IR 05000369/2017007

NRC Design Bases Assurance Inspection (Programs) Report 05000369/2017007 and 05000370/2017007

ML17083A095
Person / Time
Site:	Mcguire, McGuire
Issue date:	03/22/2017
From:	Bartley J NRC/RGN-II/DRS/EB1
To:	Capps S Duke Energy Carolinas
References
IR 2017007
Download: ML17083A095 (12)

Text

March 22, 2017

SUBJECT:

MCGUIRE NUCLEAR STATION - NRC DESIGN BASES ASSURANCE INSPECTION (PROGRAMS) REPORT 05000369/2017007 AND 05000370/2017007

Dear Mr. Capps:

On, February 10, 2017, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your McGuire Nuclear Station, Units 1 and 2, and discussed the results of this inspection with you, and other members of your staff. Additional inspection results were discussed with Mr. Jeff Thomas of your staff on March 8, 2017. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

The finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or the significance of the NCV, you should provide a response within 30 days of the date of this inspection report with the basis of your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the McGuire Nuclear Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Jonathan H. Bartley, Chief

Engineering Branch 1

Division of Reactor Safety

Docket Nos.: 05000369, 05000370 License Nos.: NPF-9, NPF-17

Enclosure:

Inspection Report 05000369/2017007 and 05000370/2017007 w/Attachment:

Supplemental Information

REGION II==

Docket Nos.:

50-369, 50-370

License Nos.:

NPF-9, NPF-17

Report Nos.:

05000369/2017007, 05000370/2017007

Licensee:

Duke Energy Carolinas, LLC

Facility:

McGuire Nuclear Station

Location:

Huntersville, NC 28078

Dates:

January 23, 2017, through February 10, 2017

Inspectors:

T. Su, Reactor Inspector (Team Lead)

M. Greenleaf, Reactor Inspector

C. Franklin, Reactor Inspector

Approved by:

Jonathan H. Bartley, Chief

Engineering Branch 1

Division of Reactor Safety

SUMMARY

Inspection Report (IR) 05000369/2017007 and 05000370/2017007; January 23 - February 10, 2017; McGuire Nuclear Station, Units 1 & 2; NRC Evaluations of Environmental Qualification 10CFR 50.49 Programs, Process and Procedures

Three Nuclear Regulatory Commission (NRC) inspectors from Region II conducted this inspection. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, or Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, (SDP) dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements were dispositioned in accordance with the NRCs Enforcement Policy dated November 1, 2016. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision

Cornerstone: Mitigating Systems

Green.

The team identified a green non-cited violation (NCV) of Title10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate requirements necessary for maintaining the environmental qualification of the pressurizer power-operated relief valve (PORV) NAMCO EA-180 limit switches into maintenance procedures. The licensee evaluated the impact of the incorrect guidance and determined that the PORV limit switches remained operable.

The licensee plans to correct the affected procedures. The licensee entered this issue into the corrective action program as NCR 02095333.

This performance deficiency was more than minor because it was associated with the mitigating systems cornerstone attribute of equipment performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, not maintaining the PORV limit switches in their qualified condition impacted their reliability. The team used IMC 0609, Att. 4, Initial Characterization of Findings, issued October 7, 2016, for Mitigating Systems, and IMC 0609, App. A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design of a mitigating structure, system, or component (SSC), and the SSC maintained its operability or functionality. The team determined that no cross-cutting aspect was applicable because the finding was not indicative of current licensee performance. (Section 1R21.b1)

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R21 Component Design Bases Inspection

a. Inspection Scope

The inspection team performed an inspection conducted as outlined in NRC Inspection Procedure (IP) 71111.21N, Attachment 1, Environmental Qualification under 10 CFR 50.49 Programs, Processes, and Procedures. The team assessed McGuire Nuclear Plants implementation of the environmental qualification program as required by 10 CFR 50.49, Environmental qualification of electric equipment important to safety for nuclear power plants. The team evaluated whether the McGuire Plant staff properly maintained the environmental qualification of electrical equipment important to safety throughout plant life, established and maintained required environmental qualification documentation records, and implemented an effective corrective action program to identify and correct environmental qualification related deficiencies.

The inspection included review of environmental qualification program procedures, component environmental qualification files, environmental qualification test records, equipment maintenance and operating history, maintenance and operating procedures, vendor documents, design documents, and calculations. The team interviewed program owners, engineers, maintenance staff, and warehouse staff. The team performed in-plant walk-downs (where accessible) to verify equipment was installed as described in McGuire Plants environmental qualification component documentation files; and that the components were installed in their tested configuration. Additionally, the team performed in-plant walk-downs to determine whether equipment surrounding the environmental qualification component could fail in a manner that could prevent the safety function of the components, and to verify that components located in areas susceptible to a high-energy line break were properly evaluated for operation in a harsh environment. The team reviewed and inspected the storage of replacement parts and associated procurement records to verify environmental qualification parts approved for installation in the plant were properly identified and controlled and that storage and environmental conditions did not adversely affect the components qualified lives.

Documents reviewed for this inspection are listed in the Attachment to this document.

The inspection procedure requires the team to select six to ten components to assess the adequacy of the environmental qualification program. The team selected eight components for this inspection. Component samples selected for this inspection are listed below:

• 2NIEV0333B, Unit 2 NI Pump Suction Flow from ND Iso. Motor

• 2NCLT5170, Unit 2 PZR Level, (U2 Containment)

• 1NCLL0340, Unit 1 PZR PORV Solenoid Limit Sw.

• 2NDPS5040, 2A ND Pump Mini Flow

• Raychem tubing qualification files for the latest qualified model at McGuire

• 2EPCGMP2B RE004, Relay GMP2BRE

• 2ETP TB1182, Terminal Box, NI System

• Okonite Cable qualification files for the latest qualified model at McGuire

b. Findings

Failure to Translate Required Gasket Replacement Requirements into Limit Switch Maintenance Manual

Introduction:

The NRC identified a Green non-cited violation (NCV) of Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate requirements necessary for maintaining the environmental qualification of the pressurizer power-operated relief valve (PORV) NAMCO EA-180 limit switches into maintenance procedures.

Description:

The licensee uses NAMCO EA-180 limit switches for the pressurizer PORVs. They provide an open or closed signal to indication in the main control room, so that operators are aware of the PORV position, and can make appropriate assessment of plant conditions during and following design basis accidents. The PORV limit switch resides in the top of the pressurizer cubicle, inside containment, and as such, the limit switch is located in a harsh environment when expected to perform its post-accident function. The limit switch was therefore included in the scope of McGuire Nuclear Stations environmental qualification (EQ) program and was subject to its requirements in accordance with 10 CFR 50.49.

In order to qualify the equipment to the requirements of 10 CFR 50.49, NAMCO tested EA-180 limit switches to provide assurance that they will perform their post-accident function when subjected to their most limiting harsh environment. Proof of this qualification was provided in qualification test report 155 (QTR 155), Generic Qualification of EA 180 Series Limit Switches for Use in Nuclear Power Plant Class 1E Applications in Compliance with IEEE Standards 323-1974, 382-1972, and 344-1975 (Duke document DPM-1393.01-00-0021). Section 11.12 EA189-90060 Maintenance and Surveillance Instructions, Subsection 2.4, Gasket and Screw Assembly Replacement, required that:

In order to maintain the qualification and integrity of the limit switch seals, replace the top cover gasket and screw assemblies each time the top cover is removed for any reason.

Equipment Qualification Maintenance Manual EQMM-1393.01-N03-01 provided the required maintenance activities that must be performed to maintain the PORV limit switch qualified. Section 1.1.1 of EQMM-1393.01-N03-01 stated that if the switch is opened for any reasoninspect cover gaskets and screw O-rings, replace if damaged.

The EQMM, as written was less restrictive than the requirements contained in QTR 155, and therefore created the potential for the gaskets and screw O-rings to not be replaced each time the top cover was removed, thereby leaving the PORV in an unqualified state after maintenance had been performed. Following the teams identification of the issue, the licensee determined that there were several instances in which the gaskets may not have been replaced on some of the PORV limit switches. The licensee entered this issue into their corrective action program as NCR 02095333 and evaluated the impact of the incorrect information provided in the EQMM. The licensee determined that the affected NAMCO limit switches remained operable, although they were in an unqualified condition.

Analysis:

The team determined that the failure to translate gasket replacement requirements into maintenance manual EQMM-1393.01-N03-01 was a performance deficiency. This performance deficiency was more than minor because it was associated with the mitigating systems cornerstone attribute of equipment performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Failing to maintain EA-180 limit switches in their qualified condition impacted their reliability. The team used IMC 0609, Att. 4, Initial Characterization of Findings, issued October 7, 2016, for Mitigating Systems, and IMC 0609, App. A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design of a mitigating structure, system, or component (SSC), and the SSC maintained its operability or functionality. The team determined that no cross-cutting aspect was applicable because the finding was not indicative of current licensee performance.

Enforcement:

Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, required, in part, that measures shall be established to assure that applicable regulatory requirements for those structures, systems, and components to which this appendix applies are correctly translated into procedures and instructions. Contrary to the above, since the issuance of revision 8 of EQMM-1393.01-N03-01 on February 29, 2012, McGuire Nuclear Station failed to assure that the gasket replacement requirements necessary for maintaining 10 CFR 50.49 qualification of NAMCO EA-180 PORV limit switches were correctly translated into EQMM-1393.01-N03-01. Specifically, the EQMM did not require that the top gasket and screw O-rings be replaced each time the top cover was opened. In response to this issue, the licensee evaluated the potential condition of the PORV limit switch and other limit switches qualified in the same manner and determined they remained operable based on other testing by NAMCO on a similar limit switch that had no gasket. The licensee plans to correct the affected procedures.

This violation is being treated as an NCV consistent with section 2.3.2.a of the Enforcement Policy. The violation was entered into the licensees corrective action program as NCR 02095333. (NCV 05000369/2017007-01 and 05000370/2017007-01 Failure to Translate Required Gasket Replacement into Limit Switch Maintenance Manual)

4OA6 Meetings, Including Exit

On February 10, 2017, the inspectors presented inspection results to Mr. Steven Capps and other members of the licensees staff. The inspectors verified that no proprietary information was retained or documented in this report. Additional inspection results were discussed with Mr. Jeff Thomas of your staff on March 8, 2017.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

Adam Goodman, Fleet Reg. Affairs

Brian Richards, McGuire Reg. Affairs

Brian Kandell, MNS-Program Eng. MGR

Chris Abernathy, Fleet EQ Program Lead

Grant Cutri, Primary System Engineer

Jeremy Bell, Programs Engineer

Robin Turpin, DES-Elec.

NRC personnel

F. Ehrhardt, Chief, Reactor Projects Branch 1, Division of Reactor Projects

A. Hutto, Senior Resident Inspector, McGuire Nuclear Station

R. Cureton, Resident Inspector, McGuire Nuclear Station

LIST OF REPORT ITEMS

Opened, Closed, and Discussed

05000369, 370/2017007-01 NCV Failure to Translate Required Gasket Replacement Requirements into Limit Switch Maintenance Manual (Section 1R21.b.1)