ML20217D247
| ML20217D247 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1999 |
| From: | Borchardt R NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Dyer J, Miller H, Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9910150083 | |
| Download: ML20217D247 (27) | |
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j NUCLEAR REGULATORY COMMISSION I t WASHINGTON, D.C. 206 2 4 001
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September 29, 1999 1
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. MEMORANDUM TO:
Hubert J. Miller, Regional Administrator Region I Luis A. Reyes, Regional Administrator Region ll James Dyer, Regional Administrator I
Region lli
. Ellis W. Merschoff, Regional Administrator Region IV Acting Associate Director for l
Inspection and Programs, NRR I
J Brian W. Sheron, Associate Director for Project Licensing and Technical Analysis, NRR Elizabeth Q. Ten Eyck, Director, Division of Fuel Cycle and Safeguards, NMSS Donald A. Cool, Director, Division of Industrial and Medical Nuclear Safety, NMSS E. William Brach, Director Spent Fuel Project Office, NMSS John T. Greeves, Director, Division of Waste Management, NMSS FROM:
R.W. Borchardt, Directo j, (
7-~~
Office of Enforcement
SUBJECT:
GUIDANCE FOR CLASSIFYING VIOLATIONS AS MINOR VIOLATIONS The purpose of this memorandum is to provide guidance to be used when determining if a violation may be classified as a minor violation. A working group consisting of regional and program office representatives developed the examples provided in this document.
Subsequent interaction between the regions and program offices clarified the overall guidance.
OE intends to incorporate this guidance into a future revision of the Enforcement Manual.
Comments are invited and may be provided to Barry Westreich (415-3456) of my staff. This document may be shared with licensees and the public and will be placed in the public document room.
1 IMPLEMENTATION Minor Violations are violations that are not the subject of formel-Jaicernent action. Issues that represent isolated' failures to implemet a re;druidnt and insignificant safety or
'" Isolated" in that based on a reasonable effort, the issue is determined to be not recurring nor does it indicate a programmatic issue such as inadequate supervision, training, resources, etc.
C, j L{ e 9910150083 990929 I
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" regulatory impact should normally be categorized as minor violations. However, violations that describe issues that are considered significant enough to be utilized in the formal NRC assessment process can never be minor, As described in NRC Inspection Manual Chapter 0610, minor violations are, by their very nature, minor issues with little or no safety
- consequence. ' Accordingly, issues resulting in minor violations are not normally described in inspection reports.
Examples' of minor violations include, but are not limited to:
- 1. Record Keepina lasues Record keeping minor violations involve issues that do not preclude the licensee from being
- able to take appropriate action on safety-related matters; or to properly assess, audit, or otherwise evaluate its safety-related activities.
- 2. Licensee Administrative Reauirement/ Limit issues Administrative limits are limits that licensees impose upon themselves that are more conservative than regulatory limits, such that exceeding an administrathe limit does not exceed an NRC requirement or limit and are considered minor violations. Violations that cause the j
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administrative limits to be exceeded, may not be minor if they are not isolated.
- 3. Non Sianificant Dimensional. Time. Calculation. or Drawina Discreoancies Non significant dimensional, time, calculation, or drawing discrepancies are characterized by 3
minor discrepant values referred to in either the licensee's FSAR or other design documents
'and are minor violations. For example, if the FSAR states the discharge piping from a station fire pump is four inches in diameter, when actually the piping is five inches, and the difference i
does not have a significant effect on flow rates, pump run out calculations, or any other safety issue, then the violation should be considered minor. Another example is if a review of design
- calculations determines an auxiliary feedwater pump requires 15 feet of head to preclude cavitation, rather than the originally calculated 14.5 feet, and the pump's water supply will l
' alwevs provide 25 feet, the violation should be considered minor.
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- 4. Isolated Procedural Errors That Have No imoact on Safetv Eauioment l
- Isolated procedural errors or inadequate procedures that have no impact on safety equipment
. are considered minor violations. For example, consider the following isolated instance where a worker inadvertently skips a step in a procedure, and later in the procedure identifies the error, either because he realizes he skipped the step or equipment does not respond as expected, 1
and is able to recover without causing a safety consequence, the procedural violation should be considered minor. Or if a procedural step is skipped and it is identified after the maintenance is completed and is determined to have no value because elimination of the step would never cause a safety consequence, such that elimination of the step would be an acceptable l-corrective action, the inadequate procedural violation should be considered minor. On the other hand, if the missed step adds value or provides reasonable assurance that the maintenance resources, etc.
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- activity would be satisfactorily completed, it may not be considered minor. For example, maintenance was being performed on a motor-operated valve actuator and a step in the procedure required workers to stake the drive shaft key on the motor shaft following installation of the motor pinion. The workers miss the step and fail to stake the key. Despite missing the step, the valve successfully passes the post-maintenance (and would probably successfully stroke for many more times). This missed step would not be considered minor. By missing the step, the workers failed to complete a step necessary for there to be reasonable assurance that the valve actuator would continue to function. An example of more than minor violation includes
' the failure to perform procedurally required post-maintenance or modification testing, regardless of whether the equipment operates as designed when ultimately tested.
- 5. Work in Proaress Findinos
- For the purposes of enforcement, " Work in Progress" is defined as any violation occurring and identified in the course of performing work or maintenance on equipment that is out of service L (or through the technical specifications deciared inoperable) and has no safety consequences, and the violation is identified and corrected prior to returning the equipment to service and/or declaring the equipment operable. These violations are minor violations. Errors that occur on non-designated pieces of equipment, such as inadvertently or mistakenly operating a different
- train of the equipment, or errors that cause another requirement (e.g., technical specifications) to be violated, are not considered minor by this' definition. As a further example, fire watches are missed during welding activities on a piece of equipment located near safety-related equipment. Despite the licensee identifying this problem and restoring the watches prior to completion of the welding activities, the missed fire watches would not be considered minor, due to the potential for a fire that could have damaged the safety-related equipment.
6.'10 CFR Part 50.59.10 CFR Part 50.71(e)
A failure to meet 10 CFR 50.59 requirements that involve a change to the FSAR description or
_ procedure, or involves a test or experiment not described in the FSAR, where there was not a reasonable likelihood that the change would es c require NRC approval per 10 CFR 50.59, would be considered minor.
A failure to meet 10 CFR 50.71(e) by not updating the FSAR, where the failure would not have a materialimpact on safety or licensed activities, would be considered minor. The focus of the 1
minor. violation is not on the actual change, test, or experiment, but on the potential safety role
' of the system, equipmenti etc. that is being changed, tested, or experimented on.
- 7. Miscellaneous-Where a licensee does not take corrective action for a minor violation, willfully commits a minor '
violatico,'or the NRC has indications that the minor violation has occurred repeatedly, the matter'should not be considered a minor vio!ation. Notwithstanding the fact an issue is i-determined to be a minor violation, the factors that caused the minor violation may not be l
. Isolated,'such that a citation is warranted for the root cause.
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' Examples of Minor violations are included as Attachment 1 to this document.
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ATTACHMENT 1 Criterion ill, " Design Control" Examples 1.
Prior to system restoration following a modification the licensee determined that the modification package that replaced the spent fuel pool cooling system suction piping did not include the siphon hole called for by the original system design. The siphon hole therefore was not installed. Due to the location of the piping, a siphoning event would lower spent fuel pool level several feet, but would not uncover the stored fuel, nor significantly increase radiation levels in the spent fuel pool area.
It's a violation because:
The pipe design was not correctly translated into proper work instructions and drawings.
It's a minor violation because:
This is work in progress. The error was identified and corrected during turnover of the modification prior to system restoration.
It would be more than minor if:
If the syC m had been returned to service with the 3
siphon hole missing, or not been evaluated to remove the requirement for the siphon hole.
2.
A temporary modification is installed on one of two redundant component cooling water system surge tanks to restore its seismic qualification. The supporting calculations, which did not receive a second-level review, are found to contain technical errors that did not result in that train being inoperable.
It's a violation because:
Design control measures for verifying or checking
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the adequacy of design were not implemented.
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Design changes, inclucing field changes, shall be subject to design control measures commensurate with those applied to the original design.
It's a minor violation because:
These are non significant calculation errors. The calculation errors were minor and the installed modification restored seismic qualification of the i
tank.
It would be more than minor if:
If calculation errors were significant enough that the modification required revision or rework to correctly resolve technical question (e.g., to restore compliance with the code).
3.
Motor-operated valve pressure locking / thermal binding design calculations assumed j
'run efficiency" to estimate opening capability. The motor-actuator manufacturer l
prohibits the use of "run efficiency" in this application.
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l it's a violation because:
Design control measures for verifying or checking the adequacy of design were not implemented.
l It's a minor violation because:
This is a non significant calculation error. The affected valves had large capability margins and remained capable of overcoming postulated pressure locking forces.
It would be more than minor if:
- 1. A valve is operable, but similar calculation problems affected a number of v :ves.
- 2. A valve is inoperable, but does not render its associated train inoperable.
- 3. A valve is inoperable, renders its associated train inoperable, but the safety and risk consequences are low.
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While performing a review of a completed surveillance test, the system engineer determines that operators performing the test had made a calculation error when determining the leak rate of a Power-operated relief valve's nitrogen accumulators.
When calculated correctly the actual check valve leakage exceeded the surveillance leakage rate's acceptance criterion in the surveillance procedures (but not the technical specifications surveillance requirement). The surveillance had been completed a week earlier and the system had been retumed to service. The surveillance test allowable leakage rate is below that used in the design assumptions for sizing of the accumulators and it is determined that with the identified leakage, the PORVs would be able to perform the required number of strokes assumed in the accident analysis.
It's a violation because:
The surveillance test's allowable check valve leakye rates were exceeded and the system was returned to service.
It's a minor violation because:
The limit exceeded was an administrative limit.
Actual check valve leakage rates, based on testing history, have always been significantly low enough to meet the required number of PORV strokes.
It would be more than minor if:
Maintenance records indicated that historical check valve leakage rates were too high to have supported the required number of PORV strokes.
Note: Although some violations of a licensee's technical specifications can be minor, in this example, if the leak rate exceeded the technical specification sun'eillance requirement, the issue would not be considered minor.
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Criterion V, " Procedures, instructions" Examples 1.
. A scaffold erected between safety related plant service water strainers was wedged tightly between the system piping. Licensee procedures require an engineering evaluation be performed for all scaffolding located above or near safety related equipment. No engineering evaluation was performed to assess the seismic impact of the scaffold, it's a violation because:
Criterion V requires that activities affecting quality shall be performed IAW procedures
~ lt's a minor violation because:
This is an isolated failure procedural error that has no programmatic implications and no safety impact.
The failure to perform an evaluation was an isolated occurrence and a subsequent evaluation determined that there was no impact on equipment it would be more than minor if:
The licensee routinely had not performed engineering evaluations on similar issues, or if a subsequent evaluation determined that safety-related equipment was adversely affected.
2.
NRC inspectors identified that one high radiation door was not locked as required by plant procedures. While the licensee's procedurally controlled administrative limit for area postings was exceeded, the door to the area was conservatively classified and did not exceed regulatory radiation levels to warrant posting as a locked high rad area.
It's a violation because:
Plant procedures require ihat activities shall be accomplished IAW procedures.
It's a minor violation because:
The. requirement was a licensee administrative limit. The area was conservatively posted and no regulatory limits requiring posting were exceeded.
It would be more than minor if:
The a~ces radiation levels exceeded the limits such that postir.g was required as a locked high rad area.
Note: Because radiation protection matters do not apply to Appendix B, this procedural violation would best be cited under technical specifications and/or Reg Guide 1.33.
3.
. While performing a Reactor Protection procedure, an operator inadvertently operated the bypass switch which caused a single channel trip condition. The operator had failed to properly follow the procedure and adequately self-check to ensure the right switch was' manipulated.
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It's a violation because:
Criterion V requires that activities shall be accomplished IAW with procecures it's a Minor violation because:
This was an isolated procedural error it was an isolated event, and no safety consequences resulted.
It would be more than minor if:
The error had caused a reactor trip or other transient.
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A licensee proced e required that all valves specified on a locked valve list be indicated as locked on P&lD Inspectors identified valves, covered by 10 CFR Part 50 Appendix B, on the locked valve. 't that were not indicated as locked on P&lDs. All valves on the locked valve nst were pu.perly positioned and locked, as determined by field verification.
It's a violation because:
Activities were not performed LAW procedures.
It's a Minor violation because:
This is a non significant drawing discrepancy. All valves required to be locked were locked and properly positioned.
It would be more than minor if:
More than one valve was in the required position, but not locked.
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Criterion XI: Test Control Examples l
1.
A Limitorque operator motor is test wired for reading operating current during GL 89-10 L
valve testing. The valve is successfully cycled, data recorded, determined to be within the acceptable range and returned to service. However the ammeter used a 0-100 amp scale instead of a 0-10 amp scale as required by the procedure. Subsequent retest with the proper meter results in satisfactory amperage readings.
It's a violation because:
The test pro:edure was not followed 1
It's a minor violation because:
This is an isolated procedural error that had no impact on safety equipment. The mistake did not result in an actual equipment problem and was isolated to only a single mistake, it would be more than minor if:
The retest revealed that the reading was actually out of specification.
2.
. Post-maintenance testing was performed on ten glycol air handling units during an outage of a Westinghouse ice condenser facility, All the requircd tests were performed, based on statements from licensee workers, but there is no record that an actual air flow test was con $ucted on two of the units. Based on indication in the control room, both air-handling units have comparable air flow to those that have documented test results, and the ice condenser.TS required air temperatures have all been well-within specification.
it's a violation because:
Criterion XI requires test results to be documented and evaluated to assure that test requirements have been satisfied.
It's a minor violation because :
This is a record keeping issue of low significance.
There is reasonable assurane.e that test requirements were met as evidenced by actual air flow being satisfactory and TS temperatures being.
within limits.
It would be more than minor if:
Air flow in the two u. nits was degraded but the TS i
required air temperature was within limits, or air flow was within limits but air temperatures were not within TS limits.
3 During a refueling outage, the licensee tested a charging pump at full flow conditions as required every 18 months. Vibration data taken during this test indicated a vibration of 0.324 inches per second (ips) exceeding the test allowable vibration of 0.320ips. As required by the test, tha vibration measurements taken during the outage would have
. required that the pump vibratiori be considered in the Alert range and the surveillance
. frequency increased to every nine months. However, because the licensee did not identify that the test result exceeded the acceptance criteria, the test frequency was not l
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O' increased and subsequent vibration testing revealed no vibration degradation. The '
ASME Code acceptance criterion for vibration measurements is 0.325 ips.
It's a violation because:
Criterion XI requires that test procedures shall incorporate acceptance limits established by design documents. Measured vibration data exceeded the test procedure alert levels and the additional testing was not performed.
it's a minor violation because:
This limit was a licensee administrative limit. The ASME Code limit was not exceeded and there was no subsequent degradation of vibration of the pump.
It would be more than minor if:
- 1. Subsequent vibration testing revealed degradation into the action range.
- 2. The same issue affected a number of valves tested during the outage, or the issue was repetitive.
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Criterion XVI: Corrective Action Examples:
1.
The inspector during a review of the lighting in the safety injection pump room identified that the lighting is less than FSAR design levels for operator action. The licensee informed the inspector that this condition had been previously identified. However, the corrective action to increase the lighting had been given a low priority and had not been worked for two years after identification. Interviews with operators revealed that some had difficulties conducting surveillances or emergency drills without using flashlight 3 in the safety injection pump room.
it's a violation because:
The licensee failed to take prompt corrective action for a condition adverse to quality, Criterion XVI.
It's a minor violation because:
This is an isolated failure to implement a corrective
. action that has no programmatic implications and no safety impact. Operators are procedurally required to carry flashlights and have had no problems functioning in this reduced light condition as evidenced by no operational errors due to poor
- lighting, h
it would be more than minor if:
If degraded lighting condition contributed to an operator mistake.
2.
In a records storage vault, the licensee observes a ceiling leak. Temporary containers are used to collect water during rainstorms. This " work around" continues for one year, with no functional problems occurring. However, during a heavy weekend rainstorm, s
when no one was available to set the containers, a significant amount of water infiltrates and some safety-related records are damaged, but readable.
It's a violation because:
The licensee failed to correct the water intrusion problem in a prompt manner which could result in damage to records which violates the 10CFR50.71 requirement to maintain certain records.
It's a minor violation because:
This is an isolated failure to implement a corrective action that has no programmatic implications and no safety impact. The safety significance is negligible; in this case, no information was lost.
It would be more than minor if:
Required records had been irretrievably lost.
3.
The system engineer for the safety injection system routinely walks down the accessible portions of the system, looking for component and equipment deficiencies. The inspector does a walkdown of this system and identifies a valve with a missing name-plate, in violation of plant procedures requiring that all valves are labeled. Discussions 10
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with operators reveal that this condition has existed for several years, but that since operators routinely refer to the P&lDs and the valve is routinely operated, all the l
operators have had no problem locating it. Operations believed that this condition had l
been identified by system engineering and were waiting for a fix.
3 it's a violation because:
The system engineer did not identify this condition adverse to quality.
It's a minor violation because:
This is an isolated failure to implement a conective action that has no programmetic implications at :f no safety impact. The operators used the P&lDs and bad no trouble identifying the valve location.
It would be more than minor if:
Improper valve manipulation had occurred due to the missing name-plate.
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During construction of a safety-related concrete wall, a licensee QC inspector observes that an imbedded Richmond insert is cocked at an angle of 6 degrees from the plane of the wall. The specification is +/- 3 degrees. The licensee discovers that the worker who placed the insert failed to use a level as required. For reasons unknown, the condition
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report is closed, without corrective cetion. Subsequently, the same worker mis-orients j
three other inserts. All four inserts were later abandoned in place It's a violation because:
The condition adverse to quality was not corrected and it recurred.
It's a minor violation because:
There mis-oriented inserts represent an isolated failure to implement a corrective action that has no programmatic implications and no safety impact. It had no direct safety impact, since the out-of-specification inserts were abandoned in place.
It would be mere than minor if:
A safety-related attachment had been made to an out-of-specification insert and placed in service.
5.
A small leak occurs on a welded connection in the diesel generator day tank causing a i
slow drip of fuel oil onto the floor in the diesel room. Auxiliary operators note the leak and clean !t with some paper towels. A deficiency tag is hung and maintenance comes to repair the feak. They use a sealant as a temporary repair and write a work order for a permanent weMing repair, which is scheduled for the next outage. Later, the sealant gives way and a6fitional leakage occurs, which soaks a safety-related solenoid and this time is discovered by an electrical engineer. The licensee subsequently determines that the wrong sealant was used in the temporary repair.
It's a violation because:
The licensee failed to correct adequately a condition adverse to quality.
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l R's a minor violation because:
This is an isolated failure to implement a corrective action that has no programmatic implications and no safety impact.. The safety impact was negligible since the diesel generator was always operable.
I It would be more than minor if:
An operational impact with the solenoid or other equipment, not affecting diesel operability, had occurred.
6.
The reach rod for a safety-related valve is jammed and cannot be used. However, by
- walking down the stairs, the valve can be manipulated locally. This condition exists for two years and, despite complaints from the operators, it is not fixed. The NRC inspector notes that this work-around costs about one minute in operator response time and recognizes that manual manipulation of this valve is required by certain off-normal procedures. The valve is accessible during all these off-normal events.
It's a violation because:
The licensee failed to identify and correct a condition adverse to quality.
it's a minor violation because:
This is an isolated failure to implement a corrective action that has nn programmatic implications and little safety impact. The valve could still be 1
operated and the licensee determined that the extra time requirement would not affect recovery operations, it would be more than minor if:
There were occasions where access to the valve could have been restricted for environmental reasons (heat, radiation, oxygen), coincident with a time in which the valve would need to be repositioned for a safety-significant evolution.
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Fire Protect!c5 Examples
'1, NRC Inspectors identified 3 ten-foot 2x4 lengths of wood left from a scaffolding disassembled the previous week, inside the room housing the auxiliary feedwater pumps. The licensee did not have an evaluation approving this temporary storage of transient combustible materials as required by the fire protection plan.
It's a violation because:
These transient combustible materials were not reflected in the fire hazards analysis.
It's a minor violation because:
This is an isolated failure to implement a fire protection plan requirement that has no programmatic implications and little or no safety impact. The licensee was able to show that the transient combustibles were well below the fire hazards analysis limits.
It would be more than minor if:
The fire loading was not within the fire hazard analysis limits but the fire detection and suppression capability in the room provided reasonable assurance that the pumps would remain operable in the event of a fire.
2.
The FSAR states that there is one dry standpipe system isolation valve per level in the turbine building.~ The as-built configuration has two in-series isolation valves per level in the turbine building.
It's a violation because:
This represented a defacto change to the facility that had not been analyzed for an unreviewed safety question.
It's a minor violation because:
This is a failure to meet 10 CFR 50.59 requirements that involves a change to the FSAR description, where there was not a reasonable likelihood that the change to the facility would ever be an unreviewed safety question. This is an isolated failure that has no programmatic implications and no safety impact.
It would be more f.han minor if:
One level of the turbine building did not have any isolation valve resulting in a non functioning hose station for that level.
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3 3.
During an inspection of silicone foam penetration seals, the inspector noted that excess foam extrusion (3/8 inch) from repaired seals was less than the amount specified in the seal repair procedure (1/2 inch). However, the silicone foam vendor's instructions permit c
. extrusions to as little as 1/4 inch.
It's a violation because:
The seal repair was not performed in accordance with the licensee's procedure.
It's a minor violation because:
This is a violation of a licensee administrative requirement. Because the silicone fcam vendors' instructions permit extrusions to as little as 1/4 inch, only the licensee's administrative limit was violated and no regulatory limit was violated.
It would be more than minor if:
Both the licensee and vendor procedures were violated such that the condition would have impacted the ability of the seal to perform its function.
4.
The licensee's procedure required that heat tracing be energized in the diesel fire pump room from September 30 to April 30. In December, an inspector obsen'ed that the heat tracing was de-energized. The room temperature was 68 degrees, maintained by the steam boiler (50 degrees was the minimum temperature for operations). The terrnercture of the room is monitored and annunciated in the control room. An annunciator response procedure instructs the operator to check heat tracing if the room temperature alarms are received. The inspector verified that the temperature in the room had not dropped below 50 degrees since September 30.
It'a a violation because:
A licensee procedural requirement was not met.
It's a minor violation because:
This is an isolated failure to implement a procedural requirement that has no programmatic implications and little or no safety impact under the situation. The temperature had not dropped below the minimum temperature for operations.
It would be more than minor if:
The annunciator was not available or the room-temperature had fallen below 50 degrees.
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- Maintenance Rule Examples.
1.
Inspectors identified that the licensee did not monitor the performance of emergency lighting associated with a motor-operated valve that requires manual operation dt. ring
' Appendix R scenarios. The licensee later determined that due to a procedural oversight, this particular emergency lighting had not been tested since inception of the Maintenance Rule. When the emergency lighting was later tested, it successfully
_ passed.
- It's a violation because:
The Maintenance Rule requires that licensees shall monitor the performance or condition of SSCs against license established goals, in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended function.
It's a minor violation because:
This is an isolated failure to implement the maintenance rule that has no programmatic implications and no safety impact. The licensee's program regarding scoping of non-safety related systems, including emergency lighting, was otherwise satisfactory and this has minor significance because it was not a performance issue. The lighting was found to be functional, and the identified issue was not particularly significant because of compensatory measures that could be taken by.the licensee if needed (flashlights).
It would be more than minor if:
This was more than an isolated example, if the SSC could not perform its intended safety function, or if compensatory measures could not be implemented.
2.
The inspectors identified that the licensee had not scoped and thus failed to adequately demonstrate the performance or condition of functions for the auxiliary service compressed air system. This system is used as a backup to two 100% capacity l
instrument air systems (as described in the FSAR, which provide normal instrument air and safety related compressed air) with little performance problems.
It's a violation because:
It was not scoped within the maintenance rule and if the auxiliary service compressed air system had been placed in service and failed, it may have caused a transient to the operating unit.
I lt's a minor violation because:
This is an isolated failure to implement a maintenance rule requirement that has no 1
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programmatic implications and no safety impact.
L Had it been scoped, the routine maintenance being l
performed on the system was acceptable and L,
would have met the requirements of the maintenance rule.
It would be more than minor if:
It represented a more than isolated problem with scoping of SSCs within the maintenance rule or the i
maintenance being performed on the system would not have met the requirements of the maintenance rule.
3.
The inspectors identified that the licensee failed to include the system unavailability time during TS required surveillance testing of the emergency diesel generators. Although
' the licensee conducts monthly EDG testing, the EDGs are unavailable to perform their intended safety function during TS surveillance testing for a few minutes during each monthly test. The unavailability time due to surveillance testing was insignificant when compared against total unavailability.
It's a violation because: ^
The licensee is required to establish adequate performance measures to demonstrate the SSCs remain capable of performing their intended functions.-
It's a minor violation because:
This is an isolated failure to implement a maintenance rule requirement to track the system unavailability during surveillance testing that has no programmatic implications and no safety impact.
. The small contribution to unavailability due to the j
surveillance testing is insignificant when compared to total unavailability.
i lt would be more than minor if: ' The contribution to unavailability due to surveillance testing was significant or resulted in exceeding established performance measures.
4.
The inspectors reviewed a failure of an SSC and determined that the licensee did not
- identify this as a maintenance preventable functional failure (MPFF). The licensee
' determined this to be an isolated exarnple, and finds that had this failure been included,
'no perf)rmance criteria would be approached or exceeded. The error was due to an
' oversLat by the system engineer, who failed to properly identify this failure as an MPFF on a procedural attachment (the attachment is to be completed and forwarded to appropriate plant personnel for. Maintenance Rule consideration).
L lt's s' violation because:
MPFFs are to be considered when determining the effectiveness of maintenance.
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It's a minor violation because:
This is an isolated failure to implement a maintenance rule requirement to identify the failure as an MPFF that has no programmatic implications and no safety impact. It did not rese!t in exceeding the overall performance criteria established for this
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SSC.
it would be more than minor if : - This'was a routine practice by the licensee (failing
. to consider MPFFs), if a performance criteria would have been exceeded for an extended period of time without establishing appropriate goals and monitoring, or if more than an isolated example.
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3 10CFR50.59 Examples 3.
The licensee develops and approves a preventive maintenance procedure (not required to be approved by the plant onsite review committee) that would require a change be made to the plant TS. and does not perform an evaluation pursuant to 10CFR50.59.
When requested to perform the PM task, control room operators identified that the PM task would violate TS, and did not perform it.
It's a violation because:
A procedure was changed that would require a change to the TS, and NRC approval was not obtained.
It's a Minor violation because:
The licensee own established process identified the problem prior to implementation, and the problem did not affect any equipment and had no safety consequences.
It would be more than minor if:
The task had been performed.
2.
FSAR steps for transferring to the recirculation phase following a LOCA, states to perform the transfer by first using Train A then using Train B. The EOPs were changed to allow concurrent use of both trains.
It's a violation because:
The 50.59 screening review performed to change the EOPS did not recognize that it resulted in a change to the FSAR.
It's a minor violation because:
This is a failure to meet 10 CFR 50.59 requirements that involves a change to the FSAR description, whers there was not a reasonable likelihood that the chango to procedure would ever be an unreviewed safety question. This is an isolated failure that has no programmatic implications and no safety impact. A subsequent evaluation concluded that concurrent use of both trains was acceptable It would be more than minor if:
The evaluation determined concurrent use of both trains was unacceptable.
3.
The FSAR stated that each column of ice condenser baskets consisted of four baskets.
The licensee modified the baskets to add a fifth basket without performing a 50.59 l
review. The addition of the fifth basket did not affect the thermal hydraulic performance of the ice condenser.
It is a violation because:
It was a change to the facility as described in the FSAR.
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It's a minor violation because:
This is a failure to meet 10 CFR 50.59 requirements that involves a change to the FSAR description, where there was not a reasonable likelihood that the change to procedure would ever be an unreviewed safety question. This is an isciated failure that has no programmatic implications and no safety impact.
It would be more than minor if:
The fifth basket caused changes in steam flow following a LOCA that would have resulted in containment design pressure being exceeded or other event constituting a USQ.
4.
Thelicensee approved a temporary procedure to flush the shell side of a steam generator blowdown heat exchanger. The 10CFR50.59 screening four:d that the i
procedure did not affect the facility as described in the FSAR. However, the procedure change opened a valve that bypassed a high radiation function of a steam generator blowdown radiation monitor which was described in the FSAR.
It was a violation because:
The10CFR50.59 incorrectly found that the procedure change did not affect the facility as described in the FSAR.
It's a minor violation because:
This is a failure to meet 10 CFR 50.59 requirements that involves a change to the FSAR description, where there was not a reasonable likelihood that the change to procedure would ever be an unreviewed safety question.
This is an isolated failure that has no programmatic i
implications and no safety impact. In the event of a steam generator tube rupture, the emergency operating procedure directed operators to line up to the monitored tank, so no unmonitored ;elease would occur.
It would be more than minor if:
The procedure lined up the radioactive water to an unmonitored release path and a release occurred.
5.
The licensee identified an error in a revised calculation for an analysis of radiation dose from a release during the design basis LOCA. The dose operators could receive was increased, but was less than FSAR and regulatory limits.
It is a violation because:
The calculation failed to identify that a de facto change had been made to the facility without an attenda.it 10CFR50.59 analysis.
l It's a minor violation because:
The FSAR dose rates did not change significantly and no regulatory limits were exceeded. This is a failure to meet l
10 CFR 50.59 requirements that involves a change to the FSAR description, where there was not a reasonable likelihood that the change to procedure would ever be an 19 I
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g o-unreviewed safety question. This is an isolated failure that has no programmatic implications and no safety impact.
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It would be more than minor if:
The FSAR values changed significantly or if
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regulatory limits were exceeded.
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i Technical Specification Examples:
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The TS require a primary sample be taken and analyzed within two hours of a power change in excess of 20E The inspector, while reviewing control room operator logs i
determined that after a recent power increase from 60-85%, the chemistry sample was taken and analyzed in two hours and 35 minutes. The sample was in specification.
It's a violation because:
TS was violated l
114 a' minor violation because:
This is an isolated failure to implement a requirement that has no programmatic implications and no safety impact. The sample delay was not significant.
It would be more than minor if:
The sample had not been conducted or was delayed to the extent that the sample results were I
not reliable.
2.
The TS states that the members of the Offsite Safety Review Board will have, at a minimum, a bachelor degree in a technical field. One member has a degree in business only.
It's a violation because:
TS was violated
~ lt's a minor violation because:
This is an isolated failure to implement a requirement that has no programmatic implicaticas and no safety impret.
4 It would be more than minor if:
The licensee fails to revise the Technical Specification (the violation would be cited for failure to take adequate corrective actions).
3.
The TS requires that 1/3 of all safety-related molded case circuit breakers (MCCB) will be tested each refueling outage (such that all are tested every three outages) and that the instantaneous trip currents will be recorded for trending purposes. The NRC inspector finds that two outages ago during testing, the instantaneous trip current for a safety-related circuit breaker was not tested or recorded. The last recorded trip current for this breaker was five outages ago. The subject MCCB was subsequently found to be in specification.
It's a violation because:
The TS was violated, because all required tests were not performed on the breaker within three outages.
It's a minor violation because:
This is an isolated failure to implement a procedural requirement that has no programmatic l
implications and no safety impact. There is no 21
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safety significance, since all other tests on the MCCB were satisfactorily at the time of the testing t
and the trip was subsequently found to be in specification.
l it would be more than minor if:
The subject MCCB was out of specification or i
additional examples were discovered.
4.
The TS states that 10 percent of all safety-related snubbers are to be tested each refueling outage and that if one failure occurs, an additional 10 percent sample must be tested during the same outage. One snubber in the original population of 17 snubbers i
(there are a total of 168 safety-related snubbers) fails, necessitating an additional j
sample. However, because of an oversight by the licensee, only 16 additional snubbers (with no failures) are tested before startup.
It's a violation because:
The TS was violateo as only 16, instead of 17, were additionally selected for testing i
lt's a minor violation because:
This is an isolated failure to implement a procedural requirement that has no programmatic l
implications and no safety impact. There is no safety significance, since none of the additional 16 l
snubbers failed.
It would be more than minor if:
A failure had occurred in the additional sample, necessitating yet another expansion of the sample,
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and this had not been accomplished.
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Other Minor Violation Examples:
.1. Exceeding administrative limit The NRC requires licensees to maintain the total ef1ective dose equivalent (TEDE) to five rem per year. The licensee established by procedure an administrative limit of 2 rem per year. Plant manager approval was required for any individual to exceed the 1,
procedurallimit. Contrary to the licensee's program, a maintenance technician received 2.7 rem in one year without approval from the plant manager.
It's a violation because:
The licensee is required to follow their procedures i
per TS 6.8.1.
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It's a minor violatir;t because:
This was an licensee administrative limit. The worker was still within federal limits.
It would be more than minor if:
Multiple examples were identified of failures to satisfy station radiation protection procedures indicating a failure to maintain and implement programs to keep exposures ALARA.
- 2. Work in progress An NRC inspector is observing a surveillance test. The I&C technician mistakenly omits one step during the test. After performing additional steps the mistake is identified and the technician immediately suspends the test to review the situation.
it's a violation because:
The licensee is required to follow their procedures per 'O CFR 50, Appendix B, Criterion V and TS 6.8.1 if applicable.
It's a minor violation because:
It is work in progress and there were no adverse consequences.
. It would be more than minor if:
The mistake is not discovered until a supervisor review of the completed and closed out procedure and there were some adverse consequence associated with the failure (if no adverse consequences existed it would still be considered minor).
- 3. Post work test discovers error During installation of a modification, the licensee failed to follow the installation procedures and a check valve is installed backward. QC does not detect the error.
During a post-modification test, prior to returning the system to service, the licensee discovers the problem.
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lt's a violation because:
The licensee failed to correctly translate the design to the as-built configuration.
It's a minor violation because:
it is work in progress and there is no safety consequences.
It would be more than minor if:
The system was returned to service and declarsd l-operable.
- 4. Minor dimensional / time nonconformances 4
The licensee's security fence is required to be 12 feet tall. The NRC discovers that, in one section, the fence is only 11 feet 10 % inches tall. The licensee is required to submit an LER within 30 days of the event. The LER is submitted 32 days following the event.
It's a violation because:
Both are regulatory requirements, it's a minor violation because:
Neither is a significant dimensional discrepancy.
- it would be more than minor if:
The fence had been significantly shorter (e.g.11 feet) or if no LER was submitted
- 5. General procedural noncompliance An operating procedure requires the shift supervisor to advise the station manager paor to making any mode changes. A mode change is made v'ithout this notification.
It's a violation because:
The licensee is required to follow their procedures per 10 CFR 50, Appendix B, Criterion V and TS 6.8.1, if applicable.
-it's a minor violation because:
This is a minor procedural error that had no impact on safety equipment and caused no saiety consequences. All requirements for the mode change were met except this notification.
'It would be more than minor if:
A mode change as made without all required equipment being operable.
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- 6. Minor reporting problems in an LER, the licensee reports that a particular problem had occurred twice before. The NRC later discovers that the problem had actually occurred three times previous.
It's a violation because:
Under 10 CFR 50.9, the licensee is required to provide complete and accurate information in all material respects, i
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ya It's a minor violation because:
. This is an isolated failure to include accurate information that has no programmatic implications and no safety impact. The failure to report the third occurrence was probably an inadvertent mistake.
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lt would be more than minor if :
The licensee was aware of the omission and
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submitted the LER anyway.
- 7. Minor calculation / drawing problems 1
A controlled design drawing shows a plug valve where a ball valve is actually installed.
This problem occurred because of an isolated oversight by the licensee.
It's a violation because:
The design is required to be correctly translated into drawings.
It's a minor violation because:
This is an non significant drawing deficiency.
It would be more than minor if:
Operation of the system had been adversely affected by the difference in valves.
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- 8. Minor measuring and test equipment discrepancies A torque wrench exceeding its calibration interval was used on a safety-related job. The j
wrench was actually in tolerance (when later checked) l it's a violation because:
The licensee is required to assure that M&TE used in activities affecting quality are calibrated at specified intervals.
It's a minor violation because:
This is an isolated failure to calibrate M&TE that has no programmatic implications and no safety impact. The wrench was actually in tolerance (when later checked) and the incident was isolated.
It would be more than minor if:
The wrench was out of tolerance, resulting it a lack of reasonable assurance that torque being applied was adequately performed on safety-related systems, or the issue was not isolated.
- 9. Nonconforming parts accepted but not installed A solenoid of incorrect specification is screened though receipt inspection and placed in
- the warehouse. When the solenoid was withdrawn to be installed, an electrician noted that it was not the correct type.
It's a violation because:
The licensee is supposed to establish controls to prevent nonconforming parts from being used 25
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inadvertently and the wrong part could have been installed if it had not identified by the electrician.
It's a minor violation because:
it was work in progress and no adverse consequences resulted.
It would be more than minor if:
The valve were installed and the system was returned to service.
- 10. Minor USAR discrepancies The FSAR states the volume of the RWST is 250,000 gallons. The actual volume is 248,000 gallons.
It's a violation because:
The facility was not consistent with the FSAR, and an analysis was not performed pursuant to 10 CFR 50.59.
It's a minor violation because :
This is a non significant isolated dimensional discrepancy.
It would be more than minor if:
The accident analysis assumed 250,000 gallons of useable volume above the suction point and the actual volume required accident analysis calculations to be re-performed to assure the accident analysis requirements were met.
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I DISTRIBUTION:
RBorchardt, OE cc:
Chr. Dice OE Staff D. Danbly, OGC Conn Diaz j
g Enforcement Coordinators Corm ItGaffigan J. Zwolinski NRR RI, RII, Rlli, RIV, NMSS, NRR (Also by E-Mail)
Ccmn. Merrifield W. Kane, NMSS PUBLIC W. Travers, E Day File F. Miraglia, DEDR M. Virgilio, NMSS C. Paperiello, DEDMRS l
G:/Barrf/ilinor Violationrev.wpd I
- NRil, OE:D [
--BMich (Na BBorch$dt c/n[h 9 alw 9-pr.Sv 27