ML19067A189
| ML19067A189 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/07/2019 |
| From: | O'Brien K Division of Reactor Safety III |
| To: | Arnone C Entergy Nuclear Operations |
| References | |
| EA-15-264 IR 2015003 | |
| Download: ML19067A189 (8) | |
See also: IR 05000255/2015003
Text
March 7, 2019
Mr. Charles Arnone
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: REVISED NON-CITED VIOLATIONPALISADES NUCLEAR PLANT
NRC INTEGRATED INSPECTION REPORT 05000255/2015003
(NCV 05000255/2015003-01; FAILURE TO JUSTIFY CONTINUED
SERVICE OF SAFETY-RELATED ELECTROLYTIC CAPACITORS
INSTALLED BEYOND THEIR SERVICE LIFE)
Dear Mr. Arnone:
On November 30, 2015, Palisades Nuclear Plant (PNP) provided a written response
to U.S. Nuclear Regulatory Commission (NRC) Inspection Report 05000255/2015003,
which was issued on October 30, 2015. Specifically, the letter contested Non-Cited
Violation 05000255/2015003-01 associated with the failure to justify continued service of
safety-related containment floor level indicating transmitter electrolytic capacitors installed
beyond their service life. The letter explained PNP agreed a performance deficiency occurred
but disagreed the deficiency was associated with a violation of Title 10 of the Code of Federal
Regulations, Part 50, Appendix B, Criterion III, Design Control, as stated in the inspection
report. The letter further stated PNP believed the performance deficiency was associated with
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.
The NRC carefully reviewed PNPs reply and determined the Non-Cited Violation should
be changed to a violation of Technical Specifications Section 5.4.1, Procedures, as
shown in the enclosed report. Technical Specifications Section 5.4.1, requires, in part, the
establishment, implementation, and maintenance of written procedures recommended in
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 9 of the Regulatory
Guide requires the development of preventive maintenance schedules and associated
procedures for the inspection or replacement of parts that have a specific lifetime. The bases
for the staffs conclusion are detailed in the enclosed report.
C. Arnone -2-
This letter, its enclosure, PNPs November 30, 2015, response, and your response (if any)
will be made available for public inspection and copying at http://www.nrc.gov/reading-
rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390,
Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Kenneth OBrien, Director
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
NRC Staff Assessment of Disputed
cc: Distribution via LISTSERV
C. Arnone -3-
Letter to Charles Arnone from Kenneth OBrien dated March 7, 2019.
SUBJECT: REVISED NON-CITED VIOLATIONPALISADES NUCLEAR PLANT
NRC INTEGRATED INSPECTION REPORT 05000255/2015003
(NCV 05000255/2015003-01; FAILURE TO JUSTIFY CONTINUED
SERVICE OF SAFETY-RELATED ELECTROLYTIC CAPACITORS
INSTALLED BEYOND THEIR SERVICE LIFE)
DISTRIBUTION:
RidsNrrPMPalisades Resource
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ADAMS Accession Number: ML19067A189
OFFICE RIII RIII RIII RIII OE RIII
NAME NFeliz- KStoedter JCameron JHeck MMarshfield KOBrien
Adorno:cl via email
DATE 02/26/19 02/26/19 03/05/19 03/06/19 03/06/19 03/07/19
OFFICIAL RECORD COPY
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information provided in
Palisades Nuclear Plant (PNP) letter dated November 30, 2015. This review was performed by
staff members having relevant technical and regulatory knowledge and who did not participate
in the inspection documented in NRC Inspection Report 05000255/2015003. Documents
referenced are listed in the Reference Section of this Enclosure.
1. BACKGROUND
On June 21, 2015, containment floor level indicating transmitter (LIT) 0446B failed a
surveillance required by Technical Specifications (TS) due to a failure of its electrolytic
capacitor. The licensee determined the likely cause was operation beyond 10 years and
replaced the failed component. Further review by the inspectors revealed the licensee
had a preventive maintenance template for the capacitors in LIT-0446B and its redundant
component LIT-0446A, which recommended inspection or replacement on a 12 year
interval. However, no preventive maintenance schedule or associated procedures for
the inspection or replacement of the components had been established. Rather, the
components were scheduled to be replaced on an as-required basis.
The inspectors also found the licensee had established a maintenance schedule for
capacitors installed in other safety-related systems. The difference in treatment was driven
by a prior decision to classify some of the capacitors as critical and others as non-critical
within its Preventive Maintenance Program. For components the licensee had classified as
critical in its Preventive Maintenance Program, a preventive maintenance schedule of
10 years had been established, which was consistent with industry operating experience
and guidance pertinent to the service life of electrolytic capacitors. No such schedule or
replacement procedures were developed for the non-critical components.
The licensee missed a potential opportunity to establish a maintenance schedule for the
capacitors in LIT-0446A and LIT-0446B when it evaluated service life information available
in NRC Information Notice (IN) 2012-11, Age-Related Capacitor Degradation. That IN
included a vendor-recommended 10-year replacement interval for electrolytic capacitors
similar to those in LIT-0446B and LIT-0446A. However, during its review of the IN, the
licensee concluded no further action was needed since its critical components already
had a 10-year preventive maintenance schedule.
On October 30, 2015, the NRC issued Integrated Inspection Report 05000255/2015003
documenting the 3-month period of inspection that assessed, in part, this issue. This
report documented this issue as a finding of very-low safety significance (Green) and an
associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR),
Part 50, Appendix B, Criterion III, for the failure to review for suitability of application of the
safety-related electrolytic capacitors in the containment floor LITs, which were installed
beyond their service life. This inspection report dispositioned this issue as
On November 30, 2015, PNP provided a written response to the NRC contesting the
enforcement decision associated with NCV 05000255/2015003-01. Specifically, the letter
explained PNP agreed a performance deficiency occurred but disagreed it was associated
with a violation of 10 CFR Part 50, Appendix B, Criterion III, as stated in the inspection
report. Rather, PNP stated the performance deficiency was associated with 10 CFR
Part 50, Appendix B, Criterion V.
Enclosure
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01
2. ORIGINAL ENFORCEMENT DECISION
The original enforcement decision as stated in Inspection Report 05000255/2015003 was:
Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that
measures shall be established for the selection and review for suitability of application
of materials, parts, equipment, and processes that are essential to the safety-related
functions of SSCs [structures, systems, and components].
Contrary to the above, as of June 21, 2015, the licensee failed to review for suitability of
application of parts essential to the safety-related functions of the containment floor level
indicating system. Specifically, the licensee did not review for suitability of application of
safety-related electrolytic capacitors in the containment floor LITs that were installed
beyond their recommended service life to justify their continued service considering
in-service deterioration. As part of their immediate corrective actions, the licensee
replaced the failed components.
3. LICENSEE POSITION
In the letter dated November 30, 2015, the licensee stated PNP agreed a performance
deficiency occurred but disagreed it was associated with a violation of 10 CFR Part 50,
Appendix B, Criterion III, as stated in the inspection report. The letter further stated PNP
believed the performance deficiency was associated with 10 CFR Part 50, Appendix B,
Criterion V. The basis for the licensees position was, in part, that regulatory requirements
(including Criterion V) and NRC endorsed quality assurance program standards (including
Regulatory Guide 1.33, Revision 2) require the establishment of maintenance schedules as
opposed to strictly adhering to vendor recommendations or formally evaluating deviations
from those recommendations under a quality assurance program established to meet
10 CFR Part 50, Appendix B. The licensee agreed it had not established a preventive
maintenance schedule for the capacitors in LIT-0446B and LIT-0446A. In addition, the
licensee asserted issuance of NCV 05000255/2015003-01 was premature because the
underlying NRC staff position may be changed by the ongoing NRC development of a
Regulatory Issue Summary (RIS).
4. NRC STAFF REVIEW
The NRC staff considered PNPs assertion that regulatory requirements and NRC
endorsed quality assurance program standards do not require licensees to strictly adhere
to vendor recommendations or formally evaluate deviations from those recommendations
under the Appendix B quality assurance program. The NRC staff agrees that a licensee
may not have requirements involving strict adherence to vendor recommendations, unless
specified in other design and licensing basis documents. However, the NRC does require
the establishment of quality assurance programs and supporting procedures that, among
other things, set preventive maintenance schedules for the inspection or replacement of
parts that have a specific lifetime.
2
NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01
In this case, the licensees preventive maintenance template established a specific lifetime
for electrolytic capacitor inspection/replacement interval of once every 12 years. The
licensee had established procedures with a replacement interval of up to 10 years for
electrolytic capacitors classified as critical components. However, no preventive
maintenance schedule or associated procedures were developed for electrolytic capacitors
classified as non-critical components. The capacitor that failed in LIT-0446B, which was in
a safety-related system, was classified as non-critical.
As discussed in the licensees letter, the failure to develop procedures to ensure continued
quality of the safety-related electrolytic capacitors in LIT-0446B and LIT-0446A during the
equipment operational phase could be dispositioned as a violation of 10 CFR Part 50,
Appendix B, Criterion V, which requires, in part, activities affecting quality to be prescribed
by documented procedures of a type appropriate to the circumstances. Similarly, the
issue could be dispositioned as a violation of TS Section 5.4.1, Procedures, which
requires, in part, the establishment, implementation, and maintenance of written procedures
recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 9
of the Regulatory Guide requires the development of preventive maintenance schedules
and associated procedures for the inspection or replacement of parts that have a specific
lifetime.
Finally, the staff considered the licensees position that any inspection finding in this matter
should await the development of a RIS. Since the licensees letter, the NRC decided not
to issue a RIS as explained in the Statements of Considerations published by the NRC
in 83 FR 46199 (September 12, 2018). Instead of issuing a RIS, in 2018, the NRC provided
training to inspectors to, in part, assist them in identifying and dispositioning issues related
to how long safety-related structures, systems, and components remain in service and
clarify the applicability of various regulations and industry standards.
5. CONCLUSION
The NRC staff carefully considered the information provided by PNP in its letter
dated November 30, 2015, and determined the original enforcement decision of
NCV 05000255/2015003-01 should be modified as follows:
Technical Specification 5.4.1, Procedures, states, in part, that written procedures
shall be established, implemented, and maintained covering the applicable
procedures recommended in Regulatory Guide 1.33, Quality Assurance Program
Requirements, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,
Revision 2, Appendix A, Section 9, Procedures for Performing Maintenance, requires,
in part, that preventive maintenance schedules shall be developed for the inspection or
replacement of parts that have a specific lifetime.
Contrary to the above, as of June 21, 2015, the licensee failed to develop a procedure
for preventive maintenance schedules for the inspection or replacement of parts that
have a specific lifetime. Specifically, the licensee did not develop procedures covering a
preventive maintenance schedule for the electrolytic capacitors in the containment floor
level indicating system, LIT-0446A and LIT-0446B, which had a specific lifetime.
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NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01
6. REFERENCES
1. Letter from Mohammed A. Shuaibi to Aby S. Mohseni; Final Task Interface
AgreementRegulatory Position on Design Life of Safety-Related Structures, Systems,
and Components Related to Unresolved Items at Donald C. Cook Nuclear Power Plant,
Monticello Nuclear Generating Plant, and Palisades Nuclear Plant (TIA 2014-01);
May 7, 2015.
2. Letter from Eric Duncan to Mr. Anthony Vitale; Palisades Nuclear Plant NRC Integrated
Inspection Report 05000255/2015003; October 30, 2015.
3. Letter from Otto W. Gustafson to the NRC Document Control Desk; Response to
Non-Cited Violation Dated October 30, 2015; November 30, 2015.
4. Letter from Edwin M. Hackett to Victor M. McCree; Committee to Review Generic
Requirements: Minutes of Meeting Numbers 446 and 447; October 17, 2017.
5. Definitions; 10 CFR 50.2; 2015-2017.
6. Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants;
10 CFR Part 50, Appendix B; 2015-2017.
7. Requirements for monitoring the effectiveness of maintenance at nuclear power plants;
10 CFR 50.65; 2015-2017.
8. Regulatory Guide 1.33; February 1978; Quality Assurance Program Requirements;
U.S. Nuclear Regulatory Commission; Washington, DC.
9. Regulatory Guide 1.186; December 2000; Guidance and Examples for Identifying
10 CFR 50.2 Design Bases; U.S. Nuclear Regulatory Commission; Washington, DC.
10. 34 FR 6599; Quality Assurance Criteria for Nuclear Power Plants; Federal Register;
Volume 34; p. 6599; Washington, DC; April 17, 1969.
11. 35 FR 10498; Quality Assurance Criteria for Nuclear Power Plants; Federal Register;
Volume 35; p. 10498; Washington, DC; June 27, 1970.
12. 48 FR 2729; Environmental Qualification of Electric Equipment Important to Safety for
Nuclear Power Plants; Federal Register; Volume 48; p. 2729; Washington, DC;
January 21, 1983.
13. 60 FR 22478; Nuclear Power Plant License Renewal; Federal Register; Volume 60;
p. 22478; Washington, DC; May 8, 1995.
14. 81 FR 30571; Disposition of Information Related to the Time Period That
Safety-Related Structures, Systems, or Components Are Installed; Federal Register;
Volume 81; p. 30571; Washington, DC; May 17, 2016.
15. 83 FR 46199; Disposition of Information Related to the Time Period That
Safety-Related Structures, Systems, or Components Are Installed; Federal Register;
Volume 83; p. 46199; Washington, DC; September 12, 2018.
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NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01
16. NRC Enforcement Manual; Revisions 9 and 10.
17. NRC Enforcement Policy; February 4, 2015, and November 1, 2016.
18. Information Notice 2012-11; Age-Related Capacitor Degradation; U.S. Nuclear
Regulatory Commission; Washington, DC; July 23, 2012.
19. Revised Appendix B to NEI 97-04; Guidance and Examples for Identifying 10 CFR 50.2
Design Bases; November 2000.
20. CR-PLP-2012-05721; Palisades Review of IN 2012-11; August 16, 2012.
21. Inspector Guidance (Training) on Service Life Issues; June 2018; ML18219A470.
22. TR-112175; Capacitor Application and Maintenance Guide; EPRI; Palo Alto, CA;
August 19, 1999.
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