This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section2.3.2 of the
Enforcement Policy.Violation:
10 CFR 50.49(e)(5) requires, in part, that the electrical equipment qualification program must replace or refurbish the equipment at the end of its designated life.Contrary to the above, on November 16, 2017, the licensee identified that thirteen Unit 1, NAMCO limit switches in environmentally qualified (
EQ) applications inside
primary containment were not installed in their fully qualified configuration. Specifically, contrary to vendor instructions and EQAR-004 requirements, the limit switches for several containment isolation valves (
CIV) have had their covers removed and reinstalled without replacing the
gasket and cover screw O-rings. For this application, opening and/or removing the
limit switch gasket /and cover screws O-ring constituted the end of the gasket/O-ring designated life. Significance/Severity Level: The inspectors evaluated this finding using
IMC 0609.04, Initial Characterization of Findings, and
IMC 0609, Appendix A, Exhibit 3,
Barrier Integrity Screening Questions. The inspectors determined that the finding was of very low safety significance (Green), because the limit switches provide only an open or closed signal indication in the main control room, so that operators are aware of the valve position, and can make appropriate assessment of plant conditions. The safety function of the containment isolation valves was not affected.