1 what is the definition of ‘non-conforming condition?’ non-conforming condition © 1999-2009...
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What is the What is the definition of ‘non-conforming condition?’definition of ‘non-conforming condition?’
Non-conforming Condition
© 1999-2009 L.A. Grime, PE
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Non-conforming ConditionIM Section 3.6 “Nonconforming Condition”
“A nonconforming condition is a condition of an SSC that involves a failure to meet the CLB or a situation in which quality has been reduced because of factors such as improper design, testing, construction, or modification.”
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Non-conforming Examples
a. “There is failure to conform to one or more applicable codes & standards (e.g., the CFR, operating license, TSs, UFSAR, and/or licensee commitments).
b. An as-built or as-modified SSC does not meet the CLB.
c. Operating experience or engineering reviews identify a design inadequacy.
d. Documentation required by NRC requirements such as 10 CFR 50.49 [Equipment Qualification] is unavailable or deficient.”
IM Section 3.2 “Degraded Condition”
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Non-conforming Example
Example1:
Unit personnel found that certain feedwater coolant system support equipment was non-seismic. The unit FSAR states that the system is designed to be seismic. The equipment was nonconforming due to a failure to meet a licensee UFSAR commitment.
1 Examples based on 10/21/94 NRC letter to R. M. Kacich.
Formal evaluation was required and determined that the system could be considered operable.
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Non-conforming Example
Unit personnel found that portions of the low pressure coolant injection/core spray piping systems could not meet code allowable stress values during certain post-accident postulated conditions. The equipment was nonconforming due to a failure to meet a requirement or licensee commitment.
Example1:
1 Examples based on 10/21/94 NRC letter to R. M. Kacich.
Formal evaluation was required and determined that the system could be considered operable.
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Non-conforming Example
Unit personnel found that the control room emergency ventilation system configuration was such that application of the dose conversion factor standard referenced in the FSAR would yield unacceptable results. The equipment was nonconforming due to a failure to meet a requirement.
Example1:
1 Examples based on 10/21/94 NRC letter to R. M. Kacich.
Formal evaluation was required and determined that the system could be considered operable. The determination relied on use of a more recent, and NRC accepted-for-use-at-the-unit, dose conversion factor standard.
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Non-conforming vs. Degraded
A non-conforming condition usually results from a discovery that, since the original installation or modification, an SSC failed to meet a requirement or licensee commitment.
A degraded condition typically results from wear, deterioration or a component failure that causes a functional capability reduction.
“The discovery of an improper or inadequate TS value or required action is considered a degraded or nonconforming condition.”
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Points to remember...Points to remember...
‘A condition of an SSC in which there is failure to meet NRC requirements or licensee commitments’ is a non-conforming condition.
The NRC requirements and commitments are in the Code of Federal Regulations, operating license, unit CLB, TS, UFSAR and other licensee commitments.
‘A condition of an SSC in which there is failure to meet NRC requirements or licensee commitments’ is a non-conforming condition.
The NRC requirements and commitments are in the Code of Federal Regulations, operating license, unit CLB, TS, UFSAR and other licensee commitments.