05000255/FIN-2014004-03
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Finding | |
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| Title | Failure to Evaluate the Adverse Effects of the Use of Non-Seismic Temporary Jumpers |
| Description | On September 10, 2014, the inspectors observed a preventive maintenance activity on 2.4kV breaker 152-106, which supplied power from Startup Transformer 1-2 to the 1C safety bus. During the activity, the inspectors noted that the licensee planned to install a temporary jumper to maintain operability of the 1-1 EDG. There was a b-contact on the breaker 152-106 auxiliary switch that was part of the 1-1 EDG auto-start circuit, which allowed the 1-1 EDG to automatically close on the 1C safety bus if both offsite power feeder breakers were open. During the preventive maintenance activity, the auxiliary switch was manipulated and re-positioned several times, which prevented the 1-1 EDG from automatically closing onto the 1C safety bus, rendering the 1-1 EDG inoperable. The licensee previously evaluated and approved a temporary modification, documented in EC 50310, for the use of temporary jumpers to maintain EDG auto-start circuit continuity, and therefore EDG operability, during preventive maintenance activities that manipulated the auxiliary switch for breaker 152-106 as well as six other breakers associated with the 1C and 1D safety buses. The evaluation acknowledged that the jumpers were being installed in seismically-qualified equipment and the jumpers should be installed using safety-related wire and ring tongue terminals. However, the evaluation also stated that, due to the design of each breaker, breakers 152-105 and 152-106 required the use of alligator clip jumpers, which was allowed by procedure EN-DC-136, Temporary Modifications, Revision 10, provided the alligator clip jumpers were not left unattended. The inspectors reviewed the process applicability determination (PAD) for the temporary modification documented in EC 50310. The licensees PAD concluded that, while some aspects of the activity were covered under maintenance risk regulations in 10 CFR 50.65, the use of temporary jumpers to maintain EDG operability was covered under 10 CFR 50.59. The 10 CFR 50.59 screening was documented in the PAD and the licensee determined that there were no adverse effects from the change.Section VI.B of the PAD referred to Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Implementation, Section 4.2, for guidance in screening issues through the 10 CFR 50.59 criteria. The inspectors reviewed NEI 96-07, Section 4.2, and identified items that appeared to not be addressed by the licensee in the PAD. Section 4.2.1 contained a list of questions that illustrate the range of effects that may stem from a proposed activity. Two of the questions were as follows: Does the activity decrease the reliability of an SSC design function, including either functions whose failure would initiate a transient/accident or functions that are relied upon for mitigation? Does the activity degrade the seismic or environmental qualification of the SSC? The PAD did not address either of these questions despite the knowledge that alligator clip jumpers were not seismically qualified, required constant attention per procedure for that reason, and were being installed in seismically qualified equipment. The inspectors discussed the issue with 10 CFR 50.59 subject matter experts in the Region III Office, and collectively discussed the issue with the licensee. At the end of this inspection period, the licensee entered the concerns into their CAP as CR-PLP-2014-04859, NRC Identified 50.59 Issue, dated October 7, 2014. The inspectors were awaiting the licensees corrective action plan and evaluation of the temporary modification through the 10 CFR 50.59 criteria to determine whether a license amendment would have been necessary. This issue is an Unresolved Item pending review of the additional information. |
| Site: | Palisades  |
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| Report | IR 05000255/2014004 Section 1R18 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | A Garmoe A Scarbeary E Duncan J Cassidy J Lennartz T Bilik |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2014004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2014Q3
Self-Identified List (Palisades)
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