05000305/FIN-2012002-06
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Finding | |
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| Title | Failure to Submit LER Per 10 CFR 50.73 |
| Description | 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. |
| Site: | Kewaunee  |
|---|---|
| Report | IR 05000305/2012002 Section 4OA3 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Other |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | D Mcneil K Riemer R Krsek K Barclay A Shaikh |
| INPO aspect | |
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Finding - Kewaunee - IR 05000305/2012002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Kewaunee) @ 2012Q1
Self-Identified List (Kewaunee)
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