ML20195H439
| ML20195H439 | |
| Person / Time | |
|---|---|
| Site: | Braidwood, 05000452 |
| Issue date: | 11/23/1988 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20195H433 | List: |
| References | |
| EA-88-198, NUDOCS 8811300406 | |
| Download: ML20195H439 (6) | |
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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY 4 ,
Commonwealth Edison Company Docket Nos. 50-456; 50-457 Braidwood Station Licenses No. NPF-72; NPF-77 Units I and 2 EA 88-198 ,
t During an NRC inspection conducted from February 29 through May 4, 1988, l violations of NRC requirements were identified. In accordance with the (
"General Statement of Policy and Procedure for NRC Enforcement Actions," f 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular :
violations and associated civil penalty are set forth below:
I, Violations Assessed A Civil Penalty A. 10 CFR 50.49(a) requires each holder of a license for operation of a nuclear power plant to establish a program for qualifying electric .
equipment identified in 10 CFR 50.49(b). I 10 CFR 50.49(b) defines equipment important to safety and includes: '
(1) Safety-related electric equipment, i.e., equipment relied upon to remain functional during and following design basis events, ,
(2) Nonsafety-related electric equipment whose failure under postulated i environmentai conditions could prevent satisfactory accomplishment of the functions of safety-related equipment.
10 CFR 50.49(f) requires that each item of electric equipment important to safety be qualified by testing and/or analysis under postulated environmental conditions.
Contrary to the above, as of May 4, 1988, items of electric equipment important to safety were not properly qualified by testing and/or analysis as pemonstrated by the following examples:
- 1. Eighty-four Limitorque actuators located inside and outside the '
Units 1 and 2 containments were determined to be unqualified because they contained lubricants with between 5 und 50 percent contaminants. No adequate tests and/or analyses were conducted I to demonstrate that these contaminated lubricants would support adequate functioning of the actuators under postulated accident conditions.
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Notice of Violation 2 NOV P3 in
- 2. Seventeen junction boxes located inside the Units 1 and 2 containments which were installed without weep holes and were used in control circuits associated with numerous systems important to safety. A qualified junction box had been tested with a weep hole to provide for drainage of condensation. The 17 junction boxes identified were considered unqualified because no test and/or analysis was performed to demonstrate that boxes without weep holes would function under postulated accident conditions.
- 3. Twenty-two Whitman General J505 pressure switches located inside and outside the Units 1 and 2 containments and used in the operation of feedwater isolation valves, containment purge isolation valves, and steam generator pwer operated relief valves were determined to be unqualified since no test and/or analysis was conducted to der.anstrate that the switches would function under postulated accident conditions.
- 4. Westinghouse components, including twenty-four OT-2A Switches, twenty-nine AR 440 and AR 660 relays, and eighty-four EZC indicating lights, located outside containment in Units 1 and 2 and used in various HVAC panels, were determined to be unqualified because these components had not been evaluated for similarity to components that had passed environmental qualification tests.
B. 10 CFR Part 50, Appendiv. B, Criterion V, as implemented by the licensee's Quality Assurance Program, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, specific maintenance activities affecting quality, necessary to preserve the qualification of environmentally qualified (EQ) components, were prescribed by documented instructions and procedures, but were not implemented as demonstrated by the following examples.
- 1. EQ Binder EQ-BB-HE10A for Target Rock Solenoid Valves specifies that the RTV Silicone rubber gasket be replaced each time the valve cover is removed. The cover of Solenoid Valve ICV-8114 was removed during completion of Work Request A99999, dated January 31, 1987. However, the Itcensee did not replace the specified silicone rubber gasket.
Notice of Violation 3 NOV P3198S
- 2. EQ Binder EQ-BB-061, Tab E, for Rosemount Pressure Transmitters specifies inspection and cleaning of mating surfaces, lubrication of "0" rings, and torquing of the housing cover each time the cover is removed. The housing covers of pressure transmitters IPT-MS-042, IPT-MS-043, and IPT-MS-044 were removed in May 1986 during calibration; however, the licensee did not accomplish the above specified activities.
- 3. EQ Binder EQ-BB-027, Tab E, for Limitorque Valves specifies the main gear case lubricant to be inspected every 18 months until operating history indicates otherwise. The licensee, however, failed to inspect the lubricant following the initial 18-month interval and did not have documented justification based on operating history to do otherwise.
- 4. EQ Binder EQ-BB-064, Tab E, for Valcor Valves specifies the installation of new "0" rings whenever the housing cover of the solenoid valve is removed. In March 1988, the licensee discovered that the housing covers of Valcor Valves PS-228A and B, PS-229A and B, PS-230A and B, IRC014C and D, and 2RC014A, B, C, and D had been removed; however, the specified "0" rings had not been replaced.
- 5. EQ Binder EQDF ESE-44A for Incore Thermocouple reference junction boxes specifies the replacement of the enclosure "0" ring each time the cover of the junction box is opened. The cover was removed from Junction Box 21T-01J during performance of Work Request A99999 dated February 5, 1988; however, the licensee did not replace the specified "0" ring.
- 6. EQ Binder EQ-BB-015, Tab E, for NAMCO Limit Switches specifies torquing of the limit switch cover to 20 inch pounds to seal the switch. During the inspection, however, it was identified that the switch cover of NAMCO Limit Switch ISI-001B-A-Z5 had not been torqued, as required, following its removal for maintenance.
- 7. EQ Binder EQDP-AE-2 for Westinghouse Pump Motors specifies Mobil DTE Medium 011 to be used for lubrication of motor bearings.
In March 1988, however, it was discovered by the licensee that unqualified Mobil DTE Heavy Medium 011 had been used for motor bearing lubrication instead of the qualified DTE Medium 011. The unqualified oil had been used in eight Westinghouse pump motors in Units 1 and 2 and included the following motors: 1/2 CV01PA, 1/2 CV01PB, 1/2 $101PA, and 1/2 5101P8.
Notice of Violation 4 NOV ?? w
- 8. EQ Binder EQ-BB-008 for Reliance and Westinghouse Fan Motors specifies Chevron SRI-2 to be used as the motor bearing lubricant.
In March 1988, however, it was discovered by the licensee that unqualified Mobilux EP was being used as the lubricant for the motor bearings in Reliance and Westinghouse Fan Motors 2VA02CC and 2VA02CD.
These violations have been categorized in the aggregate as a Severity Level III problem (Supplement I).
Cumulative Civil Penalty - $75,000 (assessed equally among the violations).
II. Violations Not Assessed A Civil Penalty ,
A. 10 CFR 50.49(f) requires that each item of electric equipment important to safety be qualified by testing and/or analysis under postulated environmental conditions.
Contrary to the above, as of May 4,1988, four Bunker Ramo electrical penetration assemblies which are items of electrical equipment
- important to safety were unqualified. Specifically, the licensee had not performed an adequate test to qualify the penetrations in the installed configuration (with Raychem splices), nor did the licensee demonstrate qualification for the loss of coolant accident (LOCA) portion to the test. procedure.
Severity Level IV (Supplement I).
B. 10 CFR Part 50, Appendix B, Criterion V, as implemented by the licensee's Quality Assurance Program requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of the type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Contrary to the above, EQ Binder EQ-ME-4, Tab E, specifies torquing of mounting bolts on Limitorque valve actuator housings. As of May 4, 1988, however, the licensee failed to prescribe instructions or procedures to assure the specified torquing of approximately eighty-six Limitorque operators was properly accomplished.
Severity Level IV (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of
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Notice of Violation 5 NOV P3 m the date of this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps that htye been taken and the results achieved; (4) the corrective steps that will be taken to avoid further violations; and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified 1, this Notice, an Order may be issued to show cause why the license should not be nodified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, Commonwealth Edison Company may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1988), should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provision of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
Notice of Violation 6 NOV 2 31585 The responses to the Director, Office of Enforcenent, noted above (Reply to a Notice of Violation, letter with paymens of civil penalty, and Answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regicnal Ad-inistrator, Region III, U.S. Nuclear Regulatory Commission, 799 Roosevelt Road, Glen Ellyn, Illinois 60137 and a copy to the NRC Resident Inspector at the Braidwood Station.
FOR THE NUCLEAR REGULATORY COMMISSION CN ___-
h kW A. Bert Davis Regional Administrator Dated at Glen Ellyn, Illinois this 23rd day of November 1988 t
g**lGg d Ice UNIT ED sT ATEs 3e g NUCLE AR REGULATORY COMMISSION
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April 7, 1989 10 A., POSEE EEA;i3 i:CLh1EE5 Ah; AU.;Uhii
SUBJECT:
MODIFIED ENFORCEMENT POLICY RELATING TO 10 CFR 50.49, "ENVIR0hMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANT 5" (GENERIC LETTER 88-07)
Background:
Generic Letters, Eulletir.s, and Informaticn hotices have been issuec to provide guidance regarding the application and enforcement of 10 CFR 50.49, "Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants."
Generic Letter 85-15, issued August 6, 1985, and Generic Letter 86-15, issued September 22, 1986, provided information related to the deadlines for compliance with 10 CFR 50.49 and possible civil penalties applicable to licensees who were not in compliance with the rule as of the November 30, 1985 deadline. Upon review, the Comission found that the EQ Enforcement Policy promulgated in Generic Letter 86-15, could result in imposition of civil penalties that did not properly reflect the safety significance of EQ violations with respect to civil penalties imposed in the past. In the interest of continuing a tough but fair enforcement policy, the Comission determined that the EQ Enforcement Policy should be revised. The purpose of this letter is to provide a modification to the NRC's enforcement policy, as approved by the Consnission, for environmental qualification (EQ) violations. This letter replaces the guidance provided in Generic Letters 85-15 and 86-15.
Modified EQ Enforcement Policy The details of the modified EQ enforcement policy are provided in the enclosure.
Generally, the changes made to the policy are to: (1) aggregate sienificant EQ violations together, rather than consider each separate item of unqualified electrical equipment, for assessment of a civil penalty, (2) assess a base civil penalty according to the number of systems or components which are affected by the unqualified equipment in a graded approach by assignment of the aggregate EQ problem into one of three categories, (3) establish a maximum EQ civil penalty of $750,000 for most cases, (4) maintain a minimum civil penalty of $50,000 for a significant EQ violation in most cases, and (5) consider mitigation or escalation of the base civil penalty based on the factors of identification and reporting, best efforts to complete EQ within the deadline, corrective actions, and duration of the violation.
This modified policy should not be interpreted as a lessening of the NRC's intention to assure that all plants comply with EQ requirements. The modified policy is intended to give a significant civil penalty to those licensees with significant EQ violations. The NRC's view is that the modified policy more closely reflects the relative safety importance of EQ violations with other enforcement issues.
Safety Issues When a potential deficiency has been identified by the NRC or licensee in the envirunmental qualificatior. of equipment (i.e., a licensee does not have an j 8-@OYOONN Off
Generic Letter 88-07 April 7, 1988 adequate basis to establish qualification), the licensee is expected to make a prompt deterr;ination of operability (i.e., the syster. or component is capable of performing its 1r. tended design function), tale irreciate steps t0 establish a ;;ar. .ith a re e s:r at h idec.:le to correct the :eficiere , are teve *ritter,
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The licensee may be able to make a finding of operability using analysis and partiel test data to provide reasonable assurance that the equipment will perform its safety function when called upon. In this connection, it must also be sht+n that subsequent f ailure of the equipnent, if likely uncer accident conditions, will not result in significant degradation of any safety function or provide misleading information to the operator.
The following actions are to be taken if a licensee is unable to demonstrate equipment operability:
- a. For inoperable equipment which is in a system covered by plant technical specifications, the licensee shall follow the appropriate action statements. This could require the plant to shut down or remain shut down,
- b. For inoperable equipment not covered by the plant technical specifications, the licensee may continue reactor operation:
- 1. If the safety function can be accomplished by other designated equipment that is qualified, or
- 2. If limited administrative controls can be used to ensure the safety function is performed.
The licensee must also evaluate whether the findings are reportable under 10 CFR 50.72 and 50.73, 10 CFR Part 21, the Technical Specifications or any other pertinent reporting requirements, including 10 CFR 50.9(b), particularly if equipment is determined to be inoperable.
This letter does not require any response and therefore does not need approval of the Office of Management and Budget. Coments on burden and duplication may be directed to the Office of Management and Budget Reports Management Room 3208, New Executive Office Building, Washington, DC 20503. Should you have questions on this letter, the staff contact is Howard Wong, Office of Enforcement. He can be reach on (301) 492-3281.
Frank J. MVaglia Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated I
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ENCLOSURE N0DIFIED ENFORCEMENT POLICY FOR EO REQUIREMENTS This enclosure provides the details of the rodified erferccrent oclicy fer E0 re:virererts for these licensees wu were n:: in c ;De"e vi t 1 :- :n g:,4; as cf the h:verter 3C, '9EE deadlir.e.
I. Scope of the Enforcement Policy for EQ Recuirements If violations of the EQ rule identified at plants operating after hovecber 30, 1965 existec before the deacline anc the licensee "clearly knew or should have known" of the lack of proper environrental qualifi-cation, then enfercement action may be taken as described in Sectiens !!!
and !V. If the licensee does not teet the clearly knew cr should have known" test, no enforcement action will be taken.
This enforcement policy applies to violations of the EQ rule identified after November 30, 1985 which relate back to action or lack of action before the deadline. Violations which occurred after Ncvember 30, 1985 (either as a result of plant modifications or because the plant was licensed after November 30,1985) will be considered for enforcement action under the normal Enforcement Policy of 10 CFR Part 2. Appendix C.
In addition, EQ violations which are identified after the NRC's last first-round inspection, 1/ approximately mid-1988, will also be considered under the normal Enforcement Policy.
II. Application of the "Clearly Knew, or Should Have Known" Test Licensees who "clearly knew" they had equipment for which qualification could not be established may have comitted a deliberate violation of NRC requirements. This situation will be evaluated on a case-by-case basis.
The NRC will examine the circuestances in each case to determine whether the licensee "clearly should have known" that its equipment was not quali-fied. The factors the NRC will examine include:
- 1. Did the licensee have vendor-supplied doeutentation that demonstrated that the equipment was qualified?
- 2. Did the licensee perform adequate receiving and/or field verification inspection to determine that the configuration of the installed equipment matched the configuration of the equipment that was qualified by tie vendor? ,
- 3. Did the licensee have prior notice that equiptent qualification deficiencies might exist?
4 Did other licensees identify similar problems and ccrrect them before the deadline?
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1/ First-round inspections are special team inspections to review licensees' compliance with 10 CFR 50.49.
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Enclosure -
2-In assessing whether the licenset clearly shoulc have knewr of a deficiency, the infermatier trevicec tc the licenstes by the M.C and the ircustry er ste:ific de'icit t:4 5 *i'i tt telt" inte c:'si:tratic'. 'hi! :- si : ,
d anc the tireline!! cf it being previced tc licensees prior to the EC-deadline are relevant facters. If one licensee determined that a specific EQ deficiency existed, it would not be assumed that all licensees should have also come to the sane conclusion unless information abcut the specific deficiency had been widely disseminated within the industry or by the 'i 0, The staff will carefully censider these criterie when evaluating whether a licensee clearly shoulo have known of a ceficiency prior to the deadline.
111. EO Violations net Sufficiently Significant to Herit a Civil Fenalty Under the Modified Policy Any failure to adequately lisi. and demonstrate qualification of equipment required by 10 CFR 50.49 may '.onstitute a violation of the rule. This does not require, however, that all violations of the rule be considered for escalated enforcement ci- be assessed a civil penalty. For example, if the qualification file presented to the inspector during an inspection did not demenstrate or support Qualification of equipment, the equipment would be considered unqualified 2/ and 10 CFR 50.49 requirenents would be violated.
However, although not G the c.ualification file, if sufficient data exists or is developed during the inspection to demonstrate qualification of the equipment or, based on other information available to the inspector, the specific equipment is qualifiable for the application in question, the qualification deficiency is not considered sufficiently significant for assessment of civil penalties. These violations would be considered to be Severity Level IV or Severity Level V violations based on a violation of 10 CFR 50.49 requirements at the tine of the inspection.
Programatic violations or problems that are identified as a result of the EQ inspections that involve several EQ violations which themselves would not be considered sufficiently significant to merit a civil penalty under the modified EQ enforcement policy nonetheless may be aggregated and evaluated for estilated enforcement action (generally Severity Level III) for the f ailure to sa';isfy applicable requirements of 10 CFR 50.49 and/or 10 CFR Part 5( S. n ndix B. The civil penalties for these violations would be assess' r the normal Enforcerent Policy of 10 CFR Part 2 Appendix C r .nt I).
IV. Basis for Dettemining Civ ;es A. Base Civil Penalty Significant EQ violations, for which the licensee clearly shculd have known that they had equipment for which qualification had not been established.
2,/ Tor purposes of enforcement, "unqualified equiptent" means ecuipment for which there is not adequate documentation to establish that this equipment will prform its intended functions in the relevant environment.
Enclosure are to be considered tetether. in the aggregete, and the bese civil : Falty assessed in a crace: apercact based on the nu-ter of syste s cr c:- ent t! cffe:tec. j' The base civil penalty would be determined as described below.
EQ Violation Category Base Civil Penalty A. Extensive; EO violations affecting many $300,000 systems and many components.
E. Moderate; EQ violatiens affecting some $150,000 systems and some components.
C. Isolated; EQ violations affecting a $ 75,000 limited nunber of systems and components.
The +,hree EQ violation categories reflect the overall pervasiveness and the general safety significance of significant EQ violations. The NRC considers violations of EQ requirements to be safety significant because the electrical eouipment required to be qualified were those which have importance to safety. The violation categories do not include those EQ violations which have been determined to be not sufficiently significant standing alone to be considered for escalated enforcement and which will be normally considered er Severity Level IV or Y violatters, as described in Section !!I. As stated in Section III, however, programatic problems may be the subject of escalated enforcement action under the NRC's normal Enforcement Policy.
The significance of the EQ violations is considered when the NRC evaluates the number of systems affected by the EQ violations and determines the EQ violation category. The NRC will assume, for escalated enforcement cases, that the unqualified equipment could affect operability of the associated system. The NRC will not consider refinements on the operability arguments such as the actual time the equipment is required to be operable, admini-strative measures or controls available to ensure the safety function is accomplished, the degree to which the operability of a system is affected, or, that through additional analyses or testing, the equipment may be demonstrated to be qualified or qualifiable. This assumption is made for enforcerrent purposes in order to reduce the resources anticipated to be spent by licensees and the NRC to evaluate in detail whether system operability was in questiun.
3/ The EQ violation categories (A-C) will be used rather than the severity levels in the normal Enforcement Policy of 10 CFR Part 2. Appendix C.
The base civil penalty for the violations will be applied consistent with the statutory limits on civil penaltics under Section 234 of the Atomic Energy Act.
Enclosure ,
Because the NRC is ccnsidering enfcrce.ent acticn rather than a justifica-tion for cer.tinued eceratien and t*e EQ deficiencies <e been corrected in n: s t ins t a ate s , t r e 'M .111 nd t a cerse <at'*( ju:; <nt as to the ever:11 st'(t si;rifi: *:t c' if t E's vicittice! !! st e c r. 6 e nc-t t- ;f safety systems affectec. This approach has the tenefits of a relatively quick, though conservative, view on the safety consequences of unqualified equipment and will focus on the underlying cause of the E0 violations.
Cases insc1ving deliberate violaticns er very sericus EQ violations (rcre safety significant than ca,nsidered in this modified enforcerent policy such as widespread breakdowns or clearly inoperable systems) will be esaluated on a case-by-case basis and ray be subject to more severe sanctions than those described in this policy.
B. Mitigation / Escalation Factors Mitigation and escalation of the base civil penalty determined in Section IV.A will be considered in the determination of the civil senalty amount.
The NRC will consider ther.Q violaticns in aggregate, not based on individual violations. Adjustment of the base civil penalty will be considered as described below:
Mitication/ Escalation Factors Maximum Mitigation /
Escalation Amount (from base civil penalty)
- 1. Identification and prompt reporting, if required, 50%
of the EQ violations (including opportunities to identify and correct the deficiencies).
- 2. Best efforts to complete E0 within the deadline. t 50%
- 3. Corrective actions to result in full compliance 2 50%
(including the tine taken to make an operability or qualification determination, the cuality of any supporting analysis, and the nature and extent of the licensee's efforts to come into ec.p11ance).
4 Duration of violation which is significantly below - 50%
100 days.
In order to be fair and equitable to those licensees who took appropriate actions prior to Neverber 30, 1985 or shut down prior to this date to be in ccepliance, civil penalties generally should not be less than $50,000 to emphasize that a significant environmental qualification failure is unacceptable.
The NRC will, however, consider full mitigation (no civil penalty) for those EQ violations which satisfy all of the five following criteria:
(1) violations which are isolated and affect a limited nuitber of systems and components (2) violations which are identified by the licensee, (3) violatior.s which are promptly reported to the hRC, if required, (4) violations which are corrected and actions taken will result in full compliance within a rvasonable tire, and (5) violations for which the licensee has deronstrated best efforts to complete EQ within the deadline.
h
Enclosure -
The intent of full nitigation of the civil penalty for E0 violations which rett all five criteria is to increase +.he incentive for self-identification of E0 deficiencies which might riot otherwise be found by NPC. The NTI will ;entrt 11.5 issue cnly a Nctice c' Viclaticn for vicir'.ic :
- Lier, rect ei' these criteria, if the licensee is able to convincingly demonstrate at the time of the I inspection, or shortly thereafter, that an item is not required to be on the EQ list, then the item would not be considered for enforcanent action.
The NRC dces nct intend te censider fer enforcement purpofes the results of a licensee's after-the-fact testing for mitigation where the licensee clearly should have known that its documentation was not sufficient.
f
- e.
- L]ST OF RECENTLY ISSUED GENENIC LETTERS G2nerne Date of Lotter No. Su: Ject Issuance Issue: Te D. EE-:.: REMCiAL Or CRCANIAT*C'. C-A:TE 0: C: EE a. : . i. ;
FROM TECHNICAL SPECIFICATION REAC704 AC'11NISTRAT IVE CONTROL LICENSEES AND REQUIREMENTS APPLICANTS ,
GL ES-C5 ECRIC ACID CORROEION OF CAREON 03/17/66 ALL LICENEEEE ETEEL REACTOR PRESSURE Cr OcE A A T I NC-SOUNDARY COMPONENTS IN PWRE AND PWR PLANTE WOLDERE Or CONSTRUCTION PERMITS FOR PWR$
GL 88-04 DISTRIBUTION OF GEMS O2/23/88 ALL NON-POWER 1RRADIATED IN RESEARCH REACTOR REACTORS LICENSEES GL 88-03 RESOLUTION OF GENERIC SAFETY O2/17/88 ALL LICENSEES. L ISSUE 93 "STEAM BINDING OF APPLICANTS FOR AUXILIARY FEEDWATER PUMPS" OPERATING LICENSES, AND ;
HOLDERS OF CONSTRUCTION PERMITS FOR PRESSURIZED WATER REACTORS GL 88-02 "INTEGRATED SEFETY ASSESSMENT 01/20/08 ALL POWER PROGRAM II (ISAP II)" REACTOR LICENSEES GL 88-01 "NRC POSITION ON IGSCC IN BWR 01/25/88 ALL LICENSEES AUSTEN! TIC STAINLESS STEEL OF DAERATING PIPING" BO! LING WATER REACTORS AND HOLDERS OF CONSTRUCTION PERMITS FOR BWRS GL 87-16 NUREG-1262, "ANSWERS TO 11/12/87 ALL POWER AND OUESTIONS AT PUBLIC MEETINGS NONPOWER RE IMPLEMENTATION OF 10 CFR55 REACTOR ON OPERATORS L1CENSEES AND L' ENSES APPLICANTS FOR LICENSES GL 87-15 POLICY STATEMENT ON DEFERRED 11/04/87 ALL HOLDERS OF PLANTS CONSTRUCTION PERMITS FOR A NUCLEAR POWER PLANT CL 87-14 REQUEST FOR OPERATOR LICENSE 08/04/87 ALL POWER SCHEDULES REACTOR LICENSEES
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( i U.S. fwCLEAR REGULATORY C0". MISSION REG:0!, 11 Reports No. 50-456/88005(DRS); 50-457/88000(DRS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-72; ho. NPF-75 Licensee: Comonwealth Ed. son Company Post Office ".ox 767 Chicago, l'. 60690 Facility Name: Brridwood Station, Units 1 and 2 Inspection At: Braidwcod Site and Glen Ellyn, Illinois Inspection Conducted: February 29 through May 4, 1988 Inspector: A. S. Gautam
- Regional Inspector, Region 11 Date I Also participating in the inspection and contributing to the report were
M. Kopp, RI!!
R. Wilson, NRR J. Hanek, INEL R. Vanderbeek, INEL K. Iepson, Schneider Enggs V. Nicolette, n s W" h "
Approved By: . Gardner, Chief 6 )f 7k8
) Plant Systems Section, Region !!! Date Inspection Sumary i Inspection on February 29 through May 4,1988 (Reports No. 50-456/88005(DRS);
i No. 50 457/88006(DR5))
]
Areas Inspected: Special, announced safety inspection of the environmental
- qualification (EQ) of electric equipment within the scope of 10 CFR 50.49.
]
The inspection included licensee action on SER/TER commitinents; EQ program a compliance to 10 CFR 50.49; adequacy of EQ documentation; and a plant physical l inspection of EQ equipment (Modules No. 30703 and No. 2557P .
j Results: The licensee tas not adequately implemented their program to meet I the requirements of 10 CFR 50.49. Deficiencies in the areas inspected are I sumartred below:
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POTENTI ALLY ENro;CE APLE UNDE 50LVED 17 EMS lienNo. Description g ort Section 50-456/88005-01(DRS) Inadequate documentation for 2 50-45?/80006-01(DES) the EQ of Johnson Control supplied HVAC components.
50-456/88005-02(DRS) Sealing, torquing and lubri- 4c 50-457/88006-02(DRS) cation (naintenance) (1 2)(3)(4) deficiencies resulting in (5 6)(7)(8) unqualified EQ equipment. (9 10) 50-456/88005-04(DRS) Inadequate documentation 5a 50-457/88006-04(DRS) for the EQ of Bunker Ramo instrumentation penetrations.
50-456/88005-09(DRS) Missing weep holes and drip 6a 50-457/88006-09(DRS) shields in 10 CFR 50.49 designated junction boxes.
50-456/88005-10(DRS) Inadequate documentation 6b 50-457/88006-10(DRS) to qualify GECO pressure switches.
50-456/88005-11(DRS) Inadequate documentation 6c 50-457/88006-11(DRS) to qualify mixed greases in Limitorque actuator main gear cases.
OPEN ITEMS Item No. Description Report Section 50-456/88005-03(DRS) Inadequate quality assurance 4e(1)(2) 50-457/88006-03(DRS) and training program in regard to EQ.
50-456/88005-05(DRS) Revision of EQ file for $b 50-457/88006-05(DRS) Joy / Reliance Fan Motors to include EQ Calculatitti.
50-456/88005-06f0RO Revision of EQ file for Sc 50-457/88006-Co(DRS) Target Rock Solenoid valves to include EQ calculation.
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( l J t e.~ ho - Descrirtion Rencr: S e: t i er, 5 0- 45( / EE UD 5- 07 ( D;.5 ) Fevisier. of EV file for Ed 50-457/EE005-07(DPS) 171 Serton Medci 752 Transnitters to include missing EQ documentation.
50-456/88005-0S(DRS) Revision of E0 file for Se 50-457/88006-08(DRS) General Atomic Radiation monitur to include E0 docume nta tion.
50-456/88005-12(DRS) Deficient Raychem Splice 6d 50-457/88006-12(DRS ) found on General Atomic high range radiation monitor.
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DETAILS
- 1. Persons Contacted
- a. Comonwealth Edison Com: any (Ceco)
C. Reed, Senior Vice President L. De1 George, Assistant Vice President, Licensing and Pim Support M. Wallace, Manager, Projects and Constructicn B. Shielton, Manager, Power Engineering K. L.,Graesser, General Manager Power Operations
- D. Elias. Superintendent, Power Engineering
- E. R. Wendorf, Assistant Superintendent, Project Construction
+R. Querio Station Manager
- G. Fitzpatrick, Station Manager
- K. Kofron, Superintendent, Production
- D. O'E ten, Superintendent, Services M. Lohr, ann, Construction Superintendent, Project Startup
- G. Masters Assistant Superintendent. Operations
- D. Paquette, Assistant Superintendent, Maintenance
- P. Cretens, Assittant Superintendent, Work Planning
- L. Davis, Assistant Superintendent, Technical Services
+*P. Barnes, Regulatory Assurance Supervisor
- R. Lemke. Technical Staff Supervisor
. J. Gosnell, QC Supervisor R. Kyrouac, QA Supervisor S. Hedden, Master Instrument Mechanic J. Smith, Master Electrician J. Huffman, Master Mechanic
- D. Kapinus Assistant Technical Staff Supervisor
- L. Woldridge, Technical Staff Parts & EQ Group Leader
- J. Roth Station EQ Coordinstor, Technical Staff B. Rosenmeier Tcchr.ical Staff Parts & EQ R. Grams, PSD - Engineering C. Moerke, General Design Engineer, Power Engineering
- W. Groszko, Configuration Management, Power Engineering
- E. Adams, BW/BY EQ Coordinator F. Lentine, Supervisor, Licensing
+*S. Hunsader, Administrator, licensing
- T. W. Simpkin, Regulatory Assurance
- D. Kruges , Technical Staf f, Byron EQ Coordinator
- W. B. McCue Operating ENGG, BWR ,
R. D. Branson, Byron, Master Electrician
- J. Snyder, Electrical Maintenance
- b. Consultants - Saraent and Lundy (S&L)
- S. M. Malak, EQ Coordinator, Project Management Division
- M. M. Hassaballa, Supervisor
- A. Mohiudidin, Senior Component Engineer
- D. P. Galanis, Electrical Engineer 4
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- A. Alsamaroc, EQ Engineer
'5. Akhtar, EQ Engineer
'L. McLe, EQ Enginu r
- A. E4here, Consultant
- n. Heiderisaf a EQ Engineer
- B. Pandit, EQ Engineer
- R. John, EQ Engineer
- D. Drankhan, EQ Engineer S. Malat PMED B. Kornbreck, EFED ,
M. Banogen, Control & Instrumentation Division (CID)
C. B. Kornoker, Electrical Engineer
- W. Poirier, Project Manager, Westinghouse
- c. Nuclear Regulatory Commission (NRC)
A. B. Davis, Regional Administrator, Rill
. C. J. Paperiello, Deputy Regional Administrator, Rl!I H. J. Miller Director, DRS E. G. Greenman, Director, DRP
- R. N. Gardner, Chief, Plant Systems Section, DRS i
. *T. Tongue, Senior Resident inspector, Braidwood i
- Denotes those attending the interim site exit meetings on March 4 '
1988.
l + Denotes those attending the exit interview on May 4,1988, at the conclusion of the inspection.
- 2. Allegation Follow-up (RIII-86-A-0131)
I During July and August 1986, an unidentified alleger contacted the NRC l regarding concerns with components supplied by Westinghouse to Johnson Controls. Inc. (JCl) for installation at Byron and Braidwood, Units 1 and 2. The alliger stated that W-2 and OT-2 switches, AR relays, and EZC indicating lights were not properly environmentally qualified to the requiremen? s of 10 CFR 50.49, Paragraph (f). As a result of this allegation, an inspection of the NRC Vendor was performed Branch (Inspection ReportatNo.
Johnson Controls by) 99901072/86001 whoinspectors concluded that the HVAC systems provided by JCI at Byron and Braidwood ,
were located in mild environments and were not required to meet 10 CFR 50.49. As a followup, Region 111 was requested by the NRC Vendor Branch to confirm whether the HVAC equir.ent supplied by Johnson Controls per JCI specification F/L 2783, was in fact located in a mild environrnent.
During this current inspection, the NRC inspectors confirmed that the Westinghouse W-2 switches in question were located in mild environments, and therefore were not within the scope of 10 CFR 50.49. The inspector l
also observed, however, that the Westinghouse OT-2 switches, EZC l indicating lights, and the AR relays in question were located in harsh 5
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. ( f environments. The licensee could not providc cvida:e that the Westinchouse components ir. stalled by JCI u rc siriler cr identical to tre corpenents tested by JC1. Subsequent to these NRC fin:ings, thc licensec presented an engineering analysis to evaluate the Westinghouse 0T-2 switches, EZC lights and AR relays, for use in various HVAC panels at Braidwood Station. This analysis concluded that (1) the subject components were installed in a relatively mild environ ent - radiation harsh only; (2) the only failure mode of con:ern was loss of dielectric strength of the insulating parts and the loss of mechanical properties of the moving parts and; (3) there was a 4GM margin in'the design electrical stress for these components.
l A checklist for comparison of Westinghouse EZC lights, AR 440 relays, l AR 660 relays and OT-2A switches had been used by the site to walkdown the Johnson Controls previded components. The checklist permitted comparison of the installed components to the tested devices. Some color discrepancies were noted. Westinghouse indicated that they were attributable to pigmen'ation and did not represent a materials change.
Discrepancies in the data printed on the EZC Light and AR 440 relays were also noted during the licensee's walkdown. The licensee attributed these discrepancies to differences in the color of light lenses and the job number, respectively.
4 The licensee has comitted to confirming their conclusions by destructive i testing. Eight Johnson Control provided components (2 OT-2 switt.hes, 2 EZC lights, 2 AR-440 relays and 2 AR 660 relays) have been removed from the Johnson Controls panels and hand carried to Westinghouse for diagnostic examination. This examination is intended to identify the j
materials in the components and confirm their qualification. Pending NRC 2
review of the results of this examination, this is considered a Potentially Enforceable / Unresolved item (No. 50-456/88005-01(DRS);
(No. 50-457/88006-01(DRS)).
- 3. Licensee Action on SER/TER Commitments ,,
The NRC inspection team evaluated the implementation of the licensee's EQ corrective action commitments discussed in Braidwood SSER 2 included in the Braidwood FSAR. SSER 2 noted that the scope of the staff review for Braidwood Unit I was limited to an evaluation of those 10 CFR 50.49 desig-nated electrical components that were different from equipment installed l in Byron Unit 1. Since the licensee did not identify any 10 CFR 50.49 equipment installed in Braidwood Unit 1 as different from 10 CFR 50.49 equipment installed at Byron Unit 1, the staff's review of the EQ program for Byron Unit I was considered applicable to Braidwood, Unit 1.
The majority of the deficiencies identified in the SER addressed documentation, sinilarity, aging, qualified life, and replacenent schedules.
All open items identified in the NRC June 21-23, 1983 audit were addressed by the licensee in their July through October 1986 responses to the NRC staff. The licensee's proposed resolutions to these items were found acceptable by the NRC, as stated in Section 3.11 of the Braidwood SSER ?.
The primary objective of the current Region III EQ Audit in this area was to verify that appropriate analyses and necessary documentation to support the li:ensee's proposed and accepted resolutions were contained in the
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licensec's EQ files, and that appropriate modifications or replacenr.ts of (cuipnent had bcen impic ented. '
During this review, the NRC inspection team reviewed EQ documentation and examined equipment in the plant relevant to prior discrepancies identified in the SERs, including replacement of equipment having qualification deficiencies.
No violations of NRC requirements in regard to the SER commitments were identified.
- 4. EQ Program Compliance to 10 CFR 50.49 The inspectors reviewed selected areas of the licensee's EQ Program to verify compliance to 10 CFR 50.49. The licensee's EQ program was found to identify methods of equipment qualification; provide for evaluation and maintenance of EQ documentation in an auditable fom; provide for upgrading of replacement equipment; and incorporate controls for plant modifications. Based on their review, the inspectors determined that the licensee had established an EQ program to address the requirements of 10 CFR 50.49. The licensee's methods for establishing and maintaining the environmental qualification of electrical equipment were reviewed in the following areas:
- a. EO Program Procedures The inspectors examined the adequacy of the licensee's policies and procedures for establishing and maintaining the environmental qualification of equipment within the scope of 10 CFR 50.49. The licensee's EQ program was reviewed for procurement of qualified equipment; maintenance of qualified equipment; modifications to the plant that could affect qualified equipment; updating of the EQ master list; and review and approval of EQ documentation. Procedures reviewed included the following documents.
BWAP 370-1, Revision 2. "Station Lubrication Program" BWAP 500-5, Revision 0, "EQ Program" BWAP 1600-1, Revision 13. "Maintenance Work Request Procedure" BWAP 1610-1, Revision 0, "Modification Requests" BWAP 800-2, Revision 1. "Control of Requests for Purchase" BWAP 800-1, Revision 4, "Classification of Parts, Safety-Related Components" BWAP 800-3, Revision 0, "Technical Evaluation of Components and Parts" BWIP 2400-111, Revision 0, "EQ Requirements for Plant Instrumentation
BWHP 4006-009 Revision 1.(NAMCO)
BWHP 4006-017, Revision 4 (LIMITORQUE)
BWMP 3305-044, Revision 0, (LIMITORQUE)
Specific areas reviewed in these procedures included requirements for review and acceptance of the EQ files, responsibilities of key individuals and departments, EQ definitions, maintenance and surveillance.
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f k violations of M C requirements were identified.
- t. . 10 CTR 50.G Master Ecuipment List (MEL) of EQ Ecuipment 10 CFR 50.49, Paragraph (d), requires licensees to prepare a list of electrical equipment important to safety, and within the scope of the rule. The NPC inspectors reviewed the licensec's MEL for compliance to 10 CFR $0.49. Areas reviewed included adequacy of the MEL, techrical .iustifications for removal of items from the MEL, and licensee reviews of the MEL changes due to field modifications. The inspectors verified the completeness / adequacy of the list in tems of equipment needed during accident conditions through review of piping and instrumentation drawings (P& IDS), emergency procedures, technical specifications, and FSARs.
No violations of NRC requirements were identified,
- c. EQ Maintenance and Surveillance Program The inspector reviewed specific maintenance, replacement, surveillance tests and inspections necessary to preserve the environmental qualifi-cation of EQ components identified on the MEL. EQ requirements in the licensee's maintenance procedures and EQ files were reviewed against maintenance records of selected equipment to verify performance of maintenance and surveillance activities at prescribed intervals.
Several deficiencies were identified in regard to gasket ('O' ring) inspection, lubrication, and torquing of EQ components. Subsequent to the NRC findings, the licensee performed an onsite review (OSR) of EQ equipment requiring maintenance and surveillance. The OSR resulted in several additional deficiencies being identified by licensee.
Details of all findings are noted below.
(1) Tarcet Rock Solenoid Valves, EQ Binder EQ-BB-HE10A EQ-BB-HE10A, Tab E, requires replacement of the RTV silicone rubber gasket every time the valve cover is removed. The licensee could not provide evidence that the cover gasket was replaced on solenoid valve ICV-8114 after the cover was removed during completion of Work Request A99999, dated January 31, 1987.
(2) Rosemount Pres.ure Transmi,tters, EQ Binder EQ-BB-061 tQ-BB-061, Tab E, requires inspection and cleaning of mating surfaces, lubrication of 'O' rings, and torquing of the housing cover each time the cover is removed. The licensee could not provide evidence that these activities were performed for pressure transnitters 1PT-MS-042, IPT-MS-043, IPT-MS-004 during calibration in May 1986 or prior to Unit I criticality in May 1987.
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(3) Westinchouse Motors. EQ Binder EQDP-AE-?
EQNJE-2 states tLtt r;otor qualific?tior. t resu .es that recomended mainter.cnce procedures are followed. An engineering study performed by Mobil Oil Company requires motor bearing oil to be replaced every twelve months. EQDP-AE-2 allows changing motor years orbearing) more . oil Forevery second exan.ple pump refueling outage motor 1RH0lPA (every bearing three oil was replaced on March 20, 1987, while the next oil replacement is scheduled for November 30, 1989. The licensee did not have adequatejustificationfornotmeetingthevendor(Mobil 011) requirements.
(4) Limitorque Valves E0 Binder EQ-BB-027 EQ-BB-027. Tab E, requires the main gear case lubricant to be inspected in accordance with Limitorque Lubrication Inspection Procedure, LC-8. Procedure LC-8 specifies lubricant inspection every 18 months until operation history indicates otherwise.
EQ-BB-027. Tab E, as revised on October 17, 1986, however, also contains conflicting requirements that allow lubricant inspection to be performed at every second refueling outage (every three years or more). The licensee could not provide operating history data or engineering justification for extending the lubricant inspection f requency from 18 months to three years.
For example the EQ General Surveillance System (GSRV) for Limitorque Valve ICS-001A-LOS indicated that the last inspection date of the main gear case lubricant was October 14, 1986, and that the next due date was November 30, 1989. In addition, the inspectors observed that the last lubricant inspection actua.ly occurred on January 1, 1986 and not on October 14, 1986 as recorded in the EQ GSRV program. These discrepancies in EQ scheduling could have resulted in a lubricant inspection frequency of over three (3) years and eleven (11) months for Limitorque valve ICS-001A-LOS.
(5) Valcor Valves, EQ Binder E0-BB-064 Braidwood EQ maintenance instructions required installation of new 'O' rings whenever the housing cover of the solenoid valve is removed. The OSR identified 'O' rings as not having been replaced on Units 1 and 2 Valcor valves PS-228A and B, PS-229A and B. PS-230A and B, IRC 014C and 0, and 2RC014A, B, Cr and D.
The licensee has subsequently replaced the 'O' rings ,or, reactor head vent velves IRC014C and D, and 2RC014A, B, C and D. The licensee also provided evidence that the remaining primary process sampling valves do not require sealing fron noisture intrusion based on the postulated accident environment at the valve location.
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f (0) Incore Thernoccuple Reference Junction Bo> , EQ Binder EON ESE-m Erciccod EC rnair.ter.ar.ce instructions require replacement of the en:losurc 'O' ring each time the cover of the junction box is opened. The OSR identified that the 'O' ring was not replaced when the cover was removed on Junction Box 21T-OlJ, l during performance of Work Request A99999, dated February 5, i
1988. The licensee has subsequently installed a new 'O' ring in the junction box.
(7) NAMCO Limit Switch 151-0018-A-25 The licensee was unable to verify that the Limit Switch cover had been torqued as required by EQ maintenance instructions.
The licensse subsequently torqued the cover, as required, per Nuclear Work Request A20704.
(8) Limitorque Operators, Unit 1 The licensee could not provide evidence that EQ installation requirements for torquing of mounting bolts and valve actuator housings had been met. Subsequent to this finding, the licensee initiated Nuclear Work Request A20661 to torque the mounting bolts on approximately (86) Limitorque operators.
(9) Westinghouse Pump Motors. EQ Binder EQDP-AE-2 1
The OSR identified unqualified Mobil DTE Heavy Medium oil being l used for motor bearing lubrication. The qualified lubricant is i Mobil DTE Medium oil, as required by the EQ maintenance documen- '
tation. The licensee subsequently replaced the Heavy Medium oil l in Westinghouse Motors with Medium oil. l l
(10) Reliance and Westinghouse Fan Motors, EQ Binders EQ-BB-008 l l
EQ-BB-008 specifies Chevron SRI-2 as the qualified motor bearing i lubricant. The OSR, however, identified the use of Mobilux EP in lieu of the Chevron SRI-2 for these motors. The licensee has subsequently replaced Mobilux EP with Chevron SRI-2, per Nuclear Work Requests A20738, A20739, and A20771.
Each of the findings described in Section 4c (1) through (10) is considered a potential violation of 10 CFR 50.49, in that the compr. ants were not qualified for their installed conditions.
Pending further hRC review, these concerns are considered part of one Potentially Enforceable Unresolved item (No. 456/88005-02(DRS);
No. 457/88006-02(DRS)).
- d. Plant Procurement of 10 CFR 50.49 Designated Equipment Licensee procedures were found to adequately address procurement of appropriate replacement equipment. Procurement procedures and docu-ments were found to adequately address appropriate quality and regulatory requirements regarding the environmental qualification 10
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I i of equipment within the scope of 10 CFR 50.49. Checilists stre cMerved to have been used to provide evidence of revie.a anc approvals.
No violations of hRC requirements wert identified.
- e. Quality Assurance (QA) and Trainino Proaram (1) During review of licensee quality assurance activities, the inspectors determined that the licensee had implemented a program to monitor the quality of EQ activities through surveillance, audits, and reviews of the records and files for plant modifications and equipment procurement. NRC inspectors reviewed the 'icensee's QA audits including QA Audit Nos. 06-80-15 and 06-87-15 conducted in May 1986 and May 1987, and found the methodology acceptable. The inspectors were, however, concerned that in view of the NRC findings identified during this EQ inspection the scope of the licensee's quality assurance activities may not be adequate.
(2) The NRC inspectors also reviewed the licensee's staff training program and associated records relative to the performance of EQ activities. The training records indicated that the licensee had implemented a formal EQ training program for newly hired personnel; however, there was no evidence that other appropriate staff (management, operations and maintenance)
. responsible for EQ activities had received this training. In addition, the inspectors were concerned that the deficiencies identified in the implementation of maintenance activities (as noted in Section 4c of this report) were a result of inadaquats training of appropriate personnel. The licensee has agreed to incorporate EQ training into an ongoing training program for appropriate plant personnel.
Pending further review of the licensee's QA and training activities in regard to EQ this is considered an Open Item (No. 456/88005-03(DRS);
No. 50-457/88006-03(DRS)).
- 5. Detailed Review of Qualification Files The licensee qualified their EQ vquipment to the requirements of NUREG 0588 Category I (10 CFR 50.49, Patagraph K). The inspectors reviewed over 40 equipment qualification files for evidence of the environmental qualification of equipment within the scope of 10 CFR 50.49, and evidence of equipment qualification to NUREG 0588, Category 1. Files addressed the description of the equipment; similarity analysis of tested equipment to that installed in the plant; allowed mounting methods and orientation; qualification of interfaces (conduit, housing, seal, etc.);
evaluation of aging effects on equipment; description of test sequence and methodology; environmental conditions for the equipment during an accident; qualification for submergence of applicable equipment; resolution of test anomalies; and maintenance / surveillance criteria for the preservation of the qualified status of equipment.
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e l The inspectors selectivcly rc> viewed the above areas, as applicabic, including special revieg for the required caration cf operability of eq uips.e nt ; licensee haluation of tested r.ncriais and configurations relative to actual plant installations; adequacy of test conditions; aging calculations for cualified life and replacement intervals; effects l of decreases in insulation resistance on equipment performance; adequacy
- of demonstrated accuracy of equipment and interfaces during an accident; and licensee evaluations of discrepancies identified in IE Notices and Bulletins.
EQ files were reviewed for electrical cables, cable splices, teminations, terminal blocks, electric motors, solenoid valves, electrical penetrations, seals, lubricants, transmitters, temperature elements, radiation monitors, control and position switches, switchgear, enntrol panels and miscellaneous electrical devices. The inspectors identified several deficiencies in the adequacy of the test documentation. Details are noted below, i a. Bunker Ramo Electrical Penetration Assemblies, File EQ-BB-058 The inspectors reviewed the following reports contained in the EQ file for the qualification of low voltage Bunker Ramo electrical assemblies to the requirements of NUREG 0588, Category 1.
Amphenol Report 123-2220, "Design Qualification Report for Electrical Penetration Assemblies," Revision 4, October 10, 1 -
1979.
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. Amphenol Report 123-2159, "Qualification Test Procedure for i Nuclear Power Generating Station Electrical Penetration j Assemblies," June 1,1979.
) The licensee confirmed that 10 CFR 50.49 designated Bunker Ramo
! penetrations were used in Braidwood Unit 2 for instrumentation i circuits inside the containment.
The Amphenol test report 123-2220 addressed a generic qualification of several models of Bunker Ramo penetrations but did not test a penetration identical to that installed at Braidwood. During the EQ file review, the inspectors observed that significantly low insulation resistance (IR) readings were recorded during the LOCA test on the instrumentation penetrations. Of (81) measurements taken only (14) were at the design minimum value of 106 ohms or higher. The licensee identified these low readings as "anomalies,"
and claimed that the suspected anomalies were due to terminal blocks used in the tested configuration. The licensee also stated that these anomalies had been corrected by installing qualified splices instead of terminal blocks in the plant. The inspectors, however, noted that the licensee had not confirmed through additional testing whether the low IR values had in fact been corrected by the installed qualified splices.
NUREG 058S, Category 1, Section 2.1(3)(a), requires equipment to be qualified by test to demonstrate its operability under harsh conditions. NUREG 0588, Category 1, Section 2.2(a) requires that 12
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O the failure criteria be established prior to testing. The inspectors concluded that th( licensee had net perforced A test to cualify the ira t ru et ra r,e t ra tic ra ' t. their irstalled cor.figsratierl (with the splico). The ir.spectors also noted that the Sunker Rame test was inadequate in that r.o failurc criterion had been established for the i LOCA portion of the testing. The inspectors concluded that the penetrations were unqualified based on inadequate documentation.
Subsequent to this NRC finding, the licensee identified four suspect Bunker Ramo instrument penetrations (2510$E, 25106E, 25107E and 2510SE) installed at Braidwood Unit 2. None were reported in Unit 1. The specific instruments associated with these circuits provide necessary inputs to the Reactor Protection System (RPS) and Engineering Safety Features (ESF) actuation systems. Some instruments also provide post accident monitoring functions.
The affected instruments are required to mitigate a LOCA, main feedwater line break, and a main steam line break in the resulting harsh environments. Parameters measured by the instruments for RPS and ESF actuation include hot leg and cold leg temperature, reactor coolant loop hot leg wide range temperature, reactor coolant loop flow, steam generator loop steam flow, steam generator narrow and wide range level, pressurizer pressure, pressurizer level, hot leg wide range pressure, reactor coolant pump bearing water flow, source and intermediate range neutron detection, and power range neutron detection. .
l The inspectors infomed the licensee of the need to follow the requirements of Generic Letter 88-07 and submit an operability analysis, l or retest the suspect penetrations, or replace the penetrations. On i March 5,1988, the licensee submitted an operability analysis to the I NRC. Subsequent to the Rill findings, NRR assumed the lead responsi- l bility for reviewing the qualification of the Bunker Ramo penetrations.
Pending further NRC review this is a Potentially Enforceable Unresolved item (No. 456/88005-04(DRS);No.457/88006-04(DRS)).
- b. , Joy / Reliance Fan Motors, Model 500826-2047, EQ Binder EQ-BB-009 The EQ file stated that the motor bearings were qualified for 40 years.
The Reliance report, NUC-12, dated October 30, 1978 (in the licensee's EQ file), however, stated that according to the Antifriction Bearing Manufacturers Association (AFBMA) Standard No. 9. bearings of motors cannot have a specific qualified life, in addition, Reliance Electric !
(vendor) retommended that the bearings be treated as a replaceable element. Tie licensee was requested to provide documentation to support their claim that the motor bearing were qualified for 40 years. 1 Subsequent to this concern, the licensee provided a calculation supporting a motor bearing life of 40 years. The calculation, Sargent and Lundy document CQD-010212 dated August 31, 1978 is to be added to :
the EQ file. Pending review of revised files, this is considered an Open item (No. 456/SS005-05(DR5); No. 467/88006-05(DRS)).
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- c. Tarcet Roci Solenoid Yalves Model 79AB-010, EQ Einder E0-EB-HE10A Revin of this file indicated that the cualifiec lif t; calculaticos I for the solenoid valves wcre based on a normel traximum te9ereture of 122'F. The valves, however, are located in a :one where the maximum temperature is expected to reach 130'F. Subsequent to this ;
concern, the licensee produced a calculation by Sargent and Lundy (transmittal COD-037264, dated September 9,1987) which used the correct temperature data basis and adjusted the qualification life.
The licensee indicated that the calculation is still awaiting final approval. The maintenance data sheet in the EQ binders will also be changed to reflect the correct qualified life and replacement schedule. Pending further review, this is considered an Open Item ,
(No. 456/88005-06(DRS); No. 457/88006-06(DRS)), t
- d. ITT Barton Model 752 Transmitters, EQ Binder FQDP-ESE-4A The inspectors noted that the "auditable link" document for the qualification of the Barton transmitters provided by Westinghouse
! was not included in the EQ file. The licensee comitted to incorporate this document into the next revision of EQ Binder EQDP-ESE-4A.
The inspectors also noted that no thermal aging analysis or radiation analysis had been provided in the binder - merely a statement that the five year qualified life would be verified. The licensee stated that the radiation analysis is provided in Westinghouse WCAP-8587,
, and that this document has been reviewed and accepted by the NRC. The J licensee agreed to include the aging analysis in the qualification binder when it is revised. Pending NRC review of licensee corrective l A
action of both the above issues, this is an Open Item (No. 456/88005-0/(DRS); No. 457/88006-0/(DRS)).
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- e. General Atomic Area Radiation Monitors EQ Binder. EQ-BB-060 ;
The inspectors observed that no documentation had been provided for I the qualification of the Tefzel insulation (Tab C), in that the l referenced reports (Okonite and Clinton) were not in the binder. The ;
i inspector concluded that the similarity between the detector wiring i and tested wiring had not been established. The licensee stated that l the referenced documents would be included in the next revision of
- the binder to establish similarity. Sufficient interim information was provided by the licensee to mitigate any irmediate safety concerns.
The inspectors also observed that no qualification documentation had i been provided in the binder for the penetration connector interface. l in that the the connector has not been properly identified or analyzed. l The licensee stated that since the subject device did not have to be '
functional during LOCA or post LOCA conditions, the qualification of 2
the connector was not of concern, end that the adequacy of the cable assembly and the connector would be verified during calibration for nomal operation. The licensee agreed th?t the connector will be identified in the next revision of the binder.
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Pending further review of licensee correctise action of both of the et>cs c issues, this is an 0;,en Iter (he. 456/EE005-0S(DES);
he. 4L7/C.LD30-DL(;EZ).
- 6. Plant Pnysical Inspection The NRC inspectors selected over 50 items on the MEL for examination in the plant. The EQ file of each item had been reviewed, and inic,rcation regarding the location, manufacturer, model/ serial number, mounting, orientation, environment, and interfaces had been noted. The inspectors examined the selected items in the field, as accessible, and examine:
each item to confirm if it confomed to its environmental qualific.: tic,n.
Specific areas reviewed included traceability of installed items to EQ files, ambient environmental conditions, qualification of interfaces (connectors, wires, seals, insulation, lubricants, etc.), evidence of significant temperature rise from process, drainage, mounting methods, physical conditions, and housekeeping. Certain significant deficiencies were identified in regard to EQ equipment not being qualified by test or analysis for their installed configuration. Details are noted below:
- a. Marathon 1600 NUC Terminal Blocks The Marathon terminal blocks were addressed by the licensee as qualified to the requirements of NUREG 0588, Category 1. These j blocks are used in control circuits inside the containment. During the EQ test conducted at Wyle, terminal blocks located directly beneath the top-entry conduits were observed to experience higher leakage currents (300 MA) than the block r.ot directly below the top conduit entry (30 MA). In order to address this deficiency, the licensee required drip shields and weep holes to be provided for all Marathon terminal blocks located directly below top entry conduits and in a steam environment.
Subsequent to NRC inspector findings in the area of maintenance and surveillance (see Section 4c of this report), the licensee conducted an onsite review (OSR) of EQ equipment. During this review, the licensee examined all (40) EQ designated junction boxes inside the containment. Of the boxes inspected (16) weep holes and (8) drip shields were found missing.
The inspectors determined that the lack of weep holes and drip shields compromised the EQ of the circuits in the boxes, in that spray and/or moisture intrusion into the boxes would cause the circuits to fail.
The licensee has subsequently performed corrective action and reported that no other junction boxes were affected.
Pending further review, this is a Potentially Enforceable Unresolved Item (No. 456/8S005-09(DRS); No. 457/88006-09(ORS)).
- b. GECO Pressure Switches EQ binders BB-025, 56 and 57 specify Whitman General Pressure switches, Models 86619, 80 M , 85743, 6S946, E6915, 88736 as qualified for use in the w rg Warner Actuators. During the OSR, the licensee identified 15
( t i t
e the use of a pressure switch, Model J505, mace by GECO and installed in conjunction with several EQ valves in the plant. Subsu;uent to ints fincing, the licensee reported inet they cic not h m sui:u ient cote to qu611fy the J5v5 bECO switch for its EV cpplicatien in the plaht.
The licensee identified the use of several of these switches in conjunction with the feedwater isolation valves, containment purge isolation valves, and steum generator power oper a ted relief valves.
The licensee has subsequently replaced the switches for the feed.io,er isolation valves, and has submitted an adequate operability analysis for the switches associated with the containment purge and steam generator power operated valves. The remaining switches will be replaced or qualified by the next outage. Pending further review, this is considered a Potentially Enforceable Unresolved Item (No. 456/88005-10(DRS); No. 457/88006-10(DRS)). !
- c. Mixed Lubricants in Limitorque Operators During review of the licensee's maintenance activities (see Section 4c of this report), the NRC inspectors identified deficiencies in the frequency of lubricant surveillance / replacement in EQ actuators, motors and fans. Subsequent to these NRC findings, the licensee performed an i onsite review to examine the installed lubricants to determine if any degradation had occurred since they were last replaced. Based on this revie.:, the licensee reported mixed proportions of a Calcium based and a Lithium base lubricant in several EQ actuators. The mixed proportions l were reported to range from 2% Lithium /98% Calcium to 50% Lithium /50%
Calcium based lubricants in different actuators. These lubricants are stated by the licensee to be Exxon Nebula EP-0 Exxon Nebula EP-1 !
(Calcium complex base) and Sun EP-50 (Lead Lithium base). The licensee, however, could not present adequate test data or analysis based on the test data to demonstrate that the mixed greases were qualified for the postulated ambient plus accident environments. Region III subsequently informed the licensee that the affected 10 CFR 50.49 ,
designated valve actuators were unqualified based on inadequate documentation.
The licensee perfomed the following corrective actions:
(1) Sampling of (222) potentially affected 10 CFR 50.49 designated Limitorque actuators. Sampling included drawing samples from the Limitorque main gear cases as accessible. These samples were then reported to be reviewed visually for quality (dirt, water, metal filings) and for consistency. If visual inconsis-tencies were found, the lubricant was reported to be replaced.
(2) All drawn samples then underwent a chemical analysis so as to identify any mixed greases. Any sample having a mixture of over 1:50 Lithium to Calcium was subjected to a penetration test. Any lubricant having a mixture of 1:50 or less Lithium to Calcium was declared acceptable by the licensee.
(3) The proposed penetration test was conducted with an acceptance 16
c' *
% ( <
1 range of 230 points above or bele, an acceptance redian cf 325 points for Exxon htbula EP-1 and 370 pcints for E>xon hebula EP-0. Any sarple ha$1r4 a Calciur/ Lithium riis ture with a Lithium contaminant of over St will be rejected, and thc-affected valve will be regreased prior to plant startup.
Samples having a contaminant of 2 to 51 will be replaced in Unit 2 prior to criticality. Samples having a contaminant of 2 to 5*. in Unit I will also be subsequently replaced during the next outage. Samples having a containment of up to 21 is being considered acceptable by the licensee.
Subsequent to the Region 111 finding 1, NRR assumed the lead in reviewing the qualification and oper ibility of the affected Limitorque operators in regard to mixed lubricants. Pending further NRC review, this is a Potentially Enforceable Unresolved item (No. 456/88005-11(DRS);
No. 457/88006-11(DRS)),
- d. General Atomic Radiation Monitor During examination of the General Atomic high range radiation monitor assembly, a split (crack) was noted on one Raychem heat shrink tube insulating a coaxial connector. The inspectors were concerned that this deficiency would increase leakage currents and affect the accuracy of the monitor.
The licensee's response stated that this was an isolated deficiency and that NWR A20577 had been written for replacement of the tubing.
They also agreed to check both high range monitors for any other such deficiency. Pending further review of licensee action in this area, this is considered an Open Item (No. 456/88005-12(DRS);
No. 457/88006-12(DRS)).
- e. Tobar Pressure Transmitters Tobar transmitter 2PT-403 was found in the field to have one loose cover bolt. This pressure transmitter was calibrated on February 25, 1988. Subsequent to the finding, the licensee took corrective action ;
and confinned that the cover screw was tightened as required per :
NWR A20549 on March 3, 1988. ;
, The inspectors also noted that the nameplate on Tobar Transmitter 2PT-407 indicated Model No. 32PA1212/94002/1.A2, while the SCEW sheet indicated 76PH24-333/94002. The licensee responded that both l models were identical, even though the model (76PH2) shown on the SCEk' sheets was that of a Veritrak transmitter and the model (No. 32PA1) shown on the nameplate of 2PT-407 was that of a Tobar transmitter. Apparently after Veritrak was acquired by Tobar, this ,
model was re-designated as model No. 32PA1 (by Tobar). The licensee agreed to revise the SCEW sheets to eliminate this concern.
No further concerns were identified. ;
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- f. Limitorque Actuator 2CC-9438 During c>arinatior,of this actuator in the fiele, the ir.spettors
- r. cite that a shipping cap was installed in the grease relief valve.
Ttt- licensee apparently had not looked for shipping caps installed inside the grease relief valves during previous inspections. Another inspection was performed by the licensee for all Limitorque operators inside the containment and the licensee identified no additional shipping caps installed inside the grease relief valves. The licensee subsequently issued a maintenance work order to rerreve the cap.
No further concerns were identified.
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- g. Bunker Ramo Electrical Penetration Assembly Two 3-lb coffee cans filled with a white granular substance were found insic; the penetration junction box assembly for penetration 21C19E. The licensee was not able to provide information on the purpose of these cans or identify the substance. The cans have subsequently been removed. No further concerns were identified.
. h. ASCO NP Series Solenoid Valves During the plant walkdown of ASCO valve 21A066-FSV (plant identification number), it was noted that an associated valve was tagged 1A0V-IA066, while it should have been tagged 2A0V-IA066.
The licensee subsequently corrected the tag. No further concerns were identified.
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- 7. Open Items 1
Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open Items disclosed during j this inspection are discussed in Paragraphs 4c, 5b, Sc, 5d, Se, and 6o.
- 8. Potentially Enforceable / Unresolved Items l
An unresolved item is a r.atter abod which more information is required in order to ascertain whether it is an acceptable item, an open l tem, a
- deviation, or a violation. Pot 2ntiall discussed in Paragraphs 2, 4c(i)(2)(3)y Enforceable / Unresolved items are(4)(5) and 6c.
- 9. Exit Interview
, The Region !!! inspectors met with the licensee's representatives l (denoted under Paragraph 1) dur',ng an interin exit on March 4,1968, i and discussed their findings at the conclusion of the inspection on May 4, 1988. The inspectors discussed the likely content of the
- inspection report with regard to document or processes reviewed by the inspectors. The licensee did not identify any such documents or processes as proprietary.
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