10 CFR 50.55a(a)(3) states, in part, that proposed alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. Contrary to this,
PG&E failed to obtain authorization by the Director of the Office Nuclear Reactor Regulation prior to using an alternate method to perform visual examinations and functional testing of
snubbers versus the American Society of Mechanical Engineers (
ASME) Code,
Section XI, requirements identified in
10 CFR 50.55a(g). Specifically, on March 21, 2006,
PG&E submitted a relief request to the NRC for their alternate method of
snubber examinations and testing as it applied to the 2nd 10-year interval inservice inspection and testing program. However, the 2nd 10-year interval ended for Unit 1 on May 7, 2006, and, for Unit 2, it ended on June 30, 2006. Therefore, for the majority of the 2nd 10-year interval inservice inspection and testing program,
PG&E used an alternate method for examining and testing
snubbers without prior approval from the NRC. Relief request regarding the alternate method was granted by the NRC for the 2nd 10-year interval on March 29, 2007. Using
IMC 0612, Appendix B, the finding was determined not to be suitable for disposition under the
Significance Determination Process since it had the potential to impact the NRCs ability to perform its regulatory function. Under the traditional enforcement process, Supplement 2, Section D.5 of the
NRC Enforcement Policy describes this finding as a
Severity Level IV violation.
