The inspectors identified an
SL IV
NCV of
10 CFR 50.73(a)(2)(vii) for the failure of the licensee to report an event where a single cause or condition caused two independent trains to become
inoperable in a single system designed to control the release of radioactive material. Specifically, the licensee failed to report that both trains of
shield building ventilation (SBV) were
inoperable due to a single cause, because both trains contained unqualified control card standoffs that were needed to maintain the seismic qualification and operability of the system. The licensee entered this into their
CAP as CR429469, planned to perform an
ACE, and was drafting an update to Licensee Event Report
(LER) 05000305/2011-005. The inspectors determined that the failure to report the event in accordance with
10 CFR 50.73 was a performance deficiency. Because violations of
10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process (
ROP)
SDP. Because the performance deficiency, a failure to report, was not an
ROP finding per
IMC 0612, Appendix B,` Issue Screening,` a cross-cutting aspect was not assigned to this violation. Per the
NRC Enforcement Policy, Section The inspectors identified an
SL IV
NCV of
10 CFR 50.73(a)(2)(vii) for the failure of the licensee to report an event where a single cause or condition caused two independent trains to become
inoperable in a single system designed to control the release of radioactive material. Specifically, the licensee failed to report that both trains of
shield building ventilation (SBV) were
inoperable due to a single cause, because both trains contained unqualified control card standoffs that were needed to maintain the seismic qualification and operability of the system. The licensee entered this into their
CAP as CR429469, planned to perform an
ACE, and was drafting an update to Licensee Event Report
(LER) 05000305/2011-005. The inspectors determined that the failure to report the event in accordance with
10 CFR 50.73 was a performance deficiency. Because violations of
10 CFR 50.73 are considered to be violations that potentially impact the regulatory process, they are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process (
ROP)
SDP. Because the performance deficiency, a failure to report, was not an
ROP finding per
IMC 0612, Appendix B,` Issue Screening,` a cross-cutting aspect was not assigned to this violation. Per the
NRC Enforcement Policy, Section 6.0,` Violation Examples,` a failure to submit a required LER is categorized as an
SL IV violation.
