05000263/FIN-2013004-05
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Finding | |
|---|---|
| Title | Inappropriate Invoking of Surveillance Requirement 3.0.3 Due to Missed In-service Te |
| Description | A violation of TS 5.5.5, In-service Testing Program, was identified. Specifically, the ASME O&M Code and TS 5.5.5, In-service Testing Program, require cold shutdown IST tests to be performed every three months while shutdown, or within three months of the system becoming operable. Contrary to these requirements, the licensee failed to perform required testing for several RHR/LPCI valves and inappropriately invoked SR 3.0.3 to delay testing. Because the violation was identified during the discretion period described in EGM 12-001, the NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and is, therefore, not issuing enforcement action for this violation. Specifically, EGM 12-001 states, The staff has determined that the enforcement discretion described in this EGM is appropriate because the restructuring of TS chapters during the development of improved Standard Technical Specifications (STS) resulted in unintended consequences when Section 3.0, Surveillance Requirement Applicability, provisions were made applicable to Section 5.0 TSs. Specifically, applying STS rules of usage would prohibit licensees from using the SR 3.0.2 and 3.0.3 allowances contained in Section 5.0 TSs. The inspectors also noted that the issue met the Enforcement Policy discretion criteria in that there was a lack of clarity in the requirement, and the issue was of very low safety significance. Specifically, the allowance contained in TS 5.5.5, Section C, was misleading, in that it stated that the provisions of SR 3.0.3 were applicable to IST activities. The licensee initiated action to test the affected valves in accordance with the IST program, changed plant procedures to include EGM 12-001 and RIS 12-10 guidance, and developed an Operations Memo to alert operators to the guidance. |
| Site: | Monticello  |
|---|---|
| Report | IR 05000263/2013004 Section 1R15 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | Violation: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | A Dunlop K Riemer T Bilik C Brown K Stoedter P Voss J Corujo-Sandin S Bell D Oliver M Ziolkowski |
| Violation of: | Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Monticello - IR 05000263/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2013Q3
Self-Identified List (Monticello)
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