EQ-Related Enforcement Activity

Transcription

1 EQ-Related Enforcement Activity Fall 2014 EQ Technical Conference Nuclear Utility Group on Equipment Qualification November 10-14, 2014 Clearwater, Florida William Horin, Winston & Strawn, LLP (Counsel to NUGEQ Ron Wise, NEQ Consulting (NUGEQ Technical Consultant

2 12/05/13 Duane Arnold NCV/ Green CRIT III Failure to Establish Measures for the Selection and Review for the Suitability of Safety-Related Cables Procedure allowed for safety-related cabling that was not qualified or specifically designed for total submergence in water to be used in water filled conduits w/o suitable testing or design control measures 01/29/14 Rosemount Nonconformance CRIT V QA Program Deficiencies RNII procedure Operations Procedure 0720, Control of Purchased Safety-Related Components, and select technical evaluations failed to include requirements or acceptance criteria sufficient to verify critical characteristics that were necessary to assure that dedicated items would perform their intended safety functions. 2

3 Failure to Maintain Environmental Qualification for Electric Equipment 02/04/14 Harris NCV/ Green Licensee failed to adequately implement the EQ Program when between September - November 2013, multiple EQ program deficiencies were identified including design documentation and the qualification of electric equipment installed in the plant. Inadequate HELB Barrier Controls 02/06/14 Salem NCV/ Green TS In October 2013, PSEG conducted maintenance activities that impacted HELB barriers w/o a dedicated barrier attendant stationed at the openings with a means to rapidly close the openings and restore the barrier function to a condition equivalent to the design condition. 3

4 02/12/14 Prairie Island NCV/ Green App B CRIT III Failure to Establish Appropriate Design Control Measures for Selection of Replacement Parts Licensee s selection and evaluation of parts essential to the safety-related functions of SSC failed to ensure that replacement materials/ parts were of equal quality to those specified for the original equipment. Replacement part(s) were not evaluated by for suitability by engineering prior to installation. Programmatic Failure to Scope SSCs 02/14/14 Ginna NCV/ Green CENG failed to appropriately include an estimated 90 safetyrelated and non-safety-related SSCs within the scope of the maintenance rule monitoring program, which could have resulted in a failure to detect SSC degradation. 4

5 03/28/14 South Texas NCV/ Green CRIT III Failure to Evaluate the Adequacy of Voltage Available at AF- 19 Valve Motor to Close the Valve During Postulated HELB Conditions Valve AF-19 was required to close to terminate auxiliary feedwater flow under certain accident scenarios (including HELB conditions) as stated in the UFSAR. However, the licensee failed to evaluate the adequacy of voltage available at the AF-19 valve motor operator to close the valve during postulated H ELB conditions. 04/30/14 Brown Ferry NCV/ Green (Closed) LER , High Pressure Coolant Injection (HPCI) System Declared Inoperable Due to an Unqualified Electrical Splice From April 3, 2013 until September 25, 2013, the motor leads for the HPCI main pump minimum flow valve were spliced with Scotch Electrical Tape resulting in a loss of EQ. 5

6 Failure to Follow Plant Procedures for Replacement of NAMCO Limit Switches 04/30/14 Watts Bar NCV/ Green TS Inspectors identified that WO was written to replace the upper limit switch on a containment isolation valve on or about November 30, The safety function of this valve was to isolate on a containment isolation signal and to provide indication that it has done so to the PAMS. The incorrect, lower limit switch was specified in the WO, drawn from stock, and installed in the upper limit switch position. In order for this limit switch to function properly to pass its post maintenance test, it was modified by disassembling and shifting around internal parts. The applicable maintenance installation procedure prohibited removing the back cover of either environmentally qualified or Class 1E (safety related) NAMCO limit switches in the Precautions and Limitations section. 6

7 05/13/14 Hope Creek Green/ NCV CRIT V Inadequate Evaluation of 480VAC Motor Control Center Design Change On October 28, 2013, electricians were installing a replacement bucket in the Class 1E 480 VAC MCC when an arc flash occurred, and caused extensive damage in the vertical section of the MCC and caused the supply breaker of the MCC to trip open on ground fault, de-energizing the MCC. The decision to install screws to connect control power blocks and terminal blocks in 480 VAC replacement buckets did not receive sufficient review and approval. 05/14/14 Steris Isomedix Nonconformance CRIT XI and XII Inadequate Test Control and Control of Measuring and Test Equipment Steris failed to ensure that the measuring and testing system (e.g. the dosimeters, associated procedures, and dosimetry reading equipment) used to determine the applied radiation dose to nuclear components was properly controlled and calibrated. 7

8 Failure to Take Timely Corrective Actions to Address Extensive Backlog of EQ Information 06/09/14 Watts Bar Green/ NCV Since January of 2010, the licensee failed to take prompt and appropriate corrective actions to evaluate and correct an extensive backlog of EQIRs, which resulted in 81 of the licensee s 99 required EQ Files not being updated to reflect the as-installed specifications and configuration of EQ equipment. Programmatic QA Program Deficiencies 06/24/14 RSCC Wire & Cable LLC Nonconformance CRIT III RSCC did not evaluate or place controls on the use of L4 oil on the KXL-760D insulation during the manufacturing process for Class 1E nuclear cables. RSCC also failed to ensure that product specification drawings were consistent with actual design specifications. 8

9 07/28/14 Indian Point Green/ NCV CRIT III Non-Qualified Component Installed in Harsh Environment for Actuator During 12-year overhaul of auxiliary boiler feedwater flow control valve, a Masoneilan air pressure regulator was installed in a harsh environment for which it was not designed or qualified. 07/31/14 Callaway Green/ NCV CRIT III Failure to Analyze Max Electrical Equipment Temps Due to Failure of Air Conditioning Licensee failed to account for the temperature differences inside/ outside of electrical cabinets in Class 1E rooms, and effects of increased temps on the components in the cabinets. 9

10 Inadequate Procedures for Preplanning and Performing Maintenance Affecting Safety-Related Hydramotor 08/01/14 Clinton Green/ NCV TS Licensee failed to properly pre-plan and perform the required preventive maintenance for the ED G Room Ventilation damper hydramotor. The hydramotor subsequently failed due to agerelated degradation. 08/01/14 Watts Bar Green/ NCV CRIT XVI Installation of Non-Conforming Contactor In Safety Related Equipment From November 2013 to May 15, 2014, the licensee failed to identify a condition adverse to quality associated with installation of non-conforming contactor into 480 volt breaker. 10

11 08/12/14 Cooper Green/ NCV CRIT III Failure to Correctly Translate Design Requirements into Installed Plant Configuration From initial construction to present, licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a HELB. 09/18/14 Fort Calhoun SL-IV Failure to Report Loss of EQ of Safety Related Limit Switches within Required Time Limits Licensee failed to report within 60 days the discovery that Namco Type EA 180 limit switches did not meet EQ due to inadequate maintenance procedures. 11

12 09/29/14 Ginna Green/ NCV CRIT XI Inadequate Test Control for MSIV Solenoid-Operated Valves Licensee did not perform adequate periodic and independent testing to demonstrate that SOVs that actuate to operate (close) the MSIVs would perform satisfactorily in the event of a postulated single failure during a design basis event. 10/10/14 Wolf Creek Green/ NCV CRIT V Failure to Perform Operability Determinations Degraded Boundaries (H ELB ) Licensee did not evaluate the ability of dedicated operators to perform credited actions before stationing them as boundary watches for HELB doors. 12

13 Observations Recent Enforcement Activity is Generally Being Driven By: latent programmatic deficiencies that become self-revealing after an actual event occurs (self-identification) or during an NRC inspection; and an underlying breakdown in some aspect of the Human Performance (decision-making, work practices or work controls) and/or the PI&R (corrective action process, operating experience, or self- assessments) 13

14 Observations Programmatic Deficiencies Continue to Account for Major Share of Noncompliances Inadequate Preventive Maintenance Practices Inadequate Design & Test Control Problem Identification & Resolution Procedural Adherence & Development 14