IR 05000285/1985026

Insp Rept 50-285/85-26 on 851118-22.No Violation or Deviation Noted.Major Areas Inspected:Previously Identified Apparent Violations,Unresolved Items,Open Items & Actions Taken by Util Re Meeting Requirements of 10CFR50.49

ML20153E834
Person / Time
Site:	Fort Calhoun
Issue date:	02/19/1986
From:	Ireland R, Andrea Johnson, Norman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153E827	List: IR 05000285/1985026 ML20153E822
References
50-285-85-26, NUDOCS 8602250172
Download: ML20153E834 (13)

Text

'T, "

w t

> * ' <

.c - ,

I f'

APPENDIX P

'

U.S. NUCLEAR REGULATORY COMMISSION

'

REGION IV'

,

NRC Inspection Report: -50-285/85-26 Operating License: DRP-40 Docket: .50-285 Licensee: Omaha Public ~ Power District

,

1623 Harney Street Omaha, Nebraska 68102 ,

Facility.Name: Fort Calhoun' Station,. Unit 1 .

. Inspection At: Omaha and Fort Calhoun, Nebraska Inspection Conducted: November 18-22,= 1985

.,

, Inspectors: [ [ .C /w / 4//9/F2 Johnson, Reactor Irispector, Engineering

-

Date ~

~

.p K. ~ Section, Reactor Safety Branch

-

b WMmsw 'W/VkN D. Norman, Reactor Inspector, Operations- Date Section, Reactor Safety Branch ,

!

Approved: / . C I// I J//9/P' /. .

R. li. Ireland, Chief, EngineeH ng Section Da'te

~ ' ' -

Reactor Safety Branch .

.

Inspection Summary Inspection Conducted November 18-22, 1985 (Report 50-285/85-26)

Areas Inspected: Announced, followup inspection of previously identified apparent violations, unresolved items, an open items (50-285/8509-01 through 08),

and actions taken by Omaha Public Power District (0 PPD) with regard to meeting the requirements of 10 CFR 50.49. Commitments made by OPPD during a December 13, 1985, meeting at Region _IV, Arlington, Texas, are summarized in the inspection report. The inspection involved 81 inspector-hours onsite by two NRC' inspector ys5 PDR ADOCK O PDR G

_

_

,

.

.

-2-Results: The inspection determined that the licensee had completed all but four corrective actions to meet the requirements of 10 CFR 50.49, with deficiencies still open regarding apparent violations / unresolved issues identified during the NRC EQ team inspection of April 29 to May 3,1985, (50-285/85-09) as follows:

Apparent Violation / Unresolved Item IE Report Item Status Allis-Chalmers Pump Motors 285/8509-01 Open PAM Instrument Accuracy 285/8509-02 Open Canax Electric Penetration Assemblies 285/8509-03 Closed States Company Terminal Blocks 285/8509-04 Open Rockbestos Pyrotrol III Cable 285/8509-05 Open Definition of Harsh Radiation Environment 285/8509-06 Closed Open Items Completion of Procedures 285/8509-07 Closed Containment Ambient Temperature 285/8509-08 Closed Oneunresolveditem(285/8526-01- Refer to paragraph 2.b), originally described as part of item 1 above, but not considered within the scope of the 10 CFR 50.49 program, has been identifie .

.

.

. -

'

+

L ., .. .

,

,

..

,

.

'

>

,

~

..

, -

3 ,

,a .

s 8 *

• .

,

g c

,

< DETAILS y . > .;

,

_'q

_

• Persons Contacted ,

Principal Licensee Emp'loyees

-

xW.G. Gates, Manager, Fort Calhoun Station

'

-,. xMerl -Core, Supervisor, Maintenance xR. 'L. Andrews, Division Manager, Nuclear Production

"

MF. A. Thurtell, Division Manager, QARA

• +A. W. Richard, Supervisor, Corporate QA

'*+xR. L. Jaworski, Section Manager, Technical Services  :~

• +xJ. K. Gasper, Manager, Administrative Sers ,ces

• +S. K. Gambhir, Manager, GSE Electrical and Nuclear

+P. Surber, Section Manager, Generating' Station Engineering

• +xR.'F. Mehaffey, Supervisor, I&C and Electrical, Technical Services

• + J. Munderloh, Engineer, Nuclear Regulatory & Industry Affairs xJ. Foley, Supervisor, I&C and Electrical xJ. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs-NRC xD. Hunter, RIV, Chief, Reactor Safety Branch xJ. Gagliardo, RIV, Chief, Reactor Projects Branch, x+P. H. Harrell, Senior Resident Inspector

+D. M. Hunnicutt, RIV, Chief, Reactor Projects Section B,

+4. E. Ireland, RIV, Chief, Engineering / Operations Section

• +xA. R. Johnson,'RIV, Reactor Inspector

• +xD. E. Norman, RIV, Reactor Inspector M. Murphy, RIV, Reactor Project Inspector

• Denotes those present during entrance intervie + Denotes those present'during exit interview xDenotes those in attendance at the December 13,~1985, meeting at Region IV, Arlington, Texa In addition to the above personnel, the NRC inspectors held discussions with various operations, engineering, technical support, and administrative members of the licensees' staf . (0 pen) Apparent Violation / Unresolved Item 285/8509-01 Allis-Chalmers Pump Motors The NRC inspector reviewed the following areas with respect to cited deficienc'ies regarding the Component Cooling Water (CCW) pump motors:

,

e r y l r *

'

m -

_._______,__m.____.__..__________ -

____.________.___._._._._.___________E______________..___ m'

j:;

.

,

'

'

-- ,.

.l .: ,

.

i s

', .

.,

-4- j

, .

'

. Replacement Windings Qualifications

~

(1) -Previous Findings: ,,  ;

The original motor windings for the CCW pump motors were-

. qualified for an 18 year life based on a thermal aging analysis of the glass fiber fabric insulating materia The' licensee had failed to demonstrate the claimed 40 year. life of the replacement windings which had been installed in motor AC-38,.which had failed,-and were to be. installed in the remaining two motor (2) Corrective Action:

'

.

During this inspection, the NRC inspectors reviewed a Sargent and Lundy letter dated June 25, 1985, which reported results:of their aging analysis of the replacement windings, with Fiberglass-Polyester insulation. The analysis, based on material aging properties reported in Wyle Report No. 26333-23, showed a quali-fied life of 40 years based on the licensee's predicted motor +

operating environment. Based on this review, the replacement windings appear to be qualified for 40 years.- , CCW Pump Vibration ,

In a letter dated October 11, 1985, responding to NRC Inspection Report 50-285/85-09~ findings concerning the CCW motors, the licensee stated that motor AC-3A required new bearings and balancing due to high vibration levels in 1979, 1982, and 1983t It was stated that the higher frequency of repair for this motor was a result of high vibra-tion induced by the inlet piping on AC-3A. During the inspection, the NRC inspectors reviewed Engineering Evaluation and Analysis Request (EEAR) No..FC-79-98, dated June 29, 1979, which identified a CCW pump inlet piping vibration problem.' Vibration levels of 4.2 mils, without the AC-3A pump running, were identified. Modification. Request No. FC 79-98, dated May 14, 1981; approved by the plant manager and section

< manager, stated that an emergency resolution of the problem was needed as soon as possible. ,The.EEAR had not been closed and there was no evidence that the requested modification was completed. The apparent failure to' act promptly on an' identified problem is-considered an 1 unresolved item pending-further' review during a subsequent. inspection (285/8526-01). . > Motor Maintenance ,

,

(1) Previous Findings:

The licensee had not established nor performed a maintenance program to preserve the Allis-Chalmers CCW pump motors in a qual- )

ified stat '

.

-s-_ .--___----__,--.-a_,-- -a<oa-,he

, o-5-(2) Corrective Actions:

The licensee's stated corrective actions, with respect to the CCW pump motors, were reviewed and found to be acceptable. The NRC inspector also reviewed the manufacturer's recommended mainten-ance procedures and Operation Support Analysis Report (0SAR) 85-73, which was the analysis leading to the establishment of mainten-ance requirements. The analysis identified the need for installa-tion of zerk fittings for lubricating the bearings with Texaco Marfax multipurpose grease at 18-month intervals. Documentation was reviewed which showed the lubricant to be able to withstand a TID of 2.3 x 107 RAD. This TID is well above the dose expected to be experienced by the motors. One motor will be inspected after 3 years of operation to determine the adequacy of the luorication schedule. The licensee replaced the bearings of motor AC-3C during the current outage because the lubricant type was unknown in that moto Documentation for the above maintenance was reviewed and the motors were inspected to determine corrective action implementa-tion, where possible. During the walkdown of the equipment, it was identified that intake grills on two motors were not in plac During the meeting in Region IV on December 13, 1985, OPPD committed to complete the following additional actions concerning CCW motor maintenance prior to operating the plant at power:

(a) Review existing procedures for adequacy and implementatio (b) Revise procedures to show a frequency of about 3 months for cleaning grill (c) Ensure that all grills are in place prior to startu (d) Assure that maintenance orders for motors (all safety-related equipment) require QA review and signoff of work accomplishe d. Generic Implications of Findings Associated with CCW Motors The EQ Master List contains a number of electric motors; however, the CCW motors were selected as a sample during the EQ team inspection, and several deficiencies were identified. As a part of the inspection followup, the NRC inspector reviewed the licensee's corrective actions and determined that they were specific to the CCW motors and did not address the maintenance program for all EQ motors. Therefore, the corrective action with respect to motor maintenance was not considered complete. During the meeting in Region IV on December 13, 1985, the licensee committed to the following additional corrective actions prior to operating the plant at power:

y

_

.

. -6- i

~

i (1) Review maintenance procedures for each motor on the EQ Master List to ensure that maintenance required to maintain qualifica-tion status is adequat '

(2) Perform necessary maintenance when procedtres are found to be inadequate or-if maintenance had not been performed as required -

by current procedure This item will remain open pending further NRC review of the corrective actions committed to by the license . (0 pen) Apparent Violation / Unresolved Item 285/8509-02 Post-Accident Monitoring Instrumentation (PAM)

(a) Previous Findings:

The required accuracies of most PAM transmitters were not established nor compared with transmitter errors reported from quali-fication type testin (b) Corrective Action: 4 The licensee's corrective action consisted of reviewing the questionable instrumentation requirements as outlined in Emergency Procedures (EP) 5, SA, SB, 29, and 36 and comparing the required accu-racies to the accuracies of the instrumentation. The licensee con-cluded that the existing instrumentation was capable of fulfilling its PAM requirements and stated that accuracy requirements would be included in the next revision to the EEQ manua The NRC inspectors reviewed OSAR 85-70 which showed the analysis performed to determine if accuracies of the installed instrumentation would be adequate for the intended functions. These functions include:

(1) Engineered Safety Feature Actuation, (2) Reactor Trip Initiation, and (3) Operator Information. In addition, Wyle Test Report No. 45700-1 and Victoreen Report No. 95031, which established PAM instrumentation accuracies, were reviewed. Revised Table 1 of the EEQ manual was reviewed; it presented the acceptable signal error and the Device (transmitter) error for PAM and other EEQ devices. In most cases the two errors were identical, indicating that all available tolerance was consumed by the transmitters, and no tolerance was available for the remaining instrumentation circuitry. When the total circuit tolerance is considered, it would be possible that the error of the signal being transmitted would exceed the acceptable signal erro Additionally, the NRC inspectors reviewed calibration procedures in Operating Manual XI, Part 8, for containment pressure channels PT-783, PT-784, PT-785, and PT-786, and it appeared that after calibration errors were permitted to be in excess of the acceptable signal error During the meeting in Region IV on December 13, 1985, OPPD committed to take the following additional actions regarding PAM instrumentation prior to operating the plant at power:

, .

-7-

'

(1) Determine the loop error (uncertainty) associated with each PAM instrumentation loo '

(2) Compare errors (uncertainties)'with those permitted by th'e new Emergency Operating Procedures (EOP) and if E0P errors (uncer-tainties) are exceeded, replace existing instrumentation with more accurate instrumentatio (3) Revise and expand EEQ Manual, Table 1 to show errors (uncertain-ties) of instrumentation loops compared to those permitted by the _

new E0P (4) Document results and conclusions of above reviews in EQ records for PAM transmitter '(5) Analyze required operating range of each PAM transmitter to con- '

sider the effect of higher errors (uncertainties) of_ transmitters -

when operating in the lower part of the operating rang This item will remain open pending further NRC review of the corrective actions committed to by the license . (Closed) Apparent Violation / Unresolved Item 285/8509-03 Conax Electrical Penetration Assemblies (a) Previous Findings:

Electrical penetration assemblies (EPA) had been modified with Dow Corning silicone rubber RTV. Qualification after the modification had not been adequately demonstrated and/or documente .The NRC inspectors reviewed documentation which identified 90 question-able EPA Teflon seals and conductor insulation in the units failed qualification tests and had been modified by applying RTV silicone rubber to the effected areas, but had not been qualified after the modificatio EEAR FC-85-009, dated January 12, 1985, identified the subject EPAs as being unqualified and recommended their replacement; however, there was no evidence at the time of the EQ team inspection that the licensee had made a decision to replace them, and it was not clear if the modi-fication was to be substituted for replacing the EPA The questionable EPAs contain 480 VAC cables which provide intermittent service to MOVs and to PORV solenoids and continuous 125 VDC, in the milliamp (ma) range, to instrumentatio (b) Corrective Action:

The licensee elected to replace the EPAs with new qualified t. nit The EPA qualification packages were reviewed by the NRC inspector The System Component Worksheet (SCEW) showed qualification of the

- _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ - - _ -

- . _ _ . .

. , .

'

,

, .  :

'

.

l-8-

~

replacement units to a 40 year life based on type tests. Qualifica- -

tion was substantiated by reviewing a Sargent and Lundy report dated November 15, 1985,-in which the Arrhenius methodology supported a qualified life greater than 40 year Test data for the model were based on Conax Report No. IPS-1319, dated October 30, 1985,- in which items similar to Conax replacement EPAs had been tested in an environ-ment more harsh than that expected at Fort Calhoun. The tested con-ductor sealant material (Polysulfone, 0.84ev activation energy) and conductor material (Kapton Polyimide Filen, 0.915ev activation energy)

were identical to the material in the replacement EPAs. Testing of these properties had been reported in Conax Report IPS-325, dated August 16, 198 Based on data reviewed, the NRC inspectors concluded l that EPAs had been qualified for a 40 year _ life, not by type tests as .

l stated on the SCEW sheet, but by provision of f(2) of Rule 50.49 which

! states, " Testing a similar item of equipment with a supporting analy-sis to show that the equipment to be qualified is acceptable."

Purchase Order No. 97233, dated May 16, 1985, issued to Conax for

procuring replacement EPAs was reviewed. Specification No. 1451, dated March 12, 1985, included in the P0, stated a service environment which was more severe than stated on the SCEW shee The licensee explained that the environment in the procurement specification was a generic value and that the predicted environment experienced by items i

'

in the harsh environment were as stated in the EQ manual. The NRC inspectors reviewed OSAR 85-14, dated September 30, 1985, which will

,

update the USAR to state that details of the EQ program were to be included in the EEQ Manual. Values N the SCEW sheet will, therefore,e be in accordance with the U A This item is considered close . (0 pen) Apparent Violation / Unrest,1ved Item 285/8509-04:

States Company Terminal Blocks (a) Previous Findings:

Contrary to paragraph (f) and (k) of 10 CFR 50.49, OPPD did not test

,

specimens of States Company terminal blocks identical to the modified l configuration installed in the plant; qualification was not based solely on testing, and the evaluation of design differences between the plant equipment and specimens actually tested did not adequately establish qualificatio (b) Corrective Actions:

The NRC inspectors reviewed OPPD's analysis of the States Company Terminal blocks (TB) type N1 (0SAR No. 85-74, 7/16/85) wlJch addresses NRC Information Notices (ins) 84-47 and 83-03. The OPPD position is that the OSAR 8b-74 analysis demonstrates qualification of the type NT tbs without credit taken for the RTV application. The NRC inspector also reviewed OSAR 85-23 EQ qualification file, which had been reviewed previously by the NRC inspector during the EQ team

, . .

-9-

.

team inspection, 50-285/85-09, of April and May 198 This qualification file included the General Electric (GE) EQ testing and supporting analysis by Sargent & Lundy (S&L), including a thermal aging analysis by Wyle Laboratorie The inspection revealed sufficient documentation in OPPD's EQ files to demonstrate that the concern about insulation resistance drop (from 1010 to 104 ohms) during LOCA tests (as outlined in IN 85-47 during Sandia testing), did not jeopardize any safety function as demon-strated by the above mentioned analysis. However, there is uncertainty about the condition of the RTV barrier, which may have been damaged during repairs or modifications; such damage could create unknown current leakage conditions in the presence of a harsh environment, where the moisture intrusion barrier of the RTV had been broken, and moisture could buildup in holes and cups, et This matter remains ope Further, the inspection revealed that OPPD did not reapply RTV nor did procedures exist for reapplication of the RTV, when terminations were removed /added to tbs during routine station modifications, maintenance, and surveillance activities. RTV was applied apparently to provide a moisture intrusion barrier to all terminations in junction boxes within the harsh environment. Additionally it was also noted that the RTV was applied during the construction of the Fort Calhoun Station as a wide spread practice by Gibbs & Hill, the architect engineer (AE). The RTV was applied to terminations after the QC inspection was complete In OPPD's response letter to the NRC dated October 11, 1985, and at a subsequent meeting in Region IV on December 13, 1985, a commitment was made to change out the tbs to Raychem qualified nuclear splices for:

two pressurizer pressure control circuits, four HPSI loop flow cir-cuits to Foxboro transmitters, and two RPS/ESF pressurizer pressure Foxboro transmitter circuits. The remaining equipment identified in the EQ team inspection, was qualified by the above mentioned OSAR 85-74 analysis. This involved only ASCO pilot solenoids for air operated valves, with their associated NAMCO limit switche OPPD committed to the following actions of providing qualified terminal blocks: (1) to implement an inspection program identifying those areas where the RTV had broken barriers on tbs (estimate 80 to 100); (2) to repair damaged RTV in those areas, controlled by new pro-cedure, (special process) and (3) to reinspect the subject tbs in accordance with their QA/QC progra Reinspection under OPPD's main-tenance order would constitute a visual inspection of completed work, verification of RTV adherence, proper junction box drainage, and an appropriate QC/QA signof OPPD stated that the foregoing actions would be completed before the plant was returned to power operatio This item remains ope o .< .

-10-

,

6. (0 pen) Apparent Violation / Unresolved Item 285/8509-05:

Rockbestos (Cerro) Pyrotrol III Cable (a) Previous Findings:

Contrary to paragraph (f) and (k) of 10 CFR 50.49, 0 PPD did not test specimens of Rockbestos Pyrotrol III cable identical in composition to the cable installed in the plant; qualification was not based solely on testing, and the evaluation of differences between the plant-cable and the specimens actually tested did not adequately establish qualificatio (b) Corrective Actions:

OPPD's attempt to qualify Pyrotrol III cable by similarity to Firewall III, as reviewed during the EQ team inspection during April and May 1985, had been replaced with OPPD's qualification file No. OSAR 85-72. The NRC inspectors reviewed the OPPD analysis and the Franklin Report (F-C3348, April 1972) which were contained in their qualifica-tion file OSAR No. 85-72. The F-C3348 Franklin tests involved cable splices with Pyrotrol III cable, for the original Fort Calhoun Station containment penetration splices (no longer installed). OPPD has elected to take credit for the cable qualification aspects of the F-C3348 testin The NRC followup inspection revealed that the F-C3348 Franklin Report contained sufficient documentation to demonstrate Rockbesto; (Cerro)

Pyrotrol III qualification during LOCA testing under the D0R guideline-

,

requirement The cable specimens were unaged, as permitted under D0R guideline The test report contained documented test data sheets, strip chart and multipoint recordings, and a' list of instrumentation used during the test. The test report indicated that tests were '

closely monitored and controlled by a test plan. No test anomalies were identified related to cable qualification. The NRC inspector compared the five 3-hour DBA steam-temperature (included chemical spray) profiles of this test to the MSLB/LOCA environments of the Fort Calhoun EEQ Manual. The five test pcofiles enveloped the '

Fort Calhoun LOCA environments adequatel The Fort Calhoun MSLB environment was above the test profiles for 35 seconds with a 355 F peak. However, the MSLB qualification inside the containment is I.ot required for Fort Calhoun, as permitted by the 00R guidelines for plants with fully-automatic redundant containment spray system The NRC inspection revealed that the OPPD analysis of the OSAR 85-72 qualification file was adequate to address the radiation and aging aspects of Pyrotrol III cable qualification'under DOR guideline requirement The analysis indicated the Pyrotrol III cross linked polymer (XLPE) to be suitable for 1 x 108 rads TID in accordance with EPRI Report NP 212 This was well above the expected exposure for gamma and beta, including

_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ ,

- ~

- .

,

=

.. ., .

-

,

'

. a

,

',

'

<

s

.

'

-11- I

~ 1 worst case background radiation. Wyle Laboratories, ' Report No. 26333, ,

"

October 1980; was included in: support of the exp'ected beta' radiation effects. ' The' analysis using the Arrhenius methodology also indicated -

a 40 year ' qualified life (QL). for Pyrotrol _ III cable, for the worst'

case conditions inside the conta_inment, considering heat rise due to

,

motor loads, ampacity, and duty cycle. The HPSI pump motors and con-tainment vent fan motors were selected to represent.the worst cas The NRC inspectors concluded that sufficient documentation existed'in OPPD's EQ files to demonstrate that Rockbestos (Cerro) Pyrotrol III cable is qualified in containmen During,the inspection, however, it was revealed that the ambient temperature of room 81 (Aux b1dg) was not considered during the ther-mal aging calculation of the Pyrotrol III cable used outside the con-tainment. The ' cable in question was the Pyrotrol III cable which was" ,

routed through. room 81 to the containment for the containment vent' fan -

cooling motors. Rough calculations. indicated a QL of less than  ;

40 years. At the time of the inspections, OPPD was in the process of-evaluating conservatisms to this methodology. OPPD proposed.to'take'

credit for redundant cables to the vent fan motors,'and to reevaluate

'

the duty cycle. calculations, to reduce the heat rise factors in .the >

Arrhenius equation. OPPD committed to formalize these analyses and place them in their EQ qualification fil OPPD'also committed to 1 recheck a sample of EQ equipment outside?the containment, where'ther-ma! aging calculations were used in their analyses applied to

<

Pyrotrol III cable qualificatio If these analyses.do not demon-  ;

, strate a qualified life of at least 40 years, they will establish ~ a '

time at which the cables must be replace This item remains ope '

J

. (Closed) Apparent Violation / Unresolved Item 50-285/8509-06: '

Definition of Harsh Radiation Environment (a) Previous Findings:

The licensee had not established that no EQ equipment could be degraded by a . total radiation dose of 1.0 x 105- rad The NRC concerns were related to Regulatory Position C.4.C, discussed in Regulatory Guide 1.89, Revision 1, with regard to equipment exposed to low-level radiation doses with damage thresholds greater than 104 rads; generally data exists to show that components containing

)

. organic materials would remain functional for a TID of 1.0 x 10s rads; but for electronic components failures in metal oxide semiconducto ,

devices can occur at somewhat lower dose .

(b) Corrective Action:

OPPD addressed the concern about choosing a radiation threshold dose .l low enough to ensure that radiation damage to master list equipment j

,

.

_ . _ _ ,

,

,

• .

" .

c .. e

.

,

-12- -

.

was adequately considere OPPD's scree'ning criteria for radiation i

dose effects were reviewed during the followup inspection' effor The NRC inspectors reviewed the OPPD EQ program documents which establish the new screening criteria: (1) EEQ Manual, Enclosure 1, ,

Revision 1, "EEQ Program Users Guide", September 20, 1985; (2) OSAR 85-33, "EEQ Environmental Determination," April 29, 1985, and -

(3) OSAR 85-69."EEQ Mild Environment," September 25, 198 OPPD revised the above documents to reflect a screening criterion in the range of 105 to 10s rad for electric cquipment requiring equipment

-

evaluation on an individual basis for its applicability, using caution -

when epoxy resin or nylon is involved. This criterion w&s supported by the review and tests conducted by EPRI (Report NP-2129) and con-firmed by EPRI Report NP-4172 M which cautions about the use of epoxy '

resin or nylo '

OPPD's screening criteria for electronic components were revised to reflect 10s rads in the above document OPPD has identified and evaluated each piece of equipment using the new screening criterion, both for electronic and electric equipment.-

The evaluation considered all EQ equipment on a case by case basis fo applicabilit This item is considered close . (Closed) Open Item 285/8509-07: Completion of Procedures (a) Previous Finding:

Three isolated deficiencies were identified:concerning inadequate EQ Procedure (b) Corrective Actions: +

.

The NRC inspectors reviewed SO G-21, Revision 24, dated September 26, 1985, " Station Modification Control" and Administrative Procedure A-6, dated August 1985, " Electrical Equipment Qualification Control File (EEQCF) Control and Updating." Resolution of the concerns' expressed during the EQ team. inspection was verifie This item is considered close . (Closed) Open Item 284/8509-08: Containment Ambient Temperature (a) Previous Findings:

Containment ambient temperatures of 85 F were used in OPPD's thermal aging calculations in their qualification files for replacemt at trans-

- .__.

,,_ ,

.

. .. . .

,

. ,

/

-13 -

.

'

- mitters used in containment. Occumentation in support of this value-

, was requested, but the item remtined open at the close of NRC team inspection.

'

-(b)' Corrective Action:

. '

The NRC inspectors reviewed OPPD's analysis (0SAR-85-67, July 19, 1985),

whicht (1) demonstrates the correctness of the normal EEQ containment operating temperature environment of 85*F; and (2) establishes actual temperature margins for each type of equipment in the containment and 6 demonstrates the conservatism used by OPPD in their determination of <

'

EEQ program QL. These margins demonstrate qualification to 90 F with no required rebuilding or maintenance of the equipment. OSAR-85-67 was reviewed by the NRC as supplemental to OPPD's response letter to

'

the NRC, dated October 11, 198 The NRC inspectors reviewed the Arrhenius methodology calculation used to determine equivalent aging for the equipment with the highest degree of sensitivity to temperature excursions over 85*F (Target Rock

\

solenoids). The calculation demonstrated less degradation than would be expected if the material were aged at a constant 85*F without vari-

ation throughout its qualified lif The NRC. inspectors reviewed OPPD's calculations for each type of equipment in containment to demonstrate conservatisms used by OPPD in their EEQ program in determining QL. Ea-h type of equipment was con-sidered for required QL plus ten percent; OPPD demonstrated qualifica-tion to an equivalent containment ambient temperature of 90* This open item is considered close . Exit Meeting Tne NRC inspectors met with licensee representatives on November 22, 1985, to discuss the scope and findings of the inspection. The NRC inspectors and Regional Staff. met with licensee representatives in the Region IV offices on December.13, 1985, to discuss the corrective actions to be taken with regard to EQ Team Inspection Report 50-285/85-09 and the corrective actions which were still needed to resolve issues raised during-the November 18-22, 1985, followup inspectio e

,

k J"

<

,

os