ML18337A183
| ML18337A183 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18337A183 (3) | |
Text
Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP): IP 71111.15, Operability Determinations and Functionality Assessments Inspector Procedure Lead: Aron Lewin Estimated Hours to Complete Review: 8 Date Review Completed: 10/1/19
- 1. Results and assessment of review of IMC 0308, ROP basis document review No conflicts noted. IP 71111.15 requirements reflect discussions found in IMC 0308,.
- 2. Results and assessment of review of any applicable changes to PIs A three year review by the PI lead did not identify any significant changes to PIs that would result in a reduction or unintended gap in the key safety attributes of each safety cornerstone.
- 3. Results and assessment of review of any applicable changes to Rules and STSs A three year review of recent rulemaking efforts and STS revisions did not identify any significant changes that would impact IP 71111.15.
- 4. Results and assessment of review of recent Operating Experience A review of recent Operating Experience Notes did not identify any issues warranting revisions to IP 71111.15. Significant findings are discussed under section 5.
- 5. Results and assessment of review based on RRPS data Adverse trends or outliers noted: No adverse trends or outliers noted.
Number of findings, samples conducted, and hours charged within last five years have been steady. Overall, findings seems to represent a small fraction of total conducted samples.
Most of the findings are NRC identified (~80%). NRC Hours Charged / Samples Conducted reflects IP resource estimates.
2013 2014 2015 2016 2017 NRC PIM Findings 54 81 73 56 59 NRC Hours Charged 7655 7715 7585 7914 7565 NRC Samples Conducted 1234 1255 1291 1221 1222 RI PIM Findings / Per 1000 Hours Charged 9.8 10.7 13.8 6.9 4.1 RII PIM Findings / Per 1000 Hours Charged 4.4 4.9 5.9 6.3 6.2 RIII PIM Findings / Per 1000 Hours Charged 3.5 15.7 11.0 9.8 12.9 RIV PIM Findings / Per 1000 Hours Charged 13.8 12.6 8.6 4.8 8.5 NRC PIM Findings / Per 1000 Hours Charged 7.1 10.5 9.6 7.1 7.8 RI PIM Findings / Samples Conducted 5.4%
5.5%
7.4%
4.5%
2.4%
RII PIM Findings / Samples Conducted 3.0%
3.3%
3.8%
3.8%
3.7%
RIII PIM Findings / Samples Conducted 2.4%
10.2%
6.8%
6.8%
8.2%
RIV PIM Findings / Samples Conducted 7.4%
8.0%
4.6%
3.0%
6.0%
NRC PIM Findings / Samples Conducted 4.4%
6.5%
5.7%
4.6%
4.8%
RI Hours Charged / Samples Conducted 5.5 5.1 5.4 6.6 5.8 RII Hours Charged / Samples Conducted 6.7 6.7 6.5 6.1 5.9 RIII Hours Charged / Samples Conducted 7.0 6.5 6.2 7.0 6.4 RIV Hours Charged / Samples Conducted 5.4 6.3 5.4 6.3 7.0 NRC Hours Charged / Samples Conducted 6.2 6.1 5.9 6.5 6.2 Four white findings have been identified in the last three years.
- 2016, Hope Creek, Self-Revealed: Violation of 10 CFR, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and TS 3.5.1.c, Emergency Core Cooling Systems - High Pressure Coolant Injection (HPCI), was identified because the licensee did not detect and act upon an adverse trend of water intrusion into the HPCI oil system. Because monthly oil samples were collected but were not analyzed for water content, the HPCI governor control valve failed due to moisture-induced corrosion that degraded its hydraulic actuator. The HPCI system was inoperable for a period greater than its TS allowed outage time.
- 2016, Monticello, Self-Revealed: Violation of Technical Specification 5.4.1.a for the licensees failure to plan and perform maintenance affecting the safety-related high pressure coolant injection (HPCI) system. Specifically, improperly planned and performed pre-April 2005 maintenance initiated a crack in a safety-related HPCI oil pipe and, for numerous years, the licensee failed to perform maintenance to resolve repeated identification of HPCI oil leakage. These failures resulted in a sudden increase in oil leakage on March 22, 2016, extending the unavailability of HPCI during a maintenance window and causing a loss of safety function.
- 2017, Catawba, NRC Identified: Violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to adequately develop and adjust the preventive maintenance strategy for the emergency diesel generator (EDG) excitation system.
The inspectors also identified an associated violation of 10 CFR Part 50 Appendix B, Criterion XVI, Corrective Actions, for the failure to correct a condition adverse to quality associated with elevated operating temperatures of EDG excitation system diodes. This resulted in the failure of an EDG excitation system diode and overcurrent trip of the 2A emergency diesel output breaker during a surveillance test performed on April 11, 2017. The finding represents an actual loss of function of a single train for greater than its technical specification allowed outage time.
- 2017, Clinton, Self-Revealed: Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to implement measures for the selection and review for suitability of application replacement relays for the Division 1 Emergency Diesel Generator (EDG) Room Vent Fan. Engineering changes introduced new relays into the circuit that resulted in the failure of the fan to operate during an under voltage conditions. This rendered the Division 1 EDG inoperable for a time longer than its technical specification allowed outage time. The issue was discovered by an equipment operator who heard a clicking noise coming from Unit Substation 1A while performing rounds.
- 6. Feedback Forms No feedback forms open. No feedback received within last three years.
- 7. Other Considerations Industry is currently developing their own operability determination guidance, via NEI 18-03.
NEI is not seeking official NRC endorsement. NEI is targeting a June 2019 finalization timeframe. Potential impact to IP likely to be minimal.
- 8. Results of discussions with regions Call held with regional representatives on 9/27/2018. Justin Heinly (region I) and Alan Blamey (region II) dialed in. Regional representatives also recommended to maintain awareness of NEI 18-03 to determine potential impact to IP.
Recommendations No revisions to IP recommended. Maintain awareness of NEI 18-03 to determine potential impact to IP.