ML19067A189

Ltr. 03/07/19 Revised NCV - Palisades Nuclear Plant NRC Integrated IR 05000255/2015003 (NCV 05000255/2015003-01; Failure to Justify Continued Service of Safety-Related Electrolytic Capacitors Installed Beyond Their Service Life (DRS-N.Feliz

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

EA-15-264

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

NCV 05000255/2015003-01

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:

Michael McCoppin

RidsNrrPMPalisades Resource

RidsNrrDorlLpl3

RidsNrrDirsIrib Resource

Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML19067A189

OFFICE

RIII

RIII

RIII

RIII

OE

RIII

NAME

NFeliz-

Adorno:cl

KStoedter

JCameron

JHeck

MMarshfield

via email

KOBrien

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

Enclosure

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

NCV 05000255/2015003-01.

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.

NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01

2

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.

NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01

3

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.

NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01

4

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.

NRC STAFF ASSESSMENT OF DISPUTED NCV 05000255/2015003-01

5

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.