillance Requirement 3.6.4.3.2 in accordance with
TS 5.5.6, Ventilation Filter Testing Program). Although the licensed operator performing Step 10b recognized the out-of-specification value and notified the Operations Shift Supervisor, an immediate operability evaluation was not made. 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 performance deficiency was more than minor and a finding because; if left uncorrected, the performance deficiency would have the potential to
lead to a more significant safety concern. The licensee entered the issue into their corrective action program as
CAP 01190129. 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.
