The inspectors identified a
Severity Level IV NCV of
10 CFR 50.73(a)(1). The licensee failed to submit a required Licensee Event Report within 60 days after discovery of an event requiring a report. The licensee failed to correctly evaluate the failure of two Unit 2
Residual Heat Removal (
RHR) system pressure relief valves, which affected the operability of both trains of the
RHR system. This was reportable as a condition prohibited by the plant\'s Technical Specification and as an event where a single cause resulted in two independent trains becoming
inoperable in a single system designed to remove residual heat and mitigate the consequences of an accident. The licensee implemented several corrective actions to address a potential adverse trend in correctly identifying and evaluating the reportability of plant events, including additional training for selected operations, regulatory affairs, and plant engineering department personnel. This finding was of more than minor significance because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations and the Technical Specification in order to perform its regulatory function. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section IV.A.3 and Supplement I, Paragraph D.4, of the
NRC Enforcement Policy, this finding was determined to be a
Severity Level IV NCV. Although this NRC identified violation was repetitive, the inspectors concluded that it was not due to inadequate corrective actions for the previous violation. The primary cause of this finding was related to the cross-cutting area of problem identification and resolution because the licensee did not correctly evaluate the two safety valve test failures with respect to the reporting requirements in
10 CFR 50.73. (
IMC 0305,
P.1(c))
