ML20150E555

Notice of Violation from Insp on 881214-18.Violation Noted: Licensee Installed Commercial Grade Parts on Equipment Requiring Environ Qualification W/O Adequate Evaluation of Suitability for Use in safety-related Applications

ML20150E555
Person / Time
Site:	Grand Gulf
Issue date:	03/25/1988
From:	Herdt A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20150E552	List: ML20150E550 ML20150E555 ML20150E559
References
50-416-87-32, NUDOCS 8804010064
Download: ML20150E555 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION System Energy Resources, Inc. Docket No. 50-416 Grand Gulf License No. NPF-29 During the Nuclear Regulatory Commission (NRC) inspection conducted on December 14-18, 1987, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and. Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:

A. 10 CFR 50 Appendix B, Criterion III, Design Control, requires that measures be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. It also requires that measures be established for the selection and review for suitability of materials, parts, equipment and processes that are essential to the safety-related functions of structures, systems and components. 10 CFR 50.49 paragraphs (f) and (k), respectively, requires (1) that each item of electric equipment important to safety must be qualified by one of the methods delineated in this section or, (2) applicants for and holders of operating licenses 3re not required to requalify electric equipment important to safety in accordance with the provision of this section if the Comission has previously required qualification of that equipment in accordance with NUREG 0588, Interim Staff Position on Environmental Qualification of Safety-Related Electric Equipment.

Contrary to the above, at the time of the inspection, the licensee had installed commercial grade parts on equipment requiring environmental qualification without an adequate evaluation of their suitability for use in safety-related applications. Material Nonconformance Report No. 454-87 dated December 7, 1987, documents the use of the following commercial grade parts in EQ applications: ASCO Solenoid Valve; ASCO Solenoid Kits; and 0-Rings for ASCO Kits.

This is a Severity Level IV violation (Supplement I).

B. 10 CFR 50.49(f) states in part that each item of electric equipment important to safety must be qualified by testing of, or experience with, identical or similar equipment, and qualification shall include supporting analysis to show that the equipment to be qualified is acceptable.

Contrary to the above, at the time of the inspection and as far back as November 30, 1985, the Raychem splice on the hydrogen recombiners and other Raychem Splices were not in a configuration that was qualified by testing or analysis.

This is a Severity IV violation (Supplement 1).

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System Energy Resources, Inc. 2 Docket No. 50-416 Grand Gulf License No. NPF-29 C. 10 CFR 50.49(j) requires that a record of qualification be maintained in an auditable form to permit verification that each item of electric equipment important to safety (1) is qualified for its application; and (2) meets its specified performance requirements.

Contrary to the above, at the time of the inspection and as far back as November 30, 1985, there was no documentation in the licensee's files to show the qualification of Mobilux EP-2 grease.

This is a Severity Level IV violation (Supplement I).

D. 10 CFR 50.49(f) requires that each item of electric equipment important to safety must be qualified by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

Contrary to +he above, the SERI files did not adequately document qualification of several Limitorque valve operators in that the installed plant equipment was not in the same orientation or configuration as the qualified test specimen and deviations were not adequately evaluated as part of the qualification documentation. Specifically, orientation of the actuator on component 1E 30F0028 was such that the T-drain acted as a high point vent rather than a drain and there were no grease reliefs installed on actuators located inside the drywell.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, System Energy Resources, Inc. is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN: Documert Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC l

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System Energy Resources , Inc. 3 Docket No. 50-416 Grand Gulf License No. NPF-29 Resident Inspector, Grand Gulf, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Viciation" and should include [for each violation]: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.

FOR THE NUCLEAR REGULATORY C0ffilSSION hN Alan R. Herdt, Chief Engineering Branch Division of Reactor Safety tianta, Georgia Dated this jfatgday of '#h, )) 1988 l

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