Title
10 CFR 50, Appendix B, Criterion III, Design Control, requires measures be established for the selection and review for suitability of application of material, parts, equipment, and processes that are essential to the safety-related functions of the
SSCs. Contrary to this requirement, the licensee identified that from 2009 until November 20, 2013,
NSR parts were installed in safety-related components. During operating experience review, the licensee identified the potential for
NSR parts, such as
gaskets and packing to be installed in safety-related systems. The licensee conducted an evaluation from 2009 forward to determine the use of both soft and hard
NSR parts in limited volume safety-related systems or other applications where it performs a safety-related function. Eight occurrences of soft
NSR parts installed in limited volume safety-related systems (SBLC, diesel fuel oil, alternate
nitrogen, and
HPCI) were identified. Four occurrences of hard
NSR parts installed in limited volume safety-related systems (alternate
nitrogen,
high pressure core spray, and
RCIC) were identified. Lastly, seven occurrences were identified by the licensee where hard
NSR parts (key, fuses, relay, seal kit, and sealant) were installed in other applications where it performs a safety-related function. The licensee entered this issue into its corrective action program,
CAPs 1407369 and 1410037, and through evaluation has determined the safety-related components impacted by the use of
NSR parts are
operable but non-conforming. The licensee has established actions to replace the identified
NSR parts. The inspectors determined that this issue was more than minor because, if left uncorrected, the installation of parts/materials which fail to meet requirements could
lead to subsequent part failure and adverse impact the ability of safety-related equipment to perform its safety function. Specifically, the licensee failed to establish measures for the selection of parts that are essential to the safety-related functions of
SSCs. As a result, the licensee installed
NSR parts in safety-related systems. The inspectors determined that this issue was associated with the
Mitigating Systems cornerstone and could be evaluated using the
SDP. The inspectors used
IMC 0609, Attachment 0609.04, Appendix A, Exhibit 2,
Mitigating Systems Screening Questions, dated June 19, 2012, and concluded that this issue was of very low safety significance (Green) because the finding was associated with a deficiency that only affected the design or qualification of the specific
SSCs.
