IR 05000346/1986010

Insp Rept 50-346/86-10 on 860224-28.Major Areas Inspected: Qualification of Electric Equipment Program Implementation. Thirty Two Unresolved Items Identified,Including LER 86-006, Limitorque Operators & Lubricant Package

ML20206E903
Person / Time
Site:	Davis Besse
Issue date:	06/05/1986
From:	Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20206E901	List: IR 05000346/1986010 ML20206E896
References
50-346-86-10, NUDOCS 8606240036
Download: ML20206E903 (18)

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U. S. NUCLEAR REGULATORY COMMISSION l

OFFICE OF INSPECTION AND ENFORCEMENT Report No.: 50-346/86-010 Docket No.: 50-346 License No.: NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit N Inspection At: Oak Harbor, Ohio Inspection Conducted: February 24 to 28, 1986 Inspector: 1 (I R. C. Wilson, Equipment Qualification & Test Engineer 0~a te I

Also participating in the inspection and contributing to the report were:

U. Potapovs, Chief, Equipment Qualification Inspection Section, IE A. Johnson, Engineer, IE M. Jacobus, Member of Technical Staff, Sandia National Laboratories J. Chavez, Member of Technical Staff, Sandia National Laboratories M. Yost, Consultant Engineer, Idaho National Engineering Laboratory D. Jackson, Consultatnt Engineer, Idaho National Engineering Laboratory A. Gautam, Reactor Inspector, RIII R. Smeenge, Reactor Inspector, RIII R. Westberg, Reactor Inspector, RIII J. Muffett, Chief, Plant System Section, RIII

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)f Inspector b AL.,1W () -E-8f U. Potapovs, Chief, Equipdent Qualification Inspection Date Section, Office of Inspection and Enforcement

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8606240036 860613 PDR ADOCK 05000346 G PDR i

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INSPECTION SUMMARY Inspection on February 24 to 28, 1986 (Inspection Report No. 50-346/86-010)

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Areas Inspected: Special announced inspection to review the licensee's imple-mentation 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 50.4 Results: The licensee was performing an extensive reworking of the EQ program during an extended plant outage. The inspection identified numerous incomplete areas that are considered to be unresolved items. Those concerns are listed below; they will be reexamined in a continuation of this inspection prior to

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UNRESOLVED ITEMS REPORT SECTION CONCERN Program and Procedures Completion of procedures . Implementation of maintenance / surveillance procedures 4.A.(2) LER 86-006 4.C.(1) LER 85-023 4.C.(2)

Environmental Qualification Files Limitorque operator package DB1-037C 4.D.(1) Limitorque operator package DB1-037D 4.D.(2) Limitorque operator package DB1-037F 4.D.(3) Deutsch relay package 081-012 4.D.(4) BISCO LOCA seal package D81-048 4.D.(5) Pyco RTD package D81-042 4.0.(6) Magnetrol level switch package DB1-024 4.D.(7) Rosemount 1154 transmitter package DB1-030E 4.0(8) Rockbestos coaxial cable package 081-047 4.0. 9)

10. General Atomic radiation element package 081-016 4.D. 10)

11. Raychem WCSF-N splice package 081-029 4.0. 11)

12. Samuel Moore instrumentation cable package DB1-031 4.D.(12)

13. Amphenol penetration assembly package DB1-003A 4.D.(13)

14. Buchanan terminal block package D81-002 4.0.(14)

15. BIW instrumentation cable package D81-007 4.0.(15)

16. Endevco and TEC charge convertor and transient shield package DB1-13B 4.D.(16)

17. Kerite power and control cable package 081-023 4.D.(17)

18. Conax ECSA package DB1-008A 4.D.(18)

19. Rosemount level transmitter package 081-0308 4.D.(19)

heat pump motor package DB1-036C 4.D.(20)

20. Westinghouse 21. Lubricant decay (unnumbered)

package 4.0.(21)

22. Stanwick terminal block package 081-032 4.D.(22)

23. Asco solenoid valve package DB1-004C 4.D.(23)

24. Rees push button switch package 081-044 4.D.(24)

Plant Physical Inspection Namco EA170 limit switches 4.E.(1) Limitorque operators 4.E.(2) Decay heat pump motor 4.E.(3) Stanwick terminal blocks 4.E.(4)

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DETAILS PERSONS CONTACTED 1.1 Toledo Edison Company (TED)

• J. Williams, Jr., Senior Vice President-Nuclear

• D. Amerine, Asst. Vice President-Nuclear

• L. F. Storz, Plant Manager i

• S. J. Smith, Assistant Plant Manager-Maintenance

• T. J. Myers, Nuclear Safety and Licensing Director

• 0. J. Mavro, Generation Manager, Engineering

• P. W. Jacobson, EQ Coordinator

• R. M. Cook, Acting Compliance Supervisor

• T. P. Beeler, Elec/ Controls Manager,' Nuclear Engineer

• T. M. Gulvas, Station I&C EQ Coordinator

• J. W. Long, Station Elec. EQ Coordinator

• C. V. Phillips, I&C Maintenance Superintendent N. L. Bonner, Electrical Maintenance Superintendent

• T. J. Chiles, Materials Manager

• R. Peters, Licensing Manager

• T. M. Broad, Licensing Engineer

• L. O. Ramsett, Quality Asssurance Director

• M. Grickas, QA Engineer M. L. Stewart, Nuclear Training Director H. C. Brinkman, Nuclear Facility Engineering Director 1.2 Consultants to TED

• W. F. Emerson, Davis-Besse EQ Program Manager, Stone & Webster

• L. S. Wigley, Project Manager, Stone & Webster

• R. Newman, EQ Engineer, Stone & Webster

• F. S. Hertrich, EQ Engineer, Stone & Webster

• P. A. DiBenedetto, Consultant, DiBenedetto Asso * T. A. Ippolito, Consultant, DiBenedetto Asso * S. J. Milioti, Section Manager, Impell

• N. Patel, EQ Engineer, Impell

• G. Gharabeigie, EQ Project Engineer, Impell

• G. A. Washburn, EQ Engineer Bechtel

- * J. Hink, EQ Engineer, Bechtel

• J. A. Yesko, Engineer, Bechtel R. C. Hildebrandt, Independent Process Review Committee, MPR Asso .3 Observer R. K. Ho, EPM, Consultant to Nuclear Utility Group on EQ 1.4 NRC

• R. H. Vollmer, Deputy Director, IE

• G. G. Zech, Chief, Vendor Program Branch, IE

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• I. N. Jackiw, Chief, Reactor Projects, RIII

• D. C. Kosloff, Senior Resident Inpsector

* Denotes those present at status meeting at Davis-Besse Nuclear Plant on t February 28, 1986

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2. PURPOSE The purpose of this inspection was to review the licensee's implementation

, of a program meeting the requirements of 10 CFR 50.49 for Davis-Besse Nuclear Power Station, Unit N . BACKGROUND The NRC held a meeting with TED on December 13, 1983, to discuss the licensee's proposed methods to resolve the EQ deficiencies identified in the SER dated February 8, 1983, and in the FRC TER dated January 11, 1983. Discussions also included TED'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. Minutes of the meeting and proposed methods of resolution for each of the EQ deficiencies were documented in licensee submittals dated April 3 and June 26, 1984. A final SER transmitted January 31, 1985 identified that certain equipment was still under JC0; by the beginning of the inspection that equipment had been replaced by equipment whose qualification documentation was stated to be complet On June 9,1985, Davis-Besse Nuclear Power Station, Unit No.1 (DB-1)

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experienced a loss of main and auxiliary feedwater event that initiated an extended outage; the plant was still shutdown during this inspectio During that outage and prior to this inspection, TED made the following additional EQ-related submittals:

(a) LER 85-023 dated December 2, 1985, states that when the steam admission valves for the auxiliary feedpump turbine were relocated, the high energy line break analysis failed to address existing lines upstream of the valves as high energy lines. Consequently, the EQ status of equipment in nearby rooms could require chang (b) TED letter dated January 6,1986, stated that an independent technical and programmatic audit of the Davis-Besse EQ program following the June 9 event led to formation of an EQ Assessment Committee, which in turn caused the following activities:

(i) review and update of EQ Master List (ii) development or upgrade of procedures (iii) review and upgrade of EQ files (iv) review of the auxiliary feed HELB analyses (v) verification walkdown of EQ equipment and review against files (vi) recommended revisions to USAR section 3.6 analyses (vii) review of Maintenance Work Orders to identify overdue EQ l maintenance and surveillance

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(c) LER 86-006 dated February 1, 1986, documents 153 components discovered to be unqualified as follows:

Overdue Maintenance / Lack of Records 25 Foxboro and Rosemount pressure and flow transmitters -

qualified life exceeded for parts or whole, or calibration interval exceeded

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l 32 ASCO solenoid valves - coil replacement interval

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34 Limitorque valve operators - no record of required i lubricant inspection 5 ITT General damper actuators - qualified life of j

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some parts exceeded 4 96 TOTAL

' Installation Discrepancies 25 Rosemount pressure, level, flow transmitters - 22 lack

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conduit weephole, 2 analyzed for wrong location,1 i improper model i i 16 Namco limit switches - lack cable entrance seal

16 SOR pressure switches - lack cable entrance seal

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) The NRC inspectors examined the licensee's program for establishing the

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qualification of electric equipment within the scope of 10 CFR 50.4 The program was evaluated by examination of the licensee's qualification  !

l documentation files, review of procedures for controlling the licensee's

EQ efforts, verification of the adequacy and accuracy of the licensee's j program for maintaining the qualified status of the covered electrical

! equipmen The inspection team determined that the licensee's 10 CFR 50.49 program was not yet completed. The inspection findings, described below, '

indicated that TED was actively working on a major revision of the

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program with completion planned prior to restart. Consequently, this .

inspection report covers findings made during the February 24 to 28, 1986 l period; the inspection will be completed prior to plant restar j

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A. EQ Program Procedures Prior to commencing the inspection, the NRC inspection team was given a presentation of the licensee's EQ program on February 24, 1986. During this presentation, the licensee provided an overview of their organization, EQ program status and EQ documentation. The It contains the EQ Equipment basic document is called the EQ Manua Master List; Sumaries of Environmental Conditions; and approximately 82 EQ packages arranged by equipment typ The NRC inspectors examined the licensee's EQ program to verity implementation of corporate and site policies and procedures for establishing and maintaining the environmental qualification of electrical equipment ir compliance with the requirements of 10 CFR 50.49. The licensee's methods, for establishing and maintaining environmental qualification of electrical equipment, were reviewed in the following documentation:

Administrative Procedures

• AD 1807.00, " Control of Conditions Adverse to Quality," Revision 10, dated April 14, 1984

• AD 1809.00, " Station Environmental Qualification Program," Revision 0, dated January 8, 1986

• AD 1844.00, " Conduct of Maintenance," Revision 15, dated December 3, 1985

• AD 1844.02, " Control of Work (MWO)," Revision 1, dated February 5, 1986

• AD 1844.03, " Control of Maintenance Instructions," Revision 3, dated October 29, 1984

• AD 1844.14. " Request of Engineering Assistance," Revision 0, dated September 28, 1985

• AD 1845.02, " Facility Change Request Initiation," Revision 0, dated July 12, 1984

• AD 1845.03, " Facility Change Request Initiation," Revision 0, dated

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July 12, 1984 AD 1845.05, " Facility Change Request Closecut," Revision 0, dated July 12, 1984 AD 1846.00, " Requisition of Material and Service," Revision 5, dated May 21, 1984

• AD 1847.00, " Station Material Control," Revision 9, dated October 4, 1985 AD MIN 005, "NRC Correspondence," Revision 3, dated July 18, 1983

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Licensing Procedure NSL/LIC - 004, " Licensing Commitment Tracking System," Revision 0, dated February 7, 1986 Nuclear Facility Engineering Procedures

• NFEP-010. " Processing Facility Change Requests," Revision 4, dated October 1, 1985

• NFEP-011, " Conceptional Designs" Revision 4, dated December 22, 1985

• NFEP-020, " Design Work Packages," Revision 7 dated December 22, 1985

• NFEP-040, " Vendor Submittals," Revision 3, dated November 23, 1985

• NFEP-041, " Vendor Manuals," Revision 1, dated November 23, 1985 NFEP-160, " Environmental Qualification Program," Revision 2, dated February 21, 1986

• NFES-070, " Procurement," Revision 2, dated Decenber 4,1985 NFES-071, " Purchase Requests for Spare and Replacement Parts,"

Revision 3, dated August 23, 1985

• NFES-072, " Purchase Requests for Engineering Items or Service,"

Revision 3, dated August 23, 1985 Nuclear Mission Procedure NMP-NE-306, " Environmental Qualification Program," Revision R0, dated February 25, 1986

• Denotes those procedures being revised by license Procedures NMP-NE-306 and NFEP-160 were identified by the licensee as their top tier procedures for implementation of the requirements of 10 CFR 50.49. As noted above, many of the licensee's lower tier procedures were in a state of revision. The NRC inspector reviewed copies of these procedures and proposed changes. In most cases, the purposes of the proposed changes were to more clearly identify the EQ related activities and to identify the applicability of Procedure NFEP-16 Pending a NRC review of the approved and issued revisions of those procedures, this is considered an unresnived ite The NRC inspectors reviewed the licensee procedures listed above for implementation of the requirements of 10 CFR 50.49 including:

definitions of harsh and mild environment, equipment qualified life, service conditions, periodic testing, maintenance, and surveillanc The licensee's EQ program procedures were also reviewed for 10 CFR

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50.49 requirements to establish, evaluate and maintain auditable EQ l

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documentation including EQ summary sheets, test reports, maintenance records and other supporting documentation to justify equipment qualification. Other areas reviewed included training of personnel in the environmental qualification of equipment; control of plant modifications, sucn as installation of new and replacement equipment; and provisions for updating replacement equipment to 10 CFR 50.49 criteria. During this review, the inspectors observed the following:

(1) The licensee's program was found to identify and define requirements for equipment in harsh environment through EQ lists and summary sheets. Mild and harsh environments were clearly defined and differentiated. Engineering analysis and evaluation had been performed to establish environmental conditions. EQ documentation was found auditable, with controls for evaluation and maintenance of these document (2) At the time of this inspection, specific maintenance and surveillance requirements were identified in the EQ files for each piece of equipment; however, the licensee did not have procedures issued for station personnel to maintain the equipment qualification. The licensee was preparing 27 maintenance procedures for EQ equipment, all scheduled for release prior to April 14, 1986. The licensee has established a computerized list, " Preventive Maintenance For Environmental Qualification," to identify preventive maintenance requirements for EQ equipment. This list does identify all the EQ equipment; however, not all preventive maintenance requirements for EQ equipment had yet been identified on this list. Pending NRC review of the implementation of appropriate maintenance / surveillance procedures for EQ equipment, this is considered an unresolved item.

l (3) EQ training for management and plant maintenance personnel is

being provided by the EQ group. Attendance lists for training

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sessions on Procedures NMP-NE-306 and NFEP-160 provided

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evidence that a significant number of the licensee personnel had received this training. The licensee indicated that in the future, EQ training would be provided by the licensee's Training Departmen Review of 10 CFR 50.49 EQ Master List The NRC inspector reviewed the actions performed by the licensee in the development, control and distribution of their EQ Master List '

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(ML). The inspector reviewed preparation and controls for the ML in the Environmental Qualification Program NFEP-160, Revision 2; and reviewed the content of the ML on Drawing 110. E-1039. Revision The licensee reported that a thorough review had been performed by them in preparing the ML, which included verification reviews by Bechtel and Impell, as well as the licensee's Operations staff. The ML consisted of systems and equipment required to mitigate the

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consequences of LOCAs and HELBs, restore the plant to a safe shutdown condition, and allow sufficient post accident sampling, monitoring, and radiation monitoring. The ML format included the plant ID, manufacturer, model, service, system, component, and locatio The inspector selected equipment from the plant Emergency Procedures EP 1202.01 to verify inclusion in the ML. The Emergency Procedures were reviewed for equipment used during symptom oriented problems leading to a reactor trip; aquipment needed during a loss of AC Power; and a Large Break LOCA. Selections were also made from PIDs for the High Pressure and Low Pressure Injection lines. All selected equipment was found listed appropriately on the Master List. No violations or deviations were identifie C. Review of EQ Related LERs Section 3 of this inspection report summarizes two EQ-related LER The inspector reviewed the status and scheduling of licensee actions to implement the corrective actions of the LER (1) LER 86-006 - Environmental Qualification Program Not Adequately Establishe Documents Reviewed Deviation Report 86-001 NCRs 85-2828, Foxboro Pressure Transmitter 85-2585, Asco Solenoid Valves 86-0098, Limitorque Motor Operator 86-0321, Decay Heat Motor Leads FCRs85-316, Namco Limit Switches86-029, Rosemount Transmitters86-016, SOR Pressure Switches85-008, Foxboro Pressure Transmitters Maintenance Work Orders 3-86-0043-01 2-85-0316-01

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2-86-0029-03 '

2-86-0016-01 1-86-0321-01 2-86-0008-01 The inspector sampled ceven categories of EQ equipment with licensee walkdown deficiencies for status of corrective action. This review indicated that while the corrective

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work requests had been written, the work was still awaiting scheduling or completion. Pending a further review of these corrective actions, this is an unresolved ite (2) LER 85-023 - Error in the High Energy Line Break Analysis in the Auxiliary Building Documents Reviewed Impe11 Reports No. 02-1040-1335, " Evaluation of Equipment Qualification

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' Concerns Associated with AFW Break Study," Revision No. 02-1040-1334, " Evaluation of Environmental Conditions

' From Auxiliary Pump Turbine Steam Supply Line Ruptures,"

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EQ Master List, Revision 0, for rooms 500, 501, 601, and 60 FCR No.85-143

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The inspector's review of LER 85-023 indicated that the licensee had identified the equipment whose qualification status

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had changed; however, work was still in progress to qualify

some of this equipment, including definition of required operating times. Pending further review, this is an unresolved

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ite Environmental Qualification Files Each EQ package is arranged as follows:

i ActionItems(ifany)

TED review checklist

Cover sheet

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Record of revisions

Table of contents

• Maintenance / installation requirements

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Harsh equipment list

• Two-page System Component Evaluation Worksheets (SCEW Sheets)

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Qualification evaluation

References t

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The EQ packages cover the necessary information in convenient, auditable form and provide for documentation of reviews and approvals. However, even the packages classified by the licensee as complete at the time of the inspection lacked signatures on the TED review checklist for Maintenance Program, Maintenance History, and

. Walkdown Verificatio The files were examined to verify the qualified status of equipment l

within the scope of 10 CFR 50.49. In addition to comparing plant service conditions with qualification test conditions and verifying

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the bases for these conditions, the inspectors selectively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be -

. qualified; similarity of tested equipment to that installed in the

plant (e.g., insulation class, materials of components of the

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equipment, tested configuration compared to installed configuration,

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and documentation of both); evaluation of adequacy of test i conditions; aging calculations for qualified life and replacement i interval determination; effects of decreases in insulation '

I resistance on equipment performance; adequacy of demonstrated accuracy; evaluation of test anomalies; and applicability of EQ

problems reported in IE ins / Bulletins and their resolution, i

The inspectors examined 37 EQ package Four of these were classified in the licensee's tracking system as complete, and no

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deficiencies were found except omission of three signatures noted above. The remaining 33 packages were not classified as complet Of these 33, four appeared to be satisfactory except for omitted

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signatures and five more involved equipment not subjected to harsh environments and thus not requiring qualification. The remaining 24

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packages, all classified by the licensee as less than complete, were found to be incomplete as described below.

4 (1) Limitorque operator package DB1-037C:

a. Lacks resolution for IE IN 86-0 ' Conclusion not reached concerning need for weepholes and/or conduit seals or sealan ' Lacks reference to the forthcoming generic lubricant file to cover qualification of lubricant ,

. Possible impact of a forthcoming TED analysis involving

< certain operators that cannot be operated twice a year, as stated in Limitorque's maintenance program, not addressed

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in file.

i Possible impact of a forthcoming Bechtel review involving '

propagation of failures of equipment located below flood level not addressed in file (2) Limitorque operator package 081-0370

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. through e, as abov Lacks quality assurance signoff (3) Limitorque operator package DB1-037F: through e, as above, R Guidelines qualification sheets lack signoff Test report applicability to the installed equipment was not verified in some cases (TED stated that verification was about 95 percent complete).

(4) Deutsch relay package DB1-012: R Guidelines and TED review checklists lack signoff Plant vs. qualification pressure discrepancy not resolve Specified operability time (one day) and cycling i

reqtirements not verifie I Test report not in file (test procedure and data sheets are).

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(5) BISCO LOCA seal package 081-048: Seal life calculation C-ECS-083-021 lacks approval.

4 Documentation that the seals were installed by a certified specialist is require (6) Pyco RTD package 081-042: Aging calculations C-ECS-064-028, -029, and -030 lack approval The demonstrated accuracy shown on the SCEW sheet lacks documentation.

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(7) Magnetrol level switch package 081-024: This package will document lack of a need to qualify, but failure effects on other safety-related equipment were not evaluate J (8) Rosemount 1154 transmitter package 081-030E: The qualified life, with replacement circuit boards, is :

only 15 years, but the TED maintenance requirements do not call for replacing the transmitter at that time.

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' The transmitters were not yet installed; QA and management reviews were not yet complete (9) Rockbestos coaxial cable type RSS-6-113, package 081-047: Lacks copy of new Rockbestos type test repor Lacks similarity evaluation for second generation plant cable vs. third generation cable addressed in new test repor Lacks functional performance criteria evaluation for the high range radiation monitor application, Lacks beta radiation evaluation for the cable path not enclosed by conduit (inside the open junction box).

i (10) General Atomic radiation element package 081-016: Lacks copy of letter BT-16228 (ref. 4 in package)

addressing accuracy and connector qualification; file addressed errors in the electronics (located in mild environment) but not in the elemen Lacks evaluation showing that qualification documentation covers installed horizontal orientatio (11) Raychem WCSF-N splice package 081-029: Lacks beta radiation evaluation and test report (since unshielded splice is used in radiation element junction box).

(12) Samuel Moore instrumentation cable package 081-031: The generic accuracy calculation for cable in 4-20 mamp circuits requires correction (brief review of a new analysis provided during the inspection revealed no concerns).

(13) Amphenol penetration assembly package 081-003A: LOCA test data do not show that 1.0 Megohm insulation resistance criterion was satisfie Although the evaluation states that test performance anomalies did not occur for materials and equipment used in Davis-Besse, test report 123-1247 (ref. 9 in package)

showed failure of a dielectric withstand test by one module {

containing materials used in the plant, Portions of this file such as the section on IEB/ ins were i incomplete.

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(14) Buchanan terminal block package 081-002: This package requires the corrected generic accuracy calculation cited under Samuel Moore cable abov (15) BIW instrumentation cable package D81-007: This package requires the corrected accuracy calculation cited under Samuel Moore cable abov Further, the file did not demonstrate that measured type test errors are acceptabl Lacks statement that safety function is completed before submergenc Lacks a pending certificate of complicace and cable construction notificatio (16) Endevco and TEC charge convertor and transient shield package DB1-13B: Lacks a Bechtel letter documenting qualificatio Not yet installed; restrictions app 1y to installation of

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both accelerometer and cable that may be verified in future walkdow (17) Kerite power and control cable package 0B1-023: The package will be revised, incorporating a new test report and resolving the following concerns:

i (i) the accuracy calculation cited under Samuel Moore i cable abov (ii) lack of submergence test insulation resistance data.

1 (iii) two cables were under 18 month surveillance intervals because of incomplete type test dat (18) Conax electrical conductor seal assembly package DB1-008A (this review was performed in conjunction with Valcor solenoid valve package 081-035 and valves RC4608A and RC4610A): Similarity not shown between plant part number N-11006-53 (as shown on the Instrument Installation Index, drawing N-115 Rev. I and verified during the walkdown inspection)

and the test sample part number N21009-0 Grafoil tape thread sealant used for Conax Test Report IPS-1079 Rev. D, May 21, 1984; Tite Seal T20-66 called out on drawing N-115 for plant use, with no qualification documentation on fil I i 15

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(19) Rosemount level transmitter package DB1-030B (transmitters LTSP9A6, 7, 8, and 9): Lacks formal copy of Bechtel letter analyzing HELB and LOCA service to clarify that submergence and LOCA radiation dose do not apply, since the SFRCS trip function would be initiated by other means; the SCEW sheets and any other applicable file changes must also be performe These four transmitters apparently received improper maintenance. The Maintenance / Installation Section of the EQ package requires 0-ring replacement whenever the cover is remove Records showed board replacements requiring cover removal in December 1984, and calibration in August 1985, yet there was no record of 0-ring replacement since June 1977, and the Maintenance Work Order for board replacement did not identify a need for new 0-ring (20) Westinghouse decay heat pump motor package 081-036C: Appropriate packages should be referenced ior documenting qualification of (i) the motor lead splices (Raychem package DB1-049C) and (ii) the lubricant (new lubricant package) discussed belo (21) Lubricant package (unnumbered): The licensee planned to qualify lubricants in a single package separate from the equipment using the lubricant The new package will be reviewed in the continuation of the inspection, with attention to equipment application consideration (22) Stanwick terminal block package 081-032: Although the package claims a 40 year qualified life with no maintenance, during the plant physical inspection a maintenance tag was observed on junction box JT6-811 (room 601, elev. 643 ft) calling for cleanup of corroded terminals nos. 106, 118, 119, and 120. Although the licensee indicated this was an isolated instance, it provides evidence that a 40-year life may not be assumed without some surveillanc (23) ASCO solenoid valve package 081-004C: Page 5 of the Maintenance / Installation requirements section states that no maintenance is required; this conflicts with Note 2 on page 4 of the same section, which staets that "all solenoid valves must be tested once a month to insure proper opening and closing." File reference 1, page 4-7 states that a conduit entrance seal is required for valves under high pressure,

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temperature, and humidity. Although valves SVICS1181 and 2 are qualified for 282 F, the presence of a qualified seal could not be verified during the plant physical inspection. Fixtures marked "K093996724" were observed, but the licensee could not demonstrate qualification of these fixture (24) Rees push button switch package D81-044: Lacks test report and evaluation for ambient pressure, Worst case conditions for " generic" qualification could not be verified because tag numbers and locations are not specified in the package; instead, the Master Equipment List is referenced but no revision of it is specified, Lacks several signoff E. Plant Physical Inspection The NRC inspectors examined 18 types of equipment, usually involving two or more specimens of each type, during the plant physical inspection. The inspectors examined such characteristics as mounting configuration, orientation, interfaces, model and serial numbers, ambient environment, and physical condition. Concerns noted during the walkdown are listed belo (1) Namco EA 170 limit switches. Based on input from the NRC resident inspector, four limit switches on valves CF 1542 and SA 2010 in room 314 were observed. Three of the four switches each lacked two of the six cover screws, and the SA 2010 open switch lacked four screws. Although these switches need not be qualified for steam service, the missing screws are considered to be evidence of poor housekeepin All of the observed switches were model EA170-31100, which is a clockwise switch. Licensee personnel agreed that as installed proper switch action would require that one switch of each pair must be counter-clockwise, which would be model 32100. The inspector concluded that licensee personnel may have relocated the internal spring in the limit switch to obtain proper action, in which case the field modification would cause the nameplate and documented model number to be incorrect. Package DB1-27E was briefly reviewed; it was not yet complet (2) Limitorque operators, MV05990: The conduit interfaces were loose; one flex conduit joint had been taped, but had worked loose. Two'

terminal board terminals had three wires each; plant procedures allow a maximum of two. The limit switch compartment gasket was deformed (folded over) so that a J path for water entrance was opened. Wires for the motor l and Dings brake could not be identified, but TED did J resolve this concern shortly af ter the walkdow ,

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9 MVDH110 and MVDH120: Limit switch compartment gaskets were missing, and rust was observed between the valve

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operator body and limit switch compartment. Lugs and lead wires connected to the terminal blocks were corrode Grease relief valve shipping caps had not been remove (3) Decay heat pump motor MP042-1. Two lube oil cans were found adjacent to the motor; they are considered a fire hazard. A lubrication tag on the motor since 1975 listed an oil not in ;

accordance with the manufacturer's recommendations. A welding cable was found lying next to the motor. The motor air intakes were dirty. Shortly af ter the walkdown, the oil cans, tag, and welding cable were removed, and the licensee stated that the apparent discrepancy in oil types occurred because the manufacturer had changed the number (4) Stanwick terminal blocks. As noted in section 4.d.(22) above, evidence of corroded terminals was observed. Other junction ;

boxes containing Stanwick terminal blocks were dirty and corroded internall