IR 05000259/1990022
| ML20138F858 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/10/1990 |
| From: | Hubbard G, Mccracken C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138F832 | List: |
| References | |
| 50-259-90-22, 50-260-90-22, 50-296-90-22, NUDOCS 9610180087 | |
| Download: ML20138F858 (24) | |
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l UNITED STATES NUCLEAR REGULATORY CCMMISSION
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0FFICE OF NUCLEAR REACTOR REGULATION O! VISION OF SYSTEMS TECHNOLOGY Report Nos.:
50-259, 260, and 296/90-22 Docket Hos.:
DPR-33, DPR-52, and DPR-68 Licensee:
Tennessee Valley Authority 6N 3BA Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Inspection Conducted:
June 25-29, 1990 l)l/fffh Inspectors P ft 44'
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S. T.Atubbard, Inspection Team Leader Date R. C. Wilson, Senior Reactor Engineer M. Merriweather, Reactor Inspector Consultants:
S. Carfagno, K. Iepson, M. Jacobus, and W. Carpenter Approved by:
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C. E. McCracken, Chief Date Plant System Branch
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INSPECTION REPORT NOS. 50-259. 260, 296/90-22
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INSPECTION SUMMARY
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i inspection Conducted:
June 25-29, 1990
Areas Inspectue:
Announced followup inspection to complete the review of the Browns Ferry Nuclear Plant's (BFN) implementation of a program per the requirements of
3 10 CFR 50.49 for establishing and maintaining the qualification of electric
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equipment within the scope of 10 CFR 50.49.
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Results:
The inspection determined that BFN has implemented a program to meet the
requirements of 10 CFR 50.49.
the inspection items remaining open from the May 9-13 Based on the inspect 1988 Environmental
Qualification (EQ) Inspection (Inspection Report (IR),50-259, 260, 296/88-11, dated September 1,1988) were closed.
Violation 50-259, 260, 296/89-16-03
(Violation C) and Inspection Followup Item 50-259,260,296/89-16-11 from IR 50-259,260,296/89-16, dateo March 9,1990, were also closed. While no deficiencies were identified during the inspection, BFN still needs to complete the EQ Program and certify to the NRC that the BFN 10 CFR 50.49 List is complete'and all electrical equipment within the scope of 10 CFR 50.49 is qualified to the
requirements of 10 CFR 50.49.
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1.0 Persons Contacted i
1.1 Tennessee Valley Authority i
0.J. Zerinque Site Director i
- J.D. Jackson, Senior Nuclear Specialist
- J.C. DeLockery, Environmental Qualification (EQ) Engineering Design i
Program Manager
- R.E. Young, EQ Project Manager
- M.E. Herre11. Plant Operations Manager J. Carlin, Unit Operations Manager
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C.M. Crane, Work Control Superintendent C. Lawrence, Modifications Engineering Manager l
- J. Schlessel, Preventive Maintenance Supervisor
M. Bajestant, Plant S
- B. McKinney, Manager,ystem Engineering Supervisor i
Technical Support i
C. Beasley, Communication Specialist
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C.T. Dexter, Site Training Manager
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A. Sorrell, Maintenance Mar.ager
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- R. Martin, Project Manager i
R.C. Parker, Manager, Quality Program, TVA
- D. Arp, Engineering Specialist
- C.A. Galuska, Engineering Specialist
- K. Greene, Santor Engineering Specialist
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- F. Tanner, Senior Engineering Specialist
- E.M. Ridge 11, Licensing Engineering
- J.R. Pittman, EQ Coordinator
- D.M. Dharia, EQ Qualty Assurance Representative
- J. Hutson, Project Engineer
- M.C. Kazanas, Vice President Nuclear Assurance and Service
- R.F. Adkinson, Instrument Engineer i
- J.W. Sanders, Electrical Engineer
- H.E. Crisler, Project Management Manager i
- D.P. Burrell, EQ Electrical Engineering Specialist
- L.W. Jones, Manager, Special Projects and Support, Unit 2
- V.D. Schiavone Nuclear Engineer
- K.M. Galloway,, Engineering Aide
- D.D. Horn, Mechanical Engineer
- B. Goodman, Associtate Engineer R. Springer, Maintenance Training Coordinator G. Campbell, Project Engineer K. Turnbull, Nuclear Engineer B. King, Electrical Planner B. Tompkins, Electrical Planner R. Goodwin, Acting General Foreman L. Miles, Instrument and Control Planner T. Scott, Maintenance Procedures Supervisor -
R. Brehm, Electrical Engineer
- P. Salas, Compliance Licensing Supervisor
- L.W. Myers, Plant Manager
- W.A. Clothier, Jr., Engineer
- R.P. Hyde, Principal Engineer Electrical D.R. Hicks, Manager, Materials and Procurement D.M. Coston, Manager Quality Engineering
- F.H. Walsh, Manager,, Procurement Engineering Group
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J.E. Ownby, Design Control Manager
D.L. Miller, Quality Tracking and Improvements Supervisor J.M. Coret, Radcom Manager W.C. Thomison, Technical Support
- J.T. Barnes, Audit Manager J.E. Swincell, Unit 3 Restart Operations Manager
G.G. Turner, Site Quality Manager
- R. Smith, Project Engineer
- K. Brown, Senior Electrical Engineer
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- L. Clardy, Quality Assurance Supervisor
- S. Moody, Instrumentation and Control Technician
- J. Birch, Maintenance Engineer i
- W.D. Tate, Electrical Engineer
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- T.J. Howard, Electrical Engineer i
- A.W. Thibodeaux, Jr., Mechanical Engineer
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- R.C. Betsch, Jr., Mechanical Engineer i
- D.J. Helms, Electrical Engineer i
- R.H. Albright, Radiation Health Manager i
- L.B. Durham, Manager Nuclear Training
- L. A. Walker, Engineer
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- B.H. Endsley, Engineer i
W.H. Deen, Mechanical Engineer R. Golub, Systems Engineer
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H. McCall, Electrical Engineer R. Widick, Lead Mechanical Engineer (Valve Group)
J. Clothier, Special Projects (Procurement)
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D. Freye, Lead Electrical Procurement Engineer
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D. Kolecki, Lead Mechanical Procurement Engineer l
1.2 Consultants
- M. A. Mittelmier, Ebasco
- D. Stinson, Digital Engineering i
J. M. Strohm, Betchel R. D. Sass, Betchel
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1.3 NRC
- E. F. Christnot, Resident Inspector
- K. Ivey, Resident Inspector
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- C. Patterson, Senior Resident Inspector
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- Attended exit meeting i
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2.0 PURPOSE
The purpose of this inspection was to perform a follow-up review and evaluation of the Tennessee Valley Authority's (TVA) implementation of a program to meet the requirements of 10 CFR 50.49 for Browns Ferry Nuclear Plant (BFN), Units
2, and 3.
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3.0 BACKGROUND On August 21-22, 1985 TVA shutdown both units at Sequoyah Nuclear Plant (Note:
All 3 units at BFN were shutdown at the time) due to concerns tha at TVA nuclear sites might be inadequate for demonstrating environmental
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qualification of electric equipment within the scope of 10 CFR 50.49.
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that time, TVA initiated an in-depth program to ensure that environmental Since
qualification of electric equipment within the scope of 10 CFR 50.49 is
established at all TVA nuclear sites.
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In order to evaluate the program at BFN, the NRC conducted an inspection of the i
BFil Environmental Qualification (EQ) Program and documented the results in NRC Inspection Report (IR) 50-259,260,296/88-11, dated September 1, 1988. This
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Program and its implementation. inspection was a continuation of the NRC
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This inspection focused on the activities i
completed since the last EQ inspection and included reviews of identified
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inspection findings remaining open from the previous EQ inspection, as well
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as some EQ related inspection findings from IR 50-259, 260, 296/89-16, dated March 9, 1990.
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4.0 FOLLOW-UP OF EQ RELATED FINDINGS OF IR 50-259, 260. 296/89-16
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l 4.1 Violation 50-259, 260. 296/89-16-03 (Violation C) (Closed)
i NRC IR 50-259, 260, 296/89-16, dated March 9,1990 documented three violations of NRC requirements.
Violation C was identified as a Severity Level IV
violation and provided five examples where the licensee failed to implement i
procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, as required in BFN Technical Specification 6.8.1.
The violation was addressed in the licensee's April 9,1990, response to the Notice of
Violation.
The licensee's response admitted each example of the violation and summarized corrective actions.
The inspectors reviewed related documentation and interviewed licensee personnel concerning the violation.
i All five of the violation examples are closed as described in the following paragraphs.
j 4.1.1 Example 1 i
Example 1 involved a valve operator tanninal block and lug which were damaged as a result of changing a wire to a larger size without proper regard for the terminal block manufacturer's termination requirements.
repaired under maintenance request (MR)A914290 and MR1017625.The damage was i
The licensee's evaluation of the incident under condition adverse to quality report (CAQR)
BFP890787 determined that, although the change was electrically acceptable, the I
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of the stiffer replacement wtre and larger terminal lug.insta seven other valve operators as using larger wires on the same type of temina block.
Three of the seven were determined by inspection to have no damage.
The other four were scheduled to be inspected under a preventive maintenance specify inspection for potential damage of this type.The preve program.
I 4.1.2 Example 2 Example 2 identified that splices in junction box JB2140 were improperly mad
or were bent too sharply, wires were bent too sharply, and several cables lacked identifying sarkings. The licensee corrected the deficiencies and inspected ten more randomly selected boxes without finding any additional During the plant walkdown portion of this inspection, the NRC concerns.
inspectors found one splice bent a little more sharply than allowed and and another splice was questioned because the splice was applied over a wire that did not have all of the triplex cable filler material, which was stuck to the wire's primary insulation, removed (see paragraphs 6.2, 6.6.4, and 6.6.10).
A licensee analysis during the inspection determined the splice was acceptable.
These concerns involved splices made during a recent extensive program to replace all environmentally qualified cable splices.
After discussions with the licensee minor and infreque,nt and were not indicative of a splice progra 4.1.3 Example 3 Example 3 involved installation of a non-EQ terminal block in an EQ rolication as a result of personnel errors.
installed; conducted personnel training and briefings on the inst ~~The lice t was EQ parts; and revised the site procedure for material issuance cion of eturn.
4.1.4 Example 4 resulting in a possible moisture path that negated the environ
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qualification of the valve operator for motor operated valve (MOV) 2-FCV-75-25.
The hardware was corrected and a review of five other work plans involving movement or removal of conduits identified no failure to properly specify or perform conduit renoval.
The licensee's organization was changed to provide a single work plan writing group that will provide uniform and more detailed instructions to craft personnel.
4.1.5 Example 5
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Example 5 involved failure to install grounding straps on two flexible conduits for two valves, even though it was required by the work plans.
straps were installed and the involved personnel were counseled.The grounding Other work performed by the s6me personnel was examined and found to be satisfactory.
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4.2 Inspection Follow-up Item 50-259', 260. 296/89-16-11 (Closed)
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This item involved inspection questions concerning whether junction box JB2140 required a cover seal and whether butt splices in the junction box were adequate for EQ applications.
The licensee verified that junction box cover seals are not required for EQ and the cables with butt splices are not required to be environmentally qualified.
splices on the other cables confonn to the applicable procedures.One ca is closed.
This item 5.0 FOLLOW-UP OF FINDINGS OF IR 50-259. 260. 296/88-11 5.1 Inspection Follow-up Item 50-259, 260, 296/88-11-01 (Closed)
l This inspection follow-up item (IFI) addressed the lack of program controls to
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adequately cover EQ requirements for equipment transferred from other licensee plants and identified that contract engineering personnel were not trained in EQ program requirements. At the time of the inspection in May 1988, two different licensee groups could specify procurement requirements for EQ equipment, using procedure NEP-4.1, " Procurement," or
" Environmental Qualification Review of ECN/ Work Plan," as applicable. procedure B NEP-4.1 specified that transferred equipment would be covered by a transfer requisition rather than a procurement specification and purchase requisition.
The licensee resolved the concerns by revising NEP-4.1 so that it became a
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controlling document and replacing PI 87-02 with a new implementing procedure SDSP-16.9, " Technical Evaluation for Procurement of Materials and Services,"
which is supported by procedure BFEP PI 88-16, " Preparation cf Technical Documents for Items Having 10 CFR 50.49 Application." All procurement packages are assembled by the contract engineering group (CEG), irrespective of whether the equipment is obtained by outside procurement or licensee internal transfer, using Form 2652 from the plant or Form 10606 from engineering as input.
The inspectors reviewed the present procurement process for EQ equipment as defined in NEP-4.1, Revision 2, and SDSP 16.9, Revision 4, without identifying any additional findings.
The training concern relative to this IFI was addressed in NRC IR 50-259,260, 296/89-54. During this inspection, the inspectors further reviewed EQ training of CEG personnel.
They determined that CEG personnel have received 45 to 75 minutes of EQ formal overview training, in addition to training in specific procedures and their revisions.
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5.2 _ Inspection Follow-up Item 50-259,260,296/88-11-02(Closed)-_
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This IFI pertained to a concern that the EQ project responsibilities for
i perforving EQ reviews of procurement actions associated with engineering ch notices had not been delineated in procedures.
In response to this concern the licensee issued procedure BFEP PI 88-16 to integrate EQ Project work scope i the procurement area.
P186-03, " Preparation and Control of EngineerinIn addition, the licensee Package," and PI 87-41, " Design Change Notice," g Change Notice Modification
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responsibilities in thote areas.
to assign EQ Project functional i
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The inspectors reviewed these procedures and
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5.3 Inspection Follow-up Item
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50-259,260,296/88-11-03(Closed)
This IFI concerns the failure by the licensee to provide EQ training to certain personnel in both Maintenance and CEG. The inspectors held discussions with licensee personnel and reviewed some training records to
confirm that appropriate personnel in CEG and Maintenance have been trained on
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t the BFN EQ Program. The inspectors noted that the type of training provided
craft personnel in the maintenance section differs from the training described j
In instruction PMI 4.4, " Environmental Qualification Training," Revision 0.
This instruction requires maintenance craftsmen to receive training on EQ
" Environmental Qualification for Maintenance." courses EQP-001, " Int
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The records of recently hired employees with hire in dates prior to June 21, 1990 shows that they received i
training on EQ course EQP 111.01, " Browns Ferry Site Specific EQ Indoctrination."
i The licensee indicated that this training will be provided to certain craftsmen, excluding support craft such as sheetmetal workers, carpenters, laborers, and etc.
The itcensee indicated that these new training requirements will be incorporated in the next revision of PMI 4.4.
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The training program in other areas has also been revised by combining courses
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EQP-001 through EQP-005 into a course EQP-010, " Consolidated EQ Program" which j
is a 45 minute video tape. The intent is to provide this training to
personnel involved in engineering, procurement, modifit.ations, maintenance, operations, and etc.
A recent internal audit of the EQ program by TVA revealed that the training i
program has not always been effectively implemented. The audit discovered
that some number of engineers and other technical personnel involved in
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EQ related activities had not been trained as required by the huclear
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PerformancePlan(MPP).
(NE) confirmed that the training records and procedures may not
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to recent changes in the training program.
However, based on discussions with licensee personnel it appears that current personnel involved in EQ have i
received EQ training through general employee training (GET), procedure review and sign-off, and/or special EQ training.
Those CEG personnel that had
previously been identified as not receiving EQ training have been trained on EQ j
(see paragraph 5.1).
Based on the above, it appears that appropriate personnel in Maintenance and CEG have received some type of EQ training.
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5.4 Inspection Follow-up Item 50-259, 260. 296/88-11-04 (Closed)
This IF1 cited several concerns with the licensee's Master Component Electrica i
List (MCEL) and Component Master List (CML). These concerns were addressed during the inspection as described in the following paragraphs.
Four unverified assumptions for the MCEL Design Basis were identified.
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The NRC inspectors verified that all four assumptions were satisfactorily covered by revision of the Design Basis sections.
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the inspectors that additional revisions will be required when BFN Units 1 and 3 are restarted, since the current MCEL assumes that Units 1 and 3
are shutdown.
The licensee stated that the analysis addressed all cosmon
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and shared equipment, so little impact is anticipated when Units 1 and 3 restart.
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The MCEL Design Basis also identified an apparent error in the Final
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Safety Analysis Report (FSAR) in that the FSAR failed to identify the d
vacuum relief subsystems as " required" to mitigate a high energy line break
outside primary containment.
1989, documented that the subsystem is not required and the FSAR
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i The MCEL was revised to delete reference to the vacuum relief correct.
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subsystem for that accident.
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Another concern was that uncontrolled logic diagrams had been used in generating the MCEL with verification by electrical schematics optional.
These analyses were, repeated where necessary to ensurr that the schemat were used for every component.
One final concern was that in contrast with EQ documentation, the systems requirement calculations (SRCs) of the BFN Baseline Program re operability of certain high pressure coolant injection (HPCI) quired gland seal components. Analyses by both General Electric and the licensee demonstrated that the components in question were not required for EQ The discrepancy was resolved by voiding the SRCs from the purposes.
Baseline Program, which is not otherwise component specific.
5.5 Unresolved Item 50-259. 260. 296/88-11-05 (Closed)
This unresolved ites (URI) pertained to concerns that the inspectors had relative to the lack of leakage current information in the loop error calculations for various auxiliary components, such as terminal blocks, conduit seals, electrical cables, and electrical penetrations.
identified general and specific comments for several equipment qualificationThe i datapackages(EQDPsorbinders).
These conenents focused on two areas of L1) the use of temperature coefficient data when steam / loss-of-coolant concern:
accident (LOCA) test data is available in the specified temperature range for the postulated accidents and (2) the use of the " Root-Sum-Square" (RSS)
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method of combining various errors, in particular, documenting that the errors are both random and independent. The report also encouraged the licensee to binders. review other binders to ensure that the above concerns were ad
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To address the concerns of this URi, the licensee provided Calculation Number ED-Q2999-890038 Revision 1, dated March 26, 1990. The licensee also stated
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that Technical Instruction EEB-TI-28 design guide in perfonning loop error, calculations."Setpoint Calculations," was us
The inspectors reviewed
Revision 1 of the calculation and the latest revision of TI-28, Revision 1, t
dated October 24, 1988. The inspectors discussed several issues relative to i
these documents with the licensee and the licensee committed to revise t calculation.
Following the inspection, the licensee provided additional i
information to the NRC to address issues raised by the inspectors.
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Included in the information was Revision 2 of the calculation, which was reviewed by the i
inspectors.
This additional information provided sufficient infonnation to justify the licensee's positions on the use of temperature coefficient data and i
the RSS method in calculating instrument loop errors.
During telephone discussions following the inspection, the licensee stated that i
they intended to revise TI-EB-28 used in performing loop error calculations
in an effort to eliminate any ambiguity and provide additional clarification
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l and guidance on the specific areas of concern identified during the inspections.
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5.6 Unresolved Itas 50-259. 260. 296/88-11-06 (Closed)
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This URI pertained to EQ deficiencies that were identified during the review of
EQ binders and were discussed in paragraphs 2(a) ttrough 2(1) of the previous EQ inspection report.
the licensee to resolve the deficiencies.This inspection examined those corrective
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results are described in the following paragraphs.The specific actions taken and the
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5.6.1 EQDP-MGN-001 The inspectors had questioned the qualification of the low pressure coolant
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i injection Concerns ra(LPCI) motor generator (MG) sets made by Louis Allis Cor.pany.
ised by the inspectors included: the justification of similarity
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of installed equipment and qualified equipment; failure to discuss equipment failures reported in a BFN 10 CFR 21 Report and a 10 CFR 50.73 Licensing Event a
Report; failure of the cualification maintenance data sheets (QMDSs) to recossnend any periodic W. Mrmance or surveillance activities even though the i
MG sets had a history of maiatenance problems; and f ailure to adequately address j
acceptance criteria.
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i-9-Subsequent to the previous inspection, the licensee reviewed the operating l
mild (EM)environmi.nt(seediscussioninparagraph6.1.1). enviro
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Therefore they deleted from the licensee's 10 CFR 50.49 List.were not required to be The inspectors reviewed the justificattun for deleting the MG sets from the 10 CFR 50.49 List and found it to be acceptable.
5.6.2 EQDP-PENE-001 The inspectors' concern with this binder pertained to the accuracy and of coaxial cable penetrations. measurement techniques used for leakage current m l
from Conax which gave insulation resistance (IR) measurements o
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feedthrough at both 300 volts direct current (Vde) and 500 Vdc curing accident conditions, as well as the irs calculated from leakage current measurements us
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i a 10 ohm resistor.
The directly measured irs were all better than IXE9 ohms while the calculated irs were as low as IXE7 ohms, l
5.6.3 EQDP-MOT-001 i
The previous NRC inspection identified deficiencies in both the QMDS section of the binder and the PM procedure which implements the QMDS requirements.
test data in the binder identified that the qualified lubricant was " Mobil DTE The light oil."
However, the QMDS section of the binder contained words that Mobil DTE or equivalent could be used to lubricate the motor bearings.
In addition, the implementing preventive maintenance procedure EPI-0-000-MOT 002, " Electrical Preventive Instruction Oil Lubricated Motors," Revision 4, specified a lubricant i
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identified as STO-1 which is related to a TVA specification for oil and is not limited to a particular type of oil such as Mobil DTE light.
This issue was discussed with the licensee during the first inspection and they agreed to
include in the binder a similarity analysis for those lubricants that are similar to Mobil DTE light.
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The inspectors reviewed the corrective actions taken by the licensee on this
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issue and found them to be acceptable. The licensee has revised the binder oil"and"ShellTurboT32 oil (STO-1)."and included an analysis to demon Procedure EPI-0-000-MOT 002 was revised to require "Shell Turbo T32" oil be used to lubricate the motors.
This is now consistent with QMDS requirements.
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5.6.4 EQDP-MOT-002 i
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The previous hRC inspection identified a concern regarding the potential for
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mixing grease during the performance of PM.
to the deficiency discussed in item 5.6.3 above.This problem is somewhat similar
The QMDS section of the binder indicated that " Chevron SRI-2 grease or equivalent" be used to lubricate the bearings.
The inspectors' concerns centered around the use of equivalent
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i greases that are not discussed in the binder and the lack of procedural controls to prevent the mixing of grease during PM.
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the qualification of the componcnt.
This could invalidate l
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specify that only Chevron SRl-2 grease be used to lubricate the bearings.
licensee included in the binder a similarity anal The for the new formulation of Chevron SRI-2 grease. ysis to support qualification Additionally, the binder was
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supplemented with vendor guidance on grease lubrication practices and grease j
compatibility (Chevron Technical Bulletin No. 27).
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At the time of the first inspection, the licensee did not have any procedural
controls to prevent the mixing of grease. The inspection report stated on page 12, "the inspectors considered the prevention of grease mixing to be t
more a matter of luck rather than procedural assurance."
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To determine if the licensee had taken adequate steps to prevent mixing of greases, the inspectors selected the residual heat removal (RHR) and core spray t
roce cooler motors to perform a review of EQ maintenance activities.
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The qualification for these components is addressed in binder EQDP-MOT-002.
The QMDS section of the binder requires that the motor bearings be lubricated at 36 j
month intervals with Chevron SRI-2 grease.
The completed maintenance records confirmed that the bearincs had been lubricated with Chevron SRI-2.
i The procedure specified on tne maintenance records was EPI-0-000-MOT 001, " Electrical Preventive Instructicr. for Motor Bearing Lubrication."
The procedure was i
reviewed by the hpector and found to be acceptable. The procedure requires
the use of new or dedicated grease guns to prevent mixing of grease in tools and verification that the proper lubricart is obtained. The procedure also
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requires the craft to verify that the existing grease is Chevron SRI-2 and if
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not it provides instructions for the replacement of the existing grease.
i Based on review of this sample of completed work the inspector considered this
procedure to be adequate.
The inspectors also noted that PM Procedure PMI-12.13, " Lubrication of In Plant Components" provides instructions for storing, obtaining and adding oil and grease to operational components.
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For grease additions, the procedure requires that the instructions of Procedure EPI-0-000-MOT 001, section 7.0 be
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implemented. For oil additions or replacement it specifies that any oil added
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should be the same as that which is described on a permanent label attached
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to the component or should be the same as that specified in procedure
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EPI-0-000-MOT 002 and instruction MMI-141, " Lubrication of Equipment."
Implementation of this procedure was not reviewed, however, the inspectors
considered the above procedures adequate to address the concerns previous i
identified regarding grease equivalency and mixing of grease.
S.6.5 EQDP-IPS-002 The previous inspection identified concerns that the ver. dor maintenance manua required that the ASCO
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are necessary; however, pressure switch be returned to the factory when repairs
this statement was not reflected in the QMDS. Since i
i the inspection, the licensee determined that the pressure switches were not required to be included in the EQ Program.
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The inspectors reviewed the licensee's justification for removing the switches from the program and found
it acceptable.
j 5.6.6 EQDP-IFS-002 i
The inspection had identified a concern relative to the establishment of a 40
year qualified life for Static-0-Rings (SOR) flow switches.
The inspectors identified that the qualified life appeared to be based on only one parameter,
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thermal degradation.
The licensee demonstrated to the inspectors that the j
binder addressed all modes of degradation (i.e., radiation).
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l found the licensee's response acceptable.
The inspectors
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4.
5.6.7 EQDP-1TE-001 The inspection concern with this binder pertained to the fact that there was no functional data in the report of the LOCA test for the Weed resistance j
temperature detectors (RTDs), despite the fact that the test lab stated that
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the data was recorded.
The inspectors were familiar with the missing data and i
were aware that the data documented large instrument inaccuracies during the LOCA test.
During this inspection, the inspectors determined that only two
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Weed RTDs, which are required to function during and after a LOCA and have
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setpoints, remair.ed in the drywell Review of the setpoint and scaling calculations for the two RTDs determined that accuracy during the LOCA test was
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not factored into the calculations.
The calculation still referenced test j
document, NTS Test Report Number 548-8854-2, Revision B, as discussed earlier
in this paragraph.
The licensee had procured a new test report (Southwest Research Institute i
Report Number 06-8680-003, and has LOCA test accuracy data. Revision 1,datedJune1987)whichwasinthebinder i
The licensee stated that they would review
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this data, revise the calculations to use the data from the new report, and i
re-evaluate the setpoint value.
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item are resolved.
Based on this statement, the concerns of this
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5.6.8 EQDP-IZS-002
The previous NRC inspection identified that limit switches 2-FSV-3-98 and j
2-FSV-3-99 did not have conduit seals and that electrical loads on the switches was identified in the binder as 20 amps when in fact it should have
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i been listed as 0.5 amps.
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The corrective action taken by the licensee was to revise the binder at Tab 8, j
section F to show that switches covered in this binder are located outside
primary containment and will not be exposed to steam conditions or 100%
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relative humidity where a conduit seal is required. The specific limit switches were deleted from the binder and EQ program. The binder was also i
revised at Tab B, Item J to show the tested load as 0.086/0.5 amps. The
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licensee performed an evaluation to support the use of these switches in certain circuits at BFN where the actual load is slightly higher than the tested load. The inspectors found this to be acceptable.
5.6.9 EQDP-IIS-001 i
l The previous inspection identified that the service current described in the i
binder was 15 amps when in fact it should have been listed as 0.5 amps.
i The current revision of the binder identified the demonstrated loads as
0.086/0.5 amps at 100 ydc.
The Itcensee performed an analysis, as mentioned above, of
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the circuits at BFN and determined the actual loads to be more like 289 m i
amps (ma) at 120 vac and 112 ma at 250 vdc.
Although these loads exceed the i
tested values, the licensee's evaluation determined that it was acceptable to i
use these switches in certain circuits identified in the binder.
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The inspectors found this to be acceptable.
5.7 EQ Maintenance Program i
The previous inspection reviewed the licensee's procedure SOSP-7.7, Revision 0,
" Qualification Maintenance Data Sheets (QMDS) Implementation and Harsh
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Equipment Maintenance System (NEMS)."
The procedure had just been issued i
to provide a detailed methology for identifying and implementing required i
maintenance for EQ components.
The inspectors found that a large amount of i
work remained to be accomplished including reviewing and revising procedures, i
developing new procedures where applicable, and baselining EQ maintenance in
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the HEMS data base.
During this inspection, the inspectors discussed the i
status of all EQ maintenance activities identified to be completed prior to i
restert.
The licensee indicated that approximately 84 percent of the 9500
tasks have been baselined.
The associated PM tasks have been assigned for those essential EQ repetitive maintenance items which have been incorporated into the HEMS data base.
to implement all the QMDS requirements. Procedures are revised and developed by th
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The status of the procedure work is
being tracked on the EQ Data Base.
resolve all the procedure open items prior to restart.The licensee indicated that they
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-13-The planners involved in planning PMs and corrective maintenance were that they do not invalidate the EQ status of the equipment. in Based on the responses provided by the planners the inspector considered the maintenance planning activities to be adequate to maintain the qualified status of EQ equipment.
maintenance procedures, EQ Master List, EQDPs, and HEMS.All t
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The inspectiun maintenance concern identified in the previous IR regarding the potential for mixing greases has been satisfactory addressed by the licensee and is discussed further in paragraph 5.6.4.
l 5.8 EQ Master List The inspectors addressed certain questions about the accuracy of the 10 CFR i
I 50.49 List (EQ Master List) during this inspec. tion; as well as, reviewing the overall program for generating the component master list (CML).
NRC Inspection Report 50-260/B8-11 on page 13 cites a discrepancy in listing l
pressure switch 2-PS-073-029.
This switch was subsequently replaced by transmitter 2-PT-73-29-1.
This transmitter, together with the Terry turbine and associated devices located in the HPCI pump room, was determined by an essentially mild environment calculation to not require listing.
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"Estentially Mild Environment" calculations are addressed separately in The
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i paragraph 6.1.1.
Inspection Report 50-260/88-11 i
terminal blocks in EQDP-TBK-001 and 002.on page 13 questioned the qualification of In addition to rel blocks as described in the IR to avoid submergence concerns,ocating terminal the licensee is replacing certain terminal blocks (including Marathon 300s) with other qualified types, and binder 002 will be cancelled upon completion of field work.
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Inspection Report 50-260/88-11 on page 17 questioned the qualifications basis of the LPCI motor generator (MG) sets presented in EQ binder EQOP-MGN-001.
These MG sets were removed from the list based on an " Essentially Mild Environment" analytis, and the binder remo' M from the CML.
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The inspectors also reviewed the basis for removal of certain other binders from the EQDP list. EQDP-MOT-003 was intended to cover rewound motor Since the motors were instead replaced by new qualified motors, the l
i rewound motor binder is not required.
EQDP-XMTR-003 for Rosemount 1154 transmitters was merg6d into EQDP-XHTR-005 covering both transmitter models 1153 and 1154 wiring) and EQDP-IPS-002 (for HPCI room ASCO pressure switch i
l deleted based on " Essentially Mild Environment" analyses,
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The 10 CFR 50.49 list changes addressed above are all considered acceptable, taking into account the discussion of " Essentially Mild Environment" analyses in paragraph 6.1.1.
The program for generating the CML and 10 CFR 50.49 List is also considered acceptable.
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6.0 F_INDINGS
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J 6.1 Environmental Qualification Files In addition to the review of EQ Binders or EQDps discussed above, the inspectors examined 24 binders not previously reviewed.
(The licensee's program included G1 total binders and 73 binders were available for the inspection.)
The.e i
binders were reviewed to determine the qualification status of equipment within i
the scope of 10 CFR 50.49.
In some cases the binders had "open items" for
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required fieldwork necessary to be accomplished in order for the installed
equipment to comply with qualification requirements established in the binders.
i The licensee had established a tracking system for the binder "open items" to
verify completion of the fieldwork in accordance with requirements.
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i In addition to comparing plant service conditions with qualification test data
and verifying the basis for these conditions, the ir.spectors reviewed areas i
such as required post-accident operating time compared to the duration of time
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the equipment had been demonstrated to be equipment to that installed in the plant (qualified; similarity of tested e.g., insulation class, materials of components of the equipment, tested configuration compared to installed
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configuration, and documentation of both); evaluation of adequacy of test
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conditions; aging calculations for qualified life and replacement interval i
determination; effects of decreases in insulation resistance on equipment i
performances; adequacy of demonstrated accuracy; evaluation of test anomalies; i
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and applicability of EQ problems reported in NRC Information Notices l
(ins)/ Bulletins and their resolution.
The inspectors found that the binders reviewed were auditable and documented
i qualification of the equipment.
While the binders documented qualification, i
the inspectors suggested that minct changes be made to some in order to
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clarif ty information in the binders. Due to the minor nature of these changes
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and the fact that the licensee agreed to make the changes, detailed discussion i
of the changes is not provided and no follow-up of the changes is required.
i For the binders discussed in the following paragraphs, discussions are provided for clarification and documentation of specific topics.
l 6.1.1 EQDP-GEN-001 i
The generic E0 binder GEN-001 and associated procedures and documents were
reviewed with emphasis on the generation and maintenance of the 10 CFR 50.49 List of equipment requiring environmental qualification. The original BFNP EQ
Master List was deleted, and a new list was developed from scrati.h in 1987
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using procedures reflecting industry experience with master lists. Briefly,
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a Master Component Electrical List was prepared which toentifies the systems required to mitigate each 50.49 pipe break. A block diagram of each system i
was made, and each circuit was walked down to identify all components including cables, and their locations; 8x10 photos were also taken.
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Environmental drawings were prepared, documenting the environment in each
affected room for each pipe break. A Component Master List was generated
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that covers all equipment including auxiliary equipment needed to address
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Section (b) of 50.49, with a matrix for each pipe break of components in
each room vs. accident functions.
(Project Instruction 88-10, " Maintenance and Control of the 10 CFR 50.49 List," now specifies performing a failure modes and effects analysis for changes to the CML).
Further refinement,
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such as elimination of equipment located in mild environments, produced the
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l-15-I 10 CFR 50.49 List, which shows for each component requiring environmental
qualification, the related pipe breaks, required operating time, and j
category (type of function required in harsh environment).
One of the refinements used to narrow the 50.49 list is the " Essentially Mild (EM) Environment" analysis. Section 3.7 of Procedure BFEP PI 87.01,
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" Environmental Qualification Program Document," and Appendix III.C.3 of generic
binder BFN2EQ-GEN-001 address this subject. Paragraph (c) of 10 CFR 50.49 l
excludes from required qualification any equipment located in a mild environment, defined as "an environment that would at no time be significantly more severe j'
than the environment that would occur during normal plant operation, including anticipated operational occurrences." The licensee's EM category defines the
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l extent of the word "significantly" in the definition to (1) be bounded by
certain temperature profiles and radiation doses and (2) require evaluation of i
the environmental stresses on the affected equipment in terms of its materials,
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complexity, and etc. Section C.3.a of Appendix III states that "it must be
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stresseo that it is the EM analysis and not simply satisfying the criteria that
is the engineering basis for an EM classification. The EM analysis... must be equipment oriented as well as environmentally orisated." A Nuclear Engineering calculation is required to document the EM onalysis as a basis for removing
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the equipment from the 10 CFR 50.49 program.
The inspectors reviewed three EM calculations for equipment addressed during j
this inspection:
l 1.
ED-Q2073-880696 RO for HPC1 turbine components including 2-PT-073-0291 (to be superseded by ED-Q2073-900008 RO,notreviewed)
2.
ED-Q2071-900042 R0 for LPCI HG sets 3.
ED-Q29999-880641 R0 for 480v reactor motor operated valve (MOV) boards 2D and 2E Each calcuation defined the normal, abnormal, and accident maximum values for temperature, relative humidity, pressure, and radiation. The first references a calculation as the source of the environmental data. The other two reference the environsental drawings. The maximum temperature addressed was 124"F, which is well within the licensee's guidelines for considering EM
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classification. The maximum radiation level was slightly less than the SE4 rad value used by the licensee for the mild environment limit.
The first calculation covered several diverse types of equipment: valve actuators, pressure transmitters, a solenoid valve, motors, and a speed sensor. The equipment was identified only by unit device, identification number, manufacturer, model number, device type, and contract. The documentation of evaluation of environmental effects on the equipment was very brief, consisting of statements that materials of construction were reviewed and no limitation on ability to perform required safety functions was identified; that "in most cases" the equipment was previously qualified; and that all equipment was either industrial grade or had been " procured ano installed for safety / reliability upgrades." The other two calculations considered the specific electrical parts involved together with such factors as duty cycle, load, design
temperature, ano derating factors. The inspectors noted that a licensee internal audit in the spring of 1990 addressed EM calculations. Weaknesses were identified similar to those noted for the first calculation.
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The NRC inspectors conclude that the licensee's treatment of " Essentially
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i Mild" environments is satisf actory. Althcugh one calculation lacked
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hardware-specific detail, it is being revised and the licensee's internal audit process is addressing the concern. The other two calculations were l
considered acceptable.
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6.1.2 EQDP-CABL-020 and -037 i
The inspectors review of EQDP-CABL-020, Okonite power and control cable with i
ethylene propylene rubber insulation and a Hypalon jacket and EQDP-CABL-037, Okonite power and control cable with "X-01ene-FMR" (cross-linked polyethylene i
(XLPE)) insulation with a Hypalon jacket, identified that the established j
qualified life of 40 years at 90'C for these cables was not based solely on i
Arrhenius aging methodology.
Based on the Arrhenius technique for thermal
aging, the cables are considered to have a qualified life of 7.4 years at 90'C
or 40 years at 72*C, l
The qualified life of 40 years at 90*C, was based on information from the i
cable vendor.
In the v ndor's method for establishing qualified life, an
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Arrhenius aging line was established for the cable materials and an adjustment factor was applied based on data of naturally aged cable materials. From this
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l information the vendor established the thermal aging time equivalent to 40 j
years of qualified life.
The vendor used the cable material parameter of percent retention of elongation to establish an adjustment factor. This factor is based on samples
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of cables (polyethylene and rubber), which have been naturally aged to as much
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as 49 years in some cases. From the sample cables, the vendor demonstrates
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that the percent retention of elongation of naturally aged cable materials (over a range of temperatures) is greater than the percent retention of i
elongation which would be predicted by Arrhenius methodology. The vendor concludes that naturally aged cables do not age as much as would be predicted a
by Arrhenius and the use of an adjustment factor is acceptable since it is j
more representative of how cables actually aged in installed applications.
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Additionally, the vendor makes the case that the cable materials used today l
are even better than the naturally aged cable materials on which he based his conclusions. Therefore, the new cable materials can be expected to be more
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resistanttoaging(i.e.,haveagreaterpercentretentionofelongation)than
j the naturally aged cable materials on which the adjustment factors are based.
I The inspectors evaluated the qualification of the above cables and determined i
that qualification of the subject cables is acceptable for 40 years at 90*C j
based on the following points.
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The approach used has been previously accepted for demonstration j
of qualification at some other plaats.
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i The determination of qualified life is based on actual material
j aging data from naturally aged cables.
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The materials used in these cables are some of the latest and
best compounds available for use in the cable industry today.
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j Other cable manufacturers have been able to qualify the materials of
j the same type (with some variations in ingredients and mixing) for
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40 years at 90 degrees using the Arrhenius methodology.
In addition to the above points, the inspectors determined that electrical maintenance instructions at BFN require observation and documentation of
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electrical wire for wire insulation damage during maintenance activities.
j Through these requirements, the licensee would be able to identify and correct any age related cable degradation, should it occur, before it became a problem.
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l 6.1.3 EQOP-SOL-009
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Because of problems at other operating plants, the NRC has a generic interest in lubricants used for 0-rings in control solenoid operated valves (SOVs) for a
i Automatic Valve Corporation main steam isolation valves (MSIVs). Accordingly, j
this binder was evaluated in more detail than is typical for an EQ binder review. The licensee uses a thin film of Dow Corning 200 lubricant with a
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j viscosity of 100,000 centistokes(cst). A Wyle Laboratories EQ test report i
17514-1 documented failures of S0Vs with similar lubricants, because the valve actuating spring could not overcome the resistance of the lubricant galled by radiation damage. Additional test specimens with thin films of lubricants,
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or no lubricant at all, passed the tests. Although no successful test specimen
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had 0-rings lubricated with Dow 200,(an identical awterial) was used on the it was used on the plunger of test
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specimen 90 and Parker Super-0-lube
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l static seals of specimen 9D.
j The licensee acknowledges that the threshold radiation dose of 1.0E6 rad for
ge11ation of 100,000 cst Dow 200 is well below the five year normal service
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dose of 8.3E6 rad. The 0-ring lubricant is regarded as an assembly aid only, i
not as an operating lubricant. The test failures are regarded as caused by the presence of a significant quantity of degraded lubricant, and the test i
successes are attributed to the presence of little or no degraded lubricant.
j This analysis is carried through the maintenance section of EQ binder l
BFN2EQ-50L-005 to the plant maintenance procedure MCI-0-001-PNL001, " Main i
Steam Isolation Valve Cylinder and Air Control Panel Disassembly, Inspection,
Rework, and Reasses61y," Revision 5, which specifies cleaning the 50V and that
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the lubricant "must be applied as a light film." Since the valves must only be operable for one hour after an accident and the accident radiation dose of 3.6E6 rad is relatively small compared to the normal operation dose, periodic surveillance can confirm the operability of the valve. The licensee noted that increased radiation resistance can be obtained by selecting a lower viscosity
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lubricant; Dow Corning 200 is available in 23 different viscosities. The highest viscosity was selected primarily)because of its flash point of 620*F
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(the flash point of 20 cst is only 474*F.
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The licensee stated that some evidence of lubricant degradation was observed
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in 1984. None had been noted since, and all of the valves have been
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refurbished in 1990, so that dissembly and inspection at this time would not likely produce any beneficial results.
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Based on the rationale outlined above and the supporting information provided by the licensee, the inspectors considered the MSly control SOVs to be i
qualified. The licensee was cautioned, however, that ongoing generic i
evaluation by the NRC could raise additional concerns in the future.
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6.2 Cable Splices - Nuclear Performance Plan (NPP) Section 13.3 NRC Infomation Notice 86-33 and a BFN employee concern raised concerns about heat shrink electric cable splice installations. After investigating the
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concerns at BFN, the licensee concluded that all 10 CFR 50.49 cable splices would have to be replaced because it could not be established that existing
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splices were installed in accordance with qualification requirements.
i Replacement of splices was identified as "Open Item i 1" in the three Raychem
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splice binders, EQDP-SPLC-001, -002, and -003.
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The licensee's replacement splice program addressed all EQ splices shown on the plant wiring diagrams, a total of more than 1000 splices.
The licensee stated
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that the program was based on procedural changes, personnel training, and
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quality inspection and verification. The inspectors reviewed Modification
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Addition Instruction MAI-3.3, " Cable Teminating and Splicing for Cables Rated Up to 15,000 volts," Revision 8 to verify that Raychem instructions were properly referenced for selecting proper tubing size ranges and perfoming
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the splicing procedure and to verify that appropriate inspection hold points
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were specified. The inspectors also reviewed a sample field verification data sheet.
During the plant walkdown portion of the inspection, the inspectors examined
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numerous splices installed in the plant. As noted in paragraphs 4.1.2 and 6.6.4
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and 6.6.10, two discrepant splices were observed. One was bent a little more
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sharply than allowed.:nd the other was applied over triplex cable filler material. During the inspection the latter was demonstrated to be acceptable.
Despite these two minor concerns,, the program was considered to be progressing satisfactorily. However, it was not complete at the time of the inspection.
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Based on the progress and the inspectors' review, NPP Section 13.3 is considered to be satisfactorily addressed, subject to completion of the splice
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program.
6.3 Ellis and Watts HVAC Equipment On Septes6er 20,1989, TVA submitted a 10 CFR 21 notification for two Ellis &
Watts air conditioning units for the shutdown board room. Although the units
had been procured as EQ and Class IE, a licensee CAQR identified the use of undocumented electrical components and inadequate EQ documentation by the vendor.
The NRC inspectors reviewed the licensee's corrective action plans and progress.
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Several activities were initiated to correct the dedication and cualification
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problems with the equipment, which had been delivered and installed.
The parts list was reviewed and the equipment walked down to identify all parts,
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and the EQ status of each was deteranned. Two control panels were relocated
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to a mild environment. A motor and all unqualified switches were replaced with i
previously qualified types, and unqualified wiring replaced as necessary, i
Seven electromechanical component types are being qualification tested by Farwell & Hendricks; one of these components was changed from the original
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type, which is no longer available. Ellis & Watts is perfonning a complete i
rededication program to document that the equipment is suitable for safety-
related application. Licensee EQ and procurement engineers have reviewea i
dedication efforts including critical characteristics lists and verification
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methods.
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The licensee has issued a concurrence letter for dedication of mechanical components, such as condensors and coils, based on the Ellis &
j Watts evaluation, performance tests, receipt inspection, seismic test reports,
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etc.
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The EQ testing of electromechanical components is being performed in two
stages. The first, covering the equivalent of 21/2 years service (sufficient l
to support plant restart), is scheduled for September 1,1990, completion. The j
second stage, covering ten years service, is scheduled for December,1990*
approval of the test report. Two revisions of binder EQDP-PNL-003 are l
lP anned. Additional source and receipt inspections of Ellis & Watts materials are being performed, including 100% source inspection of safety-related
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i material fabricated by them. During the plant walkdown portion of this j
inspection, the NRC inspectors observed that the plant modifications appeared
to be conducted with consideration to avoiding damage to the equipment. For example, cable changes associated with relocating the control panels were j
j incomplete at the time of the walkdown; however, the associated cables were j
coiled within plastic bags taped to conduit fittings on junction boxes and on
the panels.
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The licensee is tracking completion of these efforts to ensure equipment operability and qualification prior to plant restart. Although not all
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j efforts are complete, the work performed to date and the plans for completion
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provide a basis for concluding that the Ellis & Watts HVAC equipment will be
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j qualified when the EQ program is completed.
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6.4 Reactor NOV Boards
i An employee concern stated that 480 volt reactor MOV boards 2D and 2E were neither Class 1E safety grade nor environmentally qualified. The concern was included i
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in the items Eva' uation Group study performed under CAQR BFP 871060, i
pre-restart commitment Nuclear Performance Plan, Volume 3. Section 3.12.0.
Licensee analyses determined that the only harsh environment EQ function of
I the boards (at approximately 150'F) is to avoid spurious opening of four isolation valves for a reactor water clean-up (RWCU) line break, and that only a
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four circuit breakers could cause such spurious action. These breakers were i
replaced with environmentally qualified breakers unoer DCN WI 2327. The other j
50.49 accidents for these boards produce accident environments of no more than j
124'F and SE4 reds. Asdiscussedinthisinspectionreport(seeparagraph
6.1.1), the NRC inspectors reviewed the essentially mild calculation for these i
boards and considered it acceptable.
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The licensee stated that harsh environment CAQR 871060 is being closed out. A separate CAQR 900210 was written to cover mild environment aspects of this i
concern, including a 250 volt board also addressed in the employee concern.
The mild environment CAQR is a post-restart commitment.
The inspectors
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consider that restart concerns have been adequately addressed.
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6.5 TVANestec Findings
As in the previous inspection, the inspectors evaluated the binders relative i
to the licensee's corrective actions on the qualification related findings
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I identified in the TVANestee Management Review Report, dated September 25, 1985.
The inspectors reviewed the report findings for BFN, Sequoyah, and Watts Bar relative to the equipment in the binders being reviewed to ensure the findings had been corrected with the new EQ Program and qualification binders.
The inspectors' reviews identified no discrepancies with regard to the TVANestec findings for the binders examined.
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6.6 Plant Physical Inspection
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The inspectors physically examined more than 27 equipment items (21 binders represented) during the plant walkdowns.
The items inspected were chosen based
on the inspectors' review of the binders, knowledge of potential problems with
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equipment installations from previous experience, and equipment located in
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the most severe environmental zones (emphasis was placed on inside containment equipment).
Included in the items examined were some of the same items or similar items inspected during the previous EQ inspection. The items inspected were located in Unit 2.
During the physical inspection, the inspectors examined characteristics such
as mounting configuration, orientation, interfaces, model number, aesient environment, and physical condition.
Several observations were ident.ified
during the walkdown and are discussed in the following paragraphs.
6.6.1 Flow Switch 2FS-074-050 The panel (junction box (J8) number 25-59) associated with this flow switch was very dirty with sufficient foreign material to plug the weep hole.
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The inspectors noted that the old flow switch had been replaced with a new switch
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due to rust problems identified during the previous inspection.
The licensee cleaned the box during the inspection and planned to inspect other similar boxes prior to system turnover before Unit 2 restart.
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6.6.2 Level Transmitter 2LT-3-2088 The Conax connector (2-CSC-003-2088) at J8-8116 was loose to hand pressure and J8-7720 was not sealed with room temperature vulcanizating (RTV) rubber.
Several such loose connections were noted on other devices.
The licensee determined that the loose connector was not on the pressure sealing side of the unit.
The licensee stated that they would inspect and tighten all loose connections prior to system turnover.
The junction box was open for maintenance at the time of the inspection; therefore, it would not have been sealed.
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6.6.3 Level Transmitter 2LT-064-159A i
The inspectors observed that the orientation of the conduit seal assembly was i
vertical and that the weep holes drilled in the condulet would not permit water to drain out of the condulet, but into it.
Several other transmitters were noted to have this same configuration.
The licensee stated that all vertical condulets having weep holes would be filled with RTV rubber up to i
the first weep hole.
t 6.6.4 Level Transmitter 2LT-003-2030 The split.e in JB-6521 had a 90 degree bend in it. Work on the JB appeared to i
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be in progress. The licensee stated that the splice would be replaced as part i
of the Raychem splice program (see paragraphs 4.1.2 and 6.2). The licensee
provided the inspectors with a work order for perfonning the work.
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6.6.5 Temperature Element 2TE-064-161D e
i The internal head potting compound did not completely cover the terminal
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blocks as required by the qualification test report and maintenance procedure.
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The electrical cable tag was also stuffed into the head.
Although the cover I
gasket appeared to be in good shape, it did not appear to have RTV applied
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to it as required by the procedure. The licensee immediately rectified i
the problem and inspected two other identical devices in the same location and
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they were found to be acceptable. The inspectors considered this concern to be
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an isolated incident.
j 6.6.6 Level Switch 2LS-073-056A/C r
l The level switch housing was loose at the flange nut and the Conax connection j
was loose at the condulet fitting. There was no gasket installed on the junction box door. The switches were under a work order and were to be
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inspected prior to their return to service.
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j 6.6.7 Level Switch 2LS-085-045C
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The level switch housing was loose at the pipe nipple, similar to 2TE-064-1610
i above. This item was in service at the time of the inspection. The licensee issued a repair order to tighten the connection.
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6.6.8 Radiation Monitors 2RE-90-272C and -273C j
Both of the Victoreen radiation monitors, which are required to have field i
cables that are completely enclosed within sealed conduits, were installed horizontally with the cables exiting horizontally from the detectors. The ends j
of the sealed conduits at the detectors could all be wiggled slightly and did i
not appear totally tight.
One of the four was loose enough that the nut could
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be turned by hand, clearly indicating that the conduit was not completely
sealed as required. Prior to the end of the inspection, the licensee processed work orders (W0s) 90-09059 and -09061 to investigate and correct the deficiencies as required. The Swagelok nuts and strain relief fittings were
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tightened. The licensee stated that they would perform a system integrity i
check when final calibration of the detector is perfonned prior to restart.
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-22-6.6.9 JB for Conax Penetration
The JB for one Conax penetration (specific penetration could not be determined
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during the inspection) was observed to determine the condition of the Kapton insulation on the penetration lead wires. While no dama
Kapton insulation, the JB cover (weight about 30 pounds)ge was noted on the was inserted diagonally into the box.
Although no damage was apparent from the cover being inside the box, the licensee should be aware that the delicate Kapton insulation i
coup be damaged by such practices.
6.6.10 Motor Operated Valve (MOV) 2FCY 73-2 One splice in H0V 2FCV 73-2 had the red Raychem seal raterial applied over a wtre that did not have all the triplex cable filler r,aterial, which was stuck
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to the wire insulation, removed.
The licensee provideo documentation to the i
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inspectors which demonstrated that the Raychem bonds satisfactorily to the Okonite EPR/Hypalon triplex filler material.
j was acceptable for EQ purposes.
Therefore, the installation
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6.6.11 Plant Physical Inspection Sunnary
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The above comments are provided to stress the importance of ensuring that
installed equipment configurations agree with qualification documentation.
l Specific follow-up of the above items will be performed following certification by BFN that their EQ program is complete.
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