The inspectors identified a
Severity Level IV NCV of
10 CFR 50.73(a)(2)(iv)(A) in that Unit 1 inappropriately retracted an event notification report (ENR) and subsequently failed to make the required licensee event report (LER) for a valid actuation of the
HPCI system. Specifically, Constellation inappropriately retracted ENR number 48477, an 8-hour notification for a valid
HPCI actuation and failed to submit an LER within 60 days of discovery of the actuation. Constellation entered this issue into their
CAP as CR-2013-001859. The inspectors determined that the inappropriate retraction of a notification required by
10 CFR 50.72(b)(3)(iv)(A) and failure to make a required event report in accordance with
10 CFR 50.73(a)(2)(iv)(B)(4) were performance deficiencies that were reasonably within Constellations ability to foresee and correct and should have been prevented. Because this issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated these performance deficiencies in accordance with the traditional enforcement process. Using example 6.9.d.9 from the
NRC Enforcement Policy, the inspectors determined that the violation was a
Severity Level IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more than minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with
IMC 0612, Appendix B, Issue Screening, issued September 7, 2012.
