ML20155D615
| ML20155D615 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/08/1986 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20155D594 | List: |
| References | |
| 50-293-85-35, IEB-79-01B, IEB-79-1B, NUDOCS 8604170377 | |
| Download: ML20155D615 (16) | |
See also: IR 05000293/1985035
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U.S.' NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
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Report No.:
50-293/85-35
Docket No.:
50-293
License No.:
Licensee:
Boston Edison Company
800 Boylston Street
Boston, Massachusetts 02199
Facility Name:
Pilgrim Nuclear Power Station Unit 1
Inspection At:
Braintree and Waterford, Massachusetts
Inspector:
M deE-
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R. C. Wilson, Equipment Qualification & Test Engineer
'Da te
Also participating in the inspection and contributing to the report were:
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U. Potapovs. Chief, Fquipment Qualification Inspection Section, IE
S. Alexander, Engineer, IE
R. G. LaGrange, Section Leader, NRR
E. H. Richards, Member of Technical Staff, Sandia National Laboratories
M. J. Jacobus, Member of Technical Staff, Sandia National Laboratories
M. Trojovsky, Consultant Engineer, Idaho National Engineering Laboratory
L. S. Cheung, Reactor Engineer, RI
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P. J. Schaeffer, Reactor Engineer, RI
J. P. Durr, Chief Engineering Branch, RI
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Approved by:
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4- E' U
U. Potapovs, Chief, Equi pment Qualification Section
Date
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Office of Inspection and
Enforcement
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INSPECTION SUMMARY
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Inspection on December 9 to 13,1985 (Inspection Report No. 50-293/85-35)
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Areas Inspected: Special, announced inspection to review the licensee's
implementation 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.
Results: The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49, except for certain deficiencies
listed below.
Report
Name
Paragraph
Item Number
Potential Enforcement / Unresolved Items:
1.
Barton 288A main steam flow switches
4.D(1)
50-293/85-35-1
2.
General Electric EB-25 terminal blocks 4.D(2)
50-293/85-35-2
Open Items:
3.
Documentation revisions
4.A
50-293/85-35-3
4.
Completion of maintenance procedures
4.B
50-293/85-35-4
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File corrections
4.D
50-293/85-35-5
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DETAILS
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1.
PERSONS CONTACTED:
1.1 Boston Edison Company (BECO)
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- W. D. Harrington, Senior Vice President, Nuclear
- J. E. Howard, Vice President, Nuclear Engrg. & QA
- A. L.-0xsen, Vice President, Operations
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- R. Velez, Project Manager, EQ
- R. N. Swanson, Manager, Nuclear Engineering Dept.
- R. V. Fairbank, Deputy Manager, NED
- T. A. Venkataraman, Pr. Licensing Engineer
- M. N. Brosee, Chief Maintenance Engineer
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- J. K. Keyes, Group Leader, Regulatory Affairs
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- S. Dasgupta, Group Leader, NED I&C
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- R. D. Andrew, Engineer, NED I&C
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- J. Pawlak, Group Leader, NED Power Systems
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- L. A. Perfetti, Engineer, NED Power Systems
- P. Antonopoulos, Group Leader, Nuclear Analysis
- J. F. Crowder, Senior Engineer, Compliance
- R. E. Grazio, Group Leader, Systems and Safety Analysis
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- F. Mogolesko, Engineer, Systems and Safety Analysis
- L. Mcdonald, Group Leader, PS&CC
- R. M. Sheets, Engineer, PS&CC
- A. V. Morisi, Assistant Director, Outage Management
- H. F. Brannan, Manager, QA
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- D. A. Mills, Group Leader, Construction Management
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- E. T. Graham, Group Leader, Compliance
- T.~ Ferris, Engineer, Licensing
- W. Stowe, Counsel
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- D. A. Whitney, Sr. Engineer, Methods Training and Compliance
- C. E. Bowman, Acting Group Leader, ERHS
- R. Sherry, Assistant Chief Maintenance Engineer
- R. M. Titcomb, Senior Engineer, QA
- S. Das Engineer, NED Power Systems
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- R. J. Orkin, Senior Engineer, QA
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D. A. Diotalevi, Senior Engineer, QA
J. C. Mattia, Group Leader, QA Audits
R. L. Stefan, Engineer, Outage Management
J. L. Jerz, Engineer, NED Civil / Structural
P. Karatzas, Senior Engineer, Radiological
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F. L. Sche 11enger Jr., Group Leader, Quality Engrg.
J. Gerety, Engineer, Systems & Safety Analysis
F. Famulari, Group Leader, Site Quality Control
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J. Irens, Engineer, Site Quality Control
J. Poorbaugh, Senior Engineer, Site QA
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P. J. Moraites, Engineer, I&C Maintenance
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M. Maguire, Engineer, Electrical Maintenance
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1.2 Consultants
- R. Bennett, Resident Engrg. Supervisor, Wyle Labs
- J. Gleason, NES Manager, Wyle Labs
- T. Brewington, BECO Program Manager, Wyle Labs
- J. W. Anderson, Sr. Nuclear Qual. Engr., Wyle Labs
- N. Eisenmann, BECO Resident Engineer, Cygna Energy Services
J. A. Voe1xen, Manager, Systems Engrg. Dept., Cygna Energy Services
U. Rieder, Sr. Engineer, Bechtel
- J. C. Waal, Consultant, J. C..Waal Engineering Co.
J. N. Hamawi, Radiation Consultant, Entech Engineering Inc.
1.3 NRC
- M. McBride, Pilgrim Resident Inspector
- Denotes those present at exit meeting in Braintree on December 13, 1985.
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2.
PURPOSE
The purpose of this inspection was to review the licensee's implementation
of a program to meet the requirements of 10 CFR 50.49.
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BACKGROUND
The NRC held a meeting with BECO on May 22, 1984 to discuss BEC0's
proposed methods to resolve the EQ deficiencies identified in the
April 13, 1983 Safety Evaluation Report and Janua*y 19, 1983 FRC TER.
Discussion also included BEC0's general methodology for compliance with
10 CFR 50.49 and justification for continued operation (JCO) 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 BEC0 submittals dated July 9,
August 3, and September 24, 1984 and January 21 and 29,1985. The final
SER transmitted March 26, 1985 identified that certain equipment was still
under JCO. At the time of the inspection no JCOs or extensions applied.
BEC0 did request oualification deadline extensions for five types of
equipment until February 8,1986, but the requested extensions were not
granted. All five equipment types were included in the review sample
selected for this inspection.
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FINDINGS
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The NRC inspectors examined the licensee's program for establishing the
qualification of electric equipment within the scope of 10 CFR 50.49.
The program was evaluated by examination of the licensee's qualification
documentation files, review of procedures for controlling the licensee's
EQ efforts, verification of adequacy and accuracy of the licensee's
10 CFR 50.49 equipment list, and examination of the licensee's program
for maintaining the cualified status of the covered electrical equipment.
Based on the inspection findings, which are discussed in more detail
below, the inspection team determined that the licensee has implemented
a program to meet the requirements of 10 CFR 50.49, although some
deficiencies were identified.
A.
EQ Program Procedures
The NRC inspectors reviewed the Pilgrim EQ program as defined in
Nuclear Operations Procedure NOP 84A9 dated November 29, 1985, which
establishes the recuirements of 10 CFR 50.49 and delegates
responsibility to various departments. The inspectors reviewed the
following Nuclear Engineering Department (NED) and Nuclear Operations
Department (N00) procedures and work instructions which establish
and implement the EQ documentation program:
NED Procedures:
2.01
Preparation, Issuance and Control of Department Procedures,
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Rev. 6 dated November 28, 1985
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2.02
Preparation, Review and Issuance of NED Work Instructions,
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Rev. I dated February 10, 1983
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3.02
Preparation, Review, Verification, Approval, and Revision
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of Design Documents for Plant Design Changes, Rev.14 dated
November 18, 1985
3.08
Specifications and Reports, Rev. 7 dated November 1,1985
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3.09
Design Review to Determine Conformance to Regulation
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3.11
Calculation Method for Determining Component Lifetime in
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Event of Excess Drywell Temperature
4.01
Procurement of Items and/or Services, Rev.10 dated April 4,
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1985
6.03
Maintaining the Environmental Qualification Master List,
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Rev. I dated November 29, 1985
17.02 Disposition of Quality Assurance Records and Departmental
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Correspondence, Rev. 4 dated November 26, 1985
20.01 Glossary Terms and Definitions
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NED Work Instructions:
NEDWI #271 Preparation of Environmental Qualification Master
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List, Rev. O dated March 8, 1983
NEDWI #277 Preparing Justifications for Continued Operations
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for Environnental Qualification, Pev. I dated May 6,
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NEDWI 8278 Preparing Equipment Qualification Evaluation Sheets.
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Rev. 2 dated July 19, 1985
NEDWI #279 Incorporating Environmental Qualification Requirements
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into Procurement Documents, Rev. O dated May 1, 1984
NEDWI 8280 Review of Vendor Test Reports and Qualification Reports
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for Environmental Qualification, Rev. I dated Pay 1,
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NEDWI #281 Performing Record Search /Walkdown Verification for.
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Environmental Qualification, Rev. O dated May 1, 1984
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NEDWI #284 Resolution of Outstanding Items, Rev. O dated May 1,
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1984
NEDWI #285 Review of Maintenar.ce Requests for Equipment
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Qualification, Rev. O dated May 1, 1984
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NEDWI #310 Preparing, Maintaining and Updating Documentation
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Files, Rev. O dated November 6,1985
N0D (Station) Procedures:
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Failure and Malfunction Reports, Rev. 11 dated
February 6, 1985
1.3.31
Procurement of Items and Services, Rev. O dated
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November 13, 1985
1.5.3
Maintenance Requests, Rev. 16 dated March 4, 1983
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1.8
Master Surveillance Tracking Program, Rev. 4 dated
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August 8, 1984
1.8.2
PM Tracking Program, Rev. I dated June 8, 1983
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NOP 8305
Regulatory Communication and Commitment Control
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process
The NRC inspectors were also given a well-prepared presentation
describing the licensee's EQ program on December 9 and 10, 1985
during which the above procedures and work instructions were
discussed.
The licensee's program was reviewed to verify that adequate
procedures and controls had been established to meet the
requirements of 10 CFR 50.49. Areas of the program reviewed
included methods and their effectiveness for:
(a) Requiring all equipment that is located in harsh environments
and is within the scope of 10 CFR 50.49 to be included on the
list of equipment requiring qualification (EQ Master List).
(b) Controlling the generation, maintenance, and distribution of
the EQ Master List.
(c) Defining and differentiating between mild and harsh
environments.
(d) Establishing harsh environmental conditions at the location of
equipment through engineering analysis and evaluation.
(e) Establishing and maintaining a file of plant conditions.
(f) Establishing, evaluating, and maintaining EQ documentation.
(g) Training personnel in the environmental qualification of
equipment.
(h) Controlling plant modifications such as installation of new and
replacement equipment, and providing for updating replacement
equipment to 10 CFR 50.49 criteria.
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The NRC inspectors identified one concern regarding procedural
control of changes to the EQ documentation. NEDWI #310 Section 6.1.2
states that the master EQ Evaluation Sheet is considered a " working
copy" and will contain " white-out," correction tape, erasures, etc;
the record copy used for documenting qualification is a copy of the
master and is to be considered the original. The inspectors did
observe such changes in documents presented for review.
Paragraph
17.3.5 of the BEC0 Quality Assurance Manual states, in part:
... Quality Assurance records are corrected or supplemented according
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to precedures which provide for appropriate review of approval...the
correction or supplement includes the date and identification of the
person authorized to issue such corrections or supplements." The
licensee agreed to change procedures to be consistent with the QA
Manual and to review the EQ documentation and correct as necessary.
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A future NRC inspection will verify that these actions are take ..
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Documentation revisions constitute Open Item 50-293/85-35-3.
NEDWI #279 described steps for incorporating EQ requirements into
the procurement documents. Attachment 3 of NEDWI #279 provided a
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flow chart for equipment replacement, upgrading EQ requirements
from DOR Guidelines to 10 CFR 50.49. Station procedure 400 1.3.31
implements these requirements. The inspectors reviewed these
procedures and concluded that they contain sufficient information
to implement 10 CFR 50.49 requirements in the licensee's procurement
activities.
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The inspector discussed with the licensee the organizational
structure for both corporate and site concerning QA/QC activities
involving EQ.
The Nuclear Quality Assurance Manager directs
QA/QC activities at the site and corporate. The Quality Engineering
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Group Leader and the Audit Group Leader are located in Braintree.
The site contains on-site auditors and the Operations Quality Control
group leader.
This group leader is directly responsible for
the Quality Control Engineering personnel involved in reviewing
Field Change Packages (FCP's) and Maintenance Requests (MR's), both
EQ and non EQ related. The inspector verified that the QC Engineers
are certified to ANSI N45.2.6-78 in accordance with established
requirements.
In addition to discussing with the licensee the role of the QC
Engineers, the inspector reviewed the following Equipment
Qualification audit reports and their associated checklists:
Audit Report No. 84-48 " Equipment Qualification," conducted
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December 21, 1984 through January 11, 1985.
Audit Report No. 85-11 " Equipment Qualification Program,"
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conducted April 29 through May 17, 1985.
Both audits encompassed selected portions of the Equipment
Qualification program implemented by BECO including:
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Preparation and maintenance of a Master List of equipment
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important to safety.
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Identification of service data requirements of affected equipment.
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Documentation of environmental qualification for qualified
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equipment.
Justification for Continued Operation (JCO) for qualification
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pending f urther action or additional documentation.
Documentation, reporting, and disposition of equipment for which
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the JC0 has been evaluated and determined to be unacceptable.
Identification of maintenance requirements and establishment of
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a program to implement these requirements.
Procedures and instructions which implement BECO Equipment
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Qualification comitments.
Completed Equipment Qualification. files including backup
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documentation.
Maintenance and plant modification activities which impact
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Equipment Qualification status.
The inspector concluded that the audits were timely and thorough
in determining compliance to 10 CFR 50.49, the auditors involved
were knowledgeable of the EQ requirements, and the checklists were
very detailed.
The inspector interviewed corporate end site personnel concerning
the depth to which individuals were trained in accordance with
10 CFR 50.49 reouirements. Cocuments reviewed by the inspector
included:
Nuclear Policy Manual, Policy No. 5 " Nuclear Training Policy"
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NED Procedure 2.03, " Indoctrination and Training Program"
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NOP 1.3.14 " Indoctrination and Training"
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NMSP Procedure 2.01, " Indoctrination and Training"
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QAD Procedure 2.02, " Indoctrination and Training"
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Discussions with the licensee revealed that BECO sent personnel
involved directly or indirectly in the Environmental Qualification
process to various IEEE EQ seminars beginning with the first one.
These sessions covered various IEEE standards dealing with the
qualification of Class IE equipment necessary to function in DBE
conditions.
In addition, BECO personnel attended two EPRI seminars,
one dealing with EQ; the other, plant maintenance.
Further, the
inspector was given objective evidence that 90 licensee personnel
(QA, QC, maintenance, stores, nuclear operations, NED, etc.) were
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given formal two to three day plant-specific EQ training by Wyle
Laboratories and BEC0 personnel in March and April,1985. Ongoing
EQ training will continue in accordance with the policy and procedures
listed above.
The NRC inspectors concluded that with the exception of the Open
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Item cited above, the licensee has implemented a well planned
and thoroughly documented EQ program meeting the requirements of
B.
E0 Maintenance Program
The NRC inspectors reviewed the licensee's provision for preserving
the qualified status of equipment qualified to 10 CFR 50.49. The
EQ Documentation Files described in Section 4.D below include E0
Evaluation Sheets which identify required maintenance. Paragraph
7.10 of N0P 84A9 requires incorporation of these requirements into
the Pilgrim Qualification Maintenance Program (QMP). The inspectors
reviewed the N0D procedures listed in section 4.A above, which cover
implementation of the EQ requirements in the QMP. The CMP is
administered by N00, and includes replacement parts procurement,
handling and storage, installation and replacement, and 0A
verification. The QMP also includes tracking provisions to ensure
that specific activities are performed within scheduled time spans.
The licensee prepares an EQ Process Checklist for each type of
equipment, based on reviewing the applicable Documentation File.
The EQ Process Checklist includes information such as the following:
Equipment identification, specification, vendor manual,
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qualification level, etc.
Parts requiring maintenance, activity, and frequency
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Applicable procedure identification
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Parts procurement information such as availability, shelf
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life, and dc .umentation
A separate EQ maintenance procedure is prepared for each Process
Checklist. The Checklist is also used for tracking. The licensee
stated that as of December 12, 1985 all of the 72 required component-
specific procedures were written. Thirty-five were issued as of that
date; the remainder were in review and were expected to be issued
within one month. On an interim basis pending issue of the remaining
component-specific procedures, maintenance for the affected components
is performed by directly using the information in the EQ Evaluation
Sheets and Process Checklists.
The inspectors selected the following equipment-specific maintenance
procedures for review:
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N00 Procedure No. 8.E.65-2 " Torus Water Level Monitoring
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System Calibration" in draft form, not yet approved.
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N00 Procedure No. 8.Q.2-1 " Recirculation Water Sample Solenoid
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Valve EQ Repair" in draft form, not yet approved.
N00 Procedure No. 8.Q.3-2 "RHR/ Core Spray Pump Motor EQ
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Maintenance and Monitoring," in draf t form, not yet approved.
NOD Procedure No. 8.Q.3-5 "Namco Limit Switch EQ Repair," in
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draft form, not yet approved.
The inspectors found that these procedures adequately addressed the
required maintenance activities. Maintenance records for certain
equipment types were also reviewed by the inspectors with no concerns
identified. The inspectors found the Pilgrim program for preserving
equipment qualification to be acceptable, including sae interim
treatment of component-specific maintenance procedures, subject to
verification of the concerns addressed in the following Open Item.
The inspectors noted that when reviewing Maintenance Requests to
determine whether they are safety-related, the maintenance et.gineer
had only oral instructions to compare with the EQ Master List.
In
response to the inspectors' concern, on December 12, 1985 the chief
maintenance engineer issued an office memorandum stating that NOD
1.5.3
... presently requires the " Staff Engineer" to identify
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the work scope when processing the individual Maintenance
Requests. Although the present procedure only references
the Q-List, it is implicit within this assigned responsibility
that the applicable requirements (including EQ) are to be
addressed."
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"To clarify the present administrative direction, each
individual staffing a Maintenance Request will determine if
the activity is EQ-related and, if it is, will include the
appropriate technical requirements within the defined work
scope."
A future NRC inspection will verify that (1) these changes are
incorporated into maintenance request procedure N00 1.5.3 and (2)
that the remaining EQ component maintenance procedures have been
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Completion of maintenance procedures constitutes Open Item
50-293/85-35-4.
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E0 Master List
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The licensee is required to maintain an up-to-date list of the
eouipment that must be qualified under 10 CFR 50.49.
This list is
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entitled " Pilgrim Nuclear Power Station Environmental Qualification
Master List," restsion 7, dated November 1, 1985.
Considered in
the preparation of this list are environmental effects resulting
from all postulated design-basis accidents documented in the
licensee's Final Safety Analysis Report, locations within the
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plant subject to a harsh post-accident environment, technical
specification limiting conditions for operation, emergency operating
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procedures, Piping and Instrumentation Diagrams, and whether
electrical power is required for operation of the equipment. The
EQ Master List was produced as defined in NEDWI #277 and is
maintained per NED procedure 6.03.
These procedures were reviewed
and determined to provide suitable guidance.
The inspectors selected nine items as an audit sample to verify
the completeness of the current EQ Master List.
In order to compile
this audit sample, a review was conducted of the following
Emergency Operating Procedures (E0Ps) and Piping and Instrument
Diagrams (P& ids).
Emergency Operating Procedures
E0P-01, RPV Lev 9 ano Pressure, Rev. 1, dated July 29, 1985
E0P-03, RPV Level Restoration, Rev.1, dated August 21, 1985
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E0P-04, Primary Containment Control, Temperature, Rev.1, dated
July 29, 1985
E0P-05, Primary Containment Control, Pressure, Rev. 1, dated
July 29, 2985
E0P-06, Primary Containment Control, level, Rev. O, dated March 15,
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P& ids
M-207 Rev. E9, sheet 1, June 29,1984 " Condensate & Feedwater
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System"
M-207 Rev. E7, sheet 2, January 3,1985 " Condensate & Feedwater
System"
M-241 Rev. E12, sheet 1, March 22, 1985 " Residual Heat Removal
System"
M-242 Rev. E8, December 14, 1984 " Core Spray System"
M-252 Rev. E8, sheet 1, September 4,1985 " Nuclear Boiler"
The audit sample was selected to verify that those items required
to be on the Master List were in fact on the list.
The sample
also included an item required for implementation of R.G.1.97
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(torus water level).
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The inspector concluded, based on this review, that the licensee's
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EQ Master List is satisfactory.
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D.
Environmental Qualification Files
The Pilgrim EQ Documentation Files are divided into two parts', the
EQ Master Reference File (MRF) and the EQ Data Files (EQDF). The
MRF contains documentation that is used ts the basis for qualifying
components:
test procedures, test reports, analyses, Qualification
Verification Reports, etc. The EQDF documnts the qualification
of equipment identified in the EQ Master t.ist.
The FQDF is indexed
by individual component identification numbers or generic equipment
types.
Individual EQDFs document cor,ponent qualificatior, by
information contained in the EQDF and by referencing information
in the MRF or other NED records.
Each EQDF contains the following:
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An EQ Evaluation Sheet, a multi-page form whose first sheet is
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a modified IEB 79-01B SCEW sheet and which provides a detailed -
summary of the qualification, including maintenance requirements
A walkdown record and/or record search report, as appropriate
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Optional material as available, such as maintenance requests,
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Wyle review and analysis documentation such as Qualified
Life and Caveats sheet, Certificates of Compliance, etc.
A cover sheet with the equipment ID number (s), an index of the
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EQDF contents, and applicable signa,tures
The NRC inspectors examined files for 20 equipment itens, where an
iten is defined as a specific typ'e of electrical equiement,
designated by manufacturer and model, which is representative of
all identical equipment in a plant area exposed to ,the samrt
environmental service conditions.
The items were selected in advance
by the inspection team and identified 'o the licensee during
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the entrance meeting.
The files were examined to verify the qualified status of equipment
within the scope of 10 CFR 50.49.
In addition to comparing. plant
service conditions with qualification test conditions and verifying
the bases for these conditions, the inspectors selectively rhiewed
areas such as required post-accident operating time compared to'the
duration of time the equipment has been demonstrated to be
qualified; similarity of tested' equipment to that installed i,n the
plant (e.g., insulation class, materials of components of the
equipment, tested configuration compared to instalibd configuration,
and documentation of both); evaluation of adequacy'of test conditions;
aging calculations for qualified life and replacement interval
determination; effects of de. creases in insulatten' resistance on
equipment performance; adequacy of demonstrated accuracy; evaluation
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of test anomalies; and applicability of EQ prordems reported in
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IE ins / Bulletins and their resolution.'
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The files adequately documented qualification of the equipment
except as described below. The files were readily auditable and
with the exceptions described below were complete and accurate. No
generic documentation deficiencies were found.
(1) Barton 288A main steam flow switches,10 #DPIS 261-2A through
25 - Earlier in 1985 BEC0 modified 16 Barton 278 flow switches
to become model 288A flow switches, and prepared EQDFs for the
modified switches. During November and early December,1985,
as many as 11 of the modified flow switches were found to exhibit
setpoint drifts approaching plant Tech Spec. limits. This
inspection Nport addresses the EQ aspects of these modified
flow switches. The non-EQ aspects have been addressed separately
by the NRC.
The model 278 flow switch consisted of a model 224 differential
pressure sensing unit and a mercury switch transducer unit.
The conversion performed by BECO replaced the mercury switch
unit with a snap action switch unit. BECO used Barton repair
procedures to perform the modification, and in response to
questioning by the NRC inspectors obtained a letter from Barton
dated Dececher 12, 1985 which states that "a skilled Instrument
Technicien can successfully install and calibrate" the
replacement switches using the manual instructions provided by
Barton. RECO also documented a comparison between the Barton
manual procedures and the procedure written by BECO for the
modification, showing equivalence.
For environmental
qualification purposes the inspectors concluded that similarity
between the modified plant equipment and the type test specimen
was adequately established under the 00R Guidelines, and the
setpoint drift was not caused by a basic difference in the design
or materials of construction.
The inspectors did determine that the EQDF did not demonstrate
sufficient setpoint accuracy to meet the Tech Spec requirement
of 2%; in fact, the type test unit showed approximately 5%
of full scale error for the main steam line break (MSLB)
environmental conditions specified in the EQDF. The E0ES shows
a temperature increase of 156.5F, to a peak of 246.5F.
In
response to this concern, which was identified late by the
inspection, the licensee provided evidence indicating that the
specified environment was overly severe.
Specifically, the flow
switches are located on a balcony in RCIC compartment No. 3,
far from the MSLBs addressed in Bechtel analyses PBOC-7
(condenser bay) and PBOC-8 (steam tunnel).
PBOC-7 does not
model the flow switch location, and PB0C-8 models it only short
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term, showing a 5.9F increase in 2.46 seconds. The test specimen
had no accuracy problems for such conditions. The EQES shows a
required operating time of 61 minutes, whereas the actual time
of operation is about 0.5 seconds. Considering this additional
input from BECO, received just before and af ter the exit meeting,
the inspectors conclude that the files did not demonstrate
.
qualification of these flow switches because of the accuracy
concern, but that the licensee could reedily correct tl:e
documentation.
The inspectors also noted that Rev. 2 of the E0ES states with
proper justification that a previously imposed 15 year 0-ring
life limitation could be removed, but the qualification main-
tenance document and maintenance requirement sumary sheet were
t
l
not changed accordingly.
During revision of the EQDF to correctly
l
specify accuracy and environmental conditions, this discrepancy
i
should also be corrected.
Barton 288A main steam flow switches
l
constitutes Potential Enforcement / Unresolved Item 50-293/
85-35-01.
(2) General Electric EB-25 terminal blocks, file C158 - These terminal
,
blocks are used in panel C158. The basis for qualification
l
was a report on terminal blocks for use in Limitorque valve
operators. This report cited insulation resistance measurements
l
as icw as 500 ohms during the test of an EB-5 terminal block
I
subjected to a more severe environment. Similarity was adequately
established between the EB-5 and EB-25 terminal blocks, but the
effect of low insulation resistances on the performance in the
plant's 4-20 mA circuit was not covered in the file.
Discussions
with utility personnel indicated that they also based the EB-25
qualification on an Electroswitch control switch test report
for switches located in the same panel as the terminal blocks
and tested to the environment of the panel.
This report showed
i
negligible leakage currents between the contacts of the phenolic
,
switch when connected in an actual 4-20 mA pressure transmitter
i
circuit, and thus it could be used to establish terminal block
suitability for the plant environment. However, the Electroswitch
report was not referenced in the terminal block qualification
nor was applicability or similarity of the report established
for use with EB-25 terminal blocks. After further discussions
with BEC0 personnel, they decided to reference a separate report
and do further analysis to cover terminal block qualification.
Brief review of the modified file revealed no problems. General
Electric EB-25 terminal block constitutes Potential Enforcement /
Unresolved Item 50-293/85-35-2.
(3) File corrections - Three files contained relatively minor discrep-
ancies that are grouped into a single Open Item.
(a) Yarway level indicating switches LIS263-57A et al - This
file was assembled shortly before the inspection, and
covers equipment whose qualification deadline was extended
until November 30, 1985 based on acceptable JCO.
It lacks
a note relating the tested and installed terminal blocks,
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(b)
Fenwal temperature switches TSW-1A, 1B - This file was also
assembled shortly before the inspection under a November 30
deadline. Note 10 of the EQES requires modification to
clarify that it refers to the snap action switch and not
{
the terminal block.
The Isomedix certificate of testing
is also lacking.
(c) Static-0-Ring pressure switch, ID 8PS-1360-9B - Shortly
before the exit meeting the inspectors noted that a hand
calculation contained a temperature written as "105 C"
which did not correspond to the Kelvin temperature
subsequently used in an Arrhenius calculation. The effect
of this error would be to significantly overestimate the
qualified life of the component. Subsequent to the
inspection the licensee advised that the calculation was
indeed correct; the engineer had erred by transposing two
digits in writing "150 C " a number which appeared in an
earlier stage of the calculation.
A future NRC inspection will verify that these changes are
incorporated into the files.
File corrections constitutes
Open Item 50-293/85-35-5.
(4) IE Information Notices (IN) and Bulletins - The NRC inspectors
reviewed and evaluated the licensee's activities concerning the
review of EQ-related IE ins and Bulletins. The inspectors'
review included examination of procedures and EQ documentation
packages relative to Information Notices and Bulletins. The
procedures review determined that the licensee does have a
system for distributing, reviewing, and evaluating ins and
Bulletins relative to equipment within the scope of 10 CFR 50.49,
and that the ins and Bulletins are addressed in appropriate
component EQ files as described above. During the review of
individual component qualification files the NRC inspectors
evaluated the licensee's actions with respect to ins and Bulletins.
The inspectors particularly examined BEC0's actions with regard
to existing and forthcoming ins involving Limitorque operators.
These actions included upgrading all qualifications to NUREG 0588 Cat. I; replacing all internal wiring with wires known to
be qualified and by means of procedures that establish
traceability; and identifying all operator motors with magnesium
rotors and verifying that qualification is based on appropriate
test specimens. No concerns were identified during this review.
E.
PLANT PHYSICAL INSPECTION
The NRC inspectors, with component accessibility input from licensee
personnel, established a list of eleven component types for physical
inspection. All were accessible at the time of inspection. The inspectors
examined characteristics such as mounting configuration, orientation,
interfaces, model number, ambient environment, and physical condition. No
,
concerns were noted during the walkdown inspection.
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