The inspectors identified a noncited violation of
10 CFR 50.65(a)(2), after Pacific Gas and Electric Company failed to effectively control performance monitoring of the Unit 2 containment atmosphere particulate radiation monitor through appropriate preventive maintenance. Eight functional failures of the radiation monitor occurred between November 2006 and January 2008. The licensee did not categorize any of these failures as Maintenance Rule functional failures. This finding is greater than minor because it is associated with the
mitigating systems cornerstone attribute of equipment performance and it affects the cornerstone objective to ensure the availability, reliability, and capability of the systems that respond to
initiating events to prevent undesirable consequences. The inspectors evaluated the significance of this finding using
Inspection Manual Chapter 0609,
Significance Determination Process, Phase 1, Appendix A. The inspectors determined that this finding was of very low safety significance because this is not a design or qualification deficiency, does not represent a loss of a system safety function or safety function of a single train, and does not screen as potentially risk significant due to external events. The inspectors also determined that this finding has a crosscutting aspect in the area of human performance associated with the work practices component because engineering staff failed to follow the November 2006 revision to the licensee maintenance rule procedure that would have required each failure to be counted as a maintenance rule functional failure. Engineering staff incorrectly concluded that the revision was not applicable to the radiation monitors and therefore did not implement the change
H.4(b)