ML20198F263
| ML20198F263 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/07/1985 |
| From: | Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20198F255 | List: |
| References | |
| 50-324-85-26, 50-325-85-26, NUDOCS 8511140306 | |
| Download: ML20198F263 (15) | |
See also: IR 05000324/1985026
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report No.:
50-325/324:85-26
Docket No.:
50-325/324
License No.:
Licensee:
Carolina Power & Light Company
Po::c Office Box 1551
Raleigh, North Carolina 27602
Facility Name:
Brunswick Steam Electric Plant, Units 1 and 2
Inspection At:
Southport, North Carolina
Inspection Conducted:
August 12-16, 1985
Inspector:
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G. T. Hubbard, Equipn gnt Qualification & Test Engineer
Date
Also participating in the inspection and contributing to the report were:
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U. Potapovs, Chief, Equipment Qualification Inspection Section, I&E
R. O. Karsch, Reactor Engineer, NRR
P. Shemanski, Engineer, NRR
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E. H. Richards, Member of Technical Staff, Sandia National Laboratories
M. W. Yost, Consultant Engineer, Iuaho National Engineering Laboratory
N. Merriweather, Reactor Inspector, RII
3 ><-
L. E. Foster, Reactor Inspector, RII
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Approved by:
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IL ~? -b3 5-
Uldis Potapo'vs, Chief,I .quipment Qualification
Inspection Section, VPB, I&E
8511140306 851112
ADOCK 05000324
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INSPECTION SUMMARY:
Inspection on August 12-16, 1985 (Inspection Report No. 50-325/324:85-26)
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.
The inspection also included evaluations of the
implementation of equipment qualification (EQ) corrective action commitments
made as a result of deficiencies identified in the December 20, 1982 Safety
Evaluation Report (SER) and the August 6,1982 Franklin Research Center (FRC)
Technical Evaluation Reports (TERs).
The inspection involved 227 inspector
hours onsite.
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.
No deficiencies were found in the licensee's implementation of corrective
action commitments made as a result of SER/TER identified deficiencies.
Report
Item
Paragraph
Number
Potential Enforcement / Unresolved Item:
1.
Qualified Status of Installed
Equipment / Establishment of
EQ Maintenance Requirements
in Plant Procedures
4.A.(4)
50-325/324:85-26-05
2.
Procurement of Replacement Parts
4.A.(2)
50-325/324:85-26-04
3.
Inclusion of Rockbestos
Coaxial Cable on EQ List
4.D.(4)
50-325/324:85-26-10
4.
Qualification of Rockbestos
Firewall III Cable
4.D.(5)
50-325/324:85-26-11
Open Items:
1.
Sign-offs of Qualification Data
Packages (QDPs)
4.A.(1)
50-325/324:85-26-01
2.
Completion of QDPs
4.A.(1)
50-325/324:85-26-02
3.
Generic File Improvement
4.A.(1)
50-325/324:85-26-03
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4.
Damaged Cable on Installed NDT
International Accelerometer
4.C
50-325/324:85-26-06
5.
Westinghouse Electrical
Penetration Assemblies
4.D.(2)
50-325/324:85-26-07
6.
Barton 289A Pressure Switches
4.D.(3)
50-325/324:85-26-08
7.
NDT International Accelerometer
4.D.(4)
50-325/324:85-26-09
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DETAILS
1.
PERSONS CONTACTED
~1.1 Carolina Power and Light Company (CP&L)
- A. B. Cutter, Vice President, Nuclear Engineering & Licensing
- P. W. Howe, Vice President, Brunswick Nuclear Project
- C. R. Dietz, General Manager, Brunswick Steam Electric Plant (BSEP)
R. L. Morris, EQ Engineer
- T. H. Wyllie, Manager, Engineering and Cons'.ruction
- R. M. Poulk, Jr. , Senior Specialist-Regulatory Compliance
- B. E. Hinkley, Manager, Technical Support
- R. A. Schwager, Project Engineer
- P. Salas, Engineer
- S. D. Floyd, Principal Engineer
- J. O'Sullivan, Manager Maintenaace
- B. Parks, Jr., Engineering Supervisor
- C. R. Dres, Engineer-Maintenance
- W. P. Guarino, Specialist
- A. Richards, Principal Engineer - QA/QC
- W. R. Murray, Senior Engineer - Licensing
- W. Dorman, QA Supervisor
- D .: Baur, QA Supervisor
- L. Rothman, Principal Engineer
- H. Wagner, QA Specialist
- M. Rogers, QA Engineer
- F. Emerson, Project Engineer-0nsite Nuclear Safety
- R. Phillips, Engineer-Technical Support
B. Altman, Project Engineer, Maintenance Programs
S. Edge, Environmental and Chemistry Technician
- J. S. Dietrich, Project Engineering-Licensing
- K. E. Enzor, Director-Regulatory Compliance
- H. C. Brinkmann, Resident Engineer, Brunswick Engineering Support
Unit (BESU)
M. K. Sharma, Engineer
1. 2 CP&L Contractors
- D. R. Rhyne, EQ Supervisor - BESU, United Engineers & Constructors,
Inc. (UE&C)
- L. C. Suttle, Representative, Power Agency
- R. K. Ho, EPM, Consultant to Nuclear Utility Group on Equipment
Qualification
- D. Datson, Consultant-Technical Support, Cofer Associates
B. Messitt, Engineer, UE&C
F. Roy, Engineer, Patel
1. 3 Nuclear Regulatory Commission
- G. G. Zech, Chief, Vendor Program Branch, I&E
- L. Barner, Resident Inspector
- T. Hicks, Resident Inspector
- A.
F. Gibson, Division Director, RII
- M. Grotenhuis, Project Manager, NRR
- Denotes those present at the exit interview at Brunswick on August 16, 1985
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2.
PURPOSE
The purpose of this inspection was to review the licensee's implementation
of the requirements of 10 CFR 50.49 and the implementation of committed
corrective actions for SER/TER identified deficiencies.
3.
BACKGROUND
On February 2, 1984 the NRC held a meeting with CP&L officials to discuss
CP&L's proposed methods to resolve the EQ deficiencies identified in the
December 20, 1982 SER and August 6, 1982 FRC TERs.
Discussions also
included CP&L'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 a March 23, 1984 submittal from the
licensee.
In addition to the March 23 submittal, three other licensee
submittals dated September 26 and November 5, 1984 and June 28, 1985
were reviewed by the inspection team and were used to establish a status
baseline for the inspection.
At the time of the inspection, BSEP Unit 1 was in its second refueling
outage after March 31, 1982 and is scheduled to be in full compliance
with 10 CFR 50.49 at the end of the outage.
BSEP Unit 2 was operational
during the inspection and was required to be in compliance with the rule
except for certain items of equipment for which JCOs had been submitted
and for which the Director of NRR had granted a schedular extension
until November 30, 1985.
4.
FINDINGS
A.
EQ Program Compliance with 10 CFR 50.49
The NRC inspectors examined the licensee's program for establishing
the qualification of electric equipment within the scope of
The program was evaluated by examination of the
licensee's qualification documentation files, examination of
procedures which control the licensee's EQ efforts, verification
of the adequacy and accuracy of the licensee's 10 CFR 50.49 equipment
list, and examination of the licensee's program for maintaining the
qualified scatus of the covered electrical equipment.
Based on the inspection findings, which are discussed in more detail
b'elow, the inspection team determined that the licensee has implemented
a program to meet the requirements of 10 CFR 50.49, although four
Potential Enforcement / Unresolved Items and 7 Open Items were
identified.
(1) Qualification Files, General
The NRC inspectors determined that BSEP's implemented program
provides for the preparation of qualification documentation
files for equipment within the scope of 10 CFR 50.49.
The
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licensee's program, which is described in " Program Document
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Lfor Compliance with 10 CFR 50.49," PLP-02, Revision 000 and
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.other documents referenced in PLP-02, requires the
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establishment of Equipment Qualification Packages (EQPs) by
BESU. These EQPs are the documents that establish qualifi-
cation for all pieces of equipment at BSEP within the scope
of 10 CFR 50.49.
Each EQP includes the following:
-Qualification Summary with
Equipment Description
Documentation References
Discussion of Qualification Methods
Discussion of Similarity of Tested versus
Installed Equipment
Discussion of Equipment Installation
Requirements
Discussion of Testing / Analysis versus
Service Conditions
Conclusion Regarding Qualification including
Standards / Regulation to Which Item is Qualified
Qualification Evaluation Checklist
(This is an indepth documentation of the evaluation
summarized above)
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Resolution of NRC IE Information Notices
After the EQPs are prepared and approved by BESU, they are
provided to the BSEP Technical Support Group who establishes
EQ equipment maintenance requirements and documents them on EQ
Maintenance Summary-(EQMS) sheets.
The EQPs are then combined
with the EQMS sheets to form Qualification Data Packages (QDPs)
which are reviewed and approved as a total package.
The
inspection team determined that while EQPs and EQMS sheets had
been prepared, approved, and assembled into QDPs, none of the
QDPs~had been reviewed and approved.
BSEP personnel stated that
they wanted to perform a final review of the QDPs before they
approved them.
Since the EQPs and EQMS sheets were individually
prepared, reviewed, and approved and the-QDP is a formal method
of assembling the EQPs with the EQMS sheets in one file, the
team identified the lack of QDP approvals as an open item which
.will be reviewed during a future NRC inspection (50-325/324:
85-26-01).
-The inspection team determined that BSEP had not completed EQPs
and/or EQMSs for all equipment within the scope of 10 CFR 50.49.
However, the team also. established that the EQPs and/or EQMSs
which were not complete were:
(1) applicable only to BSEP
-Unit 1, which did not have to be in compliance with the rule
until the end of the present outage or (2). covered by JCOs and
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-the schedular extension granted September 28, 1984 for
operation of Unit 2 until November 30, 1985.
The completion
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.of these EQPs/EQMSs and subsequent QDPs is considered an open
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item which will be reviewed during a future NRC inspection
'(50-325/324:85-26-02).
The inspection team's review of the QDPs determined that they
were detailed and auditable; however, several generic recommen-
dations were discussed with BSEP.
One specific recommendation
pertained to.the lack of consistent answers by different~
checklist preparers. for the . questions in EQP,Section II,
paragraph D.4.a and b. concerning thermal. aging methodology.
Another specific recommendation pertained to the adequacy of
BSEP information presented in the EQPs dealing with the resolution
of IE ins relative to equipment qualification (see discussion in
paragraph 4.E.). : Based on these discussions, BSEP agreed to
review and make appropriate changes to their packages and
procedures to assure that the EQPs provide an adequate, clear,
and consistent reflection of the qualification evaluations
performed and documented.
This is considered an open item and
the NRC will review BSEP efforts for improving the EQPs during a
future inspection (50-325/324:85-26-03).
(2) EQ Program Procedures
The NRC inspectors reviewed the licensee's plant program document
PLP-02 and other documents which describe in detail how the
licensee will control EQ equipment.
The program defines its
purpose, lists references associated with the EQ program, provides
definitions to prevent misinterpretations, and describes the
controls to be utilized during design changes, replacement of
parts, and modification and maintenance activities.
The program
requires that personnel performing technical assessments be
qualified.
The program-also assigns responsibilities to certain
organizations to help assure that the overall program will be
properly implemented.
The program requires that its edequacy
and effectiveness be assessed periodically per procedure
ENP-34.4 and that corrective actions will be initiated to
correct any deficiencies.
Although the licensee has not completely implemented his EQ
program (see discussions in paragraph 4.A.(1) and (4)), the
inspectors reviewed the as-implemented program to determine
that adequate procedures and controls had been establ khed and
implemented to meet the requirements of 10 CFR 50.49.
Additional program procedures reviewed (but not addressed
elsewhere in this report) in performing the program
implementation review included:
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BESU Manual of Instruction, Section 6.3, Environmental
Qualification of Class.1E Equipment
ENP-34.1, Design Control of Environmentally Qualified
Equipment
ENP-34.2, Environmental Qualification Equipment List
Control Procedure
ENP-34.3, Qualification Data Package Control Procedure
ENP-34.4, Environment Qualification Program Assessment
Procedure
ENP-34.5, EQ Technical Reviewer Certification Procedure
ENP-03, Plant Modification Procedure
ENP-03.1, Direct Replacement Procedure
ENP-12, Engineering Evaluation Procedure
MP-3, Calibration of Process Equipment
MP-04, General Maintenance Procedure
MP-10, Preventative Maintenance Procedure
MP-14, Corrective Maintenance Procedure
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MI-10-514F, RHR and Core Spray Pump Motor Insurance
Inspection, Rev. 000
MI-10-514G-1, large Motors Operatic. 1 Inspection
Reactor Building, Rev. 001
MI-10-500G, Annual Lubrication Change Schedule
MI-16-16A, Meggering and Bridging of Disconnected
Electric Motors
MI-10-5020, Motor Inspection and Cleaning External
Inspection
MI-10-2H, ITE 4KV Breaker and Compartment Checkout
The program implementation review identified a concern with the
licensee's program for replacement equipment, as discussed in
paragraph 4.4.3 of PLP-02, relative to the upgrading requirements
of paragraph (1) of 10 CFR 50.49.
The inspectors discussed the
replacement equipment program with the licensee and identified
the fact that replacement equipment could be purchased for
qualified electric equipment and not be in compliance
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with the upgrade requirements of 10 CFR 50.49.
Further the
inspectors were concerned that this might already have happened;
however, no specific examples were identified during the inspection.
Since the inspectors were not able to fully resolve this concern
during the inspection, this is considered a Potential Enforcement /
Unresolved Item (50-325/324:85-26-04).
(3) 10 CFR 50.49 List (EQ Master List)
The licensee is required to maintain an up-to-date list of the
equipment that must be qualified under 10 CFR 50.49.
This
list is entitled " Environmental Qualification Equipment List,"
Revision 1, dated August 8, 1985.
For ease of access and
control, this list is part of a computer controlled environmental
qualification data base.
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, Technical Specification limiting conditions of
operation, emergency operating procedures (E0Ps), piping and
instrumentation diagrams, and electrical distribution diagrams.
The details on how the EQ Master List was produced is detailed
in procedure PLP-02.
This procedure and Engineering Procedures
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ENP-34.1 and ENP 34.2 provide control of the EQ Master List to
maintain its accuracy.
Twelve items were used as an audit sample to verify the complete-
ness of the current EQ Master List.
In order to compile this
audit sample, an extensive review was conducted of the following
emergency procedures and piping and instrumentation drawings
(P& ids).
Brunswick has the new symptom-oriented E0Ps.
Five
flow charts are used to provide entry to correct E0Ps.
Emergency Procedures
E0P-01-UG, Users Guide, September 19, 1984
E0P-01-ACCP, ATWS-Containment Control Procedures, September 19, 1984
E0P-01-CCP, Containment Control Procedure, September 19, 1984
E0P-01-EDP, Emergency Depressurization Procedure, May 4, 1984
E0P-01-EPP-16, End Path Frocedure:
1L, (ATWS Rods not fully in)
May 4, 1984
E0P-01-EPP-1M, End Path Procedure:
1M, (Rods not fully in
Reactor Pressure 350 psig), May 4, 1984
P& ids
9527-D-h041,ServiceWaterSystenUnit2
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9527-D-2515, Containment Atmospheric Control System Unit 2,
Sheets 1A and 1B
9527-D-2560, Containment Atmospheric Control System Units 1 & 2,
Sheet 2B
9527-D-2537, Service Water System Unit 2, Sheets 1 & 2
9527-0-2522, Nuclear Steam Supply System Unit 2, Sheet 2A
9527-D-2523, High Pressure Coolant Injection System Unit 2,
Sheets 1 & 2
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9527-D-2524, Core Spray System Unit 2, Sheets 1 & 2
9527-D-2525, RHR System Unit 2, Sheets-1A & 1B
9527-D-2526, RHR System Unit 2, Sheets 2A & 2B
9527-D-2529, RCIC System Unit 2, Sheets 1 & 2
9527-F-4073, Reactor Building Ventilation System Air Flow
Diagram Unit 2, Sheet 2
9527-D-7029, Instrument Air Supply System Unit 2, Sheet-2A
9527-D-7070, R.B. Sampling System
.The audit sample was selected to verify that those items required
to be on the list are in fact on the list. _The sample also
included one item required for implementation of R.G. 1.97
(High Range Radiation Monitor including cable).
All sample items required to be on the EQ Master List were on
the list.
Certain other equipment items perform safety functions
which a casual review might include on the EQ Master List.
To
test the thoroughness of a licensee's review, the status of
selected items in this category were questioned.
The licensee
provided a satisfactory explanation why these items were not on
the list.
No deficiencies with the list were identified during
the list review; however, during the QDP review Rockbestos coaxial
cable (QDP-71) was identified as needing to be on the master list
and it was not (see discussion in paragraph 4.D.(4)).
(4) EQ Maintenance Program
The NRC inspectors determined that the licensee evaluates
equipment test data and vendor recommended EQ maintenance
activities in accordance with procedure ENP-34.3.
As a
result of the review, the licensee develops EQMS sheets which
are included as a part of the QDPs.
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The-licensee stated in their EQ program procedures that the
Technical Support Group would evaluate each QDP and develop
a list of EQ required maintenance activities and replacement
schedules for transmittal.to the plant maintenance department.
During the inspection, the licensee stated that this program was
just getting underway and maintenance information had not been
formally transmitted to the maintenance department for imple-
mentation.
Plant maintenance personnel stated that when they
received this. data they would develop and implement appropriate
maintenance procedures and include them in the existing
maintenance program.
Based on the inspectors' review of QDPs
and discussions with licensee personnel, the inspectors determined
that applicable in-use plant maintenance procedures.have not been
reviewed to determine if EQ required maintenance activities are
already included.
The inspectors advised the licensee that this
review of Unit 2 procedures should have been completed prior to
the outage restart of October 1984 and should be completed for
Unit 1 prior to restart from the current outage to assure that
the qualified status of 10 CFR 50.49 equipment has not been
violated.
Based on the above and the fact that the qualified status of
10 CFR 50.49 equipment for Unit 2 was of concern to the
inspectors, the items of equipment discussed below were
reviewed by the inspectors.
The NRC inspectors reviewed QDPs 25A and 25B for General Electric
(GE) motors used in the core spray (CS) and residual heat removal
(RHR) pumps for recommended EQ maintenance requirements.
The EQMS
sheets in the above QDPs specified only three required and one
recommended maintenance activities; however, the inspectors'
review of the vendor's Qualification Data Reports NEDC-30294 and
30939' revealed that not all the vendors recommended EQ maintenance
activities had been included in the EQMS sheets.
Additionally,
the licensee had not documented any justification as to why all
EQ maintenance activities had not been included in the EQMSs.
Specific activities in question were:
(1) The 500 Vdc megohm
resistance test every 6-12 months with the winding temperature
below 100 F and the resistance reading being equal to or greater
than 100 megohms; (2) the licensee usage of DTE 797 oil for
motor bearing lubrication when the vendor recomnended DTE heavy
medium oil; and (3) the frequency for inspecting bearing oil for
dirt and moisture.
While discussions and review of some licensee
GE motor maintenance data by the inspectors did not identify any
violation of the qualification status of the CS or RHR pumps, the
licensee agreed to re evaluate his EQMS sheets, contact the vendor,
and correct his maintenance program as applicable.
The inspectors reviewed QDP-46 for the Pyco (NECI) N145C3224P1
thermocouple and identified that the EQMSs required special
maintenance activities to be performed each time the head covers
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are removed. .These requirements included installing new head
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gaskets and retorquing the head cover to 50 foot pounds. When
questioned, the licensee stated that they had no procedures for
head cover removal.
The licensee further stated that they
replace.thermocouples and do not repair them. When the inspectors
asked questions concerning electrical connections (how performed,
seal, etc.) the licensee agreed to re evaluate requirements
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to determine if a special procedure is required.
The. inspectors also reviewed QDP-32 for Target Rock -SMS-A-01-2
solenoid valves and determined that according to the EQMS sheets
the solenoids should be replaced every 6 years.
The inspectors
determined that this requirement had not been implemented in the
licensee's maintenance program; however, the inspectors also
-determined that this replacement schedule was not exceeded
since the valve installation dates on Units 1 & 2 are
September 21, 1981 and September 30,.1982, respectively.
Based on the review of the licensee's overall EQ maintenance program,
the inspectors were concerned that some installed Unit 2 10 CFR 50.49
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equipment, other than the above items, might be unqualified due to-
.the licensee's failure to perform required EQ maintenance activities.
This concern regarding the qualified status of installed Unit 2
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equipment and BSEP's failure to include EQ maintenance requirements
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in plant maintenance' procedures is considered a Potential
Enforcement / Unresolved Item (50-325/324:85-26-05).
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-SER/TER Commitments
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~The NRC inspectors evaluated the implementation of EQ corrective
action commitments made as a result of1SER/TER identified deficiencies
as stated in licensee submittals dated March 23 and November 30,.1984.
The licensee had committed to completing all actions for Unit 1 prior
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For Unit 2, the licensee
- had committed to having all actions. completed at the end of the fall
1984 refueling outage except for equipment items which were covered by
the schedular extension granted September 28, 1984.
This e>tensionL
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allowed operation of Unit 2 until November 30, 1985.
Additionally,
the licensee identified in his January 28, 1985 answer to Generic
~ Letter 84-24 that additional equipment required to meet paragraph
(b)(3) of 10 CFR 50.49 and R.G. 1.97 would be identified and qualified
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in a separate R.G. 1.97 program.
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Based on review of files for which the licensee had completed his
corrective action commitments, the licensee's 10 CFR 50.49 Master
-List, and the plant physical inspection, the NRC inspectors
identified no deficiencies in the implementation of SER/TER
commitments.
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C.
Plant Physical Inspection
~ The' plant physical inspection consisted.of the examination of eight
types of safety-related equipment located either outside the drywell
- on Units 1 and 2 or inside the drywell on Unit 1.
The-inspectors
= examined characteristics such as mounting configuration, orientation,
. interfaces, model number, environment, and physical condition.
One concern was identified during the physical inspection.
The
. inspection identified that-the coaxial cable jacket fo the accelerometer
installation located near Target Rock soienoid valve 1-b21-F013J on
. Unit 1 had been cut exposing the shield. The licensee indicated that
this installation was new and had not been inspected for turnover.
, During the exit meeting the licensee stated that quality-inspection
had identified and documented the damaged cable jacket and appropriate
' corrective action would be.taken prior to Unit 1 restart.
Correction
.of the damaged jacket is considered an open item which will be
reviewed during a future NRC inspection (85-325/324:85-26-06).
D.
Detailed Review of Qualification Files
The NRCLinspectors examined 19 QOPs for selected equipment types 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 reviewed areas such as required post-
' accident operating time' compared to the duration of time the equipment
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has been demonstrated to be qualified, similarity of tested equipment
to that installed'in the plant (e.g., insulation class, materials of
components of the equipment, test configuration compared to installed
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configuration, and documentation of both), evaluation of adequacy of
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test conditions, aging calculations for qualified life and replacement
interval' determination, effects of decreases in insulation resistance
.on equipment performance, adequacy of demonstrated accuracy, evaluation
of' test anomalies, and applicability of EQ-problems reported in IE'
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ins / Bulletins and their resolution.
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(1) The NRC inspectors' review of the QDPs identified ten files which
contained; (1) information that was not clear-and/or was contra-
dictory, (2) incomplete references to supporting documentation,
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and/or (3) information that did not appear to adequately support
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qualification.
The identified concerns were discussed with the
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licensee who was able to satisfactorily resolve all concerns based
on data available during the inspection.
Additionally, the licensee
made changes (in accordance with approved procedures) to the ten
QDPs to clear up the concerns and clearly document qualification
of the equipment.
These changes were provided to the inspection
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team for review prior to the end of the inspection.
Based on the
inspectors' review of the updated files, the following files are
considered acceptable and no file followup review is required:
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-QDP-21
Kynar Heat Shrink Insulation
.QDP-25A GE Motor - Core Spray
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QDP-32
- QDP-40
Static 0-Ring Pressure Switch
QDP-46
Pyco (NECI) Thermocouple
QDP-51
Hydrogen-Oxygen Analyzer
QDP-56
Rosemount 1152 Pressure Transmitter
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QDP-57
NDT International Preamplifier
QDP-59
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- QDP-66
1 Robert-Shaw Level Switch
QDP-71
GE CR151 Terminal Block
(2) The NRC. inspectors' review of QDP-14 for the Westinghouse electrical
penetration assemblies (EPAs) identified that no analysis was
provided in'the package to show that functional tests performed
during qualification testing were adequate for specific BSEP
applications.
Discussions with the licensee determined that the
,
functional tests were adequate for the BSEP application and the
'
licensee stated that the package would be updated.to reflect the
adequacy of the functional testing for the BSEP application.
This
update of QDP-14 is considered an open item that will be reviewed
during a future NRC inspection (50-325/324:85-26-07).
.
(3) The NRC inspectors' review of QDP-38 for the qualification of
,
ITT Barton Models 288A and 289A pressure switches determined that
the licensee had based radiation environment qualification of
289A switches E11-PDIS-N021A&B and E21-FS-N006A&B on a required
design basis accident (DBA) operating time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, while
the EQ list defined the required DBA operating time as "Long"
s
l
("Long" is defined as 30 days by the licensee).
Further review
I
determined that the switches had been radiation tested to 3 x 108
rads, while the 40 year life plus 30 day DBA radiation dose-
'
requirement is 1 x 107 rads.
The licensee based qualification
of the switches on a 40 year. life plus 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DBA radiation dose
requirement of 5.7 x 105 rads, a value within the test radiation
dose.
When questioned about the discrepancy between the DBA operating
'
times and associated questions regarding radiation qualification
,
i
dose, the licensee stated that they originally had planned to
replace the switches with switches qualified to the higher
.
radiation requirement; however, they had determined by analysis
that the switches would only be needed for a DBA operating time
f
of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. .Therefore, they decided not to replace the switches
L
since they could be qualified for the 40 year plus 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
requirement of 5.7 x 105 rads.
The licensee stated that the EQ
.
list had not been changed to reflect the shorter requirement.
e
9
"These QDPs were changed by the licensee based on NRC comments relative to
!
- QDP-32. .The inspectors did review the changes to the packages; however,
a complete package review was not performed.
e
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.
11
- -. ..- , - _ _
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....
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.
-
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.
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_ _ . . - .
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0
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Since the-inspection team had been informed by the licensee that
the EQ list was the controlled document that defined EQ require-
ments, the licensee was asked to provide documentation to support
the position that the EQ list was wrong and should have been
changed.
The licensee stated that documentation was available to
support the change; however, he was unable to provide the docu-
mentation during the inspection. .Since information supporting the
licensee's position was unavailable during the inspection, quali-
fication of the BSEP 289A pressure switches for the defined
requirements is considered not established.
This is considered
an open item (50-325/324:85-26-08) which should be corrected prior
to the restart of Unit 1 from the present outage and prior to
operation of Unit 2 beyond the November 30, 1985 schedular extension
deadline granted September 28, 1984.
A JC0 supporting continued
operation of Unit 2 with the Barton 289A switches was covered by
the granted schedular extension.
This open item will be reviewed
during a future NRC inspection.
(4) The NRC inspection team selected the NDT International accelerometer
which is used in the safety relief valve monitoring system for review;
however, the licensee did not have QDP-58 for the accelerometer
complete at the time of the inspection.
The licensee was in the
process of replacing existing accelerometers with new ones during
the Unit 1 outage and the accelerometers on Unit 2 were covered
by a JC0 and the schedular ext?nsion granted September 28, 1984.
Even though the package was not complete, the inspector did review
what information was available.
During this review, the inspectors
.were unable to establish similarity between the coaxial cable tested
and qualified in conjunction with the accelerometer system quali-
fication and the installed Rockbestos coaxial cable on Unit 1.
During additional discussions, the licensee identified QDP-11 for
Rockbestos coaxial cable as additional evidence of accelerometer
cable qualification based on non-system.related tests.
However,
the licensee did not resolve the question of whether or not the
installed cable was qualified; and if so, was the qualification
based on accelerometer system tests or separate cable tests.
Based on the above, qualification of the accelerometers is
considered to be not established.
The licensee should assure
that the qualification of the accelerometers and associated
coaxial cable is established prior to Unit 1 restart and before
Unit 2 operation after expiration of the existing JC0 and
schedular extension.
This item is considered an open item which
will be reviewed during a future NRC inspection (50-325/324:85-26-09).
Additionally, while the inspectors did not review QDP-11 for
Rockbestos coaxial cable, they determined that even though there
was a QDP for the cable, the cable did not appear on the licensee's
EQ list.
The licensee was questioned regarding BSEP uses of the
cable other than for the accelerometer and the licensee stated that
there were other uses of the cable in the plant.
The inspectors
did not review'these other uses of the cable during the
12
o
- _ _ _ _ _ _
- _ _ _ _ ,
,
,
inspection.
The failure to include Rockbestos coaxial cable on
the EQ list is considered a Potential Enforcement / Unresolved Item
(50-325/324:85-26-10).
(5) The NRC inspectors reviewed QDP-12 for Rockbestos Firewall III
insulated, hypalon jacketed cable and determined that the
licensee had addressed IE IN 84-44 concerning the inadequacy
of Rockbestos test reports and had included supplementary
information in the file.
However, the licensee did not include
sufficient analysis of the supplementary data to support quali-
fication for specific applications at BSEP.
Examples of analyses
not provided by the licensee included documenting that test
profiles enveloped the required environments, that the functional
tests performed.were applicable to BSEP applications, and that
similarity was established.
Based on discussions with the
inspector, the licensee revised the data package and added
additional supplementary data to the package; however, the file
still contained insufficient analysis of the supplementary data
to support qualification.
Therefore, qualification of the
Rockbestos Firewall III cable used at BSEP is considered not
established.
The failure to establish qualification of Firewall
III cable is considered a Potential Enforcement / Unresolved Item
(50-325/324:85-26-11).
E.
IE Information Notices and Bulletins
The NRC inspectors reviewed and evaluated BSEP's activities related to
the review of EQ-related IE ins / Bulletins.
The inspectors' review
included examination of BSEP's procedures and QDPs relative to 6 ins.
The procedure review determined that BSEP does have a system for
distributing. reviewing, and evaluation ins / Bulletins relative to
equipment within the scope of 10 CFR 50.49.
During the review of
individual QDPs, the NRC inspectors evaluated BSEP's actions with
respect to ins / Bulletins and made one recommendation (see discussion
in paragraph 4.A.(1)) relative to the QDP documentation of the actions
taken regarding ins / Bulletins.
The inspectors recommended that the
licensee document in the appropriate section of his EQP the identity
of the ins / Bulletins reviewed for application to the equipment even
though the specific concerns addressed in ins / Bulletins are determined
to be not applicable.
It was further suggested that a brief description
be provided in the EQP as to why the ins / Bulletins were not applicable.
By doing the above, the documentation would provide an auditable link
to assure that ins / Bulletins, which would "at quick glance" be considered
applicable, were indeed considered.
No other concerns were identified
in this review area except relative to Rockbestos cable as described
in paragraph 4.0.(5) of this report.
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