IR 05000400/1988004
| ML18005A444 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/27/1988 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A443 | List: |
| References | |
| 50-400-88-04, 50-400-88-4, NUDOCS 8806060036 | |
| Download: ML18005A444 (38) | |
Text
t
,~<<~c>,
~
(4
'Ip0 co
/p +**++
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.:
50-400/88-04 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Shearon Harris License No.:
NPF-63 Inspection Conducted:
March 7-11,
8
.
M rr1weather, earn eader Date Signed Date igned Team Members:
Q. Decker, Consultant Engineer, Idaho National Engineering Laboratory (INEL)
M. Levi s, Reactor Inspector, RI I R. Moist, Equipment Qualification and Test Engineer, NRR C. Paulk, Reactor Inspector, RII C. Smith, Reactor Inspector, RII H. StrombeI'", Consultant ng'neer, INEL Approved byC T.
E. Conlon, Section Chief
'Plant Systems Section Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was in the area of Environmental Qualification (EQ) of Electrical Equipmen and included a review of Carolina Power and Light Company's (CP&L) implementation of the requirements of
CFR 50.49; plant walkdown inspections of electrical equipment within the scope of
CFR 50.49; and a followup on previously identified EQ deficiencies (10 CFR Part 21 report on High Range Radiation Monitor).
Due to the fact that the unit was operating, the walkdown inspections were limited to equipment located outside containment.
Therefore, a
subsequent inspection may be performed to examine items inside containment.
However, the licensee's programs and procedures for the EQ Program were considered adequate.
Results:
No violations or deviations were identified.
'880b060036 880520 PDR ADOCK 05000400
REPORT DETAILS Persons Contacted Licensee Employees
- H. R. Banks, Manager, Corporate Quality Assurance
- P. Brady, Senior Engineer, Harris Plant Modificati on Unit
- J. L. Harness, Plant General Manager, SHNPP
"M. Heath, Project Engineer
"K. M. Heffner, Senior Engineer, Maintenance Department
"W. T. Helms, QA Engineer
- M. E. Jackson, Project Engineer, Maintenance Department
"J.
M. Lewis, Senior Engineer, Nuclear Engineering Department
- C. L. McKenzie, Principal QA Engineer
- D. Morrison, Project Engineer, On-Site Nuclear Safety
- L. Olsen, Project Specialist, Technical Support
- R. J. Phillips, EQ Engineer, Nuclear Engineering Department
- A. W. Powell, Manager of Training
"P. Salas, Senior Engineering, Licensing
- R. Sanders, Nuclear Engineering Department Section Manager
- J.
R. Sipp, Manager, E&RC
"L. Sullivan, Technical Support Representative
"D. Tibbitts, Director, Regulatory Compliance
"M. Turkal, Senior Engineer, Licensing
- R. B.
Van Metre, Manager-Technical Support
- M. Wallace, Senior Specialist, Regulatory Compliance
- L. Woods, Engineer Supervisor
- R. Zula, Project Engineer, Technical Support Other Organization
"D.
R.
Rhyne, EQ Engineer, Patel Engineers Incorporated NRC Resident Inspector
- G. Maxwell, Senior Resident Inspector
"Attended exit interview Exit Interview The inspection scope and findings were summarized on March 11, 1988, with those persons indicated in Paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee.
Howe'ver, the licensee did make certain commitments which are discussed in paragraph 6.h and 6.i.( 12).
The following new item was identified during this inspection:
ill
Unresolved Item 50-400/88-04-01, Nylon Type Crimp Connectors on Dual Voltage Limitorque Actuators.
Two dual voltage Limitorque actuators had nylon type crimped wire 'connectors on the motor joints.
Two additional operators located inside containment are also suspected to have the unidentified wire connectors.
These connectors are not considered to be qualified by Limitorque test reports, although they were supplied by Limitorque as a component inside the safety-related operators.
The licensee is pursuing obtaining additional information from Limitorque to establish qualification for these connectors.
The licensee did identify some material as proprietary during this inspection, but this material is not included in this inspection report.
3.
Licensee Action on Previou's Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items-Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.
One unresolved item identified during thi s inspection is discussed in paragraph 6.i. 12.
5.
Background Equipment that is used to perform a necessary safety.function must be demonstrated to be capable of maintaining functional operability under all service conditions postulated to occur during its installed life for the time it is required to operate.
This requirement is embodied in GDC
and 4 of Appendix A to
CFR
and is applicable to equipment both inside and outside containment subject to a harsh environment.
The detail requirements and guidance relating to the methods and procedures for demonstrating this capability for electrical equipment have been delineated in
CFR 50.49,
"Environmental gualification of Electric Equipment Important to Safety for Nuclear Power Plants,"
"Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment",
and various NRC regulatory guides and industry standards.
Safety-Related electric equipment located in a
harsh environment at Shearon Harris is requi red to be qualified to NUREG 0588, Category II.
Replacement equipment must be upgraded to meet the requirements of 10 CFR 50.49 (NUREG 0588, Category I) or reasons to the contrary must be adequately documente The t'hree categories of electrical equipment that must be qualified in accordance with the provisions of 10 CFR 50.49 are:
a.
Safety-Related electrical equipment (equipment relied on to remain functional during and following design-basis events)
b.
Non-Safety-Related electrical equipment whose failure under the postulated environmental conditions could prevent satisfactory accomplishment of the safety functions by the safety-related equip-ment.
c.
Certain postaccident monitoring equipment (RG 1.97 Category 1 and
postaccident monitoring equipment).
To document the degree to which the environmental qualification program complies with the NRC EQ requi rements and criteria, the licensee provided equipment qualification information by letters dated August 27, September 11, and December 23, 1985, and January 23, January 31, and March 5, 1986, to supplement the information in FSAR Section 3. 11.
The staff reviewed the licensee's EQ Program at Shearon Harris and concluded that the licensee had demonstrated full conformance with the requirements for environmental qualification as detailed in 10 CFR 50.49, the relevant parts of GDC
and 4,
and Sections III, XI, and XVII of Appendix B to
CFR 50, and with the criteria specified in NUREG 0588.
The detail results of the staff's evaluations were documented in Safety Evaluation Report, NUREG 1038, Supplement 4, Section 3. 11,
"Environmental Qualifica-tion of Electrical Equipment."
The status of the licensee's compliance to Regulatory Guide 1.97 for post-accident monitoring equipment (Category b(3)
equipment in
CFR 50.49)
is'addressed in Supplement 3, Appendix H
to the Safety Evaluation Report (NUREG-1038).
The purpose of this inspection was to determine if the licensee had implemented an adequate EQ program to identify electrical equipment covered by the EQ rule ( 10 CFR 50.49)
and had reviewed and analyzed qualification data to establish qualification files that clearly demon-strated that the safety-related electrical equipment on the EQ master list was qualified.
Additionally, the inspection was to confirm that adequate procedures and controls were in place to maintain the qualified status of equipment during its qualified life, to assure the EQ requirements are considered during procurement and plant modifications and to verify that the licensee had established training programs to make personnel knowledgeable of the requi rements of 10 CFR 50.49.
Findings The NRC inspectors examined the licensee'
program for establishing the environmental qualification of electric equipment within the scope of
CFR 50.49.
The program was evaluated by ( 1) physical inspection of EQ
i
equipment, (2) examination of EQ files and the basis for qualification, (3) interviews of personnel involved in EQ Activities, (4) review of the EQ Master List, (5) review of EQ training, (5) review of licensee's handling of new and emerging EQ'ssues in NRC Notices and Vendor data, and (6) examination of the licensee's maintenance program for maintaining the qualified status of the covered electrical equipment.
The inspection results indicate that the licensee has implemented a program which meets the requirements of
CFR 50.49 in all areas.
One unresolved item was identified regarding the use of potentially unqualified crimped type connectors in dual voltage limitorque motor operators.
The licensee's training programs on EQ were considered weak.
However, the licensee was aware of this weakness and is currently taking the necessary corrective actions.
A more detailed discussion of the licensee's EQ programs for specific areas such as maintenance, IE Notices and Bulletins, procurement, master list of EQ equipment,. training, EQ files, and walkdown results are in the paragraphs that follow:
Maintenance The EQ maintenance program review was conducted by reviewing main-tenance procedures, histories, and schedules.
These documents were compared with the requirements set forth in the Qualification Data Packages (QDPs)
and were found to be well organized and controlled as well as accurate and acceptable.
The schedule for replacement of EQ equipment at the end of its qualified life was also reviewed and found acceptable.
Problems previously identified in the EQ maintenance area have been corrected in a timely manner.
These problems involved:
( 1)
Vendor manuals that were not being updated with revised EQ information.
This was corrected by performing audits of EQ related vendor manuals, to ensure up-to-date information was included and/or revised manuals as necessary.
(2)
A lack of precautions in procedures to ensure that EQ require-ments of the equipment were not degraded during maintenance was noted.
This was corrected by revising the procedures and was verified by reviewing the maintenance procedures for ASCO solenoid valves, Barton transmitters, NAMCO limit switches, and a Charging/Safety Injection Pumps (3)
Lubrication schedules were missed on both trains of the following systems:
RHR, Containment Spray, CCW, CSIP, and Auxiliary Feedwater (this involved 12 motors).
A JCO was written which
showed that the specified frequency for the oil change out could be exceeded without affecting the qualification of the motor and that the qualification of the affected motors was never compromised.
The licensee indicated that the lubrication interval would be evaluated and changed to a longer period if justified. If the change does occur, the licensee will revise the applicable QDPs and maintenance schedules.
Other maintenance deficiencies that were identified -during the walkdowns are discussed in paragraph 6.i.
Installation packages of electrical terminations/splices were reviewed for the electric hydrogen recombiners, 2RC-D528SA-I and 2SI-V555SA-1; ASCO solenoid valves; and Barton.Pressure transmitter PT-01RC-0455IW.
The packages indicated that splices inside contain-ment were all made using qualified heat shrinkable material.
There was no indication that terminal boards or tape material was used in any EQ application inside containment.
In summary, the licensee has implemented a maintenance program to ensure equipment remains qualified in accordance with 10 CFR 50.49.
This program includes surveillance testing, preventative maintenance, and corrective maintenance.
The program is relatively new, however, and is improving with experience.
No violations were identified.
b.
Inspection and Enforcement Notices ( IENs) and Bulletins ( IEBs)
Tracking of Information Notices (IENs) is done in accordance with Administrative Procedure AP-031, Operational Experience Feedback (OEF);
Nuclear Licensing Section NLS 1. 1, Incoming NRC Correspond-ence; ONSI-1, Operational Experience Feedback; and Administrative Procedure AP-609, Review of Incoming NRC/INPO Correspondence.
IENs and IEBs are transmitted to SHNPP by the Nuclear Licensing Section in corporate headquarters.
Onsite Nuclear Safety (ONS)
screens and evaluates the documents for applicability. If further evaluation is necessary, the IEN or IEB will be routed and handled in accordance with the OEF procedures.
When some action is required, tracking is done by Administrative Procedure AP-026, Corrective Action Program (CAP).
A review of the system provided assurance that SHNPP has implemented a program for addressing IENs and IEBs.
Responses to IENs related to EQ were in the appropriate qualification packages and were reviewed as part of the packag c.
Environmental Qualification Master List (EQML)
CFR 50.49(d)
requires that each licensee prepare and maintain a
list of electrical equipment requiring environmental qualification.
This list at Shearon Harris Nuclear Plant is currently listed in drawing 2166-S2500, Rev.
O. It is a controlled document, maintained by the Nuclear Engineering Department and stored in the computer equipment database.
The preparation and control of the list is described in NED Design Guide-DG-VIII.34 Rev. 0.
Changes to the EQML are made by using an EQML change form which is processed during the normal design control process.
A revised EQML is required to be issued within one month after a revision is made.
EQML was initially developed by determining,.from a
review of Chapters 5,
11, and 15 of the FSAR, those systems and electrical equipment required for safe shutdown and accident mitigation.
Also evaluated and included where necessary was instrumentation required for safe shutdown and accident mitigation and equipment required as a
result of lessons learned from TMI.
To assess the adequacy and completeness of the current EQML, the Low Head Safety Injection System was reviewed.
Specifically, the following documents were reviewed to determine the system components and auxiliary support components, such as Motor Operated Valves, Solenoid Valves, motors, and instrumentation required for accident mitigation and safe shutdown:
Drawing S-1324R7, Simplified Flow Diagram RHR Drawing S998S03R3, Simplified Flow Diagram HVAC System Description 110 Rl Safety Injection System System Description 111 R2 RHR System EOP Users Guide RO EOP-EPP-010 R2 Transfer to Cold Leg Recirculation EOP-,EPP-011 R2 Transfer to Hot Leg Recirculation There were no deficiencies noted during this review.
d.
EQ Cable Identification During the walkdown portion of the inspection, the inspectors obtained cable identification numbers from the cable connected to selected EQ equipment.
The licensee was then asked to show that the installed cable was qualified by their existing qualification documentation.
With the cable identification number, the licensee referenced the applicable pull card which showed the cable routing, reel number, and termination points along with a Bill of Materials number for the installed cable.
The Bill of Materials number was shown on the EQ Master List which identified the EQ file which established the qualification for that cable.
The vendor's Certifi-cate of Conformance was also reviewed for the selected cables.
This
document correlated the Bill of Materials number to the Purchase Order and also listed the cable reel number and the applicable EQ test report.
Mith this sampling, the inspector determined that adequate traceabi lity existed for the installed cables requiring environmental qualification.
EQ Equipment Replacement and Spare Parts Procurement Plant Operating Manual Procedure No.
PMC-001,
"Procurement and Material Control Procedures",
Revision 3, specifies instructions for procurement and catalogi.ng of parts, material, equipment and services.
The licensee uses the Corporate Material Management System (CMMS),
an integrated on-line computer system, for procurement, receiving, stocking, issuing and accounting of materials
~
Procurement of equipment, components, direct replacement and spare parts may be initiated by generation of a
New Item Request Form (NIRF) or a
Purchase Requisition.
Plant Operating Manual Procedure No.
TMM-104, establishes the method for determining the technical and QA requirements for procurement documents prepared or reviewed by Engineering Technical Support.
This group has been assigned responsibilities for determi ning technical and quality requirements and initiating requisitions for direct replacement components and/or spare parts.
Equipment within the scope of 10 CFR 50.49 are procured Quality Class A
CMMS Quality Class Q to ensure imposition of appropriate QA program requirements.
Specific guidance or determination of technical requirements
=are shown on Attachment "A" to procedure TMM-104.
The equipment qualification baseline established by design-engineer-ing during the construction period was NUREG 0558 Category II.
Procedure No. PLP-108, Environmental Qualification Program, Paragraph 4;4.2, specifies the qualification bases of new EQ equipment to be added to the EQML. It requires new equipment to be qualified to
CFR 50.49 unless a valid sound reason to the contrary can be applied.
Licensee management was informed that this program require-ment was not in accordance with the requirement of
CFR 50.49(k).
Pursuant to identification of this program deficiency, licensee management has committed to revise Procedure PLP-108 to ensure new EQ equipment are qualified to
CFR 50.49, i.e.
NUREG-0588 Category I.
The commitment date given for revision of the procedure was April 1, 1988.
Requirements for upgraded procurement in accordance with the require-ments of 10 CFR 50.49( 1) have been established within the procurement program.
Evaluations on a case-by-case basis are conducted within the administrative controls specified by Procedure No.
MOD-103, Engineering Evaluations.
Plant Change Requests (PCRs)
evaluated in
this manner by Engineering Technical Support are dispositioned by the Nuclear Engineering Department (NED) within the design-engineering
'rogram through development and implementation of a plant modifica-tion.
New environmentally qualified equipment to be added to the Equipment Qualification Master List (EQML) are also procured through the design-engineering program.
A review of the procurement documents for various equipment types was performed.
No EQ related deficiencies were identified.
QA/QC Interface Responsibility for implementation of the Corporate QA Audit Program has been assigned to the Manager QA Services.-
Discussions with licensee management revealed that audits of the EQ Program have been conducted to ( 1) verify that equipment within the scope of
CFR 50.49 is included in the EQ Program; (2) verify the technical adequacy of EQ related maintenance procedures and; (3) review implementation of the EQ Program.
Audit Report Nos.
QAA/0100-87-02 and QAA/0022-87-04 and their associated check lists were reviewed to assess the scope and depth of the audits performed.
Additionally, deficiencies documented in the reports were reviewed to assess the nature of the problem and their root-causes.
No EQ related defi-ciencies were identified during this effort.
Interviews with personnel from the on-site QA/QC organization were conducted to assess the degree of involvement of this organization in the implementation of the EQ Program.
It was determined that surveillances of activities related to.implementation of the EQ Program have been performed.
Surveillance Report Nos.
S85-187 and 87-105 were reviewed by the inspector.
Corrective action plans developed for identified deficiencies were discussed with licensee management to assess the adequacy of root cause determination.
Additional responsibilities assigned to the site QA/QC organization in the performance areas of procurement, inspections, and processing of Plant Change Requests (PCRs)
were reviewed.,
No EQ related deficiencies were identified.
EQ Modification Program Procedure AP-600,
"Plant Change Request Initiation" specifies the administrative controls that are used for processing requests for plant modifications.
It assigns 'responsibilities for the processing of Plant Change Requests (PCRs)
and provides for a review of the station problem by the System Engineer to assess the impact on environmentally qualified equipmen Plant modification packages prepared for resolution of station problems are prepared in accordance with design-engineering controls specified in Nuclear Engineering Department (NED) procedures.
The design controls ensure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions to form a
design change package.
Considerations of the environmental qualification requirements of equipment within the scope of
CFR 50.49 are included as design inputs to the design process.
An environmental qualification review performed as part of the technical review of the PCR during the design process is included with the plant modification package.
NED Design Guide DG-VIII.34, "Preparation and Control of Shearon Harris EQ Master List," specifies the design controls implemented to ensure update of the EQML r equi red by new designs or plant modifica-tions.
These controls are intended to ensure the integrity of the computer equipment database which forms the EQML.
Additionally, they ensure that necessary changes are made to the Equipment Qualification Data Packages (EQDPs)
and required EQ maintenance are incorporated in plant maintenance procedures.
Specific guidance for review of vendor supplied environmental qualification documentation is provided in NED Design Guide DG-VIII.19.
FSAR Appendix 3. 11'.B,- "Environmental Parameter Zone Maps" provides guidance to the responsible engineer during the design process concerning environmental parameters for various plant locations.
A review of EQ related problems documented on PCR 000125; PCR 2469, Revision 0; PCR 2832, Revision 0; and PCR 0002274, Revision 0, was performed.
Discussions were held with the cognizant engineers to determine the nature of the station problem, the adequacy of the corrective action implemented via the design-engineering process and the adequacy of incorporation of EQ requirements during problem resolution.
No EQ related deficiencies were identified.
EQ Personnel Training Harris Training Instruction, TI-113,
"Related Technical Training and On-The-Job Training for Selected Maintenance Classifications,"
Revision 0, establishes requirements for training of craft personnel in specific tasks.
Plant maintenance personnel are required to participate in an on-the-job training and qualification program that provides documentation of proficiency having been achieved in specific tasks.
Discussions with licensee management revealed that a
formalized training program had not been established for indoctrina-tion and training of the Electrical and Instrumentation and Control Technicians in the requirements of Harris environmental qualification progra It was further determined that EQ awareness training had been provided to these personnel.
However, the Electrical Craft and Technical Steering Committee in late 1987 recognized a
need for a
more formalized EQ training program.
A recommendation was therefore made to the training center for development of qualification cards that define specific tasks related to the implementation of the EQ Program.
Preliminary arrangements have been started regarding development of qualification cards for the Electrical and Instrumen-tation and Control maintenance personnel't the next scheduled steering committee meeting in May 1988, these cards will be reviewed and commented on.
Personnel indoctrination, training, qualification and certification of staff members in the QA/QC organization is as specified in Proce-dure OQA-103, Revision 0.
Review of this procedure and discussions with on-site QA/QC personnel revealed that training in the require-ments of the environmental qualification program had not been provided.
Additional discussions with Site Engineering Unit (SEU)
and Technical Support personnel also revealed that a
formalized EQ Training Program had not been established for either of these groups.
A Qualified EQ'Reviewer list had been established within the Technical Support group based on completion of a specified reading list.
Also, some environmental qualification awareness training had been provided to members of this group.
Licensee management, in recognition of the need to establish a
formalized EQ training program, are in the process of developing EQ lesson plans for indoctrination and training of personnel.
At the time of the inspection, lesson plans QA6084G and QA6085G were in the review and comment cycle at all licensee operating facilities.
CPS L interoffice memorandum, serial:
88NTS60, further states that the EQ trai ni ng is scheduled to be given the second and third quarter of 1988, and provides a list of personnel selected to attend the training session.
In response to the inspector's request for information concerning when training will start, licensee management committed to a starting date of May 15, 1988.
EQ Documentation Files and Malkdown Items The required qualification level for Harris original
CFR 50.49 Category b( 1), b(2)
and b(3)
equipment is NUREG 0588, Category II,
"Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment."
Replacement equipment must be upgraded to meet the requirements of 10 CFR 50.49(L) or sound reasons to the contrary must be documented.
The EQ documentation at the Harris site is composed of a Master List of Environmentally qualified electrical equipment, Environmental Profiles (FSAR Section 3. 11)
and the EQ Data packages which make up
the central file.
The central file contains EQ Test Reports; Report Evaluation Checklists, Summaries and Qualification Statements; System Component Evaluation Wor ksheets (SCEW);
EQ Component Lists; Mainte-nance and Procurement Requirements; Vendor Data; and other supporting documentation.
The NRC inspectors examined files for approximately
equipment items, where an item is defined as a specific type of electrical equipment, designated by manufacturer and model, which is represent-ative of all identical equipment in a plant area exposed to the same environmental service conditions.
In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selectively reviewed areas such as (1) required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified, (2) similarity of tested equipment to that installed in the plan (e.g.,
insulation class, materials of components of the equipment, test configuration compared to installed configuration, and documentation of both),
(3) evaluation of adequacy of test conditions, (4) aging calculations for qualified life and replacement interval determination, (5) effects of decreases in insulation resistance on equipment performance, (6) adequacy of demonstrated accuracy, (7) evaluation of test anomalies, and (8) applicability of EQ problems reported in IEBs/IENs and their resolution.
Although deficiencies were identified with the EQ Master List and EQ component qualification files, overall, a majority of the EQ files were audit-able and documented qualification of the equipment.
The following comments on both EQ records and walkdown items are considered the most significant findings.
File Reviews/Walkdown Items ( 1)
File EQDP-4. 10 Large Pump Motor Outside Containment This file was reviewed in preparation for the walkdown of the C
Charging/Safety Injection Pump (CSIP)
motor.
The lubrication guidelines were reviewed for periodicity and type of lubricant.
Problems with the oil change out period are discussed in the Maintenance section.
Mobil oils are the only oils used at SHNPP; however, there was no similarity analysis to show that the Mobil product was an acceptable substitute.
The licensee committed to adding the analysis to the QOPs.
During the walkdown, the splice was found to be of taped material.
The licensee provided the procedure for making the splice.
The procedure, CM-E0012, Electrical Power Feed
Switchover for CSIP IC-SAB, listed the materials as Bishop No.
EPR, Okoni te T-95, Okoni te spl icing cement, Okoni te No.
or Scotch 130C.
The QDPs for these materials were reviewed and it was determined that they were qualified for use outside of containment and the steam tunnel.
The QDPs were 16.2 (Bishop Electrical Tape),
16.3 (Okonite Electrical Tape No. T-95 and Nuclear Splice Cement),
and 16.4 (Scotch Electrical Tape).
No discrepancies were noted in any of these files.
File EQDP-13.2 - Terminal Blocks; EQDP 17.2, Marathon Terminal Blocks EQDP-17;3 - GE-CR151B Tqrminal Blocks These packages were reviewed and found to qualify the terminal blocks for use outside of containment and the steam tunnel.
No discrepancies were noted 'in these files for the indicated applications of the terminal blocks.
File EQDP-13.8 - Hydrogen Recombiner This file was reviewed in order to identify the type of splice used to connect the power leads to the heaters.
There was no indication in the file as to the make-up of the electrical termination/splice; however, the installation document was provided.
A Field Change Request (FCR-E-5936)
was issued on March 18, 1986, in order to permit the installation of a five-to-one Raychem Splice Kit.
No discrepancies were noted.
File EQDP-Rosemount Transmitters, Model No.
1153, Series B
These transmitters are used for various functions such as monitoring pressure, flow, and level.
One concern that arose during the review of this file was the replacement schedule for these transmitters was not stated in the maintenance section of the file.
The Licensee, when questioned about this matter, stated that the files are being updated to a
new CP&L format and the EQDP will be revised to reflect the replacement schedule.
During the plant walkdown, Rosemount Pressure Transmitters, PDT-4838B and PDT-4843B were inspected.
No anomalies were noted during the inspection of these transmitters.
The transmitters covered by this file meet the qualification requirements of 10 CFR 50.49 and NUREG-0588, Cat. I File E(DP-8.11 - Barton Transmitters, Model Nos.
763 and 764 These transmitters are used to measure pressure (Model 763)
and flow (Model 764).
Pressure measurements are taken on the Accumulator Tank, and the Pressurizer.
Flow measurements are taken on Residual Heat Exchanger's 1A and 1B bypass, and the Hot and Cold Leg safety injection lines.
The only concern noted during the file review was the System Component Evaluation Worksheets (SCEW)
were not correct.
When the Licensee was asked about thi s, they stated that the SCEW is in the old (Ebasco)
format and they are currently in the process of updating and revising the sheets to reflect the correct parameters.
Also, the replacement schedule for the 0-rings was not defined in the data package.
The Licensee has committed to revise the EgDP to reflect the requirements for replacement of the O-rings.
During 'the walkdown, level transmitters LT-1320, 1321, and 1322 were inspected.
The transmitter's were properly mounted and sealed and no anomalies were noted.
The transmitters covered by this file meet the qualification requirements of 10 CFR 50.49 and NUREG-0588, Cat. II.
File EgDP-8. 17 - Barton Transmitters Model 763 These transmitters are NSSS supplied and are qualified by Westinghouse test report WCAP-8687, Supplement 2-E01A.
These transmitters are located in the containment building and are used to measure the Pressurizer pressure.
These transmitters were not inspected during the walkdown because of being located in the containment and access to them was not permitted.
The transmitters covered by this file meet the qualification requirements of
CFR 50.49 and NUREG-0588, Category II.
File EgDP-Gould Transmitters, Model No. DR-3200-005-18 These transmitters are located in the Auxiliary Building and are used to measure delta-pressure and actuate contact closure in the Containment Vacuum Relief System, Control Room Heating, Ventilating and Air Conditioning (HVAC) system, and Reactor Auxiliary Building Emergency Exhaust System.
They are qualified by Gould test report number 1029, dated January 18, 1985.
During the walkdown, pressure transmitter PDT-4834B was inspected.
It was observed during the walkdown that foreign material had been sprayed on the transmitter.
The nameplate
data was obscured because of this and could not be inspected.
Also because of foreign material being present, the potential problem of moisture or foreign material intrusion into the transmitter was questioned.
The, Licensee committed to inspecting the transmitter for this possibility and has written work request 88-AFGX1 to resolve this problem.
The transmitters covered by this file meet the qualification requirements of 10 CFR 50.49 and NUREG-0588, Cat. II.
(8)
File EQDP-8. 19 - Tobar Transmitters, Model No.
32DPl These transmitters are used to measure narrow range pressure in steam generators A,
B, and C.
These are NSSS supplied trans-mitters and were qualified under Westinghouse test report WCAP 8687, Supp.
2-E01B, Rev.
1.
The maintenance concerns and replacement plan are adequately addressed in the file.
During the plant walkdown Tobar pressure transmitter PT-403 was inspected.
The transmittei was properly mounted and sealed.
No anomalies were noted'nspector concluded the transmitters covered by this file meet the qualification requirements of
CFR 50.49 and NUREG-0588, Category II.
(9)
File EQDP-Siemens Allis Motor, Model 447TS The motor is used to operate the Service Water Booster Pump and is located in a mild environment.
Radiation is the only harsh environment associated with the qualification of this motor.
The motor has been qualified under Siemens Allis test report number NQ8902322, Rev.
1.
The following three concerns arose during the review of this file:
(a)
What type of lubricant is required and has it been environ-mentally qualified?
(b)
Analysis for qualified life of 40 years was not documented in the EQDP.
(c)
Replacement/maintenance requirements as defined in the test report were not documented in the EQD The Licensee's response to these concerns were:
(a)
A Lithium soap base/petroleum oil grease, stabilized against oxidation was recommended and the grease used is Mobiletemp SHC-32.
The qualification of this grease was covered in EQDP-19.1 (b)
Documentation was provided to establish a qualified life of 24 years using the Arrhenius equation (c)
The package has not been revised to the new CP&L format to document the maintenance/surveillance requirements for the motor bearings which must be replaced every 15 years.
The Licensee has committed to revising the EQOP to reflect the required changes.
This motor was not inspected during the plant walkdown.
Based on the audit inspection the Inspector concluded the Siemens Allis pump motor covered by this file meets the
CFR 50.49 and NUREG-0588 Category II environmental qualification requirements.
(10) File EQDP-4.5 - Siemens Allis Motor, Model No.
119 The motor is used to operate the Fuel Pool Cooling Pump.
The motor is located in the Fuel Handling Building and the only harsh environment the motor is subjected to is radiation.
This motor was qualified using Siemens Allis Qualification Report No.
N08902321, Rev.
5.
This motor was not inspected during the plant walkdown The Siemens Allis pump motor covered by this file meets the environmental qualification requirements of
CFR 50.49 and NUREG-0588 Cat. II.
(ll) File EQDP-Westinghouse Motors, Model Numbers HSDP, VSW1, Frame 143T The motors are located in various areas of the Auxiliary Building and radiation is the only harsh environment associated with the qualification of these motors.
The systems these motors are used in are the Auxiliary Feedwater System, the Containment Spray System and the Reactor Auxiliary Building HVAC System.
These motors are NSSS supplied motors and are qualified under Westinghouse test report WCAP 8754, Rev. ~
>
~
During the walkdown, Mestinghouse Pump Motor 1CS-CSIPC:002 was inspected.
There were no anomalies noted. during the inspection.
(12) File EQDP-Limitorque Motor Operated Valves (MOVs), Model No.
SMB/SB, Inside and Outside Containment Test reports supporting equipment qualification of the Limitorque MOVs at Shearon Harris to NUREG-0588, Category II are Limitorque Test Reports 600456, B0009, B0003, B0212, 2MD-V365A-1-B0058, 600456, and B0027 of B0058, and the document contained in CP&L File EQDP-3.3.
During the file review the following issues/concerns were discussed with the Licensee and all items were satisfactorily addressed.
The status of the braking devices associated with the MOVs.
The qualification of MOVs having Magnesium rotors.
The maintenance procedures for periodic operation of the Limitorque Actuators.
The procedures for lubricating the actuators and control-ling the lubrication.
The procedures for inspecting the termina1 blocks contained in the MOVs.
The usage of Marathon 300 terminal blocks in safety circuits having greater than 300 volts.
The criteria for determining the correct torque switch and limit switch material used in MOVs located inside contain-ment.
The removal of the grease relief dust covers.
The number of wires per termination point on the terminal blocks.
The inspection criteria used for internal splices or wire termination.
The installati.on of drain plugs as required.
The mixing of different types of grease used for lubri-cating the actuators and the steps taken to rectify this situation and to prevent reoccurrenc The rationale for qualifying safety related Limitorque Actuators located in the steam tunnel to an accident temperature of 482'F.
The plant walkdown involved a
physical inspection of four Limitorque Actuators, Component Identification Numbers lAF-149, 3CZ-B5SA-1, 3CZ-B7SA-1, and 3CZ-B32SA-1.
The walkdown identified a
number of maintenance discrepancies which were resolved by issuing work orders for repairs.
One general concern was identified.
This concern involved the quantity of grease installed in the Limitorque Actuator gear compartments.
The concern was that the Maintenance Procedure (MPT-M0082, Revision 0) for regulating grease addition to the actuator did not provide an adequate description to prevent the compartment from being overfilled.
There was at least one case identified (Valve 1AF-179)
where the compartment was overfi lied.
There were also other actuators observed to have lubrication leaking from connections.
It was surmised by the inspector that these leaks could have been the result of overgreasing.
Also during the walkdown, it was observed that plastic or nylon crimp connectors were used in the Limitorque actuator for Valve 3CZ-B7SA-1.
This actuator is for a
dual voltage motor and the concern raised was the qualification status of the wire connectors used in 'he actuator compartment.
The Licensee responded that the connectors were tested by Limitorque and documented in Test Report, B0003 and are qualified to the environment (outside containment)
they will experience during an accident.
From this response the question was asked concerning the possibility of Limitorque Actuators inside containment containing these nylon crimp connector s.
Two Valves (Nos.
were identified by the Licensee as possibly having dual voltage motors and the wire terminations possibly could be the same nylon crimp type connectors as used outside of containment.
This could not be verified due to plant operating conditions.
These connectors have not been determined to be qualified for in-containment accident environments.
The Licensee tried to prove qualification by similarity analysis, but the documentation provided was not adequate to demonstrate similarity or qualification.
At the conclusion of the audit, this issue was still unresolved.
The Licensee has committed to obtain qualification documentation for the nylon crimp connectors or if this is not possible the actuators will be walked down during the next outage and all connectors will be removed and replaced with qualified splices.
This item will be identified as Unresolved Item 50-400/88-04-01, Nylon Type Crimp Connectors on Dual Voltage Limitorque Actuator The following items/concerns were also noted during the walkdown:
The cable type and manufacturer of Field'ables 12836BSA and 12836ASA to Valve 3CZ-B7SA and its qualification status.
The cause of the discoloration of wires to the terminal blocks and the effect on the operator in MOV 3CZ-B7SA.
The slight oil leak on the limit.switch gear box for limitorque operator 3CZ-BSSA.
The identity of the manufacture and type of terminal block used in Limitorque operator 3CZ-B7SA, and the qualification status of the blocks.
The crack found in the end of the motor housing to Limitorque operator 3CZ-B7SA.
The grease leak around the motor of Limitorque operator 3CZ-B32SA.
The flange leak in the steam tunnel leaking on Electrical box B1569SA.
The oil leak observed coming from the motor casing of 1CS-341.
The broken screw and missing nut in Limitorque operator 1AF-149.
Also this operator is full of grease.
The crack (chip)
found on the limit switch block in the Limitorque operator for Valve 3CZ-B7SA.
A number of cases were observed where grease (oil) was leaking from Limitorque operators and in at least one case the gear compartment appeared to be overfi lied with grease.
These issues were discussed with the Licensee and the Licensee has committed to correct the deficiencies identified.
Work requests AFGN1, AFFH1, AFGIl, and AFFE1 were written and are to be completed to satisfy the maintenance problems of the leaks, repair s, and over-lubrication of the valves and operators.
Also the Licensee has committed to revise the appropriate maintenance procedure to reflect the proper lubrication requirement (13) File EQDP-15.3 - Conax ECSA Seal Assemblies These seal assemblies were qualified to the requirements of
CFR 50.49 and NUREG-0588, Cat. I.
There were no unresolved/
open items identified during this brief review.
(14)
These seal assemblies were not inspected during the plant walkdown due to plant operation.
Reliance Fan Motor (15)
It was observed during the walkdown that a grease tube filled with grease was installed and did not have a
cap installed on top.
It was determined by the Licensee that this motor had double sealed bearings, inboard and outboard, which do not require external lubrication.
The Licensee has committed to walking down all EQ Reliance motors and removing any grease lines prior to the end of the first refueling outage.
File EQDP-16. 1 - Raychem Splices It was determined by the NRC.Inspector that Raychem Splice materials which included nuclear plant splice kits, nuclear high voltage terminations, cable sleeves, nuclear jacket repair sleeve, cable breakout and end sealing kits, motor connection kits, shim stock, nuclear plant splice kit (custom designed)
and nuclear plant stub connection kit had adequate documentation in the file to demonstrate adequate qualification for both inside and outside containment use.
(16) File EQDP-9. 1 Namco Limit Switch It was determined that the NAMCO Limit Switch Series EA180-11302/12302/14302/15302/21302/22302/32302 had adequate documen-tation contained in the EQ file to support qualification inside/outside containment.
(17) File EQDP-9. 10 - Namco Limit Switch NAMCO Switch EA180-11303 and 12303 was supplied to SHNPP by Westinghouse.,
This file contained adequate documentation to support qualification inside/outside containment.
Limit switches 2FW-V125SAB-1 and ZAF-V158SAB-1 were examined during the walkdown.
The electrical connection type was a
conax seal.
All screws on covers were tight and the gaskets appeared brand new.
The junction boxes associated with these items were inspected.
All Raychem splices were installed properl (18) File EgDP-3.2 - ASCO Solenoid Valve It was determined that the Eg File contained sufficient.documen-tation to support qualification for ASCO solenoid values model NP8316, 8320, 8321 and 206 Series for inside/outside contain-ment.
ASCO Solenoid Valve No.
2MS-F2SAB-1 (Model NP8320A175E)
was inspected during the walkdown.
The electrical connection type was a conax seal.
This valve was deenergized but had added insulation around value body since it was located in the steam tunnel.
The junction box associated with this item was inspected.
All Raychem splices were installed properly.
(19) File EgDP-3.14 - ASCO Solenoid Valve ASCO Solenoid Valves Model FT831654 is located in mild environ-ment (radiation)
only.
Adequate documentation was in the file to support qualification in a mild environment.
(20) File E(DP-6. 5 - AIW Instrument Cable AIW cable with EPR insulation is used inside and outside containment for instrument circuits.
This cable was generally qualified for worst case conditions.
Adequate documentation was in the file to support qualification for its current applica-tion.
(21) File EgDP-6. 12 - Brand Rex Ultrol Switchboard Wire Adequate documentation was included in the file to support qualification for Brand Rex Ultrol 300V and 600V control and switchboard wire.
7.
CFR Part 21 Report - Sorrento Electronics Digital High Range Radiation Monitor (HRRM)
The licensee had Corporate Consulting and Development Company, LTC perform a calculation to show that the as-built configuration utilizing the Rockbestos coaxial cable was acceptable to provide the minimum required IR
necessary to maintain a factor of two system accuracy.
The licensee performed a thermal analysis modeling the cable in a closed conduit system to show that the peak temperature would not exceed the temperature where the IR values dropped below 5'
10'Q.
Using IR values provided by Rockbestos for the calculated temperatures the licensee performed an error analysis of the HRRM circuit.
The inspector reviewed thi s analysis and concluded it was inadequate because it did not include the error contribu-tion from all connections (i.e.,
penetration and pigtail cable).
The licensee redid the analysis and found that the IR value was less than the recommended value of 5 x 10'hms specified by Sorrento Electronics.
However, this was acceptable because the Sor rento Electronics recommended value included a margin of 40% above the required value of 3.59 x 10'.
The newly calculated value is now only 30% greater than the required value of 3.59 x 10'Q.
8.
Instrument Loop Accuracy The inspectors reviewed the procedures for the Instrument Loop Accuracy program at the Shearon Harris plant.
Included in this review was the identifying of the worst case instrument and tracing the components used and correlating these to the accuracy calculations supplied by the licensee.
The instrument reviewed was a Barton 763 pressure transmitter used for the overpower delta-T trip function.
The evaluation of Insula-tion Resistance (IR)
degradation of Reactor Trip/Engineered Safety Features and Post Accident Monitoring Instrumentation for the Shearon Harris Plant was prepared by Westinghouse Electric Corporation, Power Systems Division at the request of the Licensee.
This information was provided to the inspectors for review.
After reviewing the Loop and Accuracy program for the Shearon Harris Plant it was concluded that their program is adequate.
There were no open/
unresolved issues identified from this review.