ML20127B519
| ML20127B519 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/03/1990 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Russell W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20126M903 | List: |
| References | |
| FOIA-92-212 NUDOCS 9301120314 | |
| Download: ML20127B519 (20) | |
Text
JUL 0 319m MEMORANDUM FOR: William T. Russell, Associate 01 rector For Inspection and Technical Assessment FROM: Thomas T. Martin, Regional Administrator Region I
SUBJECT:
ALLEGATION (RI-89-A-0072) ADJUSTMENT OF MOLDED CASE CIRCUIT BREAKERS (MCCB) AT SUSQUEHANNA The purpose of this letter is to clarify the Region I office view of the above subject matter. We believe that there are no significant technical reasons nor are there any NRC requirements that prevent the licensee from performing MCCB internal trip adjustments.
An inspection was conducted by our staff (50-387/388-90-02) to review an allegation regarding the licensee performing disassembly and adjustment of MCCB trip units. Based on the inspection, we determined that the licensee does perform limited disassembly and adjustment of MCCBs. However, this task is performed in a controlled manner under their Quality Assurance Program in accordance with 10 CFR Appendix B, Criterion 2 by qualified maintenance personnel. The licensee does not perform rebuilding or refurbishment of MCCBs. Therefore, the concerns identified in Bulletin 88-10 do not apply. The licensee -
recognizes that by opening molded case circuit breakers, the manufacturer's warranty and UL approval is voided. The licensee stated that they have not contacted the vendor to get their approval, since they consider the adjustments to be minor and breaker function is assured through post adjustment testing and subsequent surveillance testing.
The inspector observed that no specific vendor procedures or recommendations ware available to perform this task. However, we noted that there are approved vendor instructions available for more significant activities such as opening MCCBs to replace components such as auxiliary switches and shunt trip coils. We are not aware of existing regulations which prevent licensees from opening and adjusting the trip units. Furthermore, even though not specifically written to address MCCBs, IN 89-45 reinforced the policy that licensees should assure that maintenance and modification of equipment are performed properly by qualified personnel using correct parts and materials and that required rotests should be properly conducted and evaluated.
t 09W0FFICIAL RECORD COPY (L\
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2 MCCBs magnetic trip adjustments were performed at Susquehanna on o a limited number (5-6) of Westinghouse HFB-TM type breakers. The licensee stated that these adjustments were made on new breakers during startup of the plant. No further adjustments have been made to breakers since that time. However, they have retained the option of making similar future adjustments. Also, these MCCB adjustments were performed only if the magnetic trip points were already within the manufacturer's trip curves. These trip adjustments were performed to meet breaker magnetic trip settings as required by the licensee's setpoint documents, technical specification 4.8.4.1 surveillance requirements and to provide proper breaker coordination. The acceptance criteria for these -
tests satisfy the manufacturer's breaker trip characteristic curves. These breakers are subjected to surveillance and functional tests (energizing the connected load) before the system is declared operable.
The licensee's maintenance procedure MT-GE-008 provides guidelines to perform this task. Even though the procedure does not give minute details for each step, the licensee follows guidelines delineated in R.G 1.33 regarding procedures for performing maintenance. This is also consistent with ANSI 18.7-1972, paragraph 5.1.6.1. The inspector witnessed the licensee's demonstration of breaker testing and magnetic trip adjustment of MCCBs. The adjustments were observed to be minor and ,
maintenance personnel who perform this task are experienced and aware of potential problems if this task is not performed correctly.
We observed that the licensee is performing these adjustments without the manufacturer's approval and outside NEMA guidelines.
However, this practice is currently neither endorsed nor prohibited by the NRC.
With regard to the alleger's follow up questions, dated April 27, 1990, the following information provides our views regarding the allegers questions :
- 1) The procedure used for this adjustment is MT-GE-008. No manufacturer or industry standards were used for these adjustments. The Westinghouse application manual was used for general guidance. Maintenance personnel working on this program are well trained and experienced on breaker operation and testing. We believe that even though the procedure does not provide minute details, it provides adequate guidelines for this activity to be performed by qualified and experienced maintenance personnel. This was observed during the licensee's demonstration of breaker adjustments.
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- 2) No assembly drawings or shop drawings were used except for the Westinghouse application data manual and the Cutler-Hammer motor control center instruction manual. Assembly drawings and shop drawings are proprietary information and are not available to the licensee. We believe that experienced personnel and good maintenance practices provide adequate assurance that MCCBs are properly reassembled after opening.
- 3) The licensee unlocks the three breaker internal adjustment screws using a standard soldering gun. Since the heat is applied only for a short duration, no heat damage to components is likely. The lock-tito used to replace the original lock-tite is used between metal surfaces. No plastic housing is affected by this adjustment. The licensee believes that the locktite is only used to prevent tampering of adjustment screws in breakers. Also, since no modifications or replacements of components are performed, they believe that the seismic qualification of the breakers is maintained.
- 4) Susquehanna uses calibrated M&TE low and high current Multi-Amp test sets to test the breakers using the surveillance and maintenance procedures, the Cutler-Hammer instruction manual for motor control centers, technical specification and the manufacturer's breaker time current curves. These tests are performed in a controlled environment under their-Quality Assurance program. The licensee's test equipment and procedures are adequate to establish proper function of-the subject MCCDs.
The manufacturer does not authorize opening of the MCCDs by personnel other than their factory trained personnel for retaining the MCCB warranty, Modifications during this adjustment are limited to replacing _the original lock-tite for the trip set screws. The licensee cannot test the breakers under the same laboratory condition as the original factory testing. However, surveillance testing of breakers is performed in a controlled environment as required by the licensee's Appendix B program and appears adequate to assure breaker function.
We also note that the NRR Allegation Review Board comments for case file NRR-89-A-0023, May 29, 1990, (Enclosure 1) dealing with t this subject, appear to be establishing NRC policy.
Specifically, the statement: " ...although the inspection related to this allegation revealed no significant deficiencies in this instance, Bulletin 88-10 applies for this type of activity and l
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4 that disassembly and adjustment of MCCB trip units violate industry codes or manufacturer's specifications. In summary, it should be made clear to the alleger and the licensee that this practice is not one condoned by NRC." We believe that this has earmarks of a backfit and constitutes a new staff position; thus, making it appropriate for review and approval by the Committee to Review Generic Requirements for promulgation to the industry.
The Region maintains that licensee's may perform maintenance on any equipment providing the activity has appropriate controls and adequate post maintenance testing. Should NRR determines that the Susquehanna practice of opening MCCBs and adjusting the internal trip units is unacceptable, then we recommend that NRR review the generic implication of this issue and issue generic communications. This should include, but not be limited to, the implications of opening MCCBs for changing factory calibrated internal trip setpoints and changing vendor approved components such as shunt trip, auxiliary switch, and bc.ll alarm switches by personnel other than the manufacturer.
Original Signed By:
n a cs T. Maa h Thomas T. Martin Regional Administrator cl9 d JY LGk RI:DRS RI:DRS RI:)R5 RI: s Anderson Durr Hodges n T artin 6/ y/90 f/3./90 //j/90 '/ 5 /90 0FFICIAL RECORD LOPY
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NRC OP " ITEM 387 / 90-24-01 Subject This iten dealt with Inspector concerns about PP&L's practice of disassembly and internal adjustrents of molded case circuit breaker trip units.
Response Sumary FF&L has ;erranar.tly c;spended internal adjustrents te olk 1 i I
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pursuar.* t? 10CFR50. 5 9 which conclude:d t ha t adjustments
.t-7. usly 4 ade *: 10 safety-related circuit breakers were a : : + ; *. = b '. e . Periciic t-sting of these breakers is in place pet Frev e. n t a t i v e Mairtenance package PMIP !!o. 020.
4 Attachments Inspecticn Report 38*7(338) 90-24 Maintenance Response Surrary PCAF 1-91-0326 and MT-GE-008 Safety Evaluation No. NL-90-040 i
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RETURN TO M&M/M/V PMIS CLOSURE DATE Fomu b eneiei
3 training chief and his staff report directly to the Nuclear Vice Presicert.
ine licensee's training program is cescribed in Procedures NTP-0A-63.1 an:
63,2. The licensee statec that the training program and these procedures
.ere cevelo:ec base: upon INPO documents85-001, 88-002,88-012, 88-015 an: 55-0022 an: ANSI Standards. At present, 90t. of the staff at the site a a v e c: :' e '.e: their training en:ect the newly hired who are currently
., a :e r;; i a ; :*e Oreg a? Ihe t0tal curriculum provides the technical keow me., ar: c*-tne-jeb t-aining for various engineering cisciplines.
- me ' :easee ia04: ate: t?at all the engineering staffs are budgete: to at e c se- aa s arc sy*::si e s ir sneir fields an: seventy-five (75) c' tae sta ee: resent lEEE, ANS anc ctne technical committees. The licensee
- art 4 : :a:es 1- tne EpR:, NUMAR an BWR Owner's group and encou ages tne
.e:-
- a' staf' to tate act've roles to meet the Station V0-t ~0'te
-e:c e, e ts. !"s trairing -ogram accears to be acecuate cased on
- 5: ss :as oita ea;'*ee'ing De" sorrel and the Oepth of the Encale:ge cf er;taeer'*; erscerel 00$ervec coring this inspection.
3.C Ea; ee ; 4:-k Reesests (EWRs)
Ihe Inscetter discusse: the EWR backlog with the corporate engineer rescensible for tracting all EWRs. The EVR backlog as of mid-Novemcer had 2,651 0:ee items. Tne licensee indicated that the EWR backlog had been teen:1rg upware and that management was aware of the increasing trenc.
Tne inspector reviewed the EWR backlog contained in a partial computer pr1ntout at the site from the compliance group. There were approximately 100 EWRs that were older than two years. The inspector ranecmly selectec 14 of these EWRs. It was noted that half of the EWRs addressed maintenance related issues (e.g. , spare parts). The inspector discussed this A 's observaticn with the maintenance manager who indicated that engineering hgenerally s /Xresponced to maintenance needs in a timely manner. -
[ [nT'Y,o\ Breaters PCCOs) at Suscuehanna Urjet 10.0 Follewuo Insoection Regarding Adjustment of Molded Case Circuit Ouring NRC inspection 90-02, an allegation regarding the licensee's Ap practice of permitting maintenance personnel to disassemble and makt g[o internal adjustments to MCCB trip units in accordance with maintenance procedure MT-GE-008 was substantiated. tencerns were also raised by the l skleggestengemeur Itcafisee's practice of diussembly arad adfestment of s HeatwMsdanseusenset specific vender published instructicas or approval l ag3 fed!C11dr& M1464r- .
During this inspection, the inspectors noted that the licensee's procedure MT-GE-008 does not provide detailed infor1 nation regarding'the operations involved in disassembly / reassembly of the breakers. ? :
'" 5" stated 's tM,htAeat did met esetut tao tender to portfy whether thWPRiHTfe of MCC9 ediwetsar.4,& cowId 1444 t.c dagradattear e# the breaimsyn The 11eensee stated that this activity is performed in a controlled environment by l
9 Qualified personnel. It.should be noted that NRC generic letter 33 28 informed all licensees that an ef fective vendor interface program snowle ce implemented for all safety related ecuipment. The inspe:ters netec that no scecific vencer outlished instructions or industry stancarcs are ava'la:1e 'er trese type of MCCS trip adjustments except fo. gere,41 ra teaaa:e aac test'ng guicance. MCCB manufacturers c0 not ; etisn pr::e:.*es f:r wser's use.
Tre insee:ters noted that even though the field test equipment and ex'st* *;
test metnocs were aceavate to estaolish the basic function of breakers.- u c*: e: esta 11sn tne o*tginal Qualification tests performed by tne ma %-
facturer. Ve-in:at'Or tests to cetermine the functi:nal ca:a:i'ity :' a Ortate* t**:ugn Owt 'ts rarge of C eration reevires strict aCrerence 1:
a*.'a: ."er's : etaec test :* :ecures, shop crawings anc act a' se*vt:e c: : t':*s. % trer-: e, the 11:ensee did not pe-fort 49 evaluatica -t:
cete -'ae e i*:a:t on t"e WCCS cualification cue t; the cisassemo y; *eas-se :'y ::eratica anc tre a:p1' cation of_ lock-tite anc use of a heat gsn f:r tals tri: a :j u s t.? e n t .
The sas:ectors in: wired about the licensee's 10 CFR 50.59 review that justi'iec the reuse of a circuit breaker which has been unsealec and acjustec without the manufacturer's approval, anc industry guidelines, and which nas lost its UL a00roval due to disassembly of the MCCB. During this review, the licensee statec that they are in the process of performing a 10CFR 50.59 evaluation to determine whether any unreviewed safety question exists regarcing this activity.
So f ar, _ the licensee identified ten breakers which had been adjusted, The inseectors reviewed test data for two of the breakers (1821613 and 1823753) which were documented in Work Authorizations 522518 and $22520.
Tnese breakers were Westinghouse HFB type magnetic adjustable type breakers which have an external adjustment dial. The information regarding other breakers was not available during this inspection. The licensee stated that they had adjusted internal trip settings for these breakers, since the as-found trip. settings of each. pole was different and the required set point woulc not be achieved with the external adjustment dial. The licensee.did not discuss these adjustments with the breaker vendor. The licanammJamtesehs; decision te cettect the settings by opesing the sealed assagecmerseen!esquiers and performing heternal trip aWersteents using
pescedure MT-E-008. The as-left set points for these breakers meet the recuirements mentioned in procedure MT-GE-008 and i
manufacturer's time / current curve.
hd inspector noted that the licensee is not testing these breakers in the minimum and maximum position of magnetic set-point dial and returning the l trip setting to the as-found position prior to-installation. The licensee's practice of testing these. breakers is not consistent with industry standards l= NEMA AB-1 and UL489. The inspectors observed that these breakers were never tested after their original functional test dated July 1982 duelo the lack of a formal maintenance _. tut _ing_ program,_ -
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10 Su:secuent to the irs:e: tier, t*e safety evaluation report for MCB inte al tri: ac;ustseat using Protecare MT-GE-008 was provicec ey tre 14:e'see. TM s was t: cete mire wheirer the changes, as a result of tre
.::thcation, satisfiec the requirements celineatec in 10CFR 50.59.
e ':e see's sa'ety evaluati:n ces rites the precess by which interaal ra; e , : 1: ac;.st e-ts are c:ae to achieve tae set point specifiec ey eag'*ee***; cestgr :::.~erts. Tee licensee's report stated that ta e
- *te**a' ac; st?e"t Or: ess has no af fe:t on e0wipment Qualificati0n arc tae :-::ess ::es e:t '*,O lve tae installati0n of new Componer'ts or rate *ia's. r:r c:as it 1*w0' ve tae re*0 val :f aay existing CO? Onect :"
- ate *ia' # :* t*e O*eate#- IPe ret,0*t further states tr.at the breakee *s
- est:re: 10 'ts C*ii?*al CC*#'ga"ation and verifie0 thrcagh the functt:Fa' test t: ass e sts :-::e creater c:eration. However, the inscectors e:te: t*at : e I'Ceesee ras not ConCvCtec ary cualification tasting or eval.at'0's t: Cete**'ae 1f the Oreat e"s satisfy the original breaker c.4: ',:att:a 5:e: 1'icat ons. Tne licensee's safety evaluation con:1cce:
t at ; e M 5 tr ; a:;.streat acc tests cie not involve an unreviewed sa'ety :.esti: .
Inis is an unresclvecitem :encing 1) licenste's completion of a 10 CFR .?-
50.59 evaluation; 2) ciscussion of the MCCB adjustments with the vendor y
-y' to icentity potential problem associated with this practice; 3) establish /
that tre Dreaker satisfies all original functional criteria anc; 4) #
4 re evaluation of tneir trip adjustment anc breaker maintenance test procecure to confirm the as-lef t MCCBs will function as intended with ]
periccic testing (C0-387/90-24-01; 50-388/90-24-01).
'.'. .C Liceasee's Attlers en Previous NRC Concerns 9
11.1 (0:ee) Unresolved Item (50-387/89-29-01 and 50-388/thl-32-01)
Tris item certains to the lack of adequate calculations to address tee availabla voltage of the equipment under reduced vol tage conci-tiens anc also during design bases events. This issue was originally icentified curing NRC inspection 90-200, During this inspection, the inspectors noted that the licensee had submitted a technical specift-cation amen 5 ment request No. 89 to address the undervoltage issue.
This request is being reviewed by the NRC Office of Nuclear Reactor Regulation. The licensee stated that they are in the process of initiating modifications to the 120 VAC system to eliminate the voltage concern. This item remains open pending completion of the modification by the licensee, 11.2 (0:en) Unresolved Item (50-387/88-21-01 and 50-388/88-24-01)
During the NRC Appendix R inspection, the team observed that most of the discrepancies identified in the common power source concern analysis report SEA-EE-40 ~ w ere addressed except for few load center breakers. An additional concern was raised by the team regarding the lack of scheduled maintenance on circuit breakers at the 480V lead center level and below.
I
i Identification
- 387/90-24-01 Resolution /Results of Corrective Actions (Cont.)
The following is in response to the NRC's unresolved item with respect to internal adjustment of melded case circuit breakers (MCCB).
Electrical Maintenance has rnade the determin6 tion that they will no longer perform internal adjustments to MCCB's. As evidenced by the copy of PCAF 1 91-0326, procedure MT-GE-0C8 has been revised to eliminate all i procedural guidance on MCCB internal adjustments. Internal adjustment ,
activities are, therefore, permanent 1v suspended.
In licht of the above staterent! the following are resperses to the individual point raised in the NRC's UNR.
- 1) Licensees completion of a 10CFR50.59 evalcation: ' '
i Safety evaluatiun NL-90-040 was prepared and approved. Maintenance's " 4' position is that the safety evaluation is adequa'te for the 10_.sofety related breakers which were internall
..; iirograirrfoV~486 VAC~NCCBTiFiliTece and will ~y adjustedt, require testingThe breaker test of these L ', breakers on a periodic basis.
- 2) Discussions with the vendor:
Since the internal adjustment activities are permanently ,uspended these discussions will not occur.
- 3) Establish that the breaker satisfies all original funt ;al criteria:
Established by Safety Evaluation NL-090-040.
- 4) Reevaluation via periodic testing:
As indicated above Preventative Maintenance Improvement Package No. 020 f 480 VAC MCC provides the basis for 480 VAC MCCB periodic testing. The 3
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Note: Attached are copies of PCAF 1-91-0326 and Safety Evaluation NL-090-040.
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N_N, 1 16qe adi. HT-GE-008 Revision 8 Page 5 of 17 S.1 Breaker Setup 5.1.1 Remo.ve breaker from cubicle.
5.1.2 Document and determinate breaker leads (on Form MT-GE-008-4) prior to connecting breaker to test set (not required if performing SM-106-0XX or SM-206-0XX procedures).
5.1.3 Verify breaker " terminal mounting screws" are securely tightened (Reference Attachment E). '
5.2 Molded case circuit breakers - Magnetic Trip.
5.2.1 Determine and record "As Found" minimum trip current for eacn individual breaker pole.
NOTE: Allow sufficient time between successive tests on each breaker pole to allow for breaker internal cooldown.
5.2.2 Adjustable Breakers:
- a. External $djustment .
Adjust breaker, if necessary, to bring trip point within tolerance of value specified in setting data and retest breaker.
- b. Inisinel Adjweisent (if reagired)
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- b. -e- Record "As Left" minimum trip current.
5.2.3 Determine and Record "As Lef t" trip (operating) time of breaker at > 120% of set point value. Record actual test current applied.
NOTE: This value shall be > 150% of set point value for breakers,specified in SM-106-0XX or SM-206-0XX.
- a. If trip time " instantaneous" <.05 seconds then the magnetic setting is complete.
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Attachment A MT-GE-008 Revision 8 TEST RECORD Page 9 of 17 A C MCLCEO CASE BREAKERS. MOTOR OVERLOA05 AND GROUND RELAYS Syst.# W.A.# EM# 0( ), non Q ( )
Breakers MFG. Type F.F. Print # Curve # Curve Date Breaker: Rating (amps.); Magnetic Set Point (4 :5.)
Adjustatie ( f rom) (amps.) (to) , (i :;.)
Overicac: No. Setting lia ti ng ( f r:m) (amps.) (to) (amos.)
Test amps .
Ground relay: Setting ( amps. )
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"AS FOUND" "AS LEFT" , k 5.2 WAGNETIC (5.2.1) (5.2.2.b) (5.2.3) lR PHASE MIN TRIP MIN. TRIP TRIP TEST TRIP CPER CURR. ( AMPS) CURR. ( AMPS) CURR. ( AMPS) TIME (SEC)
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90 H,I REY. PREFA ED ST/ REMIVEDST/ ! AFFRo b BTs/ PORC MTCv DATE DATE DATT
- This sign.1ture of the Responsible Supervisor indicates approval of tha safety evalustion and confires that interf aces with other disciplines. functional groupsi etc. have been considered and have been incorporated into the evaluation as necessary. The Responsible Supervisor must be designated on NDI-qA -9.1.1C .
A copy of the ACCEPTED Safety Evaluation aust be forwarded to the Licensing.
Group Supervisor.
15851 515ER25518 FCI-tW 9.1.1A ' '
NDI-QA-9.1.1A. Rev. $
Page 1 of 4 (4/90) MHHH y
SAFETY EVALVATION [h)L- 90-OL/C READ "!NSTRUCTIONS FOR COMPLETING NDI-QA-9.1.1A BEFORE ANSWERING EACH QUESTION I Systen/Pr ocedure/ Experiment identification. (Name and Number)
Adjustment of the magnetic trip element of 480 VAC Molded Case Circuit Breakers using internal adjustment screws.
II Description and Implications of Proposed Action.
A. Fully describe the action and its purpnse.
B. Identify all the components that will be affected.
C. List Safety Functions of affected components.
D. Describe potential effects on Safety Functions.
This safety evaluation describes the process by which internal adjustment screws are utilized to adjust the magnetic trip setpoint of 480 VAC Molded Case Circuit Breakers (MCCB).
A brief discussion of the subcomponents and structure of a MCCB is provided to clarify subsequent discussions.
A MCCB is comprised of five main subcomponents: the molded case, operating mechanism, arc extinguishers and contacts, trip elements, and terminal connectors. The purpose of the molded case is to provide an insulated housing to mount the remaining subcomponents. The molded case has two sections, the base and the cover. All remaining subcomponents are mounted in the base. The removable cover mounts onto the base. The operating mechanism provides a means to manually open or close the breaker. The arc extinguisher confines, divides and extinguishes the electrical arc drawn between the breaker contacts when the breaker interrupts current. The function of the terminal connectors is to connect the breaker to the source and load. The function of.the trip element is to trip the operating mechanism in the event of a prolonged overload or a short circuit current. The breakers covered by this evaluation utilize electromagnetic trip elements for short circuit protection, i
Magnetic trip action is achieved through the use of an electromagnet in series with the load current. Fault current passing through the breaker causes the electromagnet to attract the armature of the trip bar which in turn initiates an unlatching action, which causes the breaker contacts to open, ,
NOI-0A-9.1.1A, Rev. 5 Page 2 of 4 (4/90)
The magnetic trip element may be fixed or adjustable. Depending on the type of breaker, adjustable trip units can be adjusted with external adjusting screws or with internal adjusting screws. In both cases the adjustment varies the size of the air gap which proportionally varies the magnetic trip setting of the breaker.
A. Action and
Purpose:
Internal adjustments of the magnetic trip setpoint are perfomed in order to an to balance the tripspecified Engineering setpointvalue.
of any individual phase (or all three phases)
Any one breaker has a manufacturer's
$Ncified short circuit current operating range. No breaker is adjusted to a value cutside its specified range.
The ad.4vstrent process is perforced in the following manner:
- 1. Cover Pemoval -
The cover is secured to the base by four screws. These screws are withdrawn and the cever is removed from the base. The cover is not glued or adhered to the base, screw is epoxied. in these cases in some cases the head of one cover the epoxy is removed, by mechanical means, prior to withdrawing the screw.
- 2. Internal Adjustment -
Once the cover is removed the adjustment screws for the individual (phase) electromagnetic trip units are accessible. The adjustment screws are secured with thread fastener (Loc Tite). Prior to adjusting any one phase the adjustment screw is heated with a soldering (pencil) gun. Heat is applied only to the point where thread fastener is pliable enough to allow rotation of the adjustment screw.
The adjustment consists of rotating the adjustment screw which, through of mechanical the trip unit. linkage, either increases or decreases the air gap Once the final adjustment is made Loc-Tite #73-71 or equivalent is applied to the adjustirig screw.
- 3. Reinstall Cover -
After adjustment is complete the cover is reinstalled and secured with the four mounting screws. The screws are secured to a torque
of 12 in-lb. The molded case material is high impact, high tensile glass polyester. Reinstalling the cover screws to a torque of 12 in-lbs is sufficient to ensure the cover will stay on.
4 As-left Testing - I Once the cover is secured an as-lef t magnetic trip current test is performed in accordance with MT-GE-008. The breaker 15 tested to l meet the trip setting specified by NPE. j 1
All the above activities are performed in the Electrical Maintenance Breaker Test area. This is a controlled shop environment area where all molded case breaker testing is conducted.
The activities are perforred by cualified rechanics who have been trained in circuit breaker theory, operation, and maintenance including the adjustment process noted above.
B. Affected Cnmponents The affected component is the molded case circuit breaker undergoing adjustment. The subcomponents affected are the cover and the magnetic trip unit (s). The cover is removed and reinstalled. The magnetic trip unit is adjusted, using vendor installed adjustment screws, to trip at a setpoint specified by NPE. No other breaker subcomponent is affected by the process described above.
C. Safety function -
, The cover has no safety function other than to shield the internal components from dust and dirt. The breaker as a whole is not environmentally or hermetically sealed, nor is the cover glued or sealed to the base.
The magnetic trip unit senses the short circuit fault current passing through the breaker. When the fault current reaches the magnitude to which the trip unit is set the circuit breaker opens. This function is tested and verified as described above.
D. Potential Effects on Safety fune.tions - ,
As previously discussed the breaker undergoes an as-left electrical test '
.no prior-to affect installation in ~ the plant. 7The process does' nWinvolve"theThe.Jnternal _
on equipment qualification installation of new components or material nor does it involve the removal
of any existing component or raterial from the breaker. The breaker is restored to its original configuration once the adjustment process is complete.
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l III Does the proposed actica increase the prohbility cf occurrenco er the consegnances of an accident or malfunction of equipment important to safety, as previously evalustud in the 5AAf (Include specific reference to T5A1 asetions that ate applicable.)
.X TES~Y Provids a discussion of the basis and crit, aria used in arriving at the above conclusion.
FSAR Section 8.3.1.3.13 " Electrical Circuit Protection Systems" was reviewed. Section 8.3.1.3.13.f) addresses 480V Motor Control Center Protection. This section addresses the fact that molded-case circuit breakers are equipped with adjustable instantaneous magnetic trip functiens. The circuit breaker provides circuit protection such that fault isolation is secured with minimum circuit interruption. As indicated in section 11 after a breaker has been adjusted it is tested, in accordance with MT-GE-008, to verify the protective device calibration, setpoint, and correct operation. This activity. therefore.
does not increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety.
IV Does the proposed action create a possibility for an accident or s.alfunction of a dif ferent type than any evaluated previously in the SAA7 (Include ref erence to specific FSA1 sections applicable.)
. X YES NO Provide a discussion of the basis and criteria used in arriving at the above conclusion.
As indicated in sections 11 and lil above internal adjustments are performed in a shop environment and the breakers are tested and verified to be operational at the specified setpoints prior to installation in the plant. The breaker is not physically modified during performance of the activity. The activity, therefore. does not create a possibility for an accident or malfunction of a different type than evaluated previously in the SAR.
NDI-% -9.1.1A. Rev. 5 Page 3 of 4 (4/90) 4
V Does the proposed actico reduce the entsia cf safety as defited ta th6 basis for any Tech:1eol Spegiticatioet (!nelude reforesca to specific Technical Specification sections that are applicable.)
. X YES NO Provide a discussica of the basis and criteria used in arriving at the above conclusion.
Technical Specifications (section 3/4.8.4 and it's attendent basis section) require that on1e ;5ose circuit breakers associated with primary containment penetration conductor overcurrent protective device are periodically surveilled to assure breaker reliability. These surveillances are conducted via the SM-106 and SM-206 series of surveillances. As this activity is complete and verified prior to breaker installation it has no affect on performance of or results obtained durina performance of the above surveillances.
The activitv. therefore does not reduce the nargin of safety as defined in ene bases for any Technical Specification.
'/ ! Oces the proposed action involve a change in a Technical Specification?
. X 113 NO If "TES". KDI-QA-3.2.1 " Technical Specification Changes" applies. A "YIS" answer does not preclude activity up to a point just before it would physically af f ect the functioning of the plaat.
Provide a discussion of the basis and criteria used in arriving at the above conclusion. If appropriate, describe the estent of activity and why it should be allowed to proceed prior to the Technical Specification change.
The activity described above does not challenge the ability of an adjusted breaker to perform / respond to a design basis event. Therefore.
a change to the Technical Specifi, cation is not required.
VII Does the preposed acties create the need to make an application for amendment to the license other than to Appendia Af I
TES 20 Provide a discussion of the . basis and criteria used La arriving at the above concluatos.
A review of license commitments,shows no need to make application for a license ammendment. ..
NDI-44-9.1. LA, Rev. S
Fase 4 et 4 (4/90) .
r.t L *
. , j l
USNRC l OPEN ITEM 387 / 90-24-01 l
SHI)JECQ During NRC inspection 90-02, a concern was raiuod regarding the use of maintenance procedure MT-GE-008, 480 Volt and Under Circuit '
Breaker High Current Testing. Specifically, the procedure allowed the disassembly and internal adjustment of molded caso circuit breaker trip units at SSES. The action of disassembly and performance of internal adjustments of molded case circuit breakers without specific vendor published instructions or guidance was l considered inappropriate.
DYliln'ilnD ,
During the subject inspection, the inspectors noted that SSES proceduro MT-GE-008 did not provide detailed information regarding the methods and actions required to properly disassemble, adjust and reassemble molded case circuit breakers. A concern was expressed that it may be possible to degrade the breaker through the practice of (1sassembly and internal adjustment. Finally, the inspector inquired about the licensee's 10CFR 50.59 review that justified the reuse of a cirmit breaker which had been unsealed and adjusted without the mtnufacturer's approval.
PP&L responded to the NRC concerns as described below.
- 1. The activity of making internal adjustments to molded case circuit breakers was suspended by initiating PCAP 1 0326, to MT-GE-008, which dpleted the option that formerly allowed internal adjustment of a molded case circuit breaker.
- 2. A Safety Evaluation was prepared to review the pertinent safety issues associated with the practice of disassembling, adjusting and reassembling molded case circuit breakers.
l l
l r
DXEin'IEW_CDEDNILElh .
During March 1992, NRC Inspectors performing a SALP review of SSES Engineering Activities, requested that System Engineering review i the maintenance history of the molded caso circuit breakers, described in the original action item, to determine if subsequent performance of circuit breaker overcurrent testing supports the conclusion that, circuit breakers which had been internally adjusted would continue to perform satisfactorily. Specifically, did those breakers, which were internally adjusted, subsequently meet manufacturers tolerances for overcurrent trip testing.
Additionally, the inspectors requested that System Engineering review and document our conclusion that the disassembly of tne molded case circuit breaker did not invalidate the environmental, seismic or any other qualification critoria related to the safety function of those breakers which had been internally adjusted.
BILS!!ONSit Two specific questions have been raised by the inspectors as described above.
O Did the history of circui t bronkor ovorcurront Losting, subsequent to tho suspension of the practico of internal breaker adjustment, support the conclusion that the naturo and
, oxtant of internal adjustment activities had no offact on tho critical charactoristics of the circuit breaker ?
O Did tho suspendod practico of disassembly of molded caso circuit breakers degrado the onvironmental, soismic or other qualifications important to safoty ?
A response to these questions is provided below.
- 1. As an example of previously adjusted - breakers, a detailed review of the . breaker calibration and testing history for 52-1B216092 & 52-1B246012 was performed to dotermine if adjustments made on these breakers revealed that there were subsequent problems meeting breaker overcurrent testing criteria.
These breakers are surveilled under SM-106-009 and SM-106-036.
Technical Specifications, Section 3/4.8.4 and it's attendant' basis section, require that those circuit breakers associated with primary containment penetration conductor overcurrent protective device are periodically surveilled to assure breaker reliability.
The surveillance records indicated the following:
1
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ItESPONSE CONTINUED:
a - Dreaka.r 52-1R2111H SM-106-009 - COMPLETED 8/10/90 - NO ADJUSTMENTS SM-106-009 - COMPLETED 10/28/87 - NO ADJUSTMENTS SM-106-009 - COMPLETED 5/21/85 - INTERNAL ADJUSTMENT Subsequent to the internal adjustments made in conjunction with the 5/21/85 Surveillance, the as-found overcurrent test of the breaker has been found to be acceptable.
- Dreaker 52-1D246011 SM-106-036 - COMPLETED 5/02/89 - NO ADJUSTMENTS SM-106-036 - COMPLETED 3/11/86 - NO ADJUSTMENTS WA-S22947 - COMPLETED 8/13/82 - INTERNAL ADJUSTMENT Subsequent to the internal adjustments made in conjunction with WA-S22947, the as-found overcurrent test of the breaker has been found to be acceptable.
Additionally, the Preventive Maintenance Improvement Project, Package No. 020, 480V Motor control Centers, was instituted in March of 1991. This Program compiles and monitors all preventive maintenance activities associated with the 480 VAC MCC's at SSES. The program tracks PP&L specific failure history for McC's and associated components. The current revision of the report indicates that no problems or replacements of the sample breakers have occurred.
In summary, the example of trouble-free calibration history of the selected breakers provides reasonable assurance-that; any breaker internally adjusted in the past, has not been degraded with respect to its overcurrent trip functions as a result of those adjustments.
-, - ~
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RESPONSE CONTINUED:
- 2. The uuspended practice of disassembly of molded case circuit breakers did not degrade the environmental, selsnic or other qualifications important to safety for the following reasons.
lio_1ded C_ase Circuit Dreake_r Dep_ign _ & Constijaction s A molded case circuit breaker is comprised of five main sub-components: the molded case, operating mechanism, arc -
extinguishers and contacts, trip elements, and terminal connectors. The purpose of the molded case is to provide an insulated housing to mount the remaining sub-components. The molded case has two sections, the base ,
and the cover. All remaining sub-components are mounted in the base. The removable cover mounts onto the base.
The operating mechanism provides a means to manually open or close the breaker. The arc extinguisher confines, divides and extinguishes the electrical arc drawn between the breaker contacts when the breaker interrupts current.
The function of the terminal connectors is to connect the breaker to the cource and load. The function of the trip element is to trip the operating mechanism in the event of a prolonged overload or a short circuit current. The breakers covered by this evaluation utilize electromagnetic trip elements for short circuit protection. Magnetic trip action is achieved through the use of an electromagnet in series with.the load current.
Fault current passing through the breaker causes the electromagnet to attract the armature of the trip bar which in turn initiates an unlatching action, which cances the breaker contacts to open. The magnetic trip element may be fixed or adjustable. Depending on the type .
of breaker, adjustable trip units can be adjusted with external adjusting screws or with internal adjusting screws. In both cases the adjustment varies the size of the air gap which proportionally varies the magnetic trip setting of the breaker.
Purpose of Internal Ad_fustments Internal adjustments of the' magnetic trip setpoint are performed in order to balance the-trip setpoint of any individual phase (or all three phases) to an Engineering specified value. Any one breaker has a manufacturer's specified short circuit current operating range. No breaker is adjusted to a value outside its specified range. .
l l
i y - - - , - -
IESPONSE CONTINUED:
Adju a ts.9n_t__EIof om The cover is secured to the base by four screws. These screws are withdrawn and the cover is removed from the base. The cover is not glued or adhered to the base. In some cases the head of one cover screw is covered with epoxy. In these cases the epoxy is removed, by acchanical means, prior to withdrawing the screw.
Once the cover is removed the adjustment screws for the individual (phase) electromagnetic trip units are accessible. The adjustment screws are secured with thread f astener (Loc-Tite) . Prior to adjusting any one phase the adjustment screw is heated with a soldering (pencil) gun.
Heat is applied only to the point where thread fastener is pliable enough to allow rotation of the adjustment screw . The adjustment consists of rotating the adjustment screw which, through mechanical linkage, either increases or decreases the air gap of the trip unit.Once the final adjustment is made Loc-Tite #73-71 or equivalent is applied to the adjusting screw.
Af ter adjustment is complete the cover is reinstalled and secured with the four mounting screws. The screws are secured to a torque of 12 in-lb. The molded case material is high impact, high tensile glass polyester.
Reinstalling the cover screws to a torque of 12 in-lbs is sufficient to ensure the cover will stay on.
Once the cover is secured an as-left magnetic _ trip current test is performed in accordance with MT-GE-008.
The breaker-is tested to meet the trip setting specified by NPE.
All the above activities are performed in the Electrical Maintenance Breaker Test area. This is a controlled shop environment area where all molded case breaker testing is conducted.
The activities are performed by qualified mechanics who have been trained in circuit breaker theory, operation, and maintenance including the adjustment process noted above.
As stated previously, the disassembly, internal adjustment and reassembly of molded case breakers is no longer practiced at SSES.
k.
RESPONSE CONTINUED:
qualifipatJpn_i_pafo_tv Issues The cover has no safety function other than to shield the internal components from dust and dirt. The breaker as a whole is not environnentally or hermetically scaled, nor is the cover glued or sealed to the base.
Westinghouse Application Data Sheet,29-160 A WE A, which is applicabic to the subject breakers, recommends a specific procedure for cover removal and replacement when internal inspections are required. The vendor recommendations were followed by MT-GE-008.
As previously discussed the breaker undergoes an as-left electrical test prior to installation in the plant. The removal and reinstallation of the cover has no affect on equipment qualification. The process does not involve the installation of new components or material nor does it involve the removal of any existing component or material from the breaker. The breaker is restored to its original configuration once the adjustment process is complete.
All activities associated with disassembly were performed in a controlled environment by qualified personnel. Test equipment and existing test methods were adequate to establish the basic function of breakers. The breaker is restored to its original configuration and the most critical characteristics of the breakers, namely; instantaneous and overcurrept ,
trip functions are functionally tested with appropriately calibrated test equipment by knowledgeable and well trained personnel. Breaker as-left operation is verified by actual current injection testing to assure proper operation for its intended safety function.
In summary, in our engineering judgement, the suspended practice of disassembly, adjustment, and reassembly of molded case circuit breakers did not degrade the environmental or seismic qualifications of the breakers which had been disassembled, nor did it degrpdp the safety.
function of the breakers which ha . been d sassembled in any
/ // , f 67/
k- -Prdparhd-Bf /[ Date
.E - ) * .i m/h
- x / ) em Reviewed By /. Date
4 NOV 151331 Uoc6et Nos. 50-387 50-388 Mr. Harold W. Keiser Senior Vice President - Nuclear Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
Dear Mr. Keiser:
Subject:
Combined Inspection Nos. 50-387/91-17 and 50-388/91-17 This letter refers to the inspection conducted by Mr. R. Mathew and Mr. R. Paolino of this office on August 5-9, 1991 and August 26 through September 5, 1991 at the Susquehanna Steam Electric Station and at the Corporate Office at Allentown, q t
Pennsylvania of activities authorized by NRC License Nos. NPF-14 and NPF-22. ?
The results of this inspection were discussed with Mr. A. Male and other members -
of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region ! Inspection Report which is enclosed with this letter and included your actions to resolve 16 previously identified concerns. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. Your corrective actions for 15 of 16 previously identified NRC concerns were found to be acceptable. However, one item pertaining to the degraded bus voltage set point study based on worst case relay drifting and other scenarios identified in your Engineering Discrepancy Report (EOR) G10091 remained unresolved. Your continued effort is required in the timely resolution of this issue.
We understand that you will perforta the necessary modifications, as committed by you, to resolve the previously identified items in this report. If our understanding of your actions regarding these matters is incorrect, notify '
this of fice as soon as possible.
Within the scope of this inspection, no violations were observed.
Your cooperation with us in this matter is appreciated.
Sincerely, Jacque P. Durr, Chief Engineering Branch Division of Reactor Safety
Enclosure:
Combined NRC Region 1 Inspection Report Nos. 50-387/91-17 and 50-388/91-17 0FFICIAL RECORD COPY CIR SUSQ 91 0001.0.0 11/12/91 k
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g,.._ .. - .. - - , - - - - - - - - - - - - - - - - - -
NOV 151931 Pennsylvania Power and Light Company 2 cc w/ encl: ,
A. R. Sabol, Manager, Nuclear Quality Assurance J. M. Kenny, Licensing-Group Supervisor H. C. Stanley, Superintendent of Plant-SSES R. G. Byram, Superintendent of Plant-SSES S. B. Ungerer, Manager, Joint Generation Projects Department J. D. Decker, Nuclear Services Manager, General Electric Co.
B. A. Snapp, Esquire, Assistant Corporate Counsel H. D. Woodeshick, Special Assistant to the President J. C. Tilton, !!!, Allegheny Electric Cooperative, Inc.
Public Document Room (POR) local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC) _
K. Abraham, PA0 (2) All Inspection Reports NRC Resident inspector Commonwealth of Pennsylvania bec w/ encl:
Region 1 Docket Room (with concurrencas)
Management Assistant, DRPA (w/o encl)
J. White, DRP R. Blough, ORP J. Trapp, DRS SALP Coordinator R. Lobel, E00 J. Raleigh, NRR C. Miller, PDI-2, NRR cf Q Rl:0RS .RI:0RS RI:0RS Matthew /cmm/lb Anderson Ourr
// -
10//$/91 10/2r/91 }e//5 /91 0FFICIAL RECORD COPY CIR SUSQ 91 0002.0.0 10/09/91
4 1
l U.S. NUCLEAR REGULATORY COMMISSION REGION 1 l
Report Nos. 50-387/91-17 50-3BE/91-12 NOV 151991 !
D.,chet Nos. 50-387 50-388 License Nos. NPF-14 RbV-22 Licensee: Pennsylvania Power & Light Company 2 North Ninth Street Allentewn, PennsyTvania 18101 Facility Na're: $_u,50uehanna Steam Electric Station, Units 1 and 2 Inspection At: Allentown, Pennsylvania and Berwic_k, Pennsylvania inspection Conducted: August 5-9,1991_ and Agust 26-September 6,1991 Inscettors: R. Mathew, Reactor Engineer, RI R. Paolino, Sr. Reactor Engineer, RI R. Skokowski, Reactor Engineer, R1 C
Prepared by: 1%Mko-Roy Mathew, Reactor Engineer, Electrical 10 /2 S / 9 /
da'te Section, Engineering Branch, DRS Approved by: h (
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C. J. Arberson, Chief. Electrical Section, date Engineering Branch, DRS Areas Inspected: Announced inspection by region personnel to review the status of previously identified open items and to determine the adequacy of the licensee's acticas to resolve them. This inspection also reviewed engineering activities related to the electrical system area to determine the effectiveness of engineering support for the piant.
~
2 Results: The inspectors cetertired that tne licensee's technical evaluations, correctiva a c
- i r.a t and design modifications were adeaut.te to resolve 15 of the -
16 previously identiffeo issues. However, some of the issues needed hardware s modifications in accordance with design change modification packages. The licensee has conmitted to complete the installation of these modifications as referenced in Section 1.0 of this report. One non-cited violation (NCV'; was identified pertaining to the lack of adequate review of cable tray overfills as specified by design drawing. One item remained unresolved pertaining to the adecuacy of the revised degraded bus voltage set points based on worst case relay drif ting and other scenarios identified in the licensee's Engineering Discrepancy Report No. EDR No. G10091. The inspectors determined that continued ef fort is required for the timely resolution of this issue. A review of recent EO related NCRs confirm that the licensee's discrepancy management program is _
working. The licensee has implemented an E0 binder upgrade program to identify deficiencies in the EQ program.
l
3 1.0 Status of Previously Identified items The purpose of this inspection was to review the status of previously identified items and to determine the adequacy of the licensee's corrective -
actions in resolvirg each issue.
1.1 { Closed) Violation No. 50-387/38B-90-17-01 pertaining to the unqualified polyurethane damper actuator seals of the ITT NH90 dampers for the Standby Gas Treatment Systems and the direct expansion switchgear room cooling system when the post-LOCA reactor building temperatures were changed by the licensee in 1989, by calculation No M-RAF-032, i The equipment that needed to be requalified was identified in the Equipment Qualification Index, This index contained a field which was intended to identify temperature for which the component was qualified. The entry in that field was incorrect and led to i erroneous conclusions on the qualification of the NH-90 a:tuators.
The licensee reported this deficiency in LER 90-016-00.
Immediate corrective action was taken to replace the polyurethane '
seals with Qualified Viton seals. The licensee determined that replacement of the seals results in the actuators being in a qualified configuration. The licensee reviewed EQ binders to assure that '
similar errors had not affected the qualification of other equipment.
Similar occurrences were identified, The affected equipment for these similar occurrences was evaluated and the information in the binders '
was found to support qualification. To preclude future similar occurrences, the licensee has issued instructions to limit the use of the data in the temperature field of the Equipment Qualification Index pending verification of the data. Personnel have been counselled regarding the use of qualified controlled data. >
This item is closed.
1.2 (Closed) Violation No. 50-387/388-90-17-02 pertaining to the licensees failure to promptly. report anc corract conditions adverse to quality. uicensee Procedure No. EPM-QA-122 requires prompt' identification and documentation of engineering discrepancies.
Licensee Procecure No OPS-5 also requires prompt reporting-and correction of conditions adverse to quality.
The_ licensee indicated that the violation resulted from engineering judgement on the level of certainty required prior to_ generating .
engineering discrepancy reports. To avoid further occurrences with respect to deficiency reporting, the licensee has procedurally lowered-the threshold at which engineering discrepancy reports are generated.
Engineering personnel received training on these procedural changes.
In addition, engineering personnel have been counselled on the importance of prompt reporting of conditions adverse to quality and the need to recognize and promptly document deficiencies through the engineering discrepancy reporting program or nonconformance. reporting program.
This item is closed.
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4 1.3 (Closed) Violation No. 50-387/388-90-17-03 pertaining to the licensee's latt of promet corrective actions for suspect limitorque EQ ceficiencies. NCR 88-0181, dated Parch 24, 1988, and NCR 88-0520, dated July 11, 1988, ,,ere not closed until November 15, 1990. The licensee indicated that this >iolation resulted from inadequnte orogrammatic controls. In their presentation to the NRC on October 26, 1990, the licensee had indicated that steps to ensure that timely corrective actions consistent with the potential safety significance of deficiercies had been taken. A copy of the analysis qualifying the 250 Vdc Limitorque Motor Operators for the full range of de system voltages including the peak system voltage of 288 vde was provided to the NRC at the October 26, 1990 meeting. The analysis resolved the Nonconformance Report Nos,88-181, 88-182,88-520 and 88-521.
Concurrent with the analysis, the licensee prepared new calculations (SE-B-NA-104) superseding the Bechtel calculation Nos.18-72, Revision 2 and 200-281, Revision 1, which were used as input to the analysis.
To prevent recurrence, the licensee has indicated that all safety significant issues will: 1) receive a prompt operability /reportability determination, and 2) develop an action plan and schedule for closure.
In addition, those issues confirmed to affect installed plant equipment will be reviewed by tne Plant Operations Review Committee (PORC) on a monthly basis and prior to any start up, The licensee's goal is~
closure of all safety significant deficiencies within one fuel cycle.
Based on a review, the actuators were determined to be environmentally qualified for 250 Vdc operation in their outside Containment application.
This item is closed.
1.4 (Closed) Unresolved item No. 50-387/353-90-17-04 pertaining to the licensee's commitment to provide the NkC with a plan and scheduled completion date for upgrading the EQ Binders in accordance with the PP&L EQ Binder prototype. The licensee has prepared an_EQ. Program Upgrade Project Plan, Revision 0, dated May 6, 1991. The plan issued via licensee document PL1-68381 providas the plan and schedule for upgrading all EQ Binders.
The scope of the EQ Program Upgrade Project includes:
= upgiace of 68 EQ Binders;
+ documentation of the basis for the EQ program and program requirements;
! -. collection of required data-to support binder upgrades; l
i
5 The completion target date for this activity is Decemoer 31, 1992.
This item is closed, i 5
. (~ Closed)UntesolvedItemNo. 50-387/385-90-200-04 regarding spare breaters in the 250/125 Vdc centrol centers and the 480V motor control centers that were left in the drawn-out position as a permanent arrargement. PP&L reviewed the generic implication of the NRC concern.
They determined that the only treakers being left cut in the open position were the spare circuit breakers on the buses.
The spare load -center circuit breakers were racked back into the bus during the EDSFI. PP&L performed a formal calculation (No. KC-C-JDV-150) to demonstrate the acceptability of racking out circuit breakers for maintenance. New check lists have been developed and issued for the 480 Vac, 125 Vdc and 250 Vdc systems to verify the normal circuit breaker racked in position.
This item is closed.
1.6 (Closed) Unresolved Item No. 50-387/382-90-200-09 regarcing diesel fuel oil storage tank level indicators and low level annunciators that are not continuously monitored as stated in FSAR Section 9-5.4.4 The licensee has been checking the five diesel fuel oil storage tanks level using the dip-stick method. Level was monitored monthly and follcwing each diesel start. However, using this current method for monitoring, a fuel oil leak between diesel starts would go undetected.
Since the EDSFI, PP&L has implerented a schedule that requires fuel oil storag: tank level checks every seven days by the dip-stick method pending the installation of new instruments that continuously monitor the tank level. PP&L has completed installation of new instrumentation for fuel oil storage tank level indication. Instrumentation for Tanks A through D was operational as of December 12, 1990. Tank E level i nstrumentation became operational on January 31, 1991. Meter i ndications were revised to read in percent per PCAF No. 91-0738 dated, August 9, 1991.
-r This item is closed.
1.7 [ Closed) Violation No. 50-337/388-90-200-12 regarding installed relay ,
(27A) f or _ wnich the drop-out setting was _ outside the manuf acturer's _ _ _ _ ,
setpoint range (36-45 Volts). During the EDSFI, the licensee presented _
calibration data and test documentation demonstrating that the installed i relay (27A) performed its function satisfactorily. Test recordslof this relay (27A) indicated the accuracy and repeatability, at the prescribed setpcInt, was comparable to other relays on-the other seven buses. In response to the NRC's concern, PP&L decided to replace the-i nstalled relay with one with an appropriate band of 18-30 Volts to p
envelope the required drop-out setpoint of 24 Volts.
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6 The EDSF1 report indicates this item is closed, however, to satisfy NRC concerns, PP&L perforned a walkdown of 46 relays in the 13.8LV, 480V load centers, and the 250 Vdc motor center for similar discrepancies. None were found.
This item is closed.
l.8 (Closec) V_iolation Nn. 50-387/388-90-200-13 regarding the use of an ac te$t current source to test dc circuit breakers. The adequacy of testing low voltage air circuit breakers used in de applications with an ac test current was not established. Preliminary tests performed by PP&L during the EDSFI inspection indicated significant time-current characteristics differences between the aC and de tests. In addition - _
the test procedure in use (MT-GE-006) did not provide specific information relative to testing de breakers. The licensee has revised-the procedure (MT-GE-006, revision 7) to clarify which forms, curves and setting change information are to be used when testing de breakers.
PP&L performed an evaluation (SEA-EE-271) to determine the acceptability of using an ac source to test de breakers. The evaluation concluded that using the ac source to test dc breakers was an acceptable method.
It was cetermined that no problems with either the protection or coordination would result from the application of a shift in the response curve.
The preliminary tests were followed by controlled tests that showed the de circuit breakers installed at Susquehanna will operate within the published time current characteristics curves when tested with ,
either at er dc curren_ts. The _ acceptance criteria for _pr__imary current testing of at breakers is dependent on: 1) long time, short time and-instantaneous pickups specified in the Relay Setting Change Notices -
(RSCN) for the particular breakar, and 2) that the setpoint is -
achievable within the band limits provided on the time / current curves supplied by the_ vendor. Not meeting either of these criteria renders the breaker unacceptable. PP&L procedure MT-GE-006 provides acceptance criteria by requiring entry of both curve numbers anti the RSCN information and the yes/no determination of acceptability by the reviewer.
This item is closed.
1.9_ (Closed)-Open_ Item No. 50-387/383-90-200-0_1 pertaining to the lack of calculation incex or other systen for controlling the use of n'on-valid or superseded calculations. As a result, three short circuit calculations were found to be in ef fect for assetsing the short circuit rating.of class IE sv.itchgear with different assumptions and-results. Furthermore, the emergency. diesel general-loading calculation did not-account for any cable losses.
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7 During this inspection, the inspectors noted that all previous (13 kv ene 4 kv) >hort circuit calculations have baen superseded by the new short circuit calculation, GP-23. lhe new calculation results showed that the 13 kv and 4 kv circuit breaker interrupting capability margins are 2% and 34 respectively.
The review of the emergency diesel generator loading calculation indicated that the cable losses had been accounted for in the loading.
study, The FSAR tables were reviseo to reflect this change, The inspectors noted that the licensee has a computerized tracking ,
mechanism to control calculations. No unacceptable conditions were noted during this review.
This item is closed.
1.10 (Closed) Unresolved Item No. 50-387/388-90-200-02 regarding the ,
emergency ciesel gentrator overload relay setting and drift. During the previous inspection, the team found that the overcurrent relay settings were not adequate for diesel generator E (set at 1054 above the maximum generator rating) and that all diesel overload relays exhibited excessive drifting. .
During this inspection, the inspectors noted that the overload alarm setting for the "E" emergency diesel generator (EDG) is set at 100%
of continuous rating instead of 105% of maximum generator rating as stated in the ED5F1 report. Furthermore, diesel generator "E" uses a more sensitive and accurate solid state "Near Full Load" definite time relay. The licensee's review of relay drifting indicated that the overload alarms on the four (A-D) emergency diesel generators were not correctly applied. Engineering Discrepancy Report. EDR00157 was issued by the licensee to address this issue. The inspectors reviewed design change packages DCPs 90-3083A,B,C, and D thatLreplaces "
the existing induction disk alarm relays with "Neer full load" solid state relays to obtain an accurato and reliable overload alarm. The design packages and associated safety evaluation were determined to be adequate to conclude that the modifications did not involve an unreviewed safety question. The licensee committed to install th'ese relays prior to startup following the fifth refueling and inspection outage for Unit 2. The existing alarm relays are considered acceptable by the licensee based on the fact that the EDG worst case loading is within the continuous rating of the machine, the loading is controlled by-sequence: timers and plant procedures and-the operators are' trained-and provided with specific guidance regarding the EDG design limits and overload ratings to prevent. overloading of EDGs. The inspectors determined that' the above actions are adequate to resolve this issue and no safety concerns exist regarcing this issue.
This item is closed. ,
1.11 (Closedl Open Item No. 50-387/368-90-200-03 This item pertains to the' acceptability of DC fuses at voltages higher than 250 Volts when the-batteries are subjected to float / equalize conditions.
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The inspectors reviewed design change packages DCPS 90-3084 and 90-3085 that replaces the existing undersired f"ses (250 Vde) in various de distribution panels with a minimum voltage rating of 300 Vdc. The design change packages addressed all the fuses that are affected by the over voltage conditions. The modification packages and associate safety evaluations were determined to be adequate to conclude that the modifications did not involve an unreviewed safety question. The ,
licensee has committed to implement these modifications for Unit 1 by i March 1992 and for Unit 2 by September 1992. The inspectors determined that the above actions are adequate to resolve this issue.
This item is closed.
1.12 [ Closed) Unresolved Item No. 50-387/388-90-200-11 pertaining to'the instrument drift and lack of trending of electrical distribution protective relays and timing relays. During the previous inspection, the team identified several relays and timers that were found to be out of calibration curing testing. These relays were reset to within
, acceptable range with no formal program to evaluate "as-found" data which was outside the tolerance band or to trend the instrument drif t.
During this inspection, the team reviewed the new program for trending ,
relays and the actions the licensee hdd taken if the relays were found out of tolerance during testing.
The inspectors also reviewed sample test data for the relays identified in the previous EDSFI report. The review inoicated that the relays were found to be within the acceptable tolerance band.
This item is closed.
1.13 (Closed) Unresolved Iten No. 50-387/388-90-200-10 Th's-item pertains '
to the adequacy of fire protection piping supports in the diesel generator building. .
During the previous EDSFl. the inspection team found that the physical installation of many pipe supports exceeded the allowable spans given in the original specification. Also, there is a potential. for impacting the uperation of EDGs if the fire suppression. system fails during a seismic event due to lack of seismic qualification of fire protection systems.
During this inspection, the inspectors reviewed calculation PLS-9235,-
EDRS G00154 and G00131 that provide resolution-to the-above--issues.
The review indicated that existing supports were adequate to withstand a seismic force. The inspector also reviewed calculation SEA-CE-014, which provided documentation to demonstrate that actuation _or rupture of fire suppression systems neither di. sable any safe shutdown systems - ,
nor impact the operation of diesel generators. ,
This item is closed.
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9 1.14 [Opoate) Unresolved Item No. 50-387/388-90-200-05 regarding the adequecy of the degraced grid relay setpoints.
During the EDSFI review, the NRC inspectors determined that the setpoints for the undervoltage relays to actuate under degraded grid conditions did not provide adequate protection for safe operation of all Class IE loads at the 480 Vac and 120 Vac voltage levels. However, there was a degraded voltage alarm at 96.5 percent of the rated voltage for the 4160 Vac buses and operator actions were specified to maintain adequate voltages to all loads. The licensee committed to submit a technical specification change request for raising the degraded grid ,
relay setpoints from 84 percent of rated bus voltage _ for the 4160 Vac buses to 93 percent. Following the EDSF1, the technical specification change request was approved and the licensee changed the degraded grid relay setpoint to 93 percent.
During the current inspection, the NRC inspectors reviewed the licensee's technical specification change request "Susquehanna SES Proposed Amendment No.136 to License No. NPF-14 and Proposed Amendment No. 89 to License No. NPF-22, Degraded Voltage Setpoints",
the low voltage response procedures AR-015-001 and AR-016-001, and the-Setpoint Change Packages E90-1041 and E90-1042. The technical specification change request was approved by NRR and revealed, that
- even with the degraded grid relay setpoint set at 93 percent, i f calibration error, relay drif t and potential transformer accuracy are-considered, the worst case degraded grid relay condition could be as low as 91.2 percent of rated voltage for 4160 Vac buses, The licensee has completed an evaluation to verify adequate voltage at the equipment terminals for the 4160 Vac and 120 Vac loads for the worst case condition. Based on the evaluation, no modifications were required on the 4160 Vac level. Moreover, the licensee has committed to-implement plant modifications to certain 120 Vac circuits, to assure adequate voltage. These modifications will be implemented prior to the next refueling outage. However, the licensee had not_ completed a similar evaluation for the 480 Vac loads. The inspectors reviewed a preliminary-calculation for the voltage available to the 480 Vac loads (except Motor Operated Valves), and through _ discussions with the licensee determined that two buses, 0B136 and 08146, have less than the minimum required voltage of 80 percent at'the motor terminals.
Although the terminal voltage for worst case degraded grid condition is less than the minimum required at the motor terminals for buses 08136 and 0B146,_ preliminary justification calculations based on the minimum required motor torque appear acceptable. .Also, the existing low voltage alarm response procedure ensures adequate administrative control to maintain the requirea voltage to all loads.
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The licensee's review of voltage to 480 Vec MOV loadt revealed that i for the worst csce condition, several motor operated ..lves (MOVS)
'. have less than 80 percent of rated voltage at the motor terminals.
The evaluation of these_ valves is documented in Engineering Discrepancy Report (EDR) G10010. Preliminary calculations determined that four Reactor Building Closed Cooling Outboard Isolatien Valves (HV-11313, HV-11314, HV-21313 and HV-21314) have inadequate vultage to operate-due to excessive voltage drop across the MOVs overload heaters if the 4160 Vac voltage is degraded to a rance of 94'.1 to 91.2 percent. The licensee's operability determination concluded that there is no operability issue based on the administrative controls in place. The inspectors noted that the existing 96.5% low voltage alarm and associated response ensures adequate voltage to the MOVs. In addition, for the MOVs in question, the licensee committed to replace the overload heaters with heaters of the same rating, but with a lower resistance. This modification will increase the voltage at the terminals of these MOVs providing adequate voltage and protection.
The inspectors noted that during the licensee's evaluation of the degraded grid and related relay setpoint determination, the licensee documented a number of electrical concerns in engineering ciscrepancy report No. EDR G10091. The licensee addressed some of the concerns by installing the low voltage alarm to identify degraded voltage conditions and subsequent degraded grid relay setpoint changes and technical specification amendment. Discussions with the licensee indicated that EDR G10091 is still being evaluated and t preliminary evaluation performed by the licensee indicated that tht are no impending safety issues.
The insr "
- also reviewed SEA No. EE-83001, Revision 2, dated Februar- a. 91, "Susquehanna SES Units 1&2 Voltage Study - Class IE
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Distribv.-;- Syitem" The model used for this study has only been updated to ceflatt the 1987 plant configuration,- and only evaluated four specific cates. However, the licensee is developing a new electric plant model to be used with the commercially available computer program CYME. This new program should allow for flexibility in the cases to be analyzed, and should allow the licensee to evaluate the electrical concerns identified in EDR G10091. The licensee has committed to complete the electric plant model and update the vcitage study to reflect the current plant configuration by June 1992.
This item remains open pending completion of the licensee's evaluation and the NRC review of the following: (1) the voltage at the terminals for the 480 Vac loads for the worst case condition of 91.2 percent; (2) resolution of the issues identified in EDRs'G10091 and G10010; i
and (3) the-modifications to establish adequate voltage at the 120 Vac level.
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11 1.15 (Closed) Unresolved item No. 50-387/388-90-200-07 regarding the capacity of the heat transfer equipment serviced by the emergency service water (ESW) system.
Due to excessive fouling of the heat transfer area in the_ESW system condenser, the fouling factor has been increased from .002 hr-ft2 -
'F/ BTU to .003 hr-f t .oF/
2 BTU. In addition, approximately five parcent of the tubes in the control structure chilled water (CSCW) system condenser are plugged, and four percent of the tubes in the direct expansion unit condenser for the Unit 2 emergency switchgear room (ESWGR) HVAC system are pluggved.
In response to the NRC concern, the licensee performed an evaluation _
of the CSCW system condenser to determine-if it is capable of providing adeouate cooling. This evaluation, EDR G00167 and associated calculation No, M-CAF-21 " Transient Temperature Response of Control Structure & Emergency Switchgear Rooms With HVAC", indicates that the capacity of the control structure chiller with a fouling factor of .003 hr-ft - 2F/ BTU and five percent of the condenser tubes plugged is approximately 184 Tons. This is down rated f rom the design capacity of 230 Tons. However, the evaluation concluded that the total heat load to the control structure chiller is less than 184 Tons, and the room temperatures would remain within the limits specified in the FSAR. As a result of the CSCW evaluation, it was determined that no evaluation is required for the less limiting ESWGR HVAC.
This item is closed.
1.16 (Closed) Unresolved Item No. 50-387/388-90-200-05 regarding the lack of overpressure protection for the ESW side of the diesel generator heat exchangers.
The plant has five diesel generators, four of which are aligned to Class IE buses while the fif th is on standby. The ESW system has sufficient capacity to provide cooling to only tour diesel generators at one time. Therefore, the isolation valves in the ESW line to the standby diesel generator are normally closed, which allows for a potential overpressure condition.
In response to the NRC concern, the licensee performed an evaluation of the ESW side of the diesel generator heat exchangers for possible overpressure conditions. The Iicensee determined that diesel generators A, E, C and D met the ASME requirements for. overpressure protection.
However, diesel generator E has the potential for overpressurization of the heat exchangers on the ESW side, as result of the isolation of-diesel generator E during A LOCA/ LOOP signal. The licensee has issued Design Change Package (DCP) 90-3088 to install a pressure relief valve for the ESW piping on the E Diesel generator side of the ESW isolation
12
-valves. The inspectors reviewed this DCP and associated calculations _
M-ESW-054. "E Diesel Overpressure Protection Calculation" and M-E5W-054
" Set pressure for PSV 01126E" and found them thorough and technically adequate. The licensee has committed to complete the installation of the modification by May 6,1992.
This item is closed.
2.0 Review of Engineering Activities Related to the Electrical System Area The inspectors reviewed licensee's organization, modification packages and work control process to determine the effectiveness of engineering support for the plant. The inspectors also reviewed the licensee's long term and-short term plans to improve the functionality of the electrical distribution system.
2.1 Agastat Relay Failures The inspectors reviewed the Engineering Discrepancy Report EOR No.
G0070 regarding seven agastat 'EGP' relay failures due to overheating in panel OC876A. The relays were used in non-safety applications and provide only annuncia+or functions. The licensee's preliminary evaluation -showed that the relay cover discoloration and embrittlement are due to the possible heat build up due to the existing mounting configuration. .The licensee stated that no additional failures or similar conditions are known to exist in any'SSES application.
However, further review and resolution of this EDR is in process.
The relays that were-found degraded were-replaced with new ones. ~
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inspectors noted that a reportably evaluation was in process during i
this inspection. The licensee is also trying to determine the generic ~
implication of this problem.
The inspectors reviewed EDR No. G10089 which identifies the discrepancy I in the environment and. dynamic qualification for!the continuously energized Agastat ECPI series relays. The Agastat qualification tests are established by Southwest Research Institute Report. The licensee's=
review of the report associated with the E0 binder update program, revealed that EGPI series relay tested f ailed to change state when energized during the seismic portion'of the qualification! test. These Agastats have a qualified life of 6 years. The licensee took prompt corrective action by replacing'the affected relays on May 17,1991'.
The licensee later determined that the qualification life of these.
relays was 4' years based on other qualification reports. The licensee's evaluation indicated that the relays were qualifiable for a design basis event at the time of removal =from the panels. The team noted that the licensee had not completed the reportabilty/ operability
-evaluation during the inspection. Subsequent to the inspection, the licensee completed the evaluation which indicated that there is no
- i. operacility/reportability concern. Further testing / analysis to' assure l the functionability of the relays and implications on all applications are being reviewed by the EOR group.
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The inspectors determined that the licensee has properly addressed the Agastat failures and appropriate :orrective actions are being taken in accordance with plant procedures.
2.2 Appendix R Compliance The in>pectors reviewed licensee's programs 1to maintain App. R compliance. The Fire Protection Review Report and-about one hundred safety analyses form the _ design basis for App. R compliance. Design Standard EDS-01 provides the requirements which are applied to cable routing, component modifications, and circuit modifications to ensure compliance with the requirements of 10 CFR50, Appendix R. Also, pP&L Specification E-1012 and Drawing E-49 provide guidelines for separation and raceway and cable details. The inspectors reviewed the licensee's App. R Cable Data Management System-( ARCDMS) in accordance with design drawing specification E-671. This computerized database was developed to maintain the Appendix R Safe-Shutdown data and the relationships necessary to perform the analysis.
The inspectors randomly selected a few App. R related cables and raceways to verify design information such as routing, fire zones, affected documents, and fire wrap requirements. No unacceptable conditions were noted during this review. Also, the inspectors-reviewed several modification packages to determine whether the modifications were performed without violating the Appendix R requirements. The modifications reviewed had properly considered Acpendix R requirements. The inspectors notad that several individual SEA's are needed to be reviewed to cetermine the impact of App. R for any modification.
The inspectors determined that even though the existing review process to determine App. R compliance is complex, the licensee is maintaining.
Appendix R compliance. The licensee stated that PP&L will develop a-comprehensive long term Appendix- R compliance plan by December 1991-to provide a better and more effective method of meeting-App. R requirements.
2.3 Electrical Separation The inspectors reviewed this area to determine-wnether the licensee has adequate procedures and documentations'to maintain electrical separation- for redundant class 1E systems. lThe ;
inspectors interviewed several engineers to determine their under--
standing of the electrical separation requirements. -Also,.several modifications were reviewed to determine whether -the modifications were performed with appropriate considerations for electrical .
separations. The review indicated that the modificationsiare performed with adequate design input to review the electrical separation area-and the design engineers are knowi ddgeable of the separation requirements. The-inspectors nttoo that the licensee has updated FSAR, Design Criteria, and separation specification E-1012 to reflect the recommendations and changes developed during the separation l evaluations and modifications performed by the licensee to date.
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14 2.4 Cable Tray and' Raceway Fill The licensee's need for a more ef ficient means of tracking cable and raceway configuration, and the need for verifying the justification calculations for all raceway filled beyond the 30 percent limit was identified in Quality Assurance (QA) Deficiency Report (DR)89-001. In response to OR 89-001, the licensee established a process which captures and controls changes to cable and raceway configuration. This process consists of the following three components:
(1) Bechtel EE553 database, reflecting the original cable and raceway configuration.
(2) CABRAC database, reflecting the as engineered cable and raceway configuration.
(3) CARTS sof tware, reflecting the current as built cable and raceway configuration, by calculating it from the Bechtel-EE553 and CABRAC data.
The inspectors reviewed the licensee's process for tracking cable and raceway configuration, and found it adequate.
DR 89-001 described the need to verify the justification calculations ~
for all raceway filled beyond 30 percent. The licensee stated that due to a large number of modifications to the cable and raceway configuration, and difficulties in updating the Bechtel EE553 database, there was a need to verify the existing raceway overfill justification calculations. In response to DR 89-001, the licensee has committed to analyze and document the acceptability of raceways that exceed 30 percent fill. This analysis will be completed by October 1991, and will evaluate mechanical loading for all raceway and the thermal loadir.; for power cable trays. The licensee has completed the analysis of raceway ~that exceed 35 percent fill. - The inspectors reviewed this study, E-AAA-634, " Cable Tray Fill Justification-Trays:'E1PH42,.E1PH43, -
ElPYO1, FIPYOl" and found it acceptable. . However,- during -thelreview of Drawing E-49, " Conduit & Cable Tray Notes & Details",.the--inspectors noted the Design Criteria 3.1.3.4 required particular types of ~ control:
cable trays having more than 25 percent fill'to be analyzed for-mechanical loading. Discussion with licensee-indicated that no formal analysis of these control cable trays has been completed, and the
-licensee immediately initiated a study to-perform the_ required analysis. The study revealed that two Non-Class.1E control cable trays, 2KTK13 and 2KTL13, exceeded the acceptance guidelines for mechanical loading. However, preliminary justification calculations' indicate that the. trays in question have adequate. structural support'.
This finaing would normally be classified as a Severity Level V violation. However, the violation is not being_ cited becauseithe-criteria specified in 10CFR 2, Appendix C, Section V.A. of the Enforcement Policy was satisfied. Specifically, this violation is a Severity Level V and the licensee _ initiated-prompt corrective actions prior to the end of the inspection. Therefore, this violation constitutes a non-cited violation. (50-387/91-17-01,50-388/91-17-01)
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l 15 The inspectors also reviewed the licensee's list of conduit fill and i found no examples nf evcrfill. The licensee stf ted that it ls PP&L's l practice not to install' overfilled conduit. In addition, cables are !
only added to existing conduits in special cases. l The inspectors had no further questions.
2.5 RCIC Inverter Replacement The licensee recently replaced DC to AC static inverters B218-K801A & B. These inverters supply power to the leak detection ambient and dif ferential: temperature switches for the Reactor Core Isolation Cooling (RCIC) system. The new inverters are electrically comparable to the original inverters, except the. original inverters were rated at 250VA, and the new inverters are rated at.
500VA. The inspectors reviewed the Design Input for design change package DCP 90-9074, " Inverter Replacement in Panel 2C614". The design irput was prepared and reviewed on February 7,1991, and approved on February 12, 1991 During the inspectors review, it was noted, that the Design input Checklist was initially marked with HVAC and Station Blackout as not applicable for requiring design considerations, However, these items were changed to applicable, on February 12, 1991, by the engineer preparing the design input. Discussions with the licensee revealec that due to the ecuipment involved-in the modi.fication, and the increased rating of the new inverter, Station ,
Blackout and HVAC considerations were applicable . The inspectors questioned as to why the correction was made five days af ter the cesign input was reviewed. Based on the_ reviews of the controlling cocument for Design. inputs, epm-QA-208, and discussions with the licensee, it was determined that this correction was performed within the licensee's procedures. The NRC insper. tors found the design input 1 review process to be acceptable. Review of the DCP 90-9074, " Inverter Replacement in Panel 2C614" and associated safety evaluation found them thorough and technically adequate. In addition, the-licensee committed to prepare a document that further defines the duties of preparers, reviewers, verifiers,- and approvers. 'This document will be issued and training will be conducted by December 1991.
The inspectors had no further questions.
2.6 Nuclear Engineering Organization As a result of the licensee's Organizational Effectiveness Review (GER), the Nuclear Plant Engineering _ Department is being reorganized to. improve plant engineering support. As of November 1991, the Nuclear Plant Engineering will be divided into three sections: (1) Systems-Engineering Group .to handle daily engineering activities; .(2)
Modifications Group to handle plant modifications; (3) Nuclear Technology' Group to handle long term engineering issues, including system analysis, modification and maintenance support, and the resolution of EDRs. This department reorganization is intended to increase the effectiveness of the Engineering Department by dedicating suf ficient resources for daily engineering activities, therefore, allowing resources to be dedicated to long term-engineering issues and modifications.
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16 2.7 Closecut of EQ-NCR's As presented to tne NRC at tne Maragement Meeting of October 26, 1990, the licensee has taken steps to ensure that future equipment cualification issues recei'." prompt uperability/reportability ceterminations followed by imely corrective action and closure consistent with the potential safety significance. As of September 20, 1990, there were 32 open items which documented ceficiencies associated with EQ. Twenty of these were closed as of December 21, 1990. The remaining 12 were closed prior to startup following the Unit 2 cutage in May 1991. A review of recent EQ related NCR's confirm that the licensee's program in discrepancy management is working. Issues confirmed to affect installed plant -
equipment were generally resolved within one month following identification and documentation. One item, NCR 91-104 (Unit 1), was written on March 21, 1991. Closure for this item occurred on August 3, 1991.
3.0 Exit Meeting Tne irspector met with licensee corporate personnel and licensee represertatives (cenoted i r. Attacnement 1) at the conclusion of the i r.s pe c t i c r on Septemoer 5, 1991. The inspector summarized the scope of the irspection and the inspection findings.
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i ATTACHMENT 1 .
a PERSONS CONTACTED Pennsylvania Power and Licht Company J. Agnew, EDMG Supervisor J. Akus, Project Engineer K. Backenstoe, Senior Project Engineer
- P. Brady, Project Engineer B. Brown, Nuclear Quality Assurance B. Brunner, Engineer, Engineering Science Applications Group
- G. Butler, Manager Nuclear Design i C. Coddington, Senior Project Engineer D. Filchner, Project Engineer
- J . Kenny, Licensing Group Supervisor M. Aben, EDMG Program Advisor
- G. Kuc:ynski, Technical Supervisor, SSES
- A. Male, Manager, Nuclear Plant Engineering
- G, Miller, Supervising Engineer D. Nudge, Project Engineer J. Rotne, Supervising Engineer J. Schleicher, Senior Project Engineer
- M. Simpson, Manager, Nuclear Tecnnology A. White, EDMG Project Engineer Denotes personnel present at the exit meeting on August 5, 1991 1
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