IR 05000272/1989013

Insp Repts 50-272/89-13 & 50-311/89-12 on 890522-26. Deviations Noted.Major Areas Inspected:Licensee Implementation of Reg Guide 1.97,Rev 2 for post-accident Monitoring Instrumentation

ML18094A603
Person / Time
Site:	Salem
Issue date:	07/31/1989
From:	Anderson C, Della Greca A, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18094A601	List: IR 05000272/1989013 ML18094A600 ML18094A602
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-272-89-13, 50-311-89-12, GL-82-33, NUDOCS 8908160071
Download: ML18094A603 (17)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-272/89-13 Report No /89-12 50-272 Docket No DPR-75 License N DPR-70 Category _c_

Licensee:

Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey Facility Name:

Salem Generating Station, Units 1 and 2 Inspection At:

Lower Alloways Creek Inspection Conducted:

May 22-26 1989 Inspectors:

. Paolino, Senior Reactor Engineer-PSS/EB Approved by:

date Inspection Summary:

Combined Inspection of May 22-26, 1989 (Inspection Report Numbers 50-272/89-13 and 50-311/89-12)

Areas Inspected:

Special, announced inspection to review the licensee's implementation of Regulatory Guide 1..97, Revision 2 for post-accident monitor-i~g instrumentation and to determine the status of previously identified open EQ items and to closeout open EQ item Results:

Six previously Units 1&2) were close commitment to Regulatory post-accident monitoring identified. These items identified *EQ items (five items applicable to both Four examples of a deviation from the licensee's Guide 1.97, Revision 2 were noted regarding the instrumentation and four unresolved items were are listed below:

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• DEVIATIONS DESCRIPTION ITEM N PARAGRAPH Redundancy not provided for 50-272/89-13-01 RCS Hot Leg Water iemperatu;a 50-311/89-12-01 Redundancy not provided for 50-272/89-13-02 4A effluent radioactivity monitor 50-311/89-12-02 for noble gas effluents Redundancy not provided for 50-272/89-13-03 auxiliary feedwater flow 50-311/89-12-03 monitor Steam generator radiation 50-272/89-13-04 4.10 monitor subject to single 50-311/89-12-04 failure RG 1.97 UNRESOLVED ITEMS Type A variable isolation 50-272/89-13-05 from process computer uses 50-311/89-12-05 resistors Separation of control room 50-272/89-13-06 post-accident monitoring 50-311/89-12-06 instruments and identification of post-accident monitoring instrumentation on control boards Wiring in power supply and 50-272/89-13-07 signal wiring in process racks 50-311/89-12-07 and multiplex system not in accord with separation/

redundancy criteria. Also, inadequate electrical/physical isolation for lE/non lE loads powered from same breakers Update FSAR to reflect licensee 50-272/89-13-08 correspondence with NRC 50-311/89-12-08 regarding R.G. 1. 97 implementation

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• EQ OP EN ITEMS DESCRIPTION ITEM N STATUS EQ training for Systems 50-272/86-23-01 Closed Analysis Group 50-311/86-23-01 Limitorque MOVs inside 50-272/86-23-04 Closed containment without grease 50-311/86-23-04 relief valves Exe-Sensors Hydrogen Analyzer 50-272/86-23-05 Closed Pressure Transducer Qualified 50-311/86-23-05 Life Asco Solenoid Valve Post 50-272/86-23-06 Closed Accident Operability Time 50-311/86-23-06 Scotch 70/33 Electrical 50-272/86-23-09 Closed Splice Tape Qualification 50-311/86-23-09 Pipe mounting of Rosemount 50-311/86-23-10 Closed 1153 Flow Transmitters

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DETAILS 1.0 Persons Contacted 1.1 Public Service Electric & Gas Company R. Antonow, Salem Station Planning Engineer

• R. Bashall, Systems Analysis Supervisor

• A. Blum, Program Analysis Supervisor T. Crimmins, Vice President Nuclear Engineering D. Dodson, Licensing and Regulation T. Floyd, Staff Engineer - I&C M. Gray, I&C Engineer

• C. Lambert, Manager, Nuclear Engineering Sciences

• J. Lawrence, Senior Staff Engineer - Licensing/Regulation D. Lyons, I&C Systems Engineer G. Luh, Program Analysis Group

• C. Manges, Jr., Licensing and Regulation

• P. O'Donnell, I&C Engineer

• F. Pla, I~C Lead Designer V. Polizzi, Manlger, Electrical Engineering

• Preston~ Manager, Licensing and Regulation

• J. Ronafalvy, Manager, Nuclear Engineering Services R. Smith, Program Analysis Group F. Thomson, Supervisor, Nuclear Licensing D. Vito, Senior Engineer, Licensing 1.2 U.S. Nuclear Regulatory Commission

• K. Gibson, Senior Resident Inspector

• Denotes personnel present at exit meeting of May 26, 198.0 Introduction 2.1 Background The purpose of this inspection was to review the licensee's implemen-tation of R.G. 1.97, Revision 2, regarding instrumentation systems for assessing plant conditions during and following the course of an accident for Salem Nuclear Generating Station Units 1 and These systems were inspected to determine if they were installed in ac-cordance with Generic Letter No. 82-33, 11 Requirements for Emergency Response Capabilities" (Supplement 1 to NUREG-0737).

This letter, issued on December 17, 1982, specifies emergency response capabili-ties that have been approved by the NRC for implementatio This letter also discusses, in part, the application of R.G. 1.97 to the emergency response facilities, including the control room (CR), the technical support center (TSC) and the emergency response facility

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(EOF) at power plant R.G. 1.97 identifies the plant variables to be measured and the instrumentation criteria for assuring acceptable emergency response capabilities during and following the course of an acciden Regulatory Guide 1.97 divides the post-accident instrumentation into three (3) categories and five (5) type The three categories are noted as 1, 2, and Category 1 has the most stringent design require-ments, whereas category 3 the least stringen The five types of instrumentation identified in the Regulatory Guide are types A, B, C, D, and Type A variables are plant specific and classified by the licensee; type B variables provide information to indicate that plant safety functions are being accomplished; type C variables provide information on the breach of barriers for fission product release; type D variables indicate the operation of individual safety systems; and type E are those that indicate and determine the magnitude of the release of radioactive material Each variable type can be any

• design category, except for type A which can only be category.2 Correspondence The licensee responded to generic letter 82-33 by letter dated April 15, 1983, referring to a previous submittal dated April 2, 198 Additional information was provided to the NRC by letter

. dated September 21, 1983 and August 9, 198 Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March of 1983, to answer licensee questions and concerns regarding* NRC policy for implementation of R.G. 1.9 At these meetings, it was noted that the NRC review would be limited to explicit exceptions to the guidance of Regulatory Guide 1.9 Where the licensee explicitly states that the instrumentation systems conform to the provisions of the guide, it was noted that no further staff review would be necessar The specific references used to assess the licensee's response to R.G. 1.97 are identified in Attachment 1 to this repor.0 Inspection Scope and Details The following instrument channels, used to provide information required for operator controlled actions, have been classified by the licensee as type A variable *

Reactor coolant system hot leg water temperature

Reactor coolant system pressure

Degrees of subcooling

Containment pressure

Effluent radioactivity -- noble gas effluent from condenser air removal system exhaust

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• Refueling water storage tank level

Pressurizer level

Steam Generator pressure

Auxiliary feedwater flow

Condensate storage tank water level

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Steam generator blowdown radiation All of the above variables, except the steam generator blowdown radiation, are also included as type B, C or D variables. All meet Category 1 requirements consistent with the requirements for type A variable The NRC R.G. 1.97 inspection of the above instrument channels included:

equipment qualification (seismic and environmental), redundancy of power supplies, independence and separation of electrical circuits, measured variables, display and recording methods used, range and overlapping features of multiple instrument indicators, direct and indirect measure-ments of parameters of interest, equipment identification for R.G. 1.97 instruments, service, test and surveillance frequenc The safety related Q and EQ master equipment list were reviewed for the instruments selected, to determine if they had been evaluated and tested to the appropriate environmental, quality assurance (QA) and seismic qualification requirement The QA pror.urement of these instruments was also reviewe The inspectors held discussions with various members of the licensee's staff, reviewed drawings and procedures, and selected variables for physical inspectio A walkdown was performed for the display instruments in the control room to assess the implementation of R.G. 1.9 The instru-ment ~ariables reviewed for Salem Units 1 and 2 are described in the paragraphs belo Regulatory Guide 1.97 Variables Evaluated (Units 1 and 2) Reactor Coolant System Hot Leg Water Temperature The licensee determined the reactor coolant system wide range hot leg water temperature to be a type A variabl One instrument channel was provided for each of the four reactor coolant loops to cover the water temperature rang Each instrument channel shares a recorder with the associated cold leg loop water temperatur The four two-pen recorders are located on the main control board in the control roo All instruments in the four instrument channels are on the environmental and seismic qualification master list The instrument channels were found to be in calibration as evidenced by the plant calibration records inspected.

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Since the four instrument channels are supplied by four redundant sources of power, they were believed to be redundant to each othe Further investigation by the inspector revealed that the four instru-ment channels do not have a corresponding redundant instrument channel~

as specified by R.G. 1.97 for type A variable The licensee noted that each of the four reactor coolant loops contains three dual RTDs located downstream from the ones used for post-accident monitoring purpose These RTDs are used in the protection circuits and, after isolation, for narrow range indication of loop average and differential temperature Since these instrument channels use a method and loca-tion for measuring loop temperature which is different from those used for post-accident monitoring they may not provide the redundancy recommended by RG 1.97. This item is a deviation from the guidance in R.G.. l.97 (50-272/89-13-01; 50-311/89-12-01).

Reactor Coolant System Pressure The licensee determined reactor coolant system pressure to be a type*

A variable and provided four instrument channels to monitor this variable after an acciden Each of the four channels are transmitted through a selector switch and relay circuit to a pen recorder which can provide a trend record of any one of the four channel Evalua-tion of the circuits and devices shows that acceptable electrical isolation exists between the four channel The recorder is located in the control roo Each of the four instrument loops covers the entire variable rang All of the instruments associated with the four instrument loops were found to be on appropriate lists for environmental and seismic qualificatio Each instrument loop was found to be in calibration as evidenced by the calibration records examine No deficiencies were identified for this variabl Containment Pressure The licensee determined containment Pressure to be a type A variabl Acco.rdingly, the licensee provided category 1, environmentally and seismically qualified process and display instrumentatio The monitoring of this variable is accomplished by four narrow range and 2 wide range instrument loop Each of the narrow range loops pro-vides its input to individual indicators on the main control board in the control roo In addition, recording is provided for two of the four narrow range instrument loop Two dual-pen recorders provide a trending record for these two loops and the two wide range instrument channel Channel separa~ion is appropriately provide All loops were found to be in calibratio No deficiencies were identified for this variable.

• 4.4 Effluent Radioactivity - Noble Gas Exhaust The licensee classifies the effluent radioactivity monitor for noble gases effluents from the condenser air removal system exhaust as a type A variabl For this variable the licensee provided instrumen-tation which did not meet the R.G. 1.97 recommendation Therefore, in accordance with the position taken in the SER, the licensee assigned to this function the R41C instrument loop which was clas-sified as a type C variabl This instrument loop is category 1, environmentally and seismically qualified, and provides post-acci~ent monitoring via a digital indicator in the control roo The calibra-tion records were evaluated and found to be acceptabl The licensee, however, did not provide appropriate redundant instrumentation, as recommended by R.G. 1.97" for type A variable The licensee indicated that other safety-related instrumentation existed to provide the operator with a redundant instrument loop in the event of failure of the R41C loo However, the instruments suggested by the licensee monitors radioactive noble gases in a range not monitored by the R41C loo These instruments, therefore, are not acceptable redundant instrument This issue is a deviation from the R.G. 1.97 recommenda-tions on redundanc (50-l72/89-13-02; 50-311/89-12-02)

4.5 Refueling Water Storage Tank Level The licensee determined the refueling water storage tank level to be a type A variable. Accordingly, the licensee furnished Class lE, environmentally and seismically qualified instrumentatio The moni-toring of the variable is accomplished by two electrically independent instrument loops which provide indication on the main control board in the control roo Recording for th.is variable is provided by the Class lE SPDS compute The instrument loops do not meet the top to bottom range recommended by R.G. 1.9 However, they cover, the effective operating range of the storage tan As such, the instru-ment loops satisfy the R.G. 1.97 and are acceptable. A review of the calibration records demonstrated that the instrumentation is calibrated in accordance with the licensee's associated technical specification.6 Pressurizer Level The licensee classifies the pressurizer level as a Type A variable and has provided Class lE instrumentation which is both seismic~lly and environmentally qualified. This variable is monitored by means of four electrically independent instrument loops which provide indication on the main control board in the control roo Recording is accomplished by the safety-related SPDS compute The instrument loops do not meet the top to bottom range recommended by R.G. 1.9 However, they cover, the effective operating range of the pressurize As such, the instrument loops satisfy R.G. 1.97 and are acceptabl A review of the calibration records demonstrated that the four

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• instrument loops were calibrated in accordance with the li~ihsee 1 s associated technical specificatio.7 Steam Generator Pressure The licensee determined the steam generator header pressure to be a type A variable. Three electricaiiy independent instrument channels were provided for the post-accident monitoring of each of the four steam generators header pressur Indication is provided by means of meters mounted on the benchboard in the control room, while record-ing is accomplished by signals 1 input to the safety-related SPDS compute Review of the licensee 1s records indicates that these instruments meet the requirements for environmental and seismic qualification and for loop calibratio On the basis of the records and drawings evaluated, the inspector found the variable to meet the recommendation of R.G. 1.9.8 Auxiliary Feedwater Flow The licensee considers the auxiliary feedwater flow to be a type A variabl As such~ the instruments involved were classified as Class lE.and environmentally and seismically qualified, as indicated by the licensee 1 s associated master lists. The variable is monitored by four instrument loops, one for each feedwater train and includes

. indicating maters on the benchboard in the control room and recording v.ia the safety-related SPDS compute However, contrary to R.G. 1.97, the variable is not monitored by redundant post-accident instrumenta-tion. This item is a deviation from the Regulatory Guide (50-272/89-13-03; 50-311/89-12-03).

The existing instrument loops are properly calibrated as evidenced by the records provided by the license.9 Auxiliary Feedwater Storage Tank Level The licensee determined the* auxiliary feedwater storage tank level to be a type A variable. Accordingly, two electrically independent instrument loops were provided to cover the required water level rang The display instrumentation is located on the main control board in the control room, whereas recording is provided by signals to the SPDS compute A review by the inspector demonstrated that the instruments involved meet the requirements for environmental and seismic qualification and that calibration is accomplished in ac-cordanca with the licensee 1s technical specification. Accordingly, no deficiency were identified for this variabl.10 Steam Generator Radiation i

The licensee classifies the steam generator radiation to be a type A variabl The post-accident monitoring of this variable was originally provided by *non safety-related instrumentatio In

accordance with the position taken in the SER, the licensee added four safety-related, environmentally and seismically qualified instrument loops with indication on a back panel and recording on a front panel in the control roo To comply with the redundancy recommendations of R.G. 1.97, a second recorder was provided. This recorder is supplied by a redundant source of power and receives electrically isolated signals from the same four instrument loop In evaluating the design used to measure this variable, the inspector identified several potential single failures modes which could impair both redundant channels and, thus, prevent the post-accident avail-ability of this variable to the operato An example of failures affecting both channels is the loss of control power to the sample inlet solenoid valve In this case, the valves fail close with consequent loss of indication at both recorder The existing instrument loops were calibrated in accordance with the applicable technical specification This item is considered a deviation from the R.G. 1.9 (50-272/89-13-04; 50-311/89-12-04)

5.0 Computer Isolation A review of the wiring diagrams associated with the type A variables discussed in the above paragraphs revealed that the method used to derive

• a signal to a process computer is by routing the instrument loop current signals through a 250 ohm resisto The voltage drop across this resistor provides the signal to the computer through two 15000 ohm resistors, one in each of the two lines. This resistor network is i dent ifi ed on the diagrams as "computer signal conditioner" and provides the isolation between the Class 1 instrument signal and the class 2 plant compute The inspector informed the licensee that resistors are generally not considered acceptable isolation devices, even if they are high impedance devices (as defined by the licensee) and part of the original design by the NSSS manufacture The reason for the inspector's concern is that the use of this type of isolation could result in the inadvertent violation of the single failure criterio IEEE standard 279-1971, section 4.7.2, "Isolation Devices, 11 states in part that "No credible failure at the output of an isolation device shall pre-vent the associated protection system channel from meeting the minimum performance requirements specified in the Design Basi Examples of credible failures include short circuits, open circuits, and the applica-tion of the maximum credible AC or DC potential."

An evaluation of the drawings relating to the pressurizer pressure circuit also shows that computer signal conditioners were used to isolate the computer input signals from the signals which ultimately control the pressurizer's spray valves, heaters and PORV The drawings do not show whether these devices are Class l The licensee should evaluate its design and assure that nowhere in its instrument circuits was the single failure criterion violated as a result

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of its usi.ng signal conditioners as electrical isolators between Class lE and non Class lE device The licensee should show that its commitment to IEEE 279 with regards to isolation devices has been satisfied. This item is unresolved pending the licensee's review and resolution of this issu (50-272/89-13-05; 50-311/89-12-05)

6.0 Physical Walkdown The inspectors examined the Unit 2 control room (the Unit 1 control room was inaccessible as a result of ongoing tests at the time of the inspec-tion) to determine agreement with Regulatory Guide 1.97 for electrical/

physical separation, instrument identification and instrumentation calibratio The inspectors questioned the adequacy of the electrical/

physical separation of the control room post-accident monitoring compo-nent Redundant channels were physically mounted side by side with electrical wiring in a common bundl In addition, the type A, B and C post-accident monitoring instrumentation on the control boards was not spectftcally identified as post-accident monitoring instrumentation as specified by R.G. 1.97, Revision In discussions with the licensee it was noted that the licensee's submittal of April 2, 1984 discusses compliance with R.G. 1.9 In Item I.4 of the licensee's submittal regarding separation/redundancy, the li_censee stated that they do not conform to Regulatory Guide 1.7 The licensee noted that. separation and independence is in accordance with the licensee's design criteria No. CD-S-1, for control and protection systems, Revision 4, dated May 1, 197 In Item I.7 of the submittal regarding post-accident monitoring instrument identification; the licensee stated that they will not provide un~que identification for"R.G. 1.97 instrumentatio This item is unresolved pending NRC review and evaluation of the licensee's exceptions regarding separation and instrument identificatio The separa-tion review is to establish the extent to which the licensee R.G. 1.97, category 1 equipment is in accordance with the licensee's original design separation criteri The post-accident instrument identification review is to determine that instrument identification is in accordance with the detailed control room design review and the human factors engineering evaluation of this issu (50-272/89~13-06; 50-311/89-12-06)

During this i.nspection, the inspector noted that the licensee issued a Deficiency Evaluation Report DES-89-02241 on potential problems in separation/redundancy and isolatio The licensee had identified potential wiring deficiencies in some safety-related (A, B, C, D) and associated (H, E, F, G) power supply and signal wiring to and from the process racks and to the SPDS multiplexes systems not in conformance with the separation/redundancy criteria as routed and terminate In addition, the licensee identified Class lE and non lE loads powered from the same breakers in process interface racks with insufficient electrical/

physical isolation to satisfy the R.G. 1.97 criterion.

This item is unresolved pending NRC review of the licensee's corrective

- actions regarding these deficiencies (50-272/89-13-07; 50-311/89-12-07).

The inspectors reviewed FSAR section 7.5 regarding compliance with R.G. 1.9 Discrepancies were identified in the FSAR versus licensee destriptions of compliance in correspondence with the NR For example, FSAR, page 7.5-14 amendment Revision 6, dated February 15, 1987 references a commitment for compliance level 3b instruments which are to be upgraded to R.G. 1.97 requirements by June 1, 198 FSAR Table 7.5-4 lists several variables with compliance levels 3a and 3b which should have been upgraded in 198 The licensee agrees that the FSAR needs to be updated and is preparing amendments to the FSAR to reflect current status on compliance with recommendations of R.G. 1.9 This item is unresolved pending licensee submittals to amend the FSA (50-272/89-13-08; 50-311/89-12-08)

7.0 Status of Previously Identified Open Items

(Closed) Potential Enforcement/Unresolved Item 50-272/86-23-01; 50-311/86-23-01 pertaining to the adequacy of the EQ training for the Systems Analysis Group (SAG) personne The inspector reviewed engineering personnel employment records

- listing background information applicable to EQ, and the EQ -training history of each person in the SA The information indicates SAG personnel to be competent in E Additionally, the senior EQ engineer presents*a training seminar to the SAG periodically to assure that all members are up to date in the latest EQ-techniques and procedure The latest such session attended by all 7 members of the SAG was held on April 11, 198 In addition, SAG members are sent to applicable outside EQ seminar Records indicate approximately half of the SAG personnel have attended these seminars in the last two year Based on the auditable condition of the EQ files and the general level of competency displayed by SAG personnel during this inspection the training program for SAG was determined to be satisfactor This item is close *

(Closed) Potential Enforcement/Unresolved Item ~0-272/86-23-04; 50-311/86-23-04 p~rtaining to Limitorque (MOV's) installed inside containment without grease relief valve During the EQ team inspection 86-23, a review of file EQ-51 disclosed that some inside containment Limitorque MOV's did not have grease relief valve Ultimate resolution of this issue was accomplished by issuance of 11 Field Directive No. S-C-A900-MFD-0412-0, Status Code 58 Installation of Pressure/Grease Relief Valves on Limitorque Motor

• Operators for In-Containment Use Units 1&2 (SALEM), "September 17, 1986, and the subsequent installation of grease relief valves on all inside containment Limitorque operators that were not so configure This Field Directive was implemented in Septe~ber 1986 which technically closes this ite To prevent the future installation of Limitorque MOV 1 s without grease reliefs and to assure that all the inside containment MOV 1s are so equipped "Field Directive No. S-C-A910-MFD-0513-0 Status Code 56, Acceptable Components for Safety-Related Limitorque Valve Operators Inside and Outside Containment Salem Generating Station Units 1&2" March 30, 1988 was issued. This directs station personnel to assure new inside containment Limitorque MOV 1 s are equipped with grease reliefs.and directs maintenance personnel to check for grease reliefs during walkdown and periodic maintenance on installed Limitorque This item is technically close *

(Closed) Potential Enforcement/Unresolved Item 50-272/86-23-05; 50-311/86-23-05; pertaining to the Exe-Sensors Hydrogen Analyzer, File EQ-38 The Salem Field Directive S-O-A910-CFD-0328-RO for hydrogen analyzer maintenance requires replacement of the pressure transducers and RTDs every ten year However, data in the EQ file indicated a 2 year qualified life. During the week of the EQ team inspection 86-23, the licensee was unable to provide documentation supporting the 10 year qualified lif Shortly after the inspection, the licensee obtained data from EXO-Sensors, Irie. supporting a 19.4 year qualified life for the pressure transducers and RTD 1s at an ambient temperature of 120° This information was incorporated into their existing EQ file and forwarded to Region I. Subsequent to these actions, the EQ-38 file was upgraded and changed into a more manageable and auditable for Arrehnius calculations are now included showing the qualified life for the presstire transducers and RTD 1 s as 19.4 year References supporting these calculations are: Exo-Sensor QTR No. EXO-QTR-119, Rev. 2, 11-3-86 Exe-Sensor QTR No. EXO-QTR-101, Rev. 2, 3-8L EPRI Report EPRI-NP-1558, Project 890-1 Sept 1980 11A Review of Equipment Aging Theory and Technology 11 P.4-10 In order to preclude the future possibility of failing to adequately assess the proper qualified life of sub-components of a system, the licensee utilizes Site Engineering Instruction (SEI) 2.6 Rev. 1, April 1988 which specifically directs the licensee to identify specific components of a system o~ a replacement* schedule different

from the system itself and determine the qualified life of each of these component This qualified life is then checked to be sure it is longer than the replacement schedul This item is close *

(Closed) Potential Enforcement/Unresolved !tern 50=272/86-23-06; 50-311/86-23-06 pertaining to the qualified life of ASCO Solenoid Valves, File EQ-4 The SCEW sheet for ASCO models 206-380, 206-381, 206-382, 208-266, 208-448, 210-036, NP8314, NP8316, NP8320, and NP 8323 solenoid valves in the EQ 42 file showed a required post-accident operating time of 120 days while showing a qualified operating time of 30 day During the week of the EQ team inspection 86-23, the licensee was unable to demonstrate the 120 day qualified lif Following the exit meeting, the licensee provided information to NRC Region I to demonstrate that the "greater than 119 days" present in the (then) EQ file actually enveloped the required 120 day past accident operability requiremen Subsequent to these events Salem

. has upgraded and changed their EQ files to a more manageable and auditable for Included in these new EQ files are three sets of Arrehnius calculation supporting the 120 day operability requirement for all of the above model number SOV Test data supporting these calculations is found in the following referenc TR No. AQR-67368/Rev. 1, "Report on Qualification of ASCO Catalog NP-1 Solenoid Valves for Safety Related Application in Nuclear Power Generating Station,_ 8-19-83."

Procedures in place at the time of the August 1986 inspection and new procedures such as Site Engineering Instruction (SEI) 2.6, Rev. 1, April 1988, specifically direct the licensee to furnish documentation showing *post accident operability requirements are me Present EQ files specifically show the 120 day requirement is me This item is technically close *

(Closed) Potential Enforcement/Unresolved Item 50-272/86-23-09; 50-311/86-23-09 pertaining to qualification of Scotch 70/33 Electrical Splice Tap During plant walkdown of the EQ inspection, Scotch 70 tape splices were found on the power leads of Limitorque MOV 1SJ67 and lCS1 These MOV's are located outside containment in the auxiliary build-in Documentation supporting qualification of these splices was not in the EQ file *

The problem was corrected in the Salem EQ files by adding File N EQ-07, Scotch 70/33 Electrical Splice Tap Qualification in this file is supported by Franklin Research Center Report F-C5022-2

"Qualification Tests of Terminal Blocks and Splice - Insulating Assemblies in a Simulated LOCA Environment," November 197 Procedures such as Site Engineering Instruction (SEI) 2.6, Rev. 1, April 1988 which specifically direct the EQ staff to determine the Environmental Qualification of all components of a system should preclude such future oversigh This item is technically close *

(Closed) Potential Enforcement/Unresolved Item 50-311/86-23-10 pertaining to the pipe mounting of Rosemount 1153 Flow Transmitters i

During the plant walkdown, the NRC inspectors identified Rosemount 1153 transmitters mounted on a pipe support in a manner different than the qualified Rosemount seismic suppor Concerns raised by the inspector regarding the installed configuration include:

a)

For a rigid mount, it must have a fundamental mechanical resonant frequency of 40 Hz*or greate b)

For a non-rigid panel mount, the user must ensure that seismic input to the mounting bracket does not exceed qualification levels given in paragraph 8.0 of Rosemount Report 0830004 The first concern (a) was satisfied by the licensee producing calcula-tions and analysis showing the Salem station generic pipe mount (the mounting observed by the inspectors) exhibited a fundamental mechani-cal resonant frequency greater than 40 HZ in all three axes of movemen The second concern (b) was satisfied by the licensee producing seismic test data for two typical instrument panels used at Salem and then demonstrating how the seismic loading, or acceleration, is computed for each position in the pane For the case of a Rosemount 1153, the maximum seismic input from paragraph 8.0 of Rosemount Report 08300040 is 5.0 If the seismic computations provide for an accele-ration less than 5.0g for some selected position in the fnstrument panel, then a Rosemount 1153 may be placed there and retain its EQ accepta~ility status. This type of analysis is generically used for placement of any EQ instrumentation at Salem in a non rigid instru-ment pane This item is technically close )I c

8.0 Unresolved Items Unresolved items are matters about which more information is needed to ascertain whether they are acceptable items or violation Unresolved items are discussed in paragraphs 6.0 and.0 Exit Meeting The inspectors met with licensee representatives at the conclusion of the inspection on May 26, 198 The inspectors summarized the scope of the inspection and the inspection findings at that tim No written information was provided to the li~ensee during this inspectio ~

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ATTACHMENT 1 R.G. 1.97 References Regulatory Guide 1. 97, Revision 2 "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident."

Environs

NUREG-0737 Supplement No. 1, "Clarification of TMI Action Plan Requirements, Requirements for Emergency Response Capability," dated January, 198 *

Functional Specification No. CD-S-1 Revision 5 "Design Criteria for Independence and Separation of Safety Related Instrumentation, Controls and Protection Systems", dated February 25, 197 *

Interim SER dated May 4, 198 *

Final SER dated June 17, 198 *

PSE&G letter, E. A. Linden to the NRC, *"Requirements for Emergency Response Capability, NUREG-0737 Supplement No. 1, 11 dated January 198 *

PSE&G letter, R. A. Mittle to the NRC, "Compliance with Regulatory Guide 1.97, No. 2 Unit" dated April 2, 1981

PSE&G letter, E. A. Linden to the NRC, Compliance with Regulatory Guide 1.97, "NRC Request for Additional Information dated September 21, 198 *

PSE&G letter, E. A. Linden to the NRC, "Conformance to Regulatory Guide 1.97, Requirements for Emergency Response Capability" dated August 9, 198 *

PSE&G letter, E. A. Linden to the NRC, "Envi-ronmental Qualification Justification for Continued Operations at Salem Generating Station Units 1 and 2, 11 dated November 9, 1984.