The licensee identified a finding of very low safety significance (Green) and associated
Severity Level IV NCV of
10 CFR 50.72(b)(3)(v)(D). Title
10 CFR 50.72(b)(3)(v)(D) requires, in part, that operating reactor licensees shall notify the NRC within eight hours of the occurrence of any event or condition that at the
time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. Contrary to this requirement, on November 1, 2011, the licensee identified that they had failed to make a required non-emergency notification within eight hours for a safety system functional failure of the
CREF and
CRV systems. Specifically, on October 21, 2011, following a reactor
scram, the No. 11
EDG ESW pump was declared
inoperable due to low cooling water pump flow. The loss of this pump resulted in the No. 11
EDG, \'A\'
CREF, and \'A\'
CRV being declared
inoperable when the redundant B Division
CREF and
CRV systems were already out-of-service due to preplanned maintenance. As a result, the licensee entered
TS 3.0.3 due to both
CRV and
CREF systems being
inoperable. The licensee failed to recognize that this represented a potential loss of safety function at the time of the event. The inspectors determined that the failure to report required plant events or conditions to the NRC was a performance deficiency, and it had the potential to impede or impact the regulatory process. The NRC dispositions violations of
10 CFR 50.72 using the traditional enforcement process, and if possible, the underlying technical issue is evaluated using the
SDP. The underlying technical issue was associated with both trains of CREF/CRV being
inoperable and unavailable during a
scram, resulting from a lockout of the 2R transformer. This issue was determined to be more than minor because it was associated with the
Mitigating Systems Cornerstone attribute of Equipment Performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). In accordance with
IMC 0609, because both trains of the CREF/CRV system were
inoperable and unavailable, the regional
SRAs performed a Phase 3 risk evaluation to determine the risk significance of the issue. As a result of the
SRAs evaluation, the inspectors determined that the finding had very low safety significance. Because the failure to make the required 50.72 report had the potential to impede or impact the regulatory process, the inspectors used the Traditional Enforcement process to disposition the issue. In accordance with Section 6.9.d.9 of the
NRC Enforcement Policy, this violation was categorized as
Severity Level IV. The licensee entered the issue into their
CAP as
AR 1310956, Missed 8 Hour Report, and made the required 50.72 report.
