The following violations of very low safety significance (Green) or
Severity Level IV were identified by the licensee and are violations of NRC requirements which meet the criteria of the
NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation.Title
10 CFR 50.55a(f), Inservice testing requirements, subsection (4) required, in part, that pumps and valves which are classified as
ASME Class 1, Class 2, and Class 3 must meet the inservice test requirements set forth in the
ASME OM Code. The
ASME Code of record for Vogtle for Operation and Maintenance of Nuclear Power Plants (
OM) is the 2004 edition through 2006 addendum. Subsection ISTC-1300, Valve Categories, required in part, that valves within this subsection shall be placed in one or more of the following categories. Category A is for valves for which seat leakage is limited to a specific maximum amount in the closed position for fulfillment of their required function(s), as specified in ISTA-1100. Contrary to the above, since 1991, the licensee did not categorize valves in
ECCS recirculation flow paths to the
RWST as Category A valves to ensure the
ASME OM test requirements were met by leak testing the valves to demonstrate that their seat leakage would limit the consequences of an accident to control room operators and to the public at the site boundary per Title
10 CFR Part 100 limits. The inspectors determined this finding was of very low safety significance (Green) because the issue would only have the potential to represent a degradation of the radiological barrier function provided for the control room. This issue was documented in the licensees
CAP as CR 829367 and
TE 886122.
