The inspectors identified a non-cited violation of
10 CFR 50.73(a)(2)(vii), because
PPL did not submit a Licensee Event Report (LER) for the common cause failure and consequent inoperability of two or more
SRVs in 2005, 2008, and 2009. The inspectors determined that
SRV failures of set pressure testing per the 1998
ASME O&M Code were attributed to setpoint drift resulting in two or more independent channels (two or more
SRVs) to become
inoperable. As an immediate corrective action, the licensee entered this
NCV into their corrective action process (CR 1161398). This finding was evaluated using the traditional enforcement process because the failure to accurately report events has the potential to impact or impede the regulatory process. The finding was determined to be a
Severity Level IV violation based on Supplement I, Example D.4 of the
NRC Enforcement Policy. However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into
PPLs corrective action program, this violation is being treated as an
NCV consistent with the
NRC Enforcement Policy. This finding is related to the Problem Identification and Resolution cross-cutting area (Operating Experience (
OE)) because
PPL did not thoroughly incorporate
Information Notice (IN) 2006-24 to include
SRV set point drift as a reportable common cause failure method. (
P.2(b))