A NRC-identified violation of
10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, and
10 CFR 50.73, Licensee Event Report System, was identified when the licensee did not recognize the loss of all three main control room (
MCR) air handling units (
AHUs) was a reportable condition. Consequently, the licensee failed to make an eight hour report as required by
10 CFR 50.72 and submit a licensee event report (LER) within 60 days as required by
10 CFR 50.73. This violation does not apply to Unit 1 because it was in a refueling outage and the
AHUs were not required to be operating. This violation has been entered into the licensees
CAP as CR 2008111957. Failure to recognize the loss of the MCREC system safety function was reportable is a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function of event assessment. The inspectors determined this finding was a
SL IV violation because the failure to report this condition did not substantively impact the Agency\'s regulatory responsibilities and the Agency would not have responded in a significantly different manner had the information been properly reported. This finding had the cross-cutting aspect of evaluating for reportability in the area of Problem Identification and Resolution (
P.1(c)) because the licensee evaluated reportability only for the entry into TS
LCO 3.0.3. (Section 4AO5)
