The inspectors identified a non-cited,
Severity Level IV violation of
10 CFR 50.73(a)(1) for a failure to submit a licensee event report (LER) within 60 days after the discovery of an event requiring a report. On April 22, 2008,
PSEG determined that both trains of the control room emergency filtration (
CREF) system were
inoperable, which is reportable as a loss of safety function of a system that is designed to mitigate the consequences of an accident. Additionally, operators entered
Technical Specification 3.0.3 and commenced a plant shutdown, which is reportable as a condition prohibited by Technical Specifications.
PSEG did not submit an LER for this event until October 17, 2008.
PSEGs corrective actions included revising the applicable procedure for assessing whether an LER is required. Traditional enforcement applies because a failure to report an event in a timely manner has the potential to impact the NRCs ability to perform its regulatory function. This violation was determined to be a
Severity Level IV violation consistent with Section IV.A.3 and Supplement I.D of the
NRC Enforcement Policy. The finding has a cross-cutting aspect in the area of problem identification and resolution, because
PSEG did not properly evaluate a
condition adverse to quality for reportability. Specifically,
PSEG did not correctly evaluate the reportability of both trains of
CREF being
inoperable. As a result,
PSEG failed to submit an LER in a timely manner. (
P.1(c)) (Section 4OA3
