05000461/FIN-2017009-01

Finding

Title

Failure to Evaluate Replacement Relay Dropout Voltage

Description

Preliminary White. A self-revealed finding preliminarily determined to be of low to moderate safety significance, and an associated apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, was identified on March 9, 2017, for the licensees failure to implement measures for the selection and review for suitability of application replacement relays for the Division 1 Emergency Diesel Generator (EDG) Room Vent Fan, which were components subject to the requirements of 10 CFR Part 50, Appendix B. Specifically, Engineering Changes 330624 and 366624 failed to evaluate the change in the actual drop out voltages for replacement relays on the associated fan circuitry, and instead, introduced new relays into the circuit that resulted in the failure of the fan to operate during an under voltage condition. This rendered the Division 1 EDG inoperable for a time longer than its technical specification allowed outage time, which was a violation of Technical Specification 3.8.1, AC SourcesOperating. The licensee entered this issue into the corrective action program as action request (AR) 03982792. Corrective actions for this issue included restoring the circuit to allow the ventilation fan to operate and returning the emergency diesel generator to an operable condition. The inspectors determined that the licensees failure to verify the suitability of the replacement relays for the Division 1 EDG room vent fan was contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion III and a performance deficiency which was within the licensees ability to foresee and correct. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of the systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to verify the suitability of the replacement relays prior to installation in the Division 1 EDG room vent fan circuitry resulted in the inoperability and unavailability of the Division 1 EDG from May 18, 2016 to March 11, 2017, when one of the unsuitable relays was replaced. Using IMC 0609, Appendix A, Significance Determination Process for 3 Findings At-Power, dated June 19, 2012, a Significance and Enforcement Review Panel preliminarily determined the finding to be of low to moderate safety significance. The inspectors determined that this finding affected the cross-cutting area of human performance in the aspect of challenge the unknown, where individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, a questioning attitude was not used to understand the consequence of the differences in relay features resulting with installing a relay that was incompatible with the current design. [H.11]

01
Site:	Clinton
Report	IR 05000461/2017009 Section 1R15
Date counted	Sep 30, 2017 (2017Q3)
Type:	AV: White
cornerstone	Mitigating Systems
Identified by:	Self-revealing
Inspection Procedure:	IP 71111.15
Inspectors (proximate)	W Schaup E Sanchez M Doyle M Jones J Robbins
Violation of:	10 CFR 50 Appendix B Criterion III, Design Control
CCA	H.11, Challenge the Unknown
INPO aspect	QA.2
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v • d • e

Finding - Clinton - IR 05000461/2017009

1(4)2(7)3(5)4(4)5(0)6(0)7(1)8(1)9(1)10(0)11(1)12(3)201(1)301(0)403(0)404(0)405(0)502(0)

IR 05000461/2017009: 1

Finding List (Clinton) @ 2017Q3

CCA Matrix: 2017Q3

	Q	CCA	Title
05000461/FIN-2016009-02	2016Q4	H.3	Failure to Scope SFP Temperature and Level Instruments into the Maintenance Rule Program
05000461/FIN-2016009-04	2016Q4	H.4	Failure to Verify the Adequacy of Design Assumptions Related to Time Critical Operator Actions
05000461/FIN-2016009-05	2016Q4		Failure to Promptly Identify that the Incapability of the RHR Design to Support TS Operability Requirements Was a CAQ
05000461/FIN-2016009-06	2016Q4	H.9	Failure to Follow the Operability Determination Process Following the Identification of a Control Room HVAC System Design Issue
05000461/FIN-2016004-01	2016Q4	P.1	Failure to Demonstrate the Condition of Flood Seals Was Being Effectively Controlled
05000461/FIN-2016009-01	2016Q4		Non Conservative Control Room Radiological Habitability Assessment
05000461/FIN-2016009-03	2016Q4		Failure to Amend the UFSAR Indicating Choice to Comply with 10 CFR 50.68(b)
05000461/FIN-2016004-02	2016Q4		Dry Cask Storage Procedures Were Not Adequate to Ensure Correct Field Configuration
05000461/FIN-2017001-02	2017Q1	H.14	Failed to Verify an Appropriate Alternate Method of Decay Heat Removal
05000461/FIN-2017001-04	2017Q1	H.1	Failure to Perform Maintenance on Residual Heat Removal Pump C Breaker in Accordance with Procedures
05000461/FIN-2017001-03	2017Q1	H.12	Failure to Develop and Review a Worker Tag Out
05000461/FIN-2017001-01	2017Q1	H.14	Plant Barrier Control Program Failed to Compensate for an Impacted Flood Barrier (
05000461/FIN-2017002-02	2017Q2	P.3	Failure to Perform Adequate Evaluation of Crane Rail Clips
05000461/FIN-2017002-07	2017Q2	H.1	Root Cause Evaluation Failed to Identify Corrective Action to Preclude Repetition
05000461/FIN-2017008-01	2017Q2	H.5	Failure to Perform Required S urveillances on Multiple Fire Dampers
05000461/FIN-2017002-06	2017Q2		Failure to Perform Preventive Maintenance on a Safety - Related Breaker Cubicl
05000461/FIN-2017002-05	2017Q2	H.11	Failure to Properly Classify a Shipment per DOT Regulations
05000461/FIN-2017002-04	2017Q2	H.6	Failure to Provide Sufficient Work Instructions for Performing Maintenance on the Control Room Ventilation System Charcoal Filte
05000461/FIN-2017002-03	2017Q2	H.12	Unexpected Start of the Division 3 Emergency Diesel Generato
05000461/FIN-2017002-01	2017Q2		Failure of Operators to Meet Time Critical Operator Actions
05000461/FIN-2017009-01	2017Q3	H.11	Failure to Evaluate Replacement Relay Dropout Voltage
05000461/FIN-2017201-01	2017Q3	H.5	Security
05000461/FIN-2017007-01	2017Q3	H.1	Failure to Evaluate Defeating Reactor Core Isolation Cooling System Interlocks and Trips before Adding Them to an Emergency Operating Support Procedure
05000461/FIN-2017003-01	2017Q3	H.6	MSIV TS Leakage Limits Exceeded Due to Condition Based Maintenance Approach
05000461/FIN-2017003-02	2017Q3	H.1	Failure to Adequately Control Access in Locked High Radiation Area
05000461/FIN-2017003-03	2017Q3	H.13	Failure to Perform Engineering Evaluation to Determine the Cause of Failure of Snubbers
05000461/FIN-2017003-04	2017Q3	H.14	Flow Control Valves Not Locked Out Results in Reactor Recirculation Pump Runback
05000461/FIN-2017003-05	2017Q3	H.9	Failure to Establish Secondary Containment Prior to Entering MODE 2

Self-Identified List (Clinton)

[Clinton Findings full list]

05000461/FIN-2017009-01

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