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 Start dateSiteIdentified byTitleDescription
05000334/FIN-2017001-0131 March 2017 23:59:59Beaver ValleyNRC identifiedFailure to Follow the ASME OM Code for a Failed Relief Valve Set Pressure TestSeverity Level IV. The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (CFR) 50.55a(z), Alternatives to codes and standards requirements, for FENOCs failure to obtain prior authorization for implementing an alternative to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code). Specifically, until prompted by the inspectors, FENOC did not submit to the NRC and receive an alternative to the ASME OM Code requirement to not test the residual heat removal (RHR) relief valve, RV-1RH-721, during a recent refueling outage for Unit 1 when the charging system letdown relief valve, RV-1CH-203, failed to lift within three percent of set-pressure. FENOCs immediate corrective actions included performing a prompt operability determination, submitting a relief request, and entering the issue into the corrective action program (CAP) as condition report (CR) 2017-03937. The inspectors determined that this violation impacted the ability of the NRC to perform its regulatory oversight function, and was therefore subject to traditional enforcement. Section 2.2.1.c of the Enforcement Policy states that failure to receive prior NRC approval for changes in licensed activities when required is an example of impacting the ability of the NRC to perform its regulatory oversight function. After considering the factors in Section 2.2.1.c of the Enforcement Policy, the inspectors determined that the performance deficiency was a Severity Level IV violation because the change implemented by FENOC would likely be approved by the NRC. Because this violation involves the traditional enforcement process and does not have an associated finding that is more than minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.