Inspection Results by Plant 2017

Transcription

1 Fall 2017 EQ Technical Conference November 8-10, 2017 Clearwater, Florida William Horin, Winston & Strawn, LLP (Counsel to NUGEQ Ron Wise, NEQ Consulting (NUGEQ Technical Consultant

2 High Level Overview Currently, 13 of the 17 EQ DBA Inspections scheduled for 2017 have been completed Inspections have occurred across all 4 NRC regions 3 in NRC Region I 4 in NRC Region II 3 in NRC Region III 3 in NRC Region IV 2

3 Inspection Results for Region I Region I Station Date Results Remarks Hope Creek Week 1: May 8, 2017 Week 2: May 22, Green NCV (Violation of TS ) for failure to maintain secondary containment IR / Millstone Week 1: July 31, 2017 Week 2: Aug 14, 2017 Ginna Week 1: Aug 7, 2017 Week 2: Aug 21, 2017 integrity 1 Green NCV (Violation of TS a) for not implementing procedures as required by RG 1.33 No NRC identified or self revealing findings were identified IR / & IR / IR /

4 Inspection Results for Region II Region I Station Date Results Remarks McGuire Week 1: Jan 23, 2017 Week 2: Feb 6, Green NCV (App B, Criterion III) for failure to translate requirements necessary to maintain qualification of Namco LS 1 st EQ DBAI IR / & IR / Watts Bar Week 1: June 5, 2017 Week 2: June 19, Green NCV (App B Criterion V) for failure to implement instructions necessary maintain qualification of Namco LS 1 Green NCV (50.49(j)) for failure to maintain a complete record of qualification for Brand-Rex Cables 3 Unresolved Items IR / & IR /

5 Inspection Results for Region II (continued) Region I Station Date Results Remarks Hatch Week 1: Aug 14, 2017 Week 2: Aug 28, 2017 No NRC identified or self revealing findings were identified 2 Unresolved Items IR / & IR / Robinson Week 1: Oct 2, 2017 Week 2: Oct 16, Green NCVs 2 NOVs (Significance TBD) 5 Unresolved Items Exited on 10/31/17 5

6 Inspection Results for Region III Region III Station Date Results Remarks Fermi Week 1: May 8, 2017 Week 2: May 22, Green NCV (App B, Criterion III) involving protective devices in MCCs 1 Green NCV (50.49 (e)(1)) involving two examples related to post accident op-time calculations 1 Green NCV (App B, Criterion III) on failure to translate requirement into maintenance procedures 1 Licensee Identified violation for 10 CFR 50.49(k) IR /

7 Inspection Results for Region III (continued) Region III Station Date Results Remarks LaSalle Week 1: June 26, 2017 Week 2: July 10, Green NCV (50.49 (f)(4)) for failure to provide adequate analysis in combination with partial type testing 1 Green NCV (50.49 (j)) for failure to have adequate justification for extending service life of grease IR / & IR /

8 Inspection Results for Region III (continued) Region III Station Date Results Remarks Monticello Week 1: Sept 18, 2017 No NRC identified or self revealing Exited on 10/6/2017 Week 2: Oct 2, 2017 findings were identified 8

9 Inspection Results for Region IV Region IV Station Date Results Remarks Wolf Creek Week 1: May 8, 2017 Week 2: May 22, Green NCV (50.54 (q)(2)) for failure to maintain the effectiveness of the E-Plan upon loss of CHRRM IR / ANO Week 1: July 24, 2017 Week 2: Aug 7, Green NCV (App B, Criterion XVI) for failure to promptly identify and correct an inadequate design basis calculation IR / & IR / Cooper Week 1: Aug 24, 2017 Week 2: Aug 28, 2017 No findings were identified. IR /

10 10 So what were the two NOVs at Robinson? #1 Failure to perform adequate similarity analysis between Westinghouse prototype and installed Crouse-Hinds EPA #2 Qualified Life of ASCO NP-1 coils based on activation energy from a different material (MW35 vs. MW16). Related to use of NUGEQ memo. Both categorized as Significance TBD at (final) exit

11 Unresolved Items Region I: None Region II: 10 3 at Watts Bar 2 at Hatch 5 at Robinson Region III: None Region IV: None 11

12 So what is the significance of these URIs? Several of these URI s have generic implications To other licensees To vendors To other equipment types Some have the potential to change/challenge the CLB for the affected plants URI s in BOLD are related to NUGEQ comments 12

13 Unresolved Items at Watts Bar URI #1 Potential Failure to Address Environmental Qualification of Brand-Rex Cables Centered around the derivation of the activation energy for the cable insulation NRC challenged method that eliminated one data point (highest temperature) since it reflected the presences of a 2 nd order reaction 13

14 Unresolved Items at Watts Bar (continued) URI #2 Potential Failure to Justify Qualification of O-rings by Commercial Grade Dedication Centered around a dedication of O-rings for Barton Transmitters by a 3 rd party approved App B vendor Dedication confirmed material to be same as the baseline EQ certified O-ring NRC challenged why dedication did not include verification Ea or EQ testing for the O-rings 14

15 Unresolved Items at Watts Bar (continued) URI #3 Potential Failure to Address Environmental Qualification of Barton Transmitters Centers around the qualified life of Barton 764 transmitters and justification for deviating from the original 0.5eV activation. 0.92eV values was used by WEC (as well as Barton) for the O-rings 15

16 16 Unresolved Items at Watts Bar (continued) URI #3 Potential Failure to Address Environmental Qualification of Barton Transmitters Due to an anomaly, replacement O-rings were aged using 0.92eV for 14 hours during the test program NRC challenged the justification for deviating from the original 0.5eV value including synergistic effects and uncertainties.

17 Unresolved Items at Hatch URI #1 Potential Failure to Adequately Justify the Activation Energies by Licensee Related to the justification for selecting activation energies for 600V MCC fuses and Zytel 103 used in Scram Solenoid Pilot Valves NRC considered the activation energies being used as non-conservative 17

18 Unresolved Items at Hatch (continued) URI #2 Potential Failure to Adequately Justify the Activation Energies by 10 CFR 50 Appendix B vendors Centers around the adequacy of the licensee s acceptance of vendor s justification for the activation energies for the 600V MCC fuses and the Zytel 103 subcomponent in the SSPV 18

19 Unresolved Items at Robinson URI #1 Qualification of Penetrations Failure to consider UFSAR reference to proposed IEEE standard. Discrepancy regarding ampacity during shortcircuit conditions between RNP calculation and specification 19

20 Unresolved Items at Robinson (continued) URI #2 EQDP-0900 (Crouse-Hinds Penetration) Did not adequately extend the QL to 60 years due to inappropriate application of Arrhenius to determine activation energy and uncertainties. 20

21 Unresolved Items at Robinson (continued) URI #3 EQDP-0401 (Rosemount Transmitters) Unjustified use of single activation energy (0.78eV). NRC believes RNP should have considered multiple ev values over temperature range RNP provided insight from RNII describing the appropriateness of Ea used in QL Calculation 21

22 Unresolved Items at Robinson (continued) URI #4 Chemical Spray Qualification Maximum ph stated in TS Bases and UFSAR is The EQ Zone map and supporting WCAP calculation indicate max ph of A GSI-191 calculation shows a max ph of

23 Unresolved Items at Robinson (continued) URI #5 Penetration Submergence Qualification Submergence qualification of electrical penetration F-01 not proven. Issue previously identified by NRC in 1980s and drove modification. Closed by NRC in

24 Questions or Comments? 24