ML20134A845

Insp Repts 50-266/85-13 & 50-301/85-13 on 850722-26.Major Areas Inspected:Implementation of Program Per 10CFR50.49 for Establishing & Maintaining Qualification of Electric Equipment

ML20134A845
Person / Time
Site:	Point Beach
Issue date:	10/29/1985
From:	Wilson R, Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20134A841	List: ML20134A839 ML20134A845
References
50-266-85-13, 50-301-85-13, NUDOCS 8511110051
Download: ML20134A845 (15)

See also: IR 05000266/1985013

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Report No.: 50-266/85013; 50-301/85013

Docket No.: 50-266; 50-301

License No.: DPR-24; DPR-27

Licensee: Wisconsin Electric Power Company

231 W. Michigan Street

Milwaukee, Wisconsin 53201

Facility Name: Point Beach Nuclear Plant, Units 1 and 2

Inspection At: Milwaukee and Two Creeks, Wisconsin

Inspection Conducted: July 22 to 26, 1985

Inspector: 'O [

R. C. Wilson, Equipment Qualification & Test Engineer 'Date

Also participating in the inspection and contributing to the report were:

U. Potapovs, Chief Equipment Qualification Inspection Section, I&E

P. Shemanski, Senior Electrical Engineer, NRR

l R. O. Karsch, Reactor Engineer, NRR

1 E. H. Richards, Member of Technical Staff, Sandia National Laboratories

R. A. Borgen, Consultant Engineer, Idaho National Engineering Laboratory

M. J. Schaeffer, Reactor Inspector, RI

A. S. Gautam, Reactor Inspector, RIII

R. J. Smeenge, Reactor Inspector, RIII

Approved by: '

(6[d#[ffd

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Gdfy G. Zech, Chief, VendoNProgram Branch Date~

Office of Inspection and Enforcement

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8511110051 851101

PDR ADOCM 05000266 ,

G PDR '

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INSPECTION SUMARY:

Inspection on July 22 to 26, 1985 (Inspection Report No. 50-266/85013;

50-301/85013)

Areas Inspected: Special, announced inspection to review the licensee's imple-

mentation of a program per the requirements of 10 CFR 50.49 for establishing and

maintaining the qualification of electric equipment within the scope of 10 CFR

50.49. The inspection also included evaluations of the implementation of

equipment qualification (EQ) corrective action comitments made as a result of

deficiencies identified in the December 22, 1982, Safety Evaluation. Report (SER)

and the September 28, 1982, Franklin Research Center (FRC) Technical Evaluation

Report (TER). The inspection involved 260 inspector hours onsite.

Results: The inspection detemined that the licensee has implemented a program

to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed

below. No deficiencies were found in the licensee's implementation of corrective

action commitments made as a~ result of SER/TER identified deficiencies.

Name Report Paragraph Item Number

Potential Enforcement / Unresolved Items:

1. 10 CFR 50.49 Nonconfomance 50-266/85013-01 DRS ;

Resolution 4.A 50-301/85013-01 DRS

2. Foxboro Auxiliary Feedwater 50-266/85013-02 DRS

Flow Transmitters 4.A 50-266/85013-02 DRS

3. Rockbestos coaxial cable 4.D.(1) 50-266/85013-03 DRS ;

-50-301/85013-03 DRS

4. Limitorque de operators 4.D.(2) 50-266/85013-04 DRS ;

50-266/85013-04 DRS

Open Items:

1. Training Program 59-266/85013-05 DRS ;

Implementation 4.A.(2).c 50-301/85013-05 DRS

2. Master List Procedure 4.A.(3) 50-266/85013-06 DRS ;

Revision 50-301/85013-06 DRS

3. Maintenance Procedure 4.A.(4) 50-266/85013-07(DRS);

Completion 50-301/85013-07(DRS)

4. Limitorque 1-MS2020B 4.C 50-266/85013-08(DRS)

Conduit Separation

5. Rockbestos Firewall III 4.D.(3) 50-266/85013-09 DRS ;

control cable 50-301/85013-09 DRS

6. EQ Summary Sheet- 4.D.(4) 50-266/85013-10(DRS ;

Corrections 50-301/85013-10(DRS

7. Limitorque Operator 4.E 50-266/85013-11(DRS);

Inspection 50-301/85013-11(DRS)

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DETAILS

1. PERSONS CONTACTED:

1.1 Wisconsin Electric Power Company (WEPC) -

• C. W. Fay, Vice President, Nuclear Power

• R. K. Hanneman, Sr. Nuclear Engineer

• D. R. Blakely, Nuclear Safety Engineer

• J. Z. LaPlante, Nuclear Engineer

• M. J. Logan, Quality Engineer

• C. W. Krause, Sr. Licensing Engineer

• S. Miller Summer Student

• R. A. Newton, General Supt., Nuc. Sys. Engrg, and Analysis

• G. M. Kreiser, General Supt., QA

• R. J. Kohrt Safety Engineer

• E. J. Lipke, General Supt., Nuclear Plant Engrg.

• J. E. Knorr, Regulatory Engineer, PBNP

R. Heiden, Supt., Nuclear QA

W. Herrmann, Supt. Maint. and Constr.

N. Hoefert, Supt., I&C

R. Bruno Supt., Training

~1.2 Nuclear Regulatory Commission

• T. G. Colburn, NRR, Project Manager

R. Leemon, Resident Inspector

• Denotes those present at exit meeting in Milwaukee on July 26, 1985

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2. PURPOSE:

The purpose of this inspection was to review the licensee's implementation

j of the requirements of 10 CFR 50.49 and the implementation of comitted

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corrective actions for SER/TER identified deficiencies.

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3. BACKGROUND:

On October 13, 1983, the NRC held a meeting with WEPC officials to discuss

i WEPC's proposed methods to resolve the EQ deficiencies identified in the

December 22, 1982 SER and September 29, 1982 FRC TER. Discussions also

included WEPC's general methodology for compliance with 10 CFR 50.49 and

justification for continued operation for those equipment items for which

environmental qualification was not completed. The minutes of the meeting

and proposed method of resolution for each of the EQ deficiencies were

documented in a November 23, 1983 submittal from the licensee. The TER

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and November 23 submittal were reviewed by the inspection team members

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and were used to establish a status baseline for the inspection.

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4. FINDINGS:

A. EQ Program Compliance with 10 CFR 50.49

i The NRC inspectors examined the licensee's program for estabitshing

. the qualification of electric equipment within the scope of 10 CFR

50.49. The program was evaluated by examination of the licensee's

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qualification documentation flies, review of procedures for

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controlling the licensee's EQ efforts, verification of the

, adequacy and accuracy of the licensee's 10 CFR 50.49 equipment list,

) and examination of the licensee's program for maintaining the

i qualified status of the covered electrical equipment.

l Based on the inspection findings, which are discussed in more detail

i below, the inspection team determined that the licensee has imple-

mented a program to meet the requirements of 10 CFR 50.49, although

i some deficiencies were identified.

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10 CFR 50.49 Noncompliance Resolution

During the entrance meetin the licensee identified to the NRC

inspectors a problem that nvolves the licensee's overall response to

the discovery in the plant of equipment that is not fully qualified.

! The problem involves Foxboro N-E10 auxiliary feedwater flow trans-

t mitters FT-4036 and FT-4037 in both units. These are equipment

within the scope of R.G.1.97 and paragraph (b)(3) of 10 CFR 50.49.

! As a result of a licensee internal QA audit, actual maintenance

records were compared with EQ Maintenance Requirements Sheets.

This review disclosed that, after transmitter calibration, the cover

i gaskets were not replaced and the covers were not torqued as required

for qualification. ThesiteissuedaNonconformanceReport(NCR)

dated April 11, 1985. Later in April it was determined that the

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transmitters (installed in 1981) were not qualified because they

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had not been fitted with Style "B" amplifiers.

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The Unit 1 transmitters were then corrected, but as of the NRC

inspection (July 22,1985) the Unit 2 transmitters were still

unmodified. On April 29 to May 21 the site initiated, but did not

complete approval of, a Maintenance Work Request to upgrade the

Unit 2 transmitters. On July 22 neadquarters engineering issued a

second NCR giving the following Unit 2 status: amplifiers' not

replaced, vendor contacted but parts delivery date not established,

another contact to be made July 29. The second NCR also provided the

first documented safety evaluation of this problem, and stated that

modification will be accomplished as soon as practicable after

acceptable parts are received and processed on site. Although the

incomplete MWR indicated that work could be accomplished during plant

operation, the licensee orally indicated that modification would

likely be accomplished during a planned outage in about November 1985.

The NCRs did not document any review for reportability under 10 CFR

50.72 or 50.73, nor did any procedure require such review. In this

regard the inspectors noted the following: (a) Site NCR fann EQR-22a

dated 04-84 provides for reportability action only for " Potential

10 CFR 21 Report;" (b) in fact site QA and regulatory engineers had

determined without documenting their review that the incident was not

reportable, although no procedure required such review nor provided

specific EQ-related guidance; and (c) a licensee committee (Intersection

Review Group) operating for more than a year had generically addressed

reportability review and on June 14, 1985 had reviewed a draf t procedure

promulgating a revised NCR form with a checkoff block for reportability.

This procedure was expected to be issued by September 1985.

The inspe tors reviewed the safety analysis in the July 22 NCR against

the criteria for Justification for Continued Operation in paragraph

(i) of 10 CFR 50.49. The analysis satisfied criterion (1) by

identifying five other instruments, all either qualified or located

in mild environment, that permit proper system operation. A statement

that the transmitters are expected to survive the accident environ-

ment (the only harsh parameters are radiation and humidity) based on

testing of the unmodified design for more severe conditions addresses

criterion (2). Criterion (4)concerningcompletionofthesafety

function does not apply except with respect to possibly misleading

the operator. However, criterion (3) concerns limited use of

administrative controls over equipment that has not been demonstrated

to be fully qualified, and criterion (5) concerns misleading the

operator as a result of equipment failure resultihg from the accident

environment. Even though the licensee pointed out that the transmitters

are category (b)(3) post-accident monitoring equipment not directly

required for safe shutdown, the licensee's internal safety analysis

should have fully considered paragraph (i) of 10 CFR 50.49.

The auxiliary feedwater flow transmitter deficiency includes both

procedural deficiencies under Appendix B to 10 CFR 50 and an EQ

deficiency under 10 CFR 50.49; these are addressed as two

Potential Enforcement / Unresolved Items as follows: 10 CFR 50.49

Noncompliance Resolution is Potential Enforcement / Unresolved item

50-266/85013-01; 50-301/85013-01 including lack of procedures

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requiring timely reportability review and evaluation, failure to

document reportability review, and lack of timely EQ evaluation

of failure consequences. Foxboro Auxiliary Feedwater Flow

Transmitters is Potential Enforcement / Unresolved Item 50-266/

85013-02; 50-301/85013-02 comprising failure to properly justify

continued operation with unqualified equipment.

(1) Qualification Files, General

The licensee's control and organization of EQ files begins with ,

the Nuclear Power Department QA Policy Manual. The EQ Master

List is included in the manual as Appendix H; equipment

identification, location, type of environment, and interfacing

equipment (suchascable)areshown. Part !!! of the QA Policy

Manual provides color-coded PalD drawings showing Master List

Equipment.

Each type of Master List equipment has a computer-based I

, Equipment Qualification Summary Sheet similar to an IEB

79-01B SCEW sheet but revised in format to show additional

information such as qualification level and approval

signature. Specification and qualification references

identified on the Sumary Sheets are included in the EQ

files. The references include calculations and analyses

prepared by the licensee as necessary to supplement other

information, together with reviewer coment forms. Finally,

EQ Maintenance Requirements Sheets are provided for all Master

List equipment, defining maintenance and surveillance require-

ments for preserving Qualification. Nuclear Engineering

. procedure 3.12(May20,1985), Environmental Equipment

Qualification, covers the entire program.

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The NRC inspectors examined summary sheets and files for 15

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equipment items, where an item is defined as a specific type of

a electrical equipment, designated by manufacturer and model,

which is representative of all identical equipment in a plant

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area exposed to the same environmental service conditions. The

items were selected in advance by the inspection team and

identified to the licensee during the entrance meeting. j

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The files adequately documented qualification of the equipment

except as described in paragraph 4.D below. The files were

auditaDie and with the few exceptions described in this report

were complete and accurate. No generic documentation

4 deficiencies were found.

(2) EQ Program procedures

The inspectors examined the implementation and adequacy of

corporate and site policies and procedures for establishing

and maintaining the environmental qualification of electrical

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,' equipment in compliance with the requirements of 10 CFR 50.49.

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The licensee's methods for establishing and maintaining the

environmental qualification of electrical equipment were

reviewed in the following documents:

Nuclear Engineering Administration Manual Section NE 3.12

May 20, 1985, Environmental Equipment Qualification'

NPD Quality Assurance Procedure Manual Rev. 2 dated

July 8, 1985

QP 3-1, Modification Requests

QP 4-1, Procurement of QA-Scope Goods and Services

QP 6-1, Control of NPD Procedures Manual

! Operating PBNP Administrative Control Policies and

Procedures Manual-PBNP 3.1.3, Maintenance Work Request

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NE 3.11, dated December 30, 1983, Purchasing Requisition

NE 3.13, dated April 30, 1984, Training

QP 3-5, Revision 0, dated February 15, 1985, Specification

j Preparation, Review and Approval

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QP 4-1, Revision 0, dated November 16, 1984, Procurement of

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QA Scope Goods and Services

QP 7-2, Revision 0, dated July 8, 1985, Receipt Inspection

of QA-Scope Materials and Equipment

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Quality Assurance Policy Manual:

Part I, Section 4, Revision 0, dated November 16, 1984,

1 Procurement Document Control

Part I, Section 7. Revision 0, dated November 16, 1984,

Control of Purchasing Materials, Equipment and Service

l Part II, Appendix H. Revision 0, dated November 16, 1984,

Environmental Qualified Electrical Equipment

Quality Assurance Instructions:

PB-8, Revision 1, dated January 7, 1985, General

l Requirements for Environmental Qualification of

Electrical Equipment

PB-8.1, Revision 1. dated January 7, 1985, Procurement

of Environmentally Qualified Electrical Equipment

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PB-8.2, Revision 1, dated January 7, 1985, Acceptance

of Environmentally Qualified Equipment

PB-8.3, Revision 1, dated January 7, 1985, Review of

Environmental Qualified Test Plan and Reports

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PBNP Maintenance I&C Callup Systems

The audit team was also given a presentation describing the

licensee's EQ program on July 22, 1985, during which requirements

and procedures in the above documents were discussed.

The inspectors reviewed the above licensee procedures for implement-

ation of the requirements of 10 CFR 50.49 including: definitions of

harsh and mild environments, equipment qualified life, service

i conditions, periodic testing, maintenance and surveillance. The

licensee's EQ program was also reviewed for requirements to establish,

evaluate and maintain auditable EQ documentation including EQ sumary

sheets, test reports, maintenance records and other supporting

documentation to justify equipment qua! fication; training of

personnel in the environmental qualifit: tion of equipment; control

of plant modifications such as installation of new and replacement

equipment; and provisions for updating replacement equipment to

10 CFR 50.49 criteria. The following observations were made:

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a. The licensee's program was found to identify and define

requirements for equipment in harsh environment through

l EQ lists and summary sheets. Mild and harsh environments

l were found clearly defined and differentiated. Engineering

, analysis and evaluation had been performed to establish

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environmental conditions. EQ documentation was found

auditable, with controls for evaluation and maintenance of

these documents.

b. Purchase orders reviewed were observed to be appropriately

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identified with EQ requirements. Receipt inspections for

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EQ equipment and qualification data packages were required

to be performed by the site QA/ Quality Control (QC)

organization. Accepted equipment was required to be stored

in a controlled area reserved for safety-related equipment.

The inspector reviewed WEPC QA audit report A-P-85-02, " Nuclear

Power Department Nuclear Environmental Qualification." This

audit was conducted during January 1985 and covered EQ

activities at both WEPC Corporate headouarters and the plant.

Findings and observations of the~ audit had identified incomplete

and inconsistent summary sheets, record maintenance problems, no

maintenance callup system in the I & C area, and lack of evidence

of the required documentation reviews. The inspectors observed

that ccrrective action initiated and completed as a result of the

findings and observations identified during this audit had

enhanced the licensee's EQ program.

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c. At the time of this inspection, a formal training program for

plant maintenance personnel had n3t yet been established. The

licensee's training department was in the process of obtaining

training requirement needs from the plant operation departments.

Subsequent to the inspection in a followup telecon with the

licensee's training department, the inspector was infbrmed that

training requirements had since been identified and a training

program was being prepared for plant personnel responsible for

maintaining environmental equipment qualification. During NRC

interviews of licensee QA and plant maintenance supervisory

. personnel, it was established that a consistent awareness existed

among personnel regarding special requirements applying to

environmentally qualified equipment within the scope of 10 CFR

50.49. Many of those interviewed had attended the Electric Power

Research Institute (EPRI) seminars on " Maintaining Equipment

Qualification." A future inspection will verify the licensee's

implementation of a formal training program. Training Program

Implementation constitutes an Open Item 50-266/85013-05; 50-301/

85013-05.

The licensee's EQ maintenance program is discussed separately

in section 4.A.(4) below.

(3) 10 CFR 50.49 List (EQ Master List)

The licensee is required to maintain an up-to-date list of

the equipment that must be qualified under 10 CFR 50.49.

This list is documented as Appendix H of the "NPD Quality

Assurance Policy Manual." Appendix H is entitled " Environmentally

Qualified Equipment" and dated November 16, 1984. Considered

'in the preparation of this list are environmental effects

resulting from all pustulated design-basis accidents documented

in Chapter 14 of the licensee's Final Safety Analysis Report,

technical specification limiting conditions of operation,

emergency procedures, piping and instrumentation diagrams, and

locations within the plant subject to a harsh post-accident

environment.

The EQ Master List was produced as detailed by PT 8.1.1,

j' " Methodology for Generation of the Master List of Electrical

Equipment Important to Safety at Point Beach Nuclear Plant

1 & 2 to be Environmentally Qualified" dated May 20, 1983.

The licensee's definition of n.11d and harsh environments

explained by NEPB-85-304 dated July 15, 1985 are considered

satisfactory.

Three procedures presently in place provide guidance' for main-

taining the accuracy and completeness of the EQ Master List.

These procedures are NE 3.12, QP 3-1, and QP 6-1, identified in

paragraph 4.A.(2) above.

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Discussions with licensee personnel revealed that they are aware

of the necessity for reviewing all modifications to the plant to

determine if they would result in changes to the EQ Master List.

However, the procedures now in place do not specifically require

this kind of review, nor do they assign responsibility to a

designated individual to assure that changes to the EQ Master

List resulting from a review of design modifications are in

fact incorporated into a revision. Consistent with applicable

QA provisions governing the control of design process and related

documents, these procedures should be upgraded to include

delegation of responsibility and authority to an appropriate

individual or department to assure adequate controls over the

accuracy and completeness of the EQ Master List. This area will

be reexamined in a future 'nspection. Master List Procedure

Revision constitutes Open . tem 50-266/85013-06; 50-301/85013-06.

Eight items were used as in audit sample to verify the complete-

ness of the current EQ Master List. In order to compile this

audit sample, a review was conducted of the following emergency

procedures and piping any instrumentation drawings (P& ids).

Emergency Procedures

E0P-0. Rev. O, 7/1/85, Reactor Trip or Safety Injection

E0P-0.1, Rev. O, 7/1/85, Reactor Trip Response

E0P-0.2, Rev. O, 7/1/85, Natural Circulation Cooldown

E0P-1, Rev. O, 7/1/85, Loss of Reactor or Secondary Coolant

P& ids

541F091, Sht 1, Rev. 4, Reactor Coolant System Engineering

Flow Diagran

584J741, Rev. 25, Chemical Volume Control System Engineering

Flow Diagram

541F092, Rev. 13, Sampling System Engineering Flow Diagram

110E017, Shts. 1, 2, & 3, Rev. 22, SI System Engineering

Flow Diagram (Unit 1)

110E035, Sht 1, Rev. 20, SI System Engineering Flow Diagram

(Unit 2)

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110E018, Rev. 20, Auxiliary Coolant System Engineering Flow

Diagram

M00700190110, M201&M2201, Units 1 & 2 Main and Reheat Steam

M00300090229, Auxiliary Feedwater System

The audit sample was selected to verify that those items required

to be on the list are in fact on the list. The sample also

included an item required for implementation of RG 1.97 (core

exit thermocouple extension cable). All sample items required

to be on the EQ Master List were in fact on the list. A

sample item not required to be on the EQ Master List was

questioned to test the thoroughness of the licensee's review;

the item was not on the list and a satisfactory explanation why

it was not on the list was provided. Based on this review the

licensee's EQ Master List is considered satisfactory.

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(4) EQ Maintenance Program

Applicable program procedures are discussed in section 4.A.(2)

above. In addition, component-specific maintenance procedures

and records were examined, such as the following for Foxboro

N-E10 series transmitters:

Procedure NE 3.12, Figure 3.12-4, Equipment Qualification

Maintenance Requirement.

PBNP 6.8, Revision 0, dated July 5, 1985, Environmentally

Qualified Equipment Preventive Maintenance Callup File (I&C).

ICP 4.8 Major, Revision 4, dated December 28, 1984, Calibration

Procedure for Containment Pressure Transmitters, Data Sheet 7

(IPT968 & 2PT968).

ICP 5.35 Minor, Revision 1, dated May 4, 1984, Calibration

Procedure for Condensate Storage Tank Level and Service

Water Header Pressure Transmitters, Data Sheet 1 (ILT-4038).

Foxboro Master Instruction MI 020-164, December 1981 for NE-13

differential pressure transmitters (lists vendor maintenance

requirements).

Interviews conducted with plant QA management and engineers,

and the station maintenance supervisors of I&C, electrical and

mechanical equipment revealed that Equipment Qualifice. tion

Maintenance Requirements (EQMR) forms base been provided for

each piece of EQ equipment and were being used by the station

personnel to maintain equipment qualification. Plant personnel

were in the process of preparing component-specific procedures

for maintenance and surveillance of the equipment, based on the

EQMRs. At the time of the inspection all of the required

instrumentation maintenance procedures were completed, but only

four procedures had been issued in the electrical / mechanical area.

However, where new EQ procedures were not yet in effect, mainte-

nance personnel were directly using the EQMRs; thus, the inspectors

found that the plant maintenance currently being performed did not

appear to compromise the environmental qualification of equipment.

Implementation of appropriate maintenance / surveillance procedures

for ell remaining EQ equipment will be verified in a future

inspection. Maintenance Procedure Completion constitutes Open

Item 50-266/85013-07; 50-301/85013-07.

8. SER/TER Commitments

The NRC inspectors evaluated the implementation of EQ corrective

action commitments made as a result of SER/TER-identified

deficiencies as stated in a licensee submittal dated November 23,

1983. This submittal states that all equipment on the 10 CFR 50.49

Master List is qualified except for certain equipment 'or which

Justifications for Continued Operation (JCO) were submitted. The

final SER, transmitted August 30, 1984, identified that certain

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equipment was still under JCO. A May 2, 1985 licensee letter stated

that the only equipment still needing schedule extension was Crosby

lift indicating switch assemblies (LISAs) and incore thermocouple

connectors. NRC letter dated July 17, 1985 extended the qualification

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deadline for these items until November 30, 1985. In addition, the

licensee stated that the schedule to meet paragraph (b)(3) of

10 CFR 50.49 and for RG 1.97 equipment is identified in a separate

program for equipment not already included on the EQ Master List.

Based on review of files and of the 10 CFR 50.49 Master List, the

NRC inspectors identified no deficiencies in the implementation of

SER/TER commitments. Ongoing review of RG 1.97 implementation may result

in additional equipment being added to the Master List.

C. Plant Physical Inspection

The NRC inspectors, with component accessibility input from licensee

personnel, established a list of approximately 15 components per unit

for physical inspection. All were accessible at the time of

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inspection, during plant operation, in both units. The inspectors

I examined characteristics such as mounting configuration, orientation,

! interfaces, model number, ambient environment, and physical condition.

l No concerns were identified during the physical inspection except for

the Open Item described below.

A three-inch long opening was observed in the electrical conduit

for Limitorque valve operator 1-MS2020B, exposing the electrical

l cable at that point. Although qualification of the Limitorque

l operator or the cable is not dependent on a closed conduit path,

the mechanical / physical protection provided by the conduit is

degraded by the gap. The licensee explained that conduits had

been opened to introduce flame-suppressant caterial, and that this

particular conduit had evidently not been reconnected properly.

The licensee committed to correct this discrepancy, and this

correction will be verified in a future inspection. Limitorque

1-MS2020B Conduit Separation constitutes Open Item 50-266/85013-08.

D. Detailed Review of Qualification Files

The NRC inspectors examined files and summary sheets for 15 selected

equipment items 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 tim'. the

l equipment has been demonstrated to be qualified, similarity of tested

equipment to that installed in the plant (e.g., insulation class,

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l 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

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replacement interval detemination, effects of decreases in insulation

resistance on equipment performance, adequacy of demonstrated accuracy,

evaluation of test anomalies, and applicability of EQ problems reported

in IE ins / Bulletins and their resolution.

During its review of the component files the inspection team identified

two Potential Enforcement / Unresolved Items and two Open Items, described

below. Generally, the files were found to be auditable and they fully

documented qualification of the plant equipment.

(1) Rockbestos coaxial cable, Master List No. 11.6.c - Qualification

to NUREG 0588 Cat. I was claimed based on a Rockbestos test report

questioned by IN 84-44. During the inspection the licensee

produced a General Atomic test report for unaged cable of the

proper type, and a Raychem test report covering aged non-coaxial

cable with the same jacket material. Section 2.3 (Category 1) of

NUREG 0588 requires that the same piece of equipment must be used

throughout the test sequence. The licensee did not provide an

analysis showing that this requirement can be waived; in fact, i

the aging behavior of coaxial cable is difficult to address

analytically. Rockbestos coaxial cable comprises Potential

Enforcement / Unresolved Item 50-266/85013-03; 50-301/85013-03.

(2) Limitorque de operators, MS-2019 and 2020, both units - The file

did not include evidence that these operators were type tested in

the same configuration as installed in the plant, with no credit

for sealing the cable entrance. During the inspection the licensee

contacted Limitorque and obtained assurance, to be documented in

followup correspondence, that the tested configuration did permit

unrestricted LOCA atmosphere entry through the cable entrance.

The licensee stated that he will add this documentation to the EQ

Summary Sheet and file. Limitorque de operators comprises

Potential Enforcement / Unresolved Item 50-266/85013-04;

85-301/85013-04.

(3) Rockbestos Firewall !!! control cable Master List No. 1.10.d -

Qualification to NUREG 0588 Cat. I was based on a Rockbestos test '

report known to be deficient for that level of qualification as

, defined in IE Information Notice 84-44. In respunding to IN 84-44

the licensee assembled a supplemental file, not referenced in the

EQ files, containing a Raychem test report and other material

apparently sufficient to establish qualification. This file was

shown to the inspectors by the licensee, who stated that he

believed qualification had already been established but he would

revise the EQ Summary Sheets and files to incorporate the additional

material. Con,iletion of EQ file revision will be verified in a

future inspection. Rockbestos Firewall III control cable comprises

Open Item 50-266/85013-09; 50-301/85013-09.

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(4) Three instances of discrepancies between EQ Sumary Sheets

and documentation files or installed equipment configurations

are combined into a single Open Item:

(a) ASCO solenoid valves SV466C and D, 476C and D, and

966C - First, EQ Summary Sheet notes stated that these

valves should be installed using sealed cable conduit

having a low point weep hole, but the installed conduit

configurations did not have low points (loops). When

questioned the licensee provided an acceptable rationale

for the absence of the low point loops: the valves are

de-energized at the beginning of the postulated accident

before their environment becomes harsh, and they never

require re-energization, so that a sealed cable entrance

is not required. Second, during the documentation review

the inspectors observed a licensee internal memo stating ,

that solenoid coils and ethylene propylene EPDM seals

should be replaced every four years. When questioned the

licensee stated that the memo was based on misinterpretation ,

of the aging analysis, and that in fact coil and seal

replacement would be determined by examination during

preventative maintenance as required on the EQ Maintenance

Requirement form.

(b) Exo-Sensor hydrogen analyzer - The EQ Sumary Sheet states

that the required post-DBE operating time is one year and

the qualification time is one month. Notes on the Sumary

Sheet state that the analyzer is in fact only required for

one month. The licensee was requested to re-review the

required operating time, which under RG 1.97 is plant

specific and determined by the licensee, and revise the

Sumary Sheet and files as necessary.

(c) Limitorque operators MS-2019 and 2020 - Two discrepancies

were noted. First, licensee EQ Ref.1 Appendix E should

also be referenced on the Sumary Sheet since it is the

basis for temperature qualification. Second, although the

40 year qualified life is not impacted, the temperature

listed for thermal aging calculation differs from the

actual operating temperature because of shunt coil

heating in the operator.

Correction of the appropriate documentation to remove these

discrepancies will be verified in a future inspection. EQ

Sumary Sheet Corrections constitutes Open Item 50-266/

85013-10; 50-301/85013-10.

E. IE Information Notices and Bulletins

The NRC inspectors reviewed and evaluated WEPC's activities related

to the review of EQ-related IE Information Notices / Bulletins. The

inspector's review included examination of WEPC's procedures and EQ L

documentation packages relative to 12 Infomation Notices and one

Bulletin. The procedures review detemined that WEPC does have a

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system for distributing, reviewing, and evaluating Information Notices /

! Bulletins relative to equipment within the scope of 10 CFR 50.49.

j During the review of individual component qualification files the NRC

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inspectors evaluated WEPC's actions with respect to Information

1 Notices /8ulletins. No concerns were identified during this review

except the Open Item described below. -

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IE Information Notice 83-72 dated October 28, 1983 notified licensees

of equipment qualification problems with several component types and

, stated that addressees were expected to review the information for

applicability to their facilities. Included in Information Notice '

83-72 as EQ Notice No. 24 is a description of Limitorque operator ,

qualification concerns reported for an NTOL facility in June,1982

,

involving terminal blocks, orientation, drain plugs, space heaters,

i and other items. To address these concerns, the licensee initiated

l a confirmatory equipment inspection. However, for maintenance purposes

! the Limitorque operators are divided into fiva groups, with one group

being addressed each year. .Thus only 20 percent of about 50 operators

had been inspected by July 1985, with inspection of the last group not

1 planned until 1989. This action is not as responsive as expected, and

, possible licensee acceleration' of the inspection program will be

(

reviewed in a future NRC inspection. Limitorque Operator Inspection

constitutes Open Item 50-266/85013-11; 50-301/85013-11.

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