The licensee was effective at identifying and tracking problems. The team did not identify any issues that were not already being tracked by the licensee. However, the team identified seven examples, involving both units, where issues involving equipment failures documented in the Problem Identification process had work orders to conduct the repairs, but no Deviation/Event Reports (DERs) were written, as required by the DER procedure. The failure to initiate DERs is a violation of the Nine Mile Point, Units 1 and 2 Technical Specifications related to procedure implementation, and is being treated as a Non-Cited Violation. The violation was not assessed using the
Significance Determination Process, as it did not impact one of the cornerstones; however, it provides substantive information relative to the cross cutting issue of problem identification and resolution. (Section 4OA2.1)