ML20237H453
| ML20237H453 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/21/1987 |
| From: | Conlon T, Merriweather N, Paulk C, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20237H434 | List: |
| References | |
| 50-324-87-22, 50-325-87-22, NUDOCS 8709030278 | |
| Download: ML20237H453 (17) | |
See also: IR 05000324/1987022
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UNITED STATES
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NUCLEAR REGULATORY COMMISslON
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101 MARIETTA STRE ET, N.W.
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Report Nos.:
50-325/87-22, 50-324/87-22
Licensee
Carolina Power & Light Co.
Post Office Box 1551
Raleigh, North Carolina 27602
Facility Name: Brunswick Steam Electric Plant, Units 1 and 2
Docket Nos.:
50-325, 50-324
License Nos.: DPR-71 and DPR-62
Inspection Conducted: July 6-10, 1987
Inspe [ N. Merriweathe~r, Reactor Inspector
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Date Signed
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T. E. Conlon, Section Chief
Date Signed
Engineering Branch
Division of Reactor Safety
SUWARY
Scope:This special announced inspection was in the area of previously
identified Environmental Qualification (EQ) deficiencies.
Realts:
Eight violations were identified - HPCI Speed Sensors Not Environ-
mentally Qualified, paragraph 3.c.; Vulkene Wire Not Documented Environmentally
Qualified, paragraph 3.d.; Whitney-Blake Wire Not Environmentally Qualified,
paragraph 3.d.; SBGT Relays Not Documented Environmentally Qualified, paragraph
3.e,; Kulka Terminal Blocks Not Documented Environmentally Qualified, paragraph
3.f.; Cinch Tenninal Blocks Not Environmentally Qualified, paragraph 3.f.; SBGT
Temperature Switch Leads Not Environmentally Qualified, paragraph 3.g.; HPCI
Float Switches Not Environmentally Qualified, paragraph 3.h.
8709030278 070827
ADOCK0500g4
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- C
R. Dietz, General Manager, Brunswick Steam Electric Plant (BSEP)
- E. A. Bishop, Manager-0perations
- E. R. Eckstein, Manager, Technical Support
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- J. O'Sullivan, Manager-Maintenance
- R. J. Groover, Project Construction Manager
- B. L. Parks, Supervisor, Technical Support
- L. F. Tripp, Supervisor, Radiological Controls
- L. E. Jones, Director-QA/QC
- A. Richards, Principle Engineer, QC
- J. O'Connor, Project Engineer, Technical Support
- R. M. Poulk, Jr., Senior Specialist-Regulatory Compliance
W. Guarino, EQ Coordinator
- P. Salas, Senior Engineer, Corporate Licensing
T. Gick, EQ Coordinator-Maintenance
- T. Parlier, Principle Engineer, Engineering and Construction
- J. May, Engineer, Engineering and Construction
- S. Callas. Engineer, On-site Licensing
Licensee Contractors
- W. D. Dotson, Consultant, Cofer Associates
R. J. Phillips, Senior Engineer, Westinghouse
Resident Inspectors
- W. Ruland
L. Garner
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on July 10, 1987, with
those persons indicated in paragraph 1 above.
The inspectors described
the areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee. The licensee did not
identify as proprietary any of the material provided to or reviewed by the
inspectors during this inspection.
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Subsequent to the inspection, a telephone conversation was held on
July 30,1987, between Mr. C. R. Dietz, General Manager, Brunswick Steam
Electric Plant, and NRC representatives (P. Fredrickson,
T. Conlon,
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M. Hunt, C. Paulk, and N. Merriweather) to inform the licensee that those
unresolved items previously identified in the exit meeting as being closed
are being reopened and re-evaluated by the NRC.
The current status of
those items are discussed in paragraghs 3 below.
Violation 325, 324/87-22-01, HPCI Speed Sensors Not Environmentally
Qualified, paragraph 3.c.
Violation 324/87-22-02, Vulkene Wire Not Documented Environmentally
Qualified, paragraph 3.d.
Violation 325/87-22-02, Whitney-Blake Wire Not Environmentally Qualified,
paragraph 3.d.
Violation 325, 324/87-22-03, SBGT Relays Not Documented Environmentally
Qualified, paragraph 3.e.
Violation 325/87-22-04, Kulka Terminal Blocks Not Documented Environ-
mentally Qualified, paragraph 3.f.
Violation 324/87-22-04, Cinch Terminal Blocks Not Environmentally Quali-
fied, paragraph 3.f.
Violation 325, 324/87-22-05, SBGT Temperature Switch leads Not Environ-
mentally Qualified, paragraph 3.g.
Violation 325, 324/87-22-06, HPCI Float Switches Not Environmentally
Qualified, paragraph 3.h.
3.
Status of Previousiy Identified EQ Items
a.
(Closed) Unresolved Item 325, 324/85-26-04.
Procurement of
replacement parts.
The EQ inspection conducted August 12-16, 1985,
identified a concern with the licensee's program for replacement
equipment.
This concern involved the replacement of D0R qualified
equipment that did not meet the requirements of 10 CFR 50.49,
Paragraph (1), in that provisions had not been established for the
documentation of sound reasons to the contrary.
Subsequent
corrective action by ths licensee has resulted in the preparation of
Appendix II to Procedure PLP-02, " Program Document for Compliance
with 10 CFR 50.49," Revision 2.
This appendix lists, by equipment
types, plant equipment that are qualified to Division of Operating
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Reactors (D0R) Guidelines and delineates generic reasons for not
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upgrading this equipment to NUREG 0588, Category I.
Concerns were also identified by the previous EQ inspection that
actual replacement of D0R equipment may have occurred that did not
comply with the requirements of 10 CFR 50.49 (1).
The inspectors
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conducted interviews with licensee personnel and reviewed program
documents to assess the status of selected elements of the EQ upgrade
effort.
Paragraph 4.4.3 of Procedure PLP-02 delineates the controls
for replacement of D0R qualified equipment via near term and long
term policy objectives.
Near term replacement of D0R qualified
equipment that meets the requirements of 10 CFR 50.49 (1) are as
defined in procedure PLP-02, Appendix II.
This process is imple-
mented by the replacement of like-in-kind equipment wherein the
manufacturer, part number, model number, physical attributes of
form-fit-function, and demonstrated qualification are the same as the
original equipment.
Long term objectives for upgrade of selected EQ equipment types will
be implemented through a systematic and pre-planned replacement
process governed by IPBS-912
" Program for Upgrading Replacement
Equipment".
The long term program for upgrada of D0R qualified
equipment will be accomplished as follows:
Phase A will provide the IPBS-912 program definition of the
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equipment scope, the upgrade methodology, and implementation
direction for specific equipment.
This phase will be completed
through the review and approval of the program document by site
management.
on the Phase A direction) quired preliminary engineering (based
Phase B will perform the re
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as well as generate the IPBS-912
program proposal to define specific plant equipment identified
for replacement, their proposed Category I replacements , their
implementation (e.g.
engineering / design, procurement, and
installation) schedule, and their estimated budgetary require-
ments (for manpower and equipment).
This proposal will also
receive site management review and approval.
Where it is definitively concluded (within the Phase A document)
that the 50.49 (1) upgrade requirement can be best accomplished
(i.e. through a known replacement / refurbishment method that is
cost and scheduler effective) a separate Integrated Planning, )
Budgeting, and Scheduling (IPBS) activity (e.g. IPBS-912A, etc.
may be " spun-off" from the Fhase B activities (to assure its
implementation independent of the remainder of the IPBS-912
program).
IPBS-912 implementation activities, as budgeted and scheduled
per the approved Phase B proposal, will be performed, as
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required, consistent with other plant design change activities.
This implementation process will assure that the EQ list data
base and the qualification documentation packages are
updated / maintained consistent with the as-LJil; plant configu-
ration.
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' Review of engineering procedures and discussions with engineering
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personnel verified that measures had been established to assure the
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upgrade of EQ equipment during -the engineering design process.
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Additional discussions were- held with licensee personnel to assess
the status of the long term equipment upgrade program.
The inspec-
tors determined ' that licensee management has an ongoing effort
intended to establish the requirements of the IPBS-912 project. The
inspectors were ' additionally informed that procedure IPBS-912 " Phase
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'A" was presently being developed to define the process for review of
D0R qualified equipment relative to the need for upgrade per 10 CFR 50,49 (1), and to provide a management-approved basis for future
IFBS-912 project development' associated with presently installed D0R
qualified equipment.
Appendix II to PLP-02 represents the pre-procurement and
pre-installation reviews-of all D0R qualified equipment types not to
be upgraded that have been performed by the licensee. To assure that'
the licensee's long term policy objectives for upgrade of D0R
qualified equipment is implemented, a' commitment date was requested
by the inspectors for approval of procedure IPBS-912
Phase A.
Licensee management has committed to an approval date of January 1988, for
' Procedure IPBS-912,-Phase A.
Besed on review of. objective evidence 'and discussions with licensee
personnel, this issue is closed,
b.
(Closed) Unresolved Item 325, 324/85-26-05.
Qualification status of
installed equipment / establishment of EQ maintenance requirements in
plant procedures.
During the initial EQ inspection the NRC inspectors had a concern
that some installed Unit 2, 10 CFR 50.49 equipment might be unquali-
fied due to the. licensee's failure to perform required EQ maintenance
activities. The reasons for these concerns were:
(1) BSEP Technic &1 Support Group had not received any Qualification
Data Packages (QDP) from Brunswick Engineering Support Unit
(BESU) and likewise had not developed any EQ Maintenance Summary
Packages.
(2) Maintenance had not received an approved plant document
identifying the Unit 2 EQ equipment ntil April 1985, Unit 2
start-up was in October 1984.
(3) Maintenance had no list or knowledge of the equipment require-
ments related to EQ.
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As a result of these concerns, the licensee performed a detailed
review of those EQ items most likely to have been invalidated due to
failure to implement the required EQ maintenance. The review consist-
ed of comparing the EQ Maintenance Sheets (EQMS) to existing plant
procedures.
This review determined that EQ maintenance items
specified on EQMS-35, "Rosemount 1152 Transmitters" were not address-
ed in current maintenance pttcedures and that the potential existed
that the qualification may have been invalidated for 80 type 1152
Transmitters on Unit 2.
An analysis was performed by the licensee to
document the qualified status of Unit 2 Rosemount 1152 instruments.
It concluded that the qualification would not have been compromised
or degraded by the failure to specifically perform the maintenance
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activities identified in EQMS-35.
This analysis also addressed the
licensee's failure to seal the conduits connected to the instruments.
The evaluation demon-strated qualification of the instruments without
use of conduit seals by demonstrating that the terminal blocks used
in the instruments were similar to a GE Terminal Block which had been
type tested.
The qualification file stated that the leakage current
from the terminal blocks would not cause the loop error to exceed
Technical Specifications.
However, the analysis was lacking in that
it did not address the leakage current contributed by the field
cable.
In order to resolve the inspectors' concern, the licensee
revised the analysis (DR59.2) to show the contribution of the field
cable in the total of leakage current in the instrument loop.
The
revised analysis shows that with a worse case loop error with a
maximum cable length of 1000 feet the value for leakage current is
still within the acceptance values specified in Technical Specifica-
tions.
c.
(Closed) Unresolved Item 325/86-29-02, 324/86-30-02, HPCI turbine
speed sensor. The licensee identified in October 1986 that the speed
sensor magnetic pickups in the Unit I and Unit 2 HPCI turbines were
not environmentally qualified.
Subsequent corrective actions by the
licensee included declaring the turbines inoperable, installirg
qualified sensors, and initiating a review of the event.
The inspectors conducted interviews with licensee personnel and
reviewed documents prepared pursuant to the event to assess the
enforcement status of this issue.
Engineering Evaluation Report
(EER) No. 86-0485 was prepared by the licensee to determine the
following:
Is it reasonable to conclude that the installed device would
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perform satisfactorily through the unlikely condition of a
design basis event
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Is 'the device. that was . installed (Woodward speed sensor), in-
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fact, qualifiable and thereby provide assurance that plant
safety was not compromised
The inspectors determined that temperatures of 230 F for 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br />
exposure, and radfation aging of 1.1x106 rads were established by the
General Electric Co. (GE) for qualification of the speed sensors.
These pre-test parameters imposed conditions in excess of the
threshold limits for non-metallic materials used in the Woodward
speed sensor, and was the basis for the need to change these speed
sensors'.
The most critical non-metallic component of the Woodward
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speed sensor is Permabond 910, an adhesive used in the fabrication of
the' speed sensor.
A comparison of temperature and radiation values
between the BSEP. plant environment (normal and postulated accident)
-and the Permabond 910 reveals the following:
Temperature
BSEP Normal Service Temperature 104 F maximum
BSEP Postulated Accic 9t Qualification Temperature 148 F
Permabond-910 Service Temperature 165 F
Permabond 910 Softening Temperature 180 F
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Radiation
The total integrated dose for the speed sensor is 4.3x105 rads
The radiation properties for the Permabond 910 are 2x106 rads
There'is a 1.57x106 rad margin (273%) over the BSEP conditions
The inspectors verified that the threshold values for the Permabond-
.910 non-metallic component was determined by a literature search.
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Additionally, GE has concluded that if the actual temperatures and
radiation values to which the speed sensor is subjected stay below
the corresponding threshold values, it is their opinion that the
sensor would have perfonned its intended function.
Licensee management in the EER stated that the Woodward speed sensor
is qualifiable to the DOR Guidelines.
Based on the review of
objective evidence and discussions with licensee personnel, . the
inspectom concluded that the Woodward speed sensor was qualifiable
for the application in question.
Licensee management is also
presently in compliance with the requirements of 10 CFR 50.49 in that
the Woodward speed sensors were replaced with Category 1 speed
sensors on October 18, 1986, for Unit 1, and October 21, 1986, for
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Unit 2.
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The ' inspectors determined the root cause of the licensee's failure to
replace the Woodward speed sensors with qualified speed sensors
provided by GE was inadequate design interface control.
Discussions
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with licensee engineering personnel revealed misunderstandings with
GE regarding the scope of HPCI skid mounted components that were
being environmentally qualified.
GE's report NEDC 31001-1, received
in October 1985, clearly identified the requirement to replace the
sensor.
Therefore, the licensee clearly should have been known the
soeed sensors were not qualified.
Contrary to paragraphs (d), (f), (j) of 10 CFR 50.49, from Novem-
ber 30, 1985 to October 18, 1986 for Unit 1; and from June 15, 1986
to October 21, 1986 for Unit 2, the licensee (1) did not have the
Woodward speed sensors on the Master List of qualified equipment;
(2) did not have the speed sensors tested for qualification; (3) did
not have documentation to verify qualification of the speed sensors
in an auditable form.
This is identified as Violation 325/87-22-01,
324/87-22-01, HPCI Speed Sensors Not Environmentally Qualified.
The Unresolved Item is now considered closed.
d.
(Closed) Unresolved Item 325/86-29-03, 324/86-30-03, Limitor-
que Motor-0perator Wiring.
The licensee, in response to IE Notice
86-03, performed inspections on a sample population of Limitorque
valve actuators.
The results from 35% of the Unit 2 valves identi-
fied a wire in a Limitorque valve actuator (2-E11-F024A) as being
manufactured by Vulkene.
This wire was not on their EQ list and was
installed by the licensee.
The licensee immediately replaced the
wire and commenced testing.
Tests performed at the time indicate
that the wire was cross-linked polyethylene, and subsequently the
licensee has prepared an Engineering Evaluation Report in order to
qualify this wire to D0R guidelines.
When testing is completed on
this type wire, the licensee will complete a QDP for Vulkene wire.
Contrary to paragraphs (d),(f) and (j) of 10 CFR 50.49, at the time
of the inspection the licensee (1) did not have the Vulkene wire on
the Master List of qualified equipment, (2) did not have the wire
tested for qualifications, and (3) did not have documentation to
verify qualification of the wire in an auditable form.
This is
identified as Violation 324/87-22-02, Vulkene Wire Not Documented
Environmentally Qualified,
The licensee found another instance of improper wire in a Unit i
valve (1-Ell-F024A) during its sample inspection. This wire was made
by Whitney-Blake, was not on the qualified list, and was licensee
installed, as was the Vulkene wire discussed above.
Contrary to paragraphs (d), (f) and (j) of 10 CFR 50.49, at the time
of the inspection, the licensee (1) did not have the Whitney-Blake
wire on the Master List of qualified equipment, (2) did not have the
wire tested for qualification, and (3) did not have documentation to
verify qualification of the wire in an auditable form.
This is
identified as Violation 325/87-22-02, Whitney-Blake Wire Not Enviro-
mentally Qualified.
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Considering the fact that another unqualified wire was found, the
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licensee took inadequate corrective action after identifying the
Vulkene wire during its survey of the Unit 2 valve operators.
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action was inadequate in that the incident was waved off as being "an
isolated case." The licensee further stated that it was their policy
to " purchase and stock only environmentally qualified wire / cable for
use on Q-list sa fety-related applications," and that any
" modifications or corrective maintenance activities would have used
an acceptable qualified wire / cable."
Due to the fact that no
corrective action was taken to insure there was no additional
licensee installed wire that was not qualified (e.g. a 100% check of
Limitorque valve operators), the Whitney-Blake wire remained
undetected until identified during maintenance.
The results of the licensee's sampling program show that potential
for additional unqualified components in the Limitorque valve
actuators still exists, whether installed by the vendor or the
licensee.
In order to ensure that no valves contain unqualified
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components or wire, an inspection of all -qualified valves is
required.
With the identification of the above violation, this
unresolved item is now considered closed.
e.
(Closed) Unresolved Item 325/86-32-01, 324/86-3?-01,
Standby Gas
Treatment (SBGT) Systems Relays not Documented EQ.
On November 21,
,
1986, during a review of the electrical components on the SBGT skid,
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the licensee discovered that o"
Tication documentation for four
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control relays per SBGT unit v's ' ' Mrtently omitted from the BSEP
, .stion were CR9A, CR9XA, CR98,
EQ Program.
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and CR9XB.
These relays prnviae the logic for alignment of
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valves / dampers associated with the SBGT operation.
EER 86-0516 ras
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prepared by the licensee to justify continued operation of Units 1
and 2 with the relays that were installed. The evaluation concluded
that the relays will perform their safety function before the harsh
environment could potentially affect the accomplishment of the safety
function and subsequent foilure of the relays will not disable a
required safety function.
The licensee determined that the relays
installed in Unit I were the same (GE Type 2810) as those which were
qualified with the unit's motor control center. QDP-68 was revised
to document the qualification of Unit I relays (GE Type CR2810) which
were identical to qualified relays in the unit's motor control
center.
For currently installed Unit 2 relays (GE Type CR120) a PNSC
Action Item was established to replace the SBGT relays CR9A, CR9XA,
CR98, CR9XB during a future outage of sufficient length commensurate
with procurement of replacement relays and scheduling of the work
activities.
Expected completion date is April 22, 1988.
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During the periods, December 1985 until November 1986 on Unit 1 and
May 1986 until November 1986 on Unit 2, the licensee was in violation
with the requirements of 10 CFR 60.49, in that the SBGT relays (CR9A,
CR9XA, CR98 and CR9XB) were not identified on the EQ list as being
used on EQ equipment and the licensee did not have documentation to
demonstrate qualification.
This violation was identified by the
licensec ss part of corrective actions for a previous EQ program
deficiency on HPCI skid mounted components.
The licensee was
conducting a re-review of the as-built configurations of all skid
mounted EQ components to verify that they match existing EQ docu-
mentation.
The licensee's corrective actions included documenting a
justification for continued operations, evaluating the deficiency for
deportability, establishing qualification for Unit I relays and
scheduling replacement of the Unit 2 relays.
Subsequent to this
finding the licensee identified on March 11, 1987 that Unit 1,
Train 8 SBGT temperature switches (1-VA-TS-5296, -52971, -52298-1,
and -5298-2) were terminated using an unidentified hookup wire with
blue colored insulation.
In Ladition, the licensee found unqualified
Vulkene wire used on the other three trains of SBGT.
This item
appears to indicate that the !icensee's re-review of skid mounted
components was inadegnte.
The above item is identified as Violatian 325, 324/87-22-03, Standby
Gas Treatment Relays Not Documented Environmentally Qualified. With
the identification of this violation, the unresolved item is now
considered closed,
f.
(Closed) Unresolved Item 325, 324/87-06-05a.
RCIC steam admission
valve terminal block.
During the sampling of Limitorque valves in
response to IE Notice 86-03, the licensee found on March 10,1987, a
Kulka terminal block in the actuator for Valve 1-E51-F04E.
Kulka
terminal blocks were not on the master list and the licensee did not
have any test reports that qualified the terminal blocks.
The
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licensee subsequently qualified the 'Kulka terminal blocks in the
timitorque valve actuators by comparison to the Marathon 300 terminal
blocks. The Marathon blocks were qualified in QDP-28 and QDP-29, and
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reference to the Kulka termir.al blocks was included in order to
permit the Kulka blocks to remain until the valve actuators are
upgraded to Categcry I.
Contrary to paragraphs (d), (f), and (f' of 10 CFR 50.49, at the time
of the discovery of the Kulka termin 1 . lock, the licensee (1) did
not have the Kulka terminal blocks on the Master List of qualified
equipment, (2) did not have the terminal block tested for qualifi-
cation, and (3) did not have documentation to verify qualification of
the terminal block. This identified as Violation 325/87-22-04, Kulka
Terminal Blocks Not Documented Environmentally Qualified.
During this inspection, the licensee discovered Valve 2-E11-F004A
with an unqualified terminal block manufactured by Cinch that was
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installed by the vendor. Contrary to paragraphs (d), (f;, and (j) of
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10 CFR 50.49, at the time of the inspection, the licensee (1) did not
have the Cinch terminal block on the Master List of qualified equip-
ment, (2) did not have the terminal bicek tested for qualification,
and (3) did not have documentation to verify qualification of the .
terminal block.-
The licensee should have known the potential for
non-environmentally qualified terminal, blocks existed.
(IE Notice
83-72 addressed underrated terminal blocks as well as IE Notice
84-78.)
Due to an inadequate verification by receipt inspection
and/or field walkdown, the non-qualified terminal block was not
discovered until this inspection.
This item is identified as Viola-
tion 324/87-22-04, Cinch Terminal Blocks Not Environmentally Quali-
fled.
g.-
(Closed)UnresolvedItem 325, 324/87-06-05b. 'SBGT system temperature
switch leads.
With the unit defueled, the licensee found on
March 11, 1987, that leads connected to the 18 SBGT system deluge
system temperature switches (TS1, TS3, TSS, and TS6) were terminated
using unidentified hookup wire for extending the lead wires of the
four temperature switches.
The unidentified wire was not qualified
for this application at BSEP.
Therefore, the wire was replaced with
qualified Rockbestos FW III single-conductor wire. The other SBGT
trains on Units 1 and 2 were field inspected to confirm use of
qualified wire.
The licensee also identified unqualified Vulkene
wire used on the other trains of SBGT for both units.
The licensee developed Engineering Evaluation Report No. 87-0179 to
document their evaluation of the unidentified hookup wire utilized
for Unit 1 Train 8 SBGT temperature switches to determine system
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operability and to assist in determining deportability. The licensee
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determined that it was not reportable. However, subsequent review by
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NRC indicates that it is reportable under 10 CFR 50.73, paragraph
(a)(2)(V).
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Samples of the unidentified wire were sent to the Harris Environ-
mental and Energy (E&E) Center for chemical and material evaluation.
It was concluded from this analysis that the material was a flouro-
carbon polymer, similar to teflon or a teflon-like compound.
For
analysis purposes, the licensee considered that the material was pure
teflon.
The licensee concluded that the operation of the IB SBGT
skid would be unaffected ur. der High Energy Line Break (HELB) condi-
tions, because of good high temperature dielectric properties of
teflon insulation materials.
However, under post-LOCA conditions it
was concluded '. hat the wire insulation could degrade after 11 days
causing loss of the IB train of SBGT.
The EQ Equipment List speci-
fies a "Long" operation time for the SBGT filter skid of 30 days.
It
is concluded that this unidentified wire is not qualifiable for
post-LOCA operations beyond 11 days.
In addition, the Vulkene wire
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identified on the other three trains is also not considered qualified
but the licensee considers it to be qualifiable,
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Technical Specification 3/4.6.6, Containment Atmosphere Control
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Standby Gas Treatment System, LCO 3.6.6.1, states that "two (2)
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independent standby gas treatment subsystems shall be operable in
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modes 1, 2, 3, and 5, and when irradiated fuel is being handled in
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the secondary containment."
The licensee did verify that the other
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SBGT trains on both units did not contain unqualifiable jumper wires.
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10 CFR 50.49(d), (f), and (j) respectively require, in part, that (1)
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a list of electric equipment important tr safety be prepared, and
infurma tion concerning performance specifications, electrical
characteristics and postulated environmental conditions for this
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equipment be maintained in a qualification file; (2) each item of
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electric equipment important to safety shall be qualified by testing
of, or experience with, identical or similar equipment, and qualifi-
cation shall . include a supporting analysis to show that the equip-
ment, and the qualification shall include a supporting analysis to
show that the equipment to be qualified is acceptable; and (3) a
f
record of the qualification of the electric equipment shall be
maintained in a qualification file in an auditable form to permit
verification that the required equipment is qualified and that the
equipment meets the specified performance requirements under postu-
lated environmental conditions.
Contrary to the above, on March 11, 1987, and as far back as
December 1985 this unidentified teflon, type wire was not on the EQ
list as being used on EQ equipment and the licensee did not have
documentation to demonstrate qualification.
The above is identified as Violation 325, 324/87-22-05, SBGT
Temperature Switch Leads Not Environmentally Qualified.
This unre-
solved item is considered closed.
h.
(Closed) Unresolved Item 325, 324/87-11-04.
HPCI Condensate Float
Switches not EQ Documented.
The licensee, pursuant to the identi-
.'
fication of the Woodward speed sensor problem, conducted a thorough
review of HPCI skid mounted components to verify their EQ status.
During the course of this review, Units 1 and 2 condensate float
switches were demonstrated to be not environmentally qualified by
existing documentation.
The switches do not perform a safety function, however they are
connected to the HPCI turbine 125 VDC actuation circuit.
A failure
mode and effects analysis performed by licensee revealed that should
a ground develop as a result of the condensate high level float
switch failure, no loss of function of the HPCI turbine would result.
Licensee management has also prepared Engineering Evaluation Report
(EER) No. 87-0137, Revision 0, and 1, to present evidence that the
switches are qualifiable.
Further, the switches were successfully
environmentally qualified by GE as documented in Attachment I for EER
No. 87-0137.
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Information concerning maintenance activities l required to ensure
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qualification of the switches was. requested by the inspectors during-
the inspection of July 6-10, 1987.
This information which was not
readily available at the time has been addressed in revision 1 to EER
No. 87-0137.
The licensee has determined that there are no specific
maintenance ' activities required to maintain the EQ status- of ~ the
. switches.
An operating (mechanical) qualified life of 18 years has
been calculated for the switches.
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Corrective actions developed and implemented by licensee management
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to address this issue includes a Justification. for Continued Ope-
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ration (JCO) documented in EER 87-0137. Long term corrective action
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may either be the implementation of a plant modification to remove
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the HPCI gland steam exhauster condensate high level switch from HPCI
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actuation / control circuity; or the procurement of the required
documentation from GE.
The inspector was informed tht corrective.
action in the form of a plant modification has been scheduled for a
plant outage (planned / unplanned) of appropriate length.
Contrary to paragraph (d) and (j) of 10 CFR 50.49, as far back as
November 30, 1985, the. licensee (1) did not have the HPCI condensate
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float switches on the Master List of qualified equipment;-(2) did not
have documentation to verify qualification of the HPIC compensate
float switches in an auditable form.' This is identified as Violation
325/87-22-06,324/87-22-06. HPCI Float Switches Not Documented Environ-
mentally Qualified.~
1.
(Closed) Unresolved Item. 325, 324/87-11-05, SBGT Accident Radiation
Levels.
The licensee discovered that post-accident radiation levels
assumed for qualification of the SBGT skid and documented in QDP-68
failed to account for the increase in radiation levels due to the
accumulation of. radioactive gas and particulate within the carbon
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filters.
QDP-68, Rev. O, spec 1fied a total integrated dose reen by
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the SBGT skids of only 1 x 10 rads. However, as stated above, the
accumulation of radioactive gas and particulate
would cause the
radiation levels to increase significantly beyond this total inte-
grated dose, gheFSAR,Section 15.6.4.5.3, specified an integrated
dose of'4 x 10 rads post-LOCA for the fan motor.
To resolve this qualification problem and to document justification
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for continued operation of BSEP Units 1 and 2, the licensee, in EER
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87-0133, Rev. O, performed additional calculations of integrated
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irradiation dose for the SBGT skid and reviewed existing EQ quali-
fication data to confirm that SBGT skid components were still
qualified to the newly calculated doses.
No deficiencies were
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identified.
This iter is considered closed.
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4.
Licensee Actions on Previously Identified Inspector Followup Items
a.
(Closed) Inspector Followup Item 50-325, 324/85-14-01, Q-List Program
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Changes.
During the above inspection, the inspectors observed that
the Q-List Group had been classifying as Q or non-Q, piece parts of
major plant comp (onents and documenting the results of their evalua-
tions on three
3) part memorandums.
These evaluations were being
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used by plant staff in classifying as Q or non-Q replacement compo-
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nents on maintenance and procurement request; however, this method of
evaluations was not procedurally addressed.
The licensee committed
during this inspection to revise Volume XI, Book 2, of the Plant
)
Operating Manual to incorporate steps for processing component parts
evaluations.
Subsequently, (in revision
28 of Volume XI, Book 2)
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the licensee incorporated instructions for component / plant evalu-
)
ations by inclusion of a three page form entitled "Q List
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Evaluation." The procedure now requires that each evaluation receive
an independent review.
In addition, if the evaluation constitutes
the downgrade of an item from Q to non-Q status, the evaluation must
include the basis used in determining that the subject change will
not constitute an unreviewed safety question raise a potential safety
concern for the other unit.
The inspectors considered this to be
acceptable.
Another concern identified during the subject inspection was that
Engineering Evaluation Reports (EERs) contain information regarding
Q-List classification of components .
However, the Q-List Group who
had responsibility for revising the Q-List was not on the required
distributions for copies of the EERs.
The licensee indicated that
although the Q-List Group was not on the required distribution they
has been receiving copies of EERs.
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The licensee has subsequently revised the Engineering procedure
(ENP-12) that specifies distributions of EERs to include the Q-List
)
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Coordinator on the required distribution list for all EERs.
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This item is now considered closed.
b.
(Closed) Inspector Followup Item 50-325, 324/85-26-01, Sign-offs of
Qualification Data Packages.
The licensee completed all required
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actions to satisfy the commitment to have the QDPs completed prior
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to the restart of Unit 1.
This action was verified to have been
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completed in October 1985.
This item is now considered closed.
c.
(Closed) I*spector Followup Item 50 325, 324/85-26-02.
Completion of
Qualification Data Packages.
The licensee completed all required
actions to satisfy the commitment to have the QDPs completed prio- to
the restart of Unit 1.
This action.was verified to have been
completed in October 1985.
This item is now considered closed.
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d.
(Closed) Inspector Followup Item 50-325, 324/85-26-03, Generic File
Improvement.
The licensee revised ENP 34.3, " Qualification Data
Package (QDP) Control Procedure," in order to clarify the instruc-
tions and wording of the EQ Evaluation Form, the resolution of
Information Notices, and the EQ Maintenance Summary.
The procedure
- provides for adequate and consistent evaluations for QDPs.
This was
verified by review of the document. This item is considered closed.-
e.
(Closed) Inspector Followup Item 50-325, 324/85-26-06, Damaged Cable
on Installed NDT International Accelerometer.
The damaged cable was
repaired under PM-84-180 on 9/3/85.
Additional cable damage was
found and repaired at the same time. This was verified by review of
the plant modification work package.
This item is now considered
closed.
f.
(Closed) Inspector Followup Item 50-325, 324/85-26-07, Westinghouse
Electrical Penetration Assemblies (EPAs).
The licensee ' revised
QDP-14. " Westinghouse Electrical Penetrations Class B, C, E, and F",
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to include functional requirements analysis for the EPAs.
This was
verified by review of the document.
This item is now considered
closed,
g.
(Closed) Inspector Followup Item 50-325, 324/85-26-09, Qualification
.of NDT International Accelerometer.
The licensee prepared QDP-58 on
October , 17 1985 to qualify the NDT International accelerometers and
associated coaxial cable to NUREG 0588, Category I.
This QDP was
prepared and approved prior to the Unit I restart in 1985. This was
verified by review of the document. This_ item is' considered closed,
h.
(Closed) Inspection Followup Item 50-325, 324/85-26-08 Barten Model
289A Switches Design Basis Accident (DBA) Operating Time.
The EQ inspection conducted August 12-16, 1985, iden, ,4ed incon-
sistencies in the DBA operating time used
by the 1.
.asee for
radiation environmental qualification of Barton Model 289A switches
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Ell-PDIS- N021A and B and E21-FS-N006A ar# B.
Qualification Docu-
mentation Package (QDP) 38 showed a 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 showed the DBA operating time as "Long", (Long
being defined as 30 days).
Licensee management was unable to provide
documentation substantiating this change.
Licensee's corrective action regarding the above was reviewed during
the EQ followup inspection.
The inspectors determined that an
evaluation of post-accident operating item requirement for the RHR
and Core Spray Mini flow bypass valve controls had been performed.
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The inspectors regarded thi's evaluation as deficient, however, in
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that it was performed outside of the controls of licensee engineering
desiga prugram,' and a 10 CFR 50.59
safety evaluation was never
performed for changes to design basis information en the EQ list.
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Licensee management subsequently prepared EER 87-0320, revision 0, to
address the above deficiencies.
The inspectors reviewed this report
and determined that an analysis of the RHR LPCI'and Core Spray system
,
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operations, with reference to appropriate sections of the FSAR, had
been performed for LOCAs with large break design basis accident (DBA)
and small steam line breaks.
The licensee had documented and
justified the basis for the short time DBA operating time used for
radiation environmental qualification of the pressure switches.
Additionally, a 10 CFR 50.59 safety evaluation was performed to
address the safety significance of the change in the operation time
of the pressure switches.
Based on the review of this report, this
item is considered closed.
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