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05000266/FIN-2018003-0130 September 2018 23:59:59Point BeachNRC identifiedFailure to Perform Evaluations to Ensure that the Fabrication of Dry Cask Storage Systems Meets the Requirements of the Loading Certificate of ComplianceAn NRC-identified Severity Level IV NCV of 10 CFR 72.212 was identified when the licensee failed to perform written evaluations to ensure that the dry cask storage systems met the fabrication requirements of the Certificate of Compliance (CoC) to which they were loaded.
05000266/FIN-2016003-0130 September 2016 23:59:59Point BeachLicensee-identifiedLicensee-Identified ViolationThe licensee identified a non-cited violation of very low safety significance of 10 CFR 72.150,Instructions, Procedures, and Drawings. Title 10 CFR 72.150, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and be accomplished in accordance with these procedures. The licensee established PBF5101, Fuel/Insert/Component Movement Authorization, Revision 17, as the implementing procedure for dry fuel storage fuel loading, an activity affecting quality. Procedure PBF5101 contains instructions for fuel handlers to move specific fuel assemblies from specific spent fuel pool locations into specific dry shielded canisters (DSCs) and DSC locations. Contrary to the above, on July 18, 2016, the licensee failed to follow PBF5101. Specifically, the licensee was utilizing a PBF5101 labeled for DSC25 during the loading of DSC24. This resulted in three fuel assemblies being incorrectly loaded into DSC24. The license entered the issue into its corrective action program under AR 02144237, dated July 18, 2016, and initiated actions to perform an apparent causal evaluation. The inspectors identified that DSC24 and DSC25 have identical design characteristics and therefore there was no actual safety significance to this event. Consistent with the guidance in Section 2.2 of the NRC Enforcement Policy, ISFSIs are not subject to the Significance Determination Process and, thus, traditional enforcement will be used for this issue. However, the inspectors determined that the violation significance could be informed by the significance determination process as no similar violations existed in the enforcement policy violations examples. The inspectors determined that the violation could be evaluated using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 3, Barrier Integrity Screening Questions. This resulted in the violation screening as Severity Level IV.
05000266/FIN-2014007-0331 March 2014 23:59:59Point BeachNRC identifiedFailure to Perform a Required 10 CFR Part 50.59 EvaluationThe inspectors identified a finding of very low safety significance and associated Severity Level IV, non-citied violation of 10 CFR 50.59(d)(1), Changes, tests and experiments, when, on November 25, 2013, the licensee failed to perform an evaluation against the criteria in 10 CFR 50.59(c)(2) for a change to procedure PC 80 Part 7 to include actions to maintain functionality of drainage paths during probable maximum precipitation and turbine building flooding events. Specifically, PC 80 Part 7, Lake Water Level Determination was changed to include actions to open the CWPH rollup doors to provide an additional drainage path while wave barriers were in place, without fully evaluating the viability of reliance on additional flood features not credited for external flooding in the Current License Basis (CLB). Corrective actions for this issue included to updating the FSAR to describe the new flood paths, performing a 10 CFR 50.59 screening and 10 CFR 50.59 evaluation for the new drainage path which had put the site outside of the CLB, revising a related functionality assessment, controlling external flooding areas to ensure they are clear of debris, and creating a procedure to install curtains on the CWPH rollup doors during periods when they were required to be open. The inspectors determined that the licensees failure to fully evaluate the viability of newly created flooding drainage paths as required by 10 CFR 50.59(d)(1) was a performance deficiency. The inspectors evaluated the performance deficiency using traditional enforcement in conjunction with the SDP because the performance deficiency had the potential to impact the regulatory process. The performance deficiency was screened per the guidance of lMC 0612, Appendix B, and determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attributes of Protection Against External Factors (Flood Hazard) and Design Control, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the licensee did not fully demonstrate that the availability, reliability, and capability of mitigating systems would be maintained during flooding events due to the sites failure to evaluate the viability of alternate flood drainage paths through the CWPH. The inspectors evaluated the finding using IMC 0609, Attachment 0609.04, Tables 2 and 3, and Appendix A. Based on a review of Appendix A, Exhibit 2, Item 4.B, the inspectors determined that this issue screened as having very low safety significance (Green). Additionally, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as a Severity Level IV because the resulting conditions were evaluated as having very low safety significance (Green) by the SDP. This finding has a cross-cutting aspect in the area of problem identification and resolution, because the licensee failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance.
05000266/FIN-2013002-1131 March 2013 23:59:59Point BeachNRC identifiedFailure to Update the External Flooding Mitigation Features in the FSARA SL-IV non-cited violation of 10 CFR Part 50.71(e), Maintenance of Records, Making of Reports, was identified by the inspectors for the licensees failure to comply with the requirements to periodically update the FSAR to include an accurate description of the flooding design and credited mitigation features for the site as a result of a modification made to the plant. The issue was entered into the licensees CAP as AR01819241 for evaluation and development of corrective actions. The inspectors used IMC 0612, Appendix B, and determined the performance deficiency could be dispositioned using traditional enforcement. Specifically, the inspectors determined that the issue was considered for traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The inspectors concluded that the finding is more than minor because, if left uncorrected, this could lead to a more significant safety concern because future changes to the facility, procedures, and programs would not consider the licensing basis information that was removed or never inserted. The finding was determined to be a SL-IV violation using Section 6.1 of the NRCs Enforcement Policy because the inaccurate information was not used to make an unacceptable change to the facility or procedures. Since this performance deficiency was dispositioned using traditional enforcement, there is no cross-cutting aspect assigned.
05000266/FIN-2013002-0831 March 2013 23:59:59Point BeachNRC identifiedFailure to Submit LER 05000266/2012-003-00, 2B-04 Safeguards 480V Bus DE-ENERGIZED, within 60 DaysA Severity Level IV (SL-IV) non-cited violation of 10 CFR 50.73(a)(1), Licensee Event Report (LER) System, with an underlying Green issue was identified for the licensees failure to submit an LER in accordance with 10 CFR 50.73(a)(2)(i)(B) and 10 CFR 50.73(a)(2)(v)(D) within 60 days for a valid loss of safety-related electrical bus 2B-04, Unit 2 480V Safeguards Bus. This issue was entered into the licensees CAP as AR01851639 for evaluation and development of corrective actions. The finding was determined to be more than minor in accordance with IMC 0612, Appendix B, because, if left uncorrected, it would have the potential to lead to a more significant safety concern, since untimely reporting of issues hinders the inspectors ability to perform to perform timely and adequate regulatory reviews of the cause and underlying issues. Specifically, the inspectors determined that the issue was considered as traditional enforcement because it had the potential for impacting the NRCs ability to perform regulatory functions and constituted a SL-IV NCV, consistent with the examples contained in Section 6.9 of the Enforcement Policy. The inspectors reviewed the underlying issue associated with the mitigating systems cornerstone and determined that the finding has a cross-cutting aspect in the area of problem identification and resolution, evaluation, because the licensee failed to thoroughly evaluate the problem such that the resolutions properly addressed operability and reportability
05000266/FIN-2012004-0730 September 2012 23:59:59Point BeachNRC identifiedShift Manager Working Outage Hours Contrary to GuidanceThe inspectors identified a Severity Level lV non-cited violation and associated finding of very low safety significance of 10 CFR 26.207(a), Waivers, for the licensees failure to perform multiple activities as required when licensed reactor operators in the shift manager (SM) position worked outage hours during the Unit 1 outage in fall 2011. Specifically, for each circumstance where an SM exceeded operating hours, the licensee did not meet the following requirements: a determination that the waiver is necessary to mitigate or prevent a condition adverse to safety; a face-to-face assessment of the individual to determine that there was reasonable assurance that the individual would be able to safely and competently perform his or her duties during the additional work period for which the waiver will be granted; and a circumstance did not exist that could not have been reasonably controlled because additional personnel could have been added to the shift to perform the related outage activities. The issue was entered into the licensees corrective action program for resolution as action request AR01797782, for evaluation and development of corrective actions. The finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because if left uncorrected, the exclusion of workers from work hour controls could have led to a more significant safety concern due to personnel exceeding work hour limits while performing safety related or risk significant activities. Specifically, without proper fatigue assessments, incorrect assessment or directions could be provided by the SM for routine activities or during transient/emergency response. The inspectors evaluated the finding using IMC 0609, Significance Determination Process, Attachment 0609.04 Initial Characterization of Findings, Tables 2 and 3, dated June 19, 2012, and Appendix M, Significance Determination Process Using Qualitative Criteria, dated April 12, 2012. The inspectors determined that the finding was of very low safety significance because no deficiencies which affected risk significant structures, systems, or components occurred as a result of SM fatigue. This finding has a cross-cutting aspect in the area of problem identification and resolution, self and independent assessment, because the licensee failed to conduct sufficient in-depth self-assessments. Specifically, the licensee conducted a self-assessment of the fatigue rule annually with its corporate licensing department giving the licensee the prior opportunity to identify and correct this issue had the self-assessments been more rigorous
05000266/FIN-2012004-0930 September 2012 23:59:59Point BeachNRC identifiedFAILURE TO PERFORM ADEQUATE EVALUATIONS TO ENSURE COMPLIANCE WITH 10 CFR 72.212(b)(6) AND 10 CFR 72.122(b)(2)(i)The inspectors identified a Severity Level lV non-cited violation of 10 CFR 72.146, Design Control, for the licensees failure to perform adequate evaluations to ensure compliance with 10 CFR 72.122(b)(2)(i) and 10 CFR 72.212(b)(6). Specifically, the inspectors identified that the licensee failed to evaluate that the reactor site parameters, including analyses of earthquakes, were enveloped by the transfer cask design basis. The issue was entered into the licensees corrective action program for resolution as action request AR01780357, for evaluation and development of corrective actions. The violation was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, and Appendix E, Example of Minor Issues, dated August 11, 2009, and found that it was similar to Example 3i. Specifically, the licensees lack of evaluation did not assure cask integrity during a design basis earthquake and an additional calculation was required to evaluate the effects of the design basis earthquake during dry shielded canister processing operations in the primary auxiliary building on the cask decontamination stand in accordance with the Independent Spent Fuel Storage Installation (ISFSI) licensing/design basis analysis requirements. Consistent with the guidance in the NRC Enforcement Manual, Section 2.6.D, if a violation does not fit an example in the enforcement policy violation examples, it should be assigned a severity level: (1) commensurate with its safety significance; and, (2) informed by similar violations addressed in the Violation Examples. Therefore, the inspectors determined violation screened as having very low safety significance (Severity Level IV). Specifically, following the inspection inquiry the licensee revised their calculations and determined that overturning and sliding of the transfer cask in the primary auxiliary building on the cask decontamination stand and in the spent fuel pool would not occur during the design basis earthquake. In accordance with Section 2.2 of the NRC Enforcement Policy, ISFSIs are not subject to the Significance Determination Process (SDP) and, thus, traditional enforcement will be used for these facilities and thus a cross-cutting aspect is not assigned to this violation. In accordance with Section 2.2 of the NRC Enforcement Policy, ISFSIs are not subject to the SDP and, thus, traditional enforcement will be used for these facilities and thus a cross-cutting aspect is not assigned to this violation.
05000266/FIN-2010005-0331 December 2010 23:59:59Point BeachNRC identifiedFailure to Submit LER per 10 CFR 50.73(a)(2)(v)(A) and (D)A Severity Level IV non-cited violation of 10 CFR Part 50.73(a)(2)(v)(A) and (D) was identified by the inspectors for the failure of the licensee to report an event or condition that could have prevented the fulfillment of the auxiliary feedwater and safety injection safety functions, which are relied upon to shutdown the reactor and maintain it in a shutdown condition, and mitigate the consequences of an accident. Specifically, the licensee had not properly controlled the blocking open of doors that served as high energy line break barriers. The licensee entered the violation into its corrective action program as condition report 01616620 and revise the procedure on control of high energy line break barriers. Violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process and are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process Significance Determination Process. A cross-cutting aspect was not assigned to this violation.
05000266/FIN-2010010-0131 March 2010 23:59:59Point BeachNRC identifiedInaccurate Information Relating to Signatures on Ignition Control ProceduresA Severity Level IV, Cited Violation of 10 CFR 50.9(a) Completeness and Accuracy of Information, was identified by the inspectors for the licensees failure to maintain complete and accurate information required by the Commission. Specifically, a Point Beach Nuclear Plant employee and two contract employees from Day and Zimmermann Nuclear Power Services, signed Ignition Control Permits without the authorized person inspecting the areas as required by the ignition control procedure NP 1.9.13. The violation affected the NRCs ability to perform its regulatory function because it involved willfulness. Therefore, it was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the willful nature of some violation examples. The NRC determined that the violation should be cited because: (1) the violation was NRC-identified; and (2) it was willful; and (3) it involved a first-line supervisor.
05000266/FIN-2008009-0530 September 2008 23:59:59Point BeachNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for Changes to SI System Valve Back-Seating ProceduresThe inspectors identified a Severity Level IV NCV, having very low safety significance, of 10 CFR 50.59, AChanges, Tests, and Experiments@, for the licensee=s failure to provide documented basis for determining that changes to procedures did not require prior NRC approval. Specifically, the licensee incorrectly concluded that a 10 CFR 50.59 screening was not required when procedures were revised to eliminate the practice of back-seating normally open gate/globe valves even though the UFSAR stated that normally open gate/globe valves in the Safety Injection (SI) system are back-seated to limit valve stem leakage. The finding was determined to be more than minor because the team could not reasonably determine that the change to the plant procedure which had removed a barrier to release radioactivity into the PAB would not have ultimately required NRC prior approval. The finding was determined to be of very low safety significance because it only represented a degradation of the radiological barrier function provided for the auxiliary building. This finding has a cross-cutting aspect in the area of Human Performance, Decision Making, because during performance of the 10 CFR 50.59 applicability determination for a procedural change, in March 2008, the licensee made an inappropriate decision by failing to require a screen or full 50.59 evaluation. (H.1.(a)). (Section 1R21.3.b.5
05000266/FIN-2005018-0131 December 2005 23:59:59Point BeachNRC identifiedUpdated Final Safety Analysis Report Change to Replace ASME Class Ii, Seismic Class I, Piping with a Freeze Seal

The inspectors identified a Severity Level IV Non-Cited Violation associated with the failure to perform an adequate safety evaluation review as required by 10 CFR 50.59 for changes made to the facility as described in the UFSAR. In safety evaluation, EVAL 2004- 003, the licensee failed to provide a basis for the determination that on-line repairs to the excess letdown line with a freeze seal in place as a boundary for Reactor Coolant System (RCS) effluent from the Reactor Coolant Pumps (RCPs) was acceptable without a license amendment. Specifically, for this freeze seal evolution, the licensee would have replaced the American Society of Mechanical Engineers (ASME) Class II, Seismic Class I piping in the excess letdown line with a freeze plug while the plant was still on-line. Within the 10 CFR 50.59 evaluation, the licensee failed to provide a basis for why this freeze seal evolution did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a Structure, System and Component (SSC) important to safety. As a result of this issue, the licensee performed a revision to the original safety evaluation to withdraw the facility change that allowed the freeze seal with the plant online.

Because the issue affected the NRCs ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that the UFSAR change, which adversely affected equipment important to safety, would not have ultimately required NRC approval. The finding was determined to be of very low safety significance (Green), because the inspectors answered no to all three questions under the Containment Barriers Cornerstone column of the Phase 1 worksheet. Specifically, the licencee had not actually performed this evolution when the pressure boundary was required to be intact.

05000266/FIN-2005018-0231 December 2005 23:59:59Point BeachNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for Compensatory Actions Associated with Letdown Line Automatic Isolation

The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.59(d)(1) for the licensees failure to perform a safety evaluation for compensatory actions taken for an activity associated with a degraded plant condition. Specifically, the licensee screened out an activity which replaced an automatic action for Chemical and Volume Control System (CVCS) letdown isolation on low pressurizer level with a manual action to isolate letdown on low pressurizer level, while replacing the Unit 2 pressurizer low level bistables with Unit 2 online at power. At the end of the inspection period, the licensee planned to perform a safety evaluation in accordance with 10 CFR 50.59 for the compensatory actions taken for the activity associated with the degraded plant condition.

Because the issue affected the NRCs ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors, at the time of the inspection, could not reasonably determine that the UFSAR change, which adversely affected equipment important to safety, would not have ultimately required NRC approval. The inspectors evaluated the finding using IMC 0609, Appendix A, Phase 1 screening for the mitigating systems cornerstone and determined that the finding was of very low safety significance because the finding was not a design or qualification deficiency that was confirmed to result in a loss of operability or functionality per Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessment.

05000266/FIN-2005011-0330 September 2005 23:59:59Point BeachNRC identifiedNo. 50.59 Safety Evaluation for a 2002 Modification to AFW

The inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.59(d)(1) for the licensee's failure in September 2002 to perform a safety evaluation of the removal of the internals of the auxiliary feedwater (AFW) common recirculation line check valve, AF-117. Specifically, the licensee screened out' adverse changes made concerning the function and operation of all four AFW pumps. In this case, an automatic passive design feature of the AFW recirculation line piping was being made unavailable and the function was being changed to operation of an untested, nonsafety-related, active component--the AFW common recirculation line relief valve AF-4035--and it was being supplemented through the use of manual operator actions. This change warranted a 10 CFR 50.59 safety evaluation to determine if the changes met the criteria requiring a licensee amendment.

Because the issue potentially affected the NRC's ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. This finding was determined to be more than minor because the inspectors could not reasonably determine that the original change would have ultimately required NRC approval. The inspectors completed a Significance Determination Review using IMC 0609, Appendix A "Significance Determination of Reactor Inspection Findings for At Power Situations." Using the Phase 1 Screening worksheet the finding was determined to be of very low safety significance (Green) since the finding did not represent an actual loss of safety function for greater than the Technical Specification allowed outage time. Comparing this item to the examples in NUREG 1600, Supplement I, this finding is similar to Item D.5, "Violations of 10 CFR 50.59 that do not involve circumstances in which a change that required prior Commission approval would not be found acceptable had the approval been sought." As a result, the issue was considered to be of very low safety significance and was dispositioned as a Severity Level IV, Non-Cited Violation (NCV).

05000266/FIN-2004012-0231 December 2004 23:59:59Point BeachNRC identifiedFailure to Perform a Safety Evaluation as Required by 10 CFR 50.59, "Changes, Tests and Experiments"

The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.59(d)(1) for the licensee's failure to perform a safety evaluation for changes made to the Final Safety Analysis Report. Specifically, the licensee screened out' a change to the Final Safety Analysis Report which modified operator response times for the Steam Generator Tube Rupture Chapter 14 Accident Analysis contained in the Final Safety Analysis Report. Specifically, a time requirement for equalizing primary and secondary pressure was removed from the Final Safety Analysis Report. In addition, the licensee changed the time in which isolation of the affected Steam Generator could be achieved from 10 minutes to 30 minutes. At the end of the inspection period the licensee initiated a corrective action to perform a safety evaluation in accordance with 10 CFR 50.59 for this Final Safety Analysis Report change.

Because the Significance Determination Process is not designed to assess the significance of violations that potentially impact or impede the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of the violation were assessed using the Significance Determination Process.

This finding was determined to be more than minor because the inspectors could not reasonably determine that the change would not ultimately require NRC approval. The inspectors determined that even though the change was not adequately evaluated in accordance with 10 CFR 50.59, this violation was of very low safety significance because the design basis safety-related functions of mitigating systems to respond to this initiating event scenario were not adversely affected. The inspectors evaluated the results of the finding using the Significance Determination Process for the mitigating systems cornerstone. The inspectors determined that the results of the finding were of very low safety significance because the finding was not a design or qualification deficiency that was confirmed to result in a loss of function per Generic Letter 91-18. Therefore, the results of the violation were determined to be of very low safety significance and the violation was classified as a Severity Level IV Non-Cited Violation.

05000266/FIN-2003007-0231 December 2003 23:59:59Point BeachNRC identified10 CFR 50.9 Violation for Failure to Report in the Third Quarter of 2001 That the Emergency Response Organization Performance Indicator Crossed the Significance Threshold from Green to White

The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.9 because the licensee failed to provide complete and accurate information in the submittal of information for the emergency response organization (ERO) performance indicator (PI). Twenty-three onshift communicators should have been tracked and reported in the ERO PI, but were not. The licensee has subsequently submitted corrected PI data to the NRC.

This issue is greater than minor because it caused the PI to cross the Green-to-White threshold for the 3rd quarter of 2001. Because this issue affected the NRC's ability to perform its regulatory function, it was evaluated with the traditional enforcement process.

05000266/FIN-2003010-0131 December 2003 23:59:59Point BeachNRC identifiedFailure to Perform an Adequate Safety Evaluation for Changes to the Plant as Described in the USARThe inspectors identified a Severity Level IV Non-Cited Violation associated with the failure to perform an adequate safety evaluation review as required by 10 CFR 50.59 for changes made to the facility as described in the Updated Safety Analysis Report (USAR). Specifically, the licensee deleted Technical Requirements Manual (TRM) Surveillance Requirement TSR 3.5.1.3, which required that a quarterly flowrate test be performed for the charging pumps, but failed to provide a basis for the determination that this deletion was acceptable without a license amendment. The safety evaluation failed to address the purpose of the flowrate test which was to ensure that one changing pump could sufficiently compensate for the addition of positive reactivity from the decay of xenon after a reactor trip. Because the Significance Determination Process (SDP) is not designed to assess the significance of violations that potentially impact or impede the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of the violation, that is, the failure to evaluate the deletion of TSR 3.5.1.3 from the TRM, were assessed using the SDP. The team considered this issue of more than minor significance, because if left uncorrected, the finding could become a more significant safety concern. The inspectors determined that the issue was of very low safety significance, because the licensee was still measuring quarterly charging pump flow rates for the testing of the pumps discharge check valves. The resultant flow rates bounded the requirements of the deleted TRM Surveillance Requirement. Therefore, the results of the violation were determined to be of very low safety significance and the violation of 10 CFR 50.59 was classified as a Severity Level IV violation. Because this non-willful violation was non-repetitive, and was captured in the licensees corrective action program, this issue is being treated as a Non-Cited Violation, consistent with the NRC Enforcement Policy
05000266/FIN-2002014-0130 June 2003 23:59:59Point BeachNRC identifiedDecreased an Emergency Plan Commitment Without Prior NRC ApprovalIn October 1998, the licensee decreased its Emergency Plan's effectiveness without prior NRC approval due to an inadequate 10 CFR 50.54(q) review of six Emergency Response Organization (ERO) positions, which the licensee recategorized from being 30 minute response positions to be 60 minute response positions. These six positions were reestablished as 30 minute response positions in late January 2003. This Severity Level IV violation is being treated as a NCV consistent with Section VI.A.1 of the NRC Enforcement Policy.