05000443/FIN-2016007-02
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Finding | |
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Title | Potential Missed Evaluation and Reporting of an Adverse Condition to the NRC |
Description | Introduction: The team identified an unresolved item (URI) to further review whether NextEras evaluations associated with two PCCW pump motor failures in 2008 and one in 2015, and the associated conclusions not to report the conditions to the NRC, constituted a violation of NRC regulations. Description: As described in Section 1R21.2.1.3.1 above, the team reviewed two time periods where NextEra concluded that PCCW motor failures were the result of a manufacturing defect, however, these were not reported to the NRC. Specifically, a manufacturing defect was identified in a third-party failure analysis, dated January 21, 2009, following the failure of PCCW motors C and D in 2008. A third PCCW motor (B) failure occurred due to the same manufacturing defect in June 2015. These failures appeared to occur from one common cause. During this inspection, the team questioned whether the reporting requirements of 10 CFR Part 21 (Part 21), Reporting of Defects and Noncompliance, were satisfied, because no report was made to the NRC. In response to this concern, NextEra initiated AR 2153374, and initiated a substantial safety hazard (SSH) evaluation for the PCCW pump motor deviations in accordance with Part 21 and NextEra procedure LI-AA-102-1002, Part 21 Reporting. NextEra subsequently completed the SSH determination, and concluded that the deviation (i.e., the manufacturing defect) constituted a defect that could contain an SSH. They notified the NRC in accordance with 10 CFR 21.21(d)(3)(i) reporting requirements on October 20, 2016, via fax (Event Notification 52310). Subsequent to the onsite inspection, and while evaluating NextEras compliance with Part 21 evaluation and reporting requirements, the NRC noted that 10 CFR 21.2(c) stated, in part, that evaluation of potential defects and appropriate reporting of defects under 10 CFR 50.72 and 50.73 satisfies the evaluation, notification, and reporting obligation to report defects under Part 21. While the NRC recognized that NextEra had not made an NRC notification related to the identified PCCW motor manufacturing defect in accordance with 10 CFR 50.72, 50.73 or Part 21, the team did not review NextEras specific reportability evaluations with respect to 10 CFR 50.72 and 50.73. The team did note that NextEras Part 21 reviews, both in 2009 and 2015 did not specifically perform the evaluation specified in 10 CFR 21.21(a)(1) to determine whether the deviation in a basic component, which, on the basis of an evaluation, could create a substantial safety hazard. Since there appears to be overlapping reporting requirements among 10 CFR 50.72, 50.73 and 21.21, and the team did not specifically review NextEras reportability considerations for 10 CFR 50.72 and 50.73, additional inspection is necessary in order to determine whether there was a violation of any of the three reporting regulations. Accordingly, this issue is being treated as an unresolved item (URI) pending further inspection by the NRC staff to determine whether not evaluating and reporting the manufacturing defect associated with the PCCW motors constituted a more than minor violation of NRC reportability regulations. (URI 05000443/2016007-02, Potential Missed Evaluation and Reporting of an Adverse Condition to the NRC). |
Site: | Seabrook ![]() |
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Report | IR 05000443/2016007 Section 1R21 |
Date counted | Sep 30, 2016 (2016Q3) |
Type: | URI: |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21 |
Inspectors (proximate) | J Richmond J Schoppy M Gray M Orr S Pindale W Sherbin S Gardnerf Bowerm Modes P Cataldo P Meier |
INPO aspect | |
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Finding - Seabrook - IR 05000443/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Seabrook) @ 2016Q3
Self-Identified List (Seabrook)
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