05000219/FIN-2014009-01: Difference between revisions
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| identified by = NRC | | identified by = NRC | ||
| Inspection procedure = IP 71152 | | Inspection procedure = IP 71152 | ||
| Inspector = J Brand, J Kulp, S Kennedya, | | Inspector = J Brand, J Kulp, S Kennedya, Patelb Bollinger, C Cahill, N Floyd, S Kennedy, S Pindaleb, Bickettb Klukar, G Carpenter, H Nieh, J Wray, L Casey, M Gray, M Mclaughlin, N Warnek, R Lorson, S Kennedy | ||
| CCA = N/A for ROP | | CCA = N/A for ROP | ||
| INPO aspect = | | INPO aspect = | ||
| description = The NRC identified a preliminary Yellow finding and associated apparent violation of 10 CFR 50, Appendix B, Criterion III, Design Control, and Technical Specification 3.4.B, Automatic Depressurization System, because the station did not establish adequate measures for selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the electromatic relief valves (EMRVs). The violation was also preliminarily determined to meet the IMC 0305, Section 11.05, criteria for treatment as an old design issue. Specifically, on June 20, 2014, during refurbishment of EMRVs that were removed from the plant during the 2012 refueling outage, Exelon personnel identified deficiencies with the B and D EMRVs. As part of the planned EMRV actuator testing and refurbishment activities, Exelon personnel conducted bench testing on June 26, 2014. Both valves did not stroke satisfactorily and resulted in two inoperable EMRVs for greater than the Technical Specification allowed outage time of 24 hours. Exelons immediate corrective actions included placing this issue into the corrective action program as issue report 1679428 and redesigning the EMRV actuators to ensure the spring is on the outside of the guide bushing, therefore removing the possibility of the spring entering the guide bushing area and subsequently jamming the actuator causing valve failure. All of the actuators were replaced with redesigned actuators during the refueling outage in October 2014. In addition, Exelon issued a 10 CFR Part 21 report to inform the industry of the deficient EMRV actuator design. This finding is more than minor because it adversely affected the design control quality attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the design deficiency of the EMRVs and the inadequate maintenance process led to the inability of the B and D EMRVs to perform their safety function. The inspectors screened this issue for safety significance in accordance with IMC 0609, Appendix A, Exhibit 2, and determined a detailed risk evaluation was required because the EMRVs were potentially failed or unreliable for greater than the Technical Specification allowed outage time. As described in Attachment 3 to this report, a detailed risk evaluation concluded that the increase in core damage frequency (CDF) related to failure of the B and D EMRVs is in the mid E-5 range; therefore, this finding was preliminarily determined to have a substantial safety significance (Yellow). Due to the nature of the failures, no recovery credit was assigned. The dominant sequences included loss of main feedwater with failures of the isolation condensers, and failure to depressurize. This finding does not represent an immediate safety concern because Exelon replaced all of the actuators with the redesigned actuators during the refueling outage in October 2014. Further, the NRC is considering treatment of this finding as an old design issue because the condition existed since the original installation of the EMRVs, and is not indicative of current licensee performance. Additional details are discussed in Attachment 1. The inspectors determined that this finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency was not reflective of current licensee performance. Specifically, the inspectors determined that the performance deficiency existed since original installation of the EMRVs. Although an opportunity to identify this issue following original installation occurred in 2006 when Quad Cities changed the EMRV actuator design due to similar issues, the inspectors could not conclude that the issue would have likely been identified during that period since a Part 21 Report was not issued to inform the industry and NRC of the design change and industry operating experience focused on plants that completed or were scheduled to complete an extended power uprate. | | description = The NRC identified a preliminary Yellow finding and associated apparent violation of 10 CFR 50, Appendix B, Criterion III, Design Control, and Technical Specification 3.4.B, Automatic Depressurization System, because the station did not establish adequate measures for selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the electromatic relief valves (EMRVs). The violation was also preliminarily determined to meet the IMC 0305, Section 11.05, criteria for treatment as an old design issue. Specifically, on June 20, 2014, during refurbishment of EMRVs that were removed from the plant during the 2012 refueling outage, Exelon personnel identified deficiencies with the B and D EMRVs. As part of the planned EMRV actuator testing and refurbishment activities, Exelon personnel conducted bench testing on June 26, 2014. Both valves did not stroke satisfactorily and resulted in two inoperable EMRVs for greater than the Technical Specification allowed outage time of 24 hours. Exelons immediate corrective actions included placing this issue into the corrective action program as issue report 1679428 and redesigning the EMRV actuators to ensure the spring is on the outside of the guide bushing, therefore removing the possibility of the spring entering the guide bushing area and subsequently jamming the actuator causing valve failure. All of the actuators were replaced with redesigned actuators during the refueling outage in October 2014. In addition, Exelon issued a 10 CFR Part 21 report to inform the industry of the deficient EMRV actuator design. This finding is more than minor because it adversely affected the design control quality attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the design deficiency of the EMRVs and the inadequate maintenance process led to the inability of the B and D EMRVs to perform their safety function. The inspectors screened this issue for safety significance in accordance with IMC 0609, Appendix A, Exhibit 2, and determined a detailed risk evaluation was required because the EMRVs were potentially failed or unreliable for greater than the Technical Specification allowed outage time. As described in Attachment 3 to this report, a detailed risk evaluation concluded that the increase in core damage frequency (CDF) related to failure of the B and D EMRVs is in the mid E-5 range; therefore, this finding was preliminarily determined to have a substantial safety significance (Yellow). Due to the nature of the failures, no recovery credit was assigned. The dominant sequences included loss of main feedwater with failures of the isolation condensers, and failure to depressurize. This finding does not represent an immediate safety concern because Exelon replaced all of the actuators with the redesigned actuators during the refueling outage in October 2014. Further, the NRC is considering treatment of this finding as an old design issue because the condition existed since the original installation of the EMRVs, and is not indicative of current licensee performance. Additional details are discussed in Attachment 1. The inspectors determined that this finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency was not reflective of current licensee performance. Specifically, the inspectors determined that the performance deficiency existed since original installation of the EMRVs. Although an opportunity to identify this issue following original installation occurred in 2006 when Quad Cities changed the EMRV actuator design due to similar issues, the inspectors could not conclude that the issue would have likely been identified during that period since a Part 21 Report was not issued to inform the industry and NRC of the design change and industry operating experience focused on plants that completed or were scheduled to complete an extended power uprate. | ||
}} | }} | ||
Latest revision as of 19:52, 20 February 2018
| Site: | Oyster Creek |
|---|---|
| Report | IR 05000219/2014009 Section 4OA2 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | Violation: Yellow |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Brand J Kulp S Kennedya Patelb Bollinger C Cahill N Floyd S Kennedy S Pindaleb Bickettb Klukar G Carpenter H Nieh J Wray L Casey M Gray M Mclaughlin N Warnek R Lorson S Kennedy |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control Technical Specification 10 CFR 21, PART 21-REPORTING OF DEFECTS AND NONCOMPLIANCE |
| INPO aspect | |
| ' | |