05000352/FIN-2013004-03
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Finding | |
|---|---|
| Title | Failure to Correct a Condition Adverse to Quality associated with Defective Material Being Reinstalled into a Safety-Related System |
| Description | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, associated with Exelon staffs failure to correct a condition adverse to quality (CAQ) associated with defective material being reinstalled into a safety-related system after the component failed. Specifically, Exelons corrective actions to address the defective material issues in both Apparent Cause Evaluation (ACE) IR 900755 and Equipment Apparent Cause Evaluation (EACE) IR 1365093 did not prevent the installation of a previously failed circuit board into a safety-related system. This circuit board ultimately failed again, causing operators to declare the Redundant Reactivity Control System (RRCS) inoperable. Exelons corrective actions included revising procedural guidance for RRCS channel-checks, utilizing an alert system for continuous performance monitoring of al RRCS system parameters, conducting an extent of cause for all existing RRCS out-of-band log entries, revising the maintenance strategy to use new RRCS cards and a time-directed PM to replace failed or old cards and benchmarking the industry maintenance strategy for RRCS. Exelon is also revising material receipt procedures, training all warehouse personnel on the receipt inspection process and performing extent of conditions of all other repairable stock codes. Exelon has entered this issue into their CAP as IR 1569907. The inspectors determined that Exelons corrective actions to address a CAQ associated with defective material issues in both ACE IR 900755 and EACE IR 1365093, was a performance deficiency that was within their ability to foresee and correct, and should have been prevented. The performance deficiency was determined to be more than minor because it affected the Procedure Quality and Human Performance attributes of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Further, if left uncorrected, the performance deficiency could have the potential to lead to a more significant safety concern. The performance deficiency was also similar to IMC 0612, Appendix E, example 4.g, in that Exelons corrective actions were inadequate and failed to correct a CAQ. The finding is of very low safety significance (Green) per IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening Questions, because RRCS was determined to maintain its operability and functionality, does not represent a loss of system and/or function and does not represent an actual loss of function of a single train for greater than its TS allowed outage time. The finding had a cross-cutting aspect in the area of PI&R, CAP, because Exelon did not take the appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with the safety significance P.1(d). Specifically, Exelon did not take appropriate corrective actions to address the use of new RRCS circuit boards and did not ensure the corrective actions for the D23 Emergency Diesel Generator (EDG) rectifier failure would ensure all failed components that are sent to the vendor for analysis and sent back to the site with no failure mode were evaluated by engineering prior to re-installation. |
| Site: | Limerick  |
|---|---|
| Report | IR 05000352/2013004 Section 1R15 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | E Dipaolo J Laughlin R Nimitz F Bower J Hawkins D Aird |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2013004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2013Q3
Self-Identified List (Limerick)
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