05000259/FIN-2011005-01
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Failure to Report a Valve Motor Operator Manufacturing Defect Pursuant to 10CFR21.21 in a Timely Manner |
| Description | The inspectors reviewed the two specific structures, systems and components (SSC) within the scope of the Maintenance Rule (MR) (10CFR50.65) with regard to some or all of the following attributes, as applicable: (1) Appropriate work practices; (2) Identifying and addressing common cause failures; (3) Scoping in accordance with 10 CFR 50.65(b) of the MR; (4) Characterizing reliability issues for performance monitoring; (5) Tracking unavailability for performance monitoring; (6) Balancing reliability and unavailability; (7) Trending key parameters for condition monitoring; (8) System classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2); (9) Appropriateness of performance criteria in accordance with 10 CFR 50.65(a)(2); and (10) Appropriateness and adequacy of 10 CFR 50.65 (a)(1) goals, monitoring and corrective actions (i.e., Ten Point Plan). The inspectors also compared the licensees performance against site procedure NPG-SPP-3.4, Maintenance Rule Performance Indicator Monitoring, Trending and Reporting; Technical Instruction 0-TI-346, Maintenance Rule Performance Indicator Monitoring, Trending and Reporting; and NPG SPP 3.1, Corrective Action Program. The inspectors also reviewed, as applicable, work orders, surveillance records, PERs, system health reports, engineering evaluations, and MR expert panel minutes; and attended MR expert panel meetings to verify that regulatory and procedural requirements were met. FnResidual Heat Removal Service Water (RHRSW) 023-C, Vessel / Containment Flooding MR Function Reclassified as Risk Significant FnUnit 1, Loop I RHR Low Pressure Coolant Injection (LPCI) Outboard Injection Valve (1-FCV-74-52) Failure and 10CFR50.65(a)(1) corrective action plan b. Findings Introduction: The NRC inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 21, Reporting of Defects and Noncompliance, for the licensees failure to report a known defect as soon as practicable, but in all cases within 60 days of discovery. More specifically, the licensee did not submit an interim report or notify the NRC in a timely manner pursuant to 10CFR21.21 regarding a manufacturing defect that caused a failure of the Unit 1 RHR Loop I outboard injection valve (1-FCV-74-052) on August 2, 2011. Description: On August 2, 2011, the Unit 1 Loop I LPCI Outboard Injection Valve (1- FCV-74-52), experienced a failure of the motor operator during performance of surveillance test procedure 1-SR-3.3.5.1.6(C I), Functional Testing of RHR Loop I Valve Logic and Interlocks. During this surveillance test, 1-FCV-74-52 was cycled successfully multiple times until it suddenly failed to reopen. The licensee promptly entered the required TS Limiting Condition of Operation (LCO) 3.5.1 seven day action statement, and initiated PER 410394 to also enter this issue into the corrective action program (CAP). The valve was repaired and returned to service within its TS allowed outage time (AOT). The actual failure of 1-FCV-74-52 did not involve a past operability concern or licensee performance deficiency. The root cause evaluation for PER 410394 was presented to the Corrective Action Review Board (CARB) on September 14, 2011. As part of the root cause analysis the licensee determined the motor operator failure was a manufacturing defect due to inadequate vendor assembly procedures and manuals for the SMB-5(T) motor operator which led to incomplete lug engagement of the clutching mechanism that subsequently rendered the valve non-functional. At the conclusion of the CARB, the NRC inspectors questioned the root cause team leader regarding the lack of a Part 21 evaluation and notification. The inspectors were informed that the licensee was working with the valve motor operator vendor on further corrective actions, and any required Part 21 notification would be addressed with the vendor. On September 20, 2011, PER 435444 was initiated stating that the root cause determination did not include a Part 21 evaluation. As a result of this PER, the licensee implemented their procedure NPG-SPP-03.5, Regulatory Reporting Requirements, and recognized this issue was potentially reportable per the requirements of 10CFR21.21. The inspectors subsequently concluded that the time of discovery for a Part 21 evaluation was September 14, 2011, for which 10CFR21.21 required the licensee to complete their Part 21 evaluation within the next 60 days, and then notify the NRC within the following seven days; or submit an interim report within 60 days of discovery if the Part 21 evaluation could not be completed within the 60 days. This timeframe required the issuance of a Part 21 interim report to the NRC by November 15, 2011, or a Part 21 initial Notification by November 20, 2011. However, no interim report was issued, and the licensee did not make an initial Part 21 Notification. The valve motor operator vendor (Flowserve) did submit the required Part 21 written report on November 29, 2011. The untimely Part 21 Notification was entered into licensees CAP as PER 487357. Analysis: The inspectors determined that the licensees failure to issue an interim report within 60 days or make an initial Notification of a Part 21 reportable condition constituted a violation of 10CFR21.21. Specifically, the licensee did not ensure that the failure of the 1-FCV-74-52 motor operator due to a manufacturing defect was evaluated and reported in accordance with the timeliness requirements of Part 21. This violation was evaluated using traditional enforcement because it had the potential for impacting the regulatory process. In accordance with the guidance in Section 2.2.2 and Section 6.9.d. of the NRC Enforcement Policy, the inspectors determined this violation was a Severity Level (SL) IV violation of low safety significance because the failure to report this condition did not substantially impact the Agency\\\'s regulatory responsibilities and the Agency would not have responded in a significantly different manner had the information been properly reported. The inspectors also concluded that failing to recognize this as a Part 21 reportable issue in a timely manner was a performance deficiency under the Reactor Oversight Process (ROP). In accordance with NRC IMC 0612, Appendix B, Issue Screening, the inspectors concluded that this performance deficiency was minor. Because this performance deficiency was minor and the violation was evaluated using Traditional Enforcement, a cross-cutting aspect is not assigned in accordance with IMC 0612. Enforcement: 10CFR21.21(a) required in part that the licensee shall evaluate deviations to identify defects associated with a substantial safety hazard as soon as practicable, but in all cases within sixty (60) days of discovery. Upon completion of this evaluation, an initial Notification to the Commission was required within seven days. However, if an evaluation of an identified defect potentially associated with a substantial safety hazard could not be completed within 60 days from discovery of the deviation, an interim report was required to be submitted to the Commission within the 60 days of discovery. Contrary to the above requirements, following the discovery of a manufacturing defect associated with the motor operator for 1-FCV-74-52, Loop I LPCI Outboard Injection Valve on September 14, 2011, the licensee failed to make either an initial Notification or submit an interim report within the time requirements of 10CFR21.21. The NRC was not notified of the Part 21 defect until the vendor (Flowserve) submitted a written report on November 29, 2011. This violation was a SL IV violation of low safety significance because the failure to report this condition did not substantively impact the Agency\\\'s regulatory responsibilities and the Agency would not have responded in a substantially different manner had the information been properly reported. Because this violation was of very low safety significance and it was entered into the licensees CAP as PER 487357, this violation was treated as an NCV, consistent with the NRC Enforcement Policy. This NCV is identified as NCV 05000259, 260, 296/2011005-01, Failure to Report a Valve Motor Operator Manufacturing Defect Pursuant to 10CFR21.21 in a Timely Manner. |
| Site: | Browns Ferry  |
|---|---|
| Report | IR 05000259/2011005 Section 1R12 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | Miscellaneous |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | C Kontz C Stancil E Guthrie L Pressley P Niebaum R Baldwin T Ross |
| INPO aspect | |
| ' | |
Finding - Browns Ferry - IR 05000259/2011005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Browns Ferry) @ 2011Q4
Self-Identified List (Browns Ferry)
| ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||