ML17055B021
| ML17055B021 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/19/1985 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17055B019 | List: |
| References | |
| 50-220-85-13, NUDOCS 8601090566 | |
| Download: ML17055B021 (36) | |
See also: IR 05000220/1985013
Text
U.S.
NUCLEAR REGULATORY COMMISSION
OFFICE
OF INSPECTION AND ENFORCEMENT
Report No.:
Docket No.:
License
No.:
Licensee:
Facility Name:
Inspection At:
Inspection
Conducted:
50-220/85-13
50-220
Niagara
Mohawk Power Corporation
300 Erie Boulevard West
Syracuse,
13202
Nine Mile Point, Unit No.
1
Syracuse
and Scriba,
August
19 to 23,
1985
Inspector:
R.
C. Wilson
Equipment gualification 5 Test Engineer
Date
Also participating in the inspection
and contributing to the report were:
U. Potapovs,
Chief, Equipment gualification Inspection Section,
I&E
S. Alexander,
Engineer,
A. Masciantonio,
Engineer,
R. 0. Karsch,
Reactor Engineer,
E.
H. Richards,
Member of Technical Staff, Sandia
National Laboratories
J.
Fehringer,
Consultant
Engineer,
Idaho National Engineering Laboratory
L. Cheung,
Reactor Inspector,
RI
M. Schaeffer,
Reactor Inspector,
RI
C. Anderson,
Section Chief,
RI
Approved by:
Ul is Potapovs,
Chic
Equipment gualification Inspection Section
Vendor Program Branch
Office of Inspection
and Enforcement
Ih -,
h
k
I
INSPECTION
SUMMARY:
~Ins ection
on
Au ust
19 to 23,
1985
Ins ection
Re ort No. 50-220/85-13
A~d:
p
PP,
dd
p
.P
P
P
implementation of a program per the requirements
of 10 CFR 50.49 for
establishing
and maintaining the qualification of electric equipment within
the
scope of 10 CFR 50.49.
The inspection also included evaluations of the
implementation of equipment qualification (Eg) corrective action commitments
made
as
a result of deficiencies identified in the
December
30,
1982 Safety
Evaluation Report
(SER)
and the August 6,
1982 Franklin Research
Center
(FRC)
Technical
Evaluation Report (TER).
The inspection
involved 269 inspector
hours onsite.
Results:
The inspection
determined that the licensee
has
implemented
an
interim program to meet the requirements
of 10 CFR 50.49, except for the
deficiencies listed below,
and is developing
a long-range
program.
No
deficiencies
were found in the licensee's
implementation of corrective
action commitments
made
as
a result of SER/TER identified deficiencies.
Name
Potential
Enforcement/Unresolved
Items:
Re ort Para
ra
h
Item Number
2.
3.
4.
5.
6.
7.
qualification file deficiencies
Static-0-Ring pressure
switches
General Electric EB-25 terminal
blocks
General Electric EB-5 terminal
blocks
Fisher
304 position switches
Rosemount
1151 transmitters
4.A. (1)
4.D. (1)
4.0.(2)
4.D.(3)
4.D.(4)
4.D.(5)
4.D.(6)
50-220/85-13-01
50-220/85-13-02
50-220/85-13-03
50-220/85-13-04
50-220/85-13-05
50-220/85-13-06
50-220/85-13-07
Name
~0en
Items:
Re ort Para
ra
h
Itern Number
1.
2.
3.
4.
Implementation of Eg procedures
Closed loop cooling motor
lubrication
Acoustic monitor coaxial cable
Laurence solenoid valve
4.A.(2)
4.A.(4)
4.D.(7)
4.D.(8)
50-220/85-13-08
50-220/85-13-09
50-220/85-13-10
50-220/85-13-11
t'
1.
Persons
Contacted:
DETAILS
1. 1
Nia ara
Mohawk Power Cor oration
- T. E.
Lempges,
Vice President,
Nuclear Generation
- C. V. Mangan,
Senior Vice President
- J.
K. Jirousek,
Project Manager,
Equipment Qualification
- T. J. Perkins,
Gen. Supt., Site
- G. D. Wilson, System Attorney
- K. Sweet, Electrical Maintenance
Supt., Site
- H. T. Master III, Asst.
QA Engineer, Site
- W. Connolly, Supv.
QA, Nuclear
- M. G. Mosier, Assoc.
Sr. Nuclear Engineer
- R. J.
Pasternak,
Sr. Nuclear Engineer
- S. Loveland,
NMP No.
2 Lead
EQ Engineer
R. Main, Assoc.
Generation
Spec., Training
N. Rademacher,
Nuclear Design Coordinator
K. Dahlberg,
Maintenance
Supt., Site
1.2
NMPC Consultants
- L. W. Price,
EQ Engineer,
Gasser
Assoc.
- G. F. Eldridge, Engineer,
Gasser
Assoc.
- P. Brunsgaard,
Engineer,
Gasser
Assoc.
- T. Patterson,
Senior Staff Engineer,
Wyle Laboratories
- H. A. Zadeh,
Engineer,
Wyle Laboratories
- R. K. Ho,
EPM, Consultant to Nuclear Utility Group on
Equipment Qualification
1.3
Nuclear
Re ulator
Commission
- R. A. Hermann,
NRR, Project Manager
S.
D. Hudson,
Resident
Inspector
- Denotes those present at exit interview at Syracuse
on August 23,
1985
l
2.
PURPOSE
The purpose of this inspection
was to review the licensee's
implementation
.of the requirements
of 10 CFR 50.49
and the implementation of committed
corrective actions for SER/TER identified deficiencies.
3.
BACKGROUND
On March 15,
1984, the
NRC held
a meeting with NMPC officials to discuss
NMPC's proposed
methods
to resolve the
Eg deficiencies identified in the
December
30,
1982
SER and August 6,
1982
FRC TER.
Discussions
also
included
NMPC's general
methodology for compliance with 10 CFR 50.49
and
justification for continued operation for those
equipment
items for
which environmental qualification was not completed.
The minutes of the
meeting
and proposed
method of resolution for each of the
Eg deficiencies
were documented
in a May 31,
1984 submittal
from the licensee.
The
and
May 31 submittal
were reviewed
by inspection
team
members
and were
used in planning
and conducting the inspection.
4.
FINDINGS
A.
E
Pr'o
ram
Com liance with 10 CFR 50.49
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 documentation files; review of procedures
and other
means for controlling the licensee's
Eg effort; verification of
the adequacy
and accuracy of the licensee's
10 CFR 50.49 equipment
list; and examination of the licensee's
program for maintaining the
qualified status of the covered electrical
equipment.
Based
on the inspection findings, which are discussed
in more
detail
below, the inspection
team determined that the licensee
has
implemented
an interim program to meet the requirements
of
10 CFR 50.49, although
some deficiencies
were identified.
The
licensee
is also developing
a long range
plan to more formally
control
Eg activities.
(1)
g
life
i
Fil
During the entrance
meeting
NMPC described its Equipment
gualification File as being maintained
under the cognizance
of the
Eg Coordinator for the life of the plant for the
covered items.
The following data were listed
as included
in the file:
Equipment gualification Master List
Eg List Basis
Documentation
System
Component Evaluation Worksheets
(SCEW)
Environmental
Conditions Basis
Documentation
0)
Eg Field Verification Data Including Photographs
Eg Reports
Eg Studies/Analyses
Eg Calculations
EQ Maintenance
5 Spare
Parts
Requirements
Eg Checklists
Eg Location Drawings
Eg Correspondence
(Chronological
Order)
Some supporting information was identified as located elsewhere.
For example, installation,
procurement,
and receipt inspection
records
are maintained at the site with microfilm copies
available for engineering
reference.
The
Eg Master List and
SCEW sheets
are computerized.-
The
NRC inspectors
reviewed the files for 16 equipment
items,
where
an item is defined
as
a specific type of electrical
equipment,
designated
by manufacturer
and model, which is
representative
of all identifical equipment in
a plant area
exposed
to the
same
environmental
service conditions.
The
types were selected
in advance
by the inspection
team and
identified to the licensee
during the entrance
meeting.
Common deficiencies
in the files are described
in this
section of the inspection report,
and specific component-
related
concerns
are discussed
in paragraph
4.D. below.
The inspectors
found that traceability of references
important
to qualification of equipment
was accomplished
by reference
numbers
provided
on the
SCEW sheets
and
on component gualification
Summary Sheets.
Typically the inspector
had to search
the entire
reference
to locate the pertinent information.
File auditabi lity
was degraded
by lack of specific citations to pertinent material
in reference
documents.
All of the major references
inspected
such
as test reports
and
analyses
had rubber stamps
on the cover sheet.
Each
stamp
had
spaces
for "originator," "checker,"
and "approved" signatures,
as well as the reference
number
and
a date for each signature.
The licensee
explained that these
signatures
documented
review and acceptance
of the document.
NMPC provided the
inspectors with copies of a five page
memo to file dated
August
22 (near the end of the inspection)
which retrospectively
defined the bases for the
NMPC review and signoff.
The inspecto'rs
conclude that the
NMPC file review process
is deficient for
reasons
that include the following:
The basis for a single set of acceptance
signatures
is not
clear when placed
on
a volume of, Limitorque test reports
involv'.ng several different tests of various operator
types
in various environments,
applicable to multiple types of
operators
with varying service conditions in Nine Mile Point
Unit No. l.
(0
For most components
the files including
SCEW sheets
did not specifically document the required level of
qualification
(DOR Guidelines,
IEEE 323-1974, etc.) nor
did the inspectors find evidence that the signers
addressed
that information for each application.
did have
an "Environmental gualification Checklist" with
boxes for checking the appropriate level; however,
the
inspectors
were informed that the
Eg Checklist
was only
issued for components
whose qualification documentation
including maintenance
requirements
is complete.
Since
only a few of the
Eg Required Maintenance
packages
were complete at the time of inspection,
few Eg
Checklists
were issued.
Acceptance
signatures
were found on several
analysis
reports for components
whose functional performance
requirements
in the plant were not defined:
Rockbestos
control cable,
SOR pressure
switches,
and Rosemount
1151
transmitters,
for example.
guestions
raised
by the inspectors
resulted
in the
response
by the licensee that plant service conditions
had been improperly defined for some
components
(see
section
4.D. of this report).
The deficiencies cited above,
considered
in context with the
component-specific file deficiencies
described
in section
4.D.
of this report, collectively comprise
a Potential
Enforcement/
Unresolved
Item, gualification File Deficiencies,
50-220/
85-13-01.
(2)
E
Pro
ram Procedures
NMPC's overall equipment qualification program is addressed
in
Nuclear Engineering
and Licensing Procedure
NT-100.C,
"Equipment
gualification."
Preliminary Rev.
0 dated July 15,
1985 was
provided before the inspection,
and
an August 22,
1985
Preliminary Rev.
0 was given to the inspectors
during the
inspection.
This procedure
has not been
approved or issued;
NMPC is addressing
Eg with an interim program described
below.
A preliminary review of draft procedure
NT-100.C
by the
inspectors
revealed
no deficiencies.
Its scope
includes
the
following:
I
,
~l
References
Definitions
Responsibi
1 ities.
Eg rev iew of pre 1 imi nary des i gn
Determination of Eg procurement
requirements
Determination of qualification alternatives
Development of a qualification test program
Review/acceptance
of Eg reports
Installation requirements
Maintenance
requirements
Eg master list
Eg file requirements
~ Plant environmental
conditions analysis/documentation
Review of manufacturer
and
NRC Bulletins/Notices
Review of changes
to
NMP-1 "g" list
Review of changes
to tech
specs
and operating
procedures
Failure/trend analysis of Eg equipment
Reevaluation of Eg criteria
Verification of engineering
and plant
Eg compliance
At the time of the inspection
the following Eg-related
procedures
had
been issued:
Nl-EMP-44.2
.
Installation Procedure for Class
1 Electrical
Equipment
Nl-EMP-44.4
Installation Procedure for Sealing of Selected
Electrical Connections with Kaowool or Flameseal
and Bisco Locaseal
NI-EMP-44.22
Installation Procedure for Insulating
and Taping
Medium and
Low Voltage
Power Connections
N1-EMP-44.24
Installation Procedure for Namco Limit Switches
Nl-EMP-45.96
Equipment gualification Examination of Limitorque
Valve Actuators
and Associated
Motors, Type
SMB
and
Nl-FMP-45.97
Equipment gualification Inspection for Electromatic
Relief Valves
During-the entrance
meeting,
NMPC provided the following schedule
for completing its
Eg program:
Eg Procedures
Complete
Eg Procedures
Implementation
Eg Required Maintenance
Reviews
Site Maintenance
Procedures
Updates
Training Program
Implementation
October
1985
January
1986
October,
1985
March 1986
January
1986
l
This schedule
is keyed to implementing the long term
EQ program
by a refueling outage
scheduled for March, 1986.
A future
inspection will review the approved
issue of NMPC's
procedure
and completion
o
the schedule listed above.
Implementation of EQ procedures
comprises
Open Item 50-220/
85-13-08.
I
The inspectors
reviewed
NMPC's interim program for implementation
of the requirements
of 10 CFR 50.49 including:
definitions of
harsh
and mild environments;
equipment qualified life; service
conditions; periodic testing; maintenance;
and surveillance.
NMPC's interim program was also reviewed for requirements
to
establish,
evaluate
and maintain auditable
EQ documentation
including
EQ summary sheets,
test reports,
maintenance
records
and other supporting documentation
to justify equipment
qualification; training of personnel
in the environmental
qualification of equipment;
control of plant modifications
such
as installation of new and replacement
equipment;
and
provisions for updating replacement
equipment to
cri ter ia.
NMPC's interim
EQ program is intended to control
EQ activities
until the long term program is implemented.
Interim practice
essentially
depends
on routing all EQ-related matters
through
the
EQ project manager,
who ensures
that proper action is taken.
Previous submittals to the
NRC and
a computerized
equipment
master list were used
as
a data
base.
Interim control of the
EQ files, Master List, and maintenance
is discussed
in detail
in other paragraphs
of section
4.A of this inspection report.
The inspectors
reviewed the Quality Assurance/Quality
Control
(QA/QC) organization
and activities.
The
QA/QC organization
consists of a director of QA and five section
managers.
The
nuclear
QA section
manager
has direct control over the nuclear
QA supervisor,
who in turn directs the Quality Engineering
and
QC Inspection functions.
EQ activities requiring
QC coverage--
such
as maintenance,
receipt inspection,
and procurement
specification requirements
review -- are covered
by the nuclear
QA supervisor.
In addition, the
QC inspectors
review all
EQ work
requests.
The inspectors
examined
QA Services Audit No. SP-IN-SY-84001
dated
December
6,
1984.
The audited organization
was Nuclear
Design Engineering.
The purpose of the audit was to verify
control of contractor activities
and compliance with Engineering
Procedures,
the
QA program,
and the following:
10 CFR 50 Appendix
B
10 CFR 50 Appendix
R
The
EQ Master List (document
M.O. F1927)
i'd/ ll
Four of the
14 audit findings dealt with Eg and were reviewed
by the inspectors.
Treatment of the findings, dispositions,
and closeouts
were found to be acceptable
to the inspectors.
The inspectors
reviewed the licensee's
Eg training procedure,
intended to train maintenance
personnel
in properly maintaining
environmentally qualified equipment.
The procedure
was approved
August 16,
1985.
It covers the following topics,
intended to
make maintenance
personnel
cognizant of NMPC's requirements
for
meeting
10 CFR 50.49:
Basis for Equipment gualification regulation
Methods of qualifying equipment
Types of analysis
used to extend qualified life of
equipment
Differences
between
Nine Mile 1 and Nine Mile 2
Equipment gualification Standards
Types of accidents
defining
Eg scope
Use of a
SCEN sheet
Systems that have equipment which must
meet Equipment gualification standards
Environmental
map of the station
Equipment gualification procurement
standards
Controls applicable to installation of
Eg equipment
Maintenance
requirements for Eg equipment
Use of an Equipment qualification required
maintenance
sheet
Subsequent
discussions
with the electrical
maintenance
supervisor
on October 3,
1985 disclosed that eight of his electricians
successfully
completed the training course
on September
27,
1985.
The passing
grade for the written exam was
80 percent.
The
supervisor also stated that forty electricians
were scheduled
to
complete
the
Eg training within eight weeks.
During the site visit, the inspectors
reviewed the
training records of 16 maintenahce
electricians, all
of whom are certified to ANSI N45.2.6-78.
Verification that the licensee
completes
implementation
of his training program by January
1986 is included in
the
Open Item identified at the beginning of this report
section 4.A.(2).
10 CFR 50.49 List
E
Master List
The licensee is required to maintain
an up-to-date list of the
equipment that must
be qualified under
This list
is entitled "Nine Mile Point No.
1 Equipment Qualification M.O.
81927" dated August 15,
1985.
For ease of access
and control,
this list is part of a computer controlled environmental
qualification data
base.
Considered
in the preparation of this
list are environmental
effects resulting from all postulated
design-basis
accidents
documented
in the licensee's. Final
Safety Analysis Report,
Technical Specification limiting
conditions of operation,
emergency operating
procedures,
piping and instrumentation
diagrams,
and electrical
distribution diagrams.
The licensee
is aware that when
emergency
procedures
are rewritten as
symptom oriented
procedures,
new items will be added to the
EQ Master List.
The
EQ Master List was produced
as detailed
by the licensee'
submittal
"Equipment Qualification Program"
dated
May 31,
1984.
This procedure
and Engineering
Procedures
NT-100.2,
NT-110 and
HD-100 provide guidance
and control
n.
the
EQ Master List to
maintain its accuracy.
It was suggested
that ND-100 be
modified to more clearly define responsibility for screening
plant modifications for impact on the
EQ Master List.
Pending full implementation of the long term
EQ program,
has
addressed
possible additions of equipment to the Master List
via
a letter from the
EQ project manager to all lead design
engineers.
The letter states
that all design
changes
should
be reviewed
by .the
Eleven items were used
as
an audit sample to verify the complete-
ness of the current
EQ Master List.
In order to compile this
audit sample,
review was conducted of the following piping and
instrumentation
drawings
(P&IDs) and emergency
procedures.
10
4
J'>
Emer enc
Procedure
"Emergency Cooling Systems
05,
39
& 60" revision
15
18002-C
18007-C
18014-C
18014-C
18014-C
18018-C
18020-C
18022-C
18041-C
Sheet
¹1 rev 20
Rev
28
Sheet
¹1 rev 33
Sheet ¹3 rev
9
Sheet ¹4 rev ll
rev
6
rev
10
Sheet
¹4 rev
2
Sheet
¹7 rev
4
& High Pressure
Turbine"
"Reactor Core Spray"
"Reactor Containment
N2 Purge
& Fill
Drywell Cooling System"
"Reactor Containment
N2 Supply"
"Reactor Containment
N2 Supply"
"Reactor
"Reactor Recirculation
Loops"
"Service Hater Reactor
& h~aste
Bldgs"
"Reactor Vessel
Post Accident Sample
Points"
The audit sample
was selected
to verify that those
items required
to be on the list are in fact on the list.
The sample also
included
one item required for implementation of R.G.
1.97 (High
Range Radiation Monitor including cable).
All sample
items required to be
on the
Eg Master List were in
fact on the list.
To test the thoroughness
of the licensee's
review
a sample
item not required to be
on the
Eg Master List
was questioned;
the item was not on the list and the licensee
provided
a satisfactory explanation
why it was not.
Based
on this review the licensee's
Eg Master List is considered
satisfactory.
E
Maintenance
Pro
ram
The inspectors
determined that
NMPC has
an interim program which
covers
Eg maintenance
requirements
until the next outage,
scheduled for March,
1986.
The interim program is defined in
a March 29,
1985 letter from the
Eg Project Manager to maintenance
supervisors.
The letter summarizes
the ongoing activities for
developing the formal program; transmits
the computerized
Eg
Master List, which also identifies any action required for
qualification through March 1986 and the status of that action;
and states
that all modifications required to be complete
by
March. 31,
1985 were completed.
The inspectors
noted that,
except for the deferred
items discussed
in paragraph
4.B of this
inspection report, all required actions
were recorded
as completed
by August 14,
1985.
11
f
The March 29 letter also stated that any planned
change involving
qualified equipment would have to be assessed
to ensure that
qualification is not jeopardized;
and specified that the
responsible
maintenance
supervisor or designee
is to review
work requests
against
the
Eg master list, identify the work
request
as Eg-related if applicable,
and either use formal
Eg
maintenance
requirements
where existent or contact the
Eg staff
for guidance.
Finally, the letter called for Eg staff review
prior to performance of any preventive maintenance
and
surveillance test procedures
not previously reviewed,
and
advised guality Control to verify that
Eg Master List items
are identified on work requests.
The inspectors
interviewed the
ISC and electrical
maintenance
supervisors,
who demonstrated
that they were familiar with the
March 29 letter and stated that it is being observed.
The
Eg
project manager stated that
an additional
backup exists to
ensure that the interim program is effective; namely,
he
receives
and reviews
a monthly printout listing the status of
all Eg-related
work requests.
The inspectors
randomly selected
from the Master, List two
components
requiring corrective action to maintain qualification
until the next outage,
and reviewed the applicable
work packages
to verify completion of the corrective action.
The selected
items are (1) MSIV pilot solenoid valve SOV-01-04C,
ASCO model
206-381-2RU,
which required replacement
by a qualified
NP series
and (2)
PORV solenoid actuator
POS-NR-108D,
Unimax model
KBL711B-5, which required coil replacement.
- Khe following documents
in the work packages
were reviewed:
Work Request
WR¹25985 for Replacing
ASCO Model
206-381-2RU
by ASCO Model
NP 206-381-2RU,
dated
May 4, 1984.
Installation Instruction from J.
K. Jirousek to
T.
W.
Roman.
Description of Work for Eg Work Package
No. 01-21.
Electrical
Connection
Seal Installation
Check List
dated
June
1,
1984.
Inspection
Report
No.
840593 dated
June
1, 1984.
Work Request
WR¹25689 Inspect
and Replace
Wire
(Coil) per
EOWP¹01-6 dated April 18,
1984.
Equipment gualification Inspection for Electromatic
Relief Valve (ENR¹122) dated
May 4, 1984.
12
I'
Review of these
documents
demonstrated
that the modifications
were performed using detailed
approved instructions
and were
inspected
by licensee guality Control Inspectors.
No
unacceptable
conditions were found in this review.
The licensee
stated that all
Eg Required Maintenance
reviews
would be completed
by October
1985,
and all site maintenance
procedures
would be updated to include
Eg requirements
by
March 1986.
At that time the
Eg maintenance
program is
scheduled
to be fully implemented.
Maintenance
program
implementation is included in the
Open Item identified in
section 4.A.(2) of this inspection report.
'uring
the plant physical
inspection of the reactor building
closed loop cooling motors M70-01, 02,
and
03 the inspectors
found evidence of oil spillage
under
each motor and
pump.
guestioning of the electrical
maintenance
supervisor during
and after the inspection (in an August 29 telephone
conversation)
revealed that the
pumps
and motors
had
been
overfilled during
a requi red weekly lubrication maintenance
check.
Overfilling was said not to interfere with equipment
functioning because
the excess oil drains through vent holes.
The licensee
stated that corrective action
was taken
by
lowering the oiler fillers.'erification of this action
and
inspection of maintenance
records will be accomplished
in a
future
NRC inspection.
Closed loop cooling motor lubrication
constitutes
Open Item 50-220/85-13-09.
B.
SER/TER Commitments
The
NRC inspectors
evaluated
the implementation of Eg corrective
action commitments
made
as
a result of SER/TER-identified
deficiencies
as stated
in a licensee
submittal
dated
May 31,
1984.
This submittal states
that all equipment
on the
10 CFR 50.49 Master List is qualified except for certain
eauipment for which Justifications for Continued Operation
(JCOs)
were submitted.
The final SER, transmitted
January
10,
1985 identified that the
JCOs
were acceptable.
Licensee letters
dated
December
13,
1984 and February 5,
1985 stated that further
extension
beyond March 31,
1985
was needed for only two groups
of equipment,
four Limitorque operators
and two shutdown
supervisory
panels.
NRC letter dated
March 15,
1985 extended
the qualification deadline for this equipment until November 30,
1985.
Based
on review of files and of the
10 CFR 50.49 Master List, the
NRC inspectors
identified no failure to implement
SER/TER
commitments.
13
0
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ft
C.
Plant
Ph sical
Ins ection
The
NRC inspectors,
with component accessibility input from licensee
personnel,
established
a list of 12 types of components for physical
inspection.
All were accessible
at the time of inspection,
during
plant operation.
The inspectors
examined characteristics
such
as
mounting configuration, orientation, interfaces,
model
number,
ambient environment,
and physical condition.
No concerns
were
identified during the physical inspection
except
as noted in the
individual component discussions
in sections
4.A.(4) and 4.D.
D.
Detailed
Review of uglification Files
The
NRC inspectors
examined
SCEW sheets
and files for 16 selected
equipment
types to verify the qualified status of equipment within
,the scope of 10 CFR 50.49.
In addition to comparing plant service
conditions with qualification test conditions
and verifying the
bases for these gonditions,
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 of 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 calcu-
lations 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 resolution.
As indicated in section 4.A.(1) above,
the files were difficult to
audit and the inspectors
had to ask.numerous
questions
to develop-
necessary
information.
Even though the licensee
is vigorously
pursuing
a course that appears
to be resolving program
and file
deficiencies,
the file review identified six component-specific
Potential
Enforcement/Unresolved
Items
and two Open Items, of the
16
items reviewed
as follows.
( 1)
Static-0-Ring pressure
switch, pc.
no.
PS-70-279.
-
No
accuracy requirement
was listed for the plant application,
and the licensee
could not demonstrate
during the inspection
that the accuracy
measured
during type testing
was adequate
for the application.
Another concern relates
to the cable
14
I
V
ll
rr
entrance
seal.
The walkdown inspection
and subsequent
questioning
revealed
dependence
on
a cable seal
internal
to the conduit,
and the conduit seal
was not qualified.
The type test did not qualify the internal seal,
since it
was shi'elded
from the harsh environment
by stainless
steel
conduit extending from the switch housing electrical
port to the test vessel
port.
The licensee
subsequently
stated that
an analysis
indicated that the pressure
switch
is not required to function in a hostile steam environment,
contrary to the environment specified in the files.
According
to the licensee,
these
devices
are required only for the Loss of
Coolant Accident which does not produce
a steam environment
at their location.
The inspectors
also observed that no Eg-
related surveillance or maintenance
was required,
even though
the claimed qualified life is 40 years.
Static-0-Ring pressure
switches
comprise Potential
Enforcement/Unresolved
Item
50-220/85-13-02.
Valcor solenoid valve, pc. no.
SOV-39-14C. - Although conduit
was
used to seal
the cable entrance
path during the type test,
the walkdown inspection
revealed that no conduit seal
was
used in the'plant installation.
The licensee
responded
to
questioning
by stating that contrary to the environment specified
in the files, the component is not required to function in a
hostile steam environment.
According to the licensee,
these
devices
are required only for the Loss of Coolant Accident which
does not produce
a steam environment at their location.
The
licensee failed to identify any required surveillance or
maintenance
for a 40-year qualified life, but in this case
the
inspectors
noted that near-term
replacement with other qualified
valves is scheduled
and no degradation
that could invalidate
qualification is expected
in the interim.
comprise Potential
Enforcement/Unresolved
Item 50-220/85-13-03.
General Electric EB-25 terminal blocks,
SCEW 711 - Documents
in the
E(} file did not identify where
and for what services
these
terminal blocks are used.
No functional
performance
requirements
were defined for plant service,
and the required
operating time was specified
on the
SCEW sheet
as
28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />.
Wyle
gualification Test Plan
17655-14 specifies
an insulation
resistance
acceptance
criterion, without indicating the basis,
of
1 Megohm throughout the
LOCA test.
The actual
type test
values
dropped
below the acceptance
criterion for some terminals
8.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the test,
and after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the resistance
of two terminals
was below the test equipment limit of 50,000
ohms at
10 vdc.
Appendix I of Wyle test report 17722-1
recommends
ignoring insulation resistance
and instead
using voltage drop
measurements
as
an acceptance
criterion.
The stated voltage
drop criterion, allowing a decrease
from 137.5 vac to 102 vac,
again
was not related to any plant performance
requirements.
The
inspector could not conclude that this was acceptable
without
justification.
Leakage current measurements
were also made;
15
(4)
(5)
however,
the inspectors
determined
by reviewing the test report
that leakage current
and insulation resistance
measurements
were
made
on different terminals,
and leakage currents
were only
measured
from terminal points to ground,
except for additional
terminal-to-terminal
measurements
performed
on the last day of
the test.
The licensee
could not resolve
these
concerns
during
the inspection,
but did indicate that the qualification of this
equipment
could be established
by analyses
to shorten
the
required operating time.
General Electric EB-25 terminal blocks
constitute Potential
Enforcement/Unresolved
Item 50-220/85-13-04.
General Electric EB-5 terminal blocks,
SCEW 042 - Again
the
Eg file did not identify where
and for what services
the'terminal
blocks are used;
no functional performance
requirements
were defined for plant service;
and the required
operating
time was specified
on the
SCEW sheet
as
28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />.
gualification was based
on Limitorque test report B0119, which
did not specify acceptance
test criteria applicable to the
NNPC
service.
Three hours into the
LOCA test, insulation resistance
decreased
to 20,000
ohms from terminal
B to ground.
No further resistance
data were taken until the end of the
fourth day,
when the value decreased
to 500 ohms.
On
August 26,
1985 the licensee
advised
by telephone that
he
planned to establish qualification based
on
a newly-
determined required operating time of one hour.
General
Electric EB-5 terminal blocks constitute Potential
Enforcement/Unresolved
Item 50-220/85-13-05.
n
Fisher 304 position switch, pc.
no.
39-11-1LSC - Although
these
switches
are scheduled
to be replaced
in spring 1986,
qualification was claimed
based
on
a
LOCA type test with
supporting analyses for thermal life and radiation.
Similarity between
the test
specimen
and plant equipment
was
based entirely on
a telephone
conversation
with a
Fisher sales
representative,
who stated that
no materials
changes
were
made during the involved manufacturing
time
interval.
The thermal life and radiation calculations
were
not based
on review of a material list, but rather
on
a
telephone
conversation
with a different Fisher sales
representative
who stated that the only non-metallic material
in the limit switch assembly is general
phenolic
used in the
Kulka (not Kukla) terminal strip according to the Vendor Contact
Report in the file.
The inspector 'also stated that telephone
memos
based
on calls to sales
representatives
are not acceptable
for documenting similarity evaluations
or as substitutes
for
engineering
analysis of thermal
aging
and radiation effects
on
the equipment.
Fisher
304 position switches constitute Potential
Enforcement/Unresolved
Item 50-220/85-13-06.
16
(6)
Rosemount
1151 transmitter,
pc.. no.
FT-36-06A - The file
~ not only failed to identify the required level of qualification
(addressed
generically in section 4.A.(1) above), it also did
not identify the procurement
date for this transmitter,
which
is not ori'ginal plant equipment,
so that the inspector could
determine
the applicable criteria.
In response
to questioning
the licensee
was able to provide evidence that in fact the
DOR Guidelines apply.
The file also failed to adequately
establish
the qualified life of the transmitter.
Wyle
analysis report 17655-XNR-2. 1 calculates
a life of 27 years
based
on an oven test of a model
1153 transmitter for
which no acceptance
criterion was identified except
"successful,"
and
on
a material analysis
provided in Patel
r'eport PEI-TR-82-12-10 for a model
1152 transmitter.
The
Wyle report erroneously
used
an activation energy of
~
0.78 ev for wire wound resistors
as limiting, although
this transmitter
has
the Type
E electronics
package,
which
Rosemount report 67710A (included in the file) states
uses
metal film ceramic resistors
instead.
The inspector further
noted that the 0.75 ev activation energy of Buna-N 0-rings
and.seals
appears
to be limiting.
Rosemount
1151 transmitters
constitute Potential
Enforcement/Unresolved
Item 50-220/
85-13-07.
(7)
(8)
Acoustic monitor coaxial cable;
Rockbestos
coaxial cable,
SCEW sheets
040 and 124, for automatic depressurization
system valve position instruments
- During 'the inspection
the licensee
was unable to provide procurement
documentation
that the installed cable
was similar to the cable for which
the file established
qualification, since the Document
Retrieval
Computer
was inoperable
near the end of the
inspection.
A future
NRC inspection will verify the
-similarity.
Acoustic monitor coaxial cable constitutes
Open
Item 50-220/85-13-10.
Laurence solenoid valve, pc. no. 50V-201.2-23 - During the
plant, physical inspection,
two gA-related questions
were
raised
concerning this valve.
First, the seismic
acceptability of the valve installation
was not obvious,
particularly with respect
to
a steel
clamp.
Second,
a
deformed gasket
was noted in the conduit coupling for a
related limit switch (although
a seal
was not required
for environmental qualification).
Licensee
review and
correction of these
items
as required will be addressed
in a future
NRC inspection.
Laurence
constitutes
Open Item 50-220/85-13-11.
17
E.
IE Information Notices
and Bulletins
The
NRC inspectors
reviewed
and evaluated
NMPC's activities related
to the review of Eg-related
IE INs/Bulletins.
The inspectors's
review included examination of NMPC's procedures
and
Eg
documentation
packages
relative to
12 INs and
one Bulletin.
The
procedures
review determined that
NMPC does
have
a system for
distributing, reviewing,
and evaluating INs/Bulletins relative
to equipment within the scope of 10 CFR 50.49.
During the review
of individual component qualification files the
NRC inspectors
evaluated
NMPC's actions with respect
to INs/Bulletins and identified
no concerns.
18
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