05000395/FIN-2018010-05
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Finding | |
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| Title | Potential High Radiation Dose Areas with Unqualified Components |
| Description | The NRC opened a URI to determine if a performance deficiency exists. The licensee did not perform analysis to determine the radiation exposure to shielded components adjacent to electrical and blank penetrations on the outboard side through containment. As a result, many mild environment components may be adversely affected. The inboard side of the penetrations is exposed to rad levels approaching 9X107 rads and the out board side is shielded by thin steel plates with electrical pass-thru holes. The inspectors noted that there were many areas of the plant identified as mild environments with unanalyzed penetrations. For example, the inspectors observed that the two trains for the plant service water were adjacent to unanalyzed penetrations. The components adjacent to the outboard side of the penetrations may be unqualified for service conditions expected during the most severe DBA as required by 10 CFR 50.49(e)(4). NUREG-0588 Section 1.4 "Radiation Conditions Inside and Outside Containment," required, in part, that "(8) Shielded components need be qualified only to the gamma radiation levels required..." and that "(12) Equipment that may be exposed to radiation doses below 104 rads should not be considered to be exempt from radiation qualification, unless analysis supported by test data is provided to verify that these levels will not degrade the operability of the equipment below acceptable values. The licensee provided a white paper for this issue that asserts that consideration of radiation streaming was not part of their licensing basis, thus enforcement would be addressed through a backfit analysis in accordance with 10 CFR 50.109. The team must determine whether the site licensing basis required consideration of radiation streaming and whether a backfit analysis would be appropriate in lieu of enforcement. The licensee captured this issue in their corrective action program as CR-18-00684 and determined that the process for qualification of equipment used was found acceptable per the VCS SER. Further evaluation will be performed under this CR but currently all components are qualified to their expected operating conditions and will perform their design functions. At worst, the EQ life of components may be reduced. All equipment in penetration areas are operable. |
| Site: | Summer  |
|---|---|
| Report | IR 05000395/2018010 Section 1R21 |
| Date counted | Mar 31, 2018 (2018Q1) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21N |
| Inspectors (proximate) | T Fanelli M Riley C Franklin M Sykes |
| INPO aspect | |
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Finding - Summer - IR 05000395/2018010 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Summer) @ 2018Q1
Self-Identified List (Summer)
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