Approved 9/27/99 REQUIREMENT F. Violation/Inadequate Procedures Off-Normal (2) Use of inadequate procedures or deviations from written procedures that result in adverse effects on performance, safety, or reliability. INTERPRETATION Criteria 1.F.ON(2) requires reporting for the use of inadequate procedures or deviation from written procedures that result in adverse effects on performance, safety, or reliability. Describe the intent of adverse effects. Intent: It is not intended to report all uses of inadequate procedures or deviations from written procedures. Good conduct of operations requires follow-up when these events occur. It is intended to evaluate the effect of the event and determine the effect on performance, safety, or reliability. Willful and repetitive procedure violations are always considered to have an adverse effect on performance, safety and/or reliability, even if no injury or damage results. Additional Information: For example, non-facility personnel inadvertently enter a posted Contamination Area because they did not notice or read the markings on the door prior to entry. They were immediately stopped and the RadCon Technician and Shift Manager were notified. They were removed from the area and surveyed with negative results. No other effects were identified. The facility then determines that this event was not reportable, but holds a critique to determine the facts of the event in accordance with the good practice of conduct of operations. If it is determined at the critique that non-facility personnel have inadvertently entered posted Contamination Areas several times in the recent months, the event should be reported as collectively significant related occurrences under Group 10.A. Or, if the personnel in the above example willfully violated the posting requirements, the event would be reportable, because willful procedure violations are considered indicative of a personnel attitude that adversely affects safety. Another example may be when an operating procedure is used to transfer high level waste from one tank to another. The procedure was inadequate in that the transfer resulted in partially transferring the waste material to an unintended location. The transfer was stopped and the facility was placed in a safe condition. The event is reportable since the use of an inadequate procedure caused an adverse affect on performance and safety. Remember that an event not reportable under this criterion may be reportable in other areas. |
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