IR 05000335/1986008
| ML17308A255 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 08/06/1986 |
| From: | Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17308A254 | List: |
| References | |
| 50-335-86-08, 50-335-86-8, 50-389-86-07, 50-389-86-7, GL-84-24, IEIN-85-039, IEIN-85-040, IEIN-85-39, IEIN-85-40, NUDOCS 8608120368 | |
| Download: ML17308A255 (35) | |
Text
U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Report Nos.:
50-335/86-08; 50-389/86-07 Docket Nos.:
50-335/389 Licensee Nos.:
DPR-67, NFP-16 Licensee:
Florida Power and Light Company 9250 West Flager Street P. 0.
Box 529100 Miami, Florida 33152 Facility Name:
St. Lucie Nuclear Plant, Units 1 and
Inspection At:
Fort Pierce, Florida Inspection Conducted:
March 31 - Apri 1 4, 1986 Inspector:
4. +iY~
G. T.
Hub ard, Equipment gualification and Test Engineer Date Also participating in the inspection and contributing to the report were:
R.
N. Moist, Inspector, IE L.
E. Foster, Reactor Inspector, RII M.
W. Yost, Consultant Engineer, Idaho National Engineering Laboratory ( INEL)
D.
E. Jackson, Consultant Engineer, INEL J.
W. Grossman, Member of Technical Staff, Sandia National Laboratories (SNL)
F. J.
Wyant, Member of Technical Staff, SNL II Approved:
U. Potapovs, Chief, Equipment gualification Inspection Section, Vendor Program Branch, I dm E g/~cry Date 8608120368 860807 PDR ADOCK 05000335
INSPECTION SUMMARY Ins ection on March 31 - A ril 4, 1986 (Ins ection Re ort Nos:
3 /
~
I~II I: I dd I
I I
I
'
p1 of a program per the requirements of 10 CFR 50.49 for establishing and main-taining the qualification of electric equipment within the scope of 10 CFR 50.49.
Results:
The inspection determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed below.
Name Potential Enforcement/Unresolved Items:
1.
Limitorque Operator Wiring 2.
General Cable Qualification 3.
File Audi tabi 1 ity Victoreen Radiation Detector Qualification RDF Resistance Temperature Detector Qualification 6.
Garrett Solenoid Valve Qualification 7.
GE Vulkene/Raychem Fl amtrol Cable on EQ Lists 0 en Items:
1.
EQ Program Procedures Update 2.
Main tenance Clari-fi ca tions 3.
EQ List Deletions 4.
Limitorque File and Field Corrections 5.
Victoreen Radi a tion Detector File Corrections Repor t
~Para ra h
4.D.(2)(b)
4.D.{2)(a)
4.D.(1)
4.D.(2){c)
4,D.(2)(d)
4.0.(2)(e)
4.C.
4.A.
4.8.
4. C.
4.0.(2)(t )
4.D,(2)(c)
Item Number s
50-335/86-08-07; 50-389/86-07-05 50-335/86-08-06 50-335/86-08-05; 50-389/86-07-04 50-335/86-08-10 50-389/86-07-07 50-389/86-07-08 50-335/86-08-04; 50-389/86-07-03 50-335/86-08-01; 50-389/86-07-01 50-335/86-08-02; 50-389/86-07-02 50-335/86-08-03 50-335/86-08-08 50-389/86-07-06 50-335/86-08-09
'.
Garrett Solenoid Valve File Corrections TEC Acoustic Monitor File Corrections 4.D.(2)(e)
50-389/86-07-09 4.D.(2)(f)
50-335/86-08-11 8.
Namco Limit Switch File Corrections 4.D.(2)(g)
50-335/86-08-12 9.'icroswi tch Limit Switch Fi 1 e Corrections 4.D.(2)(h)
50-389/86-07-10
DETAILS 1.
PERSONS CONTACTED:
Florida Power and Li ht Com an FP&L K.
D.
H.
J.
T.
T.
J.
L.
C.
J.
D.
L.
A.
D.
G.
D.
D.
B.
C.
W.
J.
R.
L.
C.
D.
G.
G.
L.
J.
W.
C.
R.
D.
J.
B.
C.
A. Jrl S.
E.
N.
W.
C.
N. Harris, Site Vice-President A. Sager, Plant Manager J.
Dager, Vice-President B. Harper, Superintendent (Supt.) of guality Assurance (gA)
A. Dillard, Supt. of Maintenance J.
Vogan, Project Manager Barron, Operation Supt.
.
McLaughlin, Plant Licensing F. Leppla, Engineer Campbell, Engineer
'.
Parker, Engineer R. Casella, Supervising Engineer W. Bailey, gA Supervising Engineer Oliver, Area Stores Supervisor Gross, Engineer Kohler, Engineer Wolf, Sr. Plant Engineer J. Allman, Engineer R. Sculthorpe, Sr. Plant Engineer Ferriday, Licensing Specialist J. Korte, Electrical Maintenance Area Supervisor Scarola, Assistant Supt., Electrical Maintenance Ball, Mechanical Maintenance Planning W. Pearce, Operations Supervisor B. Kuiskern, Purchasing L. Smith, Supervisor Electrical E. Regal, Eg Coordinator R. Madden, Sr. Licensing Engineer Collins, Sr. Plant Technician Sorrentino, Instrument and Controls (ISC) Specialist S. Windecker, Assistant Plant Supt.
Crider, Outage Management Supervisor W. Akerman, Electrician H. Taimb, Electrician Bilden, Supervisor Purchasing Sandel, IKC Specialist A
Pell, Technical Staff Supervisor
. Bailey, gA Operations, Supervisor H. Yerduci, Nuclear Licensing Wunderlich, Reactor Engineer Roos, guali ty Control Supervisor Busch, Engineer Wilson, Mechanical Maintenance Planning Head
- Denotes P
1.2 Consultants M. P. Harrell, Manager, Nuclear Licensing, EBASCO W. Lewinger, Electrical Engineer, EBASCO R.
W. Walpole, Project Licensing Engineer, EBASCO W. Hotchkiss, Engineering Planning and Management, Inc.
(EPM)
1.3 NRC G.
G. Zech, Branch Chic, IE U. Potapovs, Section Chief, IE T.
E. Conlon, Section Chief, RII
0'
~
4, PURPOSE The purpose of this inspection was to review the licensee's implementa-tion of a program meeting the requirements of 10 CFR 50.49 for St. Lucie Nuclear Plant, Units 1 and 2.
BACKGROUND The NRC held a meeting with FPSL on May 8, 1984 to discuss the licensee's proposed methods to resolve the Eg deficiencies identified in the Unit 1 Safety Evaluation Report (SER) dated April 21, 1983 and Franklin Research Center (FRC) Technical Evaluation Report (TER) dated February 28, 1983.
Discussions also included FPSL's general methodology for compliance with
CFR 50.49 and Justification for Continued Operation (JCO) for those equipment items for which environmental qualification was not completed.
Minutes of the meeting and proposed methods of resolution for each of the Eg deficiencies were documented in the licensee submittal dated July 12, 1984.
An SER was issued for Unit 1 on November 15, 1984.
The SER identified outstanding JCOs for equipment not qualified and required to be qualified by the
CFR 50.49 deadline of March 31, 1985, for Unit 1.
In response to Generic Letter 84-24, dated December 27, 1984, the licensee stated in his letter, dated April 2, 1985, that all equipment within the scope of 10 CFR 50.49 was qualified.
The NRC staff provided results of the review of the Unit 2 Eg program in Supplement 3 of the SER (NUREG 0843), dated April 1983.
In letters dated May 26 and 31, 1983, FPSL responded to outstanding items concerning Unit 2's compliance wi th
CFR 50.49.
In Supplement 4 of the SER, dated June 1983, the staff concluded that all outstanding items of Supplement 3 had been resolved and the licensee had demonstrated compliance wi th 10 CFR 50.49.
The staff conditioned the operating license to require all equipment within the scope of 10 CFR 50.49 to be environmentally qualified as required by
CFR 50.49 prior to startup following the first refueling outage.
Startup after the first refueling outage occurred on November 17, 1984.
The licensee stated that all
CFR 50.49 equi pment was qualified in his letter dated November 20, 1984 and ag'ain in his letter dated April 2, 1985.
FINDINGS The NRC inspectors examined the licensee's program for establishing the qualification of electric equipment within the scope of 10 CFR 50.49.
The program was evaluated by examination of the licensee's qualification documentatiog files, review of procedures for controlling the licensee's Eg effortsverification of the adequacy and accuracy of the licensee's
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 details below, the inspect~on team determined that the licensee has implemented a
program to meet the requirements of 10 CFR 50.49, although some deficiencies were identified.
I
A.
E Pro ram Procedures The NRC inspectors determined that FP&L was in the process of upgrading its EQ program at the time of the inspection.
The EQ program was being upgraded as the result of an internal EQ assessment conducted in the fall of 1985.
8ased on the results of this assessment, which was conducted at FP&L's corporate offices and plant sites to determine whether any of the problems identified in IE Information Notices ( INs) 85-39 and 85-40 were applicable to his EQ program, the licensee decided to upgrade his existing program.
At the time of the inspection, the licensee had completed or was completing the following program improvements:
Establish corporate and plant EQ Coordinators Issue a trial use EQ Program Manual and finalize the manual based on recommendations received during the trial use period Establish the EQ List as a "Selected Record" Revise the EQ List as appropriate
.
Evaluate methods to improve the audi tabi lity of qualification files Fully develop EQ requirements into the Preventative Maintenance program Correct identified qualification file deficiencies Establish an engineering EQ group The NRC inspectors reviewed the St.
Lucie EQ program as defined in the FP&L EQ Program Manual, dated March 27, 1986, and other proce-dures.
This manual was the trial use manual discussed above and had just been issued.
It was scheduled to be revised within 90 days of the issue date.
The licensee stated that the EQ manual was developed to provide an overall EQ policy for FP&L and its nuclear plants.
The licensee emphasized that even though the EQ manual was just issued, they-have had procedures to control their EQ activi ties prior to issuance of the manual.
The isspectors'eview of the EQ program manual determined that it contained policy statements in the following areas:
EQ Equipment Failure Cause Auditability of Records and Trending of Problems History of EQ Plant Change Modifications
Procurement of EQ Items Receipt, Storage, and Handling Preventative Naintenance Issue of Material Maintaining Quality Management Controls for EQ Equipment The inspectors'eview determined that the policy statements of the EQ program would assure that qualified equipment is procured and maintained in a qualified status if implemented by adequate proce-dures.
The review of the following procedures identified some con-cerns regarding the implementing procedures'dequacy to ensure com-pliance with 10 CFR 50.49 requirements.
QP-4.5, Rev 1, Procurement of Safety-Related and Quality Related Equipment QI-4, Rev 7, Procurement Document Control QI-6, Rev 9, Document Control QI-7, Rev 7, Control of Purchased Material, Equipment, and Service QI-8, Rev 7, Identification Control of Materials, Parts, and Services QI-18, Rev 11, Quality Control Survei llances AP No. 0010431, Rev 5, Preventative Maintenance Program AP No. '0010432, Rev 26, Plant Work Orders QIM 13-S-1, Rev 7, Handling, Storage, and Shipping QIM 7-S-1, Rev 10, Control of Purchased Material Th~nspectors'eview of procurement documents, plant work orders (PWOs),
and discussions with the licensee determined that the licensee had prepared'nd revised some procedures associated with procurement, receipt, storage, and handling to incorporate EQ requirements.
The review of QP-4.5 determined that it had been revised to include pertinent requirements for procurement of 10 CFR 50.49 items; however, the following concerns were identified.
(1)
The procedure did not require purchase orders (POs)
to be identified with any indication that the item was
CFR 50.49 or EQ related equipmen (2)
The procedure did not address upgrade requirements for replacement parts per
CFR 50.49.
(3)
The procedure did not require Qualification Test Reports and/or other pertinent data to be filed in appropriate document packages after review and approval.
In addition to reviewing procedure QP-4.5, the inspectors reviewed POs Nos.
49141-66551, 61860, 66404, and 67876 and determined that the POs did not identify that the purchased item was being purchased for EQ applications.
Additionally PMOs 8193, 8194, and 8220 did not identify that the work involved pertained to EQ equipment.
The in-spectors were concerned that by not "clearly" identifying EQ equipment or work on POs and PMOs, vendors and plant personnel may not utilize adequate controls to assure that equipment is environmentally quali-fied, documented, and maintained qualified throughout its installed and qualified life.
Based on the inspectors'eview of procedures QI-6,'I-7, QI-8, QIM 13-S-l, QIM 7-S-1, and AP0010431, it was determined that they do not always identify EQ specific requirements.
The licensee's posit~on is that EQ is only one part of many areas that must be controlled by his procedures; therefore, specific EQ requirements do not need to be defined in every procedure.
While there is nothing wrong with 'this approach to EQ, the findings discussed here and in paragraphs on the
CFR 50.49 List,- Maintenance, and Qualification Files indicate the potential for a breakdown in the licensee's EQ Program.
The inspectors did not identify any generic EQ program defic~enc~es, except in the area of qualification file audi tabi lity; however, 'it is recommended that the above comments be considered when the licensee updates his EQ Program and 'procedures following the trial usage of the EQ Program Manual.
The licensee's action relative to the update of his EQ program and procedures (see paragraph 4.B) is considered an Open Item (50-335/86-08-01; 50-389/86-07-01)
which will be reviewed during a future NRC inspection.
E Maintenance Pro ram The NRC inspectors reviewed the licensee's provisions for preserving the qualified status of equipment qual~fied to
CFR 50.49.'he EQ qualification files for each applicable
CFR 50.49 equipment item contain-EQ equipment maintenance sheets, which provide information concerning equipment identification, age related requirements, and manufacturers recommendations for preventative maintenance (PM).
Procedures to process and evaluate this information for inclusion into the plants standard preventative maintenance schedule for electrical components are defined by AP 0010431.
The maintenance superintendent is responsible for implementation and administration of the PM program.
Appropriate maintenance department heads are responsible for ensuring that PM items under their charge are completed within the time allotted for each ite The inspectors'eview of the licensee's EQ maintenance included evaluation of qualification files for EQ maintenance requirements, EQ Lists for each unit (the EQ lists identify EQ maintenance require-ments),
maintenance instructions and completed PN work,orders (WOs).
The inspectors examined the utilization of EQ requirements in the Generation Equipment Management Systems (GENS)
and a trial computer maintenance tracking system used for controlling corrective and repetitive maintenance activi ties.
Additionally the inspectors interviewed responsible maintenance management and plant engineering personnel.
The inspectors review of AP 0010431 determined that the procedure did not specifically address EQ equipment; however it did address responsibilities of personnel, requirements for maintaining records, and five general maintenance instructions.
The procedure specifically states that the instructions for mechanical equipment is in General Maintenance Procedure M-0018; however, there is no reference to any PN requirements for EQ equipment.
Since qualified equipment main-tenance is as critical to plant operation as mechanical equipment maintenance, which is specifically reference in AP 0010431, the inspectors were concerned that EQ equipment maintenance could be overlooked.
The inspectors'eview of AP 0010432 for PWOs determined that quali-fied equipment items are discussed in paragraph 8.3.2.D of the pro-cedure and PWOs have a block to be checked if the work involves quali-fied equipment.
However, this procedure does not ensu~e that data from the PWOs will be entered into component history files, whether PM was performed, and where the data is recorded.
The inspectors'eview of GENS determined that the GEMS planner is responsible for the issuance of PM work orders, maintaining a follow-up system for PM, and maintaining a record of all PM performed.
Additional evaluation of the licensee's EQ maintenance program and procedures will be performed during future NRC inspections.
This evaluation will be performed as part of the open item relative to EQ program procedures discussed in paragraph 4.A of this report.
The inspectors selected four items from their review of EQ qualifica-tion files and reviewed the files for maintenance requirements.
Main-tenance requirements were annotated in the file maintenance section and on the Eg List.
Two of the items had the following discrepancies:
( 1)
General Atomics (GA) radiation detector Unit 1, Tag No.
RE 26-58-RO-23 had a maintenance requirement to replace electrolytic capacitors every ten years.
This information was not included in GEM 'J
(2)
TEC acoustic flow monitor Unit 1, Tag No.
FT 1200 had a
maintenance requirement to replace a
133A alarm module every 19.4 years and a
134 relay and power supply every 7.8 years.
This information was not in GEMS.
The licensee stated these requirements were only recommended main-tenance requirements; therefore, they did not need to be in GEMS.
The inspectors recommended to the licensee that if the requirement is in the Eg files and is not necessary, then he should doc'ument that the requirement is not necessary for maintaning qualification of the equipment so that there is no confusion as to whether it is a
requirement.
In addi tion to addressing the above specific clarifica-tions, the inspectors recommended that the licensee should document his posit~on relative to "required" and "recommended" maintenance practices for qualified equipment.
Clarification of the maintenance requirements of the GA radiation detector and TEC acoustic flow monitor and documentation of the licensee's position relative to
"required" and
"recommended" maintenance is identified as an Open Item (50-335/86-08'-02; 50-389/86-07-02)
which will be reviewed during a
future NRC inspection.
(See additional maintenance concern on Namco limit swi tches discussed in paragraph 4.D.{2){g))
CFR 50.49 E
Master List)
The licensee is required to establish and maintain an up-do-date list of the equipment that must be qualified under
CFR 50.49.
At St. 'Lucie, the licensee had Ebasco Services, Inc., develop a separate list for each unit at the si te.
These lists are entitled, "Environ-mental gualification (E.g.) List for 10 CFR 50.49,"
and assigned drawing numbers 8770-A-750 for Unit 1 and 2998-A-450 for Unit 2.
These drawings are controlled documents with Revision 5, dated February 27, 1986, for Unit 1 and Revision 3, dated January 29, 1986, for Unit 2 being the latest versions at the time of the inspection.
The E.g. List information has been put on a computer data base which lists the tag number of the item, the manufacturer, model number, maintenance notes, and other pertinent information.
The inspectors performed an audit of the Eg lists to determine their validity.
To determine the validity of the lists, the inspectors reviewed the latest versions of the following emergency operating procedures (EOPs):
l-EOP-01, 2-EOP-01 Standard Post Trip Actions 1-EOP-02, 2-EOP-02 Reactor Trip Recovery 1-EOP-03, 2-EOP-03 Loss of Coolant Accident 1-EOP-04, 2-EOP-04 Steam Generator Tube Rupture
l-EOP-05, 2-EOP-05 Excess Steam Demand l-EOP-06, 2-EOP-06 Total Loss of Feedwater 1-EOP-07, 2-EOP-07 Loss of Forced Circulation l-EOP-08, 2-EOP-08 Functional Recovery From the above EOPs, th inspectors selected 40 components from the unit
EOPs and 16 components from the unit 2 EOPs to determine if the components were on the EQ Lists.
Results of the above evaluation determined that the components required to be on the lists were on the appropriate lists.
In some cases, the selected components were not on the lists; however, the licensee provided satisfactory expla-nations for why these items should not be on the lists.
As further evaluation of the Unit 1 list, the inspectors questioned why the licensee's May 1983 EQ List submittal indicated that certain TER equipment items were to be removed from the list and the i tems were still on the latest EQ List.
The licensee provided satisfactory explanations; however, TER item 47 and
(ASCO solenoid valves)
were identified as undergoing evaluation of radiation environment data to determine if the valves should remain on the list.
Addi-tionally, it was determined that TER item 68 (Namco limit switch)
should be removed from the list.
Final determination as to whether TER item 47 and 48 should remain on the EQ List and deletion of TER item 68 from the EQ List is identified as an Open Item (50-335/
86-08-03) which will be reviewed during a future NRC inspection.
Reference is also made to paragraph 4.0.(2)(b)[3] relative to Open Item for removal of Limitorque valve operator 2-MU-3539 from the Unit 2 EQ List.
The inspectors'valuations determined that the licensee had esta-blished EQ Lists for each unit and had implemented procedures to maintain the lists in an up-to-date status.
While the above evalua-tion identified only the above problems with the lists, during the plant walkdown inspection the inspectors, identified that General Electric (GE) Vulkene and Raychem Flamtrol jumper wires were installed in Limitorque motor valve operators used in plant applications within the-scope of 10 CFR 50.49.
The GE Vulkene wires were observed in-stalled in Unit 1 operators and the Raychem Flamtrol wires were observed inftalled in Unit 2 operators.
Neither of the above wires were-included on the respective EQ Lists for each unit.
Since the qualification of jumper wires in Limitorque operators must be supported by separate wire/cable qualification reports they should be included on the appropriate EQ List Even though the above wires were not. on the respective lists, the inspectors determined that the licensee did have documentation to support qualification of these two cables.
The licensee's failure to include the Vulkene wire on his Eg List for Unit 1 is identified as a Potential Enforcement/Unresolved Item (50-335/86-08-04).
The licensee's failure to include the Flamtrol wire on his Eg List for Unit 2 is ~dent~fied as a Potential Enforcement/Unresolved Item 50-389/86-07-03).
Environmental uglification Files The NRC inspectors reviewed the Eg files for Units 1 and 2 to deter-mine if qualification had been established for al) items within the scope of 10 CFR 50.49 and on the respective unit Eg Lists.
In con-junction with the file review, the Eg Lists for each unit were also reviewed, since the lists provided traceability b'etween plant tag numbers and qualification documeritation.
Ouring the inspection entrance meeting, the licensee descr ibed the format of the files for each unit.
The licensee pointed out that the files for each unit were different, since they were developed at different points in time.
The files for Unit 1 were developed in response to IE Bulletin 79-01B; whereas, the Unit 2 files were developed as part of the licensing process.
The licensee further stated that once the initial files were completed and qualification was established, the files became historical documents.
As Eg changes are made to either unit through replacement of equipment, plant modifications, and/or other reasons, documentation to support qualification of the change equipment is included in pl ant change/modi fica tion documen ta tion.
The inspectors reviewed 11 qualification files associated with 11 equipment items for Unit 1 and 9 files. for 9, items of Unit 2 equipment.
An equipment item is defined as a specific type of electrical equipment, designated by manufacturer and model, which is representative of all identical equipment in a plant area exposed to the same environmental service conditions.
The files were examined to verify. the qualified status of equipment within the scope of 10 CFR 50.49.
In addi tion to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selectively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified; similarity o'f tested equipment to that installed in the plant (e.g.,
insulation class, materials of components of the equipment, tested configuration compared to installed configuration, and documentation of both); evaluation of adequacy of test conditions; aging calculations for qualified life and replacement interval determination; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy; evaluation of test anomalies; and applicability of Eg problems reported in IE INs/Bulletins and their resolutio J
(1)
The inspectors'eview and evaluation of the qualification files determined that many of the files reviewed were not auditable as required by paragraph (j) of 10 CFR 50.49 and in some cases they did not adequately support qualifica-tion.
As part of the licensee EO assessment (see paragraph 4.A.) in the fall of 1985, he had identified problems with file audi tability and was working to improve file audi ta-bility at the time of the inspection.
(a)
Examples of specific files that were considered to be not auditable by the NRC inspectors are provided below:
fll File 6.3 for Rockbestos coaxial cable,'nit 2, included copies of test and plant specific pressure profiles on pages E10 and E22; however, only the tail end of the profiles were visible.
Without the complete profiles, the inspectors were unable to determine if test profiles encompassed plant profiles.
L2]
File 8.2 for ITT Barton 763 and 764 pressure transmi tters, Unit 2, referenced graphs of temperature and pressure profiles to demonstrate that test conditions enveloped plant conditions; however, the profiles were foldouts that were copied in the folded configuration without the complete profile the inspectors were unable to verify that the test profiles enveloped plant profiles.
L3]
Files 22.0 and 23.0 for Unit 1 and file 8.5 for Unit 2 provided qual ifi ca tion documentation for the TEC acoustic flow monitoring system.
All three files contained a aualification report from TEC; however, the inspectors found that the reports in files 22.0 and 23.0 were not complete when compared to the report in file 8.5.
Addi-tionally, none of the files contained data from functional and operation tests conducted during TEC qualification accident simulation; therefore, the inspectors were unable to verify exact equipment functional parameters during accident simulation testing (see paragraph 4.D.(2)(F)).
I 4]
File 19.0 for Rome cable in Unit 1 contained a
FRC test report to support qualification of the cable; however, the majority of the report was missing from the package.
L5]
File 35.9 for Garrett solenoid valves in Unit 2 was not clear in establishing similarity between tested and installed solenoid valves and identifying which solenoids were attached to which valve actuators.
The fi le was uncl ear as to whether valve position switches were installed on the solenoid valves.
The file did not contain any calculations to support a 40 year qualified life (see paragraph 4.D.(2)(e)).
(b)
In addition to the above file specific examples regarding file auditability, the following general comments relative to audi tabi lity are provided:
[I]
Some files lacked or did not reference pertinent information to support qualification.
[2]
Some files were found to contain out of date information.
[31 Since additional data which was not included in
" the file for the inspectors'nitial file review, was provided during the inspection, the inspectors were unable to substantiate the additional data in all cases.
[4]
Since equipment qualification levels were not identified in the qualification files, the inspectors found it diff~cult to determine the qualification level to which the equipment was being qualified.
The licensee did provide a
list documenting qualification level.
[5]
While the licensee was able to show that IE Information Notices ( INs)/Bulletins were addressed relative to Eg (see paragraph 4.D.(4)), the traceabi lity of INs/Bulletins to specific Eg equipment was difficult, since the qualification files did not make reference to applicable
!Ns/
B'ulletins.
L6]
Demonstrated equipment functional performance parameters during qualification testing were not always clearly correlated to plant functional performance requirements, This was especially true in the case of electric cable qualification files.
The above specific file examples and general file comments are considered to be representative of the type of file auditability problems identified by the inspectors during their file reviews.
While a few of the files were considered auditable and the licensee was able to resolve
many issues and support qualification of most equiment during the inspection, the files did not meet the definition of auditable data as defined in Section 3 of IEEE-323-1971 and 1974.
Section 3 defines auditable data as information which is documented and organized so as to be readily understandable and traceable to permit independent verification of infer-ences or conclusions based on 'the information.
The inspectors acknowledge that the licensee had identified the problem and was under::aking a program to resolve it.
However, since the licensee failed to have auditable qualification files at the time of inspection, this is identified as Potential Enforcement/Unresolved Item (50-335/86-08-05; 50-389/86-07-04).
(2)
The NRC inspectors'eview and evaluation of the quali-fication files identified the following file specific problems:
(a)
General Cable, File 8.0, Unit 1 - When the inspectors in~ tially reviewed the file, they determined that the licensee based qualification of this cross-linked polyethylene (XLPE) insulated/polyvinyl chloride (PVC)
jacketed cable on test data from several different manufacturers of XLPE/PYC cable.
When the inspectors questioned the licensee relative to the use of dif-ferent manufacturers data, the licensee provided a
test report for General cable to support qualification in radiation and steam environments.
Additionally he provided a long term cable water submergence test to support cable qualification relative to cable degra-dation due to thermal aging considerations or qualified life.
Since the submergence test did not provide data that considered the effects of cable degradation in an air environment, the licensee was informed that the submergence test data was not sufficient to support a
qualified life for the cable.
Furthermore, the in-spectors determined that the licensee had not documented in the file, his resolution of FRC TER item No.
166 concerning cable submergnce and submerging fluid chemistry.
During the inspection, the licensee was able to demonstrate there were no General cable ap-plications in the plant that were subject to submer-gence; therefore, this TER item was resolved.
The licensee was able to resolve all the inspectors'ualification concerns in this file by the end of the inspection, except for documenting a qualified life for the cable.
This failure to support a cable quali-fied life with data documenting the aging character-istic of General cable is ~dentif~ed as a Potential Enforcement/Unresolved Item (50-335/86-08-06).
Limitorque Valve Operators, File 14.0 (Unit 1) and File 3.1 (Unit 2) - While these files had the generic concern relative to auditability, the file did not contain deocumentation to identify which operators required "T" drains and which required gear case grease relief valves.
This additional information was provided during the inspection.
The majo" concern with regard to these files dealt with the licensee's assurance that jumper wi res installed in Limitoruqe operators were qualified.
At the time of the inspection, the licensee had completed his activities for IE Information NotiCe ( IN) 83-72) but had not completed his activities connected with IE IN 86-03, which both dealt with this problem.
The licensee stated that he had documentation from Limitorque giving him assurance that his inside containment operators contained either Raychem Flamtrol and/or Rockbestos Firewall III qualified wires; furthermore he had inspected and changed out the Unit 1 ~nside containment operator jumper wires last fall.
He stated that he had changed the wires out so as to provide positive assurance, that he had qualified wire in the operators.
He stated that he planned to inspect and replace',
as necessary, the jumper whores in the Unit 1 outside containment operators on a schedule to be completed by June 1, 1986.
Ke planned to inspect and replace, as necessary,-
the Unit 2.operator wiring (both inside and outs~de containment)
during the refueling outage scheduled for April 5, 1986.
The NRC inspectors'eview and evalution of documenta-tion from the Unit 1 inside containment wire inspection/
replacement efforts identi fied a potential problem with the qualification of valve operator iumper wires.
The inspectors informed the licensee that since his records identified GE Yulkene SIS wire in several of the operators and this was contrary to the data Limitorque had provided, he should have recognized this as a potential problem and continued to inspect and replace, as appropriate wires in his remaining Limitorque operators.
During the plant walkdown the NRC inspectors identified one GE Vulkene SIS wire in one Limitorque operator and ITT "TFF" wire in another.
The licensee had data to support qualification of the GE wire, but could not support qualification of the "TFF" wire.
This failure to have qualification documentation for the "TFF" wire and failure to ensure that Unit 1 outside containment and Unit 2 inside and outside containment operators contain qualified jumper wires is identified as Poten-tial Enforcement/Unresolved Item 50-335/86-08-07; 50-389/86-07-05).
In addition to the above, the licensee should correct the following Limitorque related concerns identified by the inspectors.
[1]
Establish a posi tive method to identify terminal blocks in Limitorque valve operators and verify qualified terminal blocks are installed in the operators.
[2]
Tighten the sealflex connection to the operator on valve 2-Y-2553 and, repair the braid that was pulled out of the Sealflex connector on the operator for valve 2-MV-09-9.'3]
Remove valve operator 2-MV-3539 from the Eg List.
File review determined this should not be on the list.
[4]
Include documentation, which supports a demon-strated post-accident operability time of greater than 200 days, in the Unit 2 qualification file 3.1.
SCEW sheets for three valve operators (2-MY-09-9, 2-MV-09-11, and 2-V-2553)
documented the above post-accident operability time; however, support of this time was not identified in the file documentation.
The above items are identified as Open Items (50-335/
86-08-08; 50-389/86-07-06)
which will be reviewed during a future NRC inspection.
(c)
Victoreen Radiation Monitoring System, File 26.0, Unit 1 - The inspectors'eview of this file determined that the licensee had not adequately addressed the six deficiencies identified under TER item 140, relative to the FRC evaluation that qualification had not been established for the Victoreen radiation monitoring system.
The six defic~encies were:
[1]
No type tests referenced for severe temperature, pressure and steam service conditions.
f2]
No test or analysis of the effect of chemical sprays on the pressure housing gaskets.
[3]
Analysis assumption of a 16 minute operating time, when the DOR Guidelines state that assumed operating times should be at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
L4]
Victoreen pressure test report unavailable for review.
f5]
Applied Physics Analysis AP-TA-001 for thermal aging and temperature qualification analysis unavailable for review.
[6]
The licensee states that the monitor will provide a trip signal even if component failure occurs.
The DOR Guidelines state that component failure at any time, even in a so called "fail safe" mode, should be considered inconclusive.
Of particular significance was the failure to adequately address item Ll] regarding type tests.
The inspectors determine'd that documentation added to the file since the FRC evaluation consisted of two "SAND" (Sandia)
reports which documented failure analyses of similar detectors at Three Mile Island.
Additionally, the file did not identify or make any reference to cable or connectors used with the moni tor.
The cable and connectors should be referenced since their interfaces and performance have a significant impact on monitor operation.
Based on the inspectors'eview of the file as initially presented, he determined that the monitor qualification was not supported.
The licensee was able,to provide the inspectors a Victoreen test report and similarity analysis prior to the close of th'e inspection.
Addi-tionally, the licensee determined that Raychem cable and Raychem heat shrink tubing (over the connectors)
were used with this monitor and qualification of the cable and tubing was supported in other qualification files, which would be referenced in the Victoreen package.
The referencing of the Raychem cable and heat shrink tubing qualification files in the Victoreen files is considered an Open Item (50-335/86-08-09)
which will be reviewed during a future NRC inspection.
The licensee was able to establish qualification of the Victoreen radiation monitoring system prior to the end of the inspection; however, since qualifica-tion of the monitoring system was not supported at the start of the inspection, it is identified -as a Poten-tial Enforcement/Unresolved Item (50-335/86-08-10).
RDF Resistance Temperature Detector (RTD), File 39. 1, Uni t 2 - The NRC inspectors'eview of this qualifi-cation file determined that it was not auditable and that qualification of'he RTDs was not supported.
The file contained no documentation to support a qualified life for GE RTV 159 sealant used in the detectors
during loss-of-coolant accident
{LOCA) qualification testing.
Since unaged sealant was used in the detectors during the LOCA testing, the licensee needed to document the ability of the RTV 159 sealant to withstand LOCA environments in an end of life condi tion.
Mhen questioned about this, the licensee was able to support qualifica-tion of the sealant and subsequently the RTDs by per-forming an analysis of other qualification test data not previously in the file, referencing data from another qualification file, and obtaining additional data from Combustion Engineering (CE) during the inspection.
Since qualification of the RTDs was not established when the file was initially reviewed, this is identi-fied as a Potential Enforcement/Unresolved Item (50-389/
86-07-07).
Garrett Solenoid Valve, File 35.9, Unit 2 - The NRC inspectors'eview. of this qualification file determined that it was not auditable (see paragraph 4.D.(1)(a)[5]) and that qualification of the valves was not supported.
Of particular significance was the lack of documentation to support SCEM sheet values of a 1 year post design basis accident (DBA)
operability time and a qualified life of 40 years for the valves.
The file did not contain sufficient analysis nor the necessary calculations to support the stated values.
During the inspect~on, the licensee obtained data from CE and performed the necessary calculations to support the above values.
In addition, file documentation did not address similarity between the valves tested in test report 3750010 and those installed in the plant nor did documentation address the fact that valve gaskets were not radiation aged prior to DBA testing.
The licensee was able to support qualification by the end of the inspection; however, failure to fully support valve qualification with documentation when the file was initially reviewed is identified as Potential Enforcement/Unresol ved Itern
{50-389/86-07-08)
.
In addition to the above the licensee needs to clarify the file by including the following information:
[lj Documentation showing that limit (reed)
switches on valves are not required to be qualified,
[2j Documentation that galling problems experienced during qualification testing have been corrected on installed valves.
(g)
(h)
The above file additions are considered an Open Item (50-389/86-07-09)
which will be reviewed during a
future NRC inspection.
TEC Acoustic Flow Transmitter, File 23.0, Unit 1-The NRC inspectors'eview of this file identified problems with equipment maintenance and file audita-bility (see paragraphs 4.B.(2) and 4.D.( 1)(a)[3]).
The file was determined to support qualification of the flow transmitter; however, it was recommended that the licensee perform a review of functional and operational data from TEC test reports referenced in the file and document the review in the qualification file.
The inclusion of this data in the file would further support the qualification of the transmitter.
The inclusion of this data in the file is considered an Open Item (50-335/86-08-11)
which will be reviewed during a future NRC inspection.
Namco Limit Swi tches, File 15.1, Unit 1 - The NRC inspectors'eview of this file determined that qualification of the limit switches was supported by data supplied by Namco.
The inspector identified one discrepancy in that the qualification file docu-mented a maintenance requirement for replacement of elastic components every five years for inside con-tainment applications; however, EQ List, Revision 5, dated February 26, 1986 shows a replacement schedule of 10 years.
The licensee was able to demonstrate that the correct schedule is 5 years and that the plant's preventative maintenance schedule was based on a five year schedule.
The licensee said that he would correct the EQ List.
This EQ List correction is considered an Open Item (50-335/86-08-12)
which will be reviewed during a future NRC inspection.
Nicroswitch Limit Switches, File 9.4, Unit 2 - The NRC inspectors'eview of this file determined that the switches are subject only to radiation and the file supported qualification of the switches for this environment.
The inspectors identified that the SCEN sheet locations for switches 2-V-5203LS,
-5204LS, and-5205LS were incorrect and should be corrected.
The correction of the SCEW sheet loca-tions is considered an Open Item (50-389/86-07-10)
which will be reviewed during a future NRC inspection.
(3)
IE Information Notices and Bulletins - The NRC inspectors reviewed and evaluated the licensee's activities related to the review of EQ-related Information Notices (INs) and Bulletins.
The inspectors'eview included examination of Procedures and EQ documentation files relative to 17,
V
INs/Bulletins.
The review determined that the licensee does have a system for distributing, reviewing and evaluating INs/Bulletins relative to equipment within the scope of 10 CFR 50.49.
While it was determined that the licensee did not address INs/Bulletins in the qualification files, a review of his IN/Bulletin files for the equipment items selected for qualification file review indicated that appropriate actions had been or were being accomplished by the licensee, except for the IN 83-72 and 86-03 dealing with internal jumper wires in Limitorque valve operators (see paragraph 4.0.(2)(b)).
E.
Plant Ph sical Ins ection The plant physical inspection consisted of the examination of six types of safety-related equipment located outside containment on either/or both Units 1 and 2.
Since both units were operating during the inspection, examination of inside containment equipment was not possible.
The inspectors examined characteristics such as mounting configuration, orientation, interfaces, model number, environment, and physical condition.
Concerns identified during the physical inspection pertained to Limitorque valve operators and are discussed in paragraph 4.0.(2)(b)).
18