IR 05000334/1986012
| ML20215M966 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/30/1986 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20215M965 | List: |
| References | |
| 50-334-86-12, NUDOCS 8611040065 | |
| Download: ML20215M966 (18) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEFENT Report No.:
50-334/86-12 Doclet No.:
50-334 Licensee:
Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077
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Facility Name:
Beaver Valley Power _Stai. ion, Unit No. 1 Inspection At:
Beaver kalley Power Station Shippingport, Pennsylvania Inspection Conducted:
June 9-13, 1986 Id 28' 8[
Inspector:
R. C. Wilson, Equipment Qualification Date and Test Engineer Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, I&E R. H. Lasky, Equipment Qualification and Test Engineer, I&E R. J. Paolino, Lead Reactor Er.gineer, Region I M. Dev, Reactor Engineer, Region 1 W. R. Carpenter, Consultant Engineer, Idaho National Engineering Laboratory M. Trojovsky, Consultant Engineer, Idaho 11ational Engineering Laboratory M. Jacobus,, Member of Technical Staff, Sandia National Laboratories
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Approved By:
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(0 -30- E U. Potapovs, Chief, Equipment Qualifica-Date tion Inspection Section, Vendor Program Branch 8611040065 861031 PDR ADOCK 05000334 G
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A INSPECTION SUMMARY Inspection on June 9-13, 1986 (Inspection Report No. 50-334/86-12)
Areas Inspected: Special, announced inspection to review the licensee's implementation of a program per the requirements of 10 CFR 50.49 for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49.
Results: The inspection determined that tne licensee has implemented a program to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed
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below.
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Name
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Report. Paragraph Item Number Potential Enforcement / Unresolved Items:
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Continental cable 4.E.(1)
50-334/86-12-1 2.
Rosemount transmitters 4.E.(2)
50-334/86-12-2 3.
Victoreen High Range Radiation Monitor 4.E.(3)
50-334/86-12-3 4.
Limitorque operator 4.E.(4)
50-334/86-12-4 5.
Barton transmitter 4.E.(5)
50-334/86-12-5 6.
Rockbestos cable 4.E.(6)
50-334/86-12-6 Open Item:
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Equipment file discrepancies 4.E 50-334/86-12-7
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DETAILS
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Persons Contacted 1.1 Duquesne Light Company (DLC):
J. J. Carey, Vice President, Nuclear Group
- N. R. Tonet, Gen. Mgr., Nuc. Engrg, and Construction Unit T. D. Jones, Gen. Mgr., Nuclear Operations Unit
- C. E. Ewing,. Manager, Quality Assurance Unit
- H. M. Siegal, Manager, Nuclear Engrg. Dept.
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- W. S. Lacey, Plant Manager, Unit 1
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R. L. Hansen, Director, Site Maintenance
- J. Gazdacko, Director, Materials Management G. A. Kammerdeiner, Dir., Mtis. and Stds. Engrg.
- K. D. Grada, Manager, Nuclear Safety Dept.
F. Lipchick, Sr. Licensing Supervisor
- F. A. Oberleitner, Principal Engineer-EQ
- C. D. Schmitt, Director, Electrical Engineering
- E. E. Knapek, Sr. QA Specialist
- J. J. Baumler, Supervisor, 0QC
- C. R. Haney, Director, T&C Training
- A. R. D'Amico, Sr. Engineer
- R. F. Balcerek, Manager, Mang. Serv.
- M. J. Mirchich, Procurement Engineer
- W. Laughlin, Sr. Engineer-Unit 2 H. Caldwell, Director, I&C, Unit 1 M. Johns, I&C Engineer W. Koecher, I&C Instructor (0p./Maint.)
- E. Eilmann, Sr. Engineer-Unit 2
- K. Woessner, Engineer-Unit 2 W. J. Brady, Op. and Maint. Instructor D. R. Carothers, Supv., Electrical Maint.
J, E. Starr, Supv., Engrg., Man Services K. B. Lowrie, Supv., Material Procurement 1.2 DLC Consultants-Schneider Consulting Engineers:
- J. Archer, Manager, Tech. Services
- D. Suhan, Project Engineer 1.3 US NRC:
- W. M. Troskoski, Senior Resident Inspector
- A. A. Asars, Unit 1 Resident Inspector
- L. J. Prividy, Unit 2 Resident Inspector
- Denotes those present at exit meeting at Beaver Valley Power Station on June 13, 1986.
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2.
PURPOSE The purpose of this inspection was to review the licensee's implementation of a program to meet the requirements of 10 CFR 50.49.
3.
BACKGROUND The NRC held a meeting with DLC on April 5,1984 to discuss DLC's proposed methods to resolve the EQ deficiencies identified in the December 16, 1982 Safety Evaluation Report and September 10, 1982 FRC TER. Discussion also included DLC's general methodology for compliance with 10 CFR 50.49 and justification for continued operation (0CO) for those equipment items for which environmental qualification was not completed. The minutes of the meeting and proposed-method of resolution for e'ach of the EQ deficiencies were documented in a DLC submittal dated November 29, 1984. The final SER transmitted March 7,1985 identified that certain equipment was still under JCO. At the time of the inspection, no JCOs or extensions applied. Staff review of the licensee's R.G.1.97 submittal dated November 29, 1985 was in progress at the time of the inspection; qualification of additional post-accident monitoring equipment may be required at a future date as a result of that review.
4.
FINDINGS The NRC inspectors examined the licensee's program for establishing the qualification of elect'ric equipment within the scope of 10 CFR 50.49. The program was evaluated by examination of the licensee's qualification documentation files, review of procedures for controlling the licensee's EQ efforts, verification of adequacy and accuracy of the licensee's 10 CFR 50.49 equipment list, and examination of the licensee's program for maintaining the qualified status of the covered electrical equipment.
Based on the inspection findings, which are discussed in more detail below, the inspection team determined that the licensee has implemented a progr.am to meet the requirements of 10 CFR 50.49, although some deficiencies were identified.
A.
EQ Prooram Procedures The inspectors examined the implementation and adequacy of the licensee's EQ program by reviewing the following procedures:
Site Administrative Procedure No. 31, Revision 0, entitled
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" Equipment Cualification Program."
Nuclear Engineering and Construction Unit Management Procedure
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No. 2.14, Revision 1, entitled " Environmental Qualification of Class 1E Electrical Equipment."
Material Management Services Procedure No. 31.0, Revision 2,
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entitled " Purchase Requisitions."
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Nuclear Engineering and Construction Unit Management Procedure
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(NECUMP) No. 2.7, Revision 0, entitled " Engineering Specifications."
Procedures Section Procedure No. 3.7, Revision 0, entitled
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" Equipment Qualification Maintenance Assessment Package."
Maintenance Manual Section AA, Revision 0, entitled " Equipment
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Qualification Program."
Instrumentation & Control Administrative Manual,.Section N,
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Revision 0, entitled " Equipment Qualification Program."
Nuclear Engineering and Construction Unit Man'ag'ement Procedure
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No. 2.8, Revision 3, entitled."Fandlihg of Design Change Packages."
Operations Quality Control Manual.
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Nuclear Engineering Management Procedure No. 2.13, Revision 2,
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entitled " Design Verification Guidelines, Methods and Requirements."
Material Management Services Procedure No. 30.0, Revision 2,
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entitled " Stock Item Requests."
In addition, the NRC Inspectors wees given a presentation describing the licensee's EQ, program during the entrance meeting in which require-ments and procedures covered in the above documents were discussed.
The licensee's program was reviewed to verify that adequate procedures
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and controls had been established to meet the requirements of 10 CFR 50.49. Areas of the program reviewed included methods and their effectiveness for:
Requiring all equipment that is located in harsh environments
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and is within the scope of 10 CFR 50.49 to be included on the Master List of equipment requiring qualification.
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Controlling the generation, maintenance, and distribution of
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the EQ Master List.
j Defining and differentiating between mild and harsh environments.
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Establishing harsh environmeatal conditions at the location of
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equipment through engineering analysis and evaluation.
Establishing, evaluating, and maintaining EQ documentation.
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Training personnel in the environmental qualification of
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equipment.
Controlling plant modifications including installation of new
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and replacement equipment, and providing for updating replacement equipment to 10 CFR 50.49 criteria.
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Site Administrative Precedure Chapter 31 describes the Beaver Valley Power Station, Unit 1 (BVPS-1) program for addressing the environ-mental qualification of electrical equipment important to safety for compliance with the requirements of 10 CFR 10.49. This procedure applies to all site personnel and consultants who perform services for BVPS-1 relating to electrical equipment important to safety. The overall electrical EQ program involves the completion of various tasks involving several groups within the DLC organization for different types of electrical equipment considered iriportant to safety in accordance with 10 CFR 50.49. The equipment qualification tasks pertain to:
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1) maintaining the Electrical Equipment Qu,alification Master List, 2) qualifying electrical equipment types, 3) independent aging assessment of equipment and associated parts, 4) determining equipment / component replacement periods, 5) conducting maintenance on equipment to preserve its qualified condition, 6) procuring qualified spare parts and replacement equipment, 7) coordinating E'Q testing, 8) submitting qualification summary reports to the NRC, and 9) performing periodic quality assurance audits of the EQ program.
NECUMP Procedure 2.14, Revision 1, defines responsibilities and describes the methods and processes established by the Nuclear Engineering and Construction Unit (NECU) for validating and documenting the environmental qualification of Class 1E equipment in BVPS-1 in accordance with 10 CFR 50.49.
Tne NRC inspectors concluded that the procedures have been prepared or revised to include EQ requiremants. The EQ program appears well planned, documented, and implemented as required by 10 CFR 50.49.
The EQ files for BVPS-1 contain environmental and equipment data.
The files describe and tabulate the normal and accident conditions
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The files contain documents that establish environmental and perfor-mance qualification for component types.
NECUMP 2.14, Revision 1, defines responsibilities and describes the methods and processes established for validating and documenting the
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environmental qualification of Class 1E equipment in accordance with l
10 CFR 50.49 requirements.
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These procedures were reviewed and found acceptable for documenting environmental and equipment oualification parameters.
NECUMP Procedura 2.7, Revision 0, establishes responsibilities, requirements ard guidelines for the preparation, review, approval, distribution ard revision of engineering specifications issued for procurement. Section 4.2.2 of this procedure states, in part, that
"If the specification has been prepared to procure safety-related electrical equipment, the engineer shall forward the specification to the environmental qualification coordinator (EQC) for an appro-priate review of environmental and seismic criteria...."
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Procedure MMS 31.0, Revision 2, provides'~ instructions for the prepar-ation, review and approval of Purchase Req'uisitions originated for the Nuclear Group and processed by Material Procurement. Section 5.1.5 of this procedure states that Purchase Requisitions for Class 1E compo-nents, replacement parts and spare parts shall be reviewed by the NECU EQ group prior to issue and that the Material Procurement Supervisor or his designee shall forward the Purchase Requisition via an engineer-ing memorandum to the EQ group for review of the environmental qualification requirements.
Other controls in place for procurement include:
Nuclear Group Directive No. 3, entitled " Purchase Requisition Preparation;" Quality Assurance Procedure No. OP-5, entitled " Procurement Control;" Operations Quality Control Procedure No. 0QC 4.2 entitled "OQC processing of Stock Item Requests and Purchase Requisitions;" and Nuclear Division Office Procedure No. 3.1 entitled " Purchase Requisition Procedure."
It is concluded that the licensee has adequate controls to ensure that the environmental qualification of electrical equipment is a procure-ment consideration.
B.
EQ Related Maintenance and Modification The NRC inspectors reviewed the licensee's Equipment Qualification Program.
I&C Administrative Manual Section N and Maintenance Manual Section AA cover maintenance of EQ-related station equipment and components. The licensee has also developed a Procedures Section Procedure (PSP) 37, " Equipment Qualification Maintenance Assessment Package (EQ MAP)." This procedure describes methods of identifying qualified electrical equipment and revising Maintenance /I&C Procedures to ensure compliance with the requirements of 10 CFR 50.49.
Each EQ File has an MAP which outlines required maintenance activities
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including equipment and parts replacement frequencies based on EQ test reports, vendor technical manuals and aging calculations.
The overall EQ Preventive Maintenance Program involves the periodic surveillance and replacement of qualified electric equipment. The testing, inspection, and replacement cycles for equipment or parts as outlined in the MAPS are conducted in accordance with the applicable procedures under the cognizance of the maintenance supervisor.
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EQ-related corrective maintenance is performed through Maintenance Work Requests (MWRs). The maintenance supervisor establishes EO-related maintenance requirements for equipment identified in the Electrical Equipment Qualification Master List.
Prior to performance of corrective maintenance the associated MWRs, MAPS and procedures are reviewed by a responsible engineer.
Failures of EQ-related equipment and components are trended by the Nuclear Engineering and Construction Unit, which is responsible for determining the causes of failures and identifying corrective action to prevent such failures in the future.
The inspectors reviewed the station interim equipmen,t maintenance program with licensee representatives. Under this' program the station maintenance and I&E departments ggrierate a' computer-based components maintenance history. This provides the maintenance status of all EQ equipment, including information related to applicable maintenance procedures, frequency, replacement and modification schedule, and maintenance organization and interfaces. A review of the licensee's preventive maintenance activities of testing, inspection and lubri-cation of 4160V charging pump motors (CH-P-1A, -1B, and -1C), conducted during 1984, 1985 and 1986 supported the adequacy and effectiveness of the licensee's it krim maintenance program at BVPS-1.
The licensee conducts EQ-related plant modifications in accordance '
with Nuclear Engineering Management Procedure (NEMP) 2.8, " Handling of Design Change Packages." The procedure delineates responsibilities and uniform methodology for initiation, preparation, review and approval of modification and maintenance work packages. The changes and revisions to the final design and modification undergo the same review and approval process as the originals. The procedure also requires a safety evaluation for the design changes and modifications.
If any unreviewed safety concern is identified, the licensee obtains NRC approval in the form of a licensing amendment prior to implement-ation. The station FSAR and technical specifications are revised to reflect the design changes and modifications, as applicable, and the related training programs are updated.
The licensee has completed several EQ-related modifications at BVPS-1.
These completed modification packages were not available in hard cover for NRC review. However, the NRC inspectors reviewed an ongoing EQ-related modification, Design Change Package (DCP) No. 690, " Improperly Rated Field Wiring to Solenoid Valves." System Modification Request (SMR)-952 initiated the modification to perform corrective action in response to IE Notice 84-68, to prevent potential failure of the valves due to breakdown of the low temperature rated insulation on the field run wiring. Licensee compliance with the governir.g procedures and 10 CFR 50.49 and 10 CFR 50.59 requirements was considered adequate.
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EQ Master List The licensee is required to maintain an up-to-date list of the equipment that must be qualified under 10 CFR 50.49. Considered in the preparation and maintenance of this list are the environmental effects resulting from all of the postulated design basis accidents documented in the Updated Safety Analysis Reports; Technical Speci-fication limiting conditions of operation; emergency operating proce-dures; Material Equipment and Parts Lists; Piping and Instrumentation Diagrams (P&ID's); and Plant Design Change Requests. The methodology used for producing the EQ Master List is described in the licensee's NECUMP Procedure 2.14 revision 1. ' Equipment that Tes installed in the plant or purchased prior to May 20, 1980 is evaluated to IEB 79-01B which invokes the D0R Guidelines.-~Additio'nal or replacement equipment procured after May 20, 1980 is evaluated to NUREG 0588, Category I criteria. The EQ Master List is maintained under the Site Adminis-trative Procedures, Chapter 31.
In order to test the completeness of the Master List, a total of twenty components was selected for verification from five safety related systems, as follows:
Chemical Volume & Control System (Drawing No. VOND RM-159A-10,
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MOV-CH-275A, B
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Safety Injection System (Drawing No. VOND RM-1678-8)
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MOV-SI-842
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MOV-Sl-865A, B, & C Containment Vacuum & Leakage Monitoring (Drawing No. VOND
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RM-168A-7)
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PT-LM-100A, B, C SOV-LM-100A, B Feedwater (Drawing No. VOND RM-124A-10)
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S0V-FW-488A, B LT-FW-484 LT-FW-485 LT-FW-486
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Reactor Coolant System (Drawing No. VOND RM-155-B-10)
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LT-RC-460 LT-RC-461 The licensee was able to either show that the selected equipment was on the Mastar List or justify its exclusion, using applicable P&ID's, Master List, and the EEQ Environmental file.
D.
Training, QA, and QC Interfaces
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The NRC inspectors reviewed Nuclear Group, raining Administrative T
Manual Chapter 6.
The licensee cenducts general maintenance training in accordance with Section 6.2 of the Manual. Accordingly, the Director, Technical and Crafts Training coordinates and supervises the general maintenance training and is assisted by maintenance super-visors for the training topics, training schedule, and training assign-ment to the maintenance personnel. The licensee has developed Lesson Plan LP-GM-029, " Equipment Qualification" and imparted training to the station technical and maintenance personnel performing EQ-related quality control activities. The inspector reviewed the training rosters for the EQ training given by Schneider Consulting Engineers-dnd by the DLC training department. The training department has updated the indiv.idual training records to indicate the successful implementation of the program. The inspector randomly selected the training records of three individuals, one each from electrical, mechanical, and 18C disciplines and verified that their EQ-related training was authenticated and their training records were consistent.
A discussion with the Training Director indicated that the training department is in the process of developing qualification cards for each individual task.
Quality Assurance Procedure section OP-1 outlines the licensee's QA Program commitment for the operation of Beaver Valley Unit-1 Nuclear Power Plant.
Section OP-2 of the procedure identifies the organiza-tional structure and the responsibilities for the development, imple-mentation and maintenance of the Operation Quclity Assurance Program.
Accordingly, the Vice President Nuclear Group, assisted by the General Manager Nuclear Engineering and Construction Unit is responsible for the BVPS-1 EQ Program implementation. The General Manager has dele-gated his responsibility to the Manager, Nuclear Engineering Department and the Director, Materials and Standards Engineering. His staff develops and maintains the EQ Program, the EQ Master List, Maintenance Assessment Packages, and EQ Files; identifies corrective actions; monitors revisions to the plant environmental service conditions, and assists in the procurement of EQ-related equipment. The Manager, Nucloar Engineering Department and the Manager, Nuclear Construction Department coordinate EQ-related equipment modification and install-ation. The station EQ-related activities, including design changes and modifications, procurement, ver. dor interface, engineering resolution of nonconformant materials and procedures, safety evaluations and analyses, personnel training, collection, storage and maintenance of
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project files are conducted in accordance with DLC's approved QA
Program procedures and applicable departmental instructions.
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The Quality Assurance Manager is responsible for establishing and managing the Operations QA Program including EQ. He is also respon-sible for defining and measuring the overall effectiveness of the QA Program and has direct communication access to the Vice President, Nuclear Group. This provides the QA Manager and his staff the responsibilities, authority, and organizational freedom to identify
quality problems; initiate or recommend solutions; and verify imple-mentation of corrective action. The Quality Assurance Audit Group audits all participating organizations for compliance with the Operations Quality Assurance Program, depar.tmental.precedures, admini-l strative control' procedures, quality control procedures, regulatory requirements, and applicable instructions such as vendor bulletins.
The QA quality control group conducts quality engineering verification, receiving inspection, and surveillance and monitoring activities including environmental qualification at BVPS-1.
The Nuclear Engineering Department is responsible for the final review and documentation of the environmental qualification of the electrical equipment and components at BVPS-1. The Operations Quality Assurance Audit Group verifies the licensee's compliance with the EQ Program requirements delineated in 10 CFR 50.49 and the licensee's Site
Administrative Procedure (SAP) Chapter 31, and NECUMP Procedure
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(NECUMP) 2.14.
The inspector reviewed the licensee's QA Audit Nc.
BV-1-85-40, " Environmental Qualification of Electrical Equipment,"
dlong with the response of the audited organization. The audit addressed the adequacy and effectiveness of administrative control in establishing and maintaining EQ files. The audit identified two findings:
(1) auditability of EQ documentation; and (2) maintenance of EQ equipment.
It also identified one observation related to
procurement of EQ related replacement equipment.
In-response to the internal audit findings the licensee revised
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i NECUMP 1.2.1 to formalize a method to maintain EQ Files. Site i
Administrative Procedure 31 was also revised to include the interim control of maintenance activities for qualified electrical equipment.
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The licensee reviewed the procurement, storage and handling of EQ-related spare parts and replacements and verified that the replace-ment equipment was qualified and maintained in accordance wi.2
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EQ Documentation Files
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The overall EQ files are organized as follows:
Master List
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General
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Procedures IEB's, IEN's, IEC's
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Training (records in training department files)
Reference Information NRC Submittals/ Correspondence
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Service Conditions
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Equipment Item Files
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Qualification Documents
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At the time of the inspection there were 72 equipment item files, arranged as follows:
Evaluation
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Environmental Qualification Statement (with preparer, reviewer, and approval signatures)
EQ Review Checklist Equipment Item Qualification Data Summary Form (replaces SCEW
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sheet)
Equipment Qualification Evaluation Checklist SCEW (Original Equipment)79-01B Qualification Worksheet (Original Equipment)
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Traceability
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Thermal Aging Analysis
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w Maintenance Assessment Package (MAP)
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Assessment of Manufacturer's Instructions
Review of IE Notices and Bulletins Replacement Frequency of Unit and Specific Parts
Preventive Maintenance Recommendations
l Surveillance Maintenance Recommendations
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Supporting,Information
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The licensee's equipment item numbering system is arranged according to the installation period of the equipment.
For example, equipment items numbered from 2100 to 2199 were installed during the third refueling outage. This practice facilitates tracing the history of specific components and identifying applicable qualification criteria. Another feature of the files was the inclusion of clear, full-color reproductions of equipment walkdown photographs in working copies of the files.
The EQ documentation files were carefully arranged, and summary forms, checklists, and statements were added to enhance completeness, auditability, and usefulness. However, the NRC inspectors found several instances of discrepancies or obvious errors in the files, suggesting that preparation of various portions of each file -- particularly upper tiers of documentation -- may not have fully coordinated all appropriate technical considerations.
These instances include the following. First, for Louis Allis motors for feedwater pumps FW-P-3A and B, file No.
IV.B.1/46, various model and/or serial numbers were recorded. The SCEW sheet in Tab 1 gave 269319-001 as the Model No. for each. The Louis Allis certification in lab 3 gives 269319-001 and 269319-002 as Serial Numbers. The MAP in Tab 5 lists the Model Number for both as 269319-002.
EDS report Ref. V B.1.40.1 repeats the serial numbers in the Louis Allis certification. During the plant walkdown, the NRC inspector observed the motor nameplates; both were blank in the space assigned for Model Number and both were labeled MA#9-269319.
Second, for Westinghouse motors for charging pumps CH-P-1A, B, and C, file no. IV.B.1/43, the SCEW sheet showed an 18 year qualified life whereas the analysis only justified 11.7 years; the SCEW sheet incorrectly referenced as the test report WCAP/8587 Rev. 6 (a methods document) instead of WCAP/8587 Supplement 1 EQDP AE-2, Rev. 5; and the 79-01B Qualification Worksheet contained a self-contradictory description of test conditions for a test report that was identified in the licensee's evaluation as superseded and not valid (but was still in l
the file). Third, for ASCO solenoid valve S0V-RC-456-2, file no. IV.B.1/
2208, the file contained the wrong model number (compared with the component nameplate and Design Change Package) and the demonstrated peak LOCA temperature of 346 F did not envelop the 350 F specified plant temper-ature. Fourth, for Rosemount Model 1154 transmitters, file no. IV.B.1/2212, the SCEW sheet specifies 0.25 percent required accuracy for both ambient
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I and 350 F environment (an obviously unrealistic requirement) and gives no values for demonstrated accuracy; further, model 1154GP9RB gage pressure
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v transmitters with one port open to atmosphere are used inside containment (PT-RC-402 and 403) where the 42 psig LOCA pressure can cause a 1.5 percent error that was not considered in the file.
For all of the deficiencies listed above, the licensee either satisfied the concern or provided additional material judged sufficient to permit resolution during the inspection. A future NRC inspection will verify that resolution of these specific concerns has been incorporated into the files, and selected additional files will be reviewed to ensure that information on Qualification Data Summary Forms and SCEW sheets is supported by other material in the files. Equipment File Discrepancies constitutes Open Item 50-334/86-12-7.
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The files adequately documented qualification o'f the equipment except for the Open Item above and the following additional deficiencies.
Except as noted here the files were readily auditable and were complete and accurate.
(1) Continental silicone rubber insulated cable, file no. IV.B.1/5 -
Qualification to the 00R Guidelines was not established because the file contained no performance data at elevated temperatures, although LOCA qualification is required.
Functional performance requirements were addressed only by using lower temperature post-test insulation resistance values based on dielectric withstand testing. The licensee was unable to proyide additional test data during the inspection.
Continental cable constitutes Potential Enforcement / Unresolved Item 50-334/86-12-1.
(2) Rosemount 1154 transmitters PT-RC-402 and 403, file no. IV.B.1/2212
- The installation of these transmitters observed during the walkdown inspection differed from the seismically qualified configuration described in documents contained in the file.
In the plant each transmitter was mounted on the manufacturer's mounting bracket, which was attached with two U-bolts to a two inch carbon steel pipe; the pipe was welded to an angle iron instrument rack. Wyle test report 45542-3, page VIII-2, paragraph 2.0 describes the test specimen mounting as follows:
"The transmitters were mounted to a Wyle-fabricated test fixture using manufacturer-supplied mounting hardware.... The test fixture was welded to the test table in each orientation." This test mounting is equivalent to the installation labelled " required" in the manufacturer's instruction manual. When questioned, the licensee provided an analysis intended to show the acceptability of the plant installation. The NRC inspectors reviewed the calculation and concluded that it did not adequately address fit, tolerance, and relaxation considerations relative to the U-bolts, nor did it attempt to address the effects of the different mountings on trans-mitter piece-parts and overall performance. The inspectors also suggested that the licensee consult the transmitter manufacturer.
Rosemount transmitters constitute Potential Enforcement / Unresolved Item 50-334/86-12-2.
(3) Victoreen High Range Radiation Monitor (HRRM), RM-RM-219A and B. file no. IV.B.1/2015 - The qualification problem with this new system, subject to 10 CFR 50.49 criteria, derived from the lack of qualified
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coaxial containment penetrations for the detector high voltage and signal leads. The file described a cable arrangement using non-coaxial penetrations with Brand Rex 300 volt instrumentation cable,
- 16 AWG, 4 conductor, shielded quad cable.
Functional performance criteria were addressed in the file for a 4 to 20 milliamp transmitter circuit, using only post-test insulation resistances. The licensee agreed to revise the cable file for transmitter applications using worst case insulation data taken during the steam test. The more serious problem involved the HRRM application, where the plant-
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specific wiring design near the penetrations failed to shield the signal lead from the high voltage lead. The licensee and a consultant.
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agreed with the NRC inspector's es'timate that LOCA temp ~ ratures could e
produce a leakage current equivalent to about one megarad per hour, which is close to the maximum expected detector signal. Conceivably, high temperatures experienced in the absence of high radiation levels would cause the HRRM to provide misleading information. As noted in the Background Section (3) of this inspection report, the plant's R.G. 1.97 program is under review by the NRC. The licensee indicated that HRRM accuracy might be reconsidered prior to finalization of
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that program. Victoreen High Range Radiation Monitor constitutes Potential Enforcement / Unresolved Item 50-334/86-12-3.
(4) Limitorque valve operator MOV-RC-536, file no. IV.B.1/25 - During the plant walkdown the NRC inspector was unable to identify four I
jumper wires on the limit switch finger board and four torque switch wires. This concern is significant, as addressed in IE IN 86-03, since it could void qualification of the operator. As of the close
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of the inspection two days later the licensee stated he had not yet
examined the wires. Limitorque operator constitutes Potential Enforcement / Unresolved Item 50-334/86-12-4.
(5) Barton 764 transmitter LT-FW-1487, file no. IV.B.1/2103 - DLC Incident Report IR 80-060 dated May 7, 1986 reported that this steam generator level transmitter, a Tech Spec item required to be qtralified to 10 CFR 50.49, was discovered during the licensee's EQ file verification program to be located below tne maximum postulated flood level. The plant then operated approximately one additional month prior to beginning the refueling outage during which the W inspection took place. The transmitter was to be relocated aLo flood level during the outage.
DLC provided an analysis to justify interim operation with the transmitter below flood level. The analysis pointed out that during qualification type testing the transmitter was exposed to steam at
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temperatures and pressures exceeding the worst-case submerged conditions with no evidence of moisture intrusion.
Calculations were also performed to demonstrate that the main body seal, an ethylene propylene terpolymer (EPDM) would remain leaktight considering swelling, shrinkage, radiation and thermal aging effects, compression set, and corrosion. The NRC inspectors concluded that the licensee had acted promptly upon discovery of the potential problem; and that, although qualification was not established for the submerged case,
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brief interim operation was adequately justified except for one
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aspect. The licensee's analysis did not specifically evaluate the cable entrance gland seal. Late in the inspection it was determined that the type-tested gland seal part number 0764.10628 Rev. 5 differed from part number 764.1221.B shown in the vendor manual for the trans-mitter. This item is considered unresolved pending demonstration that these two cable entrance connectors are equivalent and verification that the transmitter was relocated above flood level during the refueling outage. Barton transmitter cor.stitutes Potential Enforcement /
Unresolved Item 50-334/86-12-5.
(6) Rockbestos single conductor SIS control cable, mark numbers NFA-51, 52, and 37 - At the beginning of the inspection the lic~ensee reported that exactly wha,t types of Rockbestos cable were used in BVPS-1 was still being determined, and Rockbestos was investigating purchase order records to obtain that information.
In the interim, DLC had established a basis for qualifying to the D0R Guidelines all types of Rockbestos SIS cable that could have been installed except cable using type KXL 780 insulation compound; test reports for new Rockbestos testing of that compound would be required to qualify it. This item is considered unresolved pending determination of whether KXL 780 insulation was used in the plant. Rockbestos cable constitutes Potential Enforcement / Unresolved Item 50-334/86-12-16.
(7)
IE Information Notices and Bulletins - The NRC inspectors reviewed and evaluated the licensee's activities related to the review of EQ-related IE Information Notices (ins) and Bulletins. The inspector's review included examination of procedures and EQ documentation packages relative to Information Notices and Bulletins. The procedure rev'ew determined that the licensee has a system for distributing, reviewing and evaluating ins / Bulletins relative to equipment within the scope of 10 CFR 50.49, and that ins and Bulletins are addressed in appro-priate component EQ files. During the review of the individual component files, the NRC inspectors evaluated the licensee's action with respect to ins and Bulletins. No concerns were identified during titis review, i
l The inspectors specifically reviewed licensee activities relative to IE IN 84-90, " M in Steam Line Break Effect on Environmental
Qualification of Equipment."
IN 84-90 indicated that environmental conditions outside containment following a main steam line break (MSLB) may have been nonconservatively determined in many Westinghouse plants because the steam generator blowdown model used for analysis did not account for heat transfer from the uncovered portion of the tube bundle to the escaping stearn. BVNP-1 addressed this concern through the Westinghouse Owners Group (WOG). Upon
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receipt of the WCAP report providing revised mass and energy release
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data to WOG members, DLC determined that none of the modeled cases accurately represented BVPS-1. A January 6, 1986 DLC letter to Westinghouse requested revised data, which were provided by a May 6
Westinghouse letter. By May 30 a Schneider analysis using the new data showed that +he peak temperature (in the Main Steam Valve
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House) decreased, from 311 to 280 F; the required time also decreased from the values previously used for EQ evaluation. The l
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NRC inspectors also verified that sufficient margin was included in the Stone and Webster LOCTIC calculation of in-containment MSLB conditions to satisfy NUREG 0588. Thus the licensee's actions with respect to IN 84-90 were considered timely, and the revised environmental parameters were bounded by the values previously used in EQ evaluations. The licer.see further stated that the NRC would be formally advised of the new results within approximately a month, and that the EQ files would be revised appropriately.
F.
Plant-Physical Inspection The NRC inspectors, with component accessibility input fr.om licensee person-nel, established a list of 18 component types for physical inspection.
Multiple specimens of most types were examined.' All were accessib".; at the time of inspection. The inspectors examined characteristics such as mounting configuration, orientation, interfaces, model number, ambient environment, and physical condition. Concerns noted during the walkdown inspection are addressed in section 4.E, 4.E.(2), and 4.E.(4) above.
G.
Cable Identification Verification
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The NRC inspectors selected ten of the walkdown components as specimens for testing the licensee's ability to identify plant cables and demonstrate the existence of qualification files for them. The NRC inspectors independent,1y examined these cables during the walkdown to verify the identi*1 cations provided by the licensee's documentation; information such as cable manufacturer, type, size, voltage, and plant identification number was obtained as available.
For each designated cable the licensee provided computer printouts listing cable type, size, from/to routing, reel no. from which cable was drawn, estimated length and actual length, cable ID number, service function, raceway no. and installation status. Verification of cable traceability for selected cables was accomplished using wiring diagram numbers 8700-RE-3BW, 8700-RE-36F, 8700-RE-3AR, and 8700-RE-3AS, and computer data for the following:
Cable No. IRCS ARX 011, cable ref. no. NFC-01, Reel no. C0 1131,
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from equipment no. RCP-88/C to equipment no. FT-RC414.
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Cable No. ISIL BPC 056, cable ref no. NFA-23 Reel no. A23-33, from
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equipment no. RCP15 E/C, to equipment No. MDV-SI 8658.
Cable No. 1SIL NPC 503, cable ref no. NFA-43, Reel no. A43-12, from
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equipment no. RCP-160 K to equipment no. M0V-SI 865C.
Cable no. ICHS GH 300, cable ref. no. NFB-16. Reel No. B16-07, from
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equipment no. 4KVS-1AE to equipment No. CH-P-1C.
Cable No.1FWE A0H 300, cable ref no. NFB-16, Reel no. B16-06 from
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equipment no. 4KVS-1AE to equipment no. FW-P-3A.
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Cable no. IRCS N0C 601, cable ref no. NFA-24, Reel no. A24-12, from equipment no. S0V-RC102/A to equipment no. RCP-4G/C.
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The licensee verified cable qualification by using the cable reference number noted above for each cable to locate cable manufacturer and supporting data. All selected cables were from two manufacturers, as follows:
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Cable ref. no. NFC-01 Continental Wire and Cable Company, Instrument Cable.
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Cable ref no. NFA-24 Okonite Company, 1000 volt control cable.
The NRC inspectors determined that the licensee had demonstrated cable traceability from procurement through installation and, replacement.
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