Approved 9/27/99 REQUIREMENT C. Safety Status Degradation. Off-Normal (1) Discovery of a condition that leads the facility operating personnel to limit facility operations, either self-imposed or due to the identification of a potential degradation of the authorization bases of a facility or process. This includes the discovery of analytical errors, omissions, or inadequacies that present the potential for a USQ. (2) Discovery of a potential USQ that could affect the present or future operation of the facility. Routine USQ determinations due to planned system or operational modifications are not reportable under this criteria. INTERPRETATION What is the intent of the reporting threshold of Off-Normal Occurrences in Group 1.C. Intent: To report events 1) for which the facility management considers the concern to be credible and 2) that warrant limiting facility operations until further information is obtained. Additional Information: The initial questions of an Unreviewed Safety Question Determination (USQD) need to be completed to categorize the condition. For example, on the night shift a Shift Technical Engineer identifies a potential concern and brings it to the attention of the Shift Manager. Neither person is an expert in this area and decide to continue to operate and wait until normal business hours to inform their management. The FM and Engineering Manager are informed at 0800 hours of the concern. At 0900 hours after discussions with the Engineering Manager, the FM determines that the concern is credible and orders the facility to shut down until further information is known. The condition is reportable under 1.C.ON(1) with a discovery time of 0900, corresponding to the time when the facility was ordered shut down. Subsequently, the condition is evaluated and it is determined that there is no valid concern and the facility returns to operation. If instead of shutting down the facility, suppose that the Facility Manager directed the Engineering Manager to perform a USQD. The USQD is performed and verified and the results indicate that a potential unreviewed safety question (USQ) exists and facility operations are limited. This condition is reportable under criteria 1.C.ON(2) with the discovery time being the time the USQD is verified. If the potential USQ is associated with a planned modification to the facility, then the condition is not reportable. These situations are part of the routine engineering design and modification process and must be resolved prior to implementing the modification. |
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