IR 05000219/1986008
| ML20205C162 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/04/1986 |
| From: | Andrea Johnson, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20205C140 | List: |
| References | |
| 50-219-86-08, 50-219-86-8, NUDOCS 8608120267 | |
| Download: ML20205C162 (22) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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50-219/86-08 Report No.:
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50-219 Docket No.:
DPR-16 License No.:
General Public Utilities Nuclear Corporation Licensee:
Post Office Box 388
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08731 Forked River, New Jersey Oyster Creek Nuclear Generating Station Facility Name:
GPU Nuclear Corporation - Technical Functions Inspection At:
99 Cherry Hill Road Parsippany, New Jersey and Forked River, New Jersey March 24 to 27, Inspection Conducted:
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Dhte alification i
Inspector:
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1. Johnson, Equipment Inspection Section (EQIS Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, IE S. D. Alexander, Engineer, IE R. A. Borgen, Consultant Engineer, Idaho National Engineering Labor D. Beahm, Consultant Engineer, Idaho National Engineering Laboratory M. J. Jacobus, Member of Technical Staff, Sandia National Laborator J. M. Chavez, Member of Technical Staff, Sandia National Laborator L. S. Cheung, Reactor Engineer, RI M. Dev, Reactor Engineer, RI
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~ Date Approvea by:
U. Potapovs, Chief, EQIS,ipndor Program Branch
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8608120267 860808
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INSPECTION SUMMARY:
tNo.50-219/86-081 Inspection on March 24 to 27, 1986 (Inspection Repor
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Special, announced inspection to review the licensee f 10 CFR 50.49 for f electric equipment within implementation of a program per the requirements oT Areas Inspected:
i establishing and maintaining the qualificat on o the scope of 10 CFR 50.49.
These commitments were made by the licensee as Report (SER),and i
30, 1982, Safety Evaluat ontion Report (FRC TER);
l dsficiencies in the November July 9,1982 Franklin Research Center Technical Eva uadeficiencies j
(2) proposed method of resolution for each of the EQ 22, a~nd March 15, February 21, 1984, licensee on December 7 in responses from the licensee (December 1985) as a result of the NRC staff meeting with the d (3) the Safety Evaluation t to safety submitted 1983 for which the above SER/TER was prepared t
28, 1985.
implemented a program to the licensee on May The inspection determined that the licensee has9 except for certain to meet the requirements of 10 CFR 50.4No deficiencies were foun l
Results:
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corrective action commitments made as a result oin t d in licensee responses listed below.
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d (3) the SE for 15, 1985 ; an February 22, and March 21, 1984, f
(December final resolution of EQ.
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Potential Enforcement / Unresolved Items:
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Report Item Number Paragraph Name 50-219/86-08-01 4.F(1)
Limitorque Motor Operator Grease
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Relief Valve and "T" Drain Requirements 50-219/86-08-02 4.F(2)
Limitorque Motor Operator 2.
Wiring 50-219/86-08-03 4.F(3)
Namco Limit Switches, Model 3.
01200G 50-219/86-08-04
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4.F(4)
Namco Limit Switches, Model EA740 50-219/86-08-05 4.
4.F(5)
Rockbestos Firewall III/ SIS 5.
Cable; PVC Splice Tape; GE Type EB Terminal Blocks i
Open Items:
Report Item Number Paragraph Name 50-219/86-08-06 4.F(8)
Minor EQ Documentation 1.
Deficiencies 50-219/86-08-07 4.F(6)
Thomas and Betts Wire 2.
Terminations 50-219/86-08-08 4.B(1)
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EQ Program Procedures -
Maintenance
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DETAILS
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Persons Contacted 1.
General Public Utilities Nuclear Corporation (GPUN)
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_*C.Tracy, Director, Engineer Assurance
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- J. Mancinelli, Manager EQ/F.P.
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Pagan, EQ Manager *R.
S. Markowski, Manager QA Program Development / Audit D. K. Croneberger, Director, Engineering & Design D. Grace, Engineering Projects Director, O.C.
- M. W. Laggart, Manager Licensing, O.C.
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T. G. Broughton, Director, System EngineeringL. *0. J. Corbett, QA Program Development & Training Supervisor
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E. T. Banua, EQ Engineer N. G. Trikouros, Safety Analysis
- Y. Nagai, Licensing Engineer J. C. Auger, Licensing Engineer P. S. Smith, Safety Analysis Engineer
- R. Kasthuri, QA Engineer G. Simonetti, Audit Manager, 0.C.
J. Solakiewicz, QA Engineering & Systems Manager H. Sharma, Engineer, EP&I, 0.C.T. Gaffney, Manager, Electr T. Jenkins, Asst. Manager, M&C Work Force R. Peck, Electrical Job Planner K. Bass, Manager, M&C Production
- E. Banua, EQ Engineer 1.2 NRC
- C. Anderson, RI, Chief, Plant System Section
- W. H. Bateman, Senior Resident Inspector, O.C.
- J. F. Wechselberger, Resident Inspector, 0.C.
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March 27, 1986
'* Denotes those present at exit interview at Parsippany, NJ on
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e's implementation Purpose i
2.
The purpose of this inspection was to review the l censeified de tation of corrective l
of the requirements of 10 CFR 50.49 and the imp emen f the identified action commitments made as a result of (1) identSE 21, 1984, Feb-(December NRC staff meetin~g with deficiencies documented in licensee responsesas a result of theSER f 15,1985)
ruary 22, and Marchthe licensee on December 7, 1983; and (3) the EQ.
B_ackground t to discuss On December 7,1983, the NRC held a meeting with the licens e 3.
all remaining open issues regarding environmental qua i
nt qualification acceptability of the environmental conditions for equ pm i
ntal November 30, 1982 SER and qualification deficiencies identified in the Discussions also purposes.
July 9,1982 FRC TER was the subject of discussi 10 CFR 50.49, and justification for continued safe operation mpleted. The items for which environmental qualification were not yet cod meth minutes of th'e December 7,1983 meeting and propose i
are documented in
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for each of the environmental qualification deficienc esresponses fro February 22, and March 15, 1985 the December 21, 1984, k performed on licensee.
Based on the results of an NRC audit at Oyster Cree licensee had February 5 and 6, 1985, the NRC staff concluded that the items in their EQ demonstrated environmental qualification of equipmentd during this i
program to the extent that the sample files rev eweAn SER f 28, 1985 addressing (1) the Safety was submitted to the licensee on May were adequate.
important to safety 's environmental qualification of electric equipmentfo (2) the licensee proposed resolutions for the deficiencies ident i
for 1982 SER and July 9,1982 FRC TER; and (3) the justificat ons continued safe operation (JCO's) for Oyster Creek un
qualification was complete.
ified deficiencies The above identified deficiencies in the SER/TER, ident 21, 1984, February 22 and documented in the licensee responses.(December e reviewed by the and the SER for final EQ resolution, werinspection.
March'15,1985), inspection team members and used as the ba Findinos:
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E0 Program Compliance with 10 CFR 50.49 tablishing A.
The NRC inspectors examined the licensee's program for es e of 10 CFR the qualification of electric equipment within the
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50.49.
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qualification documentation files, review of procedures d
y controlling the licensee's EQ efforts, and verification of a equac lified and accuracy of the licensee's program for maintaining the cua status of the covered electrical equipment.
il Based on the inspection findings, which are discussed in more below, the inspection team determined that the licensee has
implemented a program to meet the requirements of 10 CF Oyster Creek Nuclear Generating Station although some de were identified.
EQ Program Procedures B.
t The inspectors examined the implementation and adequa~cy of c and site policies and procedures for establishing and maintainin liance the environmental qualification of electrical equipment in compThe l with the requirements of 10 CFR 50.49.
f establishing and maintaining the environmental qualification o electric equipment were reviewed in the following documents:
GPU Nuclear Corporate Policy and Procedure Manual
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i Environmental Revision 0-00, May 31, 1985, 1000-POL-7317.01, Qualification of Equipment.
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Revision 1, OC QA Plan, Audit (Section g).
1000-PLN-7200.01,
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Revision 0, Responso to GPUN QA Audit.
1000-ADM-7218.01,
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GPU Nuclear Technical Functions Division Revision 0-01, June 14, 1985, Equipment 5000-ADM-7317.01, Environmental Qualification.
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5000-ADM-7311.03, Revision 1-01, February 21, 1986, Project
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Reviews.
5000-ADM-7313.01, Revision 1-01, August 13, 1985, Modifi and System Design Descriptions.
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5000-ADM-6230.01, Revision 1, November 15, 1984, Purchase Requisitions (TAB-011).
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Vendor
- 5000-ADM-7315.02(EP-003), Revision 4, June 16,1983,
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Document Review.
GPU Nuclear Quality Assurance Department Procedure Manua
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Revision 8, Quality Assurance Audit Program.
6100-QAP-7218.01, Revision 6, Indoctrination Training and 6130-QAP-7202.01, Certification of QA MOD /0PS Personnel.
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GPU Nuclear Oyster Creek Nuclear Generating Station Procedures
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105.3, Revision 2, March 9,1986, Maintenance of Oyster CreekEnvironmentalQualified(EQ) Equipment.
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125.2, Revision 2, Conduct of Spare Parts Engineering
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Other Procedures and Documents 0-0C-84-04, January 8,1985, Audit Report, Environmental
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Qualification of Electrical Equipment.
0-0C-85-08, January 27, 1986, Audit Report, Enyjronmental
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Qualification.
0-COM-85-04, February 22, 1986, GPUN Audit Report, Corrective
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Action.
0-COM-85-05, September 30, 1985, CMAP Audit Report.
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QAES Procedure Familiarity Training Schedule, March 28, 1985.
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Oyster Creek Audit Schedules, 1985/1986.
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ES-006, Revision 0, Equipment Procurement.
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- 700.2.028, Maintenance of Motors for Limitorque Operators, Revision 0, January 5, 1986.
Installation of Raychem Splices, Revision 1, August 25, 732.2.009,
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700.2.010, Motor Operated Valve Removal, Installation, or Inspec-
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tion, Revision 7, March 24,1986.
The inspection team was also given a presentation describing the licensee's EQ program on March 24, 1986, during which requirements and procedures in the above documents were discussed.
The inspectors reviewed the above licensee procedures for implementation of the requirements of 10 CFR 50.49 including:
definitions of harsh and mild. environments, equipment qualified
. life, service conditions, periodic testing, maintenance and The licensee's EQ program was also reviewed for surveillance.
(1) requirements to establish, evaluate and maintain auditable EQ documentation including System Component Evaluation Worksheets (SCEW), and supplemental SCEW sheets, test reports, maintenance records addressing IE bulletins, and other supporting documentation to justify equipment qualification; (2) training)of personnel in the environmental qualification of equipment; (3 control of plant modifications such as installation of new and replacement equipment;
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(4) provisions for purchasing replacement equipment to 10 CFR 50.49
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criteria; (5) maintenance and surveillance of EQ equipment; and
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(6) QA/QC audit records involving EQ activities. The following
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observations were made:
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(1) SCEW Sheets
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The licensee's program for maintenance of Oyst'er Creek environ-mentally qualified equipment is described in their station procedure 105.3, Revision 2.
The inspection team reviewed this procedure against t'he' supplemental SCEW sheets of some specific types of EQ equipment and noticed
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conflicting information between the procedure and supplemental SCEW sheet information.
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Paragraph 7.2.7 of Procedure 105.3 requires the cable terminations be checked for surface corrosion which may be caused by conden-
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sation, contact with water or other fluids. However, the supple-mental SCEW sheet for EQ terminal blocks and cable terminals (EQ files 0C-389, OC-374, OC-350) were left blank. Since the Technical Function Group sets up their maintenance schedule for a specific equipment type based on supplemental SCEW sheets,disd.
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procedural mechanism exists for this maintenance to be sched This item is considered an Open Item and is required to be closed out during a subsequent NRC inspection (50-219/86-08-08).
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(2) EQ Personnel Training The training requirements for on-site personnel performing EQ maintenance and inspection activities were defined in station procedure 105.3, section 4.6.
The inspection team reviewed the -
following records of onsite EQ personnel training:
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A memo entitled, " Summary Report of Training EQ Site Program -
Oyster Creek" from D. J. Corbett to QA Module 68 file, dated July 22, 1985, indicated that two training sessions entitled
" Environmental Qualification of Electrical Equipment 2 Site Program" were conducted on July 16 and 17, 1985, and were f
attended by 26 personnel, b)
EQ training session' conducted by the Director of Engineering
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Assurance on October 10, 1985 and attended by 26 personnel.
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EQ training session conducted by R. Thomas on January 11,'1985, and attended by 21 personnel.
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Two training sessions on station EQ maintenance procedure 105.3 conducted on September 9 & 18, 1985, and attended by '
11 and 5 personnel respectively.
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However, The training of corporate EQ personnel was not extensive.
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three key personnel received EQ ~ training from Wyle Laboratories,
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Also the records Technical Seminars Inc., and RAM-Q Institute.
reviewed by the inspection team showed that two GPUN managers and five EQ engineers completed reading assignments on applicable EQ procedures.
Based on the review of the available training records, the inspec-tion team concluded that site and corporate EQ personnel received adequate training.
(3) Control of Plant Modifications The NRC inspection team reviewed procedure 5000-ADM-7317.01, para-graph 5.9, which is used by GPUN for implementation of EQ require-ments related to plant modifications. Accordingly, the cognizant
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engineer establishes and defines equipment environment qualifica-tion parameters relative to its location in the plant as indicated The engineer verifies that the EQ requirements on the SCEW sheets.
are incorporated in the purchase requisition, and the equipment is installed and documented in accordance with the applicable procedure. Changes or modifications are adequately reviewed and interfaces verified prior to installation. Qualification data are reviewed by the EQ section prior to system turnover for
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opera tion.
The NRC inspection team concluded that the GPU procedures contained sufficient detail to establish adequate control of plant modiff-cations, and based on the team's sample of two EQ files which required station modifications, the procedure is being adequately implemented.
(4)
Purchasing EQ Equipment / Replacement Equipment GPUN's Administrative Division is responsible for initiating and implementing the program for procurement of EQ spare parts and for maintaining an appropriate stock inventory for replacement Revision 0.
parts, in accordance with procedure 5000-ADM-7317.01, The Administrative Division is also responsible for providing adequate storage and retrievability of EQ spare parts, including The Administrative Division shelf-life sensitive components.
implements this program to preclude the inadvertent issuance of non-qualified equipment in an application requiring qualified
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components.
The NRC inspection team reviewed five GPUN procedures and standards,
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three purchase order requisitions, and discussed with the GPUN QA Engineering and System Manager the procuremer.t practices of Review of GPUN procedures EQ related equipment and components.
and standards showed that EQ requirements were properly addressed in procurement documents.
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The NRC inspection team concluded that procedures regarding EQ
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procurement activities were beirig adequately implemented.
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EQ Maintenance Program The licensee's implementation program for maintenance activities is described in station procedure 105.3, Revision 2.
The yequired maintenance for each equipment type is defined in supplemental SCEW sheets for EQ equipment. The Technical Functions Group is responsible for incorporating all maintenance items into a schedule and initiating the maintenance activities by issuing the " Maintenance and Construction Short Form" (describing what needs to be done and by whom).
This short form is transmitted to the Maintenance Construction and Facilities (MCF) planning group for activity planning and th6n forwarded to MCF production group who perform the required maintenance activities.
When the activities are' completed, the short form is returned to the
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Technical Function grnup for record keeping.
The Technical Function group has developed a computer program to help monitor and track all related maintenance activities and to avoid maintenance overdue problems. The NRC inspection team reviewed part of this computer tracking system. For each maintenance activity, the computer program identifies the (1) discipline responsible for. the maintenance; (2) the applicable procedure number; (3) the preventive maintenance number; (4) description of the activity; and (5) completion date, frequency of the maintenance, next due date, including estimated manhours.
The licensee had developed a maintenance procedure for each type of maintenance activity. The inspection team reviewed three randomly selected maintenance procedures.
The NRC inspection team concluded that the GPU procedures contain sufficient detail to establish adequate maintenance and replacement activities.
For procedure deficiencies regarding implemertt. tion of EQ maintenance and surveillance, see paragraph 4.B.(1) above.
D.
SER/TER, SER, and Licensee Response Commitments The NRC inspection team evaluated the implementation of EQ corrective action commitments made as a result of (1) the identified deficiencies in the November 30, 1982, SER and July 9, 1982, FRC TER; (2) proposed method of resolution for each'of the EQ deficiencies documented in
- responses from the licensee (December 21, 1984, February 22, and March 15,1985) as a result of the NRC staff meeting with the licensee on December 7,1983 for which the ebove SER/TER was prepared; and (3)
the SER for Final Resolution of Equipment Important to Safety issued on May 28, 1985. The majority of deficiencies identified above in-volved deficiencies in EQ file documentation pertaining to similarity, aging, qualified life, and replacement schedules. The approach used by the licensee in resolution of the above deficiencies resulted in
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additional analyses and type test qualification documentation placed
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in the EQ documentation files, including evidence of numerous examples of replacement, replacement / relocation, partial replacement and re-location of equipment. Also the licensee shielded numerous components (e.g., 4160 motor control centers) from harsh env.f ronment conditions inow classified as mild environment) and removed them from the 10 CFR
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50.49 Master List. The licensee's EQ corrective action commitments provided in December 21, 1984, February 22, and March 15,1985 submittals to the NRC, and again reiterated in the SER for final resolution, identified the results of the licensee's efforts to re-examine, up-grade, add, and de'ete JC0's in effect at that time. The numerous JC0 deletions which were indicated at that time were a result of the licensee's replacement equipment programs prior to the 10 CFR 50.49 (g) extension deadline date of November 30, 1985.- The licensee had in effect programs to replace, replace / relocate, partially replace, relocate, test, and perform additional analys s on equipment, earlier
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identified in JCO's.
This program was accomplished during a four week outage in mid October, 1985.
i Based on review of files and of the 10 CFR 50.49 Electrical Equipment Environmental Qualification Master List (EEMQL), the NRC inspection teams identified no deficiencies in the implementation of SER/TER, SER, and licensee response coninitments. Ongoing review of the licensee's post accident monitoring (PAM) program (RG 1.97) imple-mentation may result in additional equipment being added to the EEMQL.
E.
10 CFR 50.49 Electrical Eauipment Environmental Qualification Master List The NRC inspection team reviewed the Oyster Creek EEMQL, Revision 2, February 5, 1986, and associated documents, to verify the adequacy of the implementation of GPUN's master list development and maintenance methods as accepted in the SER for Final Resolution of Equipment Impor-tant to Safety issued on May 28, 1985.
In addition to the EEMQL and SER, the following documents were reviewed by the NRC inspection team:
(1) Technical Functions Division Procedure 5000-ADM-7317.01 (EP-031)
Revision 0-01, Equipment Environmental Qualification, June 14, 1985.
(2) GPUN-EQ-86-657 Oyster Creek EQ Master List Deletion Justifications, March 13, 1986.
(3) Oyster Creek Nuclear Generating Station (OCNGS) Emergency Opera-ting Procedure (E0P) EMG-3200.01, sections as follows:
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RPV Control, RC/L level control, Revision 1, January 31, 1986.
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RPV Control, RC/P Pressure Control, Revision 1, January 31,
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RPV Control, RC/ Power Control, Revision 1, January 31, 1986.
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(4) OCNGS E0P No. EMG SMG 3200.02, Containment Control, sections as
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Containment Control, January 31, 1986.
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DW/T Drywell Temperature c.
Primary Containment Pressure
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Torus Level (5) OCNGS E0P No. EMG-3200.03, Level Restoration, RPV, September 30, 1984.
(6) OCNGS E0P No. EMG-3200.04, Emergency RPV Depressurization, September 30, 1984.
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(7) OCNGS E0P No. EMG-3200.05, Steam Cooling, September 30, 1984.
(8) OCNGS E0P No. EMG-3200.06, Spray Cooling, September 30, 1984.
(9) OCNGS E0P No. EMG-3200.07, Alternate Shutdown Cooling, September 30, 1984.
(10) OCNGS E0P No. EMG-3200.07, RPV Flooding, September 30, 1984.
The 10 CFR 50.49 EEMQL review consisted of E0P reviews to determine what equipment is required to support and carry out these E0P's and associated safety functions.
56 components were selected from equip-ment identified in the E0P's, and verified against the EEMQL. All were found on the EEMQL.
In addition, the EQ file documentation pertaining to individual dele-tions from the EEMQL were reviewed with no unjustified removals iden-tified.
Post accident monitoring equipment is yet to be added to the EEMQL after NRC approval of GPUN's PAM (Regulatory Guide 1.97) program.
Some PAM equipment has already been added to the EEMQL.
Based on this review, the 10 CFR 50.49 EEMQL is considered satisfactory.
F.
Environmental Qualification Documentation Files The licensee's EQ documentation files are established within the
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corporate office engineering data and configuration control system (ED & CC) with duplicate files maintained at the Oyster Creek Nuclear Generating Station, as defined by the requirements of their administrative procedure 5000-ADM-7206.01. These files consist of component qualification files,10 CFR 50.49 Master List, SCEW sheets, supplement SCEW's, accident profiles, EQ test reports, test report
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index (EQTRI), regulatory and general correspondence, and documentation
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of Class IE items determined to be outside the scope of the EQ program.
The 10 CFR 50.49 Master List and SCEW's are released to operation and -
maintenance departments in accordance with their administrative procedure 5000-ADM-1215.02. These releases occur. prior to turnover of a modification to the plant in accordance with their administrative
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procedure 5000-ADM-7311.04. A checklist is used and maintained to evaluate qualification requirements of components coveted. by each file. A component file is defined as a specific type of electrical equipment, designated by manufacturer and model, and is representative of all identified equipment in a plant area exposed to the same envi-ronmental service conditions.
The NRC inspectors examined files for 26 selected equipment items (EQ documentation packages) to verify the qualified status of equipment within the scope of 10 CFR 50.49.
In. addition to comparing plant
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service conditions with qualification test condit' ions and verifying i
the bases for these conditions, the inspectors selectively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified, I
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similarity of tested equipment to that installed in the plant (e.g.,
insulation class, materials of components of the equipment, tested configuration compared to installed configuration, and documentation of both), evaluation of adequacy of test conditions, aging calculations for qualified life and replacement interval determination, effects of decreases in insulation resistance on equipment performance, adequacy of demonstrated accuracy, evaluation of test anomalies, and applica-bility of EQ problems reported in NRC IE Information Notices /Eulletins and their resolution.
During its review of the component files the inspection team identified
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five Potential Enforcement / Unresolved Items and four Open Items, described below.
(1)
File OC-333, Limitorque Motor Operator Model Number SBD-0, Tao Number V-16-1
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l This valve operator is located in the drywell and used as a system cleanup isolation valve. GPUN considers this valve to be quali-fied to the requirements of NUREG-0588, Category I, as evidenced
by SCEW sheet 0C-243-039. The qualification test reports utilized to demonstrate qualification are Limitorque reports 600376A and B0058.
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It could not be established from the files whether the grease l
rr 'ief valve that was present on the test specimen in Limitorque report 600376A was actually installed on this operator.
In addition, there was no information in the file concerning the installation of the grease relief valve on in-contair. ment Limi-
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torque valve operators V-16-1, V-5-166, V-17-19, V-14-36, and i
V-14-37.
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GPUN provided an analysis claiming that "T" drains were not
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required _ to be installed on the above operators. However, this analysis depended on test data that was derived from an unplanned -
occurrence during the test described in Limitorque report 600376A.
This data and the supporting analysis were not. considered suffi-cient to obviate the need for installation of "T" drains as re-quired by written communications from Limitorque,orporation.
C The NRC inspection team determined that the lack of similarity between the tested and installed motor operator configuration regarding the installation of "T" drains, and grease relief valves are considered a Potential Enforcement / Unresolved Item 50-219/
86-08-01.
(2) File OC-334, Limitorque Motor Operator Model Number SMB-1, Tag Number V-20-40
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This valve operator, which is located in the reactor building at elevation 58 ft.,10 in., is used as a discharge isolation
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valve for one cf the four core spray pumps.
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GPUN considers this valve motor operator to be qualified to the D0R guidelines, as shown on SCEW No. OC-212-053. The qualification test reports used to establish qualification are limitorque report B0003 (dated 6/76) and B0058 (dated 11/80) with an additional similarity analysis.
The similarity between the tested valve operator and the a.
installed valve operator was not completely established by a certification from Limitorque or on site inspection.
The certification does not positively identify internal wiring, and GPUN did not adequately demonstrate by analysis qualification of "TW" wiring which was believed to be installed.
"TW" wire cannot be identified as to manufacturer. This creates qualification uncertainty, because different manu-facturing processes (e.g., vulcanizing temperatures, extru-sion methods, insulation thickness) and quality control i
standards are used. The analysis did not adequately address these uncertainties.
f The analysis affects the following valves:
V-1-110, V-1-111, V-16-61, V-20-3, V-20-4, V-20-15, V-20-21, V-20-32, V-20-33, l
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V-20-40, V-21-1, V-21-3, V-21-5, V-21-11, V-21-13, V-21-15,
l V-21-17, and V-21-18.
b.
Additionally, the qualification files did not address l
possible modifications to the motor operator wiring by valve manufacturers or installers. This concern also affects the following valves:
V-1-106, V-1-107, V-1-110, V-1-111, V-16-61,
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V-17-55, V-17-56, V-17-57, V-20-3, V-20-4, V-20-15, V-20-21, V-20-32, V-20-33, V-20-40, V-20-41, V-21-1, V-21-3, V-21-5, V-21-7, V-21-9, V-21-11, V-21-13, V-21-15, V-21-17, and V-21-18.
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No positive identification of all internal wiring was available
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for these operators.
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Failure to demonstrate similarity between the tested and installed operating configuration with respect to internal wiring is con-sidered a Potential Enforcement /Unrc:;olved Item 50-219/86-08-02.
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(3) File 0C351, Namco Limit Switches, Model 01200G used. on Valve V-23-18 The Namco Limit Switch was located in the rsactor building at elevation 75'3".
It was mounted such that the bar moved vertically. Conduit from a junction box entered the switch from above. The junction box has two 1/4" weepholes for moisture drainage.
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These limit switches were required to be qualified in accordance with the D0R guidelines.
No documented evidence in the file demonstrated a steam test was performed to establish qualifica-tion as required by the D0R guidelines. The licensee's position was that 193 F and 100% relative humidity (the worst case exposure of any of the limit switches) did not constitute steam service, and therefore a steam test was not required. The qual-ification period af ter the DBE required the switch to be operable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The NRC inspection team determined that based on (1) the lack of test data available in the documentation file, and (2) lack of analysis to justify switch performance in 100%
humidity and elevated temperature environment, qualification had not been adequately established in accordance with the DOR guidelines. This inadequacy of the EQ documentation file is
^
considered a Potential Enforcement / Unresolved Item 50-219/86-08-03.
(4)
File OC-319, Namco Limit Switches, Model EA740 used on Valve V-27-4 This limit switch was mounted about 30" off horizontal. The attached conduit had a Patel conduit seal, but the seal was not required by the documentation file. The manufacturers date and bill of materials revision code was observed to be 1185P (manu-factured the lith week of 1985 to bill of materials revision level P). These limit switches are to be qualified in accordance with 10 CFR 50.49, NUREG-0588, Revision 1, Category I requirements.
The test profile enveloped plant conditions. The file did not address the differences in model numbers between installed and
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test components, but the catalog showed that the only difference is mounting configuration. The model tested was chosen based o.. seismic considerations. The test report by Namco, contained in the file, showed qualification to a bill of materials revision level N, however, the documentation file did not indicate to what revision level the installed switches were manufactured.
Observation on the plant walkdown by the NRC inspection team indicated that the installed switches were manu-
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factured to revision level P.
The licensee's contact with Namco
disclosed that the only change between revision N and P were
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minor changes in a mechanical part which apparently did not affect qualification of the hardware. The switches were procured as Class 1E components along with the documented report which establishes qualification.
Namco apparently never communicated to the licensee that there had been any manufacturing changes
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made.
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The qualification report contained in the file, supplied by Namco, indicated that it was the user's responsibility to ensure that the switch internals were protected from the harsh environment. The EQ file did not require the use of moisture seals. GPU's position was that all limit switches which were not required to be sealed were installed with conduits exiting from below the switch such that any condensed moisture would
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drain from the switch. No test data was contained in the docu-mentation file to support the switch survivability when the internals were exposed to harsh environment.
Failure to evaluate the bill of material change which could have affected qualification and failure to adequately demonstrate equipment operability with the switch internals exposed to harsh environment are considered Potential Enforcement / Unresolved Item 50-219/86-08-04.
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(5)
File OC-312, Rockbestos Firewall III and Firewall SIS Cable; File OC-388, PVC Splice Tape; File OC-326, GE Type EB Terminal Blocks Rockbestos Firewall III and SIS cable was qualified in accordance with 10 CFR 50.49, NUREG-0588, Category I.
The test specimens were identical t'a the installed cable (760-D insulation) and the test profile enveloped the plant profile.
Credit was taken by the licensee for beta radiation shielding by the neoprene jacket.
Type testing results conducted by Rockbestos documented that the neoprene jacket of this type cable had been degraded severely after the Rockbestos type tests. The licensee indicated that all this type cable was installed in conduit. This fact is not addressed in the documen.tation file.
Functional performance criteria for this cable was addressed
as "not applicable" in the documentation file. This cable is used in power, control, and instrumentation applications, but the EQ file documentation did not adequately demonstrate qual-ification because of failure to show that the cable functional performance requirements were satisfied. No analyses were found which address how measured parameters taken during type test (e.g., irs, severe degrading of neoprene jacket in the Rockbestos type tests) would affect plant circuits.
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The EQ documentation file for PVC splice tape did not show that
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the equipment functional performance requirements were satisfied in accordance with the D0R guidelines.
No functional performance criteria were addressed in the documentation file. No analyses were found which address how measured parameters taken during
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type test (IR reading as an example) would affect the application
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of PVC splice tape in the plant.
GE terminal blocks, type EB, are qualified to the D0R guidelines.
Type test data in the documentatign file demonstrated terminal block IR drops as low as 1.9 x 10 ohms during the LOCA simula-
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tion. The file analysis had a discussion of low irs in the performance criteria section. However, in addressing the effect of the low terminal block irs on instrumentation circuits, the
calculations performed were incorrect. This error was corrected by the end of the inspection.
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The failure to address functional performance requirements in documentation files 0C-312, OC-388, and 0C-326 are considered a Potential Enforcement / Unresolved Item 50-219/86-08-05.
(6) File 0C-350, Thomas & Betts Wire Terminals, Model STA-CON, Tefzel
The inspection team reviewed the documentation file of Thomas &
Betts wire terminals, model STA-CON Tefzel, to ascertain whether the file contained sufficient evidence that these terminals were
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qualified for the environmental conditions in which they must operate.
The licensee's intent is to qua,lify these wire terminals gener-ically including those located inside the drywell. Thomas &
Betts qualification test report QPS-TB(CH)-878 as modified by
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Impell calculation 0370-089-051 requires qualification for a post DBA operating time of 48 days. However, Impell report 02-0370-1293 Table 1 requires this operating time to be greater than 48 days. No documents were available for the inspection
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team's review showing that the qualified operating time matches
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the required operating time.
This item is considered an Open Item to be closed out in a l
subsequentNRCinspection(50-219/86-08-07).
(7)
File OC-389, Stanwick Terminal Blocks Type SLS During Region I inspection of the Oyster Creek plant in December, l
1985 (Inspection Report 50-219/85-39) a violation was identified pertaining to the qualification of Stanwick terminal blocks.
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The inspection team followed up on the licensees corrective action by reviewing the documentation file of Stanwick terminal blocks, type SLS to ascertain whether the file contained sufficient
evidence that these terminal blocks were qualified for the
i environmental conditions in which they must operate.
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The four terminal blocks are used in a control circuit for
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pressure switches RE-23A, B, C,- D and are located in Room X on the north wall, at elevaticn 7'6" in the turbine building.
The inspection team physically inspected the i.nstalled condition of these terminal blocks. Each of them was mounted vertically in a wall box about 4" wide, 6" high and 3" deep. A weep hole was provided at the bottom of the wall box which was. mounted on the wall adjacent to the pressure switch (RE-23A, B, C, D). Each wall box and the associated pressure switch were enclosed in a large locked cage.
Within scope of this file review and physical inspection, no unacceptable conditions were identified.
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(8) EQ Documentation File Observations
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Several examples were identified by the NRC inspection team where the EQ documentation files contained errors, incorrect calcula-tions, incomplete documentation, missing references and incorrect SCEW sheet changes.
OC-374, States Company Terminal Blocks, Type NT and ZWM a.
GPUN has installed States Company terminal blocks, type ZWM, in the MCC 1AB2, located in the reactor building room 28, elevation 23'-6".
These terminal blocks were purchased for their intended use prior to the February 22, 1983 effective date of 10 CFR 50.49 and were qualified by test-ing a similar item in accordance with the 00R Guidelines.
The States Company terminal blocks type NT were tested for the most severe accident and normal environmental service conditions inside containment. The test specimens were exposed to a LOCA condition of 340 F,117.7 psia, and 100%
relative humidity. The thermal aging analysis of the terminal block material is based on Underwriter Laboratory (UL) published data. Similarily analysis for radiation exposure is based on EPRI Report NP 1558 relative to the material of construction. These analyses supported the environmental qualification of the terminal block for 40 years r.ormal operation at 90 C plus six months posg-accident environment with a total integrated dose of 2 x 10 rads.
The NRC inspection team determined that the States terminal blocks are environmentally qualified to perform their intended
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function during 40 years normal plus 30 days postulated accident conditions. However, the NRC inspection team raised the following concerns regarding the qualification documen-tation:
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1.
GPUN qualified the installed States Company terminal
blocks type ZWM based on similarity to the tested.
type NT. The qualification file did not conclusively address the similarity of the material of construction and physical configuration of these two terminal block types. Additional documentation is required to be added to the EQ file to link qualificatjon by similarity.
2.
The lowest insulation resistance (IR) of the States
l Company terminal block NT during4the simulated LOCA test was observed to be 2 4 x 10 ohms, but in the
4 calculation either 2 x 10 ohms or 1.9 x 10 ohms (from GE terminal block test data) was used without any justification. Explanation an'd clarification of these documents are required.
3.
The terminal blocks located in room 28, in the reactor building are subject to an accident condition due to a loss of HVAC. This area is considered harsh with respect to temperature and radiation. Although the terminal blocks have been tested for more severe LOCA conditions, the qualification file and SCEW sheet are not consistent relative to actual design temperature parameters. The SCEW sheets are required to be corrected.
4.
A memorandum from S. Wilson to E. Banna (GPUN EQ Engineer), contained in the file, suggested replacement
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of the States Company terminal blocks type ZWM 25012 by an environmentally qualified type ZWM 25003. During the review of the qualification documentation the inspector could not determine if the terminal block type ZKM 25012 was ever replaced during the last outage. A clarification of this event to permit a clear aualification trail should be added to the EQ file.
5.
The licensee used two different numerical values for activation energy in two different calculations per-taining to the thermal aging of the same material.
Although the results do not affect the qualification l
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status of the terminal blocks, the basis for conser-vatisms is not, documented, and shoud be added to the EQ
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file.
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OC-349, Amp Inc., PIDG Plasti-Grip Wire Terminals Type PIDG Plastic-Grip wire terminals are attached to wire lugs for electrical connections throughout the plant.
Their environmental qualification is documented in accor-dance with the requirements of NUREG-0588, Category I.
The
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qualification similarity analysis provided a justification
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for environmental qualification for 40 years normal opera-
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tion plus 48 days post-accident environment. Review of purchase orders did not support the material traceability.
During the NRC inspection, GDU generated a DCN to initiate
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corrective action to update the qualification file.
OC-377 HyCal Thermocouple Plant ID TE-59-28,IModel No.
c.
TC-2436X-A-T-36 X5 This component is used for the temperature density compen-sation of one of two reactor fuel zone level indication reference legs. GPUN purchase order No. 16748, dated May 21, 1979, called for 16AWG thermocouples contrary to the docu-mentation in the EQ file, (drawing no. A-8077) which certi-fied 20 AWG. Also, in note 4 of the GPUN 00R Guideline
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Checklist, contained in the file, a documentation error showed the upper temperature range limit for the thermo-
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couple as 700 F.
Review of the component specifications indicated that this value is required to be 500 F for 20
<
AWG thermocouples. During the inspection, GPUN initiated DCN's to correct these EQ file deficiencies. The above observations appear to have generic implication that
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possibly further documentation deficiencies similar in nature could exist in the EQ documentation files. Although these documentation deficiencies are only minor, the licensee should take corrective action to remove these types i
of errors from his files.
The above items 4.F(8)a thru 4.F(8)c above are considered an Open Item to be closed out in a subsequent NRC inspection (50-219/86-08-08).
G.
IE Information Notices and Bulletins The NRC inspection team reviewed and evaluated the licensee's activities related to the review of EQ-related IE Information Notices /
Bulletins. The NRC inspection team's review included examination of GPU's procedures and EQ documentation files relative to 12 Information Notices and one Bulletin. The procedures review determined that the
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licensee does have a system for distributing, reviewing, and evaluating Information Notices / Bulletins relative' to equipment within the scope of 10 CFR 50.49 (refer to paragraph 4.B). The requirements of these activities are defined Section 5.14.1 of procedure 5000-ADM-7317.01.
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GPUN had developed administrative procedure 1000-ADM-1216-03 " Regulatory Correspondence Control" revision 1-00 dated December 20, 1985 to control the inclusion of applicable IE Bulletins and Information Notices into the appropriate EQ packages. The GPUN licensing group is responsible for implementation of this activity. A file had been set up which contains EQ related NRC IE Bulletins and Information Notices.
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The inspection team concluded that t.he licensee has an adequate program
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to ensure the incorporation of EQ related NRC IE Information Notices and Bulletins into their EQ packages. No concerns were ider.tified during this review except as described in section 4.F(2) of this report
H.
Plant Physical Inspection
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The NRC inspection team walked down and physically inspected approx-imately 19 components at the Oyster Creek Nuclear Generating Station.
The inspection team examined attributes and characteristics such as mounting configurations, orientation, interfaces, model numbers, ambient environment, and physical condition. Conserns noted during the walkdown inspection are addressed in sections 4.F(3), 4.F(4), and 4.F(7) of this report.
It should be noted that Oyster Creek Nuclear Generating Station was operating during the NRC inspection, and there-
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fore some equipment could not be throughly inspected, as this equipment could not be tagged out of operation (e.g., Limitorque motor operators V-16-1 and V-20-40 where limit switch housing covers were not removed).
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