05000327/FIN-2012005-05
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Finding | |
|---|---|
| Title | Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers |
| Description | The inspectors identified a violation with several examples of 10 CFR 50, Appendix B, Criterion III, Design Control, for failure to implement design control measures that review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of the structures, systems, and components and that provide for verifying or checking the adequacy of design such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program, including qualification testing of a prototype unit under the most adverse design conditions. The licensee entered this issue into the CAP as PER 668367. Failure of the licensee to ensure measures used to review the suitability of application of materials, parts, and equipment essential to the safety-related functions of molded case circuit breakers, and measures to provide for the verification of checking the adequacy of design were in place was a performance deficiency. This performance deficiency was more than minor because it affected the design control attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, adequate measures were not implemented to ensure the station 120-VAC vital instrumentation boards had properly maintained their seismic qualification for their application. The inspectors assessed this finding for significance in accordance with NRC Manual Chapter 0609, Appendix A, Exhibit 2, Significance Determination Process (SDP) for Findings At- Power Mitigating Systems Screening Questions, and determined that it was of very low safety significance (Green) as the devices in question had been intrinsically qualified for this application as part of a complete panel test by the original vendor and the licensee determined that the SSC maintained its operability or functionality despite the identified non-conformances. The inspectors evaluated this finding and violation of NRC requirements in accordance with the NRC Enforcement Policy, Section 2.3.2, and found two conditions to not be met requiring a Notice of Violation be issued. First, inspectors found the licensee failed to restore compliance within a reasonable time after the original violation (05000327.328/2011002-01) was identified. The NRC Enforcement Manual, Section 3.1.2.A.1.b).1), further defines restoring compliance to include those actions taken to stop an ongoing violation from continuing. Second, the inspectors determined that the identified non-conformances represented a repetitive violation as a result of inadequate corrective action and that identification was by the NRC inspector. The lack of rigor in addressing the root of the prior violation which resulted in the inadequate corrective action further led the inspectors to identify a crosscutting aspect in the CAP component of the Problem Identification and Resolution area |
| Site: | Sequoyah  |
|---|---|
| Report | IR 05000327/2012005 Section 4OA2 |
| Date counted | Dec 31, 2012 (2012Q4) |
| Type: | Violation: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Shehee R Monk S Shaeffer R Hamilton J Laughlin M Speck R Carrion R Lewis C Fletcher B Collins K Miller J Rivera L Mahlahla W Deschaine C Dykes R Kellnerc Kontzg Smith J Bartley W Deschaine |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Sequoyah - IR 05000327/2012005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Sequoyah) @ 2012Q4
Self-Identified List (Sequoyah)
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