Junk Plant FitzPatrick Purchasing Junk New Components.

"The previously installed Temperature Transmitters were Fisher Controls transmitters; model PM511, an original electronic transmitter from the 1970s. Model PM511 is obsolete and replacement parts were running out so an Engineering Equivalent Change evaluated using an alternative model. The new Moore Industries
temperature transmitters, model RBT/3W20-40/4-20mA/117 AC/-EZ84.06-LNP-VTD[EX], were procured from Moore Industries International and Nutherm International performed the Commercial Grade Dedication."

The industry would say this equipment would be needed so infrequently that not shutting down when required by tech Specs is, the risk is insignificant. I am saying if the plant doesn’t pay a steep price for incompetence with purchasing poor quality new safety components( shutdown per tech specs), then the industry will keep calling events like this to their doorstep.

Junk Plant FitzPatrick Purchasing Junk New Component.  

LER: 2015-008 

‘Containment Atmosphere Dilution System Reliability Degraded due to Manufacturer Defect in Temperature Transmitters’

Dec 18, 2015: Part 21notification

July 31, 2015: First Failure

On 11/11/2015, a second failure

On December 18, 2015, James A. FitzPatrick Nuclear Power Plant (JAF) was operating at 100 percent power when a 10 CFR 21.21(d)(3)(ii) Notification was received from Nutherm International. It identified a defect in Moore Industries temperature transmitters. Specifically, insulation was damaged in the T2 transformer during assembly which could result in premature failure.

These components were installed starting in June 2015 at 27TT-113A and 27TT-113B in the Containment Atmosphere Dilution (CAD) system. The defect caused failures in July and November which resulted in either the “A” or “B” CAD subsystem isolating. Corrective actions included replacing both temperature transmitters with ones that were confirmed to not contain this defect.

Even though these defective temperature transmitters function appropriately until they fail, this defect reduced the reliability of the CAD system to perform its function for its entire mission time. Therefore, this deficiency resulted in a loss of safety function to mitigate the consequences of an accident, reportable per 10 CFR 50.73(a)(2)(v)(D). Also, a single cause affected the safety function of independent CAD trains, reportable per 10 CFR 50.73(a)(2)(vii)(D); and, this condition existed longer then allowed by Technical Specifications 3.6.3.2, reportable per 10 CFR 50.73(a)(2)(i)(B).

Background

The Containment Atmosphere Dilution (CAD) system [EIIS designation: BB] functions to maintain combustible gas concentrations within the Drywell and Torus [BT] at or below the flammability limits following a postulated loss of coolant accident (LOCA) by diluting hydrogen and oxygen with nitrogen. Also, the CAD system provides the pneumatic supply to instruments and controls inside the Drywell; including the long term (100 day) pneumatic supply to the Automatic Depressurization System (ADS) valves [SB] and accumulators following a LOCA…

Event Description 

On December 18, 2015, James A. FitzPatrick Nuclear Power Plant (JAF) was operating at 100 percent power when a 10 CFR 21.21(d)(3)(ii) Notification was received from Nutherm International. It identified a defect in Moore Industries Resistance Temperature Detector (RTD) temperature transmitters supplied to JAF. The transmitters were installed at 27TT-113A and 27TT-113B in the CAD System. A failure of 27TT-113A initiates a closure of CAD subsystem “A” isolation valves 27AOV-128A and 27AOV-129A. A failure of 27TT-113B initiates a closure of CAD subsystem “B” isolation valves 27AOV-128B and 27AOV-129B. Isolating either CAD subsystem impacts the containment makeup capability and the Instrument Nitrogen Header. An Operability Evaluation determined that this defect reduced the reliability of the CAD system such that it may not be able to meet its full 100 day mission time.

This condition was reported to the NRC per 10 CFR 50.72(b)(3)(v)(D), ENS 51613, as a condition which could have prevented the fulfillment of a safety function to mitigate the consequence of an accident.

Event Analysis

The previously installed Temperature Transmitters were Fisher Controls transmitters; model PM511, an original electronic transmitter from the 1970s. Model PM511 is obsolete and replacement parts were running out so an Engineering Equivalent Change evaluated using an alternative model. The new Moore Industries temperature transmitters, model RBT/3W20-40/4-20mA/117 AC/-EZ84.06-LNP-VTD[EX], were procured from Moore Industries International and Nutherm International performed the Commercial Grade Dedication.

The new Moore temperature transmitter contained a defect which first failed on 7/31/2015 in 27TT-113A.

When 27TT-113A failed the “A” CAD subsystem automatically isolated by closing the supply valve 27AOV 128A and backup valve 27AOV-129A. This failure was initially identified as component infant mortality and the component was replaced with a spare component.

On 11/11/2015, a second failure of a new Moore temperature transmitter occurred at 27TT-113B. In a similar fashion to the 7/31/2015 failure, “B” CAD subsystem automatically isolated by closing the supply valve 27AOV-128B and backup valve 27AOV-129B. Based on this now being the second failure of newly installed components, there was increased scrutiny placed on this failure. The components were returned to Nutherm to perform a failure analysis.

The December 18, 2015, Part 21 notification from Nutherm informed JAF that the wire insulation in T2 transformer on the Moore Industries RTD temperature transmitter was damaged during assembly. This damage reduced the insulation resistance and dielectric breakdown between the windings of the transformer; resulting in premature failure of the temperature transmitter.

It has been determined that no visual inspection of the transformer or testing after the transformer is installed will discover this defect. This defect can only be found by performing testing on the transformer prior to installation.

The investigation into the two failures on 7/31 and 11/11 became the driving force which led to the Part 21 Notification on 12/18. The replacement spares installed after the two failures were the two serial numbered components included in the Part 21 Notification made to JAF. The removed failed components were also determined to contain the same defect as the Part 21 Notification.

With no method available to inspect the potentially degraded subcomponent after installation, there is not a reasonable assurance the two components would have been able to meet their required 100 day mission time. This condition could have prevented the fulfillment of a safety function, reportable per 10 CFR 50.73(a)(2)(v)(D). This condition caused two independent trains to be Inoperable in a single system designed to mitigate the consequence of an accident, reportable per 10 CFR 50.73(a)(2)(vii)(D). Technical Specification (TS) 3.6.3.2 requires the CAD system to have two Operable subsystems. On June 17, 2015, when the first defective temperature transmitter was installed, “A” subsystem was Inoperable. Required Action A.1 of the TS requires that it be restored within 30 days. On July 2, 2015, a second CAD subsystem became Inoperable when a second defective temperature transmitter was installed. Required Action B.2 requires that one CAD subsystem be restored within 7 days. When this was not accomplished, Required Action C.1 requires that the plant be in Mode 3 within 12 hours. Since JAF was not in Mode 3 within the required completion time, this event was a condition prohibited by Technical Specifications, reportable per 10 CFR 50.73(a)(2)(i)(B).

Cause

The cause of this event is a defect introduced during the manufacturing of temperature transmitters 27TT- 113A and 27TT-113B installed in the Containment Atmosphere Dilution system which resulted in decreased system reliability.