ML18009A707

is within the worst

case

condition [four seconds]

between

load block

starts.

The licensee

stated

that the

computer

code

used for system loading

and

voltage calculations

is

a vendor

program not controlled

by NED.

There is

no regulatory

requirement

to validate

or control

such

vendor

owned

computer

codes.

Based

on the licensee's

response,

Region II does

not consider this issue

to

be in violation of regulatory

requirements

and

no further action is

required.

2.

EDG Air Tank Relief Valves (Deficiency No. 90-200-02)

The licensee

agrees

that the qualifications

documentation

maintained

by

was

inadequate

-to establish

total

seismic

qualification of the

subject

valves.

However,

the

licensee

had

performed

an engineering

evaluation

in April 1989

based

on verbal information from the Perry Plant

and

determined

that the Harris valves

were

enveloped

by the acceptable

portion of the Perry seismic test data.

The test documentation

has since

been

procured

from Cleveland Electric Illuminating and incorporated

into

the qualification files.

Since the valves

were ultimately found to be qualified and the supporting

documentation

was easily retrievable,

Region II does

not consider this

issue to be in violation of Regulatory requirements.

3.

EDG Lube Oil and Jacket

Water Heaters

(Deficiency No. 90-200-03)

The

postulated

common-mode

failure of the

subject

heaters

due to

a

seismic event is not considered

credible for the following reasons:

a.

If the heaters

were to fail, it would take several

hours for the

to reach

normal

ambient conditions.

b.

The

lube oil and jacket water temperatures

are

recorded

every six

hours

by an auxiliary operator at Shearon Harris.

Enclosure I

c ~

If a seismic'vent,

of a magnitude sufficient to fail the heaters,

were to occur during winter conditions it would

be reasonable

to

assume

plant personnel

would

be

aware of it. If the seismic

event

caused

a loss of non-IE power, the diesels

would automatically start.

Failing that, plant personnel

would have sufficient time to manually

start

them.

d.

The

EDG building is equipped

with space

heaters

and there is ample

evidence

in the industry that

these

EDGs

would fast start

under

normal ambient conditions.

Region II does

not

consider

this

issue

to

be in vio'lation of

Regulatory requirements.

4.

EDG Air Receivers

(Deficiency No. 90-200-04)

Shearon

Harris

Technical

Specifications

3/4.8. I

A.C.,

Sources,

Surveillance

Requirements

4.8.1.1.2.a.5

requires,

"verifying the pressure

in at least

one air start receiver to

be greater

than or equal

to l90

psig."

Neither the

NRC nor the licensee

were able to determine

the basis

for the

above

line item.

Review of background

documents

such

as:

Standard

Review

Plan,

Regulatory

Guides

and

Generic

Letters

proved

fruitless with respect

to defining

a standard for the

number of engine

starts

and the pressure

at which these

consecutive starts

should begin.

Nevertheless,

there is sufficient documented

data

(Transamerica

Delaval,

Inc. (TDI), Grand Gulf and

Shearon

Harris Tests)

which confirms there is

five start

capacity

at

pressures

of less

than

190 psig.

Region II

concludes

that

no violation of Regulatory requirements

exist.

5.

Design Basis Control (Deficiency No. 90-200-05)

This deficiency consists

of minor errors

in the design calculations for

the

EDG fuel oil system

and the

EDG HVAC system.

a.

Fuel Oil System Setpoints for Storage

and

Day Tanks

As previously

stated

in the

cover letter,

supplemental

verbal

information

was

obtained

from the

licensee

in late

August

1990.

Specifically the gallonage

at each level in both the day and storage

tanks

was quantified.

~oa

Tank

Low level tank alarm (535 gal)

Low level transfer

pump start

(628 gal)

High level transfer

pump stop

(2792 gal)

High level alarm (2947 gal)

High level transfer

pump discharge

valve closure

(2978 gal)

Enclosure

1

The

day tank allows

one

hour of diesel

operation at the low level

alarm.

This allows adequate

time to replace/repair

the transfer

pump

and is consistent with regulatory positions

on diesel fuel systems.

Stora

e Tank

Low level alarm (104,975 gal)

Fuel oil below suction line (unusable)

(11,663 gal)

The licensee

furnished the time (54 minutes) for the transfer

pump to

restore

the

day tank from low level start to high level stop

and the

fuel

consumption

(445 gal/hr) for the

EDG at

100 percent

load.

Simple computations

show

13,000

excess

gallons

above the

seven

day

required

75,000 gallons in the storage

tank.

Based

on the licensees'esponse,

Region II concludes that the issue

is not

a violation of regulatory requirements.

b.

EDG Building Fan

Calculation

9FP-BE-08

was

performed

by the

licensee

to evaluate

changes

to

the

HVAC air hand'ling unit that

took

place

during

design/installation.

This

calculation

was

not

performed

to

initially size the unit.

An initial heat

load

and

HVAC calculation

9-OGB Section

E

was

performed to determine

the size

and type of air handling unit.

The licensee

performed

system

testing

to determine;

flow in each

duct,

fan

and

motor

rpm,

manometer

readings

(inches

of

H 0),

amperage,

discharge

total

pressure

and static

pressure.

Th( test

data confirmed the adequacy

of the initial calculations.

Region II concludes

that the calculations

were adequate

and that this

issue

does

not constitute

a violation of regulatory requirements.

6.

Emergency

Load Sequencer

Modifications (Deficiency No. 90-200-06)

The

licensee

had

issued

LER-89-016

dated

September ll,

1989,

which

identified

a

substantial

difference

between

alternating

current

(AC)

contac't rating

and

the direct current

(DC) contact rating of the relays

used

in the load sequencer

and

had issued

Plant

Change

Request

(PCR)

4765

for testing of the circuits in the sequencer.

This action was taken priot

to the

EDSFI.

Based

on the

above

information it is evident that the

licensee

had identified this deficiency,

had reported it to the

NRC and

begun corrective action.

This item is identified as

a Non-cited Violation 90-200-0I,

Emergency

Load

Sequencer

Deficiencies.,

This licensee .identified violation is not being

cited

because

criteria specified

in Section

V.G. 1 of the

NRC Enforcement

Policy were satisfied,

and

a licensee

response

is not required.

Enclosure

1

7.

Commercial

Grade Breakers

and Relays (Deficiency No. 90-200-07)

The

NRC has deferred

enforcement

related to commercial

grade

procurement

and dedication

programs

pending

reevaluation

of Agency policy in this

area.

Region II believes

that

the

above listed actions

apply to this

item

and that

no enforcement action'ill be taken.

8.

Failure of LK-16 Circuit Breakers

(Deficiency No. 90-200-08)

This item was previously identified

as

an unresolved

item (89-13-01)

by

the

NRC resident

inspector.

This item is being followed by the resident

inspector

and will not be addressed

as part of the

EDSFI findings.

9.

Testing of Class

IE Underground

Cables

(Deficiency No. 90-200-09)

The licensee's

response

states

that the testing of underground

cables

is

performed

to ensure

the integrity of the spare

6.9

kv and

480 vac

power

cables

as

the result of

a

FSAR concern

power

cables.

This concern is addressed

in the

FSAR, Section 8.3. 1.2.37.

Region II concludes

that the licensee

is meeting its commitment to test

the

power cables

as

required

by Section

8 of the

FSAR.

The licensee

advised that testing is being

performed

as required

which meets

the

commitment.

This item is closed.

ENCLOSURE 2

APPENDIX A

Deficiencies

OEF ICIENCY NUHBER 90-200-01

Deficiency Title:

EOG Load Sequencing

Calculation

(Unresolved

Item - Section 2.1.2 of report)

Descrf tion of Condition:

The emergency diesel generator

(EOG) calculation

17-EP established

the m5nfeem

voltage available at thc 6.9-kV emergency

buses

during thc sequencing of

'afety-related

loads onto the

EOG to be used

as input to other system loadfng

and voltage calculat5ons.

The team noted the following deficiencies in the

ca 1 cul at 5on:

The effect of sequencing

time drift on the tfm5ng of load blocks was not

addressed

fn the calculation.

(If orfft becomes

excessive,

the voltage

transIents

resulting from the two adjofnfng load blocks could overlap,

causing

4 voltage dfp beyond the tolerance of the load's cqu5pment.)

The computer

code

used to perform this calculation

had not been adequately

val5dated

and quality assurance

measures

had not been taken, contrary to

the Nuclear Engineering

Department

procedure

(Reference

1).

Information fn the calculation

on the sources

of input data were inade-.

quate to allow audit ard verification, contrary to Harris plant procedure.

(Reference 2).

The transient effect of the suddenly-applied

load, which reduces

the speed

of the generator

and hence

the generated

voltage,

was

assumed to be

neglfgfble.

The team considered this assumption

nonconservatfve

and the

calculation dfd not justify or establish

the upper

bound of its effects.

All loads

(both starting

and running) were assumed to be accurately

represented

as constant

fmpedances.

The accuracy of this'ssumptfor,

depended

on the mfx of loads'fn each

load block.

In view of the Shearon

Harris load mfx, the constant-impedance

assumption

was considered

not

properly justified or bounded

fn the calculation.

The licensee

provided additional information and stated that

a transient

loading test performed during the qualification of the eaergency

dfesel

generators

(Peference

1) demonstrated

the basic validity of the calculation.

The transient

loading test consisted of a block-loading

sequence

intended to

approximate

the actual

loading on the Shearon Harris

EOGs

as closely as tes't

facility limitations allowed.

The

NRC team agreed that the qualification test

enveloped

the plant conaftfons

and prcvfded reasonable

assurance

that the

results cf the calculation were conservative.

Although there were no iarnedfate

safety concerns

because

the qualification tests

confirmed the adequacy of the

EOG system,

the team concluded that the content of the calculation dfd not

assure

that sufficient voltages

were delivered to safety-related

loads during

an event of loss cf offsfte power,.

Enclosure

2

The licensee staff ~ill revise calculation 17-P by append)ng clarification of

the calculation methodology

and 3ustif.ication of the nonconservat$ ve assumptions

to the calculation.

The licensee stiff also vill to add additional information

on the verification and control of the computer

code.

Refere'nces:

TRP Revision 8, April 10, 1981, "qualification Test Report for TpI

Stardby Generator

Set"

A-2

Enclosure

2

DEFICIENCY HUHBER 90-200-02

~Dfl1

Tll:

EDGAR

't kRl~fVl

. (Potenti ~ 1 Enforcement Finding - Section 3.1 of report)

Descr1 tion of Condition:

The vendor for Crosby air tank relief valves

had issued

a Part

21 report on

fa1lures of these

valves at the Perry Huclear Plant.

The licensee

had

installed Crosby a1r tank relief valves in the

EDG air starting

system per

plant change request,

PCR 4406.

There was inadequate

documentation

to

determine if the rel1ef valves were seismically qualif1cd in. accordance

with

thc

FSAR and

ASNE Section Ill (References l and 2),

PCR 4406 sho~ed that the Crosby relief valves were similar to those installed

at the Perry Huclcar Plant.

The Perry investigation

had determined

these

valves to b'e shock sens1tive

and had included

a seismic test confirming that

the valves

renaine'd properly seated

up to their set point for a certain seismic

spectra.

Accelerations

above

these limits werc determined

by Perry to result

in a

cowmen-node

fa11ure.

The Shearon

Harris 11censec

performed

a safety

evaluation for PCR 4406 and determined that the accelerations

for the installed

rel1ef valves vere less than the limits of the Perry test

and were therefore

qualified.

However, the licensee

had taken

no action to obtain and properly

review th1s test to ver1fy.assumptions,

anomalies

ard plant-specific applica

tion.

The team concluded that the licensee

had not performed

a formal design

evaluation for the qualif1cation of these valves.

The licensee will perform a-.

formal design evaluation to ensure that the Perry seismic test bounds the

Shearon Harris'uclear Plant requirements

and to complete the

IEEE 344-75

documentation

requirements

for these relief valves

by April I, 1990,

10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

design

control measures

to be provided for verifying or checking the adequacy of

des1gn

by performing design reviews, using alternate or simplified

calculational

methods,

or providing a suitable testing program.

References:

1 ~

FSAR,Section 9.5.6.1,

Design Bases,

states

in c) that "the portions of the

air starting

system necessary

for emergency

operation

meet

Se1smic

Categcry I, Safety Class

3 requirements"

and in d) that "the air

receIvers,

piping and valves

from the receivers

up to the d1esel

engine

are designed to Safety Class

3 and Seismic Category I requiren~nts (refer

to Table 3.2.1-1)"

2.

FSAR Table 3.2.l-l lists components

under the heading "Diesel Generator

Air Starting System

as

ASHE lll, Class 3, Seismic Category I, the Diesel

Generator air receivers

and associated

piping, tubing and valves essential

for emergency

operat1on"

A-3

Enclosure

2

DEFICIENCY NUMBER 90-200-03

~Df1i

. tel: tmib

Oll

dJ kilfi

M

t

(Potent1al

Enforccmcnt Finding - Section 3.2 of report)

Dcscri tien of Condition:

During standby the

EDG lube oil system temperature

was maintained at 140of

ainimum by a non-Class

lE inversion heater

located in the

sump tank,

The

jacket water

system heater temperature

was also maintained at 140

F minimum by

a non-Class

lE irarersion heater

located in the standpipe.

The Shearon Harris Technical Specifications

(Reference

1) required the diesel

generator to be derrenstrated

to be operable

by verifying that it could start

within 10 seconds,

with a test

us1ng the manufacturer's

eng5ne prelube

and

warmup procedures.

The technical specifications

gave

no reference to

low-temperature limits.

During standby only non-Class

lE heaters

were avail-

able

and could be lost 1f'a corwen-mode fa1lure occurred during

a seismic event

because

there

was

no evidence that the

EDG had the capability to cold start in

10 seconds ~ithout the lube oil and jacket water heaters.

This was contrary to

FSAR requirewnts

(Reference 2).

The team determined this to be an unreviewed safety

concern with regard to the

des5gn of the plant.

After a seismic event during winter. conditions, the

EOG,.

may not be able to star't in.l0 seconds.

The licensee

took 5amediate corrective

action

and estab11shed

temperature

limits for jacket water (40'F) and lube oil

(70'F) below which the

EOG would be considered

inoperable.

The licensee x5ll

establish administrative controls to monitor the temperatures

of the heaters

and taking appropriate

actions to restore

the

EDG to optimum cond5t5ons if

temperatures

approached

these limits.

~Re ufrenents

10

CFR Part 50, Appendix 8, Criterion 111, Design Control requires design

control rreasures

to be provided for verifying or checking the adequacy of

design

by performing design reviews, using alternate

or simplified

calculational

methods,

or providing a suitable testing program.

References:

1.

Technical Specification 3/4.8.1 A. C., Sources,

Surve1llance

Requirements

4.8.1.1.2.a.4,

1dentifies that 'each diesel generator shall

be demon-

strated

OPERABLE by verifying the diesel

can start ... with1n 10

seconds.'n

the notes it is stated that 'this test shall

be conducted in accordance

with rranufacturer's

recormendatio'ns

regard1ng

engine prelube

and warmup

procedures,

and

as applicable regarding

loading recommendations"

2.

FSAR Section 8.3.1.1.1.5,

Standby

AC Power Supply, b), states that 'each

diesel generator

has

been provided with a preheat

system which maintains

adequate

engine temperature

to ensure fast starts"

A-4

Enclosure

2

DEF 1c 1EHCY NUHBER 90-200-04

~ll II I

litt .'IIIDl I

(Potcntfal Enforcement

Ffnd5ng - Sectfon 3.3 of report)

Dcscrf tfon of Condition;

The

EOG afr start

system

had not been adequately

evaluated to demonstrate i,

five-stari capabf lfty of the diesel it a starting afr rece1ver

prcssure of

l90 psig.

The team observed

the present

alarm set point for the starting ifr

receiver fn the plant was

190 a

5 ps5g.

The present technical specffication

surveillance

requirements

(Reference l) specified

a minimum prcssure of

190 psfg fn each rccefvcr.

-The

FSAR (References

2 ind 3) stated that each

starting afr-receiver shall

be demonstrated

by test io successfully start the

dfesel five times without recharging

the receivers.

During plant pre-

operatfonal testing,

the licensee

had demonstrated

that the diesel generator

had

a five-start capability, but thfs test

was done it high initial pressures

of up to 248 psfg,

and not at the technical specification requirement of 190

psfg.

Test data

provided by the diesel generator

vendor demonstrated i seven-start

capaHlfty for the

EDG, but this test

was not done

on

a receiver 1dentfcal to

the

EOG afr receivers at Shcaron Marrfs.

During thc inspection per5od,

the

licensee

provided relevant test data from the Grand Gulf Nuclear Power Plant

Unit l w1th a similar

EDG afr start

system configuration to the Shcaron Harris

a1r start

system which demonstrated

five or morc starts at in initial pressure

of lower than

190 psig.

The licensee

dfd not make any comnftment to perform testing of the starting ifr

receivers

(actual

equ5pment) for the five-start capability, as coamftted to fn

the

FSAR (Reference 2).

The licensee

stated that i retest would cause

exces-

sive wear on the diesel generator

and afr start system.

Mowcver, the licensee

did perform an evaluation of the Transamcrfca

Delaval (vendor)

bench test,

Grand Gulf test,

and Shearon

Marrfs preoperat1onal

testing to conclude that the

conbfnatfon of these tests result in a safe condition and an adequate

demon-

stration of the five-start capability at 190 psfg.

The tean:

had

no fnnedfate safety

concerns after reviewing the licensee's

evaluat1on,

but noted that no engineer 5ng evaluation

had been performed for

this concern before the inspection; other than the Shcaron

Marr5s pre-

operatfc nal test.

The team considered

the prc-operational test by itself to be

an unacceptable

resolution with regard to meeting licensing conmftments to

denonstrate

a five-start

EDG capability at

a set point of l90 psfg.

l0 CFR Part 50, Appendix B, Criterion ill, Design Control, requires

design

control measures

to be provided for verifying or checking the adequacy of

des1gn

by performing design reviews, using alternate or simplified

calculatfonal

methods,

or providing suitable testing program.

I

~

Enclosure

2

References:

1.

Technical Specification 3/4.8.1

A. C., Sources,

Surveillince Requirements

4.8.1.1.2 states

that each diesel generator shall

be demonstrated

operable

by (item 5)" ... verifying the pressure

in at least

one air start receiver

to be greater

than or equal to 190 psig"

2. 'SAR 8.3.1.2,14

k, qualification Testing Program, identifies that qualifi

. cat1on testing of the diesel generator for the

SMNPP consists mainly of

three test steps:

(1) Factory Run-ln Test, (2) Type Qualification Test,

and (3) Sit<< Test.

'Test Steps

1 I 2, performed at the manufacturer's,

facility, established

test conditions similar to what can

be expected at

the actual site except that the intake and exhaust

system

and starting air

of the test facility is substituted for the actual equipment.

burin

reo erational test at the site

test ste

3

the actual

e ui men

uti

zeo.

s

sect

on

urt er

e

nes t e sterttnp

a r capac ty

test pertormed at toe manufacturer's tactltty under step 2, (3) as "start-

ing Air Capacity Test:

This test demonstrates

the eng1ne-generator's

ability can

be successfully

stated

a minimum of five times without

recharging

the air rece1vers'

~

FSAR Sect1on 9.5.6.1,

Design Basis, states

in a) that "each starting air

receiver will supply sufficient compressed air to crank the cold d1esel

engine five times without recharging

the receiver.

Each cranking cycle

brings the diesel generator

up to

a speed of 200 rpm'

A-6

Enclosure

2

DEFICIENCY NU~1BER 90-200-05

~Df14

VI I

'.

5

1g

B

I

C t

(Potential

Enforcement Finding - Section 3.4 of report)

Descri tion of Condition:

The team found errors

and inconsistencies

in the design calculations for the

fuel oil transfer

system

and

HVAC systems,

Calculations establishing

setpoints for the fuel oil storage

tank (Refer

ence

1) and fuel oil day tank (Reference l) vere not retlected in the

present plant setpoints.

No design basis

had been provided in calculations

(Reference

2) for the

technical specification (3/4.8.1)

minimum fuel oil storage

tank volume

requirement of 100,000

ga lions.

Calculations

(Reference

4) for the

EDG building fans did not provide the

fan curve analysis of HVAC air handling unit AH-85 static pressure,

nor

did it provide

a conclusion.

A calculation

(Reference

5) demonstrated

the effect of winter condition

temperatures

on diesel generator building areas/rooms,

but did not address

acceptance

of non-Class

lE unit heaters

for aeintenance

of the area/room

temperatures.

The team noted that discrepancies

in the format and content of these calcula-

tions ~as contrary to plant procedures

(Reference 6).

In addition, the

1icensee

did not have

a program to ensure that the mechanical

and electrical

design

bases

had been maintained

and properly translated

into plant operating

procedures.

~di:

1C CFR Part 50, Appendix B, Criterion III, Design Control, requires the design

basis to be correctly translated

into specifications,

drawings,

procedures,

and

instructions.

References:

l.

Calculation EgS-28,

Fuel Oil Day Tank

2.

Calculation E(5-23, Fuel Oil Storage

Tank

3,

Calculation

EgS F0-5, Fuel Oil Storage

Tank

4.

Calculation 9FP-BE-OB,

HVAC Air Handling Unit

5.

Calculation 9-DGB, Tab 0,

EDG Building Temperature

1

NED Gl E-4, Revision 0, February k3, 1989,

"NED Guideline-Preparation,

Documentation

and Control of Calculations

A-7

F'

Enclosure

2

DEFJCIENCY

NUHBER 90-200-06

~ltfli

Ill:

E

I

yL d5q

llof1

(Potentfal

Enforcement

Ffndfng - Section 4.2.l of report)

Desert tfon of Condftfon:

Durfng the fnspectfon,

the team questfoned

the adequacy of the contact r'atfng

for load sequencer-relays.

Hodfffcatfons of the load sequencers

were fmple-

mented under

PCR-4765 to elfmfnate relay contact overload condftfons that had

led to relay ccr.tact faflures.

ln addftfon,

an analysfs of relay contact

'loads

was undertaken

by the lfcensee tu verffy the adequacy of the sequencer

desfgn.

Ho~ever,

the safety analysfs dfd not provfoe an acceptable

basis for the

adequacy

of the dc fnductfve ratfngs of the contacts.

The lfcensee

was able to conffrm that the contacts of the suspect

relays,had

been fnspected

and were observed to show no sfgns of damage;

therefore,

there

was

no fmmedfate safety concern.

However, the lfcensee fnftfated a test

program to establfsh

an acceptable

relay contact fnductfve load ratfng for

Potter-Brumffeld relays

used fn dc cfrcufts and scheduled to complete thfs test

program by September

1, 1990.

Reaufrements:

10

CFR Part 50, Appendfx B, Crfterfon ill, Desfgn Control, requfres

measures

be

establfshed

for determfnfng the suftabflfty of materfals

and equfpment that are

essentfal

to the safety-related

functfons of the systems

and for verffyfng or

checkfng the adequacy of the desfgn.

References:

1.

NRC Regulatory

Gufde 1.32, Revfsfon 2, 'Criterfa for Safety Related

Electrfc Power

Systems for Nuclear

Power Plants"

2.

lnstftute of Electrfcal and Electronfcs

Engfneers,

Standard

lEEE 308-

1980,

" lEEE Stanoard Crfterfa for Class

)E Power Syst'ems for Nuclear Power

Generatfng

Statfons'-8

Enclosure

2

DEFICIENCY

NUMBER 90-200-07

~Dfll

Ill.'C

I I.G

d

B

I

dRly

(Potential

Enforcement

Find1ng - Section 4.2,3 of report)

Descri tion of Condition:

The team reviewed the plant procedure

(Reference I) for performing coeeercial-

grade dedications

and noted that the procedure did not require the documenta-

tion of critical characteristics

and did not specify methods to verify critical

characterist1c.

The storage

and maintenance

sheets for <<olded-case circuit,

breakers

also contained

no testing or inspections to verify the seismic

qualification of conrnercial-grade

breakers.

The 11censee's

response

to an

NRC violation dated

November 8, )989, shwed that

the licensee

had installed several

correercial-grade

<<olded-case circuit break

ers in safety-related

applications without a proper revie~ for seismic qualifi-

cat1on or other important critical characteristics.

The response

to the

violat5on, ho~ever,

did not address

other corvercial-grade

breakers that may

have

been installed for a sim1lar deficiency.

The licensee identified 35 commercial-grade

breakers

installed in

safety-related

applications,

and at the team's request,

contacted

several of

the c1rcuit breaker manufacturers

who indicated that changes

had been

made to

the breakers

since their original qualification.

The licensee

was not aware of

these

chinges

and their effect on capab111ty of these circuit breakers to

perform their safety function.

The team also identified several

comnercial-grade

Potter

and Brumfield relays

installed in safety-related

applications.

No testing

was apparently

done to

verify the critical characteristics

of these relays including those for seismic

qualif5cation, contact ratings,

p1ckup,

and dropout for Class

IE applications.

As a result of these

concerns,

the licensee will demonstrate

the Class jE

qualification of the co<<~ercial-grade

breakers

and relays or replacing

them

prior to startup

from the next outage.

~Rd

i:

IO CFR Part 50, Appendix 8, Criterion III, Design Control, requires measures to

be established for determining the suitab1lity of materials

and equipment,

essential

to the safety-related

functions of systems

and

components

and for

verifying or checking the adequacy of the design.

Peferences:

).

Procedure

THY-104, "Determination of Technical

and

gA Requirements for

Procurement

Documents"

A-9

\\

10

DEFICIENCY NUMBER 90-200-08

P

~otM

Till:

F 1l

f BIC t/p

LK-lS.Ct

8

B

k

(Unresolved

Item - Section 4.3.1 of rcport)

Dascrf tfor of Condition:

, Past failures of BBC type LK-16, 1600A-.frame,

480-Y (600-Y class)

power cfr cuit

breakers to open

on demand fn non-Class

lE distribution switchgear

had occurred

after the breakers

had experienced

a relatfvely large

number of cycles

between

preventive maintenance.

The team noted that the non-Class

1E type LK-16

breakers at Shcaron Harris were physically identical to the Class

1E breakcjs

installed at the plant.

The licensee

stated that the LK-16 breakers

in

Class

IE service operated only during operational

surveillance,

post-

m'ntenance

testing,

and accidents

and consequently

accumulated relatively few

cycles

o

The licensee

reported that the basic design of the openfng

mechanism of the

breakers failed to prcvfde enough force to separate

the movable-and stationary

contacts

against

the clamping force of the contact springs, especially

when the

crritact surfaces

had been

roughened

by repeated

cycling.

The licensee

had been

working with the cfrcu)t breaker vendor,

Asea

Brown Boverf (ABB, successor

to

BBC), as well as independently

to resolve this problem.

CPSL and

ABB attempted

a variety of "fixes'ith unsatisfactory

results,

and

ABB apparently withdrew

from the effort.

The licensee

had 'established

an internal engineering

task

force before this

NRC inspection,

but had not established

a root cause for

failures for the past

4 years.

In response

to the team's

concerns,

the licensee

prepared

a safety evaluation

(Reference

1) to justify the continued operation of the plant with the

18 LK-16

breakers

fn Class

1E applications

and conmftted to an accelerated

program of

preventive

maintenance

(Reference

2) on the Class

1E breakers.

The licensee

also will oetermfnc the root cause of the failures by the end of Harch 1990.

Reoufrements:

1G CFR Part 50, Appendix 8, Crit'erfon III, Design Control, requires

design

control measures

to be provided for verifying or checking the adequacy of

design

by performing design reviews, using alternate

or simplified

calculatfonal

methods,

or providing a suitable testing

program.

References:

1,

Licensee's

safety evaluation,

"Response

to

NRC question

on LK-16

Swftchgcar Breakers" (with attachments

A and B), February 26, 1990

2..

CPhL Letter No. HS-903128(0),

L. J.

Moods to d. F. Nevflle, LK-16

Breakers,

Harch 12,

1990

A-10

Enclosure

2

DEF ICIENCY HlNBER 90-200-09

D~fl I

'Hl:

T

t1N

fC1

lEUd

y

dnbl

(Unresolved

Item

Section 4.3.4 of report)

Oescri tion of Condition:

The

FSAR (Reference

1) requires

a random sample of Class

1E cables in the

underground

cable system to be tested to demonstrate

that the dielectric

integrity of the insulation is maintained throughout the life of the cables.

The )icensee

indicated that their current test program procedures

only required

power cables of large 6.9-'V and 480-Y rotating equipment to be tested for

insulation dielectric integrity,

The team was concerned that the licensee's

test program did not fully meet the intent of the

FSAR as all cable types were

not being tested (i.e., power, instrumentation,

and control) ~

The licensee

acknowledged

the concern

and will include appropriate

underground

cables

in the

test program.

Region il will folio~ up on review of testing of appropriate

cables.

10 CFR Part 50, Appendix B, Criterion XI, Test Control, requires that all

testing required to demonstrate

that

components will perform satisfactorily in

service are identified and performed.

References:

1.

FSAR Section 8.3,1.2.37E,

Test program for Class

1E Underground

Cables

ENCLOSURE 3

CPEL Comments

Def iciency Muaber 90-200-01

EDC Load Sequencing

Calculation

~dank round

The

EDSFI

reviewed

Emergency

Diesel

Generator

(EDC)

Loading

Calculation

17-EP.

The

purpose

of

this

calculation

is

to

demonstrate

acceptable

voltage

and frequency of the safety-related

Electrical Distribution System

when loads

are being

sequenced

onto

the

EDC.

This

calculation

was

prepared

by

the

vendor

of

the

generator

(Parsons

Peebles/Electric

Products)

that

is

mounted

on

the

EDC skid.

The purpose

of the

EDSFI revie~

was to verify that

the

content

of

the calculation

provided

adequate

assurance

that

the

EDC would provide

an acceptable

power supply.

NRC Deficiencies

Although

containing

several

individua'l,

items,

this

EDSFI

deficiency addressed

the following major issues:

1.

Documentation

and

conclusions

on

the

effect

of

sequencer

relay timing drift.

2.

Absence

of validation information for the

vendor's

computer

model.

3.

The calculat ion

package

did not contain al.l the information

that is required

by existing

CP&L design guidelines.

believes

that

there

is

no

technical

issue

in

rhis

deficiency.

The

issue

is

the

quantity

and

presentation

of

technical

information

in

the

calculation.

Responses

to

the

specific points listed

above are

as follows:

l.

As

shown

in the

computer

printouts

included

in Calculation

17-EP,

the worst

case

recovery

time to

90Z voltage is

1.01

seconds

with full recovery in less

than

2 seconds'ince

the

maximum drift on timer setpoint

is 0.5

seconds,

the

minimum

,possible

time between

load block starts

is

4 seconds

assuming

a late

start

of

one

block

and

an early start

of the

These

values

are

confirmed

through

performance

of

Engineering

Surveillance

Tests

EST-316

and

EST-317 'ince

the diesel

generator

voltage will recover in appreciably

less

time

than

the

minimum possible

time

between

sequenced

load

blocks,

there will be

no

adverse affect

from sequence

timer

drift.

This topic will be addressed

in the next revision of

the subject calculation.

In

summary,

the

calculation

contained

the

essential

information to

reach

a

favorable

conclusion

even

though it

was not stated

in explicit terms.

MEM/HO-9001130/4/Osl

Enclosure

3

2.

NED

procedures

softMare

control

cover

programs

used

in-house,

and

therefore

are

not applicable

to previous

Work performed

by vendors.

Control

and verificatiori of the

sof tMare

is

covered

by the manufacturer's

QA program.

The

software

used

in the

above

calculation

was

developed

and

is

maintained

by

the

manufacturer

(Parsons

Peebles/Electric

Products).

3.

During

the

audit,

the

calculation

preparer

(Parsons

Peebles/Electric

Products),

verbally

provided justification

for

the

assumptions

used

in

the

calculations.

has

requested

the

reference

documentation

Mhich vill

be

incorporated

in

the

of

the

calculation

for

cl'arity.

Conclusion

CPhL

believes

that

there

is

no

technical

issue

in

this

deficiency.

However, additional

supplemental

information Mill be

added

to the calculation.

HEM/HO-9001130/S /Os 1

Enclosure

3

Deficieocy Number 90-200-02

EDC hi r Tank Relief Valves

~Back round

CP&L initiated

an

engineering

evaluation

on

April.

14,

1989

to

review the application of the Crosby Starting Air Relief Valves

on

the

EDC at

Harris

based

on

receipt

of

a

Nuclear

Network Report

(NO.

OE-3260)

from the

Perry, Plant.

The evaluation

(PCR-4406)

assessed

the Perry acceleration

(g) values

determined

by test

(and

obtained

verbally from Perry) to determine

that

the Harris valves

were

enveloped

by

the

Cleveland

Electric

Illuminating

(CEI)

Reports

This

was

based

on

specific

Harris

seismic

input.

An

additional

condition

considered

was

valve

positions

The

Perry

problem

was initiated

when

the valves,

mounted

in the horizontal

position,

were

bumped.

The

Harris

valves

are

mounted

in

the

vertical

position further

reducing

the possibility

of

a similar

occurrence.

The

evaluation

concluded

these

valves

were

acceptable'he

fact that the actual qualification report

was not

obtained

at

that

time

was

based

on the fact that

the valve

was

assured

qualified

for

initial

design

conditions

(with

documentation

included with the

EDC package)

and

was evaluated for

specific

loadings

and

criteria

identified,

not

'totally

requalified.

The total qualification report

was later

obtained

and

a complete qualification package

generated.

On January

17,

1990,

the original equipment

vendor

(Transamerica

DeLava1 )

informed

under

10

CFR

Part

21

that

the

valves

procured

for

the

Shearon

Harris

Plant

had

not

been

seismically

qualified,

contrary

to their original responsibilities

to

CP&L.

Because

of the evaluation

performed,

based

on the Nuclear

Network

Report,

CP&L determined

that there

was

no immediate safety

problem

at Harris'n

March 9,

1990

ICE. Notice 90-18

was

issued

by the

NRC.

The

EDSFI report stated

that "the team concluded

that

the licensee

had not performed

a formal design evaluation for the qualification

of these valves" based

on the

absence

of the seismic qualification

report being on file.

The

EDSFI does

not adequately

and accurately

portray the

sequence

of

events

surrounding

this

issue.

agrees'hat

the

qualification documentation

maintained

by

CP&L was

inadequate

to

establish

total

seismic

qualification

of

the

subject

valves.

However,

the conditions

questioned

were

thoroughly

evaluated

and

found

acceptable.

The

seismic

qualification

package

has

subsequently

been

upgraded

to

include

the

qualification

information based

on the receipt of the Part

21 from Transamerica

DeLaval.

The seismic test report

was procured

from CEI, subjected

MEM/HO"9001130/6/OS1

Enclosure

3

to

an

engineering

revie~

and

incorporated

into

the

seismic

qualification files'P&L disagrees

with

the

impression

that

prior to the

EDSFI,

the

issue

had

been dealt with on

a less

than

formal basis.

The

issue

had

been dealt

with from the standpoint

of the

anomalous

behavior of the valves at

CEI and

subjected

to a

detailed engineering

evaluation.

Conclusion

This

issue

was

subject

to

ongoing

CP&L reviews

in

accordance

with the

review of Part

21 notices

made

to

CP&L.

As

such,

the

issue

of lack of qualification documentation

had

been

already

identified

to

CP&L and

would

have

been

corrected,

The

technical

issue

of the applicability of the valve had already

been

the

subject

of

engineering

evaluation

based

on

reliable

test

information from CEI about

the valves'eismic qualification test.

HEH/H0-9001130/7/OS1

Enclosure

3

Deficiency Number 90-200-03

EDC Lube Oil and Jacket

Mater Heaters

~Back tound

The

design

of

the

Harris

Emergency

Diesel

Generators

(EDCs)

includes

non-safety

in the lube oil reservoir

and

jacket

water

reservoir.

The

heaters

are

used

for maintaining

temperatures

for minimizing wear

on the

EDCs during

an

EDC start

as

described

in

FSAR Sections

9

5

2

and

9 5.7.2.

The heaters

are

not

required

during

EDC operation.

The

maintenance

of the

proper

engine

temperatures

is

subject

to

routine

(daily)

verification by the logging of

EDC parameters.

The fact that

the jacket water heaters

are

powered

from non-safety

is identified in the

FSAR (see

Section 9.5.5.2).

The

FSAR does

not clearly state

that the

lube

oil heaters

are

powered

from a non class

lE bus.

The plant design

philosophy

as

stated

in

FSAR Section

3.2.1.1

is

that

Class

1E

power

would

be

required

only if the

function

is

necessary

to

assure:

a)

b)

c)

The integrity of the

reactor

coolant

pressure

boundary

(RCPB),

The

capability

to

safely

shutdown

the

reactor

and

maintain it in a safe condition, or

The capability

to prevent

or mitigate

the

consequences

of

accidents

which

'could

result

in potential offsite

exposures

comparable

to the guideline exposures

of 10CFR

Part

100

~

These

heaters

do not perform such

a function.

The

EDSFI reported

that

the

NRC team position

was that the heaters

must

be

powered

by

a Class

1E power

source.

The

bases

that

was

given for this position

was that if the

non Class

1E power supply

were

lost

during

extreme

cold outside air

temperature,

the

EDC

would

no longer'be

capable

of a successful

emergency

start within

the required

10 seconds.

The response

to this

issue

contains

two basic points.'he first

(also

discussed

in Deficiency 90-200-05 ) is that heaters

required

solely for temperature

maintenance

of equipment

and not required

during

emergency

operation

of equipment

need

not

be

designed

to

Class

1E

requirements.

This

design

philosophy

is

utilized

throughout

the design for SHNPP.

This design

philosophy is based

on the

NRC's guidance

provided in Reg

Guide

1.29

"Seismic

Design

Classification."

MEH/HO-9001130/8/Osl

Enclosure

3

In the

specif ic example

of the

EDC heaters,

it is unlikeLy that

the

non-Class

LE

power

supply

system

would

be

lost

without

resul t ing

in

the

operat ion

of

the

EDG.

The

Class

LE

buses

are

dependent

on

the

same offsite circuits,

transformers

and

6.9

KV

distribution that

feeds

the non-Class

LE distribution system.

If,

on the other hand,

the

Loss of the heaters

is due to a malfunction

of the heaters,

this failure

would

be possible

regardless

of the

qual ification of the heaters

~

The

loss

of

a specific heater

is

discussed

in the second

point ~

Secondly,

the deficiency

does

raise

the

issue

whether

there

is

a

Lo~er

limit for

successful

operation.

A

review

of

the

technical

information and

past

EDC starts

at lov oil temperatures

established

that there

are

lover limits of jacket water

and

lube

oil

temperature

which

are

required.

has

determined

that

jacket

vater

temperature

must

be

maintained

greater

than

40

degrees

F and that lube oil temperature

must

be maintained greater

than

70

degrees

F.

These

limits

have

been

established

in

appropriate

administrative

procedures

and vill require

that if

these

temperatures

cannot

be

maintained,

then

the

EDG vill be

declared

inoperable.

Conclusion

It is

CP&L's position

that

the

key issue

is maintaining

the

lube

oil

and

jacket

vater

temperatures

within the

appropriate

limits.

However,

the

components

to maintain

these limits do not

necessarily

require

the

use of Class

LE equipment.

The basis for

this

position

is

that

only

those

components

necessary

for

operation of safety related

equipment

are required to be Class

LE.

HEN/H0-900 I 1 30/9/OS I

Enclosure

3

Def iciency Number 90-200-04

r

EDC Ait Receivers

~Bakcround

The

EDCs including the air start

systems

for SHNPP,

were

procured

from TransAmerica

DeLaval

~

The qualification testing

for the

EDC

included

factory run-in tests,

type qualification tests,

and site

tests.

The

in Section

8.3.1.1.2.14.k.2,

defines

which of

these

tests

were

used

to

satisfy

the

applicable

regulatory

requirements.

For

SHNPP,

the

vendor

demonstrated

adequate

air

start

receiver

capacity

using

a prototype air start

and

exhausr.

system.

The

FSAR clearly states

that the qual.ification of the air

start receiver capacity, was

performed

as

a type qualification test,

in

the

vendors

faci lity.

Section

14 .2 . 12. 1. 16,

which

discusses

the specifics

on

the onsite testing, clearly omits

the

air start receiver capacity testing.

Notwithstariding

these

commitments

and their approval

by the

NRC

SER,

CPhL conducted

an onsite air receiver

capacity test.

This

testing

was

performed

with

a

starting

air

pressure

of

approximately

235 psig.

This pressure

is the nominal air receiver

pressure

that results

when the associated

air compressors

complete

a running cycle.

The

purpose

of the onsite. air receiver testing

was

for commercial

reasons.

Differences

between

the air start

system

used

at

the

factory

and

the

onsite

installati'ons

are

minimal.

The size of the piping and

number of components

are the

same

~

The main exception

is that

the size of the air receiver at

the test facility had

a smaller

volume than those at Harris.

NRC Deficienc

The

EDSFI

team

concluded

after

reviewing

the

start

and

load

acceptance

test

(performed

onsite)

that

the

system

had

not

been'dequately

evaluated

to demonstrate

a five-start capability of the

EDC at

a 'starting air receiver

pressure

of 190 psig.

CPhL Res

nse

The interpretation

of

the

by the

EDSFI is incorrect.

The

section

is incorrectly

and

incompletely

referenced

by

the

inspection report.

The entire

FSAR passage

is provided

below'.

8.3

~ 1 ~ 1.F 14.K

Qualification

Testing

Program

- qualification

testing

of

diesel

generator

for the

SHNPP plant consists

mainly of the

following

steps.'.

Factory run-in test.

2.

Type qualification test

MEM/H0-9001130/10/OS I

Enclosure

3

(a)

Start

and

load acceptance

qualification

(b)

Load capability qualification

(c)

Hargin qualificacion

(d)

Sequencial

loading test

(e)

Starting air capacity test

3.

Site test

(a)

Start

and

Load acceptance

test

(b)

Load capability test

(c)

Design load test

(d)

ELectrical tesc

Test

Steps

1

& 2,

performed

at

the manufacturer's

faciLity,

estabLished

test

conditions similar to Mhat can

be

expected

at the actual site

except

that the intake

and

exhausc

system

and starting air of the test facilicy is substituted

for the

actual

equipmenc.

Ifuring

che

preoperacional

test

at

che

site, test

Step 3, the actual

equipment is utilized.

This

clearly

shoMs

that

CP6L's

commitment

on

the

air start

receiver. capacity test did not include the requirement

to perform

a site test

Mich che air tanks inirially at

190 psig.

Conclusion

The

commitmenc

has

been

properly

addressed

by existing

tescing

and

no further testing is required.

HEMIHO-900 1'1 30 I 1 1 IOS 1

I

Enclosure

3

Def iciency Number 90-200-05

Des ign Bas i s Cont ro 1

This, item

addressed

four specific

mechanical

calculations

that

were

reviewed

during

the

EDSFI

~

The first and

second

items

are

addressed

together

and

the latter

two

are

addressed

separately

below.

A suranary conclusion for all four items is presented

after

the conclusion of the fourth item.

Items

A & B)

Fuel Oil Tank setpoints

(Two examples)

~Back raund

The

Main

Fuel Oil Storage

Tanks

for

SHNPP

were initial,ly sized

when

the

SHNPP

was

a four unit design.

The design

consisted

of

four underground

tanks.

Each

tank

was

to

be

shared

between

two

EDCs

from separate

units.

Because

of this,

the original size

was

determined

to

be

175,000

gallons

(suf ficient

to

accommodate

accident

loads

on

one

unit while allowing safe

shutdown

of the

other unit).

Subsequently,

the size of the station

was

reduced

to

a

single

unit.

The

required

quantity

of

fuel

was

revised

downward.

The result

was that

74,760 gallons

of useable

fuel oil

would

be acceptable.

The value is the result of calculation

EQS-

23,

Rev.3

(January

14,

1986).

Subsequently,

the

Technical

Specification

value

for

the

Main

Fuel

Oil

Storage

Tanks

was

selected

in

1986.

This

value

was

chosen

to

be

100,000

gallons

(indicated)

to

envelope

the

result

of

the

most

recent

calculation.

The

Main Fuel Oil Tanks

level transmitter

feeds

a

local

indicator

at

the

Main

Fuel

Oil

Tanks

and

feeds

a

Main

Control

Board Annunciator.

The annunciator

is

set

to alarm

when

the

fuel oil

level

reaches

an

indicated

level

equivalent

to

104,970 gallons.

Each

EDC has

a dedicated

Day Tank with a capacity of approximately

3100 gallons

~

There are

several

functions

that

are

performed

by

the

level

transmitter

and

level

switches

on

the

tank.

In

ascending

tank level these

functions are:

1.

Low level tank alarm

2.

Low level transfer

pump start

3.

High level transfer

pump. stop

4.

High level alarm

S.

High level transfer

pump discharge

valve closure

Mhen Technical

Specifications

were

developed,