ML20237H453

Insp Repts 50-325/87-22 & 50-324/87-22 on 870706-10. Violations Noted.Major Areas Inspected:Previously Identified Environ Qualification Deficiencies

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: ML20237H432 ML20237H453
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

/pe Afog 'o NUCLEAR REGULATORY COMMISslON

[s n REGION !!

g j 101 MARIETTA STRE ET, N.W. j

• c ATL ANTA, GEORGI A 30323

3 \...../

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. > _b Date

M /Signed

-F7

SW

Merriweathe~r, Reactor Inspector

V

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Date Signed

C. W Paulk

C . F . Srh

"An ik S Date

'7- / A

Signed

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Approved B M

T. E. Conlon, Section Chief

dn< rv' bZ / ~b

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

DR 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

l *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

i types, plant equipment that are qualified to Division of Operating

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Reactors (D0R) Guidelines and delineates generic reasons for not

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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I 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

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.

- Phase B will perform the re

on the Phase A direction) as quired preliminary

well as generate theengineering

IPBS-912 (based

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

Budgeting, effective)

and Scheduling a separate

(IPBS) activity Integrated Planning,

(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

l 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 I

upgrade of EQ equipment during -the engineering design process.  !

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 ,;

'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 l

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:

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Is it reasonable to conclude that the installed device would

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-

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

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

J 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-

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.910 non-metallic component was determined by a literature search.

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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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 '

licensee took inadequate corrective action after identifying the .

Vulkene wire during its survey of the Unit 2 valve operators. The '

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 l

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, i

the licensee discovered that o" Tication documentation for four )

control relays per SBGT unit v's ' ' Mrtently omitted from the BSEP

EQ Program. The control rela,3 - ~ , .stion were CR9A, CR9XA, CR98, j

and CR9XB. These relays prnviae the logic for alignment of j

valves / dampers associated with the SBGT operation. EER 86-0516 ras I

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

licensee subsequently qualified the 'Kulka terminal blocks in the

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timitorque valve actuators by comparison to the Marathon 300 terminal

blocks. The Marathon blocks were qualified in QDP-28 and QDP-29, and 4

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

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with an unqualified terminal block manufactured by Cinch that was

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 +

operability and to assist in determining deportability. The licensee j

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determined that it was not reportable. However, subsequent review by

NRC indicates that it is reportable under 10 CFR 50.73, paragraph

(a)(2)(V). ]

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

h 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 I

Standby Gas Treatment System, LCO 3.6.6.1, states that "two (2)  !

independent standby gas treatment subsystems shall be operable in  !

modes 1, 2, 3, and 5, and when irradiated fuel is being handled in  !

the secondary containment." The licensee did verify that the other 1

SBGT trains on both units did not contain unqualifiable jumper wires. .

10 CFR 50.49(d), (f), and (j) respectively require, in part, that (1) -

a list of electric equipment important tr safety be prepared, and

infurma tion concerning performance specifications, electrical

characteristics and postulated environmental conditions for this j

equipment be maintained in a qualification file; (2) each item of '

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

L 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.

'

Corrective actions developed and implemented by licensee management '

,

to address this issue includes a Justification. for Continued Ope-

[

ration (JCO) documented in EER 87-0137. Long term corrective action

l may either be the implementation of a plant modification to remove

l the HPCI gland steam exhauster condensate high level switch from HPCI

l 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

i 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

the SBGT skids of only 1 x 105rads. 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 1

for continued operation of BSEP Units 1 and 2, the licensee, in EER l

87-0133, Rev. O, performed additional calculations of integrated j

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 J

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 t

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

tions onplant comp

three (onents

3) part and documenting

memorandums. These evaluations the resultswere

of their

beingevalua-

used by plant staff in classifying as Q or non-Q replacement compo-

}

L 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)

h the licensee incorporated instructions for component / plant evalu-

) ations by inclusion of a three page form entitled "Q List

J 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

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has been receiving copies of EERs.

The licensee has subsequently revised the Engineering procedure

(ENP-12) that specifies distributions of EERs to include the Q-List )

_ Coordinator on the required distribution list for all EERs. j

l

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

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  !

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", l

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 1

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.

l The inspectors regarded thi's evaluation as deficient, however, in

l

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 ,

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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