A non-cited violation of
10 CFR 50.73 was identified for untimely submittal of a licensee event report (LER). In March 2004, station personnel had all necessary information available to identify that both trains of high pressure injection (
HPI) had been
inoperable for a brief period in 2003. The issue was not reported until December 2004, following identification by the inspectors. A contributing cause of this finding is a shortcoming in problem identification in the cross-cutting area of PI&R in that station personnel did not consider unavailability of the emergency power supply to the second
HPI train and associated technical specification requirements when determining reportability of this condition. Additionally, the original
operability determination did not correctly address seismic qualification of
HPI support systems until identified by the inspectors. Corrective actions included submittal of the condition report, training for station personnel, and entering the issue into the corrective action program as issue report 267630.