ML20150E559

Insp Rept 50-416/87-32 on 871214-18.Violations Noted.Major Areas Inspected:Environ Qualification of Electrical Equipment,Implementation of 10CFR50.49 Requirements & Electrical Equipment within Scope of 10CFR50.49

ML20150E559
Person / Time
Site:	Grand Gulf
Issue date:	03/24/1988
From:	Conlon T, Ruff A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20150E552	List: ML20150E550 ML20150E555 ML20150E559
References
RTR-NUREG-0588, RTR-NUREG-588 50-416-87-32, NUDOCS 8804010067
Download: ML20150E559 (20)

See also: IR 05000416/1987032

Text

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g 4 Cfou UNITED STATES

NUCLEAR REGULATORY COMMISSION

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n REGION 11

g j 101 MARIETTA STREET, N.W-

• i ATLANTA, GEORGI A 30323

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Report No.: 50-416/87-32

Licensee: System Energy Resources, Inc.

Jackson, MS 39205

Docket No.: 50-416 License No.: NPF-29

Facility Name: Grand Gulf

Inspection Conducted: December 14-18, 1987

Inspectors: /2M. / [. -/ 8 -) M

A. Ruf f, tem Leader, RII / Date Signed

Team members and participating Inspectors:

S. Alexander, NRR

C. Smith, RII

C. Paulk, RII

B. Levis, RII

M. Trojovsky, Idaho National Engineering Laboratory (INEL)

L. Magleby, INEL

M. Jacobus, Sandia National Laboratories

ApprovedbyrTM

T. E. Conlon, Chief

'eWhe 3 2'l - N

Date Signed

Plant System Section

Division of Reactor Safety

SUMMARY

Scope: This special, announced inspection was in the area of Environmental

Qualification (EQ) of Electrical Equipment and included a review of System

Energy Resources, Inc's (SERI) implementation- of requirements of 10 CFR 50.49

for Grand Gulf Nuclear Station (GGNS) and an inspection of electrical equipment

within the scope of 10 CFR 50.49.

Environmental Qualification (EQ) for electrical equipment was initially

required to meet NUREG 0588 category II requirements.

The electrical equipment requiring environmental qualification at GGN; is

qualified to the requirements of NUREG 0588 Category I or Category II. The NRC

inspectors examined System Energy Resources, Inc. (SERI) program for

establishing the qualification of equipment within the scope of 10 CFR 50.49.

8804010067 880325

PDR ADOCK 05000416

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The program was evaluated by an examination of SERI's qualification

documentation files, review of procedures for controlling the EQ effort,'ind

verification of adequacy and accuracy of the program for maintaining the

qualified status of the applicable equipment at Grand Gulf.

Based on the inspection findings, which are discussed in the report, the

inspection team determined that SERI has implemented a program to mest the

requirements of 10 CFR 50.49 fo- Grand Gulf although some deficiencies were

identified.

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Results: Four violations were identified: (1) Commercial Grade Components

installed in EQ Equipment, Paragraph 12; (2) Limitorque MOV, T-Drains and

Grease Relief Valves, Paragraph 13.c.(2); (3) Raychem Heat Shrink Tubing in

Unqualified Configurations, Paragraph 13.c.(4) and 13.c.(10); and (4) Qualification

Package for Lubricants, Paragraph 13.c.(1).

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REPORT DETAILS

1. Persons Contacted <

Licensee Employees

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• Steve Bennett, Nuclear Licersing

• J. C. Cesare, Nuclear Licensing

• Ted H. Cloninger, Vice President - Engineering and Support

• James E. Cross, Site Director

• P. M. Different, Plant Licensing Engineer

• Joel P. Dimmette, Manager - Plant Maintenance

• Steve M. Feith, Director, Quality Programs

• Steven P. Hutchins, Principal Electrical Engineer

• Gerald B. Lantz, Nuclear Plant Engineering (NPE)/ Electrical

• Fred Lindsay, Plant Staff / Electrical

• Allen S. McCurdy, Manager - Plant Operations

• Dan Pace, Manager - Nuclear Design

• J. L. Robinson, Plant Licensing Support

• Fred W. Titus, Director Nuclear Plant Engineering

Other licensee employees contacted included craftsmen, engineers,

technicians, operators, mechanics, security force members, and office

personnel.

Other Organization

• S. Pauly, Supervising Engineer, Impe11 Corporation

NRC Personnel and Resident Inspectors

• D. Verrelli, Chief, Reactor Project Branch No. 1, Region II

• U. Potapovs, Chief, Special Project Inspection Section, NRR

• H. Dance, Chief ProjectSection18,RegionII

• R. Butcher,SenlorResidentInspector

• J. Mathis, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on December 18, 1987,

with those persons indicated in Paragraph 1 above. The inspectors

described the areas inspected and discussed in detail the inspection

findings. No dissenting comments were received from the licensee. The

following new items were identified during this inspection:

a. Violation 50-416/87-32-01, Commercial Grade Components installed in

-fQ Equipment, Paragraph 12.

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b. Violation 50-416/87-32-02, Limitorque MOV, T Drains and Grease

Relief, Paragraph 13.c.(2).

c. Violation 50-416/87-32-06, Raychem Heat Shrink Tubing in Unqualified

Configuration, Paragraph 13.c.(4) and 13.c.(10).

d. Violation 50-416/87-32-04, Qualification Package for Lubricants,

Paragraph 13.c.(1).

e. Unresolved Item 50-416/87-32-05, Nylon Wire Crimped Connectors on (

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Limitorque Dual Voltage Motors, Paragraph 13.c.(2).

f. Unresolved Item 50-416/87-32-06, Accuracy Calculations for PAM

Instruments for Postulated Harsh Environments, Paragraph 13.c.(7).

g. Unresolved Item 50-47.6/87-32-07, Summary Test Reports for Terminal -

Blocks to Category 1 Requirements to be Upgraded, Paragraph 13.c.(8).

h. Unresolved Item 50-416/87-32-08, Seal Assembly for Victoreen

Radiation Monitor Connectors, Paragraph 13.c.(11). i

The licensee did identify some naterial as proprietary during this

inspection, but this material is not included in this inspection report.

3. Licensee Action on Previous Enforcement Matters

NRC's Unresolved Items 50-416/86-39-04 concerning wiring in Bettis and

Hiller actuators and 50-416/86-37-02 concerning Raychem splices are closed

with this report. These items are discussed in Paragraphs 13.c.(5) and

13.c.(10),respectively.

4. Unresolved Items '

Unresolved items are matters about which more information is required to

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determine whether they are acceptable or may involve violations or

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deviations. Four unresolved items identified during this inspection are

, diseussed in paragraphs 13.c.(2), 13.c.(7), 13.c.(8) and 13.c.(11).

5. Electrical Equipment Environmental Qualification Program and Procedure

Review

i The inspectors reviewed SERI/ Grand Gulf EQ Program directives to verify

establishment of an EQ Program in compliance with 10 CFR 50.49 including e

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the following:

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Engineering Standard (ES) .?l, Environmental Qualification Program.

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ES-19, Environmental Equipment Qualification Maintenance (includes

NUREG 0588/10 CFR 50.49 Equipment list and Maintenance / Surveillance

Requirements).

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ES-10, Installation Standard for Class 1E Equipment Environmental

Sealing.

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Nuclear Plant Engineering Administrative Procedure 803, Preparation

and Review of Environmental Qualification Documentation Packages.

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Nuclear Plant Engineering Administrative Procedure 804, Evaluation

and Control of Documents Affecting the Equipment Qualification

Control File.

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Maintenance Section Procedure 07-S-01-227, Equipment Qualification

Program.

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Administrative Procedure 01-S-09-1, Procurement of Material and

Services.

The above procedures along with procedures discussed elsewhere in the

report confirm that an EQ program has been established for Grand Gulf.

These procedures define the scope of the EQ Program and the responsi-

bilities of various organizations for implementing it. The procedures

assign the Nuclear Plant Engineering (NPE) staff the responsibility of

preparing and controlling the Equipment Qualification Central ciles and EQ

list of equipment in the Grand Gulf EQ program.

The Grand Gulf Safety Evaluation Report (SER) and Supplemental Safety

Evaluation Reports (SSERs) Nos. 2, 3, 4 and 5 and related licensee

submittals were reviewed. Exhibit 8 of Appendix H to SSER 2 listed

equipment items requiring additional information or corrective action for

final qualification. The inspector compared this to the current EQ Master

l List noting that equipment had been replaced and/or qualification

information provided as required. Exhibit C listed equipment that was to

be included in maintenance and replacement schedules and subject to

surveillance to ensure that excessive and or unpredicted age degradation

was not occurring. A program was in place for this equnpment. No

deficiencies were identified with resoect to Grand Gulf Nuclear Station

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(GGNS) meeting licensing and/or SSER commitments.

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6. EQ Maintenance Program

EQ maintenance requirements are developed by NPE and transmitted to the

plant staff via procedure ES-19. Maintenance Engineering uses ES-19 to

input EQ requirements into the Maintenance Planning and Scheduling System

(MPSS). Scheduling of EQ maintenance is done through the MPSS. MPSS Task

Cards schedule required maintenance before the end of qualified life.

Each qualified component with required EQ maintenance has a surveillance

or mandatory Preventive Maintenance (PM) action assigned to ensure

compliance with the maintenance requirements and time inter"als.

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SERI has established two EQ engineering groups on site. These are in NPE

and Maintenance Engineering. The two groups are working together and should

form the nucleus to ensure a well organized EQ program. Since EQ is an

ever evolving area, this organization appears to be staying even or ahead

of the issues.

One of the vendor test reports stated that in order to ensure the

continued qualification of its eaufpment, it is assteed that the vendor

recommended maintenance is being performed. This allows for the

possibility of maintenance being missed because'it was only recommended,

not required, because of the licensee's maintenance philosophy. No

instances of missing required maintenance were identified, however, the

licensee stated that it would evaluate the possibility in the future.

The licensee has been responsive to EQ maintenance problems. Material

Nonconformance Reports (MNCRs) were issued as far back as July 1983, more

than two years prior to the EQ rule taking effect. Since 1983, the

licensee has identified approximately 40 MNCRs related to EQ. Of this 40,

eight were written during walkdowns for Inspection and Enforcement

Information Notice (IEN) 86-03 for Limitorque wiring. Most of the MNCRs

were written for clarification of perceived problems. Four of the MNCRs,

however, were examples of failing to maintain equipment qualified. These

were MNCR-0252-086, Late Motor Lubrication; MNCR-0595-86, Incorrect

Solenoid Valve Installed; MNCR-0658-86, Unqualified Terminal Strip in MOV;

and MNCR-0864-86, Safety Relief Valve (SRV) Conner. tors. Each of these were

identified by the licensee and corrected. If thef had been identified by

NRC, they would be considered as four exam 31es of one Severity Level IV

violation. However, since (1) they were identified by the licensee;

(2) fit in Severity Level IV; (3) they were reported, if required;

(4) they have been corrected; and (5) they could not reasonably be expected

to have been prevented by corrective action from a previous violation, no

notice of violation will be issued for this in accordance with 10 CFR

Part 2, Appendix C, Paragraph V.a.

7. IE Information Notices (IENs) and Bulletins (IEBs)

The NRC Inspector reviewed and evaluated the licensee's actions for

EQ-related IENs and IEBs. The inspector's review included

examination of procedures and EQ documentation packages relative to

Information Notices and Bulletins. The procedure review resulted in the

determination that the licensee does have a system for distributing,

reviewing, and evaluating IENs and IEBs relative to equipment within

the scope of 10 CFR 50.49, and that pertinent IENs and IEBs are

addressed in appropriate component EQ files. During the review of

individual component qualification files, the inspectors did not identify

any concerns with respect to Information Notices and/or Bulletins.

8. Environmental Qualification Equipment 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 at GGNS is currently

controlled as Appendix A to Engineering Standard ES-19. The list was

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based on a review of the Final Safety Analysis Report (FSAR), Electrical

Diagrams and Mechanical P&ID's to identify the electrical equipment that

can be exposed to the postulated harsh environment of Design Basis

Accidents and that are required to function in those environments to reach

and maintain safe shutdown. Other equipment evaluated included certain

post accident monitoring (PAM) equipment as specified by R.G.1.97 and

nonsafety-related electrical equipment whose failure under postulated

harsh environmental conditions could prevent the satisfactory ,

accomplishment of safety functions. To aid in documenting the basis for

the Equipment List and to allow for future additions or deletions from the '

list, SERI is developing Shutdown Logic Diagrams (SLD's). The SLDs

identify the systems required to shutdown the plant following an

initiating event. From these SLD's, Safety Function Diagram (SFD) are

developed which gra)hically shows the actions of the individual safety

system from its in' tiation to completion of its safety function. All

active, essential system components and interfaces necessary for the

system to perform its safety functions are identified. To assess the

completeness of the NUREG 0588/10 CFR 50.49 list and to verify the

methodology used to develop the list, the Residual Heat Removal (RHR)

system was selected as the system for review. The following specific

documents were reviewed to determine the system components such as: Motor

Operated Valves (MOV's), Solenoid Valves (50V's), motors, and

instrumentation that are required to bring the plant to a safe shutdown

condition:

Drawing No M-1085B R32, P&I Diagram Residual Heat Removal System

Unit 1

• Drawing No. EQ-7124-097 R0, E12 RHR System Loop "A" LPCI Composite

Drawing No. EQ-7124-100 R0, E12 RHR System Loop "A" Suppression Pool

Cooling Composite

Drawing No. EQ-7124-102 R0, E12 RHR System Loop "A" Shutdown Cooling

Composite

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Drawing No. EQ-7124-104RO, E12 RHR System Loop "A" Containment Spray

Composite

All components that were identified as required to be on the Equipment

List were included on the Equipment List.

9. EQ Modification Program

Administrative Procedure, 01-5-16-1, "Plant Design Changes and

Modification", gives the requirements for initiation, control, review,

implementation and documentation of plant design changes to ensure quality

equivalent to that specified in the original design. Responsibilities of

the various site organizations involved in the plant design program and

the interfaces with offsite organizations have also been specified in

writing.

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Nuclear Plant Engineering (NPE) has been assigned responsibility for

preparation of Design Change Packages (DCPs) which define final design and

specify requirements for implementation of the change. The following NPE

administrative procedures were reviewed to assess the adequacy of the

licensee's control of EQ requirements in %e modification program:

Procedure No. 304, Design Change Packages, Revision 12; Procedure No, 323,

Design Inputs, Revision 1; Procedure No, 324, Design Verification,

Revision 0; Procedure No. 804, Evaluation and Control of Documents

Affecting the EQ Central File, Revision 3.

The above procedures specify that the Responsible Engineer (RE), during

preparation of the DCP, is required to incorporate all a3plicable codes

and standards as part of the design input. The requ rements of

10 CFR 50.49 although not specifically addressed are included by this

design control requirement. In addition to the above, the RE is required

to complete an Equipment Qualification Central File (EQCF) change review

questionnaire (Form 804.2) in accordance with Procedure Number 804. This

form documents the fact that the design change reviewed by the RE meets the

requirements of 10 CFR 50.49. Upon completion of this review, a request

may be made for review of the OCP by the Principal Electrical Engineer to

determine its impact on the Equipment Qualification Documentation Packages

(EQDP). Based on review of the program documents, it was determined that

the licensee's design controls provide for incorporation of environmental

qualification requirements in the design change program.

Five OCPs involving EQ related modifications were reviewed to verify the

adequacy of procedural compliance with the design change program.

Engineering requisitions associated with these DCPs for the procurement of

equipment / components were also reviewed to determine conformance with the

requirements of 10 CFR 50.49. No EQ related deficiencies were identified

in the DCPs reviewed.

10. EQ Equipment Replacement and Spare Parts Procurement

Administrative Procedure, 01-S-09-1, "Procurement of Materials and

Services / Safety-Related," established measures necessary to assure that

applicable regulatory requirements, design bases, and other technical and

quality requirements are included for the procurement of material,

equipment, and services. Responsibilities for determining the safety

class, quality level, and identification of the design bases have been

assigned to the Materials Technical Supervisor and his staff. Materials

Section Procedure, 12-5-01-1, "Procurement Document Processing-Safety

Related," specifies the recuirements for evaluation and processing of

, procurement documents by Material Specialist. This procedure defines the

metnods to determine technical and quality requirements for materials and

services contracts.

As a result of the review of the above program documents, it was

determined that the requirements for procurement of equipment and

l component within the scope of 10 CFR 50.49 was not adequately addressed.

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Administrative controls for procurement of electrical equipment, modules,

or components which must be environmentally qualified in accordance with

10 CFR 50.49 were not addressed in the program documents. Specifically,

procedural requirements for procurement of new equ,ipment to be added to

the EQ Master List via design change; replacement-in-kind and spare parts

purchases; or upgraded purchase in accordance with 10 CFR 50.49(1) were

not specified in writing. Programmatic deficiencies involving dedication

of commercially procured material used in EQ application were also

identified.

Procurement documents for new equipment to be added to the EQ Master List,

and upgraded purchases are reviewed by engineering design personnel.

Nuclear Plant Engineering (NPE) Procedure 01-401, "Procurement of Material

Equipment and Services," establishes the requirement that for procurements

processed by NPE, an engineering review and completion of engineering

inspection checklist will be performed by NPE. The Materials Technical

Supervisor and his staff complete the procurement process in accoroance

with the controls delineated in Procedure 01-S-09-1,

i Discussions with the SERI's management regarding these identified

deficiencies revealed that they were aware of the procurement program

deficiencies. In preparation for the NRC EQ inspection, a review of the

EQ program procurement activities was performed by the licensee.

Deficiencies were identified both with procurement procedures and past

procurement activities. Discussions with SERI management regarding

corrective actions to be taken for the programmatic deficiencies were held

and the licenseee committed to revising the procuremen'. procedures to

include EQ requirements by March 17, 1988.

A, review of the most recent purchase order for eight equipment types

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within the scope of 10 CFR 50.49 was performed by the inspectors. NoEQ

, deficiencies were identified.

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Plant administrative Procedure 01-S-07-33, "

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Certification of Maintenance Section Personnel"Qualification

establishes training

requirements to ensure qualification and certification of maintenance

personnel. In discussions with the Nuclear Instructor Supervisor, it was

determined that specialized training in the requirements of the EQ Program

had been provided to maintenance personnel; i.e., Electrical,

Instrumentation and Control, and Planning. The licensee stated that the

engineering staff members from NPE had also been provided with this

training.

The following lesson plans developed for the environmental qualification

training were reviewed: EQ-101/ Revision 0, Background and Fundamentals;

EQ-102/ Revision 0, EQ Engineering for Maintenance Work Planning Group;

EQ-103/ Revision 0, EQ Surveillance / Maintenance for Maintenance Personnel.

Lesson Plan EQ-101, provided basic knowledge regarding the purpose of the

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EQ Program, EQ Regulatory History, and the division of responsibilities

and implementation of EQ requirements at Grand Gulf. The other lesson

plans covered and ensured that the environmental qualification status of

equipment was maintained as a result of work activities performed by the

Maintenance Work Planning Group and Maintenance personnel. Objective

evidence in the form of class attendance sheets were reviewed to verify

completion of EQ training of five NPE engineers, four Electrical

Maintenance personnel, four I&C Maintenance personnel, and five

Maintenance Work Planners.

It was determined that tra*ning in the requirements of the EQ program had

not been provided to the Material Technical Supervisor and his staff.

Discussions with this grous revealed that various aspects of the EQ

Program are covered by thei r training program, e.g. required reading of

applicable codes or standards. However, to better ensure an adequate

personnel-procedural interface for this group, it was considered that EQ

training at least equivalent to that provided other plant staff should be

given to the Material Specialist group. The Licensee was responsive to

this suggestion and committed to provide EQ training to the Material

Technical Supervisor and his staff at the next scheduled training session.

12. QA/EQ Interface

The Manager, Nuclear Site QA and his staff had performed audits of the EQ

Program to verify its compliance with 10 CFR 50.49, and applicable codes

and standards. Quality Assurance Audit Report No. MAR 85/0088, Unit 1 was

conducted during the period June 26 - July 19,1985, to verify the

adequacy of implementation of the EQ Program requirements. The NRC's

Information Notice 85-39 which identified concerns with the implementation

of 10 CFR 50.49 requirements at operating facilities, was used as a guide

l for this audit. Another audit of the EQ Program was conducted on

November 4-20, 1985. The scope of this audit included reviews of NPE

l Procedure ES-19 and associated documents, a review of maintenance section

! Procedure 07-5-01-227 and maintenance activities performed to maintain the

l qualified status of equipment. Both audits identified deficiencies for

which corrective actions were developed by licensee management.

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Discussions with licensee management concerning involvement of the QA

organization in the EQ Program revealed that the audit schedule did not

include audits of the EQ program. Instead, during the conduct of

scheduled audits, the elements of the EQ program that are contained within

the performance area being audited are examined. Based on discussions

with licensee QA organization personnel and review of objective evidence,

there appears to be adequate involvement of this quality organization in

the implementation of the EQ program.

In preparation for the NRC EQ inspection, the licensee conducted a review

of EQ program procurement activities. They identified programmatic

deficiencies which are discussed in paragraph 10, and inadequate

procurement practices that are discussed in the following parsgraph.

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Material Nonconformance Report (MNCR) No. 454-87 was written on

December 7, 1987, to document the procurement and installation of

commercial grade replacement parts in EQ equipment. Thescopeofthe

problem appears to be limited. This is based on the inspector s review of

the disposition of the MNCR by NPE of the various equipment types and

systems involved. It was determined that the root cause was poor

personnel procedural interface within the Material Specialist group in

that, (1) the procurement procedures were deficient and (2) the staff were

inadequately trained in the requirements of the EQ program. This

situation was made worse by a deficient dedication process for

commercially procured replacement parts which did not require an

engineering review by NPE. The use of commercial grade material in EQ

application is a design change and is subject to design control measures

delineated in ANSI N45.2.11-1974. In response to the inspector's

question concerning corrective actions taken to assure the continued EQ

status of installed equipment, licensee management stated: 0-Rings for

ASCO Kit #302-9296E (stock code GG 86164006) and Solenoids for ASCO Kit

1. 8321 AGE (stock code GG 85336008) were determined to be dispositioned as

"Rework". Qualified replacement parts have oeen ordered, and Maintenance

Work Orders (Rd0s) have been prepared for their installation. Upon

receipt of the ordered parts the Rd0s will be implemented and the removed

components will be forwarded to NPE for examination and if necessary

destructive tests. Additionally, items in the warehouse associated with

stock codes GG 86164006, GG 85336008, and GG 81106090 1.e. ASCO Solenoid

Valve #29701-5 have been dispositioned as "Reject", and will be scrapped

to prevent recurrence of installation.

At the time of the inspection, the environmental qualification status of

equipment having cpare or replacement parts associated with the above

stock codes was indeterminate. The above material nonconformance is

therefore classified as a licensee identified violation, in that

commercially procured spares and replacement parts were installed in EQ

equipment without an adequate dedication process. This is identified as

Violation 50-416/87-32-03, Use of and failure to Evaluate Commercial Grade

Parts for EQ Applications.

13. Environmental Qualification Documentation Packages and In-Plant Physical

Inspection

a. Environmental Qualification Documentation Packages (EQDP)

System Energy Resources's EQDP are prepared and controlled by the

Nuclear Plant Engineering Department. The packages included an

Equipment Evaluation Checklist, Aging and Radiation Calculation /

Analysis, Environmental Parameters, Test Reports, NRC IENs and IE8s

reconciliations, Vendor Notifications etc.

An EQDP is prepared for each specific type of qualified component

designated by manufacturer and model that are exposed to the same

environmental service conditions.

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The NRC inspectors examined 25 EQDPs for selected equipment types.

In addition to comparing plant service condition with test conditions

and verifying the bases for these conditions, the inspectors

selectively reviewed areas such as required post-accident operating

. time compared to the duration of time the equipment has been

demonstrated to be cualified, similarity of tested equipment to that

installed in the p' ant (e.g. , insulation class, materials of

components of the equipment, tested configuration compared to

installed configuration, and documentation of both), evaluation of

adequacy of test conditions, aging calculations for qualified life

and replacement interval determination, effects of decrease in

insulation resistance on equipment performance, adequacy of

demonstrated functional performances, evaluation of test anomalies,

and applicability of EQ problems reported in NRC IE Information

Notices and Bulletins and their resolutions. Most of the

comments / concerns with these EQDP were resolved or corrected before

the exit. Some of these comments / concerns and unresolved items are

discussed in Section c.

b. In-Plant Physical Inspection

The NRC inspection team physically inspected some 30 qualified

components and selected field run cables. The inspection team

examined characteristics such as mounting configurations,

orientation, interfaces, name plate data, ambient temperature,

moisture intrusion seals, splices, terminal blocks, internal wiring

and material condition.

c. Comments on EQOP and Plant Walkdown Items

(1) EQDP 15.1, Reliance Fan Motor - Review of this package indicated

that Chevron SRI-2 grease was to be used for the lubrication of

reliance fan motors with no substitution allowed. The licensee,

however, uses Mobilux EP-2. The licensee stated that it

procures all its lubricants from Mobil and that introduction of

the Chevron product would increase difficulties in control and

could possibly lead to misuse.

The licensee provided information to the inspectors, including a

German written test report for Mobil 011. The information was

considered to be adequate to show cualification, however, the

licensee did not have it in an aud' table form. The licensee

stated the EQ packages for lubricants not covered elsewhere

would be included as part of the Generic E0 package. This is

identified as Violation 50-416/87-32-04, Qualification Package

for Lubricants.

(2) EQDP 02.0, 02.1, 02.2, Limitorque Motor Operators - These files

contain documentation to support Limitorque actuators with

motors that have class B & H insulation and type RH insulation.

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The RH insulation MOV are located throughout the plant, both

inside and outside the drywell and containment. T1e cla:;s B & H

insulations are used on MOVs located outside the containment.

The files contained Grand Gulf Nuclear Station (GGNS) positions

on Limitorque EQ concerns some of which are: interfaces for

control, indication, and power cable; internal jumper wire;

required maintenance; resolutions to I&E Notices and Bulletins;

the use of nylon crimp connectors as found in motor leads of

dual voltage motors; and the use of grease reliefs.

In regard to interfaces of f! eld cable, the Licensee has

incorporated GE (File EQ01.1), Kulka (File EQ01.2), Curtis (File

EQ01.3), Marathon (File EQO1.4), Buchanan (File EQ01.5), or

Cinch-Jones (File EQ01.6) terminal boards. SERI was not using

the Limitorque reports as the principle documentation to support

qualification of these terminal boards.

Either AMP terminations, Scotch Tape splices or Raychem splices

were incorporated as terminations / connectors in the Licensees

Limitorque actuators.

Internal jumper wire of the MOVs is either Rockbestos Firewall

III (File EQ04.16), Raychem F18mtrol (File EQ04.8), or BIW

Bostrad (File EQG4.9) cable.

The only I&E Notice not addressed in the Licensees Limitorque

files was IEN 87-08, Degraded Motor Leads in Limitorque DC Motor

Operator. When this concern was brought to the attention of

Licensee personnel, documentation was presented that showed that

, the concerns of IEN 87-08 had been addressed but not added to

l

the files because no actuators with DC motors were installed at

GG.

SERI's position on the use of nylon crimp connectors on dual

voltage motors installed in Limitorque actuators is documented

in File EQ02.0, Volume 4, Tab L5. This section contained a ,

letter from Limitorque stating that the nylon crimp connectors

found in the actuators supplied to GGNS were the same or of

similar material to those tested in Limitorque Report 600376A.

Also contained in this section was an evaluation of Wyle

'

Laboratories scope testing performed on Thomas and Betts nylon crimp

> connectors for the Clinton Nuclear Generating Station. Because

GGNS connector were not specifically identified (nor could they

be verified by visual examination) the traceability problem

associated with these nylon crimp connectors, (see NRC

Inspection Report No. 99900100/07-01), is identified as an

Unresolved Item 50-416/87-32-05, Nylon Crimp Connector on

i limitorque Dual Voltage Motors. It should be noted that the

,

nylon insulated crimp connectors of the MOV located in the l

l

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12

drywell were replaced with qualified splices during this NRC

inspection.

Two other items of concern were identified during the walkdown

inspection of Limitorque motor operators. The orientation of

the motor on Component ID 1E30F0028 was such that the T-drains

could not function as a drain, and there were no grease reliefs

installed on the actuators located inside the drywell. Although

grease reliefs were installed on actuators during the course of

this onsite audit (where required), the analysis used to justify

the as found configuration of the affected actuators was found

to be unacceptable.

(a) NUREG 0588 Section 2.2(3) references Section 5.2 of IEEE

'

Standard 323-1971. Paragraph 5.2.3.7 of the IEEE Standard

require the orientation and mountings be considered in the

qualification of equipment. Paragraph 4.1.3 of the basic

Limitorque Qualification Report B0058 stated that the

mounting position chosen for qualification testing (motor

horizontal with the switch compartment vertical up) was

considered the worst possible condition because it allowed

for any condensate that collected in the unit to flow

through the motor to provide the most damaging effect on

'

its 11sulation system. Because the motor orientation of

1E30F002E was found to be in the vertical up position, the

"T" drains could not function as drains. No other

orovisions were incorporated on the actuator to allow for

water to drain in the event of moisture intrusion under

postulated accident conditions.

(b) Actuators were installed inside the drywell that did not

have grease reliefs. This is contrary to the information

provided in Paragraph 6.0, "Design Life", of the basic

i L'mitorque Qualification Report, B0058, dated January 11,

1980, Partgraph 6.0 stater that grease relief valves are

used to accommodated the extreme temperatures and 3ressures

of containment DBA environments. NUREG 0588 Sect <on 5.(1)

endorses requirements of IEEE Standards. IEEE Standards

382-1972, Section 2, and 323-1974, Section 6, require all

salient factors be shown to common between tile tested

i valve operator and installed valve operator and that

modifications to equipment items be evaluated to determine

'

their effect on qualification. 10 CFR 50.49(f)(2) allows

for supporting analysis to be used with testing of similar

equipment to establish qualification. The analysis found

'

in the licensees files did not adequately address the

concerns MrTected above.

,

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, 13

The above is identified as a violation of NUREG 0588 Section

5.(1)/10 CFR 50.49(j) and is identified as 50-416/87-32-02.

Similarity of Installed Equipment to The Test Sample was Not

Established in the Qualification Files. i

(3) EQDP 09.2, Thermocouples Model 27620s manufactured by

Thermoelectric - This file contained the qualification

documentation for 20 thermocouples, ten of which are used to

monitor the suppression pool water temperature, and the

containment and drywell air temperatures.

The only maintenance identified in the file was 0-ring

replacement every 11 to 12 years (11.89) on the thermocouples

located inside the drywell. This was based on the Arrhenius

Methodology with ambient conditions of 135 F.

During the walkdown portion of the inspection, one thermocouple

(T/C) head was considered to be loose so that the 0-ring seal

was questionable. The licensee stateo that the standard

practice for instrument technicians on re-c!osing the head

covers is to ensure a hand tight seal. The licensee

subsequently verified that the remaining T/Cs covers were

handtight (none were loose) so that the 0-ring sealing was

effective. The test report and the vendor's technical manual do

not provide a torquing requirement and pre-audit confirmation

with the vendor indicated that a handtight cover closure was

adequate to maintain a seal. The licensee determined and the

NRC inspector agreed that this single questionable item would

2 not affect the safe shutdown or operation of the plant. The

licensee committed to up grade the applicable procedures and/or

training guidance to assure that hand tight closure of these

covers is maintained in the future.

(4) Hydrogen Recombiner - During the walkdown of the hydrogen

recombiner, it was found that the terminations were made with

Raychem sp' ices in unqualified configuration. The s

i made with all leads connected together forming a 'V' plices

shape were

and a

single WCSF-N Raychem sleeve over the connection and cables. The

>

sleeve was shrunk around all the cables with the top being

, "sealed" in a manner that appeared to have been heated and

pinched together by hand. This configuration has not been

tested by Raychem and would allow moisture intrusion between the

cable leads where sealing was not adequate. Another problem

with this configuration was that the top end of the sleeve could

,

re-open whenever subjected to heat again. This splice

. configuration was not qualified for an accident environment with

high humidity and/or spray.

,= ..

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14

Prior to the NRC inspection team's arrival, walkdowns were being

performed by the licensee on various components identified by

previous inspections. The splices on the hydrogen recombiner

were characterized by the licensee as cosmetically"

unacceptable and work requests had been initiated to replace the

existing splices because of their appearance. The NRC inspector

determined that the effects of spray and high humidity was not

adequately evaluated. The licensee stated that there was no

sealing requirement for the splices in that the splices were

located in an enclosure. The inspector determined that the

enclosure was not moisture proof. At the exit, the licensee

stated that the splices would be replaced with qualified Raychem

kits. This replacement was completed under WO-E76966 and

WO-E76967 by December 31, 1987. This is identified as an

example of Violation 50-416/87-32-06, Raychem Heat Shrink Tubing

Installed in Unqualified Configuration.

(5) Bettis & Hiller Actuators - The inspector reviewed licensee

activities with regard to a previously reported problem

concerning

and the potential

Hiller actuators on air use of unqualified

operated wiring)with

valves (A0V's . This Bettis

was

identified in NRC Report No. 50-416/86-39 as Unresolved Item

50-416/86-39-04. As a result of IEN 86-53, which was received

by the licensee in July 1986, the licensee decided to initiate a

comprehensive review of their Raychem splices at their earliest

available opportunity, which occurred during their first

refueling outage in September 1986. During the course of their

inspection, the licensee identified 19 out of 99 valves that

contained unidentified wiring. The installation of this wire

was traced to a construction / maintenance activity in 1982. At

the time this wire was installed, GGNs' constructions standards,

purchase and procurement specifications required class IE wire

to be used in class IE applications. The unidentified wiring was

immediately replaced with known qualified and traceable wiring.

The wiring which was removed was categorized into eight different

wire types. A representative sample of each of the wire types

was sent off to a materials analysis firm to identify the

specific insulation materials used. Once the specific materials

were identified the licensee performed an analysis, documented

in calculation EC-Q111-87001, RO which demonstrates the wiring

had sufficient therms 1 and radiation withstand capability to

perform its function. Based on this calculation, the inspector

concluded that the wiring was qualifiable for its intended

application. The licensee also stated that none of the 19

valves were in the ECCS System and that all these valves would

have performed their safety (isolation) function within a minute

of the postulated harsh environment accident. Because this item

was licensee identified, would fit in the Severity Level Ik

category, had prompt corrective action taken and could not have

been reasonably expected to have been prevented by any

licensee's corrective action for a previous violation, no

citation will be issued in accordance with the guidelines of

10 CFR 2 Appendix C, Paragraph V. A. This Unresolved Item is

closed.

, " ,

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15

(6) Cable Identification and Traceabilitj t; Cable

EQDP - For the cable identification rr/'ew, eight

cable numbers were recorded during the walkdown.

The licensee demonstrated the ability to enter

his Electric Circuit Schedule (Computer Data Base ,

E553) with the cable number and identify the

Cable Code, the purchase order number, the ,

purchase order item number and the master list

number (Component identification number). For ,

one of the cable identification numbers selected,

cable from two vendors was used. The E553 file

correctly identified two purchase orders and the

item numbers for the cable.

With the cable code and cable identification number, the

Licensee demonstrated the ability to enter his Quality Tracking .

System data base and identify the reel number used at the site.  :

The licensee had a cross reference log that identified the

vendor reel numbers for the corresponding site reel numbers.

With the vendor reel number, the ld censee was able to retrieve

the receipt inspection to verify that the cable received was the

cable that was installed. The licensee provided the receipt ,

inspection form:, for the eight cables identified.

With the Purchase Order Number and the component identification '

number, the licensee demonstrated he could retrieve, from the

Purchase Order file, the identification of the manufacture and

.

the detailed description of the cable. With the component

i identification number, the licensee demonstrated he could enter

his ES-19 data base file and identify the Equipment

Qualification file that demonstrates qualification of the cable, j

'

(7) Review of Insulation Resistance (IR) effects on Loop Accuracy

- The inspector reviewed Calculation 0200-047-128, which

included analysis to determine the effects of reduced irs in  !

harsh environments on instrument accuracy. The calculations i

included analyses for transmitters, RTDs, and thermocouples and

i included consideration of terminal blocks, splices,  ;

>

penetrations, and cables as applicable for different circuits.

Terminal blocks are not used at GGNS in RTO or transmitter

circuits where a steam environment is postulated. The maximum )

error loss from IR was calculated and was considered acceptable

for the applications at GGNS. The Victoreen radiation monitor r

was also addressed in the file and the licensee was questioned

on the basis for input data and acceptance criteria. The

question was resolved by the licensee citing alternative test

i

data to meet the 20 megohm requirement of Victoreen. Also

i

included in this calculation was a position paper regarding i

l accuracy criteria for post-accident monitoring (PAM)

l instruments. This paper implied that RG 1.97 did not require

l

any accuracies for PAM instruments. The licensee position was

l

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16

based on their interpretation of RG 1.97, on the typical values

of locp error demonstrated for the PAM instruments contained

within the EQ documentation packages, on the actions of the

operator from the other indications and the trends of these

indications. The licensee committed to perform conservative

calculations on typical RG 1.97 variable loops to confirm

expected loop accuracies for operatcr response. Thir is

identified as Unresolved Item 50-416/87-32-06, Accuracy

Calculation for PAM Instruments for Postulated Harsh

Environments.

(8) Documentation to Support NUREG 0588 Category I - Sevcral of the

files reviewed to Category I requirements had test resorts which

were not considered to be in accordance with app 11 cable

documentation requirements, especially with regard to supporting

test data. NUREG 0588 Section 5.(1) references IEEE 323-1974.

The documentation requirements of IEEE 323-1974 include such

items as a) description of the test facility (test setup) and

instrumentation used including calibration records reference,

b) test data and accuracy, and c) supporting data. Supplement 2

to IEB 79-018 states that the staff will accept summary reports

if the licensee makes the determination that necessary

information and documentation is at an NSSS vendor's facility.

Further

auditable,these type of filesthroughout

and available must be maintained

plant life.current,

No

documentation was produced by the licensee to indicate that they

had audited more complete test records, no additional test

reports were referenced by the EQ files, and no records

indicated the existence of further test documentation. The

licensee files which were considered inadequate to support NUREG

0588, Category I requirements included the Cinch Jones terminal

blocks, and Marathon terminal blocks. The licensee stated that

this would re-examined for possible up grading of subject file.

This is Unresolved Item 50-416/87-32-07, Summary Test Reports

for Terminal Blocks to be Up-Graded to Category I Requirements.

(9) Raychem Stilan Cable (File #EQ04.13) - The Raychem Stilan Cable

File was reviewed briefly and it was considered deficient with

regard to Category I requirements. This cable is not presently

used for EQ qualified application. The licensee stated that it

would be removed from the EQ master Mst.

(10) Raychem Heat Shrink Tubing - At the time of t.h inspection, the

Raychem

rations were EQOP and a sampling

satisfactory except (inspection

for issue onof the

the installed configu-

Hydrogen

recombiner terminations discussed in paragraph 13.c(4) above).

The Senior Resident Inspector opened Unresolved Item

50-416/86-37-02 in his report of November 1986 on this item.

This report indicates that some Raychem configurations were

deficient.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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17

IEN 86-53, Improper Installation of Heat Shrinkable Tubing,

dated June 26, 1986, was received at the utility in the early

part of July. The first opportunity for inspection after

receipt of this IEN, was the refueling outage of September 5,

1986 to January 1987. At this time, the licensee performed a

routine walkdown inside containment for 10 CFR 50.49 equipment

and the IEN concerns. As a result, some non-standard raychem

heat shrink tubing installations were identified. The license

determined from their records that these non-standard

installations were not covered by existing GGNS test reports.

Being in an outage, the licensee replaced all non-standard

configurations as a conservative measure to insure that this

item would not impact restart.

The licensee stated that they performed additional analysis and

obtained additional test data to show that the non-standard

Raychem configuration would have remained operable in the event

of a DBA. (See SERI's Letter AECH-87/0045 of March 20, 1987 to

the NRC.) This unresolved item is closed and up-graded to a

violation identified as an example of 50-416/87-32-06 Ray

HeatShrinkTubingInstalledinUnqualifiedConfiguratIons. chem

(11) EQDP 14.1, Victoreen Radiation Monitor - The file for the

Victoreen radiation monitors for high-range containment

monitoring was reviewed. The qualification basis was

NUREG-0588, Category I. The test conditions enveloped the plant

profile and the accuracy of detector was properly addressed and

4 is discussed in paragraph 13.c.(7) above. The test specimen was

identical to the plant installed item except for installation.

This component was tested by Victoreen in a number of

configurations. After eight unsuccessful attempts, the cable,

and connector were sealed in stainless steel conduit from the

detector to the LOCA chamber penetration. This was the only

configuration that passed the LOCA test. The test report stated

that the intention was to seal the connector, but that the

proximity to the penetration made it convenient to seal up the

,

cable as well. At GGNS, the connector assemolies are contained

in a stainless steel (SS) box, connected to the detector housing

with sealed high pressure metal bellows flex conduit, and sealed

at the cable entrance points. During the walkdown inspection,

the NRC insaector requested that the access cover on the SS box

be removed 'n order to examine the splices. The GGNS technician

had no trouble loosening the approximately 7-inch diameter cover

cap and screwing it off of the 6-inch diameter threaded collar

on the front of the junction box. It was clear th?t the cap had

been only hand tight and also there was no gasket, or 0-ring or

other apparent sealing device fer the heavy, machined stainless

steel cap.

_ . _ _ _ . . -

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GGNS personnel contended that the cap was sealed because the

collar was in fact a large pipe nipple with NPT tapered threads.

They stated that their standard for sealing pipe thread was use

of thread sealant and "three full turns."

Based on the observation and physical removal of the SS cap, the

NRC inspector questioned whether a good moisture intrusion seal

existed via the SS cap. Itappearedthatonlyanantigalling

Neolube lubricant was used on the threads and 'three full turns"

for tightness of tapered pipe threads is considered to mean

three turns past the point of hand tight. This would require a

strap wrench to install or remove the SS cap. As a result of

further discussion between the NRC and licensee engineers, which

included possible sealing techniques for the cap, the licensee

agreed to do an additional analysis to support their position

and if necessary, to take additional measures to ensure that a

good moisture intrusion seal exists for the cap on the SS

connector assembly box. The licensee stated that this would be

accomplished before restart. This is identified Unresolved Item

50-416/87-32-08, Seal Assembly for Victoreen Radiation Monitor

Connectors.

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