05000382/FIN-2009010-01
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Finding | |
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| Title | Failures to Evaluate Adverse Conditions for Reportability to the NRC |
| Description | The team identified an unresolved item (URI) to further evaluate whether two examples where the licensee\'s evaluations of relay failures and decisions not to report the conditions to the NRC constituted a violation. Specifically, on September 11, 2007, the licensee identified that 17 Agastat E7024PB relays with date code 9948 had either failed in service or exhibited excessive set point drift. On October 14, 2008, the licensee identified four defective Agastat E7024PB relays with date code 0804 during pre-installation bench testing. The licensee did not adequately evaluate to determine whether these failures were required to be reported to the NRC. The team identified two examples where the licensees evaluations of relay failures may not have been adequate to address NRC reporting requirements. Example 1: On August 20, 2007, while performing calibration on an Agastat E7024PB relay associated with safety-related ventilation systems, the licensee found that relay contacts would not operate as designed. On September 11, 2007, during an extent of condition review following this failure, the licensee identified that Agastat E7000-series relays with a date code of 9948 had repeatedly been identified as being out-of-tolerance during routine calibrations and had experienced five hard failures. Out of 22 purchased by Waterford 3, only two relays from this date code had demonstrated acceptable performance. Table 2 summarizes the performance problems for the relays in this group. Based on this information, the licensee concluded that relays with this date code were unreliable and initiated action to replace all date code 9948 relays at their next scheduled calibration. Prior to identifying this adverse trend, the licensee had determined the August 20, 2007, failure which initiated the extent of condition review to be not reportable. The licensee failed to reconsider the condition for reportability after recognizing the full extent of the problem. The team determined that these parts were basic components as described in 10 CFR 21.3. Procurement documents for this group of relays specified that these relays had a qualified life of 10 years, and would maintain a setpoint within plus or minus 10 percent. Since the relays exhibited unacceptable performance well before reaching 10 years, it appeared that the licensee\'s evaluation should have concluded that the condition constituted a deviation as defined in 10 CFR 21.3. The team determined that these relays were installed in both trains of the Engineered Safety Features Actuation System (ESFAS), with functions to autostart safety-related mitigating systems. In some cases, date code 9948 relays with unacceptable performance were installed in redundant equipment (e.g. both trains of high pressure safety injection pumps). Therefore, it was possible that this condition may have involved a substantial safety hazard as defined in 10 CFR 21.3 and NUREG 0302, Remarks Presented (Questions /Answers Discussed) at Public Meetings to Discuss Regulations (10 CFR Part 21) for reporting of Defects and Noncompliance, Revision 1. It was also possible that this condition may have involved a potential for loss of safety function as described in 10 CFR 50.72(b)(3)(v) and 10 CFR 50.73(a)(2)(v). Example 2: On October 14, 2008, while performing pre-installation bench testing on a spare relay intended to replace a failed Agastat E7024PB relay, maintenance personnel noted that the replacement relay obtained from the warehouse had a loose terminal point. Three of the remaining six spare relays also had a bad terminal point. The licensee identified these relays as defective and returned them to Tyco Electronics for a cause evaluation. All four defective relays shared a date code of 0835. On November 11, 2008, the licensee incorrectly determined that the defects in four 0835 date code relays were the same condition as had been previously captured in Condition Report CR-WF3-2008-4765 which had been written for date code 0804 relays which failed on September 11 and October 13, 2008. The licensee documented in Condition Report CR-WF3-2008-4782 that a reportability evaluation for the date code 0804 relays would satisfy the requirements to evaluate the date code 0835 relays for reportability. Subsequently on January 28, 2009, Tyco Electronics concluded that the cause of the failures of the two 0804 date code relays was misadjusted terminal blocks. Since this was a different condition that the loose terminal points noted on four date code 0835 relays, the licensee appears to have failed to evaluate the date code 0835 condition for reportability. The relays in this example were designated for the same uses as those described in Example 1, and therefore also were basic components. The failure of these relays prior to use also appeared to constitute a deviation which had the potential to involve a substantial safety hazard. However, because these relays had never been installed in the plant, this condition did not involve a potential for loss of safety function as described in 10 CFR 50.72(b)(3)(v) and 10 CFR 50.73(a)(2)(v). The team compared the licensee\'s reportability evaluation procedures and determined that the licensee\'s procedures did not incorporate all applicable NRC guidance that related to these examples. In particular: The licensee did not include consideration of single failures in addition to the condition being evaluated The procedure guidance evaluated whether the failure had created a substantial safety hazard of a loss of safety function, rather than whether the condition could have created one The procedure did not address whether the failure involved a loss of the potential loss of accident mitigation functions when considering whether a substantial safety hazard was involved The procedures did not address evaluating spare parts which were found to have problems during pre-installations checks to determine whether a deviation from technical requirements was involved On September 3, 2009, the licensee provided three position papers to the NRC documenting positions on Part 21 reporting (reference ML092520027). The licensee stated that they had met their responsibilities based on guidance in NUREG 1022, Event Reporting Guidelines: 10 CFR 50.72 and 50.73, Revision 2 and 10 CFR 21.21. This finding is being treated as an unresolved item (URI) pending determination by the NRC staff whether the licensees failure to evaluate and report the trend of Agastat E7024PB relay unreliability constituted a violation of 10 CFR 21: URI 05000382/2009010-01, Failures to Evaluate Adverse Conditions for Reportability to the NRC |
| Site: | Waterford  |
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| Report | IR 05000382/2009010 Section 4OA3 |
| Date counted | Dec 31, 2009 (2009Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | L Ricketson M Davis G Werner L Carson E Ruesch C Alldredge C Steely N Greene T Farina J O 'Donnell C Speer P Hernandezn O 'Keefe G Nicely E Ruesc |
| INPO aspect | |
| Finding closed by | |
| IR 05000382/2013004 (20 November 2013) | |
| ' | |
Finding - Waterford - IR 05000382/2009010 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2009Q4
Self-Identified List (Waterford)
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