IR 05000333/1989016

Insp Rept 50-333/89-16 on 890710-14.No Violations Noted. Major Areas Inspected:Status of Previously Identified Open Items & Adequacy of Licensee Actions to Resolve Issues.One Addl Item Remain Open Pending Issuance of Procedures

ML20247K616
Person / Time
Site:	FitzPatrick
Issue date:	09/06/1989
From:	Anderson C, Della Greca A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247K603	List: IR 05000333/1989016 ML20247K597
References
50-333-89-16, NUDOCS 8909210213
Download: ML20247K616 (7)

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U.S. NUCLEAR REGULATORY COMMISSIO REGION I Report No .50-333/89-16 Docket N License N DPR-59-Licensee: Power Authority of State of New York P.O. Box 41-Scriba, New York Facility Name: James A. Fitzpatrick Nuclear Power Plant (JAFNPP)

L Inspection At: Scriba, New York Inspection Conducted: July 10-14, 1989-Inspector: 't/ A L4r '

A. L. Della Greca, Weactor Engineer, PPS/EB date

' Approved by: MIMF J. Anderson, Chief, Plant Systems Section, date ngineering Branch, DRS

. Inspection Summary: Inspection of July 10-14, 1989 Areas Inspected: Announced inspection by regional personnel to review the status of previously identified open items and to determine the adequacy of the licensees actions to resolve these issue Results: The inspector determined that the licensee has satisfactorily responded

.to:four open items. One additional item will remain open pending the licensee's issuance of procedures to address the purchase and dedication of commercial grade components used in safety related applications. No new violations were identifie PDR ADOCK 05000333 g PDC L _ __ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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DETAILS 1.0 Persons Contacted New York Power Authority (NYPA)

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W. Fernandez, Resident Manager R. Liseno, Superintendent of Power T. Landers, Superintendent of Material Control v. Walz, Technical Services Superintendent A. Brais, Procurement Engineering Supervisor K. Moody, Plant Engineering Technical Services J. Mangano, Quality Assurance Engineer All of the above personnel were present at the exit meeting of July 14, 198 .0 Purpose The purpose of the inspection was to review the status of previously identified items and to determine the adequacy of tne licensee's corrective actions in resolving each issu .0 Status of Previously Identified Items 3.1 (0 pen) Violation (Item No. 50-333/87-14-02) nvolving the licensee's failure to provide documentary evidence that critical component characteristics had been met for commercial grade equipment used in safety related application During the original review, the inspector noted that Procedure N ;

EDP-16 provides the means for procuring commercial grade replacement parts and equipment for use in safety related application However, i the checklist which must be completed for this purpose (Enclosure 6.1, Part II, to the procedure) only ensures that the equipment or parts are available as commercial grade items. Neither the checklist i nor the procedure imposes requirements to ensure that the commercial parts being purchased exhibit the critical characteristics necessary for their use in the safety related applications. The inspector also identified two examples of commercial grade components which had been declared to be safety related, but for which no requirements had been specified on the checklist to ensure their suitability for the intended applicatio The deficiency was identified as a violation of 10 CFR 50, Appendix B, Criterion VII, which states, in part, that: " Documentary evidence that material and equipment conform to procurement requirements shall be available..." In response to the Notice of Violation, letter s

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No. JAFP 87-0905, dated November 5,.1987, the licensee disagreed with the NRC's finding. The disagreement was primarily based upon the -

facts that:

~ The original equipment design utilized commercial component The licensee's engineering review of the components' technical l requirements had concluded that no special seismic testing was necessary. The basis for this conclusion was that the original seismic tests were conducted on the housing equipment rather than on the components themselve In addition, the licensee clarified that for the first example (General Electric's relay P/N 225A5365P001) the devices were already in stock, having been obtained as spares from the original equipment supplie For the- second example (General Electric's type AB-40 meters), the licensee specified that its subsequent investigation had determined

- the devices to be available as qualified components and that, therefore, it had taken steps to procere them as suc '

Although the explanation provided by the licensee and confirmed by the inspector, during the current review, resolves the safety concerns relative to the specific examples discussed above, it does not address the inspector's underlying concern relative to the use of commercial grade components in safety related applications without 6ppropriate evaluation,' dedication, testing and documentation of their suitability for the intended functio The procurement of a commercial grade device with the same commercial attributes as found in the original equipment does not guarantee its suitability for the same application unless its manufacture is supported by an appropriate Appendix B program and/or dedication. Also, seismic tests conducted on the housing equipment do not exempt the component from seismic requirements. Therefore, the violation is justified and stands as state During the current review, the inspector observed that a revised version of Procedure No. EDP-16, scheduled to be issued in early 1988, according to the above noted letter, was still unsigned. A related procedure, EDP-31, designed to address dedication of commercial grade equipment and parts was also waiting to be issue To ensure that no safety concerns exist in the procurement of commercial grade spare parts the inspector evaluated a small sample of recent procurement technical reviews. The evaluation showed marked improvements over the older checklists. However, the review showed some inconsistent-cies and errors, which are indicative o' the licensee's need for finalizing and issuing the applicable procedures. No safety concerns were observe This item will remain open pending the licensee's finalization and issuance of Procedures EDP-16 and -31 and the NRC's further evaluation of the licensee's practices for procuring and dedicating commercial grcde components and equipmen i

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3.2 (Closed) Violation (Item No. 50-333/87-14-11) regarding the lack of qualification documentation for Class B, DC motors used with Limitorque operators inside containmen During the original inspection the NRC noted that the qualification file for Limitorque motor operators did not contain an analysis to show similarity between the installed DC, Class B, Peerless motors and the tested AC, Class B, Reliance motors. The qualification was primarily based upon statements from the valve operator's manufacturer and the architect-engineer (AE). Accordingly, the licensee concluded that the Peerless motor's materials were equal to or better than those found in the Reliance motor The lack of similarity analysis was determined to be a violation of 10 CFR 50.49, paragraphs (f) and (g) which require that: Qualification of each item of electrical equipment be based on testing or experience with identical equipment or with similar equipment with supporting analysis to show that the equipment is accr. tabl . Each item of electrical equipment important to safety be qualified and that qualification be completed no later than November 30, 198 In its response to the Notice of Violation, the licensee disagreed with the NRC finding indicating that the materials used for the motor's insulation system are proprietary information and, therefore, the materials' analysis could not be found in the qualification packag In addition, the licensee stated that the materials' analysis performed by the AE had been performed in accordance with the AE's Quality Assurance (QA) program. As such, the analysis was valid and required no separate review to demonstrate qualificatio Evaluation of the AE's trip report, used by the licensee for quclifi-cation, shows that the material analysis was performed by the AE in conjunction with Wyle Laboratories. However, the report neither states that the analysis was performed under a QA Program nor does it identify the presence of an AE's QA person. In addition, the trip report provides no assurance that the similarity analysis was performed by qualified individuals. With respect to the proprietary nature of the insulation system's materials the qualification file provides no indication that material lists were requested from the motor manufacturer Based on the above, the use of the trip report as a basis for similarity is considered to be inadequate proof of qualificatio Therefore, the violation assessed is justified and stands as state _ - _ - - _ _ _ - _ _ _ - _

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.Following the original inspection, the licensee conducted an independent review of the AE's similarity analysis. The results of the licensee's review were added to the qualification. package in questio This item is close ,

33 (Closed) Violation (Item No. 50-333/87-14-12) pertaining to the qualification of Limitorque Motor Operated Valves (MOV) at reduced voltag Review of the Limitorque MOV qualification package during the original inspection showed that it contained no analysis to demonstrate th capability of the motor operators ~to perform their intended safety functions under reduced voltage conditions, i.e., 518 VAC. The lack of analysis was determined to be a violation of 10 CFR 50, paragraphs (f) and (g), which are stated in the previous paragraph In its response to the Notice of Violation, the licensee disagreed with the NRC's violation assessment stating that the. capability of the motor operator to perform at reduced voltages is taken into account by the manufacturer's appropriate sizing of the motor. The licensee's position is based upon a similar' statement found in Limitorque's qualification repor The NRC inspector agrees that a qualified and appropriately sized motor operator is capable of performing its safety function under degraded voltage conditions. However, the licensee's qualification

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packago contained no test data to establish a relationship between voltage, accident temperature and torque developed. Moreover, the file contained no analysis by the licensee to ensure that the manu-facturer had sized the motors such that they would be capable of developing the required torque. Therefore, the licensee could not be sure that the motor operators would be able to perform their safety functions under the accident and degraded voltage. conditions. In view of the above, the violation is considered to be justified and stands as state As stated in Report No. 50-333/87-14, during the original inspection period the licensee performed such analysis and demonstrated the capability of the motor operators in question to perform the required function at 518 VA This item is close .4 (Closed) Violation (Item No. 50-333/87-14-17) pertaining to the in-adequate qualification of General Electric's canister type electrical penetration __-___-__ _ _

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Review of._ the qualification package for General Electric's canister type electrical penetrations revealed the existence of the following deficiencies in the environmental qualification of the devices: Required minimum cable insulation resistance greater than the one registered during qualification testin Plant LOCA profile not enveloped by test LOCA profile with peak temperature reached 45 minutes after onset of even Inadequate analysis to support qualification of penetration in the plant's specific radiation environmen Inadequate analysis to support extrapolation of accident test profile to required 180 day Penetration's _ leakage requirements not enveloped by leakage test

~ result Qualification of GE coaxial cable not supported by repor Discrepancy between radiation requirements for GE and Conax penetration Response to NRC Information Notice IEN 86-104 not addressed by the qualification file.

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Evaluation of the revised qualification package, QDR No.15.1, shows that the licensee adequately addressed each of the above NRC concerns and that it performed the analyses require This item is closed.

i 3.5 (Closed) Violation (Item No. 50-333/88-25-01) relative to the finding I

of unqualified Okonite caole splice During the physical examination of Limitorque Valves No. 02-MOV-53A & B the inspector discovered that the splice configuration did not comply with the installation requirements for a qualified Okonite splic Specifically, the requirement for two half-lapped layers, each, of T-95 (red) and T-35 (black) tape had not been observed. This was evidenced by the fact that the red tape was visible at the end of the splice. In addition, the measured overlap was less than the requireo 3/8 to 1/2 inc Corrective actions by the licensee included replacement of the improperly installed splice, review of possible causes for the deficiency, i: reinspection of at least one splice performed by each electrician L during the last outage, hands-on training of all personnel involved in the installation and inspection of the splice Upon review of appropriate documentation, including training records, the inspector found the corrective actions taken by the licensee to adequately resolve the violatio This item is closed.

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4.0 Exit Meeting The inspector met with the licensee's personnel denoted in paragraph I of this report at the conclusion of the inspection period on July 14, 198 At that time the scope of the inspection and the inspection results were summarized. At no time during the inspection was written material given to the licensee.

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