05000261/FIN-2017007-07
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Finding | |
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Title | Justification of Activation Energy of ASCO Solenoid Coil Assemblies |
Description | Introduction: The inspectors identified a URI concerning the qualified life of ASCO solenoid operated valves. The qualified life determined by the licensee utilized unvalidated information provided by a third-party, non-Appendix B vendor and discounted other critical materials in their weak-link analysis without providing justification in accordance with Regulatory Guide 1.89, Rev. 1. Description: In 2006, the Nuclear Utility Group for Environmental Qualification (NUGEQ) provided a letter suggesting methods to extend the qualified lives of the solenoid operated valves. The licensee modified the qualified life of their ASCO valves as described by NUGEQ and failed to validate and justify the informations acceptability for use. Inspectors determined that the use of MW-35 magnet wires activation energy in place of MW-16 was not appropriate as activation energies are material and failure specific, and are not transferrable between different material compositions. Furthermore, the inspectors determined that the licensee (and NUGEQ) failed to adequately justify the discounting of the other materials in the ASCO solenoid coils, which had lower activation energies than the MW-16 magnet wire as reported by ASCO in their qualification test reports. The failure to justify the discounting of MW-16 magnet wire and other identified limiting component of the ASCO coil assembly was a performance deficiency and a violation of 10 CFR 50.49. Regulatory Guide 1.89, Rev. 1, Regulatory Position 5.c requires, in part, that the basis upon which the rate and activation energy were established should be defined, justified, and documented. Contrary to the above, the licensee failed to justify and document their use of the MW-35 activation energy in place of all other identified limiting activation energies in the ASCO solenoid coil assembly. Additionally, 10 CFR 50.49(e)(5) requires, in part, that equipment be replaced before the expiration of its qualified life unless ongoing testing can demonstrate that the equipment has additional life. Contrary to the above, the licensee failed to demonstrate that the ASCO solendoid coil assemblies have additional life when they failed to justify their departure from ASCOs limiting activation energies. This URI is being opened to determine if this performance deficiency is more than minor. To resolve this URI, the inspectors need to review the licensees response to proposed questions regarding the validation and justification of the appropriate activation energy that will be used in determining the qualified life. (URI 05000261/2017007-07, Justification of Activation Energy of ASCO Solenoid Coil Assemblies) |
Site: | Robinson |
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Report | IR 05000261/2017007 Section 1R21 |
Date counted | Dec 31, 2017 (2017Q4) |
Type: | URI: |
cornerstone | No Cornerstone |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21N |
Inspectors (proximate) | G Ottenberg T Fanelli M Greenleaf S Walker |
Violation of: | Pending |
INPO aspect | |
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Finding - Robinson - IR 05000261/2017007 | |||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Robinson) @ 2017Q4
Self-Identified List (Robinson)
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