IR 05000395/1988023
| ML20196E444 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/01/1988 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20196E439 | List: |
| References | |
| 50-395-88-23, NUDOCS 8812090343 | |
| Download: ML20196E444 (14) | |
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- 4 UNITED STATES j,
. j NUCLEAR REGULATORY COMMISSION
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o, REGION ll t
g 101 MARIETTA ST., N.W.
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ATLANTA. GEORGIA 30323 Report No.: 50-395/88-23 Licensee:
South Carolina Electric and Gas Company
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Columbia, SC 29218 Docket No.: 50-395 License No.: NPF-12 Facility Name:
V. C. Summer Nuclear Station Inspection Conducted: October 17-21, 1988 N/A d
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Inspector:
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N. Merriw6ather, Team Le& der. RII Date Signed
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I Team Members:
W. Carpenter, Consultant Engineer, Idaho Mational Engineering Laboratory (INEL)
C. Paulk, Reactor Inspector, RII W. Roesener, Consultant Engineer, INEL C. Smit, Reac$or Ins ector, RII e
Approved by:(
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T. E. Con'on, Chief 06te Signed r
Plant Systees Section Engineering b*anch Division of Recctor Safety
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i SUMMARY Scope:
This special announced inspection was ronducted in the area of Environmental Qualification (EQ) of E*ectrical Equipment which included:
a review of South Carolina Electric and Gas Company's implementation of a program to meet the requirements of 10 CFR 50.49; walkdown inspections of equipment inside containment; preventive and corrective EQ maintenance; EQ Procurement; and followup on previous inspection issues and comitments.
Results:
In the areas inspected, one violation was identified involving mixed grease in limitorque operators, paragraph 3.b.
The root cause for the violation was riue to the licensee's failure to take adequate corrective action in response to INP0 SER No. 7-84 which identified
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the potential problem of having mixed grease in limitorque actuators.
The licensee failed to evaluate all limitorques, both inside and outside containment, resulting in a small population of valves being omitted, i
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0812090343 001200
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PDR ADOCK 05000395 PNU
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This inspection was considered to be Phase II of the previous EQ inspection which was conducted January 11-15, 1988.
The previous inspection concentrated on EQ equipment located outside containment because the plant was operating-preventing containment walkdowns.
The team conclnded during the first inspection that "SCE&G had implemented. program which meets the requirements of 10 CFR 50.49 for VCSNS although some deficiencies were identified."
During this inspection, the team concluded that SCE&G continues to have an adequate EQ program.
The program is not outstanding at this point, however, there are certain initiatives that are currently ongoing which will greatly enhance the EQ program.
One strength found in the licensee's program was the commitment of upper management to support the EQ enhancement program and to resolve NRC concerns and initiatives in a timely manner.
The deficiencies identified in the license's EQ program were documented in the first inspection repcrt as violations and unresolved items.
The licensee is aggressively pursuing the corrective actions on these items as part of their EQ Enhancement Program and followup on these items is discussed in this report.
The licensee also made certain commitments as discussed in paragraph 3.c. and 3.f.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- M. Browne, General Manager, Station Support
- R. Campbell, Senior Engineer
- S. Carroll, Representative, Design Engineering
- R. Clay, Manager, Design Engineering
- S. Crumbo, Senior Engineer, Design Engineering
- H. Donnelly, Senior Engineer, Regulatory Interface
- W. Higgins, Supervisor, Regulatory Compliance
- S. R. Hunt, Manager, Quality Systems
- J. Jordan, Engineer, Design Engineering
- F. Miller, Jr., Quality Systems
- G. Moffatt, Manager, Maintenance Services
- D. Moore, General Manag2r, Engineering Services
- G. Mundy, Design Engineer
- J. Nesbitt, Electrical Maintenance
- J. Proper, Associate Manager, QA
- J. Skolds, General Manager, Nuclear Plant Operations
- G. Soult, General Manager, Operations
- R. Waselus, Supervisor, Design Engineering
- T. Wessner, Representative, Design Engineering Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personnel.
Other Organizations
- J. Breon, Lead Senior Engineer, Impell
- D Kelly, Principal Electrical Engineer, Gilbert C.qmonwealth
- T. Reitz, Control Systems Engineer, Gilbert Commonwealth Other NRC Personnel
- J. Hayes, Project Manager, NRR
- P. Hopkins, Resident Inspector, RII
- Attended exit interview 2.
Evaluation of Licensee's Program for Qualification of Electrical Equipment Located in Harsh Environments (TI 2515/76)
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This inspection was considered a continuation of the first inspection except concentrating on those inside containment components which were not physically examined during the first round EQ inspection.
Similar to the first inspection, the NRC inspectors examined files as the basis for qualification; performed walkdown inspections of equipment (inside containment only); continued the review of the EQ maintenance program; examined the licensee's commercial grade dedication process for EQ applications; reviewed EQ training; and examined what actions had been taken on previous inspection concerns.
The results of the inspection and the conclusions reached are discussed below:
a.
Maintenance The licensee is currently re-inspecting all EQ equipment located in a harsh environment in accordance with maintenance special instructions (MSIs).
Completed MSI forms were checked for a limitorque, ASCO Soler.oid Valve (S0V), and a NAMC0 limit switch.
In general these MSis are extremely comprehensive and if used properly during component inspections will help assure the "as left" components will be in their environmentally qualified condition.
The three completed MSIs which were inspected were filled out completely. Any omissions were explained and initialed.
It appears the proper usage of thase forms is being taken very seriously by V. C. Summer personnel.
At present, two of the 10 inside containment limitoruges have been inspected with no findings which would insalidate their EQ.
b.
EQ Personnel Training The first round EQ inspections identified weaknesses in the EQ training of licensee personnel with assigned responsibilities for implementation of the EQ program.
Licensee management in Enciosure IV to their letter dated May 24, 1988, addressed to Dr. J. Nelson Grace, Region II Regional Administrator, provided information regarding EQ training that would be given to their employees under the controls of the EQ Enhancement Program.
The scope of the EQ training were specified by the EQ Enhancement Program activities number Al through A4.
The inspectors conducted interviews with members af the training staff and reviewed objective evidence to verify completion of the above activities.
Upgrade of the EQ training program for maintenance and QC personnel, activity A1, resulted in the development of lesson plan AQA06-001.
Based on review of training attendance records and examination grade result; the inspector confinned that upgraded EQ training for maintenance and QC personnel had been completed.
Activities A2, required the development of an EQ training program for the engineering staff.
This activi ty was completed with
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the development of the following lesson plans: DEA 01-001, Introduc-tion; DEA 01-002, The EQ Process; DEA 01-003, Documentation; DEA 01-004, Aging Theory; and DEA 01-005. Maintaining Qualification.
The inspectors verified that the above lesson plans had been taught and acceptable examination grades had been achieved by the attendeec.
The licensee has met his commitment for EQ training of the engineer-ing staff.
A Minor weakness was identified with the EQ training of QA personnel in that training records could not be found for one individual.
Based on discussions with p tonnel from this organization, however, the inspectors determined t a, EQ training over and above licensee's commitment was indeed giver, to QA lead auditors.
No EQ related deficiencies were identified in this area.
c.
EQ Equipment Replacement and Spare Parts Procurement Design Guide PR-02, Critical to Function Attributes Determination, provides specific guidance for determination of the critical characteristics of spares or replacement parts.
An engineering
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evaluation of the parts function and environment in a specific application is performed to identify the critical characteristics defined by dimensions, physical properties, chemical properties, material composition, performance requirements.
The dedication process is used to verify the critical to function characteristics of an item and provides assurance that these characteristics are within specified limits or tolerances.
General guidance for developing dedication criteria for spare or replacement parts is given to the engineering staff in Design Guide Number PR-03, Basic Dedication Methodology.
The inspectors reviewed two purchase requisitions to verify procedural compliance with the above design guides during the dedication process.
Purchase Requisition Number 278731 was prepared for procurement of commercial grade Dow Corning Sylgard 170B elastomer.
Requirenents for a specified shelf life was imposed on the purchase order and dedication of the product was performed by the licensee in accordance with SCE&G Procurement Technical Requirements.
PTR-MS-3.
Specified tests and acceptance values of identified critical characteristics of the Sylgard 1708 elastomenr were contained in this document.
Purchase Requisition Number 371051 was prepared on October 17, 1988 for procurement of Reed Switch assembly Target Rock Part Number 100967-1.
Requirements for provision of the Certificate of Conformance from the original vendor in addition to a copy of the Qualification Test Report was imposed on the order.
Additionally, requirements were established for dedication of the switches, and acceptance criteria had been specified for the critical character-istics.
No EQ related deficiencies were identified during this revie.
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In Plant Physical Inspection The inspection team physically inspected 21 qualified components and selected field run cables.
The inspection team examined character-
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istics such as mounting 5.'onfigurations, orientation, interfaces, name plate data, moisture intrusion seals, splices, internal wiring and
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physical conditions.
Since the EQ files had been previously reviewed
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during inspection 88-01 only a cursory review of selected EQ files
were made to confirm special ins;allation or mainterince requirements and equipment qualified lifes. No significant walkdown concerns were identified which were not already addressed by the licensee in
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NCN-2852.
A more detail discussion of the equipaent examined and walkdown results are in the paragraphs that follow.
t (1) Barton Transmitter Model 764, Equipment Tag No. LT-474 l
No deficiencies or open items were identified.
(2) MINC0 RTD, Equipment Tag No. ITE 1313/1314
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No deficiencies or open items were identified.
(3) CONAX, Electrical Penetration Assembly, XRP 0106 A&B No deficiencies or open itens were identified.
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(4) D.G.O'Brien,ElectricalPenetrationAssembly,XRP00gA
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No deficiencies or open items were identified.
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(5) Rosemount Transmitter Model 1153, Equipment Tao No. ILT-1969/1975
No deficiencies or open items were identified as a result of the l
walkdown.
An Unresolved Item dealing with instrumert loop
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accuracies was inspected. The results are reported in paragraph
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F (6) Limitorqu,e 'h.1ve Serators Tag NO. 8 Stripped fit:ld wires were used to connect limit switch to torque switch and for jumpers on lirt; switch:
These wires could not be identified on the walkdown except to establish that they were identical to the field cable coming into the limit switch
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compartment.
Subsequent record audit using L ^,
the condait 10 showed these wires to be 1, '
environmentally qualified Kerite wire.
b There are no E0 concerns regarding this MOV.
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Tag No, (995 B:
Same cormient and conclusionc as MOV 8096 A
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Tag h. 8112:
Same comment arid conclusion regarding field wire as dO96 A (above). with the additionai
initial concern of a "sifted leed" with a (black) taped end.
Record audit showed this to be a spare wire.
There are no EQ
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concerns regarding this MOV.
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c No. 9006 0
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.nd 8095 A:
No EQ concerns.
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(7) ASCO SOVs Tag Nos. PCV 444B and PCY 445A:
Thase two SOVs were being
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re-worked at the time of the walkdown and were not in their
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final mounting configuration.
Of note worthiness was the fact
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air lines leading to them.
The licensee furnished documentation
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no EQ concerns.
l Tag No. 4458:
This SOV wts not p. st c. Room 37-01 due to h
re-work but it will be rigidly instal 5;;d ',;h brackets since the
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I air lines to it are tubing and not hard >.pe.
Tsiere are no EQ
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i (8) NAMCO Limit T.;tches j
l ASCO PCV 444B had its associated two NAMCO Limit Switches (LS)
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hermetic connector. No EQ concerns were identified.
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(9)
I Tag Nos. XVX 00508 and XVX 6051B
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The ela ' Heal connection was a D. J. F,
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There are no EQ concerns reg, i
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(10) Targe Rock SOVs - Tag Nos. XVX 9356 A&B These two S0Vs were observed from about five feet since tney were in a high radiation area.
Both appeared to be in good condition, were rigidly mounted on steel brackets using U-bolts and had D. G. O'Brien hermetic electric connectors.
No EQ concerns were identified.
(11) Hyde gen Recombiner, Tag No. XHR004A No deficiencies or open items were identified.
(12) Reliance Motor for Reactor Building Cooling Unit Tag No. MFN0097A No deficiencies or open items were identified. Verification of the breather / drain plug was done by observing pictures taken during recent maintenance on the unit.
(13) Victoreen high Range Radiation Monitor No deficiencies or open items were identified.
The unit was installed in a sealed / welded stainless steel system from the detector to the penetration as described in the test report.
(14)RaychemSplices Raychem splices were observed on trrnsmitters, solenoid valves and limit switches; and in electrical penetration assembliet.
Limitorque operators, and the hydrogen recombiners. All splices observed were satisfactory,
e.
Cable Identification and Traceability to Cable EQFs The following circuit numbers, obtained during the containment walkdown, were given to the lictisee to establish traceability of the cables involved:
ICB604-A; MSU41A; and NDU7A.
Additionally, the licensee was asked to identify the circuits in conduit number XX3935B and verify EQ of the cable types routed through the conduit.
The licensee presented documentation consisting of conduit block diagrams; cable pull sheets; bill of materials; and Environmental qualification Data Packages.
Pursuant to the inspectors review of the documentatior, it was determined that the information presented was adequ6te to show traceability and CQ of the field cable. No EQ identified.
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.3.
Action On Previous inspection Findings
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a.
(Closed) Violation 50-395/88-01-01, Missed EQ Maintenance Requirements During an inspection conducted January 11-15, 1988 EQ maintenance on i
Emergency Feedwater (r,FW) Pump MMP-0021A was found to have exceeded the required annual period for two consecutive years.
The licensee
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responded to this violation by letter dated May 25, 1988, and was in i
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agreement with the violation.
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The licensee stated that a grace period was applied to the lubrica-L tion schedule of the EFW pump in error.
The input into CHAMPS
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allowed a 25". grace period to be applied to the annual lubrication
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period, thereby, permitting an extra three months on the schedule.
Since-this maintenance was required to maintain the equipment
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The licensee, in response to the violation, performed an indepth
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review of all EQ maintenance requirements and developed a list of
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when those maintenance activities were performed. This was performed in accordance with NCN-3041 and the history files were reviewed back to October 22, 1982, the date of initial operation.
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129 items were identified that either did not have the Idaintenance i
perfomed or the maintenance was late.
For those items which were
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historical in nature, the licensee evaluated each on a case-by-case
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basis and detemined there vere no operability issues, nor were there
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any instances that the equipment would not have perfomed its
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For those items that were identified as being late during
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implementation as soon as possible.
Some of the currective actions
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These were also evaluated for i
operability and ability to perfom their function, and were
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The licensee incorporated the maintenance requirements into its EQ i
j Maintenance Manual and the EQF.
The EQ Maintenance Manual is a l
compilation of the maintenance sections from all the EQFs.
In order j
to maintain an accurate and up-to-date EQ maintenance program, the j
l licensee is in the process of fine tuning the maintenance manual.
One task the licensee is pursuing is evaluating the time period for L
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lubrication and calibrations.
Since both of these are presently set
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I d 18 months in most instances, an evaluation is being done to change
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this to every refueling cutage and requiring that the task be (
performed prior to start-up.
This will ease ame of the maintenance j
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work load by allowing the tasks to be spread out over the outage, j
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Based on the licensee's action and review of the EQ Maintenance
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Manual. NCN-3041, and the apolicable JC0s, this item is closed.
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b.
(Closed) Unresolved Item 50-395/88-01-02. Mixed Grease in Limitorque Valve Operators During an inspection conducted January 11-15, 1988, a potential for
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mixed grease in limitorque valve operators was identified.
During the inspection, the licensee was questioned on the completeness of NCN-1673 which was prepared in response to SER 7-84.
The SER identified specific serial numbers which the licensee based its actions on.
The intent of the SER was to identify all limitorque motor operators of size 0 to 4 as having the potential for mixed grease.
During the inspection in January the licensee identified 11 operators that were missed on the initial review.
Subsequent to the inspec-
tion, three more operators in a harsh environment were identified, t
Of these operators, two had the grease replaced prior to November 30, j
1985; four never had any grease added; the remaining eight had the potential for having mixed grease.
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t The licensee has scheduled to replace the grease in the four
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operators that did not have mixed grease during Refueling Outage 4 which is presently in progress.
Three of the operators which had the potential for mixed grease were samplad and the grease replaced during this inspection.
The results indicated a mixing of greases did occur. The remaining valves are scheduled to be sampled and have
tne grease replaced during the outage.
i Based on mixed grease being confirmed, the unresolved item is closed
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and Violation 50-395/88-23-01, Inadequate Corrective Action for INP0 L
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SER 7-84 is opened.
Based on the licensee's present corrective
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actions, no response will be required and the violation is closed.
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c.
(Clr. sed) Unresolved Item (50-395/88-01-03), Resolution of NCN-2852
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and NCN-2661
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At the time of the first round EQ inspection the licensee was
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involved in implementing the EQ Enhancement program which included
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walkdowns of equipment on the basis rf accessibility.
Deficiencies
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identified by the licensee during equipment walkdowns were documented
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on Nonconfornance Notice (NCN) 2852, and disposition 42 of this NCN
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was prepared to address the nature of the deficiencies found; operability of the affected equipment; and provided Justification for Continued Operation (JC0) for equipment not yet inspected.
Because of the broad scope of the deficiencies identified which involved i
various equipment types across multiple systems this issue was identified as an unresolved iten.
The licensee in their letter dated May 25, 1988, to l
Dr. J. Nelson Grace, Reponal Administrator, included an updated Equipment Qualification Enhancement Program schedule.
This program
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described activities developed as part of the corrective action plan for resolution of the environmental qualification problems.
The inspectors conducted interviews with licensee management and reviewed the status of selected activitier dcscribed in the most recently revised version of the EQ Enhanct_ 7t Program dated October 12, 1988.
~ 2852-2 has been developed and is Maintenance Special Instruction,1
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presently being implemented to r Ide inspection criteria for the acceptance or rejection of Class
. instrument termirition splices.
This activity fulfills a licenset ommitment previously made in the i
first round EQ inspection.
Adt,tionally, the following MSIs, completed at the time of the first round EQ inspection, are presently being used during performance of enhancemant program activity B.1, Inspection of harsh environment equipment.
MSI 2852-1, Inspection of Control Termination / Splices Per NCN 2857 Revision 5 MSI 2852-3 Inspection of 480V Power Termination /Sp? ices Per NCN 2852, Revision 3 MSI 2852-4, Solenoid Valve Inspection / Limit Switch Inspection, Revision 4
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MSI 2852-5. Inspection of Limitorque Motor Operated Valves Per NCN 2852, Revision 5
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MSI 2852-6 Inspection of 7.2 KV Power Termination / Splices Per NCN 2852 Revision 0 l
MS! 2852-7, Inspection of Penetration Junction / Splice Boxes Ps.
NCN 2852 Revision 0 The inspectors verified that training had been provided to the Electrical Maintenance craf t on the use and requirements of the MSIs.
Similar training has also been given to licensee contractors who are
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presently involved in equipment walkdowns during egfueling outage (RF0) Number 4.
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The status of maintenance activity B.1 was next reviewed by the inspectors.
In response to the inspector's request for information
concerning this activity, licensee management provided the following tabulation of equipment types for which walkdown inspections had been
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EQUIPMENT INSIDE CONTAINMENT Equipment Type Total Complete Percent Rosemount 1153
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A0V (ASCO, NAMCO)
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Barton
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ASCO (Alone)
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2
Limitorque W/NAMC0
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Fan MTRS (RELIANCE)
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Panels
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Gamma-Metrics Detector
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Gamma-Metrics J.B.
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Valcor S0L Valve
1 12.5 Target Rock SOL VLV
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TEC Monitor
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PYC0 (Dual Element
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Counted as one)
RDF TEMP. Element
0
MINC0 TEMP. Element
0
Victoreen
0
H2 Recombiner
0
Rotork
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TOTALS 121
9 EQUIPMENT OUTSIDE CONTAINMENT Equipment Type Total Complete Percent Rosemount 1152
0
Rosemount 1153
5
A0V (ALLIED)
0
A0V(ASCO,NAMCO)
20
A0V (SKINNER)
2
Barton
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ASCO (ALONE)
3 100 Veri trak
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2 100 CCW MTRS (W)
3 100 Fan MTRS (RELIANCE)
3 100 RHR MTRS (W)
2 100 CH/S! MTRS (W)
3 100 NAMC0 (ALONE)
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Transfer Switch
O Panels
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Gamma-Metrics AMP
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Valcor SOL Valve
6 100 Target Rock SOL VLV
4 1 00 TOTALS 201 101
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Operability reviers, JCOs and walkdown evaluations, Activity IV.2, involves an engineering review of the results of the field walkdowns of harsh environmental equipment for reportability to the NRC.
The licensee has contracted with Impell Corporation for performance of these reviews. The inspectors reviewed procedure ES-407, Disposition of Site Nonconformances, and discussed with licensee engineering personnel and contractors the process by which completed MSIs are received in design-engineering from the walkdown teams and the status of engineering reviews performed by Impell Corporation.
Proce-dure ES-407 paragraph 6.3.2, specifies the disposition actions required by design-engineering and requires a 10 CFR 50.59 evaluation for nonconformances dispositioned accept-as-is or repair. Addition-ally, an evaluation for reportability in accordance with the requirements of 10 CFR 21,10 CFR 50.72, and 50.73 is required to be performed.
Administrative controls for performing operability evaluations per Generic Letter 88-07 are not specifically addressed in procedure ES-407.
Licensee management attributes this to the diverse nature of the EQ deficiencies for which corrective actions are presently beirl taken.
Based on the inspectors' review of selected examples isted on a computer printout sheet, titled "EQ Operability Evalua, ons", it appeared that technical and operational concerns are adequacely addressed during this process.
Discussions were held with licensee management concerning the status of the EQ Enhancement program in general, and the program activities reviewed by the inspectors in particular. The licensee has committed to completing inspections and repairs of EQ equipment located in inside containment prior to start-up of the unit from RF04.
This commitment does not include completion of the operability reviews for reportability to the NRC.
The results of the operability reviews along with an evaluation of the effectiveness nf the completed corrective actions and an overall assessment of V. C. Summer EQ program will be provided to the NRC at a later date.
Licensee management will track this commitment via Regulatory Tracking System Number REM 880029.
NCN 2661 was written by the licensee to document a problem with Raychem heat shrink material which had been installed over braided material for ASCO solenoid valves.
The problem was determined to be generic and the root cause was found to be inadequate installation procedures.
The installatiot, procedure did not include requirements for removal of the woven braid material.
The procedure was revised and engineering evaluations were performed to assess the adequacy of splices on (1) vendor supplied leads for solenoid valves and dampers; (2) limitorque motor operations; (3) 480 Volt Motors; and (4) vendor supplied leads for transmitters.
Based on corrective actions completed the licensee has closed NCN 266 _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _
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- Pursuant to review of selected activities of the EQ Enhancement program and discussions with licensee management the inspectors determined that adequate resources have been allocated for resolution of the identified problems. Additionally, the licensee has committed to make completion of inspections and repairs of all EQ equipment inside containment a start-up item, and will provide a comprehensive assessment of V. C. Summer EQ program and completed corrective actions to the NRC.
Based on the above actions taken by the licensee, Unresolved Item 50-395/88-01-03 is closed.
d.
(Closed) Violation 50-395/88-01-04, Insufficient Information in
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Qualification File for Lubricants.
During an inspection conducted January 11-15, 1988, deficiencies were noted in EQF-LU2-G13-1282, Lubricants-Grease.
The deficiencies were noted as nnt establishing the similarity of the Gulf Lubricants with
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those qualified lubricants that the Gulf products were replacing.
The licensee responded to this violation by letter dated May 25, 1988, and was in agreement with the violation.
The licensee stated that the cause of the violation was the lack of programatic controls which allowed the EQ file to be affected by equal-to-or-better-than evaluations without being properly revised.
Instructions to preve. t this in the future were proceduralized in TS-161, Rev.1, Equal-to-or-better-than Evaluation dated January 25, 1988.
This procedure was superseded by ES-323, Rev. O, equal-to-
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or-better-than evaluation dated September 1,1988.
The change was
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due to the reurganization the licensee underwent, j
i The file deficiencies identified were corrected when the file was j
revised as part of the enhancement program.
The original file was
superseded by EQDP-LU2-G13, Lubricant Greases, Rev. O, August 29,
1988.
The new file was reviewed and found to be acceptable with additional information supplied by the licensee shortly after the
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conclusion of the inspection, i
i
!
dased on the revision of the files and the proceduralization of i
eaual-to-or-better-than evaluations, this violation is closed.
I e.
(Closed) Violation 50-395/88-01-05, IR Values for Performance j
Characteristics Not Prnperly Established in EQF The Phase ! EQ inspection identified Violation 50-395/88-01-05, IR
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I Values for Performance Characteristics Not Properly Established in
!
EQF.
During the Phase II EQ inspection, the inspectors found that
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the licensee had met its comitments to obtain and incorporate test I
reports which support the IR perfomance characteristics for both
CONAX and D. G. O'Brien Electrical Penetration Assemblies.
In the case of the CONAX penetrations, test reports IPS-1089 and IPS-5852, i
which both contain data taken before, during and af ter the LOCA test, were included in EQDP-C05-C08, "CONAX Electrical Penetration
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_
,
_ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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_ __
_
_
,
d
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Assembly," and used in the associated IR calculations contained in VCS-423-DC15, subsection A20.
In the case of the D. G. O'Brien penetrations, test reports ER-252 and 1R-070, containing data taken before, during and after the LOCA test, were included in EQDP-C05-001-2,
"D. G. O'Brien Electrical Penetration Assembly," and used in the associated IR calculations contained in VCS-423-DC15.
Based on the results of the Phase II EQ inspection, Violation 50-395/88-01-05 is closed.
f.
(0 pen) Unresolved item 50-395/88-01-06, Re-evaluation of Instrument Loop Accuracy Calculations Concerning Negative Margin The Phase ! EQ inspection identified Unresolved Item 50-395/88-01-06, Re-evaluation of instrument Loop Accuracy Calculations Concerning Negative Margin.
During the Phase II EQ inspection, the inspectors found that the licensee had completed the evaluation of instrument loop accuracies.
The evaluation indicated that four detectors have negative margirs greater than that allowed in the FSAR.
The instruments and accuracies are:
Accuracies Tag Functional Shown in FSAR Calculated Nos.
Description Table 7.5-1 Error LT-1969 & 1970 RHR Sump Level-10%
-58.3%
Detector (Rosemount)
LT-1975 & 1976 Reactor Building-10%
-14.1%
Level Detector (Rosemount)
The licensee has identified that the negative margins are not in compliance with the FSAR and has perfcrmed a 10 CFR 50.59 analysis which concludes that the non-conformity is not an unreviewed safety question.
The licensee has committed to rt placing the transmitters with qualified equipment having the appropriate accuracies by start-up after refuel 5.
This issue will continue to be tracked as an unresolved item until the transmitters have been replaced, g.
(Closed) Violation 50-395/87-30-02, V-Stub Taped Splices Not Environmentally Qualified During an inspection conducted October 20-23, 1987, deficiencies were noted with the taped splice file and the tape installation procedures, the licensee responded to this violation by letter dated December 10, 1987 and concurred with the citing.
The taping procedures prohibited the use of tape on instrument circuits inside containment and in areas subject to a high energy line break.
The procedures did permit the use of tape for power and control circuits, but the V-stub configuration was not aildressed in the qualification fil _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ - __ ____________ ____-___ ___ _______ ____ __ _ ___ _ ____ _ _ ___ _______________ _ ___
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The licensee revised the qualification file to qualify the V-stub tape splices by similarity.
The licensee has also changed its policy to require all splices inside containment, with the exception of the
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Reactor Building Cooling Units, to be made using Raychem heat shrinkable tubing. The changeover to Raychem will be completed prior to start-up from the present refueling outage.
Based on the corrective actions taken, this item is closed.
Exit Interview 4.
The inspection scope and results were summarized on October 21, 1988, with those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results.
Dissenting comments were not received fron the licensee; howevert the licensee did make certain commitments which are discussed in Paragraphs 3.c and 3.f.
One violation was identified to the licensee as discussed in Paragraph 3.b above, for having potentially mixed grease in the gear case of eight inside containment limitorque operators (Violation 50-395/88-23-01).
Proprietary information is not contained in this report.
5.
Acronyms and Initialisms Environmental Qualification EO
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EQDP -
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INPO -
Institute of Nuclear Power Operatitns Insulation Resistance IR
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Justification for Continued Operation JC0
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Level Transnitter LT
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Motor Operated Valve MOV
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Maintenance Special Instruction MS!
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MTRS -
Motors Nonconformance Notice NCN
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Pressure Control Valve PCV
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SCE&G-South Cdrolina Electrical and Gas Con.pany Significant Event Report SER
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Solenoid Valve 50V
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Temperature Element TE
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VCSNS-V.C. Summer Nuclear Station
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