ML18092B363
| ML18092B363 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/17/1986 |
| From: | Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML18092B362 | List: |
| References | |
| RTR-NUREG-0588, RTR-NUREG-588 50-272-86-23, 50-311-86-23, IEIN-84-44, NUDOCS 8612010033 | |
| Download: ML18092B363 (17) | |
See also: IR 05000272/1986023
Text
Report Nos:
Docket Nos:
License Nos:
Licensee:
Facility Name:
Inspection At:
Inspection Conducted:
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
50-272/86-23; 50-311/86-23
50-272/311
Public Service Electric and Gas Company
80 Park Place
Newark, New Jersey
07101
Salem Generating Station, Units 1 and 2
Lower Alloways Creek, New Jersey
August 11-15, 1986
Inspector: ~};}--=_* . ....,..,/__,._Jj_A.A.-'~~~.--___,..-=-......,....,.....,,...,..--.--=--==-----=---.-
G. T. Hubbard, Equipment Qualification & Test Engineer 'illff
ate
Also participating in the inspection and contributing to the report were:
L. Cheung, Reactor Engineer, RI
- R. Paolino, Lead Reactor Engineer, RI
J. W. Grossman, Member of Technical Staff, Sandia National Laboratories
M. Trojovsky, Engineer, ldaho National Engineering Laboratory (INEL)
D. E. Jackson, Senior Engineer, INEL
Approved by:
8612010033 861113
\\
- SDR
ADOCK 05000272
INSPECTION SUMMARY
Inspection on August 11-15, 1986 (Inspection Report Nos:
50-272/86-23;50-311/86-23)
Areas Inspected: Announced inspection to review the licensee's implementation of
a program for establishing and maintaining the qualification of electric equip-
ment within the scope of 10 CFR 50.49.
Results: The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed
below.
Report
Name
Paragraph
Item Number(s)
Potential Enforcement/Unresolved Items:
1.
Qualification of Rockbestos Coaxial
4.0.(2)
50-272/86-23-03;
and EPR Cables
50-311/86-23-03
2.
Qualification of Scotch 70/
4.E.(l)
50-272/86-23-09;
Construction Splices
50-311/86-23-09
3.
Qualification of Inside Containment
4.0(3)
50-272/86-23-04;
Limitorque Operators without Gear
50-311/86-23-04
Case Grease Relief Valves
4.
Qualified Life of Components in
4.0(4)
50-272/86-23-05;
Exo Sensors Hydrogen Analyzers
50-311/86-23-05
5.
Post-Accident Operating Times for
4.0.(5)
50-272/86-23-06;
ASCO Solenoid Valves
50-311/86-23-06
6.
Engineering EQ Training
4.A.
50-272/86-23-01;
50-311/86-23-01
7.
Mounting of Rosemount Transmitters
4.E.(2)
50-311/86-23-10
Open Items:
1.
Completion of EQMLs
4.C.
50-272/86-23-02;
50-311/86-23-02
2.
BIW Coaxial Cable File Additions
4.0.(6)
50~272/86-23-07;
50-311/86-23-07
3.
Conax ECSA File Additions
4.D.(7)
50-272/86-23-08;
50-311/86-23-08
'**
1.
DETAILS
PERSONS CONTACTED
1.1 Public Service Electric and Gas Company (PSE&G)
- C. McNeill, Vice President-Nuclear
- L. Reiter, General Manager-Licensing and Reliability
J. T. Boettger, Assistant Vice President
- J. N. Leech, Principal Engineer-Licensing
- D. J. Vito, Senior Engineer-Licensing
- G. R. Sayer, Group Head-Engineering Core Group
- W. N. Macintyre, Quality Assurance (QA) Core Group
W. R. Meyer, Principal Training Supervisor
R. V. Watson, Chemistry Supervisor
- E. B. Robinson, Instrument and Controls (I&C) Training Supervisor
- K. M. 0
1Gara, Licensing Engineer
R. S. Patwell, Senior Staff Engineer-Licensing
D. K. Strong, Maintenance Engineer
C. W. Lambert, Principle Engineer
- R. A. Burricelli, General Manager-Engineering and Plant Betterment
P. White, Maintenance Manager
- B. A. Preston, Manager-Licensing and Regulation
- D. A. Perkins, Manager Station QA
- M. Levine, Technical Audit Team Leader
R. Edmonds, Assistant Manager Nuclear Training
J. H. MacKinnon, General Manager-Nuclear Safety Review
- R. L. Gura, Manager-Engineering
- B. G. Horst, Engineer
R. B. Donges, Licensing Engineer
- J.M. Zupko, Jr., General Manager-Salem Operations
- E. A. Liden, Manager-Offsite Safety Review
- D. J. Jagt, Assistant General Manager-Project Engineering
- L. Salamon, Public Information Representative-Nuclear
- C. W. Hambert, Principal Engineer
- R. Antonow, Senior Engineer-Salem Maintenance
- M. J. Shaeffer, On-site Safety Review
- V. Getsinger, Senior Maintenance Supervisor
R. VanderDecker, Senior Engineer, Engineering Planning Department
A. Osborne, Group Leader, Method and Assurance
C. Gregory, I&C Supervisor
F. Mekulsia, Senior Supervisor, I&C
1.2 PSE&G Contractors
- M. J. Cavalier, Site Representative, Atlantic City Electric Company
1.3
NRC
- U. Potapovs, Chief, Equipment Qualification Inspection Section
- J. P. Durr, Chief, Engineering Branch, Region I
- L. J. Nurrholm, Chief, Reactor Projects Section, Region I
- T. J. Kenny, Senior Resident Inspector
- K. H. Gibson, Resident Inspector
- Denotes those present at exit meeting
2.
PURPOSE
The purpose of this inspection was to review the licensee's implementation
of a program meeting the requirements of 10 CFR 50.49 for Salem Nuclear
Generating Station, Units 1 and 2.
3.
BACKGROUND
The NRC held a meeting with PSE&G on April 24, 1984, to discuss the licen-
see 1 s proposed methods to resolve the deficiencies identified in the Unit 1
Safety Evaluation Report (SER) dated January 21, 1983, and Franklin Research
Center (FRC) Technical Evaluation Report (TER) dated July 15, 1982, and the
Unit 2 SER dated January 19, 1983, and FRC TER dated July 15, 1982.
Discus-
sions also included PSE&G's general methodology for compliance with 10 CFR
Part 50.49 and Justification* for Continued Operation (JCO) for those equip-
ment items for which environmental qualification was not completed.
Minutes
of the meeting and proposed methods of resolution for each of the EQ defi-
ciencies were documented in the licensee submittal June 8, 1984.
Final EQ
SERs were issued for Unit 1 on December 5, 1984, and for Unit 2 on
January 14, 1985.
On May 8, 1986, PSE&G submitted Licensee Event Report (LER) number
86-007-00 to the NRC concerning problems with their compliance with 10 CFR
50.49.
The LER stated that during.a "self initiated walkdown inspection
of environmentally qualified equipment for Unit 1 during the refueling out-
age which started on March 22, 1986, it was discovered that eleven inside
containment Limitorque motor valve operators were not in full compliance
with 10 CFR 50.49 requirements due to T-drains not being installed in
operator motor housings.
Additionally the LER documented for Unit 1, that
12 solenoid operated valves did not have required Conax seal assemblies,
7 junction boxes were not properly sealed, and 4 Limitorque motor valve
operators (located outside containment) had brakes still installed. The
LER stated that although the brakes had been electrically disconnected,
the brake assemblies had not been physically removed from the valve
operators.
As a result of the Unit 1 findings, an inspection of Unit 2 was started on
May 1, 1986.
Based on the initial findings of this inspection, PSE&G
shutdown Unit 2 on May 1, 1986, to correct qualification deficiencies
similar to the ones discussed above for Unit 1. Additionally, it was
determined from reviews of junction box documentation for Units 1 and 2
that flow transmitter connections were made with terminal blocks rather
than required splices. The LER stated that corrective action for all
identified deficiencies for both units was completed by May 6, 1986.
On August 6, 1986, PSE&G notified the NRC that as of 6:30 PM that day
both Units 1 and 2 were being shutdown due to questionable environmental
qualification of Limitorque motor valve operators.
The licensee shut
both units down because physical inspections of selected operators
determined that qualification of internal jumper wires in the operators
could not be established. PSE&G replaced the jumper wires in their
2
qualified operators with qualified Rockbestos Firewall III SIS wire
following the shutdowns.
Both units were back in operation prior to the
end of the inspection.
On August 7, 1986, PSE&G submitted LER 86-015-00 to the NRC documenting
that during their review and evaluation of Information Notice (IN) 86-53
they determined that Raychem splices in Unit 1 had not been installed in
accordance with Raychem instructions. Unit 2 Raychem splices were
determined to be in accordance with Raychem instructions. Based on this
determination PSE&G performed an analysis of their splice installation
and determined that affected equipment was operable. Futhermore, they
obtained qualification test data from Wyle Laboratories which supported
qualification of their splice installations. This data was reviewed by
the NRC inspectors during the inspection.
4.
FINDINGS
The NRC inspectors examined the licensee
1 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
1s qualification
documentation files, review of procedures for controlling the licensee
1 s
EQ efforts, verification of the adequacy and accuracy of the licensee
1s
10 CFR 50.49 equipment list, and examination of the licensee
1s program
for maintaining the qualified status of the covered electric equipment.
Based on the inspection findings, which are discussed in more details
below, the inspection team determined that the licensee has implemented
a program to meet the requirements of 10 CFR 50.49, although some
deficiencies were identified.
A.
EQ Program Requirements
The NRC inspectors examined the implementation and adequacy of the
licensee
1 s EQ program for establishing and maintaining the environ-
mental qualification of electrical equipment in compliance with the
requirements of 10 CFR 50.49.
The licensee
1s program for establishing
and maintaining qualification of electric equipment within the scope
of 10 CFR 50.49 is defined in the following procedures.
GM8-EMP-022, "Environmental Qualification of Safety Related
Electrical Equipment for Salem Generating Station," Revision 1,
dated February 12, 1986
GM8-EMP-Oll,
11 I tern Classification Guidelines,
11 Revision 0, dated
March 1, 1985
GM8-EMP-010,
11 Safety Evaluations and Field Directives,
11
Revision 1, March 1, 1985
GM8-EMP-013,
11Material Order/Item Classification Processing,
11
Revision 0, dated February 7, 1985
3
GMB-EMP-019, "Engineering Evaluation, Revision 0, dated
April 16, 1985
GMB-EMP-009, "Operational Design Change Control, Revision 0,
dated December 2, 1985
The licensee's qualification program, which was incorporated into the
licensee's existing procedures when the program was established, is
defined in Procedure GMB-EMP-022. This procedure defines the require-
ments for establishing the Equipment Qualification Master List (EQML)
and ensuring that all equipment on the list is qualified. This
procedure together with the listed procedures and other procedures
discussed in this report ensure that qualification of equipment is
documented, equipment is installed and maintained in accordance with
qualification documentation, EQ is considered when plant modifications
are made such as installation of new or replacement equipment, and
personnel are trained in the requirements of EQ.
The NRC inspectors' review of the licensee's procurement activities
for qualified equipment determined that the system sponsor engineer
is responsible for determining appropriate environmental qualification
requirements for procurement.
He utilizes the EQML, which contains
information such as purchase order number, plant location, design
change control numbers, and other identifying information for each
piece of qualified equipment, in determining appropriate requirements.
For new equipment, the discipline design change sponsor is responsible
for determining the need for equipment to be environmentally qualified
based on function and location. These requirements are identified in
the procurement specification and added to the EQML. Procedure GM8-
EMP-022 requires that the Systems Analysis Group (SAG) review all
changes for concurrence with the sponsor's environmental qualification
classifications.
Procedure M27-P-235 describes the responsibilities and requirments for
ordering spare parts and general inventory items.
The Nuclear Quality
Assurance (NQA) Group reviews final equipment classification in
accordance with procedure GM9-QAP-3-1 and updates purchase requisiticr.s
with appropriate QA codes.
Procedure GM9-QAP-3-l.l, revision 1,
describes the process implemented by NQA to verify item classifications
established by Nuclear Engineering.
The inspectors' review of the implementation of the licensee's train-
ing program determined that 44 plant craftsmen and 14 plant quality
control inspectors performing EQ maintenance and inspection activities
had recieved training in EQ.
While the inspectors determined through
review of plant training records and observation of one training
$ession that plant personnel were receiving EQ training, the inspectors
determined that the licensee had no evidence that personnel in SAG had
received any dedicated EQ training (such as 10 CFR 50.49, NUREGs,
Regulatory Guides, and IEEE Standards). Since SAG personnel are
4
responsible for reviewing and evaluating EQ test reports, preparing
and approving qualification documentation, and preparing and approving
all EQ related field directives, training for these personnel is
essential.
This finding is considered to be significant since the inspectors
identified the use of several qualification techniques without proper
- justification. An example of this was the referencing of the 10
degree C rule
11 for thermal evaluations in many qualification files
without justification that use of this methodology was more conserva-
tive than Arrhenius analysis techniques.
The inspectors also deter-
mined that an outside audit report of the Salem EQ program, dated
February 7, 1986, questioned references to the
11 10 degree C rule"
without proper justification; however, this rule was still referenced
in some files during the audit. Additionally, the licensee used
thermal equivalancies under time-temperature profiles to justify
differencies of 50 degrees Fahrenheit (F) between peak test temper-
atures and plant design basis accident temperatures.
While the licensee was able to establish qualification, after question-
ing by the inspectors, based on qualification methods acceptable to
the NRC, the use of the original techniques to establish equipment
qualification indicates that training would have been appropriate.
The
licensee stated that training-on procedure GM8-EMP-022 was scheduled
for SAG personnel on Tuesday August 19, 1986, as part of their normal
engineering training.
Appendix 3A of the Salem Updated FSAR, Revision 1, dated July 22,
1983, cormnits to compliance with Regulatory Guide 1.33, Revision 2,
dated 1978, which endorses ANSI Nl8.7-1976.
ANSI N18.7-1976 requires
that provisions be made for training of personnel performing activities
affecting quality to assure that suitable proficiency is achieved and
maintained.
The licensee's failure to have documentation, during the
inspection, of EQ training for SAG personnel is identified as a
Potential Enforcement/Unresolved Item (50-272/86-23-01; 50-311/
86-23-01).
B.
EQ Maintenance Program
The NRC inspectors reviewed the licensee's provisions for preserving
the qualified status of equipment qualified to 10 CFR 50.49.
The
licensee identifies maintenance requirements for qualified equipment
in field directives and lists the appropriate field directive for each
equipment item on the EQML.
The field directives are written for each
type of equipment in accordance with GM8-EMP-010. The following field
directives were reviewed by the inspectors to ensure that they were
consistent with applicable qualification documentation.
S-C-A910-NFD-092, "Maintenance Requirements for Environmentally
qualified Namco Limit Switches, Model EA-180," Revision 5, dated
September 26, 1985
5
L
S-C-A910-NFD-100, "Maintenance of Rosemount 1153 Seri es D
Pressure Transmitters Requiring Environmental Qualification,"
Revision 2, dated June 6, 1985
S-C-A910-CFD-0327, "Maintenance Requirements for Environmentally
Qualified RDF Corporation Bypass Loop Narrow Range RTD
1s,
11
Revision 0, dated July 29, 1985
S-C-A910-NFD-0335, "Maintenance Requirements to Ensure the
Continued Environmental Qualification of the Target Rock Solenoid
Operated Valves," Revision 0, dated October 2, 1985
S-C-A910-CFD-306, "Maintenance Procedures for Environmentally
Qualified ASCO NP-Series Solenoid Valves," Revision 3, dated
March 12, 1986
S-C-A910-CFD-0328, "Maintenance Requirements for Maintaining the
Environmental Qualification of the Exe-Sensors Hydrogen
Analyzer," Revision 0, dated July 29, 1985
The NRC review determined that once field directives are written
by SAG, the directives are transmitted to the station response
coordinator.
The station response coordinator then reviews the
directives and incorporates the specific maintenance requirements
into the "Maintenance Tracking System (computer program)." Station
EQ maintenance procedures are then written by the field I&C and
electrical engineers, reviewed by station qualified reviewers,
and approved by appropriate maintenance managers.
In addition to the field directives reviewed above, the following
station maintenance procedures were reviewed to ensure that they
contained maintenance information consistent with applicable
field directives and sufficient for the craftsmen to perform the
required maintenance activities.
IC-14.1.013,
11Maintenance of Environmentally qualified Limit
Switches (EA-180),
11 Revision 2, dated July 2, 1986
IC-14.1.021,
11Maintenance of Environmentally Qualified Solenoid
Valves,
11 Revision 1, dated August 6, 1986
IC-14.1.019,
11Maintenance of Environmentally Qualified
Transmitters, Revision 1, dated August 8, 1986
Prior to due dates of the maintenance activities (scheduled by the
computerized maintenance tracking system), senior instrumentation and
control (I&C) supervisors issue work orders to appropriate I&C super-
visors, who direct craftsmen in completion of the specified maintenance
activities. The inspectors review of work orders 86-03-31-075-1,
dated March 31, 1986 and 86-06-19-039, dated June 19, 1986 determined
that the activities were properly performed and appropriate hold
points were identified for quality control inspection and supervisor
approval.
6
The inspectors' review of the licensee's maintenance activities
identified no deficiencies in the areas reviewed.
C.
10 CFR 50.49 List (EQ Mast~r List)
The licensee is required to establish and maintain an up-to date list
of the equipment that must be qualified under 10 CFR 50.49.
At Salem
Units 1 & 2, an extensive review of electrical equipment was performed
by the licensee to determine the equipment required to be qualified
and included on the master list. The criteria used for determining the
electric equipment requiring qualification included the identification
of Class lE equipment required to function to mitigate the consequences
of design basis events, and which must operate in harsh environments.
This included devices required for the initiation of automatic protec-
tive functions as well as those required for post-accident recovery
actions.
In addition, equipment located in areas subject to harsh
environments and not required to perform a safety function, but whose
failure or misoperation could cause a degradation of required safety
equipment was considered.
Many of the items in this category were
control systems for normal plant operation that had been assumed to
remain "as is for various accident scenarios. Devices or components
that provide operator information or indication required for operator
action was also included on the master list. All electrical and
control equipment which was required to mitigate the consequences of
an accident and which is not located in the control room was identified.
The data generated by the high energy line break analysis and docu-
mented in equipment qualification record (EQR) No. 1 was utilized to
identify equipment which would be subject to elevated temperatures
and pressures due to a line break. Calculations were performed to
determine radiation doses within the plant following a design basis
ac.ci dent.
At Salem the SAG is responsible for establishing, maintaining, coor-
dinating, and controlling the EQ program to ensure compliance with
10 CFR 50.49. These activities include maintaining the 10 CFR 50.49
list or EQML, as it is known at Salem.
Changes to the EQML occur when a design change request (DCR) is
prepared for implementation.
The EQ sponsor is responsible for
reviewing the OCR and its impact on the environmental profiles and
the EQ program.
If necessary, the EQ sponsor will issue an opera-
tional design change notice (ODCN) which is included in the DCR for
update of the EQML.
The NRC inspectors performed an audit of the EQMLs to determine their
validity.
To determine the validity of the lists, the inspectors
reviewed 25 items of equipment to determine whether they should be
on the lists. The 25 items consisted of 5 ASCO solenoid valves, 9
Rosemount transmitters, 4 Westinghouse motors, 4 Namco limit switches,
2 Victoreen radiation detectors, and 1 RDF resistance temperature
detector. The licensee was able to either show that the selected
equipment was on the appropriate EQMLs or justify its exclusion by
using applicable piping and instrumentation drawings, equipment lists,
and the qualification files.
7
At the time of the inspection, the licensee had performed a walkdown
verification of the Unit 1 EQML in accordance with section five of
field directive S-C-A910-NFD-0356, Revision 0. Results of the walkdown
had not been included in the latest revision of EQML at the time of
the inspection. The Unit 2 walkdown and equipment verification of the
EQML had not been performed and was scheduled during the next outage,
October 1986. Licensee verification and completion of the EQMLs for
Units 1 & 2 is identified as an Open Item (50-272/86-23-02; 50-311/
86-23-02) which will be reviewed during a future NRC inspection.
The NRC inspectors' evaluations of the EQMLs identified only the open
item discussed above; however, during the plant physical inspection,
the inspectors identified cable splices in Limitorque operators which
were not on the EQMLs. Additional information on this deficiency is
discussed in paragraph 4.E.(1).
0.
Environmental Qualification Files
The files were examined 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 conditions, the inspectors selectively reviewed
areas such as required post-accident operating time compared to the
duration of time the equipment has been demonstrated to be qualified;
similarity 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 calculations
for qualified life and replacement interval determination; effects of
decreases in insulation resistance on equipment performance; adequacy
of demonstrated equipment accuracy; evaluation of test anomalies; and
applicability of EQ problems reported in IE INs/Bulletins and their
resolution.
The inspectors reviewed 20 qualification files associated with 20 equip-
ment items for both Units 1 & 2.
At Salem, the qualification files
for each equipment item support qualification of the equipment for
use in either unit. An equipment item is defined as a specific type G'
electric equipment, designated by manufacturer and model, which is
representative of all identical equipment in a plant area exposed to
the same environmental service conditions.
(1)
The inspectors' review of the qualification files determined, fer
the files reviewed, that the files supported qualification, except
as discussed in this report.
However, the inspectors had diffi-
culty in following some of the licensee's evaluations and con-
clusions as documented in the files. While the licensee was
able to clarify his positions and establish qualification in the
8
files, the difficulties encountered by the inspectors in
reviewing the files resulted in the inspectors recommending
to the licensee that the following file improvements be made.
(a)
Revise the qualification files or provide other controlled
qualification documentation that clearly reflects the level
of qualification (e.g. NUREG-0588 Category I or II) of the
equipment being qualified. Initially, the inspectors could
not determine the level of qualification; however, the
licensee finally provided a list of the equipment which
was considered qualified to NUREG-0588 Category I. The
inspectors were told that all other equipment was considered
qualified to NUREG Category II.
When this information was
provided, the inspectors identified problems with regard to
the level of qualification for the cables connected to
Victoreen radiation detectors and Exe-Sensors hydrogen
analyzers.
Even though the licensee was able to resolve
the problems, they might have been avoided if qualification
levels of each type of equipment had been clearly documented.
Identification of qualification levels would also help
prevent similar problems in the future when qualified equip-
ment is upgraded or replaced during the life of the plant.
(b)
Remove any information in the files that is not pertinent
to qualification. The inspectors found files which contained
information which was not needed to support qualification of
the equipment. In some cases several tests reports were
in a file and it was unclear to the inspectors which
report/reports were used by the licensee to qualify the
equipment.
In another case the licensee included data to
support qualification based on the
1110 degree C Rule
11 of
thermal aging when this data was not needed for qualifi-
cation. See additional discussions on the
11 10 degree C
rule
11 in paragraphs 4.A.,4.D.(4), and 4.D.(5).
(c) Clarify equipment operability times. Operability times were
identified on generic SCEW (system component evaluation work-
sheet) sheets in each file that covered all the equipment in
the file. This led to some problems when the inspectors
determined that some of the equipment actually had shorter
operability requirements due to the fact that the equipment
was submerged prior to re~ching the claimed operability ti~es.
While the licensee referenced, on the SCEW sheets, a sub-
mergence analysis for the equipment subject to submergence
and shorter than stated operability times, the inspectors
found the stated operability times on the SCEW sheets to be
misleading in some files.
9
(d)
Make sure SCEW sheets are accurate reflections of the
environments to which ~he equipment would be exposed
during a design basis accident (DBA).
In two cases the
licensee claimed qualification of equipment to peak
temperatures of 347 degrees F from a high energy line
break (HELB).
When the inspectors questioned the quali-
fication temperatures, th~ licensee determined that the
equipment was only exposed to loss of cooling accident
(LOCA) peak temperatures of 260 degrees F and was qualified
for that temperature.
(e)
Include discussions in qualification documentation which
addresses how functional performance of cable (particu-
larly insulation resistance for instrumentation cable)
is ensured.
The licensee
1s approach is to specify
performance requirements (including minimum insulation
resistance requirements) in procurement documents and
obtain certificates of compliance from the cable vendors.
This methodology should be discussed in qualification
documentation so that there is documented evidence that
cable function performance requirements have been addressed
when cable qualification is established.
(f) Make .corrections to.files to reflect minor documentation
discrepancies identified to the licensee during the
inspection.
The licensee was able to address the inspectors concerns regarding
the files based on the personal knowledge of the licensee
1s EQ
personnel.
However, the inspectors considered the recommendations
appropriate to ensure that during future EQ activities during the
life of the plant, licensee personnel will be able to understand
the basis for qualification of the equipment.
(2)
Rockbestos Cable, Files EQ-08 and EQ-32
(a)
When the NRC inspectors initially reviewed file EQ-08 for
ethylene propylene rubber (EPR) cable, qualification was
based on Franklin Test Report FC3798 and Rockbestos Test
Reports 7801 and 1804. Since these reports are subject to
the concerns identified in IE Information Notice (IN) 84-44
on Rockbestos cable, the inspectors questioned the licensee
as to whether or not he had taken any of the possible
corrective actions discussed in the IN. The licensee was
unable to provide any documented evidence that he had
undertaken any of the discussed actions; however, during
the inspection the licensee added Wyle Laboratories
Qualification Test Report 17722-2 to the file. This Wyle
report established qualification of the EPR cable for its
application at Salem.
10
(b)
When the inspectors initially reviewed file EQ-32 for
coaxial cable the file contained Rockbestos Qualification
Report, dated March 15, 1979, which is also subject to the
concerns of IN 84-44. Again the licensee was unable to
provide the inspectors with documented evidence that any of
the corrective actions of the IN were taken. Prior to the
end of the inspection, the licensee added Rockbestos
Qualification Report QR 6802 for
11 LE
11 coaxial cable and a
similarity analysis to demonstrate the similarity of the
tested "LE" cable to the installed
11L0
11 (foam dielectric)
cable to the file. This report and the similarity analysis
demonstrated qualification of the installed
11L0
11 coaxial
cable for its application at Salem.
Even though the licensee was able to establish qualification of
the EPR and coaxial cables prior to the end of the inspection,
the qualification files as presented to the inspectors did not
support qualification of the cables, since the licensee was not
able to provide documented evidence that adequate corrective
action had been taken with regard to IN 84-44.
The reports upon
which qualification was initially based were not adequate to
establish qualification.
Failure to establish qualification of
the Rockbestos EPR and coaxial cables is identified as a
Potential Enforcement/Unresolved Item (50-272/86-23-03; 50-311/
86-23-03).
(3)
Limitorgue Motor Valve Operators, File EQ-51:
The inspectors' review of file EQ-51 for Limitorque motor valve
operators determined that operators were installed in inside
containment applications without gear case grease relief valves.
This is contrary to the information provided in paragraph 6~0
"Design Life" of the basic Limitorque Qualification Report,
80058, dated January 11, 1980.
Paragraph 6.0 states that grease
relief valves are used to accommodate the extreme temperatures
and pressures of containment OBA environments.
The inspectors
questioned the licensee concerning his justification for not
using the grease relief valves and the licensee did not have any
documented analysis for not using the valve when questioned.
Based on the concerns raised by the inspectors and prior to the
end of the inspection, the licensee documented his position as
to why the inside containment operators were considered qualified
without the relief valves.
The inspectors' review of this justi-
fication determined that it was adequate to establish qualification
of the installed configuration of the operators.
Since there was no documented justification in the file for
installing the inside containment operators in a configuration
different than the qualified configuration when the file was
initially reviewed, this is identified as a Potential Enforcement/
Unresolved Item (50-272/86-23-04; 50-311/86-23-04).
11
(4)
Exo Sensors Hydrogen Analyzer, File EQ-38:
The inspectors' review of file EQ-38 for Exo Sensors hydrogen
analyzers determined that the qualification test profile for
OBA conditions did not envelope plant conditions (test 300
degrees F, plant 347 degrees F).
The licensee had included an
analysis using the 10 degree C rule to show thermal equivalence;
however, the inspectors found this method of resolving the
profile differences unacceptable.
Upon questioning by the
inspectors, the licensee determined that the analyzers were
only needed for LOCA accident conditions which had peak temper-
atures of 260 degrees F; therefore, the analyzers' test profile
enveloped its plant profile for DBA environments at Salem.
The
inspectors recommended that the file be changed to reflect the
LOCA requirement.
The inspectors also identified concerns with regard to the quali-
fied life of components in the analyzers.
The qualification file
indicated that the pressure transducers and resistance temperature
detectors (RTOs) used in the analyzers should be replaced every
two years; however, Field D"ir1~ci111! ~~ .. c*-t~lC-CFD-0328-RO for
hydrogen analyzer maintenance requires replacement of the trans-
ducers and RTDs every ten years. During the inspection the
licensee was unable to provide documentation supporting a ten
year qualified li Fe for *:tu~ prE!S5.ure transducers and RTDs.
Following the inspection, the licensee provided summary test data
from Exo Sensors, Inc. to the NRC which claimed a qualified life
of 19.2 years for the transducers and the RTOs.
Since the licensee's documentation was not in agreement with
regard to the qualified lifes for pressure tranducers and RTDs
used in the hydrogen analyzers and the licensee did not have
documentation during the inspection to support the replacement
schedule (qualified life) contained in the field directive for
hydrogen analyzer maintenance, this failure to support a
qualified life for the transducers and RTOs is identified as a
Potential Enforcement/Unresolved Item (50-272/86-23-05;
50-311/86-23-05).
(5)
ASCO Solenoid Valves, File EQ-42:
The inspectors reviewed file EQ-42 for ASCO models 206-380,
206-381, 206-832, 208-266, 208-448, 210-036, NP8314, NP8316,
NP8320, and NP8323 solenoid valves. This review identified
some confusion regarding post-accident operating times in the
licenseels documentation.
The file SCEW sheet indicated that
the required post-accident operating time had been revised
from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 120 days; however, the qualified operating time
on the SCEW sheet was 30 days.
Qualification documentation (QD) analysis 1 in the file documented
that the valves could be qualified for 120 days using the 10
degree C rule (this method is not considered acceptable unless
12
it is demonstrated to be more conservative than Arrhenius method-
ology).
QD analysis 2 using Arrhenius methodology documented
that the valves were qualified for 100 days.
QD analysis 3 using
Arrhenius methodology documented that the valves were qualified
for greater than 119 days.
Since none of these documents demon-
strated, by an acceptable means, that the qualified valve operat-
ing times enveloped the required 120 day post-accident operating
time, this item is identified as a Potential Enforcement/Unresolved
Item (50-272/86-23-06; 50-311/86-23-06).
(6)
BIW Coaxial Cable, File EQ-27:
When the inspectors reviewed the file EQ-27 for cross-linked
polyethylene (XLPE) insulated/hypalon jacketed coaxial cable,
qualification was claimed for a HELB OBA environment with a
maximum temperature of 347 degrees F. The inspectors were able
to find only one page of data in the file which documented
testing which would support qualification for an HELB environment.
This page of data was a summary of a proprietary Franklin test
report, documenting testing of the BIW cable.
When the
inspectors questioned the adequacy of the one page summary to
meet the documentation requirements of NUREG 0588, the licensee
determined that the BIW coaxial cable was only used in the
Victoreen radiation monitoring system and was subject only to a
LOCA accident environment with maximum temperatures of 260
degrees F.
The file contained a BIW test report, 8912, to
support qualification to the LOCA environments.
The inspectors
review of this report determined that test parameters enveloped
plant requirements; however, the report did not provide informa-
tion on cable IR values during the accident testing. The
inspectors recommended that the licensee obtain IR data obtained
during the testing to assure that the licensee's minimum speci-
fication values for cable !Rs (see discussion in paragraph
4.0.(l)(e)) were met.
The inspectors also recommended that the
file be changed to reflect that qualification is established
for LOCA environmental conditions.
The obtaining of cable IR
data during accident testing and the changing of *the file to
reflect qualification to LOCA environments is identified as ar.
Open Item (50-272/86-23-07; 50-311/86-23-07) which will be
reviewed during a future NRC inspection.
(7)
Conax Electrical Conductor Seal Assemblies (ECSAs), File EQ-22:
File EQ-22 for Conax ECSAs stated that the tested equipment was
not identical to the installed equipment and there was no analysis
demonstrating why the tests on the tested equipment were applicable
for supporting qualification of the installed equipment.
The
licensee provided the inspectors with a report from Conax whic~
documented the similarity of the materials of the tested and
installed ECSAs.
The inspectors* review of the similarity report
and other documentation in the file determined that qualification
of the ECSAs at Salem was supported; however, the inspectors
recommended that the similarity report be included in the quali-
fication file.
The licensee also should make appropriate correc-
13
tions to the file to demonstrate equipment similarity. Inclusion
of the Conax report and related corrections in the file is
identified as an Open Item (50-272/86-23-08; 50-311/86-23-08)
which will be reviewed during a future NRC inspection.
(8)
IE Information Notices and Bulletins:
The NRC inspectors reviewed and evaluated the licensee's
activities related to the review of EQ-related INs and Bulletins.
The inspectors* review included examination of Commitment
Management procedure VPL-LEP-03, revision 1, and procedure
GM8-EMP-008, revision O.
The commitment management procedure
describes the requirements and responsibilities for ensuring
compliance and systematic tracking of commitments to regulatory
agencies and to ensure that the commitments are met in a
responsive and timely manner.
Sources of commitments include
responses to NRC inspection reports and responses to NRC Bulletins/
Circulars/INs/Generic Letters. Procedure GM8-EMP-008 establishes
the methods used by the Nuclear Engineering Department (NED) to
coordinate the review of NRC documents.
The inspectors reviewed
seven INs and one Bulletin as part of the review of the licensee's
system.
Other INs and Bulletins were reviewed as part of the
inspectors* individual file review.
The inspectors* system review
determined that the licensee has a system for review and tracking
of INs/Bulletins relative to qualified equipment and that they
are addressed in appropriate equipment files. The only concern
associated with the handling of INs/Bulletins identified during
the inspection pertained to the licensee's resolution of IN 84-44,
Rockbestos cable (see paragraph 4.D.(2)).
E.
Plant Physical Inspection
The plant physical inspection consisted of the examination of eight types
of safety-related equipment located outside containment on either/or both
Units 1 and 2.
Since both units were operating the day of the physical
inspection, examination of inside containment equipment was not possible.
The inspectors examined characteristics such as mounting configuration,
orientation, interfaces, model number, environment, and physical
condition.
(1)
During the physical inspection, the inspectors identified electric
wiring splices in outside containment Limitorque valve operators
1SJ67 and 1CS16.
The licensee had no documentation to support
qualification of these splices nor were these splices included on
the EQML for either unit. These splices were identified to the
inspectors as Scotch 70 or construction splices and the licensee
stated that they were probably used in most of the operators
located outside containment.
Prior to the end of the inspection,
the licensee provided the inspectors with a summary of a test of
similar splices written for the Surry Nuclear Operating Station.
During the afternoon of August 15, 1986, following the inspection
exit meeting, the licensee provided the inspectors from Region I
with a complete copy of the test report conducted for Surry. This
14
.~.
report was reviewed by the NRC following the inspection, and was
considered adequate to support qualification of the splices.
However,
in order to establish qualification of the splices for Salem applica-
tion, the licensee must include the report in a qualification file and
evaluate the report for its applicability to Salem environments.
This
failure to establish qualification of these splices and include them
on the EQML is identified as a Potential Enforcement/Unresolved Item
(50-272/86-23-09; 50-311/86-23-09).
(2)
During the inspection the inspectors identified that Rosemount flow
transmitter 2FT-128 was installed on a pipe support with U-bolts to
fasten the transmitter in place.
Rosemount instruction manual for
1153 transmitters (section on mechanical installation) states: "the
transmitter was seismically qualified with the bracket mounted using
4 each 3/8 inch diameter bolts." It also states:
11 if the transmitter
is *mounted to a nonrigid panel the user must ensure that seismic
input to the mounting bracket does not exceed qualification levels
given in paragraph 7.2 of Rosemount Report No. 08400102.
Engineering justification for the U-bolt and seismi.c input to mounting
bracket was not available for this inspection. This observation is
not within the.scope of 10 CFR 50.49; however, it is of concern to
the NRC from the standpoint of seismic qualification and is identified
as a Potential _Enforcement/Unresolved Item (50-311/86-23-10).
(3)
In addition to the items discussed above, the observations discussed
below were made during the plant walkdown.
These observations are
provided for the licensee's information and action as determined
appropriate.
(a)
Evidence of grease weapage around the gease seals of the
limit/torque switches of Limitorque motor operators 11RH4,
11CC16, 1CS16, and 1SJ67.
The evidence consisted of the
observation of a thin film of oil/grease on the inside wall*
of the limit/torque switch compartments of the operators .
. (b)
External inspection of Limitorque valve operator 11SJ33
revealed possible seal leakage by the presence of oil/
grease on the external surface of the limit/torque
switch cover. This is of particular significance since
the operator is oriented such that the switch compartment
is down and directly below the gear case of
the operator.
15