A Non-cited Violation of
10 CFR 50, Appendix B, Criterion V, wa
identified associated with five examples of failure to implement the written procedures o
the corrective action program, an activity affecting quality. Four examples involve
failure to properly classify adverse trend corrective action items as required by th
corrective action program procedure LR-CG-10. The adverse trend items wer
associated with various topics including component mis-positioning, procedur
adherence, and reactor downpower events. The fifth example of failure to implemen
LR-CG-10 involved failure to conduct an operability evaluation of emergency diese
generators (EDGs) in April 2000, when PECO determined that 70 of 88 flexcouplin
clamps on the cooling water systems of its EDGs were over tightened. The failure t
implement the procedures of the corrective action program is considered more than
minor violation in that it suggests a programmatic problem that has a credible potentia
to impact safety and involved more than an isolated occurrence. (4OA2.3)