View source for W3P88-1828, Forwards Response to Request for Addl Info Re Equipment Qualification of RTV Seals & Other Issues,Including Borg- Warner Qualification Test Rept DEI-TR-850100-18,SPEER 85-162 & Electrical Design Criterion 8

{{Adams
| number = ML20205H292
| issue date = 10/18/1988
| title = Forwards Response to Request for Addl Info Re Equipment Qualification of RTV Seals & Other Issues,Including Borg- Warner Qualification Test Rept DEI-TR-850100-18,SPEER 85-162 & Electrical Design Criterion 8
| author name = Burski R
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = Beach A
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000382
| license number = 
| contact person = 
| document report number = W3P88-1828, NUDOCS 8810310014
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 137
}}

=Text=
{{#Wiki_filter:_____ _.
I
                                                              . e. o. cox s0340 LOUISI POWE  R & ANA LeGHT/   sir NEW 8AnoNNestatti OnLEANS, LOUISIAN A 70160 * (504) 595 3100
    $ i M E.sYt$
October 18, 1988 W3P88-1828 A4.05 QA U.S. Nuclear Regulatory Conmission ATTN    Document Control Desk Washington, D.C. 20555 ATTENTION:    A.B. Beach

==Subject:==
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Request for Additional Information on Equipment Qualification Issues In response to your request for additional information expressed at the recent Enforcement Conference on Equipment Qualification Issues, we submit the followings o    The Borg-Warner Qualification Tsst Report (dei-TR-850100-181 is provided to clear up the issue of qualification cf RTV as a teeporary seal.
o    SPEER 85-162 is sleo included to support qualification of RTV seals, o    Electrical Design Criterion No. 8 "Power Cable A pacities" provides evidence that naintaining cable temperatures belev 90*C is indeed part of Waterford 3's design program.
o    EQ Maintenance Input File No. 6.2/16.2 Rev. 2, the appropriate portion is provided to show the location of instructions to Engineering for naintaining cable temperatures belov 90'C.
o    The detailed vrite-up which supports the outline presentation provided at the conference.
As indicated at the conference. Louisiana Power & Light pronptly addressed the issues raised during the 1986 Inspection and is anxious to close all itees identified in Inspection Report 86-32.
I E310310014 QS1018,,                              f FE6 ADOCL usevi % .                           -(A P                  I D'-                          g l                             "AN EQUAL OPPORTUNITY EMPLOYER"

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!       Page 2                                                                      i W3P88-1828                                                                  I i
If there is any additional information that you need or if there is         ;
anything we can do to expedite the closure of these issues, please contact  !
J.E. Novard at (504) 464-3202.
Yours very truly,
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Yurski$g,'
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                                               $a,t1 t'er                          I l
u/ uclear N Safety 5 ReRulatory Af fairs     l l
RTB r JEHi s e r'                                                          j l       Attachments cc (w/o attach.it    J.A. Calve, NP.C-NRR                                  I D.L. Wigginton, NRC-NRR                               i NRC Resident Inspectors Office i                            E.L. Blake                                            f W.M. Stevenson                                        i I                                                                                  i i
1 h
i I
I l

o 4
BACKGROUND o          EQ PROGRAM DEVELOPED IN CLOSE COORDINATION WITH STAFF.
o          SUBSTANYIAL INITIAL EFFORTS Dll .aG LICENSING (1979-1983)
RECEIVED EXTENSIVE STAFF REVIEW.
o          BASED ON STAF' REVIEW AND JANUARY 1983 ON-SITE INSPEC-TIONS OF E0, STAFF CONCLUDED IN SSER 8 THAT LP8L COM-PLIED WITH 10 CF.1 50.49.
o          LPal AS A RESULT OF'0BSERVED INDUSTRY / STAFF EVOLVING EQ KNOWLEDGE, IMPLEMEi'TED EQ REVERIFICATION PROGRAM IN                                                                              -
1984-1985. KEPT STIFF INFORMED.
i               o         REVERIFICATION PROGRAM REQUIRED SIGNIFICANT EFFORT, INCLUDING ADDITIONAL \'ALKDOWNS.                                                                                                  ,
o         BASED ON REVERIFICATION. PROGRAM WAS STRENGTHENED.
o         LPal VERY ACTIVE IN CONTINUING TO MONITOR INDUSTRY E0 ISSUES. MEMBER OF NUCLEAf! UTILITY GROUP ON E0 MEETS REGULARLY WITH STAFF TO DIiCUSS AND RESOLVE EQ ISSUES.
o          IN 

==SUMMARY==
LP&L EXPENDED SIGNIFICANT EFFORTS TO ASSURE E0 PROGRAM ACCEPTABLE PRIOR TO EQ DEADLINE.
EFFORTS INCL.UDED TWO SIGNIFICANT VERIFICATION PROGRAMS AND WALKDOWNS.
KEPT STAFF FULLY INFORMED 0F ALL EFFORTS CONTINUE TO CLOSELY MONITOR INDUSTRY ACTIVITIES TO IMPROVE PROGRAM,
      -                                                    111-1 l

    .c 1
INSPECTION REPORT j      o     INSPECTION CONDUCTED IN LATE 1986 - EARLY 1987 o     STAFF DETERMINED LP8L HAD IMPLEMENTED A PROGRAM TO MEET THE REQUIREMcNTS OF 10 CFk 50,49 o    STAFF SUBSEQUENTLY REQUESTED DISCUSSION OF FIVE POTEN-TIAL VIOLATIONS / UNRESOLVED ISSUES AND TWO OPEN ITEMS, POTENTIAL VIOLAT!0NS o    BORG-WARNER MOTOR OPERATOR (50-382/8632-01) o     ITT BARTON TRANSMITTER (50-382/8632-02) o    OKONITE SPLICE ON CHARGING PUMP MOTOR (50-382/8632-03) o    THOMAS 8 BETTS CONNECTORS (50-382/8632-04) o    BlW CABLE ASSEMBLES (50-382/8632-06 AND 07)
OPEN ITEMS o    RTV SEALANT ON ROSEMOUNT TRANSMITTERS (50-382/8632-14) o    OKONITE SKV CABLE AND SPLICES (50-382/8632-10)
III-2

    .          i 7
i DISCUSSION TOPICS 2
0          MINDFUL OF THE ISSUES DISCUSSED IN GENERIC LETTER 88-07 DISCUSSION TOPICS 4NCLUDE THESE CONSIDERATIONS o          AS APPROPRIATE, TOPICS INCLUDE:                                                                                          I STAFF FINDING LPal' POSITION ON EACH FINDING LPal POSITION ON o      "CLEARLY SHOULD HAVE KNOWN" o     SAFETY SIGNIFICANCE MITIGATION FACTORS STATUS OF EqulPNENT i
III-3

it? '                                                                    i t
V
                                                   ~ ITEM NO. 1                                                     -
P0TENTIAL ENFORCEMENT-                   .
t BORG-WARNER, MODEL 39400 VALVE OPERATORS (50-312/8632-01)                                        '
STAFF FINDINGS THE EQ FILE FOR BORG-WARNER MOTOR-0PERATORS DID NOT ESTABLISH
                       - QUALIFICATION BECAUSE SIMILARITY BETWEEN THE TESTED MODEL AND THE INSTALLED MODEL HAD NOT BEEN DEMONSTRATED,                                   -
9 l
b 6
i 0   9.

                 ?
    ~*I                                                                           ,
LP8L'S POSITION l'
              .o    LP8L' MAINTAINS THAT EQUIPMENT WAS AND CONTINUES TO BE QUALIFIED.
o   BACKGROUND AND BASES FOR POSITION FINDING INVOLVES 1983-1985 TESTING
                   -      APRIL 9, 1984 LETTER:      PROVIDED TEST STATUS EARLY MAY, 1935 TESTING, ANOM0 LIES NOTED
                   -      MAY 7, 1985 CONFERENCE CALL: STAFF AGREED WITH COURSE OF ACTION INCLUDING POSITIONS ON JC0
                   -      MAY 16, 1985 LETTER: DOCUMENTED JC0, NOTED POTEN-TIAL MODIFICATIONS TO ACHIEVE QUALIFICATION AND COMMITTED TO PROVIDE QUALIFICATION INFORMATION BY NOVEMEER 1, 1985                                       !
                   -      NOVEMBER 1, 1985 LETTER: STATED BASIS FOR QUALIFI-CATION.
PROVIDED SCHEDULE FOR NON-ESSENTIAL MODIFICATIONS NO RESPONSE FROM STAFF, LP8L ASSUMED CONCURRENCE LP8L PERFORMED MODIFICATIONS ON SCHEDULE               :
NO TECHNICAL RESPONSE FROM STAFF TAKING ISSUE WITH     t NOVEMBER 1, 1985 LETTER,                               !
LP8L BASIS FOR QUALIFICATION STILL VALID.
IV.A.1-2 l

LP8L'S POSITION REG'ARDING WHETHER ENFORCEMENT ACTION SHOULD BE TAKEN UNDER THE EQ ENFORCEMENT POLICY
,         ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:
l 0     LP8L SHOULD NOT HAVE CLEARLY KNOWN A DEFICIENCY EXISTED IN THAT VENDOR SUPPLIED INFORMATION (QUALIFICATION TEST REPORT) WHICH WHEN COUPLED WITH THE SPECIFIC ANALYSIS (DOCUMENTED IN THE NOVEMBER 1, 1985 LETTER TO THE STAFF), PROVIDED REASONABLE ASSURANCE OF QUALIFICATION.
THE STAFF WAS MADE AWARE OF LP8L'S ACTIONS AND POSITION PRIOR TO NOVEMBER 30, 1985 AND DID NOT EXPRESS ANY CONCERNS THAT ADVERSELY IMPACTED LP8L'S QUALIFICATION DETERMINATION.
o    NO ESCALATED ENFORCEMENT UNDER GL 88-07 BECAUSE:
PRIOR TO THE INSPECTION THE STAFF WAS PROVIDED INFORMATION REFLECTING THE QUALIFICATION OF THE EQUIPMENT.
               -                ALSO DURING THE INSPECTION, LP8L'S QUALIFICATION BASES WAS PROVIDED TO THE STAFF.
               -                THE ISSUE WAS NOT SAFETY SIGNIFICANT,
 ;                                               IV.A.1-3

MITIGATION FACTORS o LP8L IDENTIFIED THE UNDERLYING PROBLEM AND KEPT THE STAFF FULLY INFORMED OF THE STATUS OF liND LP8L'S POSI-TION REGARDING THE ISSUE.
1 o THE CONDITION WAS ISOLATED IN CONTENT AND WAS NOT SAFETY                                                                                               <
SIGNIFICANT.
o THE CONDITION WAS RESOLVED ON A SCHEDULE PROVIDED TO THE STAFF PRIOR TO NOVEMBER 30, 1985.
o LP8L CLEARLY DEMONSTRATED BEST EFFORTS TO COMPLETE ALL EQ REQUIREMENTS BEFORE THE NOVEMBEP. 30, 1985 DEADLINE.
o THE CONDITION WAS ISOLATED TO TWO COMPONENTS OF ONE SYSTEM.
IV.A.1-4

==SUMMARY==

o STATUS:
EQUIPMENT IS FULLY QUALIFIED WITH ALL MODIFICATIONS COMPLETED.
o LP8L POSITION:
N0 VIOLATION IN ANY EVENT, o    NOT "CLEARLY SHOULD HAVE KNOWN" o    NO SAFETY SIGNIFICANCE (JCO) o    SUBSTANTIAL MITIGATION WARRANTED IV.A.1-5

1 ITEM N0. 2 ITT BARTON TRANSMITTER SUBMERGENCE (50-382/8632-02)
STAFF FINDING LPal DID NOT ADEQUATELY ESTABLISH QUALIFICATION FOR ITT BARTON TRANSMITTERS BECAUSE SUBMERGENCE QUALIFICATION HAD NOT BEEN DEMONSTRATED IN ACCORDANCE WITH NUREG-0588 WHICH RE-QUIRES THAT A TYPE TEST BE USED T0 QUALIFY EQUIPMENT LOCATED i
IN A SUBMERGED ENVIRONMENT.
THE STAFF ALSO STATES THAT LP8L'S RESCINDING 0F THE SAFETY-RELATED FUNCTIONS OF AFFECTED TRANSMITTERS SUPPORTS THE j                                              STAFF'S CONCLUSION.                                                                      -
t L
IV.A.2-1                                 I i
4

LPal POSITION LPaL DENIES THE PROPOSED VIOLATION IN THAT:
o                       CONTRARY TO THE STAFF CONCLUSION, 10 CFR 50.49 AND NUREG-0588 ALLOWS FOR TYPE-TESTING WITH ANALYSIS TO SUPPORT QUALIFICATION. THESE DOCUMENTS DO NOT PRECLUDE APPLICATION OF THIS POSITION TO SUBMERGENCE ISSUES.
o                       ITT BARTON AND LPal CONTINUE TO MAINTAIN AND STRONGLY SUPPORT THEIR POSITION THAT THE TEST PLUS ANALYSES THAT EXISTED PRIOR TO NOVEMBER 30, 1985 ESTABLISH QUALIFICATION FOR SUBMERGENCE.
o                       THE STAFF HAS NOT TECHNICALLY RESPONDED TO THE ANALYSIS ON THE LPal DOCKET.
o                       LPal'S ANALYSIS WHICH WAS FORWARDED TO THE STAFF ON FEBRUARY 2, 1987, DID NOT RESCIND THE SAFETY-RELATED FUNCTION FOR THE TRANSMITTERS.
IV.A.2-2
: i. , . , . . .

CONTANMENT / SAFETV NJECTON SUMP LEVEL NSTRUMENTATON ARRANGEMENT 10/3/se at                   + 9'S'
                                                                                       ~~
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                                                                                                                 -2 3'0' REFERENCE 5430 At 17.1 & 19.1                                                                                             -26
           + FIELD WE ASUMEMENTS                                                                 CONTAWWENT SUWP
: j.                  .
LP8L'S POSITION REGARDING WHETHER ENFORCEMENT ACTION SHOULD BE TAKEN UNDER THE E0 ENFORCEMENT POLICY t
ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:
o      LP8L SHOULD NOT HAVE CLEARLY KNOWN THAT A DEFICIENCY EXISTED IN THAT:
LP8L HAD VENDOR SUPPLIED INFORMATION ESTABLISHING QUALIFICATION.                                      l THERE WAS NO INFORMATION THAT WOULD HAVE MODIFIED LP8L'S APPROACH TO QUALIFICATION.
THE BARTON TRANSMITTERS AT ISSUE WERE REVIEWED BY THE STAFF IN 1982-3 AND SUBMERGENCE WAS NOT RAISED  ;
AS AN ISSUE. .SEE SSER 5, APPENDIX 3B AND SSER 8,  t SECTION 3.11.
ESCALATED ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:
,       o     THE DEFICIENCY IS NOT SAFETY SIGNIFICANT:                 (
IMPACTED INSTRUMENTS ARE NOT THE PRIMARY MONITOR FOR SAFETY INJECTION SUMP LEVEL INDICATION.
UPPER RANGES OF IMPACTED INSTRUMENTS ARE            I i                   OVERLAPPED BY OTHER QUALIFIED SI SUMP LEVEL         !
INSTRUMENTS                                         !
i                                                                       i IV.A.2-3 i

    ..       O                                                                                       l MITIGATION FACTORS o   THE CONDITION WAS ISOLATED IN CONTENT.
  ,           a                o   THE CONDITION WAS NOT SAFETY SIGNIFICANT.
o  LPal CLEARLY DEMONSTRATED BEST EFFORTS TO COMPLETE ALL           .
                                 .EQ REQUIREMENTS BEFORE THE NOVEMBER 30, 1985 DEADLINE.
o   THE CONDITION WAS PROMPTLY ADDRESSED.
a                             o   THE CONDITION WAS IF0 LATED TO TWO COMPONENTS OF ONE             "
                                 . SYSTEM.
4
;                                                                                                  L i
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l                                                                                                  I
!                                                        IV.A.2 I4 it i

==SUMMARY==

o STATUS:
EQUIPMENT CONTINUES TO BE QUALIFIED.
o LP&L POSITION:
EQUIPMENT WAS AND CONTINUES TO BE QUALIFIED.
     -    IN ANY EVENT, o    NOT "CLEARLY SHOULD HAVE KNOWN" o    N0 SAFETY SIGNIFICANCE o    SUBSTANTIAL MITIGATION WARRANTED IV.A.2-5

ITEM NO 3 OK0 NITE SPLICES ON GENERAL ELECTRIC CHARGING PUMP MOTORS
                .. _           (50-382/8632-03)
STAFF FINDING THE E0 FILE FOR GENERAL ELECTRIC (G.E.) CVC CHARGING PUMP MOTORS DID NOT ADEQUATELY ESTABLISH QUALIFICATION BECAUSE SIMILARITY BETWEEN THE TYPE-TESTED SPLICE AND THE INSTALLED OKONITE BOLTED-TYPE TAPE SPLICE HAD NOT BEEN ESTABLISHED.
IV.A 3-1

LPal POSITION o LP8L MAINTAINS THAT THE OKONITE TAPE / CEMENT SEALING SYSTEM WAS AND CONTINUES TO BE QUALIFIED, o BASIS FOR LPal POSITION:
THE WATERFORD 3 G.E. MOTOR HEATERS FOR CHARGING PUMP A/B ARE NOT IN OUR EQ PROGRAM AND WERE NOT AT THE TIME OF THE INSPECTION, THE ISSUE OF BOLTED TYPE SPLICES IS ADDRESSED OR QUALIFIED BY THE OK0 NITE TEST REPORT (NORN-3) AND THE PATEL ENGINEERING TEST REPORT (PEl-TR840704-1)
IV.A,3-2

==SUMMARY==

o STATUS:
QUALIFICATION NOT REQUIRED o LPal POSITION:
EQUIPMENT IDENTIFIED IN THE INSPECTION REPORT IS NOT IN E0 PROGRAM ITEM SHOULD BE CLOSED IV.A 3-3

ITEM N0, 4 THOMAS & BETTS BLIND BARREL CRIMP SPLICES IN LIMITOROVE MOTOR OPERATORS
_(50-382/8632-02)
STAFF FINDING THE EQ FILE FOR LIMITORQUE MOTOR OPERATORS DID NOT ESTABLISH QUALIFICATION BECAUSE SIMILARITY BETWEEN TESTED AND INSTALLED CABLE SPLICES (THOMAS a BETTS BLIND BARREL CRIMP SPLICES) HAD NOT BEEN ESTABLISHED. THE THRUST OF THE STAFF CONCERN IS THAT THE TEST REPORTS QUALIFYING LIMITORQUE MOTOR OPERATORS DID NOT STATE THAT THE THOMAS a BETTS SPLICES WERE ALSO TESTED.
IV A.4-1

t LP&L POSITION                                                               'f o                                              LPal MAINTAINS THAT THE CONNECTORS WERE AND CONTINUE T0 BE QUALIFIED.
* o                                             BASIS FOR POSITION:
THOMAS a BETTS CRIMP SPLICES WERE TESTED AND QUALIFIED IN LIMITORQUE TEST REPORT B00058 (WHICH INCLUDES 600198).
MC INSPECTION REPORT N0. 99900100/88-01 (AUGUST 1, 1988) CONFIRMS THAT THE CONNECTORS TESTED IN
;                                                                                  MOTOR OPERATORS OF THIS TYPE WERE THOMAS 8 BETTS.                                             ,
o                                              LP8L COMMITNENT REGARDING A RELATED ISSUE:
LPal IS AWARE THAT RECENT TESTING MAY RAISE QUES-                                             i TIONS REGARDING THE QUALIFIED LIFE OF THE CONNEC-                                             -
TORS. TO AVOID QUESTION, LPal WILL REPLACE THE CONNECTORS AT THE NEXT OUTAGE (WELL BEFORE THE f
EXPIRATION OF THE QUALIFIED LIFE SUGGESTED BY                                                 !
RECENT TESTING),
:                                                                                                                                                                                l c
-l IV A 4-2                                                                    l 1
l t
1 j

L LPal'S POSITION REGARDING WHETHER ENFORCEMENT ACTION SHOULD TAKEN UNDER TH:E EQ ENFORCEMENT POLICY                                                             F ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:                                                                     :
o      LPal SHOULD NOT HAVE CLEARLY KNOWN THAT AN EQ DEFICIENCY EXISTED IN THAT:                                                                                             ;
LPal HAD NO REQUIREMENT TO CONDUCT A DETAILED REVIEW 0F ALL SUBCOMPONENTS IN A PIECE OF EQUIPMENT TO ASSURE THAT ALL ARE REFERENCED IN A TEST REPORT, WHERE QA 0F THE VEND 0R PROVIDED THIS ASSURANCE.
IT WAS REASONABLE TO CONCLUDE THAT INTERNAL SUB-COMPONENTS TESTED WITH THE LIMITORQUE ACTUATORS WERE QUALIFIED CONCURRENT WITH THE OPERATOR.
IT WAS REASONABLE TO CONCLUDE THAT THE CRIMP CONNECTORS CONTAINED IN THE LIMITOROVE OPERATORS AT                                             -
WATERFORD WERE THE SAME AS THE TYPE TESTED CON-NECTORS AND WERE THEREFORE QUALIFIED.
A RECENT NRC INSPECTION CONCLUDES THAT THOMAS a BETTS CRIMP SPLICES WERE THE ONLY TYPE OF SPLICE PURCHASED OR USED BY LIMITOROVE DURING TESTING AND ACTUATOR PROCUREMENT TIME FRAME.
ESCALATED ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:                                                           i o
THE ISSUE IS NOT SAFETY SIGNIFICANT IN THAT THE CONNEC-TORS ARE QUALIFIED AND EVEN UNDER THE RECENT INDUSTRY                                                        t TESTS, THE CONNECTORS HAVE NOT EXCEEDED THEIR OVAllFIED l
LIFE.                                                                                                        ;
i IV.A.4-3 l
                                                                                                                                          ~

Q,*
l l
MITIGATION FACTORS                          I o LP8L'S ACTIONS DEMONSTRATE BEST EFFORTS TO COMPLETE ALL EQ REQUIREMENTS BEFORE THE NOVEMBER 30, 1985 DEADLINE.          !
o THE EQUIPMENT WAS AND CONTINUES TO BE QUALIFIED.                ;
i o THE REPLACEMENT BY THE END OF THE NEXT REFUELING 0UTAGE OF THE T8B SPLICES WITH AN UNDISPUTED QUALIFIED CONFIGURA-         I TION IS PROACTIVE AND REFLECTS LP8L'S PROMPT RESPONSE TO        !
I THE ISSUE.
o THE ISSUE IS LIMITED IN CONTENT AND IMPACTS ONLY THREE SYSTEMS.                                                        t i
r e
                                                                                                              .I i
f I
t I
I f
I i
IV.A.4-4                              I

==SUMMARY==

o STATUS:
InE CONNECTORS ARE QUALIFIED THE CONNECTORS WILL BE REPLACED BY THE END OF THE NEXT REFUELING OUTAGE, WELL BEFORE EXPIRATION OF QUALIFIED LIFE.
o LP8L POSITIONS:
THE CONNECTORS WERE AND CONTINUE TO BE QUALIFIED
     -     IN ANY EVENT, o     NOT "CLEARLY SHOULD HAVE KNOWN" o     NO SAFETY SIGNIFICANCE o     SIGNIFICANT MITIGATION WARRANTED IV.A.4-5

Gi ITEM N0. 5(A)
BIW CABLE ASSEMBLIES DBA TEMPERATURE-(50-382/8632-06)
I                                                                     . STAFF FINDING THE EQ FILE FOR CERTAIN BIW CABLE ASSEMBLIES DID NOT ADE-QUATELY ESTABLISH QUALIFICATION BECAUSE THE EQ FILE DID NOT SATISFY THE REQUIREMENTS OF NUREG-0588, CATEGORY II, PARA-
;.                        GRAPH 1.2(5) IN THAT IT DID NOT BASE TEMPERATURE QUALIFICA-TION (FOR MATERIALS WITHIN THE CONNECTOR / CABLE ASSEMBLY) ON 1
THE TEMPERATURE EFFECTS OF A MSLB AS MODIFIED BY A THERMAL l                         LAG ANALYSIS.
i:
S I
i I
i l
IV.A.5-1

s F
LP&L POSITION o LPal MAINTAINS THAT THE E0F FOR BIW CABLE ASSEMBLIES        -
WAS ADEQUATE TO JUSTIFY QUALIFICATION AND SATISFIED THE REQUIREMENTS OF NUREG-0588, CATEGORY II, PARAGRAPH          l 1.2(5).
o BASES FOR POSITION:
THERMAL LAG ANALYSIS AND TYPE TESTING PROVIDED IN     {
THE EQF PRIOR TO NOVEMBER 30, 1985 SATISFIES          !
NUREG-0588, CATEGORY II, PARAGRAPH 1.2(5).            !
THE THERMAL LAG ANALYSIS ASSUMED SURFACE TEMPERA-     i TURES THAT WERE IN EXCESS OF MSLB PARAMETERS. LP8L A.NALYZED ANY REMAINING AN0M0 LIES BY ARRHENIUS METHODS. THIS METHODOLOGY WAS ACCEPTED IN WATER-FORD'S SSER 5, PARAGRAPH 3.11.3.2.1.
(
THE COMBINATION OF THESE ANALYSES AND TYPE TESTING SHOWED QUALIFICATION IN EXCESS OF TEMPERATURE         '
PROFILE.
{
LP8L QUESTIONS WHETHER STAFF REVIEWED BOTH ANALY-l SES.                                                  j LP8L'S LETTER TO THE STAFF DATED FEBRUARY 2, 1987     !
PROVIDED NATIONAL TECHNICAL SYSTEMS TEST REPORT NO.   [
558-165l1 IN WHICH THE TESTED ACCIDENT PROFILE        l ENVELOPES THE WATERFORD MSLB PEAK TEMPERATURE.
THIS REPORT PROVIDED FURTHER VERIFICATION OF QUALIFICATION.
IV.A 5-2

  .r LP8L'S POSITION REGARDING WHETHER ENFORCEMENT ACTION' SHOULD BE TAKEN UNDER THE EQ ENFORCEMENT POLICY ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:
o    LP8L SHOULD NOT HAVE CLEARLY KNOWN THAT A DEFICIENCY EXISTED IN THAT ITS INTERPRETATION OF NUREG-0588, CATEGORY II, PARAGRAPH 1.2(5) WAS REASONABLE AND CONSIS-TENT WITH THE STAFF'S POSITION IN THE WATERFORD SSER, SUPPLEMENT 5.
ESCALATED ENFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:
o    THE ISSUE WAS NOT SAFETY SIGNIFICANT IN THAT THE INSTRU-MENTATION OF CONCERN WAS AND REMAINS FULLY QUALIFIED.
o    OTHER QUALIFIED INSTRUMENTATION EXISTS TO MONITOR CORE llEAT REMOVAL AND RCS INVENTORY.
IV.A 5-3

lilTIGATION FACTORS o LPat CLEARLY DEMONSTRATED BEST EFFORTS TO COMPLETE ALL EQ REQUIREMENTS BEFORE NOVEMBER 30, 1985.
o THE CONDITION WAS NOT SAFETY SIGNIFICANT.
o THE ISSUE WAS PROMPTLY RESOLVED.
IV.A.5-4

k

==SUMMARY==

o STATUS:
EQUIPMENT FULLY QUALIFIED o LP8L POSITI0th EQUIPMENT WAS AND CONTINUES TO BE QUALIFIED
         -    IN ANY EVENT, o    NOT "CLEARLY SHOULD HAVE KNOWN" o    NOT SAFETY SIGNIFICANT o    SIGNIFICANT MITIGATION WARRANTED IV.A.5-5

I
* i ITEM NO. 5(B)                            l I
BlW CABLE ASSEMBLIES REPLACEMENT SCHEDULES (50-382/8632-07)
! //
;V'    ,
h I                                                                           l STAFF FINDING                             i i
THE EQ FILE DID NOT ADEQUATELY ESTABLISH QUALIFICATION 1
BECAUSE CONTRARY TO NUREG-0588, CATEGORY II, PARAGRAPH 4(2),
ii       NO REPLACEMENT SCHEDULE HAD BEEN ESTABLISHED FOR BlW CABLJ
;        ASSEMBLIES SUSCEPTIBLE TO AGING EFFECTS THAT ARE LOCATED IN AN ELEVATED AMBIENT TEMPERATURE ENVIRONMENT.
i i
1 IV.A 5-6

LP8L POSITION o     LP&L MAINTAINS THAT THE E0F FOR BlW CABLE ASSEMBLIES WAS ADEQUATE TO JUSTIFY QUALIFICATION.
o    BASES FOR POSITION:
1 THE BlW CABLE ASSEMBLIES WERE QUALIFIED FOR 40 YEARS AT THE DESIGN TEMPERATURE OF 120*F.
LPal HAD AND HAS AN ON-G0ING CONTAINMENT TEMPERA-TURE MONITORING PROGRAM TO TREND TEMPERATURES.
NO REPLACEMENT SCHEDULE FOR CABLE ASSEMBLIES WAS NECESSARY UNTIL SUFFICIENT DATA WAS ESTABLISHED TO ACCURATELY PROJECT A CHANGE IN QUALIFIED LIFE.
(NOTE:    PLANT BEGAN FULL POWER OPERATION IN 1985).
ASSEMBLIES ARE WELL WITHIN (BY TENS OF YEARS) ANY IMAGINABLE QUALIFIED LIFE REPLACEMENT SCHEDULE.
REPLACEMENT SCHEDULES HAVE NOW BEEN MODIFIED FOR BIW ASSEMBLIES; ANALYSIS OF SUBSEQUENT TRENDING MAY REQUIRE FUTURE MODIFICATIONS OF REPLACEMENT SCHEDULE.
IV.A.5-7

LP8L'S POSITION REGARDING WHETHER ENFORCEMENT ACTION
_._ SHOULD BE TAKEN UNDER THE EQ ENFORCEMENT POLICY SNFORCEMENT ACTION SHOULD NOT BE TAKEN BECAUSE:
o    LPat SH0'JLD NOT HAVE CLEARLY KNOWN THAT THE EQ FILE WAS DEFICIENT IN THAT NEITHER VENDOR NOR NRC INFORMATION (PRIOR TO NOVEMBER 30, 1985) INDICATED THAT LP8L'S PROGRAM WAS INADE0 BATE. ADDITIONALLY, ALTHOUGH LPal
<                HAS HAD AN ONGOING, INSIDE CONTAINMENT, TEMPERATURE MONITORING AND TRENDING PROGRAM, AS OF NOVEMBER 30, i
1985 THE PLANT HAD BEEN OPERATING MUCH LESS THAN A YEAR AND SUBSTANTIAL TRENDING DATA WAS NOT AVAILABLE.
i ESCALATED ENFORCEMENT ACTION IS NOT WARRANTED BECAUSE:
o    N0 SAFETY SIGNIFICANCE
 \
.           o    INFORMATION PROVIDED TO STAFF REFLECTING EQUIPMENT WAS WELL WITHIN QUALIFIED LIFE.
J 4
i
!                                       IV,A.5-8 i

MITIGATION FACTORS o LPal WAS PROACTIVE IN THAT IT MAINTAINED AN ONG0ING PROGRAM TO MONITOR AND TREND CONTAINMENT AMBIENT TEMPER-ATURES, o LPal WAS RESPONSIVE TO THE STAFF'S CONCERNS IN THAT ADDITIONAL CONSERVATISMS WERE VOLUNTARILY INCLUDED IN AN UPDATED ANALYSIS EVEN THOUGH LPal HAD NO ACTUAL INDICATION THAT TEMPERATURES IN EXCESS OF PRIOR ASSUMP-TIONS WOULD ?.E REACHED.
o LPal'S MONITORING PROGRAM WAS BEYOND NUREG-0588 REQUIRE- l MENTS IN THAT ANALYSES IN PLACE AT THE TIME SUPPORTED    !
j                       GREATER THAN A 40-YEAR QUALIFIED LIFE.                   ,
:                                                                                i
;                     o THE EQUIPMENT WAS AND ?.0NTINVES TO BE QUALIFIED.
i
)
i                                                                                !
i 4
l 1                                                                                I 1                                                                               :
h
)                                             IV.A.5-9                           l I
f

                                                                                                                                        ; - t 4
I 1

==SUMMARY==

o                   STATUS:                                                        ,
i EQUIPMENT IS FU'LY QUALIFIED QUAllFIED LIFE HAS BEEN CONSERVATIVELY CHANGED FROM 40 TO 20 YEARS.
o                   LPaL POSITION:
EQUIPMENT WAS AND CONTINUES TO BE QUALIFIED AND N0 1
DEFICIENCY EXISTS.
                                                                            -        IN ANY EVENT, l
o'   NOT "CLEARLY SHOULD HAVE KNOWN" o    NOT SAFETY SIGNIFICANT' o    SIGNIFICANT MITIGATION WARRANTED i.
IV A.5-10 4
1

  "O OPEN ITEM 1 USE OF RTV SEA 1. ANT ON ROSEMOUNT TRANSMITTERS (50-312/8632-14)
ISSUE THE STAFF QUESTIONED THE QUALIFICATION OF RTV SEALS USED TEMPORARILY ON ROSEMOUNT TRANSMITTERS.
IV.B.1-1

p i
DISCUSSION OF ISSUE                                                                   ;
o   DURING EQ REVERIFICATION PROGRAM WALKDOWNS IN 1985,                                                                 !
LPal FOUND SOME ROSEMOUNTS WHICH DID NOT HAVE CABLE                                                                 !
ENTRANCE SEALS.
<                       o   LPal USED ROSEMOUNT SEALS ON SOME.                                                          BECAUSE OF DIFFICUL-
,                           TY IN PROCUREMENT OF SEALS, LPal DECIDED TO INSTALL A                                                               !
RTV SEAL UNTIL THE FIRST REFUELING OUTAGE WHEN THEY WOULD BE REPLACED.                                                                                                  '
1 o   THE RTV MATERIAL HAD BEEN QUALIFIED BY A BORG-WARNER
:                           TEST (PREVIOUSLY DISCUSSED) COMPLETED IN MID-1985.                                                          IN      !
I                           ADDITION, LPal HAD COMPLETED A QUALIFICATION ANALYSIS OF                                                            I THE RTV SEALANT IN A REPORT DATED FEBRUARY 21, 1985.                                                                !
i                                                                                                                                               !
o   IN 

==SUMMARY==
, LPal HAD REASONABLE ASSURANCE THAT THE RTV l
WOULD BE QUALIFIED FOR INTERIM USE.                                                                                 i i               i       o   WHILE THIS INFORMATION WAS CONTAINED IN LPal FILES,                                                                 :
i IT WAS NOT CONTAINED IN OR REFERENCED IN THE ROSEMOUNT                                                              i
)                           EQ FILE. (IT SHOULD BE NOTED THE REPLACEMENT SCHEDULE                                                               !
!                           WAS IN THE MODIFICATION PACKAGE N0. 1675.)
l j                       o   IDENTIFIED RTV EQ SEALS WERE REPLACED WITH QUALIFIED E0                                                             I
,                           SEALS DURING THE FIRST REFUELING OUTAGE AS SCHEDULED.
t 4
l IV.B.1-2

==SUMMARY==
o STATUS:
ALL EQUIPMENT CONTAINS OVALIFIED SEALS.
o LPal POSIT 10fi:
EQUIPMENT WAS Af1D CONTINUES TO BE QUALIFIED.
ROSEMOUNT EQ FILE DID NOT CONTAIN OR REFERENCE QUALIFICATION INFORMATION ON RTV SEALS.
THIS DEFICIENCY SHOULD NOT BE SUBJEC1 TO ESCALATED ACTION BECAUSE:
o     NOT SAFETY SIGNIFICANT o     OVALIFICATION INFORMATION IN OTHER LP8L FILES o     INFORMATION DISCUSSED WITH INSPECTORS AT TIME OF AUDIT.
IV.B.1-3

E i
OPEN ITEM NO. 2 OKONITE SKV CABLE AND SPLICES: JUSTIFICATION FOR CONCLUSION THAT CABLE SERVICE TEMPERATURES WILL REMAIN BELOW 90*C (50-382/8632-10)
ISSUE                                   ;
THE STAFF IS CONCERNED THAT:
o     EVEN THOUGH THE EE0D CONTAINS A STATEMENT REQUIRING VERIFICATION THAT INSTALLED CABLE SERVICE TEMPERATURE, INCLUDING INTERNAL HEAT RISE REMAIN BELOW 90*C, THERE IS NO INDICATION THAT THIS VERIFICATION HAS BEEN ACCOMP-LISHED.
o     THE REMOVAL OF THE AB0VE STATEMENT FROM THE EE0D HAS NOT BEEN JUSTIFIED.
I l
IV.B.2-1 f
_--.__._m _ _. ._,__ . _ . . -.-

LPal POSITION o LPaL MAINTAINS THAT THE VERIFICATION STATEMENT IS A DESIGN REQUIREMENT INAPPROPRIATELY PLACED IN THE E0MI, o THIS CABLE DESIGN REQUIREMENT WHICH WAS PART OF AN EBASCO ELECTRICAL DESIGN CRITERIA FOR POWER CABLE AMPACITIES AND NOW HAS BEEN ADOPTED BY THE LPal DESIGN GROUP.
o LPal'S QA PROGRAM ENSURES THAT THESE REQUIREMENTS ARE MET IN THE DESIGN PROCESS.
i IV.B.2-2
____-,s -

p.
i

==SUMMARY==

o    STATUS:
THE REFERENCED STATEMENT HAS BEEN DELETED. NO MODIFICATIONS TO EQUIPMENT WERE REQUIRED.
o    LP8L POSITION:
THE OPEN ITEM SHOULD BE CLOSED THE ITEM D]ES NOT REFLECT A VIOLATION OF 10 CFR 50.49 REQUIREMENTS.
l l
IV.B.2-3 l
1

GENERAL 

==SUMMARY==

BEST EFFORTS o     LP8L HAS MAINTAINED CLOSE C0 ORDINATION WITH THE NRC STAFF PRIOR TO AND SUBSEQUENT TO FULL POWER LICENSING REGARDING ITS EQ PROGRAM.
o    AFTER SIGNIFICANT REVIEW 0F LFaL'S EFFORT, AND A JANUARY 4-6, 1983 INSPECTION, THE NRC CONCLUDED THAT LP8L WAS IN COMPLIANCE WITH 10 C.F.R. 50.49.
o     1984-85 EQ VERIFICATION PROGRAM CONSISTING 0F A COMPLETE REVIEW 0F THE'WATERFORD PROGRAM AND ADDITIONAL WALKDOWNS 0F EQ EQUIPMENT.
o     INVOLVENENT IN INDUSTRY-WIDE EFFORTS REGARDING EQUIPMENT QUALIFICATION (NUCLEAR UTILITY GROUP ON EQUIPMENT QUALIFICATION).
PROPOSED ENFORCEMENT / UNRESOLVED ITEMS (PE/VI) o    FIVE PE/Uls WERE PROPOSED BY THE STAFF l                        o    LP8L DOES NOT BELIEVE THAT ENFORCEMENT IS APPROPRIATE FOR ANY PE/UI BECAUSE:
1 EQF WAS ADEQUATE TO SUPPORT QUALIFICATION.
                              -      IF ANY EVENT, FOR EACH PROPOSED VIOLATION:
o     LPal SHOULD NOT HAVE CLEARLY KNOWN THAT THE DEFICIENCY EXISTED, AND o     THE DEFICIENCY WAS NOT SAFETY SIGNIFICANT.
V-1

o.
f OPEN ITEMS o    TWO OPEN ITEMS WERE NOTED BY THE STAFF.
i-    o    LPal HAS PROVIDED SUFFICIENT INFORMATION TODAY THAT SHOULD CLOSE THE ITEMS.
o    LPal BELIEVES THAT WITH REGARD TO THE RTV SEALANT ISSUE,
: l.         HOWEVER, WHILE QUALIFICATION INFORMATION WAS IN LPal FILES, IT WAS NOT IN OR REFERENCED IN ROSEMOUNT EQ FILE.
THIS DEFICIENCY DOES NOT WARRANT ESCALATED ENFORCEMENT ACTION.
2
?
!     STATUS
)
I     o    ALL COMPONENTS WERE AND CONTINUE TO BE QUALIFIED.
)     o    LPal CONTINUES TO KEEP THE STAFF INFORMED OF ONG0ING E0
:          ACTIVITIES.
o    BASED ON DOCUMENTED STAFF CONCLUSIONS, LP&L HAS A GOOD EQ PROGRAM AND HAS MADE SIGNIFICANT EFFORTS TO ENSURE THAT 10 C.F.R. 50.49 REQUIREMENTS HAVE BEEN SATISFIED.
o    STAFF REVIEW HAS RESULTED IN STRENGTHENING 0F LPal PROGRAM.
V-2

      %~
         %4 a                                                                                                                                                                               !
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!   3 LOUIS!ANA POWER AND LIGHT COMPANY WATERFORD STEAM ELECTRIC STATION, UNIT 3                                                                 :
                                                                                                                                                                               / '
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DOCKET 50-382 SUl94ARY OF INFORMATION PRESENTED AT THE ENFORCEMENT CONFERENCE                                                                      l
,                                                                                                                                                                              j
 '                                                                        REGARDING EQUIPMENT QUALIFICATION                                                                      ,
b t
f October 4, 1988                                                                     i f
;                                                                                                                                                                              i 2
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>-                                    Meeting Agenda October 4, 1988 Louisiana Power & Light Company EQ Enforcement Conference for Waterford Steam Electric Station, Unt*, 3
: 1. Introductory Comments - NRC Staff
: 11. Introduction - Jerrold G. Cewease III. Background and Sumuary of Findings - John R. McGaha IV. Discussion of Potential Violation and Open items - James E. Howard A. Potential Violations
: 1. Borg-Warner Motor Operator (50-382/8632-01)
: 2. ITT Barton Transmitter (50-382/8632-02)
: 3. Okonite Splice on Charging Pung Motor (50-382/8632-03)
: 4. Thomas and Betts Connectors (50-382/8632-04)
: 5. 81W Cable Assemblies (50-382/8632-06 and 07)
: 8. Open items
: 1. RTV Sealant on Rosemount Transmitters (50-382/8632-14)
: 2. Okonite SKY Cable and Splices (50-382/8632-10)
V. Conclusion - John R. McGaha y

~.
LOUISIANA POWER & LIGHT COMPANY WATERFORD STEAM ELECTRIC STAYION, UNIT 3 DOCKET 50-382 EQUIPMENT QUALIFICATION October 4,1989 INTRODUCTION Louisiana Power & Light Company (LP&L) received a full power operating license for Waterford Steam Electric Station, Unit No. 3 (Waterford 3) from the NRC on March 16 1985. At that time LP&L had implemented a comprehensive program to address the environmental qualification of electrical equipment (EQ). Both LP&L and the NRC (Safety Evaluation Report (SER), Supplement 8) determined that there was reasonable assurance that the plant was in cogliance with the requirements of 10 CFR 50.49.
An NRC inspection team conducted an inspection at the plant on December 8-12, 1986, to review again LP&L's EQ Program, in Inspection Report No.
50-382/86-32, dated April 16, 1986, the NRC identified several potential violations and open items with respect to 10 CFR 50.49. By letter of September 7,1988, the NRC Staff requested that LP&L attend an enforcement conference to be held on October 4,1988, and address five potential violations which the Staff felt may require additional discussion prior to determining whether or what level of enforcement was appropriate. In addition, the Staff requested th]t LP&L be prepared to discuss two open items, in this presentation LP&L addresses these items.
In sumary, LP&L denies tht! five potential violations and, in the alternative, maintains that each does not warrant escalated enforcement action because (1) the conditions lacked safety significance, (2) LP&L should not have clearly known of the deficiencies and (3) the presence of mitigat. ion considerations. LP&L provides information to close the two open iten.s.
However, with regard to the open item involving RTV seals of Rosemount transmitters, LP&L adnits that documents fully supporting qualification were not in the Rosemount qualification files at the time of the inspection. LP&L, however, does not believe that this item warrants escalated enforcement action because the basis for qualification was contained in LPli. files and LP&L was well aware of that basis.
THE EQ PROGRAM LP&L, ds the licensee for Waterford 3 has implemerted an effective program for the environmental qualification of electrical equipment. LP&L has and continues to recognize the importance of the EQ Program to safe operation and its management is comitted to completely addressing any EQ deficiencies or unresolved items at Waterford 3. LP&L's EQ Program for Waterford 3 has been developed and implemented to assure that appropriate electrical equipment will remain functional in a harsh environment during and following a design basis event. As a result of the program, equipment should also remain qualified and be maintained in a qualified condition throughout the life of the plant.

LPR Nuclear Operations Procedure NOP-009. Equipment Qualification, establishes the Waterford 3 EQ Program. The program addresses, among other things, the scope of equipment requiring qualification, the actions to be taken in the event any equipment becomes unqualified, and the maintenance of the qualified condition of the equipment. Auditable records of the selection, qualification, and maintenance of the equipment are also maintained. Finally, the program includes the requirements for the control of purchases of qualified equipment, and the control of design changes to assure proper EQ consideration.
Overall responsibility for the EQ Program lies with the Senior Vice President of Nuclear Operations. Specific responsibility for overall coordi.
nation, development, and implementation of the program rests with the Manager of Nuclear Operations Engineering and Construction. These individuals are knowledgeable with respect to the program and are committed to its continued success.
The EQ Program at Waterford 3 has been developed in close coordination with the NRC Staff and has kept pace with the evolution of EQ knowledge within the industry. During its initial development efforts, LP&L conducted a comprehensive review of and obtained information on the equipment required to be qualified, and provided this information to the Staff. Af ter significant review of this information, interaction with LPR and an on-site inspection of January 4-6, 1983, the NRC Staff concluded th6t LPR was in compliance with 10 CFR 50.49, the criteria specified in NUREG-0588, and relevant parts of General Design Criteria and Appendix B of 10 CFR 50. (See Section 3.11.5 of SSER 8, December, 1988)
As industry and the NRC Staff became mre aware of EQ issues and concerns, in 1984-85 LPR decided to implement an EQ Reverification Program consisting of a complete review of its existing program and additional walkdowns of EQ equipment.       Based on the results of this additional significant effort, changes to the EQ Program and plant equipment were made to provide additional assurance of LPR's compliance with 10 CFR 50.49. As discussed further herein, as is LPR's policy, the Staff was kept fully informed of LPR's efforts.
In addition to these plant-specific efforts, LPR has closely monitored industry activities in EQ. For example, LPR is an active member of the Nuclear Utility Group on Equipment Qualification. This Group meets routinely with the NRC Staff to discuss EQ concerns and issues.
In sum, LPR has expended substantial resources and applied its best efforts to assure that its EQ Program was in compliance with 10 CFR 50.49 prior to its EQ deadline. In the NRC's April 16, 1987, inspection report, the subject of this enforcement conference, the Staff specifically found that LP&L has implemented a program to meet the requirements of 10 CFR 50.49. While the NRC Staff identified several potential violations in the inspection report, in tems of both the number of potential deficiencies and the low safety significance of those items (as discussed below) LP&L believes that the EQ Program at Waterford ? has been effective and compares favorable to EQ programs throughout the. industry. The items identi fied are isolated in nature and do not reflect any programatic weaknesses.
The following discussions of each enforcement item separately address the issues raised by the NRC in the April 16, 1987, Inspection Report.

e 3-Potential Enforcement / Unresolved items The following discussions provide Louisiana Power & Light's (LP&L) positions regarding five (5) issues categorized in NRC Inspection Report 50-382/86-32 as Potential Enforcement / Unresolved Items. In sum, LP&L does not believe that escalated enforcement action should be taken for any of the items because (1) the equipment was qualified or (2) Generic Letter 88-07 requirements were satisfied in that LP&L should not have clearly known that the deficiency existed, or (3) the deficiency is not safety significant.
Item No. 1 Borg-Warner, Model 39400 Valve Operators (50-382/8632-01)
A. Statement of The issue The Staff's inspection Report states, "Contrary to paragraph (f) of 10 CFR 50.49, the Equipment qualification file (EQr), electrical equipment qualification documentation package (EEQD) 42.3, for Borg Warner motor operator model 39400 installed in the containment building, did not adequately establish qualification because of failure to demonstrate similarity between the tested model 86090 and the installed model 39400.
Justification for~ Interim Operation (JIO) for Borg-Warner operators, datt.d May 16, 1985, required a station modification to upgrade these operators by November 39, 1985, (paragraph 4.f (a), item 50-382/8632-01)."
B. LP&L Position Regarding the Existence of a Violation LP&L denies the proposed violation.        LP&L maintains that the equipment was and continues to be fully qualified.        As support for its position, LP&L provides the following:
The issue revolves around the qualification testing of the Borg-Warner pneumatic-hydraulic actuator model PN 86090, which spanned from early 1983 through mid-1985, LP&L kept the Staff fully inforined of the status of, and actions regarding, the qualification testing, le. . letters to the Staff dated April 9,1984; May 16, 1985 and November 1,1985, as well as numerous phone calls and other inforinal contacts with the NRC staff. (A detailed history and discussion of the issue is provided in Attachment 1).
During qualification testing in May 1985, several anomalies were observed. Based on agreement with the Staff, on May 16, 1985 LP&L submitted a JC0 to the Staff to provide reasonable asseance of operability while the anomalies were being resolved. (The positions established in the JC0 were previously discussed with and accepted by the Staff in a May 7, 1985 conference call. The JC0 was also approved by the Staff in SSER 8. Section 3.11.3.4) Based on, among other things, the finding of operability documented in the Fay 16 JCO, LP&L determined that the condition was not reportable under 10 CFR 50.72 or 73. In the JCO, LP&L infomed the Staff of its intent to install the necessary replacement components by November 30, 1985 in order to complete qualification.

4 By letter of November 1,1985, LP&L notified the Staff that it had completed all modifications necessary to establish qualification and provided an analysis as to why some modifications previously noted were not required to establish qualification. Further, the letter stated that these few outstanding modifications would, none the less, be completed by the first refueling outage. (A discussion of these ceveral modifications is contained in Attachment 1.)
believed that its technical analysis establishing LP&L     reasonably (which referenced 10 CFR 50.49.f(2)) was adequate.
qualification The Staff did not take issue with LP&L's {{letter dated|date=November 1, 1985|text=November 1,1985 letter}}, and LP&L reasonably relied on the Staff's silence as tacit approval of its actions. In its inspection Report, the Staff did not discuss the qualification analysis contained in the {{letter dated|date=November 1, 1985|text=November 1,1985 letter}}.
In any event, the further modifications were con $l eted dering the first refueling outage (at the time of the inspection), as scheduled.
In suninary LP&L maintains that the equipment was fully qualified by November 30, 1985 and the Staff was fully informed of the details and basis for LP&L's position on November 1,1985. The Staff has not provided a basis for rejecting this position.
C. LP&L's Position Regarding Whether Enforcement Action Should Ee Taken Under the EO Enforcement Policy if, contrary to LP&L's position above, the Staff concludes that the finding constitutes a violation, LP&L maintains that for the reasons noted below, it does not warrant escalated enforcement action under
;          Generic letter 88-07.
: 1. The facts reflect that this finding does not constitute a violation 1
which LP&L clearly should have known of and, accordingly, pursuant to Generic Letter 88-07 enforcement action is not warranted. As support    for this (qualification       position,)LP&L test report          had vendor supplied informationwhich analyses documented in its {{letter dated|date=November 1, 1985|text=November 1,1985 letter}} to the Staff, provided reasonable assurance of qualification. Information establishing qualification (including the qualification test results) was provided to the Staff prior to Novetter 30, 1985.
Indeed, the Staff was well aware of LP&L's actions and position at that time. No other infonnation from the Staff or other licensees was known to LP&L, which would have led LP&L to a contrary conclusion,     in short, LP&L acted reasonably in its assessment of qualification.
: 2.      If the NRC determines that a violation exists, LP&L maintains that the safety significance does not warrant escalated enforcecent 1                   action pursuant to Generic Letter 88-07 in that:
a

5-
: a. The NRC Staff recognized that operation with the equipment in               ,
an unmodified condition would not present a safety risk by its acceptance of positions established in LP&L's JC0 for the equipment submitted to the Staff on May 16. 1985. Accordingly, operation of the equipment from November 30. 1985 until the first refueling outage had no adverse safety significance.
This is particularly the case because the modifications required for Qualification, which were referenced in the May                ;
: 16. 1985 JCO. were completed prior to November 30, 1985.
: b. LP&L provided the NRC detailed information on November 1,1985,              !
which reflected that the equipment was fully qualified and established a schedule for additinnel work. The Staff's tacit acceptance of that information and schedule clearly reflects the Staff's position, prior to tue inspection, that the condition was not "significant" as defined by Generic Letter                .
88-07.
O. If a Civil Penalty is Proposed, Mitigation Should Be Allowed By The Staff Because Of The Following, Factors                                                 ,
: 1. LP&L identified the underlying issue and kept the Staff fully informed of the status of and LP&L's position regarding the issue.
: 2. The condition was an isolated issue and was not safety significant.
: 3. The issue was promptly resolved on a schedule provided to the Staff prior to November 30, 1985.
: 4. LP&L clearly demonstrated best efforts to complete all EQ requirements before the hovert>er 30, 1985 deadline,
: 5. The condition was isolated to two components in one system.
E. Status of Equipsent All modifications were completed by the schedule provided to the Staff (during the first refueling outage) and the equipment continues                         ,
to be fully qualified.

Itan No. 2 ITT Barton Pressure Transmitter Submergence (50-382/8632 02) 4 A.           Statement Of The Issue
'                                                          The Staff's Inspection Report states. "Contrary to 10 CFR 50.49. the EQF.
EEQD 8.2A for ITT Barton pressure transmitters model 763 and 764 during the time of the NRC inspection, did not adequately establish qualification because of failure to demonstrate qualification for submergence based on OBA/ post DBA conditions." The Staff also states that since the safety-related functions of the transmitters during design basis accident (DBA) and post-0BA has been rescinded by substitute transmitters located above flood level, this issue should be considered for potential enforcement action.
B.           LPAL Position Regarding The Existence Of A Violation LP&L denies the proposed violation. LP&L reintains that the equipment was and continues to be fully qualified and that methods used to qualify the equipment were acceptable. The following discussion supports this position:
: 1.               As the basis for its position, the Staff states that NUREG-05B8 Category I requires that a type test be used to qualify equipment located in a submerged environment. LP&L believes that NUREG-0588 Category 1. paragraph 2.2(5) as well as 10 CFR 50.49(f}(1),
allow for a type test and analysis to qualify components.
NUREG-0588. Paragraph 2.2(5) states. ..."Where equipnent is located in water tight enclosures, qualification by test or analysis should be used to demonstrate the adequacy of such protection..." 10 CFR 50.49(e)(6) requires that submergence be addressed as applicable.
1 10 CFR 50.49(f)(1) permits testing of an identical item of j
equipment under similar conditions with supporting analysis to show that the equipeent is qualified.
in a Partial Initial Decision by the Atomic Safety and Licensing Board (ASLB). it was held that cable not subjected to a submergence test, but exposed to peak conditions of 113 psig.100% humidity and 3
390'F throughout a 100 day test and, analysis of those conditions, was "adequat,e to account for the submerged condition of the cable for a 30 day duration." (Public Service Company of New Hampshire, et al. 25 NRC 177.211 (1937). Consistent with this decision and the above requirements. LP&L maintains that information in the EQ file for Moo (1764 Barton Transmitters provided adequate documentation cad analysis to qualify the transmitters.
Barton Test Report No. R3-764-9 subjected the same model transmitters to 75 psig, the equivalent of 62.5 psig (submergeo
  !                                                                             under 30 feet of water). This condition more than envelopes Waterford 3 LOCA conditions. The testing of the same model
  '                                                                             transmitters and Barton's analysis of the conditions (correlating them to submergence equivalents) satisfied 10 CFR 50.49(f)(1) and NUREG-05BS requirements. This information was contained in the EQ file prior to the November 30. 1985 deadline. Significantly. Barton adheres fully to this position today.
1 I
1
: 2. LP&L also disagrees with the Staf f assertion that LP&L has rescinded the safety-related functions of the transmitters. LP&L correspon-dence dated February 2,1987 provided an analysis regarding the use of the subject transmitters and other qualified instrumentation that had overlapping readout ranges.      In sum this analysis showed the use of the subject transmitters until they reached the range of the Safety injection sump level instrumentation. At the point of submergence, the other safety-related, fully qualified transmitters (Safety injection sump level) would be used as primary indicators.
This analysis did not rescind the safety-related function of the transmitters,     it merely illustrated the range of readout for the transmitters that operators could utilize without comparing readings to redundant instrumentation.
C. LP&L's Position Regarding Whether Enforcement Action Should Be Taken Under The EQ Enforcement Policy if, contrary to LP&L's position above, the Staff concludes that the finding constitutes a violation, LP&L maintains that it does not warrant escalated enforcement action under Generic Letter 88-07 in that:
: 1. The facts reflect that this finding does not constitute a v.olation which LP&L clearly should have known of and, accordingly, enforcement action is not warranted. As support for this position,      l LP&L was not aware of any information that would have indicated that a deficiency existed in that (a) there was no vendor-supplied docurrentation that would have nullified LP&L's approach to qualification and (b) the NRC had not previously expressed any concerns to industry regarding the acceptability of LP&L's approach in qualifying the components.
LP&L interpreted NUREG-0588 consistent with the Staff's conclusion      .
provided in the Waterford SSER Supplement 5. Should the Staff decide subsequent to the November 30, 1985 deadline that LP&L did not satisfy qualification requirements, this should not be categorized as a "clearly should have known" issue.
: 2. If the NRC determines that a violation exists, LP&L maintains that the safety significance does not warrant escalated enforcement action pursuant to Generic Letter 88-07 in that:
: a. LP&L's "Analysis of Reactor Containment Building Sump Level Indication for Submergence," in letter number W3887-0218 dated January 29, 1987, was forwarded t?.; the Staff on February 2, 1987. Cnntrary to the Staff's Inspection Report conclusions, this analysis did not rescind the safety-related function of these transmitters. This analysis concludes that the function of the subject transmitters (SP-ILT-6705A and B) would have been completed prior to their sutxnergence. Subsequent to submergence, their safety-related function is no longer required in that other sump level transmitters with over-lapping ranges (SI-ILT-7145A and B) will provide the required information.
: b. LP&L still maintains that the containment sump level transmitters (Reg. Guide 1.97 equipment) are qualified for their required function period. As noted in LP&L's {{letter dated|date=February 2, 1987|text=February 2, 1987 letter}}, EQ file EEQO 8.2A was modified to close out this issue but should not be construed as a modification of LP&L's position regaruing qualification of the transmitters.
The potential failure of the containment sump level transmitters would not be safety significant in that sump level rise is not an indication that affects operator response during the mitigation of a design basis accident. Moreover, the transmitters are redundant to other instrumentation which provides indication at a higher level and overlap part of the range of the containment surp level transmitters,
: c. The Staff has previously issued Severity Level IV violations at
                                                       . Kewaunee (April 22,1987) and Sequoyah Qune 17,1987) for similar issues. Those violations confinn that LP&L's issue should not be considered significant enough to warrant escalated enforcement.
D.        If a Civil Penalty is Proposed Mitigation Should Be Allowed By The Staff Because of the Following Factors
: 1. The condition was isolated in content.
: 2. The condition was not safety significant.
: 3. LP&L clearly demonstrated best efforts to complete all E0 requirements before the November 30, 1985 deadline.
: 4. The condition was promptly addressed.
: 5. The condition was isolated to two components of one system.
E. Status of Equipment No modifications to equipment were necessary as a result of this issue.
Steps have been taken to revise appropriate procedures.
The equipment was and continues to be qualified.

e f
i
           ' Item No. 3                                                                                            '
Okonite Splices On General Electric Charging Pump Motors (50-382/8632-03)
A.                Statement Of The Issue The NRC Inspection Report states, "Contrary to paragraph (f) of 10 CFR 50.49, the EQF for General Electric CVC charging pump motors, did not adequately establish qualification because of failure to demonstrate similarity between the type tested nuclear qualified heater connection
>                                  splices and the installed Okonite bolted type taped splices at the Waterford 3 plant (paragraph 4.h.(2) c. Item 50 382/8632 03)."
The specific Staff concern as stated in the Inspection Report was that "the Okonite bolted type splices for heater connections en GE motor UNIO No. CVC EMTR-31AB-4C1, contained no supporting qualification documentation in the EQF, EEQD 6.2,16.2, or 4.14. The EQF for the above G.E. CVC charging pump motors do not adequately establish qualification because of failure to demonstrate similarity between the type tested
'                                  nuclear qualified motor connection splices and the Okonite bolted type taped splices installed at the Waterford 3 plant. Lack of qualification documentation in the file is considered a Potential
;                                  Enforcement /Unres'olved Item (50-382/8632-03)."
.                B.                LP&L's Position Regarding The Existence Of A Violation LP&L denies the stated violation. As support for its position, LP&L provides the following:
l                                   1. The heater and connecting splices on the A/B charging pump motor i
were removed from the EQ program and so qualification per 10 CFR 1                                        50.49 was not required. The specific splices identified in the I                                        Inspection Report for the heater connections on the A/B charging
'                                        pump motor were originally included in the EQ program in error. A follow-up review of the documentation and a functtonal evaluation of
(                                        the equipment resulted in this and similar items being removed from
'                                        the EQ program. The basis for removal of the equipment (i.e., the l
motor heaters and splices) was because they served no safety function during or following a design basis event.
+
!                                   2. With regard to bolted splices in the EQ program, LP&L stated at the
'                                        October 4,1988 Enforcement Ce sference that Okonite Test Report No.
NQRN-3, Revision 0 (June 23,1980) and Patel Engineering Test Report P El-Tk-840704-1 qualified bol'ed splices in the EQ program. When l
this issue was raised during ;he December 1986 inspection. LP&L inanediately contacted Okonit / to confire LP&L's interpretation of bolted splice qualificatier. In a letter to LPR dated December 11, 1986, Okonite stated that the test report qualified materials used l                                         fer various splices and termination assemblies estalled in accordance with Okonite instructions.
: 3. As further confinnation of its determination of qualification, during the Staff's review of LP&L's program, LP&L provided the Staff infonnation on Patel Engineering's Test Reports which documents testing on other configurations of Okonite splices for LOCA/MSLB conditions.

Recent infomation from Okonite now limits the application of their test report to in-line splices and back-to-back arrangements opened    <
to at least 45*, that are installed using a cement / tape sealing      ;
system and applied in accordance with Okonite instructions. Through an oversight on our part, we inadvertently did not reference at the Enforcement Conference, Patel Test Report PEl-TR-842900-01, or Wyle Test Report 17947-01, October 8, 1987, which are in t.P&L's files. Both reports qualify other Okonite configurations presently known to be installed at Waterford 3.
C. LP&L's Position Regarding Whether Enforcement Action Should Be Taken Under the EQ Enforcement Policy If, contrary to LP&L's position noted above, the Staff finds that the finding constitutes a deficiency, LP&L maintains that it does not warrant enforcement action pursuant to Generic Letter 88-07 in that:
: 1. The facts reflected that this is not an item that LP4L should clearly have known of and, accordingly, pursuant to Generic Letter 88-07 enforc'ement action is not warranted. As support for this position, LP&L had vendor supplied information supporting Okonite splice qualification as long as it was installed in accordance with Okonite installation instructions.      (In addition, the Patel Engineering Test Reports, noted above, confim qualification).
During the Staff's January 4-6, 1983 EQ audit of Waterford 3, Okonite splice qualifications were reviewed and no deficiencies were note d. LP&L is not aware of infomation published which called this conclusion into question prior to November 1985.
: 2. If the NRC Staff determinas that a violation exists, LP&L maintains that it is not "significant" such as to warrant escalated action pursuant to Generic letter 88-07 in that;
: a. During the time of the inspection LP&L provided the Staff additional infomation clearly affiming LP&L's conclusion of qualification, (i.e., the {{letter dated|date=December 11, 1986|text=December 11, 1986 letter}} from Okonite and Test Reports from Okonite and Patel Engineering).
Accordingly, pursuant to Generic Letter FB 07, escalated enforcement action is not warranted,
: b. Bolted splices properly taped are clearly qualified. Operation with bolted splices had no safety impact.
: c. The specific splices in question were removed from the EQ program in February 1987 based on an evaluation performed in September of 1986.

O
     'D. If A Civil Penalty !s Proposed. Mitigation
          $rould Be Allowed 8ecause Of The Following Factors
: 1. The condition was isolated and impacted only one system.
: 2. The condition was not safety significant.
: 3. The condition required no corrective action under the EQ program.
4    LP&L clearly demonstrated best efforts to complete all EQ requirements before November 30, 1985.
: 5. The motor heater and splices should not have been included in the program.
E. Status Of Equipment The heater and connecting splices at issue are not ir, the EQ program and therefere. no modification of the equipment is required.
LPAL is currently inspecting a sampling of splices as part of a reverification effort to ensure proper configuration requirements have been satisfied. Should questionable splices be discovered. LP&L will evaluate and report the findings as appropriate. As is our policy, we are keeping the Resident inspector inforrad of the status of our review.

                                                     !ssue No. 4 Thomas & Betts Blind Barrel Crimp Splices in Limitorque Motor Operators (50-382/8632-02)
A. Statement Of The issue The Staff's Inspection Report states, "Contrary to paragraph (f) and (k) of 10 CFR 50.49, and NUREG-588, Category 11, paragraph 5 the ECF for Limitorque motor operator model SMB 00, UNID No. EFW HVAAA-220 A, did not adequately establish qualification because of failure to demonstrate similarity between the tested and installed cable spl?ces. No evidence was contained in the EQF which could demonstrate qualification of Blind barrel crimp cplices used in operator EFW-HVAAA-220-A."
B. LP&L's Position Regarding The Existence Of A Violation LP&L denies the proposed violation. LP&L raintains that the connectors were and continue to be fully qualified and that methods used to qualify the equipment were acceptable. The following discussion supports this position:
Thomas & Betts (T&B) crimp splices were qualified based on Limitorque Test Reports B0058 and 600198, which were in the EQ file prior to November 30 E Accordingly, in that the splices were an integral part of the Limitorque operator during testing, LP&L does not believe it was necessary to include in the EQ file a statement regarding the qualification of each internal sub-component.
These operat;rs were built and tested for the voltage arrangement required for their application at Waterford 3. Thus, for plant installations, there was no reason to alter any of the splf ces or connectors of concern. If any changes to t'ese connectors were required j            our wrk control program would ensure that they were replaced by the same splice or another qualified configuration.
The Staff has questionei? ,imilarity cf installed and tested crimp        4 l
connectors. We have raintained that the installed configuration matched the as-test'.d component. Pecently, the NRC performed a comprehensive inspection of Limitorque ..nd reported its findings in IRC Inspection i
l Report No. 99900100/88-01, dated August 1,1988. The Staff's findings I
confinn that the connectors tested in motor operators of the type l            installed at Waterford 3 were Thomas & Betts, and therefore are i
quali fi ec.
J                                                                                      (
l            LP&L    thewgh its association with the NUGEO, is aware that mre recent l            testing Ms concluded that the qualified life of the connectors nuy be l            limited. In light of this information. LP&L will replace the connectors by the ec of the third refueling outage which will occur before the end   ,
l            of qualified life as reflected in recent testing.                         '
l l
i
{
t

l
{
i 13 1
C. LP&L's Position Retarding Whether Enforcement Action                                l Should Be Taken Uncer The EQ Enforcement Policy                                     j If contrary to LP&L's position above, the Staff concludes that the                  f finding constitutes a violation LP&L maintains that it does not warrrnt             ,
escalated enforcement action under Generic Letter 88-07 in that:                    ;
: 1. The facts reflect that this finding does not constitute a violation            !
which LP&L clearly should have known of, and accordingly,                      !
enforcement action is not warranted.                                           !
: a. LP&L had no requirement in 1985 to conduct a detailed review of        l all subcomponents in a piece of equipment to ensure that all           )
l                 were specifically referenced in a test report where QA of the           l vendor provided this arturance. The industry's level of                ;
J knowledge in 1985 regaiJing subcomponent qualification did not         [
]                   create a reason to doubt LP&L's conclusions at that time.
1 i             b. As previously discussed. Test Report B0058 which was included l                   in the EQ file prior to November 30. T9Futilfred crimp
]                   splices in the tested Limitorque opsrator. It was reasonable           ,
1                   to conclude from the reports that what Limitorque tested was           i the same or equivalent to what was installed.                          !
!                                                                                          f
: c. NRC concerns regsrding the model and manufacturer of the               i a
tested connectors have been satisf actorily resolved. (Itis            !
'l our understanding that an Information Notice will be issued in         !
i                   the near term regarding the issue.) The anticipated resolution         I 1                   of this issue adds support to LP&L's original conclusion               (
1                   regarding whether the installed connectors had in fact been            r type-tested,                                                           j l
: d. LP&L was not aware of industy; ver. dor, or NRC concerns in 1985       t regarding the potential inadequacy of T&B crimp connectors             !
contr.ined in Limitorque operators.
: 2. If the NRC determines that a violation exists, LP&L maintains that the safety significance does not warraat escalated enforcement               i action pirsuant to Generic Letter 88-07 in that:                             !
I
: a. The issue is not safety significant in that recent testing by          ;
Wyle Labs has re-qualified T&B erig splices for a limited              [
life. The test report parameters appear to envelop those at         ;
Waterford 3 for pressure, temperature, radiation, and                  <
h uidity. T5e tested splices performed their intended                 .
functions for a period equivalent to a qualified life of              i approximately 8 years. Since the T&B crig splices at                  !
t Waterford 3 have not been installed for longer than 8 years, the installed configurations are still qualified. However, as          ,
a conservative measure, LP&L will replace the TSB splices by the. end of the next refueling outage.
: b. The Staff has previously issued Severity Level IV violations for a similar issue at Palo Verde (March 17.1988). This violation confirms that LP&L's issue should not bn J 751dered significant enough to warrant escalated enforceme. *.                                         It should also be noted that this Notice of Violation pre %tes the Staff's recent vendor inspection.
D. If a Civil Penalty is Proposed, Mitigation Should Be Allowed By The Staff Because Of The Fe11owing Factors
: 1. As discussed above, LP&L actions demonstrate best efforts to complete all EQ requirements before the November 30, 1985 deadline.
: 2. The eventual replacement by the end of the next refueling outage of the T&B splices with an undisputed qualified configuration is proactive and reflects LP&L's prompt response to the issue.
: 3. The equipment was and continues to be qualifted.
4     The condition was an isolated issue and now impacts only three systems.
E. St6tus of Equipment The T&B connectors were and continue to be qualified and will be replaced by the end of the third refueling outage, currently scheduled for September, 1989.
1
[

      ~-
  ~.
Item No. 5 (a)
BIW Cable Assemblies DBA Temperatures (50-382/8632-06)
A. Statement of the Issue The NRC Inspection Report states "Contrary to paragraphs (f) and (k) of d
10 CFR 50.49, and NUREG-0588, Category II, paragraph 1.2.(5), the EQF, EE00 14.1/52.1, for BIW cr.ble assemblies (which includes CIR series connectors and flex conduit), did not adequstely establish qualification because it failed to base the temperature qualification for materials within the connector / cable assembly on the temperature effects of the MSLB as modified by a thennal lag analysis."
: 8. LP&L Fosition Regarding the Existence of a Violation LP&L denies the proposed violation.        LP&L maintains that the equipment was and continues to be fully qualified. As support for its position LP&L provides the following:
NUREG-0588, Categ'ory II, Paragraph 1.2.(5) provides acceptable techniques for demonstrating that LOCA qualification conditions exceed or are equivalent to utaximum calculated MSLB conditions. Paragraph 1.2.(5)(c) states that, "If the (olculated surface temperature exceeds the qualification temperature, the staff requires that (1) additional justification be provided to demonstrate that the equipment can maintain its required functional operability if its surface temperature reaches the calculated value, or (2) requalification testing be performed with appropriate margins, or (3) qualified physical protection be provided to assure that the surface temperature will not exceed the actual qualification temperature."
LP&L's combination of analysis and type testing demonstrated that the actual temperature profile was within qualification parameters.
Therefore, the analysis provided in the EQF prior to Novenber 30, 1985 was adequate to satisfy NUREG-0588 Category 11 requirements.
LP&L chose to provide (a) a thermal lag analysis to assess actual temperatures on the surface of the assemblies and (b) analyze any remaining anomalies by arrhenius methods. This methodology was accepted by the Staff in Waterford's SSER 5 (Ane i                     1983). It is not clear that the Staff reviewed both the thennal lag analysis and the arrherius calculations. LP&L concludes that information contained in the file as of November 30,1985 and at the time of the NRC inspection was adequate to support NUREG-0588, Category !! wa lification.

4
~.
   ~
LP&L's letter to the Staff dated February 2,1987, referenced National Technical Systems (NTS) lest Report No. 558-1654 in which the tested accident profile envelopes the Waterford 3 MSLB peak temperature. The NTS test report was not required to establish qualification, but was submitted as further decification of prior qualification conclusions.
C. LP&L's Position Regarding Whether Enforcement Action Should Be Taken Under the E0 Enforcement Policy If contrary to LP&L's position above, the Staff concludes that the finding constitutes a violation, LP&L maintains that it does not warrant escalated enforceu nt action under Generic Letter 88-O' in that:
: 1. The facts reflect that this finding does not constitute a violation which LP&L clearly should have known of and accordingly, enforcement action is not warranted. Specifically, the Waterford 3 SSER 5 at 3.11.3.2, "Qualification Methods," subsection 3.11.3.2.1, "Electrical Equipment in a Harsh Environment " states "...For tests already completed, NUREG-0588 permits analysis to supplement LOCA test data to demonstrate qualification for MSLBs. The Staff has-reviewed this analysis and finds the approach utilized acceptable."
: a. As previously stated, LP&L believes that the analyses and conclusions contained in the EQF as of November 30, 1985 adequately responded to NUREG-0588 requirements. This was a reasonable position based on the industry's level of knowledge in 1985,
: b. At the time the EQF was prepared LP&L was aware that certain anomalies had to be addressed and responded to this requirement based on itr, reasonabic interpretation of the requirement.
: 2. If the NRC determines that a violation exists, LP&L maintains that the safety significance does not warrant escalated enforcement action pursuant to Generic letter 88-07 in that:
: a. The core exit thennocouples aid in verifying that RCS and core heat removal requirements are being satisfied. They provide one of several indications used to evaluate the performance of systems designed to maintain adequate RCS and core heat removal. Other indications are provided by wide range steam
                      -generator level in conjunction with S/G feedwater flow, LOOP DELTA T and RCS subcoolad margin.
: b. The heated junction thermocouples are used to determine whether a void exists in the upper reactor vessel head area.
They also provide an additional parameter to monitor adequate RCS and core heat removal, and RCS inventory control. Voiding in the upper RV head area causes fluctuating pressurizer level indication and implies that pressurizer level is no longer a reliable indication of RCS inventory. Other indications of RV head area voiding are provided by pressurizer level in conjunction with pressurizer pressure and RCS subcooled margin.
D. If a Civil Penalty Is Proposed, Mitigation Should Ba Allowed Because of the Following Factors
: 1. The condition required no corrective action.
: 2. LP&L clearly demonstrated best efforts to complete all EQ requirements before November 30, 1985.
: 3. The conditidn was not safety significant as indicated by qualification documentation in the EQF and confirmed by additional test reports.
4     The issue was promptly resolved.
E. Status of Equipment LP&L maintains that the equipment was and continues to be qualified.

Issue NO. 5(b)
BIW Cable Assemblies Replacement Schedules (50-382/8632-07)
A. Statement of the Issue Th NRC Inspection Report states that, "Contrary to paragraphs (f) and (k)
E0r,ofEEQD 10 CFR     50.49,for 14.1/52.1,   and NUREG-0588, BlW              Categnry cable assemblies        (II, paragraph which includes        4(2), the CIR series connectors and flex conduit), did not adequately establish qualification because no replacement schedule had been established for components susceptible to aging effects that are located in an elevated service temperature environment."
B. LP&L's Position Regarding the Existence of a Violation LP&L denies the proposed violation. LP&L maintains that the equipment was and continues to be fully qualified. As support for its position, LP&L provides the following:
: 1. NUREG-0588, Category II, Paragraph 4(2) requires that
                  ... qualification programs should address aging only to the extent that equipment that is composed, in part, of materials susceptible to aging effects should be identified, and a schedule for periodically replacing the equipment ed/or materials should oe established. During individual case reviews, the staff will require that the effects of aging be accounted for on selected equipment if operating experience or testing indicate the equipment may exhibit deleterious aging mechanisms".
LP&L believes that aging concerns were adequately addressed in the EQF. The Staff concern appears to be focused on a statement in the EQF that the ambient temperature in the reactor vessel head area could reach 250*F. The nominal temperature referenced in the EQF was 120'F. LP&L has had an ongoing inside containment ambient temperature monitoring program. This p.ogram m 'itors and trends containment temperature on a continuous basis. As of November 30, 1985 LP&L did not have indications that its 120*F nominal temerature value was erroneous, in that the plant had not operated for a substantial period. Therefore, it was appropriate to perform its EQ analysis based on the 120*F value. Since the 120' nominal temperature qualified the components to greater than a 40 year life, no replacement schedule per Paragraph 4(2) was required.
Moreover, LP&L's approach (i.e., the use of technicai specification /FSAR ambient conditions assumptions) was consistent with the industry's approach to this type of issue. As systems are modified or the industry's level of knowledge grows, modifications in analysis philosophy occur. The Staff questioned LP&L's position regarding in-service conditions. LP&L again reviewed its nominal temperature values and concluded that additional conservatism could be added without nullifying qualification. Specifically, LP&L has raised the nominal temperature to a very conservative level which results in a decrease in qualified life, yet still substantiates current qualification. As previously stated, this qualified life reduction does not result in a conclusion that the assemblies were unqualified, nor does it undennine prior conclusions. Now that a less than 40-year life has been documented, a replacement schedule has been developed.

           ~C.
LP&L's Position Regarding Whether Enforcement Action Should Be Taken Under the EQ Enforcement Policy If, contrary to LP&L's position above, the Staff concludes that the finding constitutes a violation, LP&L maintains that it does not warrant escalated enforcement action under Generic t.etter 88-07 in that:
: 1. The facts reflect that this finding does not constitute a violation which LP&L clearly should have known of and, accordingly, enforcement action is not warranted. As previously stated, LP&L reasonably believed that the analyses, conclusions and ongoing monitoring programs provided reasonable assbrance that qualification parameters had not been exceeded.
Information from vendors, other licensees, or the NRC available as of November 30, 1985, did not ir.dicate that conditions exceeding calculated values were still a concern when they had been adequately addressed by analysis.
: 2. If the Staff determines that a violation exists P&L maintains that the safety significance does not warrant escala                 enforcement action pursuant to Generic Letter 88-07 la that;
: a. The BIW assemblies whether analyzcd under old or new nominal temperature values have not e,u eded their qualified life, are still cualified, and thus will perform their intended safety function.
D.              If a Civil Penalty is Proposed, Full Mitigation Should Be Allowed By The Staff Because of the Following Factors
: 1. LP&L was proactive in that it maintained and continues to maintain                    "
an ongoing program to monitor and trend containment ambient temperatures.
: 2. LP&L was responsive to the Staff's concerns in that additional conservatisms were voluntarily included in an updated analysis even though LP&L did not have sufficient prior indication that temperitures in excess of earlier assumptions would be reached.
: 3. LP&L's monitoring program exceeded NUREG-0588 requirements in that analyses in place at the time supported greater than a 40 year qualified life,
: 4. The equipment was and continues to be qualified.
: 5. The issue is limited in context and impacts only one system.
E.            S tatus of . Equipment LP&L believes that the equipment was and continues to be qualified.
Modificatiens to the EQ file were made to provide additional conservatism, resulting in qualified life of 20 years. Note that this is a change from our {{letter dated|date=February 2, 1987|text=February 2,1987 letter}} which came about from a re-analysis which considered material properties in addition to an increased temperature.
)                                 LP&L still maintains that the file was adequate as of Novenber 30, 1985 and at the tine of the NRC inspection.
l 1

II. OPEN ITEMS In accordance with NRC {{letter dated|date=September 7, 1988|text=letter dated September 7,1988}}, discussed below is LP&L's response to two Open Items noted in NRC Inspection Report 50-312/86-32.
Open Item 1 Use of RTV Sealant on Rosemount Transmitters (50-312/8632-14)
A. Statement of the issue The NRC Inspection Report noted that during the inspection, LP&L was replacing the RTV conduit seal on one Rosemount 1153 Series A Pressure Transmitter with a seal configuration identical to that used in the Rosemount Test. The Report stated that the replacement was being performed pursuant to Station Modification No.1675. The Inspection Report raised, as a concern, the fact that the replacement schedule was not noted in the EQF. Further, in discussions with the Staff prior to the enforcement conference, the Staff questioned whether the RTV used as a sealant was qua.lified.
: 8. Discussion During equipment walkdowns conducted prior to November 30, 1985, LP&L identified the need to provide environmental seals on certain Rosemount transmitters. The available stock of Rosemount seals were installed but there were not enough to complete all plant applications. There was also some difficulty experienced in the timely procurement of additional seals. To expedite resolution of the issue in the near term, LP&L elected to seal the conduit entrance with a qualified RTV in the interim and then to change out the RTV seal at the first refueling outage to confonn precisely with the Rosemount tested configuration.
The RTV selected was qualified to the LP&L profile during qualification testing of Borg-Warner Motor Operators completed prior to November 30, 1985. In addition, LP&L evaluated the use of RTV as a sealant in a Spare Parts Equivalency Evaluation Report (SPEER) dated February 21. 1985 and concluded that it was qualified. However, LP&L did not place or reference in the Rosemount EQ file these qualification analyses. These documents, ho.vever, were made known to the Staff during the December,1986 Inspection.
In response to Staff concerns, LP&L submits that:
: 1.      The replacement schedule was clearly set forth in the Modification on Package No 1675, a part of LP&L files, which was completed a:, scheduled.
: 2.      The RTV sealant used for the approximately 12 months from November,1985 until the first refueling outage was qualified.
: 3.      LP&L did not place or reference in the Rosemount qualification file the documents which qualified the RTV sealant, but the documentation did exist in other LP&L files.

                               ~C.                        Status of Equipment All the RTV seals on impacted Rosemount transmitters were replaced during the first refueling outage, as scheduled.
D.          Suma ry o     The Rosemount transmitters at issue were qualified and continue to be qualified, o     To the extent a documentation deficiency exists, it was not safety significant.
o     The information requested by the Staff has been provided and the item should be closed.
l
;                                                                                                                                                                                         L I
i

64 Open Item No. 2 Okonite SKV Cable and Splices Justification For Conclusion That Cable Service Temperature Will Remain Below 9_0'C (50-382/8632-10)
A. Statement of the Issue NRC inspection report 50-382/86-32 states in part, "...EEQD 6.2 contains a statement requiring verification that the installed cable service tenperature, including internal heat rise, remain below 90'C. There is no indication in the file that this verification has been accomplished...
During the inspection, LP&L indicated that this verification statement should have been removed from the EQF, EEQD 6.2. An analysis to justify negating the verification requirement is required in the EQF, and will be evaluated during a subsequent NRC inspection."
In addition, the Inspection Report also refers to LP&L's use of the cable tray system for thermal shielding of contained cables.
B. Discussion o     LP&L does not believe that the failure to justify in the EQF a deletion of an unsupported statement (as referenced by the Staff) negates qualification of the associated components.
Moreover, LP&L believes that the deletion was an administrative action that was apparently misunderstood by the NRC inspection team, o     Contrary to the inspection report, LPSL has not taken credit for the cable tray system as thertnal shielding for contained cables. The cable tray system provides support, physical protection and some beta dose shielding for contained cables.
o     In response to Staff concerns, LP&L submits that:
f
: 1. The Waterford 3 EQ Program incorporates an Environmental Qualification Maintenance Input (EQMI) doctanent which identifies to maintenance, maintenance-related actions that are required to maintain equipment qualification. Initial issuances of EQMIs contained action items for operations, engineering, and maintenance groups. As the program developed, itens that were not specifically maintenance department actions
                              . required for qualification were removed from the EQM!s.
The subject verification action was originally intended to be a reminder to engineering groups that future design changes should incorporate initial design parameters. Therefore, consistent with other non-maintenance related deletions, this type of a requirement should have also been deleted.

Engineering requirements for cable design (including consideration for maintaining continuous conductor temperature below 90'C) are cortained in Waterford 3 Electrical Design Criteria, Criterion #8 "Power Cable Ampacities". This criterion identifies ampacities of cables in conduits, duct banks and open top trays. Additionally, the 6npacities for cables in closed top trays are covered by calculations EE5-31-08, 11 and 12. These calculations verified on a cable by cable basis their individual acceptability. It should be noted that these calculations further reduce cable ampacity to compensate for the restricted heat loss caused by the addition of tray covers. The addition of cables to closed top trays would require the designer to revisit these calculations to ensure proper conservatism and thus preserve the 90*C temperature limit. The above criterion and calculations have been in place (essentially unchanged) since EBASCO (the AE) began its effort on Waterford 3. The EBASCO criteria is based on industry standards and was considered appropriate for use as LP&L's design criteria subsequent to plant operation.
An NRC approved LP&L QA program is in place to assure that, among other things, design criteria are followed during the design phas' of plant modifications. Therefore, the design criteria and the QA program ensures that design verification concerns are met. There is no requirew nt for maintenance personnel to perform any verification function regarding Okonite SKV cables and splices and therefore no need for the 4                       verification statement in the EQMI.
C. Status of Equipment As stated in the inspection report, the referenced statement has been deleted. No modifications to equipment are required.
D. Siminary o     The Okonite cables and splices are qualified.
o     Infortnation provided above should close this item.
s

ATTACHMENT 1 Borg-Warner Pneumatic-Hydraulic Actuator A. Safety Program The Borg-Warner pneumatic-hydraulic actuators provide operation of the isolation valves SI-MVAAA-405A and SI-MVAAA-405B (EBASCO Identification Nos.1SI-V1501B and ISI-V1503A) on the Shutdown Cooling System (SOCS) suction line. These valves are normally closed and are opened by the actuators to provide shutdown cooling or long term recirculation following a small line break. For long term recirculation, these valves must open 16-24 hours after a small line break and remain open.
B. System Operation The SDCS is used to reduce the temperature of the Reactor Coolant System (RCS) in post shutdown periods from normal operating temperature to refueling temperature or to cool down and depressurize the RCS following a small break Loss of Coolant Accident (LOCA). During shutdown cooling operation, a portion of the reactor coolant is diverted to the SDCS headers via the shutdown cooling nozzles (suction line) located in the RCS hot legs. The flow is then cooled by circulating through two shutdown cooling' heat exchangers via two low pressure safety injection pumps. The cooled flow returns to the RCS through four low pressure safety injection headers connected to the cold legs. Plant cooldown rate is controlled by two flow control valves which proportion the amount of shutdown cooling flow passing through the heat exchanger bypass line.
The SDCS is not designed to accept RCS operating pressure since it is a low pressure system. System operation is only perforned at reduced prassured conditions. Pressure isolation is provided by two motor operated isolation valves (one in each line) and two hydraulically operated isolation valves (i.e., SI-MVAAA-405B, one in each line) installed in series in the two shutdown cooling suction lines. To assure proper operation and hence, protect the low pressure portion of the SOCS from inadvertent pressurization, each of these valves is interlocked by    -
one of four independent pressurizer pressure measurement channels to prevent opening when RC5 pressure exceeds 377 psig. The pressure setpoint is selected such that the design pressure of the SDCS is not exceeded.
These valves are closed at operating pressure. Each pressure measurement channel provides a permissive signal to one of the four isolation valves to allow opening that valve when pressurizer pressure is below 377 psig.
If a valve is open and the RCS pressure rises above 700 psia, the valve is automatically closed by the interlock. The design of the interlock is such that loss of electric power to a permissive channel would leave the  j valve in its set position and would render inoperative both the open permissive and the automatic c. lose features. If the valve is open it can be manually closed, but if the valve is closed, it can only be opened using a keylock switch when the permissive signal is present.
i

m ATTACHMENT 1 (Page 2 of 5)
C. History of Borg-Warner Qualification The qualification testing of the Borg-Warner pneumatic-hydraulic actuator model PN 86090 was underway as early as 1983 with the testing initially to be completed by July 1983. However, the test was postponed due to a hydrolization problem experienced with the Fyrquel 220 hydre.ulic fluid.
The Fyrquel hydraulic fluid was changed to PA0 synthetic hydrocarbon hydraulic fluid which did not exhibit a hydrolization reaction during aging.
The testing of the actuator was rescheduled for completion in February 1984. After successfully completing thermal aging, several failures occurred which were attributed to the Buna-N material which was              -
apparently incompatable with the hydraulic fluid. The PA0 fluid was replaced with a silicon based fluid which was compatible with the seal materials. LP&L, by letter of April 9,1984, provided the NRJ the status of the qualification test program. The piston and cylinder 44s subsequently rebuilt and thermally and mechanically re-aged.
The qualification test program was completely re-run connencing in May 1985, and was scheduled for completion in August 1985. LP&L took a very proactive role in the qualification of the actuator. LP&L personnel supervised and witnessed all facets of the test, expediting in accordance with detailed procedures. During the perfomance of the qualification testing, several anomalies occurred which were subsequently addressed by LP&L and documented in a telecon with the NRC dated May 7,1985 and LP&L letters to the NRC dated May 16, 1985 and November 1, 1985.
LP&L on May 7,1985, contacted the staff (J. Wilson, P. Smith, and H.
Garg) to inform the staff that the Borg-Warner Actuator test specimen had experienced several anomalies during the LOCA/MSLB simulation. LP&L informed the NRC that the anomalies resulted because of test specimen configuration errors, simulations beyond Waterford 3 requirements, and improper test 3rocedures. LP&L also informed the NRC that the anomalies observed for tie test specimen were not applicable to the actuators installed at Waterford 3 and that in fact, the test data substantially supported the operability of the installed actuators. The NRC requested that LP&L take the following action:
: 1. LP&L conduct an evaluation pursuant to 10 CFR 50.73, specifically paragraph (V), to detemire the need to submit an LER.
: 2. LP&L. submit a JC0 within ten days which would provide the infomation conveyed in the telecon and, in particular, which would provide infomation to substantiate the operability of the intia11ed Borg-Wr.rner Actuators at Waterford 3.
: 3. LP&L infom the NRC resident inspector of the sub,iect matter.
LP&L, on May 16, 1985, completed a Potential Reportable Evaluation Report
'        (PRE) PRE 85-103, to determine reportability pursuant to 10 CFR 50.72 and 50.73. The PRE also concluded that the anomalies were attributable to the test program and were not applicable to the actuators installed at Waterford 3. The PRE also concluded that reporting pursuant to 10 CFR 50.73 was not required.

s ATTACMMENT 1 (Page 3 of 5)
LP&L, on May 16, 1985, provided a letter and Justification for Continued Operation (JCO) to the NRC which provided root cause infonnation about the test anomalies, identified inteaded design changes, and infonned them that LP&L expected to inform the NRC of the successful qualification of the actuatcrs by November 1, 1985.
LP&L, on November 1,1985, provided formal notification to the hRC of the successful completion of the qual'fication of the Borg-Warner actuator.
LP&L's letter also notified the NRC that the design changes, noted in the May 7, 1985, telecon and May 16, 1985, lettar, had been implemented for the installed actuators at Waterford 3 with the exception of the pump and motor co@iing set screw, the solenoid valve 0-rings, and the ".arge fil ter. The letter provided the technical analysis for not implementing                                              .
for the installed actuators, the foregoing design changes. The letter also made the statement that "This analysis meets the criteria of 10 CFR 50.49, paragraph (f)(2)".
Discussion of Design Changes Made During First Refuel Outage The Asign changes comphted during the first refueling outage via SM-1398 and discussed in the May 7, 1985, telecon with the staff and LP&L's letter W the staff of November 1,1985, were not required to be implemented in order to establish environmental qualification of the actuator pursuant to 10 CFR 50.49. The following information sunnarizes LD&L's position on this issue.
Fump and Motor Mechanical Coupling Two anomalier are discussed in LP&L's {{letter dated|date=May 16, 1985|text=May 16, 1985, letter}} to the staff.
The first anomaly was attributed to installation error. Loctite was not used on the set screw. The absence of Loctite allowed the set screw to back out. An uneven seating surface facilitated the separation of the pump and motor coupling. As noted in the May 16 letter, the pump and motor coupling was verified to be acceptable.
The second anomaly occurred during the LOCA testing.                          The purnp and motor mechanical coupling is designed to be a protective device. Prior to a pump or motor failure, the coupling separates. During the LOCA test,                                                   '
high levels of contaminants clogged the hydraulic filter. The decreased fluid flow caused an increase in the pressure on the purnp which forced the coupling to separate.
The successful qualification test demonstrated that the check valve installed in the hydraulic re*ervoir reduced the level of hydraulic fluid                                             t contamination. The reduced level of contamination allowed successful pump and motor operation. The check valve was part of the original equipment on the installed actuators.                  (It should also be noted that both anomalies address mechanical equipment considerations, not issues subject to 10 CFR 50.49 consideration.)
i i
i

ATTACHMENT 1 (Page 4 of 5) i 1
Secondary Seals (0-Rings) for the Solenoid Valve Assembly The initial analysis conducted on the solenoid valve assembly identified a chemical attack on the electrical lead wires to the solenoid coil as the cause of the problem. The result was a 125 VDC short across the lead wires. Subsequent testing on other identicalThesecoils revealed a findings, manuf acturing process-induced failure mechanism.
reported by {{letter dated|date=July 19, 1985|text=letter dated July 19, 1985}}, from Fleetwood Electronics, Inc.
to Borg-Warner, indicate the earlier test anomalies may have been attributable to a manuf acturing process defect. Moisture in this case chemical spray may not have been the primary cause of failure, rather it provided a path to ground, (i.e., a secondary failure mechanism).
In addition, the solenoid valve was tested without the protection of f.he conduit. TI.is allowed direct access to the solenoid coil with subsequent moisture accumulation.
As stated in the May 16 letter, the installed actuators were fitted with the proper conduit for environmental protection. In addition, a modification was completed via SM-1126 prior to November 30, 1985, to fully encapsulate the solenoid coil lead wires and conduit entrance with RTV 106 to prevent moisture accumulation.
The secondary sealing was designed to backup the original netal-to-metal seals provided by Borg-Warner. Af ter extensive review, and the knowledge gained from the Fleetwood Electronics coil failure analysis on an identical coil, it was determined that adequate sealing was provided by the conduit and RTV modification.
The use of secondary seals (0-rings) noted in SM-1398, therefore, was an enhancement and not a condition of similarity or qualification.
Hydraulic Filter The May 16 letter discusses a provision to install larger filters in the solenoid actuated pilot valve. This modification was not implemented on the installed actuato s, The failure of the test specimen was due to severe contamination of the hydraulic fluid as a result of LOCA testing which could not occur in the installed. configuration due to the ce of a check valve on the hydraulic reservoir. The small filters subsequently passed the LOCA qualification testing.
A larger in-line filter failed during the subsequent qualification orogram baseline functional test due to thosphate restdue contamination of the hydraulic fluid. Phosphate was used to clean the refurbished actuator af ter the earlier qualification program. Failure    was a result This filter was, of assembly techniques, not equipment perfnnnance.
however, replaced with a larger, externally mounted cartridge filter.

      ~
                                                                                -s 1
ATTACHMENT 1                             .
(Page 5 of 5)
As previously stated, subsequent testing demonstrated that the small filter could successfully complete a qualification program if contamination is limited. The check valve added to the hydraulic reservoir limited ingress of chemical spray and debris to the hydraulic fluid.
The use of the larger, externally mounted, cartridge filter noted in SM-1398 was an enhancement and not a condition of similarity or qualification. The larger filter improved filter accessibility for maintenance and extended filter life due to a larger surface aru.

 ,     ,                                                                               3ECEIVED
      ,p" " %,                                   UNITE) STATES                     ON SITE LICENSING J'              4               NUCLEAR REGULATORY COMMISSION E             :
REGloN IV                           APR 211987 til RYAN PLAZA DRIVE. EUITE 1000 ARUNOTON, TEXAS 19011 In Reply Refer To:                           APR 16196T Docket:      50-382/86-32 License:      HPF-38 Louisiana Power & Light Company ATTN:     J. G. Dewease, Senior Vice President Nuclear Operations N-80 317 Baronne Street New Orleans, Louisiana       70160

==Dear Mr. Dewease:==

==SUBJECT:==
EQUIPMENT QUALIFICATION INSPECTION - WATERFORD STEAM ELECTRIC STATION, UNIT 3
                                                                                                ~
This refers tn'the first round special 'eam      t   inspection to review compliance
~-
with 10 CFR 50.49, of activities authorized by License No. NPF-38, conducted by Mr. A. R. Johnson and other NRC representatives, onsite during the period of December 8-12, 1986, and subsequently at the NRC Region IV office until March 13, 1987, concerning the Waterford Steam Electric Station, Unit 3. The team's findings were discussed with members of your staff at the conclusion of the onsite inspection on December 12, 1986.
Areas examined during the inspection included your implementation of a program for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. In preparation for this inspection, the NRC team included reviews and evaluations of your implementation of EQ corrective action comitments identified in Safety Evaluation Reports (SERs) NUREG 0787, Supplements 5, 8, and 10 (June 1983. December 1984, and March 1985), which were satisfactorily accepted by the NRC staff at that time with regards to equipment for which justification for interim operation (JI0s) were provided prior to the November 30, 1985, deadline.
Within these areas, the inspection consisted of the examination of selected procedures and records, interviews with personnel, and observations by the NRC inspectors. The inspection findings are documented in the enclosed inspection report.
The inspection determined that you have implementeo J program to meet the requirements of 10 CFR 50.49. Seven deficiencies with respect to your program implementation, involving EQ documentation files and physically installed configurations of equipment in your plant, are sumarized in Appendix A and are classified as Potential Enforcement / Unresolved Items requiring further action.
O s Y - 0 Y A A W N $~( Y

( __ _ . _ _____- _______ _--_ _______
1 4
Louisiana Power & Light Company                                      All seven Potential Enforcement / Unresolved Items represent failures to fully establish the qualifications of tht following equipment: Borg-Warner motor operators, ITT Barton 763/764 pressure trensmitters Okonite bolted cable splices to General Electric pump motors, Thomas and Betts blind barrel crimp cable splices to Limitorque SMB series :notor operators, unidentified internal wiring in Limitorque SMB series motor oprators, and BIW cable assemblies.
Sixteen concerns are classified as Open items and a future NRC inspection will review your actions concerning them.
Your letter to NRC, Region IV of February 2,1987, providing additional information subsequent to the onsite inspection, addressing the inspection findings presented in the exit interview on December 12, 1986, has been reviewed and was considered in preparation and issuance of the enclosed inspection report.
Your corrective actions regarding the identifiec deficiencies in the enclosed inspection report should not be delayed pending a future NRC Region IV inspection.
We are available to discuss any questions you have concerning this inspection. -
Sinefrely.
Y dl k,
j , > E .1 agliardo, Chief act r Projects Branch

==Enclosures:==
: 1. Appendix A - Potential Enforcement / Unresolved Items
: 2. Appendix B - NRC Inspection Report 50-382/86-32 cc w/ enclosures:
Louisiana Power & Light Company ATTN:     G. E. Wuller, Nuclear Services Licensing P. O. Box B Killona, Louisiana                  70066 Louisiana Power & Light Company ATTN:    N. S. Carns, Plant Manager - Nuclear P. O. Box B Killona, Louisiana                  70066 Middle South Services ATTN:    Mr. R. T. Lally P. O. Box 61000 New Orleans, Louisiana                  70161

I Louisiana Power & Light Company                                                        -  3-Louisiana Power & Light Company ATTN:             K. W. Cook, Nuclear Support and Licensing Manager 317.Baronne Street-                                                                                                                              .
P. O. Box 60340 New Orleans, Louisiana                                                  70160 Louisiana Radiation Control Program Director e
6             % mee 6
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                                                                                                                           ,,g. _ ----,m.- -., _ , - -- --.- a -.-

t APPENDIX A Potential Enforcement / Unresolved Items As a result of the special equipment qualification (EQ) inspection of December 8-12, 1986, the following items have been identified by Region IV as Potential Enforcement / Unresolved Items (paragraph references are to the detailed portions of the' inspection report).
: 1. Contrary to paragraph (f) of 10 CFR 50.49, the equipment qualification file (EQF), electrical equipment qualification documentation package (EEQD) 42.3, for Borg-Warner motor operator model 39400 installed in the containment building, did not adequately establish qualifications because of failure to demonstrate similarity between the tested model 86MO and the installed model 39400. Justification for Interim Operation N10) for Borg-Warner operators, dated May 16, 1985, required a station icdification to upgrade these operators by November 30, 1985, (paragraph 4.f.(1), Item 50-382/8632-01).
: 2. Contrary to paragraph (f) of 10 CFR 50.49, the EQF, EEQD 8.2A for ITT Barton model 763 and 764 pressure transmitters during the time of the NRC inspection, did not adequately establish qualification because of failure --
               .to demonstrate' qualification for submergence based on DBA/ post DBA
     .          conditions.     (paragraph 4.f.(3), Item 50-382/8632-02).
: 3. Contrary to paragraph (f) of 10 CFR 50.49, the EQF for General Electric CVC charging pump motors, did not adequately establish qualification because of failure to demonstrate similarity between the type tested nuclear qualified heater connection splices and the installed Okonite bolted type taped splices at the Waterford plant (paragraph 4.h.(2)c, Item 50-382/8632-03).
: 4.      Contrary to paragraph (f) and (k) of 10 CFR 50.49, and NUREG 0588, Category II, paragraph 5, the EQF for Limitorque motor operator, model SMB-00, UNID No. EFW-HVAAA-220-A, did not adequately establish qualification because of failure to demonstrate similarity between the tested and installed cable splices. No evidence was contained in the EQF which could demonstrate qualification of blind barrel crimp splices used in operator EWF-HVAAA-220-A (paragraph 4.f.(4), Item 50-382/8632-04).
: 5. Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and NUREG 0588,         -
Category II, paragraph 5, the EQF, EE0D 3.1, for model SMB series Limitorque motor operators did not adequately establish qualification of t
internal wiring installed in operators prior to September 1986, in that wiring was unidentified and there were no test reports to show that .he wiring was qualified in accordance with 10 CFR 50.49 (paragraph 4.f.(6),
l                 Item 50-382/8632-05).
l l
l l

2
: 6. Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and NUREG-0588, Category II, paragraph 1.2.(5), the EQF, EEQD 14.1/52.1, for BIW cable assemblies (which includes CIR series connectors and flex conduit), did not adequately establish qualification because it failed to base the temperature qualification for materials within the connector / cable assembly on the temperature effects of a MSLB as mc.dified by a thermal lag analysis (paragraph 4.f.(7)(a) Item 50-382/8632 96).
: 7. Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and NUREG-0588, Category II, paragraph 4(2), the EQF, EEQD 14.1/52.1, for BIW cable assemblies (which includes CIR series connectors and flex conduit), did not adequately establish qualification because no replacement schedule had been established for components susceptible to aging effects that Are located in an elevated service temperature environment (paragraph 4.f.(7)(b), Item 50-382/8632-07).
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                                                                                     **             W ege 8
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)

t   '
APPENDIX B U.S. NUCLEAR REGULATORY COM ISSION REGION IV NRC Inspection Report: 50-382/86-32                             License:  NPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)
N-80 317 Baronne Street New Orleans, Louisiana        70160 Facility Name: Waterford Steam Electric Station, Unit 3                            '
Inspection At:     Killona, Louisiana Inspection Conducted: December 8-12, 1986 (onsite)
             -                       to March 13,1987(NRCRegionIVoffice)
Inspectors:              $ * ^ lW2mY
                       @ D. E. Norman, Reactor Inspector. Team Leader
                                                                                '///3/f7 Ikte '
E     Engineering Section, Reactor Safety dranch YWm ArifaY                                       Yb WP1 Date '
p . E. Bess, SectionReactdr ReactorInspdctor, Safety BranchEngineering W ad m in)
A.\ . John n. Reacter Inspector (Nuclear s As/sv Date     /
Eng         . Engineering Section, Reactor Safety Branch Also participating in the inspection and contributing to the report were:
R. Heishman, Chief, Vendor Program Branch, DOAVT, IE R. Moist, Equipment Qualification & Test Engineer. VPB, DQAVT, IE J. Grossman, Member of Technical Staff, Sandia Normal Laboratories (SNL)
J. Fehringer, Consultant Engineer Idaho National Laboratory (INEL)
J. Stoffel, Censultant Engineer, !HEL
   -MC@fL66k 32 y,

2 Approved:                 Ibd R. E. Ireland, Chief. Engineer 1ng Section 9I7/P/
D(te /
Reactor Safety Branch Inspection Sunsnary Inspection Conducted December 8-12, 1986 (o site) to March 13, 1987 (NRC Region IV office), Report 50-382/85-32 Areas Inspected:-
Special, announced ins >ection to review the licensee's implementation of a program for establis1ing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. In preparation for this inspection, the NRC team included a review of LP&L's implementation of equipment qualification (EQ) corrective action comitments, identified in Safety Evaluation Report NUREG 0787, (SER) Supplements 5, 8, and 10 (June 1983, December 1984, and March 1985), which were satisfactorily accepted by the NRC staff at that time with regards to equipment for which justification for interim operation (JI0s) were provided prior to the November 30, 1985, deadline.
                                               ~     ~
                     ~
Results:''The Inspection determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49 except for certain deficiencies listed below in Tables I and II.
The licensee's letter of February 2,1987, (L. L. Bass of LP&L to A. R. Johnson of NP.C, Region IV), provided additional information subsequent to the onsite inspection and addressed the inspection findings presented in the exit interview by the NRC on December 12, 1986. The licensee's information and proposed methods of resolution to the inspection findings have been reviewed and were considered in preparation and issuance of this report.

3 Table I Potential Enforcement /Unresc1ved Items-t Report         Item Name                                       Paragraph       Number
: 1. Borg-Warnce Motor Operators, Model 39400;   4.f(1)    50-382/8632-01 station modification upgrade requirements
: 2. ITT Barton Pressuro Transmitters,           4.f(3)    50-382/8632-02 Model 763 and 764; submergence requirkaents
        ^
: 3. General Electric CVC Charging               4.h(2)(c) 50-382/8632-03 Pump Motors, Okonite Bolted Type Taped Heater Splices; lacking qualification documentation                                          p 4    Limitorque SMB-00 Motor Operators,          4.f(4)    50-382/8632-04 Thomas.and.Betts Blind Barrel. Crimp _                             -
Cable Splices; lacking qualification documentation
: 5. Limitorque Motor Operators; internal        4.f(6)    50-382/8632-05 '
wiring qualification
: 6. BIW Cable Assembly (includes CIR series     4.f(7)(a) 50-382/8632-06 Connectors and Flex Conduit); OBA temperature qualification requirement
: 7. BIW Cable Assembly (includes CIR series     4.f(7)(b) 50-382/8632-07 Connectors and Flex Conduit);
replacement schedule due to process temperature aging effects requirement t
l
[
I

  ?
4 s
Table II Open Items:
Report                 Item Name                                         Paragraph              Number
: 1. Conax Electrical Penetration,                 4.f(8)(a)   50-382/8632-08 Model 7320-10,000 Series;                     4.f(8)(b)
: a. documentation deficiency, MSLB             4.f(8)(c)                                         !
temperature excursion
: b. documentation deficiency, functional performance calculations
        .      c. documentation deficiency, analysis of Kulka terminal blocks (IN 84-47)
: 2. Conax Electrical Penetration,                 4.h(4)(b)   50-382/8632-09 Model 7320-10,000 Series; engineering study of polysulfone seals on damaged modules
: 3. - OkonitW 5' k'V Cable and Splices;              4.f(9)(a)   50-382/8632-i0 thermal lag analysis and documentation        4.f(9)(b) deficiency
: 4. Rosemount RTOs, Model 104-1619-6;             4.f(10)     50-382/8632-11 submergence qualification requirement
: 5. BIW Coaxial Cable; functional                 4.f(11)      50-382/8632-12 performance calculation for operating voltage and current levels                                                                      ;
: 6. Okonite 600 VAC Cable; qualification          4.f(12)(a)   50-382/8632-13 of cable jacket and documentation             4.f(12)(b) deficiencies                                  4.f(12)(c)
: 7. Rosemount Pressure Transmitters,             4.h(5)        50-382/8632-14 Model 1153 Series A; RTV plug seal replacements
: 8. ITT Barton, Model 763/764 Pressure           4.h(6)        50-382/8632-15 Transmitter; anduit seal requirements
: 9. Seimens-Allis HP;i Motors, Model 113;        4.h(7)(a)      50-382/8632-16                     I
: a. oil reservoir fill holes and            4.h(7)(b) ventilation covers
: b. rear ventilation screens
: 10. Allis Chalmers Motors, Model 500P56;           4.h(8)(a)       50-382/8632-17
: a. motor bearing oil leakage                 4.h(8)(b)
: b. air intake filter L
                                                          -   -    w-  r . - , , .,-     - , - - - - , . _ . -

c 5
: 11. General Atomic Radiation Detector,      4.f(14)   50-382/8632-18 Model RD-23; Rockbestos test report and                               '
performance data for BIW coaxial cable
: 12. Okonite V-Type Taped Cable Splices 4.h(1)    50-382/8632-19 used in:                                4.h(2)(b)
: a. Limitorque motor operators
: b. General Electric motors
: 13. Limitorque SMB-2 Motor Operator;        4.h(3)    50-382/8632-20 improper installation / inadequate maintenance of Okonite V-type taped cable splices
: 14. Limitorque SMB Motor Operators;         4.f(5)    50-382/8632-21
: a. switch compartment component aging requirements
: b. separate temperature qualification on degradable items
: 15. Seimens-Alljs HPSI Pump Motorj       . 4.f(2)    50-382/8632-22
                        - qualification analyses and test reports
.                   16. Conax Electrical Penetrations           4.h(4)(a) 50-382/8632-23 Model 7320-10,000 Series; terminal block qualification 4
l I
: g.                                                        . . _
:         +
6 DETAILS
: 1. Persons Contacted LP&L R. Barkhurst, Vice President - Nuclear T. F. Gerrets, Quality Assurance Manager J. G. Carns, Plant Manager - Nuclear A. S. Lockhart, NOSA Manager R. A. Crawley, Training K. W. Cook, Nuclear Support and Licensing G. E. Wuller, Nuclear Services Licensing L. L. Bass, Technical Support Engineering W. J. Hayes, Technical Support Engineering R. F. Burski, Nuclear Operations Engineering Manager J. R. McGaha, APM - Operations and Maintenance
             - R. J. Murillo, Nuclear Licensing Manager R. P. Thibodeaux, Technical Support Engineering                            .
K. L. LeBlanc, Maintenance Erigineer'
     - -       T. H. Smith, Maintenance Superintendent P. N. Backes, Operations - Quality Assuranti i              M. V. Hamilton, Technical Support Engineering B. R. Messitt, Engineering R. V. Seidi, I&C Engineering Supervisor Ebasco J. N. VanName, Consulting Engineer I. V. Sydoriak, Mechanical Engineer NRC
,              J. G. Luehman, Senior Resident Inspector
: 2. Purpose The purpose of this inspection was to review the licensee's implementation of the requirements of 10 CFR 50.49,
: 3. Background NUREG-0588 was issued in December 1979 to promote an orderly and systematic implementation of equipment qualification programs by industry and to provide guidance to the NRC staff for its use in ongoing licensing reviews. The positions contained in NUREG-0588 provided guidance on (1) how to establish environmental service conditions, (2) how to select methods that are considered appropriate for qualifying equipment in areas

~
7 I
of nuclear plants, and (3) other areas such as margin, aging, and documentation.
A final rule on environmental qualification of ele:tric equipment important to safety for nuclear power plants became effective on            t February 22, 1983. The rule 10 CFR 50.49, specifies the requirements to i                                               be met for demonstrating the environmental qualification of electrical
* l                                              equipment located in a harsh environment. In accordance with 10 CFR 50.49, paragraph (k), the same electrical equipment at Waterford 3 may be qualified in accordance with the acceptance criteria specified in Category II of NUREG-0588.
To document the degree to which the LP&L environmental qualification
                                          . progrse complies with the NRC environmental qualification requirements and criteria LP&L provided equipment qualification information by letters dated November 15, 1982; November 30, 1982; January 27, 1983; February 2, 1983; February 11, 1983; February 24, 1983; and March 2, 1983, to supplement the information in Section 3.11 of the FSAR.
Supplement 5 to the SER NUREG-0787, (SSER-5) dated June 1983, documented what the NRC staff had reviewed and. evaluated regarding the Waterford 3  -
                                              ' program for the environmental qualification of electrical equipment important to safety. This review included (1) the systems selected for qualification, (2) the environmental conditions resulting from design basis accidents, and (3) the methods used for qualification. In addition.
LP&L added to their EQ program information demonstrating qualification of all electrical equipment located in a harsh environment, including (1) nensafety-related equipment whose failure under postulated accident conditions could effect safety-related equipment; and (2) equipment required by the TMI action plan for post accident monitoring purposes, in accordance with RG 1.97. Justifications for interim operation in accordance with 10 CFR 50.49 would be provided if this equipment did not adquately demonstrate qualification. This qualification information and justifications were submitted to the NRC staff for review and approval before the granting of an operating license at Waterford 3.
In addition, a license condition was required to be met by LP&L, where all installed electrical equipment important to safety, located in a harsh environment, was required to be qualified before startup from the first refueling outage. This date was later modified to the November 30, 1985, deadlire. Once qualification was completed, documentatien was required to be incorporated into an auditable file. On the basis of these considerations, the NRC staff concluded that satisfactory coe.pletion of the corrective actions, identified in the Appendices of SSER-5 would ensure conformance with the requirements of 10 CFR 50.49.
By {{letter dated|date=August 3, 1983|text=letter dated August 3, 1983}}, and March 13, 1984, LP&L had submitted the complete list of TMI action plan equipment that required qualification and the qualification status of the equipment. All the equipment located in a harsh environment was included in the qualification program. For any equipment that was not qualified, a JIO was provided. The NRC staff

8 evaluation of these JIds was discussed and the NRC staff found LP&L's responses acceptable.
By {{letter dated|date=November 7, 1983|text=letter dated November 7, 1983}}, LP&L responded with the statement that no nonsafety-related electrical equipment located in a harsh environment whose failure under postulated accident conditions could prevent satisfactory accomplishment of a safety function by safety-related equipment.                              The NRC staff concluded that the applicant's response to this raquirement was acceptable.                                                                                                         ;
LP&L was required to evaluate all NRC I&E information notices (IENs)                                                               !
applicable to equipment environmental qualification and either determined that the I?Ns do not apply to equipment at Waterford 3 or take corrective action to ensure the equipment is qualified.                                                                                       l SSER-8, December 1984, described the NRC staff evaluation of LP&L's responses to outstanding EQ items and described the NRC staff position at that time for concluding that conformance with 10 CFR 50.49 had been                                                               .
demonstrated.
l
;                                                                      LP&L, in response to NRC Generic Letter 84-24, submitted their
;                                                                      certificati'on (W3P85-0193) of the LP&L environmental qualification program 1
to the NRC staff on January 28, 1985, as follows:
1                                                                      a.                   LP&L had in place and was implementing at that time an environmental qualification program that satisfied the requirements of 10 CFR Section 50.49 as documented in the Operating License, NUREG 0787, and                                         .
SSER-8.
: b.                   The Waterford Unit 3 Station had at least one path to safe shutdown using fully qualified equipment or equipment for which there was a JIO accepted by the NRC staff pending full qualification of any equipment not fully qualified.                                                                               '
;                                                                       c.                   All other Waterford Unit 3 Station equipment within the scope of i                                                                                            10 CFR Section 50.49 was either fully qualified or a JIO had been accepted by the NRC pending full qualification.
In addition, SSER-8 to the Waterford SER required that an aging analyses for all nonmetallic components in safety-related mechanical equipment                                                            !
j located in a harsh environment should be completed before exceeding                                                              !
i                                                                      5 percent power. The Waterford 3 low power operating license contained a license condition to ensure that this requirement be fulfilled.                                       By letter                  l from LP&L to the NRC staff dated February 15, 1985, LP&L informed the                                                            ;
staff that the required analyses have been performed, and that on the                                                            l 1                                                                        basis of these analyses, all safety-related mechanical equipment is qualified for its intended service life and environmente.1 conditions.                                                  The      I results of the analyses are contained in the equipment qualification I
1                                                                         files.                           These analyses were performed in accordance with the methodology previously accepted by the NRC staff (SER Supplements 5 and 0). On the
* I s
                                  ,   , _ _ _ , - _ _ - _ _ - , - - . . - . _ - . - _ - . , , - , _ . _ . .                     ,   , _ . -  _ . . ---_-.- ,,.,-. - .., .,w__. __._,._-____,_.,r.

9 basis of infonnation provided in LP&L letter, February 15, 1985, the NRC staff found that LP&L had met the requirements of this license condition.
SSER-10, dated March 1985, described the NRC staff position in that before November 30, 1985 LP&L would have environmentally qualified all electrical equipment according to the provisions of 10 CFR 50.49.            t The above identified documents were reviewed by the inspection team members and used in preparation for this inspection. The inspection involved an onsite and subsequent NRC Region !Y in-office inspection of records subsequently furnished by the licensee.
: 4. Findings:
a,     E0 Program Compliance With 10 CFA 50.49 The NRC inspectors examined the licensee's program for establishing the qualification of electric equipment within the scope of 10 CFR 50.49. The program was evaluated by examination of the licensee's qualification documentation files, review of procedures for controlling the licensee'3 EQ efforts, and verification of adequacy and accuracy of the licensee's program for maintaining the ~
qualified status of electrical equipment. Based on the inspection findings, which are discussed in more detail below, the inspection team determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49 for the Waterford Steam Electric Station, Unit 3 although some deficiencies were identifiet (refer to '
Sections 4.f and 4.h).
: b. E0 Program Procedures The inspection team examined the implementation and adequacy of site policies and procedures for establishing and maintaining the environmental qualification of electrical equipment in compliance with the requirements of 10 CFR 50.49. The licensee's methods for establishing and maintaining the environmental qualification of electric equipment were reviewed in the following documents:
1 Nuclear Operations Proceoures Title                               Date Proc. No./ Revision Equipment Qualification             10/20/86 NOP-009/Rev. 0.1 Project Management Procedures Proc. No./ Revision         Title                              Dye The Project Management             04/04/86 PMP 101/Rev. 2 Procurement Process

a    ,!
10 i
l PMP 103/Rev. 2            Preparation and Processing of       05/02/86 Purchase Documents PMP 302i 'e J. 1        Procedure Change Notice (PCN)       08/07/85 PHP 304/Rev. 4            Modification Prokc' Closeout        08/28/86 PMP 322/Rev. 1            Engineering Purchase Requisition    01/27/86           l Preparation PMP 325/Rev. 1            Equipment Qualification             11/17/86
                  .        Project Management Instructions Instruct No./ Revision          Title                         Date PMI'309/Rev. O                  Preparation of Equipment      11/22/85 Qualification Assessment Reports                                      ;
                                                                                                        ~
                                                         " Development, Centrol, Update.
* PMI'-310/Rev'. *
   ~ -
and Issue of the EQML PMI-311/Rev. 1                  Developmer.t. Control and     11/19/86 Update of EQ Data Base PMI-312/Rev. O                  Use of the Ma*erials Aging    11/22/85 Data Base (System 1000)
PMI-313/Rev. O                  Instruction Change Notice     04/18/86         [
(ICN)                                        ,
Engineerina Procedures i
Proc. No. / Revision            Title                         Date r
 !                         PE-2-006/Rev. 8                 Plant Engineering Station     07/16/86         l Modification                                 i PE-2-014/Rev. 3                  Equipment Qualification      12/17/85 Administrative Procedures Proc. No./ Revision             Title                         Date UNT-1-015/Rev. O                 Equipment Qualification      11/26/85 Program
* revision and date not documented by the NRC inspector during the inspection L
F L
s     - - ~ , - , - - -              . - ,  ,- , .,  ,         ,..-,,,_~,,,n, -

0 11 i
UNT-8-001/Rev. 12                   Processing of Procurement     03/07/86 Documents Maintenance Department Procedure Proc. No./ Revision                 Title                         Date             l
!                MD-1-020/Rev. 1                      Equipment Qualification       08/28/86         I Program The inspection team reviewed the above licensee's procedures for meeting the requirements of 10 CTR 50.49 including (1) qualified life; (2) service conditions; (3) periodic testing; and j                        (4) maintenance and surveillance. The licensee's EQ program was also reviewed with regard to establishment of an auditable documentation 1
file, including such documents as EQ audit reports, mainte3ance and surveillance records, supporting documents which establish EQ training of personnel, and supporting documents which contrci plant modifications procurement, and installation of replacement equipment
                     - to-the requirements of 10-CFR 50.49. -                                      -
l                        The licensee's EQ program procedures and policies are established and are being adequately implemented to control and maintain the environmental qualification of electrical equipment at Waterford 3 for compliance with the requirements of 10 CFR 50.49.
: c. EQ Maintenance / Replacement Parts / Control of Plant EQ Modification Programs The following programs were effectively in place at Waterford 3:
(1) EO Maintenance Program The LPR EQ maintenance program is an integral part of the licensea's overall EQ program and is specifically addressed in Procedure MD-1-020. General and specific maintenance tasks are specified in plant instructions and schedules at the plant.
For safetyeach (ENSEQ) master list component, engineering and nuclearprov qualification maintenance instructions (EQMI's). The maintenaxe environmental qualification coordinator (MEQC) uses the information on the EQMIs to prepare EQ data records, and assist in the development of procedures that ensures the qualification of equipment is maintained. Required EQ maintenance is in;orporated into the EQ maintenance program.
Monitoring and rniew of maintenance activities and failure data is performed by a maintenance engineer for the purpose of detecting trends on EQ equipment. Examples include chronic or repetitive failures of similar or identical components, and

7%
conditions and malfunctions that indicate equipment degradation or failure. The NRC inspection team also reviewed the following specific documents pertaining to the licensee's implementation of his EQ maintenance program:
EEQD file 3.2 - Asco Solenoid Valve Installation and maintenance instructions - Bulletin 83-16 EEQD file 35.1 - Valcor solenoid operated valves.
EQ maintenance input summary - LPL-EQMI, 35.1
        ,                  Environmental Qualifications Assessment on Target Rock solenoid valves - Report No. LPL-EQA, 35.6 EQ maintenance input file 35.6 In addition to procedural reviews anti personnel interviews, the
            .        NRC inspection team, on a sampling basis, reviewed maintenance procedures and records for selected components covered in the (Q
               - file reviews and pTant walkdown inspection.           Based on these inspections, the NRC inspection team concluded that the LP&L maintenance program appears well planned and implemented.
(2) EQ Replacement / Procurement Program The LP&L EQ replacement / procurement program is an integral part of the licensee's overall EQ program, and is addressed in procedures PMP-101, UNT-8-003 and UNT-8-001. The referenced procedures describe the licensee's overall program for meeting 10 CFR 50.49. The procedures describe the method for plant staff personnel to initiate and obtain items identified as EQ for plant station modification, spare and replacement components, subcomponents, parts, material, tools, and services.
The NRC inspection team concluded that these proceduret will cover the LP&L EQ activities and requirements. The EQ replacement / procurement program appears well planned, documented, and implemented as required by 10 CFR 50.49.
(3) Control of Plant EQ Modification The NRC inspection team examined the implementation and adequacy of the licensee's control of plant EQ modifications.               The modification program is addressed in procedures PE-2-006 and PMP-304. The licensee's program was reviewed to verify that adequate procedures and controls had been established to meet the requirements of 10 CFR 50.49. Areas of the program reviewed included methods and their effectiveness for:

e ,                                                                                                                                                                      ,
j ,.                 .                                                                                                                                                          1 4
13 Describing the w thod for processing modifications to plant                                         !
systems from the time of request through implementation to                                          !
final closeout.                                                                                    [
Controlling plant modifications including installation of                                           !
new and replacement equipment, and providing for updating                                          i replacement equipment to 10 CFR 50.49 criteria.                                                     !
e The NRC inspection team t.oncluded that these procedures will                                                         [
cover the LP&L EQ activities and requirements. The EQ program for control of plant modifications appears weli platined,                                                             3 documented, and implemented as required by 10 CFR 50.49.                                                             ;
No Potential Enforcement / Unresolved Items or Open Items were                                                                          i identified during this inspection for these EQ programs in paragraphs (1) through (3) above.                                                                                                      !
: d. EQ Surveillance /Trainina/and Audit Programs                                                                                            ,
                                         .           The NRC inspection team did not review the procedures and controls                                                                     !
,                                                     for the.Waterford 3 EQ surveillance (preventative maintenance)                                                                         t prograin, EQ training program ~, and EQ~ audit program. Verification of j            - -                                      these program implementations will be accomplished during a                                                                          :
1                                                     subsequent NRC insp+ction.
: e. Eautoment Qualification Master List - Electrical (EONL-E)                                                                             l Development, control, update, and issuance of the EQML-E is E                                                     prescribed in project management instruction PMI-310.
f Considered in the preparation of the EQML-E by the licsnsee was                                                                       ,
1                                                     review of Technical Specification, emergency operating                                                                                ;
procedures (EOPs), FSAR, artchitect engineers master equipment                                                                        ,
j                                                     list /Q-list, vendor information, purchase orders, P& ids, and control                                                                :*
wiring diagrams (CWDs) for the equipment located in a harsh 4
environment which requires qualification.                                                                                              !
In order to test the completeness of the EQML-E, specific components                                                                  -
were selected from the Waterford 3 CWDs relating to the safety                                                                       1 i                                                      injection (SI) system. The following CWD's and P&ID's were selected:                                                                  [
                                                      -                 CWD-LOU-1564-8-424, sheet 5005 - High pressure safety injection                                                      ;
e pump A.
                                                      -                 CWD-LOU-1564-B-424, sheet 5075 - High pressure safety injection                                                      f pump AB.                                                                                                             [
{
j
                                                       -                CWD-Loll-1654-E-424, sheet 5125 - Reactor coolant loop #2 hot leg i
flow control.                                                                                                       ;
i                                                                                                                                                                                            l l                                                                                                                                                                                            !
I l                                                                                                                                                                                          i
  -- .,. - - . - _ - _ _ _ , _ , ~ , _ ,     _

14
                                      -       CWD-LOU-1564-B-424, sheet 527 - High pressure safety injection flow control valve.
                                      -       CWD-LOU-1564-B-424, sheet 4305 - Low pressure safety injection pump.
                                      -       CWD-LOV-1564-B-424, sheet 5525 - Safety injection tank A.
                                      -       P&IO-LOU-1564-G-167-SI - flow diagram.
Also the Waterford 3 E0P No. 902-002 entitled "LOCA Recovery Procedure," dated February 8, 1985, and operating procedure No OP-9-008," Revision 6, dated September 16, 1986,
                        .             entitled "Safety Injection System," were reviewed, by the NRC inspection team.
All of the components and equipment selected for review were found on the EQML-E. Components were also selected from an earlier Waterford 3 EQML-E submittal dated October 25, 1985. These components were also found on the current EQML-E dated November 12,
                                  ,, 1986,. Revision 4.          _      _
   '~                                  Based on the NRC inspection team's review, the 10 CFR 50.49 EQML-E 1:
considered satisfactory.
: f. Environmental Qualification Documentation Files The licensee's Equipment Qualification File (EQF) has been established and is being maintained to meet the requirements of 10 CFR 50.49 at the Waterford Unit 3 Steam Electric Station. The requirements for establishing, controlling, maintaining, routing, j
filing, and updating the EQF are contained in LP&L procedures (1) PMP-325, Revision 1, "Project Management Procedure - Equipment Qualification"; (2) UNT-1-015, Revision 0, "Administrative Procedure
                                        - Equipment Qualification Program"; and (3) NOP-009, Revision 0.1, "Nuclear Operations Procedures - Equipment Qualification". Other LP&L procedures which govern EQF activities are listed in paragraph 4.b of this report. The responsibilities for an auditable 4
and complete EQF is assigned to LP&L ENS personnel.
The NRC inspection team examined the licensee's EQF for 37 selected electrical equipment qualification documentation (EEQOs) packages to verify the qualified status of equipment witnin the scope of 10 CFR 50.49.
In addition to comparing plant accident conditions with qualification test conditions and verifying the bases for these conditions, the NRC inspection team selectively reviewed areas such as (1) required post accident operating times compared to the duration of time the equipment has been demonstrated to be qualified; (2) similarity of type tested equipment to that installed in the plant; (3) evaluation I'

15 of adequacy of test conditions to environmental profiles of the planc; (4) aging calculations for qualified service life; (5) maintenance, and replacement part schedules; (6) the effects of insulation resistance (IR) decreases on component performance; (7) adequacy of demonstrated accuracy of equipment under plant environmental conditions; (8) evaluation of test anomalies relating to installed equipment configurations; and (9) applicability of EQ problems as reported in NRC IENs and Bulleties (IEBs) and their resolution.
During this review of the EQF the inspection team identified the following Potential Enforcement / Unresolved Items and Open Items, described below.
(1) EEQD 42.3, Bora Warner Operators, Model 39400, UNID No.'s SI-MVAAA-405A, and SI-MVAAA-405B The above operators are located inside containment and are used for the shutdown cooling isolation valves. The licensee considers these cperators qualified to the requirements of NUREG 0588, Category I. . A station modification No. SM-1398,        .
                                                               ~ Revision 1, was in place during this NRC inspection to upgrade these operators in establishing similarity between the plant instslied madels (39400) and the tested model (86090). The NRC l
inspection th3m reviewed the station modification which showed that similarity would be established once the upgrade work was completed.       Comp,3 tion of SM-1398, Revision 1, considers these l                                                                        operators qualifieo' to the requirements of 10 CfR 50.49 NUREG 0588 Category I. The upgrade su scheduled for completion during the noterford 3 first refueling outage during which this NRC inspection occurred.
The EEQD 42.3 file is requireo to document and reflect the as-built installed upgraoes of SM-1398. A JIO for Borg-Warner operators, dated May 16, 1985, addressed the test anomalies, resolutions, and required modifications (reference: Waterford 3 letters, W3P85-1188 of May 16,1985, and W3P85-3130 of November 1, 1985). The licensee's letter to NRC Region IV, dated February 2,1987, provides further information on the licensee's basis for interim operation and further discusses the scheduled completion of the qualification for these actuators.
LP&L submitted a JIO to the NRC on May 16, 1985, targeting qualification of these actuators by the November 30, 1985, deadline date of 10 CFR 50.49. During the testing program, several equipment anomalies occurred in which design changes to 4                                                                         the type test actuator, were either implemented en the actuator type test specimens and/or required changes to the installed
!                                                                         equipment, as follows:
   .y  ,                    - ___. .___ _ _ , -         _y__-     - - - -     .         ,r   ~ * - - - - - - - - - - - - + -              %

16 (a) The motor / pump sechanical coupling separated during seismic testing. The pump and motor shafts are connected by a
;i                                                            rotating mechanical coupling. The coupling is keyed to the motor shaft and laterally by a set screw.       During the test, the set screw was found to have backed off the motor shaft.
The motor / pump coupling was secured by indenting the motor shaft and adding one additional set screw.
(b) An anomaly occurred during testing in which an improper electrfcal wiring connection to a single phase caused an operator failure. All terminal blocks were removed and replaced with qualified splice materials.
(c) A solenoid valve failed due to chemical spray intruding through a faulty conduit to the solenoid coil connections.
This anomaly occurred during simulated accident testing es a result of item (b) above in which the conduit was not adequately replaced to the operator wiring connection. The
                                 ~
solenoid valve and nther electrical conduit pathways were sealed. 0-rings were addf.d to the solenoid valve assembly as a secondary seal.--                                              -
(d) As a result of the multiple test runs, excessive contamination of the hydraulic fluid occurred. The hydraulic fluid contamination clogged the small filter in the solenoid actuated pilot valve causirg excessive pressure resulting in the seizure of the pump and the decoupling of the motor shaft. The hydraulic filter size was increased to reduce the potential for clogging. A check valve was required to be added to the hydraulic
,                                                              reservoir to limit ingress of chemical spray and other contaminants into the hydraulic fluids (however, this check valve was an integral part of the installed equipment at Waterford 3).
(e) During manufacture, the wrong size shim was used on the type test pilot piston / cylinder configuration. As a consequence of improper tolerance, the actuator failed immediately when operated at the peak test temperature during accident testing. The installed equipment at Waterford 's is similar but does not have the same pilot piston configuration and the licensee claims the anomaly is not applicable. No design changes were required, i                                                        With the exception of item (b) above, and ites (e) which the licensee claims not- applicable, the design changes required were
:                                                       not incorporated on the Waterford 3 installed equipment configuration as follows:
j                                                              The pump / motor coupling set screw modification was not implemented on the installed actuators because the licensee I
d

17 maintains that during the fabrication of the type test actuator, the sealing surface on the test actuator was identified as being abnormal. The specification allowed 2.005 inch. The sealing surface was just within the maximum allowable tolerance. The licensee judged this condition as the contributor in providing the inclined forces necessary to decouple the coupling. The pump / motor coupling for the installed operators, however, were verified by the licensee to be well within the allowable tolerance and judged acceptable.
The 0-rings, used for secondary sealing, were not available for use during the design change period of the installed
        .                actuators due to the extensivo machining required. The licensee elected to seal the electrical conduit with RTV 106 potting compound.
A change to a larger filter was not implemented on the installed actuators due to unavailability of the component and the extensive machining required to implement this
_ , . . design change,.        ..   .                                                  .
  ~ '
All modifications required to establish qualification by similarity were not completed by the November 30, 1985, deadline, but rather completed during the first refueling outage during which this NRC inspection occurred.
Potentially, this equipment was in an unqualified status from November 30, 1985, to this outage.
This item is considered a Potential Enforcement / Unresolved Item (50-382/8632-01).
(2) EEQD 4.12 and 4.13, Seimens/Allis Motors, Model 113 UNIO No.'s SI-EMTR-3AB-3A and SI-EMTR-3B-3A The above Seimens-Allis motors are located outside containment in the reactor auxiliary building and are used as drivers for the high pressure safety injection (HPSI) pumps AB and B. The
!                 Waterford 3 plant considers these motors qualified to the t                  requirements of 10 CFR 50.49/NUEG 0588, Category II. Specific test reports were not referenced in, or contained in EQF, EEQD 4.12 and 4.13, at the time of this inspection. LP&L's letter to NRC Region IV, dated February 2, 1987, provided test report No. NQ 890339-1, Revision 0, dated June 26, IS81, "Equipw nt Qualification for Class 1E Safety-Related Service in Power Generation Stations Outside Containment." This document now forms an attached EQ assessment incorporated as part of the EQF, EEQD 4.12 and 4.13 for Waterford 3 HPSI and LPSI motors.
The NQ 890339-1 document is currently undergoing NRC review ar.d may be closed out during a subsequent NRC inspection.

1   '
18 The EQF. EEQD 4.12 and 4.13 for Siemens-Allis HPSI pump motors did not establish qualification during the time of the NRC inspection because the qualification documentation was incomplete and not available in the EQF to support qualification. This item is considered an Open Item (50-382/8632-22).
(3) EEQD 8.2A,            ITT Barton Pressure Transmitters. Models 763 and 764 Examination of an equipment qualification assessment (EQA) contained in EEQD 8.2A. identified a deficiency concerning
!                           submergence of ITT Barton model 7ti3/764 pressure transmitters.
The basis of qualification for this equipment is NUREG 0588 Category 1. The E0A did not contain documentation to show that j                         a type test was conducted for the equipment in a submerged environment. LP&L's position was that the equipment was
!.                         qualified for submergence based on a letter from ITT Barton who had perforwed a steam test at a prescribe:1 pressure. The ITT
,                           Barton letter claimed that this test equated to the equipment
!                          being submerged under 30 feet of water under type test pressure
                 .      .- conditions. The NRC-inspection team during the inspection                -
        .                   concluded that the EQF. EEQD 8.2A for ITT Barton Model 763/764
!                           pressure transmitters, did not adequately establish
;                           qualification because of failure to demonstrate qualification i                           based on DBA conditicns in that no type test to demonstrate j                          qualification for "5 mergence were contained in the EQF.
i j                           LP&L's letter to NRC Region IV dated February 2.1987, provided i                           engineering evaluation letter No. W3B87-0218 dated January 29 I                           1987. "Analysis of Reactor Containment Building Sump Level indication for Submergence." This document now forms an integral part of EEQO 8.2A for the Waterford 3 ITT Barton pressure transmitter, models 764 and 764, used for post accident monitoring purposes. Analysis W3887-0218 now indicates that
;                           containment sump level transmitters SP-ILT-6705A and B. located l
approximately 5 feet below the accident flood level, will not be used for DBA/ post DBA conditions. Analysis W3887-0218 also ind'tates that SIS sump level transmitters SI-ILT-7145A and SI-ILT-71455 located above the postulated accident flood level i
will be used in lieu of SP-ILT-6705A and B. during the post l                            accident period. SI-ILT-7145A and B will therefore not be l                            required to be submergence qualified.
LP&L indicates that the EQF. EEQD 8.2A will require modification to incorporate the above changes. Also, the emergency operating p-ocedures will be reviewed to clarify use of the changed post accident indicating instruments. EQF. EEQD 8.2A will be required to reflect the correct accident operating times for the appropriate transmitters.

19 Because the EQF, EEQD 8.2A, during the time of the NRC inspection, did not adequately establish qualification for submergence of the ITT Barton models 763 and 764 for post accident conditions, and because its safety-related function during DBA/ post DBA is now rescinded by substitute transmitters above flood level, this item is considered a Potential Enforcement / Unresolved Item (50-382/8632-02).
(4) EEQD 3.1. A, Limitorque Motor Operators, Model SMB-00, Thomas &
Betts Blind Barrel Crimp Cable Splices The basis of qualification for these operators are NUREG 0588, Category II. During the walkdown of limitorque valve operators,
                                    -           it was observed that motor lead connections in operator EWF-HVAAA-220-A had been spliced with blind barrel (pigtail) crimp splices. Qualification test reports provided for the operators contained in the EQF, EEQD 3.1A did nat include qualification of the splices; there was no documentation at thF time of the inspection to show that the splices had ever been separately qualified.
                                        ~'  ~
he licensee's letter to SRC Region IV, dated February 2, 1987,'
provided: (1) a memorandum to the EQF, EEQO 3.1A, dated January 16, 1987; and (2) a W3887-0300 response letter to LP&L j"                                              from Limitorque Corporation, dated January 6, 1987. The above memorandum presents LP&L's position with respect to 38 timitorque. actuators which have dual voltage motors incorporating extra motor leads interconnected to field cable, utilizing Thomas and Betts, type RB-4 or RC-6, blind barrel (pigtail), crimp type, cable splicas. The LP&L position references the W3687-0300 letter which indicates a dual voltage motor type test, utilizing Thomas & Betts RB-4 and RC-6 crimp type splices, was performed. However, the crimp type cable splice information was not fully documented in Limitorque test l                                                report numbers 600198 and 600376A.
NUREG 0588, Revision 1, Category II, paragraph 5, requires that i                                                qualification documentation shall verify that eech type of electrical equipment is qualified for its application and meets its specified performance requirements. The basis of qualification shall be explained to show the relationship of all facets of proof needed to sunport adequacy of the complete equipment. Data used to demonstrate the qualification of the  ,
equipment shall be pertinent to the application and organized in an auditable form. The docuraentation should include sufficient information to address those items identified in NUREG 0588,
,                                                Appendix E, which includes splices.
The qualification documentation referred to in Limitorque test report 600198 and 600376A should be placed in EEQO3.1A and I                                                evaluated by the NRC for its applicability to demonstrate

*   ?
20 qualification of the splices for the EFW valve operators. The qualification test reports provided in EQF, EEQD 3.1A, together with any new oualification data should be documented in EQF, EEQD 3.1A, to demonstrate full qualification requirements.
1his item is considerte a Potential Enforcement / Unresolved Item (50-382/8632-04).
(5)   EEQD 3.1, limitorque Motor 0)erations, SMB Series switch Compartment Com)onent Aging Requirements; Qualification of Temperature )egradable Items The basis of qualification for these operators are NUREG-0588,
      .           Category II. It has been the practice of LP&L to energize space heaters in Limitorque valvt operator limit switch compartments during plant operation. Since the heaters were not considered in the operator qualification documentation of the EQF, EEQD 3.1, precautions should be taken to ensure that the energized heaters will not affect operator qualification. One concern of the NRC inspection team was resolved during the inspection where it was found that the heaters were supplied                                                      .
              ~ from a Class IE source, but double fused for purposes to protect the power supply in the event of a heater failure.                     Another area of concern of the NRC inspection team which had not been adequately addressed, was that no documentation was available in EQF, EEQD 3.1, to show the effects of accelerated aging of temperature degradable items within the limit switch compartment due to temperature rise and radiant heat transfer produced by the heaters. It was also observed by the NRC inspection team that the EQF, EEQD 3.1 did not contain documentation to qualify components within the limit switch compartment separately.
The licensee's letter to NRC Region IV, dated February 2, 1987, indicated a station modification program in effect which has deenergized those heaters which were energized. The qualified life of the deenergtzed heaters ha; also been reevaluated considering the time that the heaters were energized. The results of this station modification program should be fully documented and placed in the EQF, EEQD 3.1. This item will be evaluated during a subsequent NRC inspection.
This item is considered an Open Item (50-382/8632-21).
(6) EEQD 3.1, Limitorque Motor Operators, SM8 Series, Internal Wiring Qualification Generic letter 85-15 sets a deadline of November 30, 1985, for all equipment quellfication, except where the Commission has granted an extension. Additionally, IENs 83-72 and 86-03 identified several internal parts or design features of Limitorqee operators as possible sources of qualification

21 deficiencies. The NRC inspection team found that the concern of unidentified wiring addressed by IEN 86-03 existed at Waterford 3 until Septemoer 1986 at which time replacement of                                                                          .
potentially unqualifi.ed t.iing was reportedly completed. A review of information provir'ed during the NRC inspection                                                                             ,
suggested that continued operation during the November 30, 1985,                                                                       '
through September 1986 time interval could be in noncompliance with 10 CFR 50.49, NUREG 0588, Category II, paragraph 5, and Generic Letter 85-15 because the EQF, EEQD 3.1 lacked supporting                                                                      ;
documentation to demonstrate qualification for the unidentified                                                                       ,
wiring removed.
1 The licensee's letter to NRC Region IV, dated February 2,1987, provided a time history account in LP&L's response to IEN 86-03.
LP&L implemented scheduled inspections and work on all 64 EQ Limitorque operators on January 17, 1986. By the beginning of                                                                         ;
March 1986, walkdown inspections had been completed on 27 valves                                                                      l and by the end of March, 55 operators had been inspected. Five                                                                       !
               -                         of the remaining nine onrators were completed shortly after the                                                                      :
March 1986 outage. Wal(down inspections on the remaining four                                                                    ~
cperators were ct;mpieted'on' June 19, 1986. When unidentified
; - -                                    wire was identtYied, it was replaced with documented Rockbestos                                                                       !
SIS wire, qualified for use in all harsh environments at                                                                             >
Waterford 3 documented in EEQD 6.3 and 6.3A. Representative sampling of wires were removed from the operators as a result of                                                                     !
the walkdown inspection program, and tested under simulated                                                                          -
accident conditions. The applicable test conditions enveloped the outside containment accident environment. No unidentified wiring was identtfied in operators located inside containment.                                                                        !
:                                        LP&L maintains that test results on the unidentified wiring                                                                          i removed is av.tilable and that harsh environment accident                                                                             '
conditions would not have negated valve operator functions. The test results of the unidentified wiring removed during LP&L's                                                                        j
;                                        walkdown inspection program, between November 30 1985, and                                                                            ,
t                                        June 19, 1986, should be fully documented to support                                                                                  ;
j                                        qualification and placed in the EQF. This item will be evaluated during a subsequent NRC inspection and is considered                                                                        -
a Potential Enforcement / Unresolved Item (50-382/8632-05).                                                                          ;
j (7) EEQD 14.1/52.1. B:W Cable Assembly                                                                                                    l (a) The qualification criteria for this file is NUREG 05B3, Category II. The EQF contains an Isomedix test report on                                                                 .
t                                                    radiation aging performed for Litton Precision Products.                                                                 l The EEQD 14.1/52.1 is intended to qualify a connector and                                                                ,
flex conduit in addition to the cable.
Appendix 11 cor.tained in EEQD 14.1/52.1 included an EBASCO memo describing the thermal lag analysis done on the                                                                     ,
assembly.               The analysis indicates that the silicone potting                                                 ;
compound may be subjected to temperatures as high as r

:   o 22 404' F. The EQF does not address the effects of this temperature on the complete cable / connector assembly whose qualification temperature only qualifies to 340'F for a MSLB accident. The EEQD 14.1/52.1 for the BIW cable assembly contained information showing that the silicone potting comnound degradable material had temperatures during an MSLB exceeding this qualification temperature, and no analyses to meet the staff requirements of NUREG-0588, Category II, paragraph 1.2(5), was contained in this file. The NRC staff requirements ask for documentation in the file to demonstrate that the MSLB test conditions exceed those postulated for the accident particularly in regards to the surface temperature of the equipment. The staff requires this additional justification documented in the file to demonstrate its required functional operability.
The licensee's letter to NRC Region IV, dated February 2, 1987, provides an additional test report No. 558-1654 performed by National Technical Systems in which the test
                            .. - accident profile envelopes.the MSLB temperature peak. The-NTS test report now contained in EQF, EEQD 14.1/52.1 will be evaluated during a subsequent NRC inspection. This item is considered Potential Enforecement/ Unresolved Item (50-382/8632-06).
(b) The EQMI for the BIW cable assembly, contained in the EQF, identified an area in the plant where the installed assemblies would be subjected to a service temperature that exceeds the manufacturer's temperature rating. This does not meet NUREG-0588, Category II, 4(2) requirements for periodic replacement of equipment susceptible to aging effects. The qualification documentation in the EQF should address aging to the extent that equipment with materials susceptible to aging effects should be identified, and a schedule for periodically replacing this component / material should be established.
Components identified in the EEQD 14.1/52.1 BIW cable assemblies were located in an elevated service temperature environment and no replacement schedule had been established. Only an inspection program to monitor degradation on 18-month intervals was in effect. A component replacement schedule is required, based on an air temperature measured close to the connector assemblies.
LP&L is in the process of determining a replacement for these assemblies on the RVH and will revise the file and EQHI accordingly.
This item is considered a Potential Enforcement / Unresolved Item (50-382/8632-07).

23 (8) EEQD 15.1, Conax Electrical Penetrations, Model 7320 10,000 Series The qualification criteria for this EQF is NUREG-0588 Category I. The EEQD uses the following Conax test reports to establish qualification:                (1) No. 596, Low Voltage Power, Control and Instrumentation; (2) No. 607, Medium Voltage; and (3) No. 700, Personnel Air Lock.
(a) The test reports above, in the EQF, reference Conax report ISP-568 to support qualification in that the internal tempersture of the penetration will not exceed the saturation temperature of the steam during the maximum
                                                .                              temperature excursion for the MSLB, This report was not available in the EQF for review.
(b) The above test reports list an acceptance criteria for IR measurements of 1 x 20s ohms for terminal blocks. There was no documentation in the EQF to show that the plant specific functional performance requirements were
                                                                .              satisfied.. The analysis which shows application of the     .
                                                    '~    ~
type test configuration to the installed configuration was
    ~-
missing in the EQF.
(c) The EQMI requires an analysis of the Kulka terminal blocks with respect to IN 84-47 (EQ LOCA/MSLB tests conducted on electrical terminal blocks at Shadia National Laboratories in which a moisture film formed on the surface and resulted in degraded IR measurements between terminal points and ground). There is no indication in the EQF, EEQD 15.1 that this analysis was accomplished. The analysis in the EQF was missing.
The licensee's letter to NRC Region IV, dated February 2, 1987, provides further corrective action with respect to (a) above in that report IPS-568 has been placed in EQF. EEQD 15.1, and may be reviewed. Also with respect to (b) above, the licensee indicates the missing evaluation associated with IR measurements, which shows application of the test configuration to that installed, addressed in LP&L letter W3887-0222 dated February 3, 1987, is now placed in the EQF and may be reviewed.
With respect to (c) above, the licensee's response to IEN 8b47 has been addressed in LP&L letter W3887-0222, and also may be reviewed in the EQF. LP&L, in letter W3887-0222, indicates that the terminal blocks in question during the NRC inspection installed in Conax electrical penetrations are utilized for non-1E circuits with the exception of those used for reactor vessel core exit thermocouples. The EQF, EEQD 15.1 should
)                                                              identify subassemblies, components, and parts which are not i                                                             required to be EQ qualified in the electrical penetration assembly.

1, 24 The above items (a), (b), and (c) will be evaluated during a subsequent NRC inspection and are considered an Open Item (50-382/8632-08).
(9) EEQD 6.2/16.2, Okonite SKV Cable and Splices The EQF, EEQD 6.2/16.2 is set up to qualify Okonite Okoguard insulated cables and No. T95 Okonite splices used with No. 35 splicing tape. The qualification criteria for this file is NURiG-0588, Category I.      The EQF uses Okonite test report NQRN-3 to support qualification.
(a) The EQF, contains a thermal lag analysis for the DBE
         .              accident that takes cradit for the cable jacket. The file does not indicate the jacket material for the installed cable. The type test cable and splices were not jacketed.
It did not appear, during the NRC inspection, that the thermal lag analysis was applicable.
 ,         -            The licensee's letter to NRC Region IV, dated February 2, 1987, provided additional information with reg rd to the _
qualification ~of the' installed jacketing material on
   - -                  Okonite cables. Qualification by similarity to the jacketing material on Samuel Moore cables used at 4
Waterford 3 has now been established, referencing EEQD 6.8 in the EQF, EEQO 6.2/16.2 files. The licensee now maintains qualification is established and credit can be taken for the thermal lag analysis. The analysis and qualification documentation of EEQO 6.8, with regard to jacketing qualification will be evaluated during a subsequent NRC inspection.
(b) Also EQF, EFQO 6.2 contains a statement requiring verification that the 1 stalled cable service temperature, including internal heat rise, remain below 90'C.      There is no indication in the file that this verification has been accomplished. LP&L accepted an EBASCO engineering judgement that both splices and cable are thermally prottcted by the cable tray enclosures and therefore no requirement for verification was needed. During the inspection, LP&L indicated that this verification statement should have been removed from the EQF, EEQO 6.2.      An analysis to justify negating the verification requirement 4                       is required in the EQF, and will be evaluated during a subsequent NRC inspection.
Items (a) and (b) above are considered an Open Etem (50-382/8632-10).
f

o 25 (10) EEQD 39.3, Rosemount Resistance Temperature Detectors (RTDs)
Model 104-1619-6 These RTDs acnitor reactor coolant temperatures and send input signals to the core protection calculators.      The qualification criteria for this file is NUREG 0588, Category II. At the time of the NRC inspection, the file indicated that these RTDs were required to be qualified for submergence, but file documents demonstrated they were not tested for submergence. During the 4                                NRC inspection, the licensee showed that these instruments are located above the flood level of -1,2 feet mean sea level and do not require submergence qualification. The licensee's letter to NRC Region IV, dated February 2,1987, provided corrected pages
               ,                 to EEQO 39.3 showing the submergence requirement for EQF, EEQD 39.3 rescinded. This file will be reviewed during a subsequent NRC inspection and is considered an Open Item (50-382/8632-11).
(11) EEQD 6.6, BIW Coaxial Cable The qualificatica criteria for this file is NUREG-0588,                                    .
                            --" Category I. The file uses the BIW test report 8912 with
   - -                           supplemental documentation from the Franklin test report F-C3859-1. The cable is used for the neutron detector wiring to the control room. The NRC inspection team determined that the current and voltage levels utilized by this cable in its application at the Waterford 3 plant are not those used in the same range during the generic type test. A significantly lower level is required for the plant specific application. A a                                separate calculation in the EQF would normally be required to address the functional performance of the BIW coaxial cable used in the plant specific application for EQ qualification.
2 i                                However, the licensee's letter to NRC Region IV, dated February 2, 1987, identifies the BIW coaxial cables as non-EQ qualified, in that LP&L claims no requirement for this cable to survive the LOCA/MSLB accident.
The EQF, EEQD 6.6 should identify subassemblier, components, and parts which are not required to be EQ qualified, with regard to the excore neutron monitoring system, and will be evaluated during a subsequent NRC insper. tion and is considered an Open Item (50-382/8632-12).
(12) EEQD 6.1, Okonite 600 VAC Cable The qualification criteria for this file is NUREG-0588, Category I. The EQF uses the Okonite test report NQRN-1.
(a) The file includes a thermal lag analysis for Okonito 600 VAC cable during a DBE accident. The thermal lag l

26 analysis is a generic document and should be evaluated on a case-by-case basis. The analysis is used to show that the short duration peak temperature of 414*F will not cause equipment and cable to heat up above the test temperature of 340*F. No credit is taken for the mitigating effects of cable tray, or conduit, in this calculation. However, credit is taken for the cable jacket. For cables, the temperature rise associated with the peak temperature is shown to be acceptable below the cable jacket thickness.
The type test report must demonstrate documented jacket performance during thermal and raciation service life aging to ensure its integrity prior to survival of the DBE accident simulation.
Test report NQRN-1 does not identify the jacket conditions at the conclusion of the thermal and radiation service life aging. The thermal lag analysis shcuid reference documented service life aging results of the cable.
The licensee letter to NRC Region IV, dated February 2,
               ~ .. 1987, indicated that.the jacketing material on              -
    - ~
Okonite 600VAC cable has been qualified by similarity to the jacketing material on Samuel Moore cables used at the Waterford 3 plant, qualified as demonstrated in EQF, EEQD 6.8. This vindicates credit for the thermal lag analysis approach found in the EQF, EEQD 6.1 for Okonite 600 VAC cable.
The analysis and qualification documentation of EEQD 6.8, with regard to jacketing qualification, will be evaluateo during a subsequent NRC inspection.
(b) Submergence, including demonstration of acceptable IR measurements during post submergence voltage withstand tests are contained in a separate test report. The test report is not referenced in the file. This item is a documentation deficiency.
(c) The EEQD 6.1 references a test report to support the cable temperature rise due to ampacity heating of the cable. The report document is not in the file. This is a documentation deficien:y.
The above items (a), (b), and (c) are considered an Open Item (50-382/8632-13),
(13) EEQD 6.3 and 6.3.A, Rockbestos Firewall III Cable The qualification criteria for this file in NUREG-0588, i
Catsgory I. The file uses Rockbestos test reports QR-5804 (chemically XLPE), QR-5805 (irradiated XLPE) and TR-6801 l
l
[

          -                                            27 (similarity analysis). A letter from Rockbestos indicates which qualification reports are applicable to each respective shop order. Both the chemically and irradiated XLPE cables are qualified for a 40 year life at the worst case accident profile conditions and are therefore intetchangeable. The Waterferd 3 pull card system maintains records of cable identification and location within the plant.
No Potential Enforcement / Unresolved Items or Open Items were identified.
(14) EEQO 8.30, General Atomic Radiation Detector, Model R0-232 UNID No. ARM-IRD-5400A5 The'above detector is located outside containment and is used as an area radiation monitor for the reactor building. The Waterford 3 plant considers the detector qualified to 10 CFR 50.49. Qualification will be established when the EQF, EEQD 8.3C is upgraded to reflect the ca.,rrect Rockbestos test report and performance data for the BIW coaxial cable used in the reactor building area. radiation monitoring system. The     .
                          ~ licensee letter to NRC Region IV, dated February 2, 1987,
                     'J
  - -                          indicated this information has been placed in the EQF, and will be reviewed during a subsequent NRC inspection. This item is considered an Open Item (50-382/8632-18).
: g. IE Information Notices and Bulletins The NRC inspector team evaluated the licensee's ar.tivities related to the review of EQ-related IENs and IEBs. The NRC inspection team review included examination of the licensee's procedures and EQ documentation files relative to IENs and IEBs. fhe procedures rev bwed determined that the licensee does have a system for o!s.ributing, reviewing, and evaluating IENs and IEBs relative to equipment within the scope of 10 CFR 50.49 (refer to paragraph 4.b).
During the review of the licensee's EQF, however, the inspection team identified one concern regarding the licensee's implementation of        1 IEN 84-47 involving EQ LOCA/MSLB tests on electrical terminal blocAs.
This concern is identified in paragraph 4 f(8)(c) of this report, with regard to the EEQD 15.1 documentation review by the NRC inspection team.
By {{letter dated|date=September 26, 1984|text=letter dated September 26, 1984}}, the applicant informed the staff that IENs 82-03, 82-52, 83-45 and 83-72, which are related tu equipment environmental qualification, have been addressed.      LML explicitly tracks the resolution of IENs, IEBs, and IE circulars.
The NRC inspection team evaluations with respect to each IEN are addressed under the paragraphs of this report, related to each EQF, EEQD (paragraph 4.f) and each component / equipment (paracraph 4.h)

O l   o 28 reviewed or physically inspected by the team. Also, background information pertaining to the Waterford 3 plant, in regard to IENs and IEBs, are addressed in paragraph 3 of this report.
: h. Plant Physical Inspection The NRC inspection team, with the required tagging out of operation selected equipment and components by the licensee, walked down and physically inspected approximately 24 components / equipment ior the Waterford 3 plant. The inspection team examined attributes and characteristics such as acunting configurations, orientation, interfaces, ambient environment, physical condition, and verified traceability of equipment identified in the EQF by model and serial numbers.
During the NRC walkdown inspection, the NRC inspection team identified that Potential Enforcement / Unresolved Items and Open Items described below:
i-(1) Limitorque Motor Operators, Series SMB, Okonite V-Type Taped
!                _ ,. Cable Splices        _       -    -
During the NRC walkdown inspection, motor lead splices in the
-                     above Limitorque operators were observed. (he splices were
]                     Okonite V-type taped splices. The Okonite V-type taped splice
 ;                    documentation was found in EQF EEQD 6.2/16.2; however, the file j                     did not adequately support qualification to demonstrate similarity between the type tested splices and those installed.
!                     LP&L's letter to NRC Region IV provided an additional test l                     report No, PEI-TR-82-4-29 which addresses the V-type taped i                    Okonite splice configuration installed at Waterford 3.                       This item will be evaluated during a subsequent NRC inspection.
This item is censidered an Open Item (50-382/8632-19).
l (2) UNIO No. CVC-ENTR-31A8-4C1, EFW-EMTR-38-2A, and SI-EMTR-3AB-3A,
;                     General Electric Motors (Model No.'s 5K6404AK238V and j                     5K811045C25), and Seinens-Allis Motor (Model No.113)
During the NRC walkdown inspection, cable splices to the above motors were observed. The qualification basis for these motors is NUREG 0588, Category I. The abova motor and heater connections were installed using (1) Okonite in-line butt splices; (2) Okonite V-type taped motor connection splices; and (3) Okonite bolted splices for motor heater applications.
(a) The Okonite in-line bolt splices, used for motor power connections of GE motor UNIO No. CVC-EMTR-31AB-4C1, were fully supported by documentation in the EQF, EEQD 6.2/16.2.

r 6'
* O 29 (b) The documentation for Okonite V-type taped motor connection splices, used for power connections on General Electric (GE) motors UNIO No. EFW-EMTR-38-2A, SI-EMTR-3AB-3A, were found in the EQF, EEQD 6.2/16.2, 4.3, and 4.12. However, the documentation file did not adequately support qualification to demonstrate similarity between the type tested splices and those installed.
LP&L's letter is NRC Region IV provided an additional test report No. PEI-TR-82-4-29 which addresses the V-type Okonite splice configuration installed at Wattrford 3.
This item will be evaluated during a subsequent NRC inspection (refer to paragraph 4.h(1) of this report).
This item is considered an Open Item (50-382/8632-19).
(c) Also, the Okonite bolted type splices for heater connections on GE motor UNIO No. CVC-EMTR-31AB-4C1, contained no supporting qualification documentation in the EQF. EEQD 6.2, 16.2, or 4.14. The EQF for the above G.E.
CVC charging pump motors do not adequately establish qualification because of failure to demonstrate similarity
_, ..      between the type tested nuclear qualified motor connection-splices and the Okonite bolted type taped splices installed at the Waterford 3 plant. Lack of qualification documentation in the file is considered a Potential Enforcement / Unresolved Item (50-387/8632-03).
(3) UNID No. SI-HVAAA-331A, Limitorque Motor Operators, Series SMB-2, Improper Installatio'1/ Inadequate Maintenance of Okonite V-type Taped Cable Splices During the NRC walkdown inspection, it was observed that the Okonite V-type taped cable splices on motor leads inside Limitorque operator SI-HVAAA-3'al-A were in contact with the limit switch compartment energized space heaier and that the tape had begun to deteriorate.
The licensee's letter to NRC Region IV, dated February 2, 1987, indicated that the LP&L Waterford 3 maintensnce department had performed corrective action.
This item is conside ed an Open Item and will be closed out during an NRC subset;uent inspection (50-382/8632-20).
(4) UNIO No. CB 'IPEN-316-142 and CB-EPEN 316-117, Conax Electrical Penetrations, Model No. 7320-10003-02 (a) During the NRC walkdown inspection, the team observed the outside containment penetration CB-EPEN316-142 had two small terminal blocks located at the 4 and 8 o' clock positions close to the containment wall which were unidentified. Terrinations to this penetration were made

  ;   . e 30 using these two unidentified terminal blocks. The terminal blocks observed could not be identified as to manufacturer and modei, and EQF, EQQD 15.1 did not contain documentation to demon:trate similarity between any type test and these installed components. The licensee's letter to NRC Region IV, dated February 2,1987, indicated these terminal blocks were initially installed for measuring internal tcsperature of the penetrations containing power cables, and are classified as nonsafety-related, non-EQ qualified.
LP&L shonid completely identify components by description (list, esc.) in the EQF, EEQD 15.1 to clarify what subassemulies, parts, and components to the                 .
           .              model 7320-10003-02 electrical penetrations are considered EQ qualified, as this equipment appears as only one item on the EQHL-E. LP&L should fully identify and document that these terminal blocks are not part of the penetration assembly that requires qualification. This item is considered an Open item (50-382/8632-23).
(b). During the NRC.walkdown inspection, the team also observed.
that t,"e outside containment penetrations CB-EPEN 316-117 and CB EPEM 316-142, had the polysulfone ends on the modules cracked with pieces o'I some ends missing and displayed damage. LP&L indicated during the NRC inspection that an engineering evaluation of the problem had been performed but no results or conclusion had been finalized   ;
or documerted. The licensee's letter to NRC Region IV, dated February 2,1987, provided additional information with regards to cracked polysulfone resilient seals.
LP&L's electrical penetration generic problems and resolutions had been documented on March 9, 1984, as discussed with the Conax field service engineer. This documentation is now in EQF, EEQO 15.1 and may be reviewed.
This item is considered an Open Item (50-382/8632-09).
(5) UNID No.'s ESF-IPT-6750A and CS-IDPT-5158-A, Rosemount 1153 Series A Pressure Transmitters Pressure transmitters UNID Nos. EFS-IPT-6750-A and CS-IDPT-5158-A were physically examined during the NRC plant walkdown. UNIO No. ESF-IPT-6750A had an RTV plug used as an environmental seal for the electrical conduit connection.
Replacement schedules for upgrading the RTV plug seal configuration to a Rosemount conduit seal conf!guration as tested were not found in the EQF, EEQD 8.1.
The 1icensee's letter to NRC Region IV, dated February 2, 1987,   ;
identified station modification No. 1675 currently being implemented during the Waterford 3 first refueling outage, in which qualified Rosemount No. 353C environmental conduit seals    (
l

j   0 8 I                                                              31 were replacing RTV plug seals. An LP&L walkdown inspection had been completed to confirm tne current status of installations required to implement replacement seals to station modification No. 1675.
l l                                    The EQF, EEQD 8.1 will be reviewed ist an NRC subsequent
!                                    inspection. This item is considered an Open Item l                                    (50-382/8632-14).
(6) UNID No. RC-IDPT-9116-SM8, ITT Barton, Model 763/764 Pressure Transmitters l                                    The EQF, EEQO 8.2A for ITT Barton model 763 and 764 pressure
                            ,        transmitters was examined by the NRC inspection t6am. Component RC-IDPT-9116-SM8 was physically examined during the NRC plant walkdown. An RTV environmental seal plug was used for the electrical conduit connection. Replacement schedules for i
upgrading the RTV plug seal configuration to either Namco, BIW, i
or Rosemount conduit seal configurations as tested, were not l
found in the EQF, EEQD 8.2A.
                                                           ~
l                                ~ The licensee's letter to NRC Region IV, dated February 2, 1937, 1
indicated that LP&L has recently reviewed the qualification l                                    requirements for ITT Barton model 763 and 764 pressure
;                                    transmitter installations at Waterford 3 and concluded these instruments do not require conduit seals. The analysis has been placed in the EQF.
i The LP&L analysis which demonstrates that conduit seals do not
!                                    apply will be reviewed by the NRC during a subsequent NRC l
inspection. This item is considered an Open Item (50-382/8632-15),
i                               (7) UNID No. SI-EMTR-33-3A and SI-EMTR-3AB 3A, Seinens-Allis fiF5TMotors Model 113 l
The above motors were inspected during the NRC plant walkdown and physical inspection and the follcwing deficiencies were noted:
(a) For UNID No SI-EMTR-3B-3A, the fo Ward bearing oil reservoir fill hole was not plugged as required, and ventilation covers had missing screws.
(b) For UNID No. SI-EMTR-3A8-3A, the rear ventilation screen cover was loose and no mounting screws were installed The licensee's letter to NRC Region IV, dated February 2,1987, stated that corrective actions have been performed.

  ;..E I
l                                                  32 l
The above items (a) and (b) will be reviewed during a subsequent NRCinspectionancareconsideredanOpenItem(50-382/8632-16).
(8) UNID No. CS-EMTR-38-5. Allis Chalmers Motors. Model 500P56 The above motor was inspected during the NRC plant walkdown and physical inspection, and the follow <ng deficiencies were noted:
(a) There was evidence of a slight amount of oil leakage from both m tor bearing reservoirs.
(b) The air intake filter hold down plate was not installed.
The licensee's letter to NRC Region IV. dated February 2.1987, stated that corrective actions have been performed.
Theaboveitems(a)and(b)willbereviewedduringasubsequent MRC inspection and are considered an Open Item (50-382/8632-17).
: 5. ' Exit Interview                     -       -
  - .        An exit interview was conducted on December 12, 1986, at the conclusion of the onsite inspection, with LP&L in which the scope of the inspection and findings were summarized.

V'g e
February 2.1987 To          A.R. Johnson FROM L.L. Bass M k

==SUBJECT:==
Waterford 3 SES EQ Inspection Supplemental Information on Thursday. January 22. 1987, a phone conversation was held between NRC Region IV and LP&L Nuclear Operations Engineering - Equipment 4
Qualification.
subject inspection which are to be included in the Inspection                           It R
was to the agreed  that LP&L Inspection        team.would send supplemental information on several items additional information.                   This letter is to document the transmittal of this A synopsis of the inspection items was given classifying eleven Potential Enforcement / Unresolved items and rvelve Open items. The following is sent as supplemental inforestion on these items.
Potential Enforcement / Unresolved Attachment F-1 (Borg Warner Motor Actuators) o      Summary Statement.
o Letter W3P85-3130 dated November 1. 1985.
Attachment F-2 (Steeens Allis Pump Motors) t                                                                    o       Susanary Statement.
o       Revised page 10 of EQA file Motor).                                    4.12/4.13 (Stenen Allis RFSI/LPSI Pump o        Test Report NQ890339-1.
Attachment o                F-3 (ITT Barton Sussiary Statement.
Transmitters)
;                                                                   o Engineering tvaluation. letter W3887-0218 January 29, 1987 Attachment F-4 (Okonite "Y" Type Splices on Limitorque/ General Electric /
o                   Siemens Allie Motors)
Summary Statement.
Attachment o
P-3 (Limitorque Blind Barrel splicea)
'i                                                                          Summary Statement.
o o
Scratch Memorandue, dated January 16, 1987 o        Letter to Limitorque. W3587-0300, dated January 6. 1987 Letter from Limitorque, dated January 7.1987.

          ,   Page 2 Attachciqt F-6 (Okonite Splices in Limitorque Switches) o     Susanary Statement.
Attachment F-7 (Energised Heaters in Limitorque Switch Compartment) o     Summary Statement.
Attachment F-8 (Limitorque Internal Wiring /IEN 86-03) o     Summary Statement.
Attachment F-9 (Conax Penetrations) o     Summary Statement.
Attachment F-10 (SIW Litton Connector Silicon Potting Compound) o     Summary Statement.
Iten F-11 (BTW Disconnect Assemblies) o     No Attachment, See Attachment F-10.
OPEN ITEMS Attachment 0-1 (Conax Electrical Penetrations) o     Summary Statement, o     LP&L Rekponse to IEN 84-47.
l Attachment 0-2 (Conax Electrical Penetrations / cracked polysulfone plugs).
 ,            o     Summary Statement.
o     Resolution dated March 9, 1984 l
Attachment 0-3 (Okonite SKY Cable).
o     Summary Statement.
<             Attachment 0-4 (Rosemount Tranesitters/ submergence) o     Summary Statement.
o     Fasee 3, 9, and 12 of EQA 39.3, t
i Attachment 0-5 (BIW Excore Instrumentation Coaxial cable)
 ;            o     Summary Statement.
o     Response to Question los number 12 dated December 10, 1986.
Attachment 0-6 (0konite 600Y Cable) o     Summary Statement.
!             Attachment 0-7 (Rockbeston Firewall Cables) l            o     Summary Statement.
Attachment 0-8 (Rosemount RTV Plug Seale) o     Summary Statement.
I Attachment 0-9 (ITT Barton RTV Plus Seals) o     Summary Statement.
l i
i

     / . ,a Page 3 Ites 0-10 (Siemens Allis MPSI Motor) o     No Attachm4nt 0-10, see Attachment F-6.
Ites 0-11 (Allis Chalmers Containment Spray Pump Motor) o     No Attachment 0-11, see Attachment F-6.
Attachment 0-12 (General Ateetc. Radiation Detectors) o     Summary Statement.
o     Copy of page 11 of EQA 8.3C.
Please direct any questlers you say have either on the attachments to this letter or on the NRC EQ Inspection to Lon less on (504) 467-2791 Extenstor.
327 or Rene Thibodeaux oo +'504) 467-2791   Extension 393.
1 1
A LLBtDARissf Attachments

       ?
l Attachment P-1 TECHNICAL DISCUSSION OF BORG-WARNER INSTALLATION DISCREPANCIES

==REFERENCE:==
1.)    LP&L Letter W3P85-1188, dated May 16, 1985 2.)   LP&L Letter W3P85-3130, dated November 1, 1985 Reference il provided a JCO for the Borg-Warner operators at Waterford 3. Section III of this JC0 discusses five (5) equipment anomalies which occured during qualification testing. These items are:
: 1. A coupling set screw backing off the motor shaft.
This anomaly was dispositioned in the test report                                             and JC0 as a random failure.
: 2. Improper wiring connection during test set-up.
This    anomaly was dispositioned by inspection and verification of proper installation at Waterford 3.
,               3. Failure of a solenoid valve due to chemical attack.
This failure was because a       testing lab technician failed    to   retighten a conduit connection                                         aftn correction of the motor miswiring.
: 4. Clogged filter and resulting motor / pump de-coupling.
Tilter clogging, caused by ingress of chemical spray, increased back pressure to the pump and in combination with the max, allowable misalignment created sufficient i                     forces to uncouple the coupling.
: 5. Pilot / cylinder failure.
This anomaly was attributed to installation of a                                     wrong part during manufacture of the equipment.
Items 1,   2,   and 5 were sufficiently dispositioned while items 3 and 4 required further analysis to determine applicabily to i          Waterford 3's installed configuration.
4          Reforence 2 provided further details concerning the filter clogging and the resultant motor / pump de-coupling along with the concern of moisture intrusion into the solenoid valve housing.
The following discussion provides further technical      information verifing    these concerns were addressed in         the    installed configuration at Waterford 3.
The  clogging of the hydraulic filter and resulting uncoupling of the motor and pump was attributed to ingress of chemical spray solution during LOCA/MSLB simalation,     inadequate cleaning during specimen assembly and the motor / pump being at its max. allowable tolerance.
1

t
* The solution to this concern (as discussed in reference
                            #1)   was to install a check on the hydraulic reservoir to   prevent ingress of contamination and to improve the alignment between the motor and pump. This che;X valve existed o.1 Waterford 3's actuators and the motor to
,                           pump    alignment was found to be well within the allowable     tolerances.      Additionally,     samples        of hydraulic     fluid    were    taken    and    analyzed        for contamination levels. The fluid analysis results were well    within    the recommendations       of    the        fluid manufacturer which were the values recramended by the
       ,                    equipment manufacturer.
Due   to the existing check valvs,           the         alignment inspectio      results and the results of the fluid anaylsis,     the filter clogging was not considered a concern at Waterford 3 and justified continued operation until the first refueling outage.
Moisture   intrusion into the solenoid valve        was attributed to improper      reassembly    of    the    conduit    connection         during qualification testing.
4 The design change to address this concern                  was  to install o-rings within the soleniod housing to             prevent moisture intrusion.
Waterford's      installed actuators had         RTV        potting throughout the entire conduit pathway and into the solenoid housing. This configuration was considered to provide adequate moisture sealing until the first refueling.
All   modifications necessary to make Waterford's                   installed actuators conform to the tested configuration were                 completed during Waterford's first refueling outage on SM1398.
CONCLUSION LP&L  considers    the abrve discussion to adequately address all concerns   with the Borg-Warner actuators installed at Waterford 3 and to support continued operation of the plant from November 30, 1985 to the first refueling outage.
PREPARED BY / DAT      .       esedd                      7 C. D. Somerville~   Ff        '
REVTEWED BY / DATE                           /e L' 7                      i R. P. Thibodeaux             j/
2
                                                                                   -        -  -~

I OU181 AN A / ..a m-- m P O W E R & Ll G H T / ww catsue 6ousar*=
e   .o .o .oo.
m u44ane     e too.w34e November 1, 1985                W3P85-3130 A4.05 QA Director of Nuclear React.               ,gulation Attention:         Mr. G.W. Knighton, Chief Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Coassission Washington, D.C. 20555

==SUBJECT:==
Waterford 3 SES Occket No. 50-382 Environmental Qualification -
Borg-Warner Actuators

==REFERENCE:==
LP&L Letter W3P85-1188, dated May 16, 1985

==Dear Sir:==

LP&L couaitted in the referenced letter to provide formal notification of the successful completion of the qualification of the Borg-Warner actuators. This letter provides such formal notificatien.
The Borg-Warner test specimen successfully completed the qualification cast program. An analysis pursuant to 10 CFR 50.49 has been completed, and the analysis demonstraces that the presently installed actuators are qualified for the function required. The final test report is expected to be finalized shortly, and the final test report is not expected to change significantly sinca the test program was managed by LP&L. De following provides additional information pertinent to the an.nlysis of record.
During the prior testing of the Borg-Warner test specimen actuator several equipment anomalies resulted that were determined to be uniquely attributable to the inherent elements of the test program. Subsequently, LP&L recommended several design changes to the test actuat .r design which would further enhance the environmental survivr.bility of the test specimen. n ose desigs changes were implemented for the test specimen, and included the following:
         .               o         A check valve was added to the hydraulic reservoir vent to limit ingress of chemical spray and other contaminants into the hydraulic fluids.
o         The motor / pump coupling was secured by indenting the motor l                                  shaft and adding one (1) additional set screw.
I l
i g3 l-lO$O (St )f

    .         Mr. G.W. Knighton W3P85-3130 Page 2 l
o  The solenoid valve and other electrical conduit pathways were sealed.
i o  0-rings were added to the solenoid velve assembly as a secondary seal.
,                                    o  The hydraulic filter size tas increased to reduce the potential f( c clogging.
o  All terminal blocks were removed and replaced with qualified splice materials.
The above design changes have been implemented for the installed vat.ve actuators at Waterford 3 with the exception of the pump / motor coupling / set screw, the solenoid valve o-rings, and the larger filter.
He pump / motor coupling / set screw was not implemented on the installed actuators because during the fabrication of the tast actuator, the sealing surface on the test actuator was identified as being abnormal. We specification allowed 2.005 in.                The sealing surface was within the allowable tolerance but was +.005 in. on one side and .005 in, on the other. This condition provided the neces-sary incline for the forces to decouple the coupling. The pump / motor coupling for the installed actuators has been verified to be acceptable.
The o-rings, used for secondary sealing, were not available for use during reconfiguration of the installed actuators due to the extensivs machining required to impleneat the design change. The present installs 1 actuators include conduit sealing with RTV 106 potting. Though the present configuration provides adequate moisture sealing, o-rings vill be installed at the first refueling outage.
The change to a larger filter was not implemented on the installed actuators                       ;
due to the unavailability of the part and the extensive nachining required to                      ;
implement the design change. This modification is an enhancement, and it will he installed at the first refueling outage.                                                       l This analysis mesta. the criteria of 10 CFR 50'.49, patagraph (f)(2).
1 Please feel free to contact as or Robert J. Murillo if you have any questions.
                 .W. Cook i          Nuclear Support & Licensing Manager KWc/aJMlyc1 cc              B.W. Churchill, W.M. Stevenson, R.D. Martin, J. Wilson, T. A. F11ppo              ,

bect R.S. Leddick, R.P. Barkhurst. S.A. Alleman, N.S. Carns. F.J. Dru:nmond.
T.F. Garrets, D.E. Dobson, R.M. Nelson, G.E. Wuller, R.J. Murillo, R.A. Savoie, C.D. Groome, M.J. Meisner, J.H. Houghtaling (Ebasco-W3),
G.G. Hofer (Ebasco-NY), W. A. Cross (LP&L Bethesda), J.W. Veirs (CE) .
D. Krepe (C1), P. Christofakis, Project Files Administrative Support, Licensing Library d
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g     [flL L t rter l* .HA". . . _ _ _ _ - _ _
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     *~       Attachment P-2 Siemens Allis Pump Motors Auditor was concerned about the completeness of the test report. Attached for review is test report NQ 890339-1 revision number 0, dated June 26, 1981. The attached environmental qualification assessment (EQA 4.12/4.13, page 10) for Waterford 3 HPSI/1. PSI motors has been revised to reflect this test report.
I'

     .   ,.                    REPORT NO.3   LPL-EQA-4.12/4.13 RGv. 2 a
SECTION III:   QUALIFICATION DOCUMENTATION ASSESSMENT III .1L    QUALIFICATION DOCUMENTATION

==Title:==
Equipment Qualification for Class 1E Safety Related Service in Power Generation Stations outside Containment - Form Wound Motors Report No.:   NQ-890339-1 Waterford 3 Document No.:     EEQD File 4.12/4.13, Section IV, Source:   Siemens-Allis 9
Location:   Waterford 3 I
J 10 v  r-

       .1A
       /j'
     /       . ,_
a EQUIPMENT QUALITICATIC!!
FOR CLASS lE SATETY RELATED SERVICE IN POWER GENERATION STATIONS CUTSIDE CONTAINMENT TOR.M WOUND MOTORS P UR". MAS E F.:       Ingersoll Pand Company CONSULTAN               Combustion Engineering Power Systems USER: _ Louisiana Power aad Light Co.
PLAN!:        Waterford No. 3 SIEMINS-AIJ.IS CEER NO. EL8-5117-90339-1 CUS N MT.R O CER:         P.O. No. C-573422 PFIFAFI; BY:                                               VIA:TII:, BYs NAME:       D.S)nIlle{                                     N;M_ :/Q* K,. TW
( ( e t. d %.
v LV6e TIT:,E S            pplication Engineer                    TIT:.E : Mgr. Product Sales DATE :           6/26/81                                   DATE:      6/26/81 1
DOCUMENT NO.        NO 890339-1
                                                             .                       REV. NO. O        DATE 6/26/81 i                       FOTE:   References to Seismic Analysis contained herein pertain to Seismic Analysis provided for motors furnished on drawing no. 8-5771-90203, S-A order no.
EL1-5117-47924.

r 9
INTRODUCTION IEEE 323-1974 is a general document which describes the basic requirements for the qualification of Class 1E equipment. IEEE 334-1974 is a document which specifically provides direction in demonstrating the adequacy of continuous duty Class LE electric motors located both inside and outside the containment, to perform all of their required Class 12 functions under the required service conditions.
While IEEE 334-1974 does not delineate the exact qualification requirements for Class 1E motors located outside the containment, a reasonable inter-pretation of the document indicates that qualification is provided under the provisions of paragraph 5, "Normal .7ervice Qualification Tests". This paragraph requires that the following areas be considered:
: 1)     Thermal Endurance                                                ,
: 2)     Radiation Endurance
: 3)     Seismic Qualification
: 4)     Lubricant - Bearing - Seal System As we interpret the intent cf paragraph 5, IEEE 334-1974, the treatment of the above four areas of consideration which is provided by our current qualification program will establish an adequate basis for qualification without the inclusion of full type testing.
The basic qualification program is outlined below:
: 1.      Perform analysis on moter, including vital appurtenances, to determine significant failure mechanisms and potential effects on motor Class 1E function.
: 2.      Coeparision of the asphaltic-mica insulation system having known installed thermal life characteristics with the present epoxy-nica vacuum pressure impregnated insulation system. The basis of this comparison will ba data derived from thermal life tests conducted in accordance with IEEE Standard 275-1966 (reaf f.1972) . A statement of qualified installed thermal life will be made as a result of this compari son.                                          ,
: 3.      Evaluate radiation endurance of basic materials and subassemblies used in motor construction.
: 4.      Analyze motor materials other than the main insulation system materials and, if affected by radiation exposure or thermal aging, perform required endurance testing and analyses.
: 5.      Perform seismic analysis to demonstrate seismic withstand capability per IEEE 344-1975.                                                           7
: 6.      Detemine bearing and lubri :ation life and establish maintenance and replacement schedule. Bearing and lubriaation history of older motors, together with measurements of critical characteristics, will serve sa a basis for neplacement program for bearings, if required.

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: s.                                    ,e e
TABLE E CONTENTS PACE INTRODUCTION POWER PLANT IDENTIFICATION                                                           1 1.
MOTOR FUNCTION                                                                       1 II.                                                                                    ,
MOTOR PERTOPp.ANCE SPECIFICATION                                                     1 III.
IV.      MOICR FEAWPIS                                                                      1&2 V.      E!NIRONMENTAL ' PARAMETERS                                                         2& 3 MO'IOR OPERATION RESTRICTIONS                                                         3 VI.
STATEMENT OF REQUIRED SAFETY FUNCTIONS                                                3 VII.
3 VIII.      STATEMENT OF DESIRED DESIGN LIFE IX.      TYCES AND EFFECTS OF FAILUPIS                                                    4 thru 7 A) Mechanical B)       Electrical C)       Insulation 8
X.      QUALIFICATION CRITERIA AhD FAILURE ANALYSIS A)       Preliminary Component Evaluation
: 3)       Identification and Limit of Extrapolation C)       Classification of Failures 9
XI.      OPERATING EXPERIENCE XII.      SPECIFIC QUALIFICATION                                                          10 thru 16 A) Mechanical
: 5) Electrical C)       Insulation 17 XIII.       STATEMENT OF QUALIFIED LIFE 17 XIV.      QUALIF,1 CATION RECCrADS XV.       INSPECTION, MAIN 3 NANCE AND PREVENTIVE MAINTENANCE                                 IS APPENDIX A      F. VALUATION OF IRJADIATED M01CR COMPONENTS APPENDIX 3      SEISMIC WITMSTAND CAPARILITt APPENDIX C      M RMAL LIFE CORVE - SYSTEM 1.D.4 APPENDIX D      MERMAL LIFE CURYE - SYSM M I.D.2A l
i f        .                                                                                                                                    *
                                                           ,   ---w         ,

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                                                                                                             .,,4 i
       ' A>                                                                                                     i EQUIPMINT SPECITICAT10!15 AllD E14VIRoitiLi4TAL DATA
: 2. Pot:IE PLANT 20ENTIFICATICt:
A.      FI s r.: Owner:      Louisiana. Power & Light Company B.      Fl a *. : . t.are : Waterford No. 3 C.      Geogra;nical lo:stson of plant: Taft, Louisiana i
::.  !:m; T'Ju :::':
A.      Driven equipe.ent f unc t a ct.:     Low pressure safety injection pump
: 3.      Spe:tfar Ic:a:1cr. :n plant: Auxiliary building pump room C.      Le:at:en re:stive to contair.nent:           Cutside C.      C; eras: .:        Continuous 2: . MOT   .5  FI.:JCF.''.A';;E 5 Frt:12 0AT    :!
A.       HP: 500            Service Factor:     1.15
: 5.       speed: 1800/1780 l
C.       V:2: age (in:Aude tolerance): 4000 volts 1 10% with dips to -25%
rated voltage for start.
D.       Trequency (include tolerance):            60 HZ ! 5%
E.       Trace size: 580CS8 l                         T.       WX2 (driven equipment):          851b. ft.2 G.       Torque requirements: Sufficient to accelerate to full load RPM within 8 sec. at 75% full voltage and within 4 sec. at 100% F.V.
H.       Tamperature rise 900C rise by resistance at 1.15 service factor, Actual by test - 840C rise by resistance at 1.15 service factor.
I.      Maximum ar.bient terporature:
400C IV. pKrton FIATURIs A.      anclosures        WP1 l                         S.      Bearing type & cooling: Thrust - Angular contact / oil Guide - Deep groove ball / grease 1
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                                      ,                  g
                            , ,    2 *. . MOT 0* TIATJRI! .(continued)
                   'i*                      C.                                                        0 Insulation class and insulaticn type: 7 VP1         (vacuum-pressure 0
improgr.48.<l D. Type c.       temperature detectors
  !                                                2.      Bearings:          None
: 2.      stator           Thermocouples - chromel constantan E. Surge Prete:t: : : None T.
Te rr ar.a l s
: 2. I:a : r. : Burndy-two hole
: 1. Auxiliar*. d+v::es:            Amp O. sys:e Heaters: 600 watts, 230 volts H. Te rr.inal b:x t + > l deser ptier.:
: 1.      Ma:r-       20. 5" L X 12" W X 12" D
: 2.      Aux:1: :, -        6" L X 6" W X 3.75" D
                                   ..      I:.".*:F::: 2:::A; ; A;A".: I:.1 a
A.     :::rra;
: 1.      Te ; s ra* .: . :     110 F (430C)
: 2.      Press;rt:          Atmospheric
: 3.      Atlativt Nu ad:ty:             100% maximum
: 4.      Ra dia t a ct.:    1 X 107 Cumulative
: 5. Che-1:a! Spray:           N or.4
: 6.      S t e a. . :  i::r.e
: 7.      Operating basis earthquake (0.3.I.):           See Seismic Analysis
: 3. Desigt. Basis Event           (D.B.E.)*
: 1.      Temperature: 110'F (430C)
: 2.      Pressure:          Atmospheric
: 3.      Relative Humidity:            100% maximum
                            *Although a Class B rated insulation system was ordered, a Class F rat.d system was actually furnished.
2

i-              V.       ERJIRONMINTAL F/JACTEP.5 (3 Stinu;d)
: 4. Ra dia tion :    1 X 107 Cumulativo
     ,                           5. Chemica. Spray:        None
: 6. Steam:      None
: 7. Safe shutdown earthquake (SSE):          See Seismic Analysis
                                      *2n=1ude rate of change and duration where appropriate.
C. Post DEE**
: 1. Time s     one Year
: 2. Tarperature:          0 110 7 (43 0C)
J. Pressure:        Atmospheric
: 4. nslative Hur.idity: 100% maximum            *
: 5. Radia tion'       1 X 107 Cumulative
: 6. Che.mical Spray:      None
: 7. Stea :      None
                                     **In:1ude rate of change and duration where appropriate.
VI.      M0707. 07E7AT:0:: M577:07:0::5 A. Voltage tolerances         ; lot with dips to -25%
: 3. Frequency tolerance s         j 5% at rated voltage C. Cor.bined voltage and frequency variation per NIMA standards.
!                      D. Nar.ber of starts and time between starts:            Six consecutive starts cold, hot. Ti T 3rm i      acutivestart$1rtyminuT.ebetweenadditionalstarts:
s running, t                 es not running.
E. T rust        its:
2500 lbs. up and down F. Physical orientation of equipment:             Vertical VII.      STATEMINT or RI7JIRI3 SArtit FUN 0 TIC?ts Motor must drive low pressure safety injection pump 1
necessary for safe shut down of plant.
VIII. STATEMENT or DES!PID DESIGN LIFT Wormals     Forty years
;                    Post DRE:One year 3
{

n-              w.
IX. T
_'tPES  AND ETTECTS OF TAILUKIS A. Insulation
: 1. Thermal Aging Proper operation of electrical apparatus is dependent on the integrity of the insulation system. Thermal aging of , insulation In itself, this will manif ests itself in hardening and cracking.                              I not cause a motor to f ail unless one or more of the following conditions occur subsequent tc cracking:
: a. Creepage paths are reduced to a level where dielectric breakdovn occurs,
: b. Hoisture is present on the surface and in cracks within the insulation creating shor* circuits or grounds,
: c. Excessive temperature exposures that result in a caterial phase change.
: 2. Radiation Aging Tests on motor components and systems show that accummulated dosages of ganma radiation (cobalt 60 source) have littiv or no effect at levels up to 2 x 10 8 RADS. See Appendix A for radiation endurance test report.
: 3. Relative Humidity Insulation systems can be adversely affected by the presence of moisture. With long exposure periods, noisture may be absorbed In addition, l                               into the insulation, lowering insulation resistance.
surface coatings a y increase capacitance and power factor values, There-resulting in high4c leakage currents and local hot spots.
fore, during periods of inactivity, space heaters may be utilized l
l'
                             - to decrease ralative humidity values and eliminate condensation within the motor structure.
A l

2x.      4. M:chtnical Tsilure Possible failure modes:
: a. Cracking of insulation due to coil-end motion. Causes of motion can be vibration of the coils due to improper balance of the motor or the driven machine, improper alignment of the equipment and motor, or magnetic forces caused by ecces;tric position of the rotor with respect to the stator.
: b. Breakage of coil conductors due to insufficient bracAng of the end windings and subsequent flexing of the coil ends as described in a. above.
: c. Abrasion damage to insulation system caused by motion of coil against coil or coil against a fixed me.mber, due to motion of the coil ends or of the coils within the slots.
B. Bearings
: 1. Ther=41 Operation Ot excessive temperature causes degradation of the lubricants and can caust improper clearances (thermal expansion) in anti-friction bearinos. This causes increased friction losses which produce more heat and eventual destruction of the bearing.
                                                     ^
: 2. Radiation There will be no damaging effects on bearings from radiation dosage
* 0 1evels to 2 X 10 RADS.      Radiation effects on lubricants are covered in' XII.D.
: 3. Seismic Excessive bearing loading will damage anti-friction bearing races.
This occurs whan the overloading is continuous, cyclical (vibration) or impulsive. Differing limits of maxisram permissable loedlag esist for the three conditions: see Appendia: a.
   .                                                   S

(
l
  -          IX. 4. seals                                                                                     j
           -            wear on the seals could cause oil to leak into the coil windings.
If the leak is not repaired and oil level restored premature bearing failure will re". ult.
C. Lubricants (oils and grease)
Failure of the lubricants will ultimately result in hot bearings and finally bearing failure. Lubricant failure can be caused by:
: 1. Contamination
: 2. Radiation
: 3. Temperature                                                                            ,,
D. Terminal Box (and attachment means)
The most likely failure mode for the main terminal box is loss of attachment to the motor frane. Possible mechanical da.. age to the motor leads could result in the failure of the lead insulation and cause either a short-circuit fault or an open-circuit condition in one or more phases. Either condition would req.. ire or cause the immediate shutdown of the equipment. Failures in the auxiliary terminal box could cause loss of accessory function, but would not result in loss of function of the motor proper.
E. Space Heaters Normally space heaters are not considered a vital appurtenance. The motor can perform its safety function whether the space heaters are operational or not. When motors are operated only infrequently, it                            l is good practice to have the space heaters energized during idle periods so as to minimise moisture and condensation in and around the motor windings. Open-circuit failure of the space heater can be detected by periodic maintenance checks.
4
       +                                                                                   _ _ _ . . . - . _ -

r s  ,
4 IX. F. Terminals The principal failure modes in the main lead terminals relate to the means of attaching the terminal lugs to the lead cables. Open-circuit or high resistance of the terminal lugs cause arcing and resultant heating which quickly causes failure.
Virty or improperly-tightened interfaces between motor terminal lugs and the power-supply terminal lugs represent high-resistance current paths and potential failures.
G. Kotor and Shaft
: 1. Bent shaf ts caused by sudden extreme overloads, such as seizure of driven machine or by the driven machine or coupling becoming unbalanced to the point of causing destructive motor vibrations.
: 2. Seismic force or load-induced shaf t deflection may result in the rotor momentarily rubbing the stator.
H. Auxiliary Devices This do..ument is confined to a treatment of the previous listed potential failure modes. Accessory itens are not normally considered to be vital appurtenances and necessary for the performance of the motors required safety function. Paragraph 6.2(6) of IEEE, Standard 323-1974 states that the equipment performance specification must specif-ically define any class LE requiraments involving auxiliary devices contained in the equipment or external to the equipment and required for proper operation.
I

  .* ,e X. QUALIFICATION CRITERI A AND TAILU3Z ANALYSIS A. In the preliminary component evaluation, radiation endurance was evaluated as outlined in Appendix A.
: 3. Identificatiori and Limits of Extrapolation The deterioration of electrical insulation can be treated as a chemical-rate phenomenon. A graphical plot of the log of life (hours) versus the reciprocal of tenperature ('K) results in a straight line.
1 Extrapolation may be used to predict a given property at any later time after the slope is established.
C. Classification of railures Tailures in the motor are classified as random or coenon-mode. IEEE Standard 308-1974 defines common failure mode as "A mechanism by which a single design basis event can cause redundant equipment to be inoperable." IEEE Standard 352-1975 defines common-mode failure as "Hultiple f ailure attributable to a connon cause." only coenon-mode failures are significant in qualification for class LE service. The qualification of the systems and components to be used is intended to assure that conunon-mode f ailures will not occur during the qualified life of the system. Sufficient margin will be applied to eliminate uncertainty due to engineering judgment applied to qualified life based on experience.
8

    .o ,
XI. OPEPATINO EXPTRIENCE - ASPHALTIC-MICA INf UIATED MOTORS VS. SUBJECT MOTORS To establish a qualified therr.a1 life for the class F-VPI insulation system used in the subject motor, we will offer a comparison between the class B esphaltic-mica system and the Class F-VPI system based upon the results of accelerated themal aging tests conducted in accordance with IEEE Standard 275-1966 (reaf f 1972) .
The asphaltic-mica insulation system was introduced in the late 1920's and used by all principal motor manufacturers as the premier and preferred insulation system until various electrical manufacturers introduced the synthetic resin system (Silco-Tlex, Thermalastic, et'c.) in the mid-1950's.
Tne asphaltic-mica system was also the standard insulation systen used for hydro-generators. It was the only systen available for 13.8XV.                   Users expected and received at least twenty years of thernal life from this system under con-ditions of continuous opern ion.        The systen was used by many large users of electrical aquipent to meet a requirenent for minimun design life of twenty years.
Decades of experience with the asphaltic-mica insulation system have conclusively established the absence of any coreon-mode failure when operated within design lead and ambient parameters.
i

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    .         XII. SPECITIC QUALIt'1 CATION A. Seismic Analysis (See also Appendix 3)
: 1. Determination of Rigidity The first step in sei     .cally qualifying the motor, as a component in the system, is to determine its rigidity. The motor natural frequency is determined and if the lowsst natural frequency observed is greater than 33 H:, this is generally ace sted as an indication tha*. the component is rigid. The seismic accelerations to which the motor may be exposed in-situ are applied in this component seismic analysis.
: 2. Component Analysis To assure the seismic-withstand capatility, a motor corponent must conform to an adequacy criterion assuning a predicted possible failure mode.
These corponents are deered critical by Sienens-Allis, Inc.
concerning uninterrupted operation during a seismic event.
: a. Anchorage rastener rallure
(
,                               Verification of seismic-withstand capability is based on a comparison I
i                               of the calculated bolt stresses to allowable unit stresses.
l
: b. Excessive Rotor Deflection l
Verification of rotor leismic-vithstand capability is based on the l
                              , ability of the rotor assembly to resist deflection. Analysis shows that the rotor is capable of withstanding abnormal magnetic pull forces added to seismic-induced loads.
: c. Premature searing railure Anti-friction Bearing:    If the seismic forces are less than 60 per-
{
cent of the static loso ratings, there is no persenent deforsation j
due to shock. A life expectancy calculation based on continuous l                               esposure to seismic forces indicates ao permanent deformation.
l l
10 Y

l XII. A. saismic Analysis (c ntinued)
: 2. Component Analysis (continued)
: d.        Conduit Box Detachment verification of seismic-withstand capability is based on a comparison of the calculated stresses of the supports to allowable working stressel B. Asphaltic-mica System vs. Class F vacuum Pressure impregnation (Epoxy) systa=
: 1. This paragraph addresses the consistencies between the asphaltic-mica insulated system and the present Class r inpregnated system as introduced in 1969.
Both systems use composites of rica as the primary ground wall insulation, a
The asphaltic system uses a rice paper carrier to support the mica whereas the Class F VPI systen uses a synthetic polyester and glass fabric conbination. The latter combination provides a carrier with improved thermal and mechanical stability relative to the rice paper carrier.         In the construction, or insulating of the asphaltic-mica group coils, layers of tape were applied and subsequently coated with a thermoplastic asphalt resin that was hot pressed in the slot portion to minimize voids.
In the .ase of the class r VPI insulation system, the coils are wound i
into the slots and the creplete winding assambly subjected to vacuum l
l pressure impregnation. This process consists of subjecting the assambly to a high vacuum which draws out all entrapped air and gases in the insulation systam. These voids are then filled with a solventless liquid epoxy resin by subjecting the stator to pressures several times atmospheric pressure. The assembly is baked to cure the catalysed resin, producing a solid, sealed, void-free insulation systaa.
the differences in the inherent qualities of the respective resins and carriers used in the two systems are significant. The thermoplastic asphalt resin will flow at leur temperatures than will the thermoset epoxy resin.
12              .

  ,        XII. B. Asphaltic-aica Systtm vs. Class T V cuum Pressuro Imprcgn tien (Epoxy) Systen (continued)
: 1. Under continuous operating conditions, the asphalt resin is rated 130 C by IEEE standards. The newer Cla: s r VPI system is rated 1550C by IEEE Standards.
: 2. Experience with VPI Systems Since 1969, Allis-Chalmers (now Siemens-Allis) plants at Norwood, Ohio and West Allis, Wisconsin have supplied customers with VPI insulated motors totalling in excess of ten million horsepower. The system ir rated for continuous duty at 155 0C. The effects of gamma radiation (Cobalt 60 source) on U bars insulated with the VPI system rhow that up to an aceunulated dose level of 2 x 10 8PADS, the f.iemens-Allis systen inproves slightly with respect to power factor and decreases insignificant 1y in dielectric breakdown (32KV initially to 30KV at 2 x 108 RADS on an insulation systen designed for 4160 volts).
: 3. Thermal Life Comparison As the result of thermal life tests conducted in accordance with IEEE Standard 275-1966 Iraaf f 1972), we are able to plot thermal life curves for the asphaltic-mica system (Syatam I.0.4) and the irradiated (worst case) vacuum pressure impregnated system (System I.D.2A) . These curves are included in this document as Appendix C and Appendix D respectively.
In both cases a test voltage equivalent to 37 volts per mil of insulation thickness was applied, based on line to ground voltage.
IEEE Standard 275-1966 requires the establishment of three test temperatu points for each class of insulation tested. Test temperature points selected for the Clas* 3 rated asphaltic-sica system were 1400C,150 0C and 1600C. Test temperature points selected for the class F rated VFI systems were 1800 C, 2000C, and 2100C. A total of nine forenrettes of each particular insulation system were tested at each of the appropriate
                .        test temperature levels.
12 f
!                                                                                                      I

XII. 3. Asph31 tic-cica SyStam vs. Cicss F V;cuum Pressure Impregnati n (Epoxy) System (continued)
: 3. These tests consatt of repeated cycles of thermal exposure at the above mentioned test temperature levels. Test cycle durations were twenty eight days at the loweat test tamperature, fourteen days at the middle test temperature, and seven days for the highest test tamperature for all classes of insulation. Upon completion of each cycle of thermal exposure, the formettes were exposed to mechanicai stress on a seismic shaker table, rollowing the mechanical stress test, the formettes were exposed to an atmosphere of 100 percent relative humidity.
Each formette was exposed to repeated cycles of thermal exposure, mechanical stress, and moitture in sequence until failure occerred as determined by a voltage test.      In order to check the cond* tion of the samples and determine when the end of their useful life has been reached. a 60-Hertz over-voltage was applied af ter each successive exposure to heat, mechanical stress and moisture.
The evaluation of system I.D.2A is now complete with the exception of the third point (1800 C) with five out of nine fermettes having reached the end of useful life. The test is sufficiently advanced to permit e hypothetical three point plot assuming that all formettes have failed. Additional third point test data obtained upon completion of the test will only serve to increase life as indicated by a steeper slope of the hypothetical plot. Final data for the third point of system I.D.2A should be available within six months.
Although system 1.D.2A is a Class r insulation system rated at 155 0C, the Class 3 insulation thermal rating of 130 C is0 not exceeded Ln cases of motors latended for use in Class 1E applications. Therefore, the thermal lift test curves of both system 2.D.2A and system I.D.4 may be extrapolated to the Class a thermal rating of 130 C0 (see paragraph X.B.)
and.a valid comparison of the thermal life of the two systems established.
33
                                                                                                \

XII. 3. Asphaltic-mica System Vs. Class T Vacuum Pressure Impregnation (Epoxy) System (centinued)
: 3. Thermal life data derived from a computerized regression analysis of the test dae.a indicates the thermal life of system I.D.2A to be 53,047 hours at 130 C as compared to 8,635 hours for system I.D.4 at 1300C. On this basis, we are able to establish the , thermal life of system I.D.2A to be at least 6.14 times that of system I.D,4.      Co.iple tion of the third point test for system I.D.2A will result in an incrosse of this ratio.
Conditions imposed upon the formettes during the above described tests are generally more severe than those expetienced by a motor winding under actual installed conditions. Thernal life curves are used to form a basis of corparison between a system of unknown installed life characteristics and a system whose installed life characteristics are established. The extrapolation of the thernal test curve for a particular insulation system to the a,etual operating temperature
(                          levels does not, in itself, establish a realistic upper limit of thermal life under actual installed conditions.
C. Bearings
: 1. Thermal Anti-friction bearings are applied in accordance with ATBMA Standards and are qualified on the basis of B-10 life.
: 2. Radiation i
There will be no damaging effects on bearings from radiation dosage levels through 2 x 108 RADS. Radiation effects on lubricants are covered in X11.D.
l I

                                                                                                      }
.           XII. C. Bearings (continued)
: 3. Seismic and Vibration Seismic, normal loads and bearing life are addressed in the seismic Analysis, Appendix a. Maintaining NEMA Standard vibration limits ensures against pramature bearing fatigue failure.
D. Lubricants The types of lubricants specified in the instruction manual are qualified for Class 1E service.
Angular contact anti-friction bearings are oil lubricated, the oil must be maintaineo free from contaminants, free from exposure to high temperatures, as indicated by the lubricant manufacturer, and free from exposure to radiation dosage accumulating to 2 x 10 8 RADS.*
In sny of the above cases, the oil can deteriorate and should be repla;ed.
Under normal conditions, the oil should be drained and the bearing reservoirs cleaned, if necessary, and refilled with new o41 at eighteen month intervals.
It should be noted that the maximum allowable bearing temperature is of ten lower than the maximum allowable lubricant tamperature.
Anti-friction guide bearings are grease lubricated. They should be inspected and regreased one per year under normal conditions. More frequent relubri-cation is indicated if the grease becomes contaminated with dirt or if it deteriorates because of high temperature or excessive exposure to radiation.
Regreasing should be carried out at any time the lubricant has been orposed 8
to radiatica accumulating to 2 x 10 RADS.
I. Terminal sox See seismic analysis (Appendix B)
F. Space Meaters see section IX.E
                     *Resul 4 of radiation tssting, as well as data received from lubricant suppliers,  indicatetono radiation dosages      2 asigngficant 10         deterioration of oil or greaans by AADs.
15

XII. G. Terminals A.6xiliary wiring terminals are crir.p type, selected from suppliers' published data and installed with supplier-approved tools.
M. Motor and Shaf t The rotor assembly stress and deflection analysis is covered in the seismic analysis (Appendix B).
: 1. Paint Motors supplied will be painted with an epoxy ester paint that is 8
suitable for total cunulative radiatior, doses of 2 x 10 RADS.
J. Core Plate Preliminary components evaluation proves that all core platings in use are suitable for radiation levels up to 2 x 108 RADS.
K. Seals All lubricant seals used in our motors are metallic, non-contact, frictionless type and are not subject to wear.
l 1
l 4
O lb

                  'F'*     .                                                      .    .
XIII. STATEMINT or QUALITIED LIFE As stated in paragraph XI, the installed life of asphaltic-mica insulation systems has been conservatively accepted by industry to be twenty years.
The results of out thermal life testa have established the epoxy-sica VPI insulation system (System I.D.2A) to be superior to the asphaltic-mica system (System 1.D.4) by a ratio of 6.14 to 1.      (See paragraph XII.b.3) .        q Cn this basis, the thermal life of the epoxy-mica VPI insulation system, as mathe-atically correlated to the known installet life of the asphaltic mica system becomes 122.8 years. This correlation permits the conservative establishnent of a qualified installed therral life of forty years pre-            ,
ceding a DBE plus the required post DBE period.
              .\s indicated in I!!. H and '!!. I, the des',n heat rise was 900C rise b" resistance based on a naxinum ambient terpecature of 40 C for a total temperature of 13u CC. Ine actual r13e b" resistance of the subject rotors, cy test, is 54 C0 at 1.15 service f actor and tiie actual naximun ambient in 0    Since tota'.
the installed condition is 43 C (1100 F) fo a total of 127 C.
temperature is the significant factor, the subject motors are suitable'for operation under the 43 C maximum ambient condition since a total temperature of 130"C is not exceeded.
XIV. QUALIFICATION RICORDS A. Test results B. Calculation C. Qualification Q.A. records as appropriate e

XV. INSPECTION, MAINTENANCE AND PREVENTIVE MAINTENANCE REQUIREMENTS A. Tests
: 1. Pass / fail criteria
: 2. Corrective action
: 3. Inspections
: 1. Pass / fail criteria per instruction manuals
: 2. Corrective action per instruction manuals C. Lubricant Replacement (See Section XII.D)
D. Bearing Replacement Schedule The bearings used in vertical motors are normally sized to accommodate                                       ,
the thrust values and the desired B-10 life as stated in the specifications.
In the case of the subject motors, the thrust bearing is sized on the basis of a twenty-seven year B 10 life and a maximus, thrust of 2,500 pounds up and down.      The B-10 life of the lower guide bearine is fifteen years.
b'e recommend enat all bearings be replaced at the end of their B-10 life to prevent the possibility of a common mode failure.                                      This replace-ment should be repeated, as required, throughout the forty year design life of the plant.
i k
18

im =V 4,
  ..     ,.                                                                                           l APPENDIX A
* l Abstract of Siemens-Allis Report "Evaluation of Irradiated Motor Components" l
ne safety classification of electrical equipment essential to the isolation and shutdown of the reactor in Nuclear Power Plants is t.lassified 1E. Manufacturers of equipment so classified smet qualify this equipment to accepted standards and guides.
One consideration in a qualification program is thermal life of the Arradiated insulation system. D ermal life tests, even on a accelerated basis, are of long term duration, generally 1 to 1 years.
Therefore, a preliminary evaluation of radiation endurance is necessary to determine ef fects of radiation exposure on various material s in the insulation system. This information is i.1 turn used to specify the maxim .2 radiation exposure which would result in acceptable physical parameters for use in motors. It is also used to determine radiation exposure prior to                 [
t1 srmal endurance tests on insulation system samples.
Tn:.s report is a study to optimise selection of components with respect to             l radiation exposure. Also included are tests on paints, lubricants, and                 l complete insulation systems as applied to form wound coils. Each itam tested is exposed to gamma en -(       ,.
wge levels up to 10' RADS. Testa i
are chosen to demonstrate thosa .         :v sers judged to be critical in motor operation. Results are compared to control or non-irradiated items.
Reported are the test methods, results and selection of insulation systema       . . .
for future thermal life tests.                                                  .. .
     ?                                                .-
D

Components of form wound insulation systems as presently in use at Norwood (MMD) and. West Allis (!JAD) showed improvements in dissipation facter and puncture voltages with increased radiation levels.
1,ubricants, both oils and grosses proved suitable f4r exposure to 2x108 RADS. Paints presently used on production units showed no tendency to flake at levels up to 109   RADS.
1 I
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l Appendi.x C
     -                                                                                                                                                                                                 l 100,000                                                                                                                  ,
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ADRA LT. ES_TJA s                                                                                                 C MW:---
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          ,                                                                                   .                                                                                                       (

Appendix D
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9                                                                                         .

g                                          Attachment P-3 ITT Barton Trarisaitters Model 763/764 t
Two level transmitters SP ILT 6705A and SP II.T 67058 were determined to be below the maximum postulated flood level of . 2 feet mean sea level (MSL).
The attached engineering evaluation indicates that the two transmitters, SI ILT 7145A and SI ILT 71455, which are used for Post Accident Monitoring, are at elevation -0.5 MSL and therefore not subjected to submergence.
These SI instruments are qualified and fulfill Post Accident Monitoring requirements.
Therefore, these qualified SI instruments, which are not subjected to submergence, fulfill the Post Accid 2nt monitoring requirements (see attached Engineering Evaluation for further reference).
i d

a ~
  .       j) touisiana powan ouewt coemun
         ..,u.,,;
INTER-OFFICE CORRESPONDENCE MQ      NEW nas aanna pugue esNVICS K January 29, 1987 W3B87-0218 A4.07 P2.59 QA EQ TO:          I..L. Bass TROM:       R.V. Seidl

==SUBJECT:==
Analysts of Reactor Containment Butiding Sump Level Tndication for Submergence Aceneding to the EQ inspection, the NRC does not accept the ITT Barton qualification report regarding submergence qualification. This impacts the containment sump level transmitters SP ILT 6705A and SP ILT 6705B at Waterford 3 which are approximately 5 feet below the containment flood level under an accident.
I Engineering has reviewed this in Itght of the operational use and accident function of these indicators. Although the containment sump level indication l
i is in Reg. Guide 1.97 Waterford 3 does not reference them or use them in our l               emergency operating procedures.
l l               The SIS sump level indicators SI ILT 7145A and SI ILT 71455 being in the same
!               vietnity are above the maximum postulated flood level of -1.2 feet MSL and are fully qualifted. According to operations, emergency operating proceduTem only reference maintaining containment SIS sump level.
Since the two sump measurements overlap, the SIS sump indication vill shov 50%
or 3 feet of level when the containment sump instrument begins to see flooding. Since this is well within the capability of the SIS level instruuent, the readout is satisfactory for Post Accident Monitoring.
It is therefore evaluated that the SIS susp indicator is both qualif ted and available fce Post Accident Monitoring, and it fulfills all the readout requirements, "AN EQUAL OPPORTUNITY E.* aft.0YE2"

1
      ,o .
    .      P:s> 2 W3587-0218 January 29, 1987 f t 'is recosusended that no modificatione be made to the containment sump instruments at thtJ time for Post Accident Monitoring use.
Q *4l                                                                   !
                                                       ..V. Yetd1                                                                    i RYS/j t s Attachment                                                                                                                ;
t cet     R.F. Burskt, EQ Files. Project Files. Administrative Support (2)
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LOUISlANA P O W E A fa !. I G H T "ed Page    Sof A By                        _ Date / N"f7 Checked by                                Date j @ f fisM        I"D)*CE         C                          !                       <#
* ARTMoMEW % W 'S B ti-6 >lt                                   ca1e. no.
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                                                                                                            - 2 s-
              + f.*eLA heasure me.ds                                                   gla,; ,, r su up

AttCcha:nt P-4 e
!                                            Ohonite "V" Type Splice
!                                            Our  EQ documents have been updated to include an additional test l
report       (PEI-TR-840704-1)                addressing                       the V-type               splice configuration usirg Okonite splicing material.
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i Attachment P-5 Bitnd Barrel Splices These splices were not specifically identified in Limitorque test reports.
It is the position of Waterford 3 th4t these blind barrel splices are qualified for forty (40) years. Refer to attached Scratch Memorandum dated 1/16/87 LP&L letter dated 1/6/87, and Limitorque letter dated 1/7/87 which substantiates this position.
                                               -,,.,m. ,- , ..-----__--w-----_vm-.--.e -.,

F
  .c   .
  .               P unusaAAsa powen C uewt coensassy
         , ,,, ; ,,7 INTER-OFRCE CORRESPONDENCE
                             ,)   peew omtaAAfG PUGUC 88RVICS 18sC.
January 16, 1987 SCRATCH MEMORANDUM TO:             EEQD Package 3.1 FROM:           L. L. Bass

==SUBJECT:==
Blind Barrel Splices in Dual Voltage Motor Limitorque Rive Actuators Re fe re nc e :   LP&L Letter W3887-0100 and Limitorque Corporation Response Letter (attached)
Waterford 3 has identified thirty-eight (38) Limitorque actuators utilizing dual voltage motors. All concerned actuators are out-side containment.          Eleven (11) of the thirty-eight (38) actuators were identifiei from walkdown information sheets to have the extra motor leads interconnected with the questioned blind barrel splices.             The splices in the remaining twenty-seven (27) actuators were unidenti-fiable by walkdown information.
It is Waterford 3's position that the blind barrel splices in Limitorque actuators are qualified for forty (40) years. This position is based on Test Reports 600198 and 600376A which covers Limitorque actuators that utilize dual voltags motors. The ref6tenced letters state that the actuator units tested in reports 600198 and 600376A are production units and that all production units utilizing duni voltage motors have the extra motor leads interconnected with Thomas and Betts RB-4 or RC 6 wire joint connectors. These connectors are referred to as blind barrel or pigtail splices.
6L.a. L L. L. Bass LLB/JTS/ps ces     (w/o attachment)
W. J. Hayes        C. D. Somerville. R. P. Thibodeaux. J. T. Steadman.
EQ Files (2)
                                                 "AN EQUAL OPPORTUNITY EMPLOYER"

l Louisiana P O )N.E R & L i G H T! WATEAFCAO 3 SES
* 90 BCX 8. (LLONA    ,
N9NsfsM January 6, 1987          .
                                                                                      \
W3B87-0300 A4.10 P2.58 QA Mr. Jce Drab Limitorque Corporation 5114 Woodall Road P.O. Box 11318 Lynchburg, VA      24506-1318

==Dear Mr. Drab:==

Regarding     your tele. phone conversation with   J. T. Steadman   on January 5,     please confirn the following:
1.)   The    Limitorque actuators tested       in   Qualification    Test Reports 600198 and 600376A were        production units with   dual   {
voltage motors.                                                       ;
J.)   All Limitorque actuator production units with dual voltage motors had the spare motor leads interconnected with Taomas a           and Betts RB-4 and/or RC-6 wire joint connJctors.                     ;
3.)   The time period in which the Thomas and Betts wire            joint connectors were used.
We are requesting that you restate these items when responiing.
Our telecopier number is (504) 464-3362.           Your assistance    and   i expediency in this matter is very much appreciated.                Please contact J., T. Steadman at (504) 467-2791, extension 222, if you should require additional information.
c=><. a:t. 4 -
L. L. Bass LLB/JTS/pz cc2    C. D. Somerville, W. J. Hayes, R. P. Thibodeaux, EQ Files (2),    Administrative   Support (2 ),    Project Files,   J. T.
Steadman 9
4

Eus4 645 97.% t.!NITCm e A C 3ir,                                                  et/1rt/1r? 10:55                   set O
e g                          Limitorque Corporation-.-..-s....u.............u..,_                                                                                          '
oo.Oo=tisto                          Lyncbwg, VA 245061316 M                          site wooon twod
                                                        ''''P6 "'-' '.32a.44oo .1.4 x-62. w O
e-E muo usma-3362 J
January 7, 1937 toutstana Porer & l.ight C W any Waterford 3 P. O. 804 B Kiliona, t.A 70066-0751 Attention: Mr. L. L. Bass Gentlemen:

==Subject:==
Qual Voltage Motor Sp1 fee W3897-3M A4.10 P2.58 Regarding your letter of January 6, we are pleased to provide the followirg:
: 1.                The Limitorque actua*. ors tested in C:Jaltfication l'est Reports 6001g8 and 600378A were production units with dual voltage motors.                                                                     l t
l
: 2.                Productico actuators with dual voltage rotors had the extra Ntor leads interconnected with Thomas and Betts RS.4 or RC.6 wire joint
'                                             connectors or equal.
: 3.                The above Thomas and Betts wtre joint connectors were used during the time period of the above qualification tasts and in fact are still Currently used.
Ve: y truly yours, LIMITORQUE, CORPORATION ii.G. A L,                                                                                                                                                            ;
I             J. 8. Orab                                                                                                                                                             !
Spacial Projects Engineer                                                                                                                                              !
J0:mlb                                                                   '                                                                                             i

   .o ,
Attachment P-6
* Okonite Splices in Limitorque Switches (Also includes response on Siemens                        .
Allis HPSI Motor and Allis Chalmers Containment Spray Pump Motor)                               !
The following conditions were observed during the inspection walkdown on                         ;
December 11, 1986.
i
          -     One splice was observed to be in proximi *y of heater on SI-MAAA331A valve operator.                                                                           t
          -     011 resevoir fill hole cap missing on motor SI EMTR3B-3A.
          -     Air vent intake filter grills were missing and evidence of oil leakage                    ;
observed in motor CS-EMTR-35-5.                                                           l These items were identified to Waterford 3 maintenance department on December 11. 1986. Correceive actions have been performed.                                       .
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Attachment F-7 Eneraised Heaters in Limitorque Switch Compartment _
Limitorque operators with energised heaters will be de-enetstred in accor-dance with the station modification program. The qualified life has been reevaluated for the time that the heaters were energized. Results have the qualified life remaining in excess of forty /40) years.

7 4
Attachment P-8 Limitorque Internal Wiring Upon receipt of IEN 86-03, dated January 14, 1986, Waterford 3 implimented a plan to perform inspections and work for all 64 EQ Limitorque operators on January 17, 1986.
The first point to point wire inspected was completed one day after notice issuance on January 15, 1986. The remaining valve operators were inspected during the subsequent weeks.
By the beginning of March 1986, inspections had been done on 27 valves and by the end of March, 55 operators had been inspected.
Five of the remaining nine operators were completed shortly after the March mid-cycle outage when the associated systems were being worked for other reasons.
Inspections on the remaining foi operators were completed ot: June 19, 1985. Throughout this entire program, when indeterminant wire was found.
it was replaced with documented wire on the spot in accordance under appropriate work authorization with Rockbestos SIS vire which is qualified for use in all harsh environments at Waterford 3 pursuant to EQA 6.3/6.3A.
A representative sampling of wires which were removed from the operators as a result of the inspection program where tested under simulated accident conditions. (No rewiring was required for valves inside containment, hence the test condition enveloped the outside containment accident environment.)
The test results show that the wires would have performed their individual functions had they been required for a design basis accident through June 19, 1986.
The position for Waterford 3 is that corrective action was terlemented and completed in a timely manner and that this concern is resolved.      The documents associated with the above activities are available for review upon request.

                             +
REPORT N3. 8     LPL-EQA-39.3 Rtsv. 2 III.2  QUALIFICATION DOCUMENTATION ANALY, SIS
: a. Design Basis Event Accident Analysis LOCA Simulation Profiles       Figure Number     1 Yes No* N/A
: 1. Are all peak temperature / pressure and time requirements during the tran-sient phase enveloped?                           X
: 2. Are all temperature / pressure and time requirements during the post-accident phase enveloped?                                  X
: 3. Are   margins    as    applied   consiste.$t with those defined in NUREG-0588 and/
or IEEE 323-1974, as applicable?            _X_
: 4. Are the functional tests as performed adequate to demonstrate          that the functional requirements         (accuracy,              i repeatability, insulation resistance,                   j etc.) for the equipment can be met?          X          i
: 5. Was the normal and accident radiation                    1 applied prior to and/or simultaneous-ly with the accident simulation?         If             '
yes, to what level?
2.0E8 _ rads gamma.                         X i
: 6. If submergence is a requirement, does                    i the test demonstrate acceptable oper-ation?                                               X
: 7. Was     the requirement      for   chemical spray enveloped?                             X I
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    .                                                    Attachment P-9 C,oaax Penetrations During the inspection of Conax penetrations, terminal blocks thet could not be readily identified were found in the outboard (outside containment) e .d of these penetrations.
Although   these terminal blocks are subject to elevated radiation and slightly   elevated temperature during a postulated design basis accident, they are   located in an area that is not subject to a eteam environment (with an     overpressure condition). Therefore, they are not considered to be susceptible to excessive leakage currents due to a steam e*monobare.
In addition, a review of the terminal blocks show that they are not part of any safety-related. EQ, nor IE circuits. These terminal blocks were initially installed for measuring internal temperature of penetrations containing power cables. As these non-essential terminal blocks have been
,                                                        identified to be o low voltage, low current circuits, and are not required for equipment qualification, Waterford 3 considers this concern not to be
,                                                        significant.
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1
          .                                                                                                                                                                                      I
                                                                                                                                                                                                 +
Attachment P-10 i
BIW Litton Connector Silicon Potting Compound                                                                                                                            i To address the qualification of the BIW cable assemblies and                                                                                                             l associated                                Litton connectors,                           a test report has been obtained                                                   ,
enveloping Waterford                                                3 peak LOCA temperature of 414 degrees                                                               ;
fahrenheit.                                   This test report (f 558-1654) is incorporated in                                                                           :
qualification documentation (EEQD 14.1/52.1).                                                                                                                            !
The subject equipment installed on the reactor vessel heed at                                                                                                            !
Waterford 3 are qualified for five (5) years in an environment of 175 degrees fahrenheit. Based upon :                                                                                                                                     I o         Testing performed for Litton by Isomedix,                                                                            in which the                  ;
connector assembly was aged for 15 days at 160 degrees C,                                                                                          '
and then successfully passing a LOCA exposure.
o         Testing performed by National Technical Systems (NTS) on aged Litton connector assemblies (report no. 558-1654) in accordance with IEEE 323-1974. The NTS test accident 7
profile envelopes the temperature peax at Waterford 3, providing evidence that the connectors are capable of                                                                                              !
withstanding the Waterford extremes, i
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                                                                                                   ''m A Attochrcnt 0-1 Conax Electrical Penetration The NRC inspection team identified three (3) areas of concern in equipment file 15.1. These areas were test report IPS-568 Rev. A not included in the EQ file,             IR drop position,    and response to IEN 84-47.
Based          on discussions with the NRC inspectors,     test report IPS-568 Rev. A,             which was referenced in EQ file 15.1,      has now been included.
t The IR drop position, and associated terminal block concern has been evaluated and it is the position of Waterford 3 that any error induced, during postulated plant events, by the terminal blocks contained within conax penetrations is acceptable.                             l LP&L's response to IEN 84-47 was submitted to the NRC inspectors during the inspection. Another copy is attached for review purposes, i
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                                                                                   ~
_..._____-_.___         n=====-- -
__=__       _    __        __
NON 1-E EQ EQUIPMENT WITH CIRCUIT TERMINAL BIACKS IN RCB 8 (- 19 7                                     En avu p w UNID          ve r .W     CWO            I4 CAL  PEN
* 1)    MS IFT0300 A    0 ir      1682         -
T     T            P IM
* 2)    MS ITT0300 B    DIF       1682              T     T                 ''         "
: 3)   RC IPT0110      WO         932              -     T    ,,
                                                                              .. peu f* O
: 4)   RC ITE0111 Y     V8        204              -
T          pov b%                  d4
: 5)   RC ITE0111 Y1              204              -
T                   l'       ''
I
: 6)   RC ITE0115                 204              -
T          W f * #'b
: 7)   RC ITE0115 1               204              -
T               "          "
: 8)   RC ITE0121 Y               205              T     T                l'       "
: 9)   RC ITE0121 Y1              205              T     T              In       8'
: 10) RC ITEo125                  205              T     T               't      "
: 11) RC ITE0125 1      y         205              T     T                lt D3                                                ll      t'
* 12) SI I LT0 311                 551              T     T
* 13) SI ILT0321                   557              T     T               li       4
* 14) SI ILT0331                   563              T     T                ll      lj
   '
* 15) SI ILT0341          V        569              T     T               I'      Il
: 16) SI IPSO 405 At    4         596              -
T               U b[ N
: 17) SI IP30405 A2               596              -
T
: 18) SI IPS0405 B1               591              -
T               ll 4
: 19) SI IPSO 405 B2     b        591              -
T               I'      "         i-
* 20) SI IPT0311          pj       550              T     T         *EO I
I
* 21) SI IPT0321                   556              T     T
* 22) SI IPT0331      ,
562              T     T
* 23) SI IPT0341          1r       568              T     T                   q
* Previously identified; to be spliced in Station Mod 1675 T Terminal block 2

r l
           /    -
LOUISIANA P OWE R S LIG H T / INTER-OFFICE CORRESPONDENCE NidbsYN February 3, 1987 W3B87-0222 A4.07 QA TO:        George Wuller FROM:      R.V. Seidl

==SUBJECT:==
Response to IEN 84-47 Discussion:
IEN 84-47 discusses the results of a recent NRC-sponsored environmental qualification research test conducted on electrical terminal blocks at SNL. The results of the test show that a moisture film will form on the surface of the terminal block during the simulation of the LOCA/MSLB events, and will result in the reduction of insulation resistance between terminal points and ground, and thus will allcw soue Leakage currents to flow to ground.
All safety-related instrument pretess measurement milliamp signals are installed using splices not tern nal blocks in containment. The termir.41 blocks in question are installed at Waterford 3 in Conax Penetrations, utilized in non-1E circuits, with the exception of core exit thermocouples.
Conax Test Report IPS-379 Rev. D documents the installation of these terminal blocks during qualification testing of the penetration assembly.
Additionally, Conax Test Report IPS-586 Rev. A documents successful completion of DBE testing of the Kulka terminal blocks simulating the actual installed condition for the inboard end of an electrical penetration.
A tabulation of non-lE EQ equipment with terminal blocks in contal' .ent is attached.
The value of leakage current due to moisture la unquantified, although the NUREG CR-3691 Report may be useful. The NUREG CR-3691 analysis assumes the reference junction inside containment which is not the case for Waterford 3.
It also assumed a cable routing configuration that is less conservative than the Waterford 3 design. The resulting tenperature readouts show a range of error of + 300*F using the worst case arrangement closest to Waterford 3 design. The actual Waterford 3 error is expected to be much less than this. At higher temperatures, the Thermocouple EMF increases and the error would decrease. In a post accident environment the CET reading is not an immediate operator concern, since he can't do more than he already is doing based on the readout. This measurement is used mainly for core damage assement after the accident.
                                "AN EQUAL OPPORTUNITY EMPLOYER"

W3887-0222 Pcgo 2
  ,         Fcbruary 3, 1987 There also exists the capability to measure Core Exit Temperature using the atsolute mersurement of the RVLMS or Heated junction thermocouples.
Since the required accuracy for core exist temperature is not definitive and   there vill not be exists an concern.
a safety alternate means to read the required parameter, this If you have any questions regarding this response, please contact me at extension 422.
R.V. Seid1 RVS/jtz cci L.L. Bass, Support  (2)D. Rothrock EQ Package 15.1, Project Files, Administrative I
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Attachment 0-2 Conax Electrical Penetration During che inspection valkdown, an auditor observed cracked polysulfone plugs. LP&L observed this phenomena in 1984, and persuant to the attached resolution dated March 9, 1984, this item was resolved.

9 Pag 3 1 of 2 ELECTRICAL PENETRATIONS PRosLENW & RISOLUTIONS                   March 9, 1984 Some of the generic problems highlighted in CIWA's listed in attachment No. I were discussed with "CONAX" senior field service engineer Mr.
Patrick A. Christopher on March 7 and 8,1984, and resolutions were listed below:
: 1. Cracked polyst:1fone resilient seals (referred as cracked potting in CIWA's, which is aisnamer):
Polysulfone resilient seals, which are cracked da not affect the electrical integrity and/or pressure boundary of electrical penetrations.           They are normal occurrences of plastic and no further corrections or resolutions are necessary and as is exceptable.
!                                                2. Rust in Electrical Penetration (at places such as aidlock caps, squirrel cage brackets and other conponents):
Appearance of rust does not af fect the pressure boundary and electrical integrity of Electrical Penetrations. Rust at nidlock caps is only of superficial and cosmetic appearance and rust at other components is of minor appearance and does not affect the function or integrity of elect-rical penetration. Presently no action is required. During scheduled out-age (in future) observe for any further rust formation, and if 50% of the part is rusted, recommendation is removal and cleaning of aidlock caps (or even replacement if necessary) and sandblasting and painting other parts (such as brackets, etc.)          (Note: Sandblasting and painting to be done in i                                                    paint shop and not at the penetration).
: 3. Missing or damaged Components (such as screws, nuts, washers, tie wraps.
l                                                    barrel nuts, gaskets, etc):
Replace as necessary
: 4. Light film of gray paint on connectors Light film of gray paint on stainless steel modules is not required to be removed.
: 5. Corrosion build up on terminal studs (i.e., corrosion on terminal points):
If problema are discovered during electrical tests of the systems involved, then only cleaning or replacing the affected component is recommended. If any terminals screws are badly affected then clean the terminal point and replace screve.
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Page 2 of 2
: 6. Varnish insulation (correct terminology is Kapton insulation) frayed on solid copper conductors:
No action to be taken on just visual inspection solely. If any problems discovered during electrical tests of system involved, follow the reco-meended test procedure per vendor manual.
: 7. Cable Pulling Lubricant If found, must be removed and cleaned fron'inside electrical penetration enclosures.
NOTE:                         CLEANING SOLUTION MUST NOT CONTAIN AROMATIC HYDRO CARBONS (ACETONES).
NYDRO CARBONS, CHLOR 0NATED HYDRO CARBONS, KETONES, MTK, FRION 22.
l                                           8. Penetration ground is loose on RAS side
                                                 ' lighten as required
.                                           9. Cleaning of penetration:
Clean the penetration by using vaccum blowers.                                                      Do not disassemble the penetration for clesning purposes.
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                                                                                                                        //'         S. Nayak                    <
                                               "CONAX" Nuclear Products Division                                                           LP&L Plant Engineering l
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CIWA'S ON ELECTRICAL PENETRATIONS 005520                      005660 005522                  . 005710                                           .;-
003542                       005711 005543                       005712 005544                       005713 005546                      005803 005569                      005804 005570                      005805 005573                      005828 005574                      006001 005575                      006042 005577 005581 005600 005601                          .
005611 3                         005612 005/i*
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005625                                                                                                      ;
005626 005627                                                                                                      l
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005629 ,                                                                                                    j 005630                                                                                                      ;
005631                                                                                                      .
005632                                                                                                      ,
005634                                                                                                      :
005641                                                                                                      .
005644 005646                                                                                                      l 005647

Attachment 0-3 Okonite 5KV Cable and Splice The auditor was concerned that the thermal lag analysis did           not agree with actual installation.
1          The    jacketing material on Okonite 5KV cables has been qualified by  similarity to the jacketing material on Samitel Moore cables used at Waterford 3 (EEQD 6.8). Therefore, credit can be taken for the thermal lag analysis.
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    ,                        c Attachment 0-4 Rosemount Transmitters                                          ,[
LF&L has confirmed thet no Rosemount transmitters are below the flood level of -1.2 feet uaan sea level. Refer to attached pages 3, 9, and 12 of EQA 39.3 which shows the corrected file deficiency. This information had been provided to the auditors on December 11, 1986.

REPORT NJ.:         LPL-EQA-39.3 R;v. 2
: c. Design Basis Events Accident Profiles Figure Number                           1 Source:             MSLB               X_
HELB                                                        'Y LOCA               X Operating Time:                    36                       Hours Required Radiation:                      3.3E7                       Rads Gamma (Air Equivalent)
Relative Humidity:                  100%                    Maximum Submergence:                   Yes                                No X chemical Spray:                 Yes                X              No Mode:                           Active                            X Passive Fall-Safe                                                      ,
: d. Functional Requirements                                                                          l
     .                     Accuracy               +/-0.50% __
Responst 'rina        Time constant less than or equal
* to 3.0 seconds at water velocity =
f 40 feet /second.
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REPORT N3.2           LPL-EQA-39.3 R;v. 2 DESCRIPTION OF CHANGES AND PAGES REVISED Rev.        Section          Page No.         No.             No.             Description of Change 1            All            All           Added revision page.           Renumbered Table of Contents and pages.           Changed report no. to read "Rev. 1". Changed "Water-ford III" to "Waterford 3".
1              -              -
Deleted Attachments cover page.
1     Appendix 1              -
Deleted UNIDs:             RC ITE0111 Y RC ITE0115                 RC ITE0111 Y1 RC ITE0115 1               RC ITE0121 Y RC ITE0125                 RC ITE0121 Y1 RC ITE0125 1 Added        hyphens    where   necessary   for UNICs.
1              I              6           Deleted note on qualified life outside of containment.
1            IV.3           18            Clarified section on Synergistic Efects
                                                                                                                ~
t                       1                           18            Changed "is judged" to "was determined that" 1         8,   20, 21, and 24             Corrected spelling and puctuation
                                                               ~~
1                          15,16          Reformed paragraphs
!                       1                           20            Changed "is judged" to "was determined
'                                                                 that" 1                           16            Changed "assumed to be qualified for aging-related degradation" to "qualified for" 1                           24            Reformed page so that all information would fit.
2                             9           Changed submergence           requirement  from yes to no.
2           III.2a6         12            Changed        submergence    requirement  from yes to N/A.
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                                                                       ,sttchment 0-5 BIW Excore Instrumentation Coaxial Cable                                  ,
Auditor was concerned that functional performance calculation for low voltage and low current was not included in files with reference to Tranklin test report FC 38591.
The excore neutron detector instrumentation uses SIW cable, but on       !
non-safety channels. These channels are not required for a design basis accident.                                                                 ;
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The attached resolution to tiis concern indicating the inclusion of the desired information was previt.u=4y provided to the NRC auditors during their visit.
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                                                        /ATERFORD 3 SES                     Fag 3 _ cf _
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Attachment 0-6 okonite 600V Cable, The thermal lag analysis is acceptable but should reference                                                           the test report.
The jacketing material on Okonite 600V cable has been qualified by similarity to the jacketing material on Samuel Moore cables                                                            ,
used at Waterford (EEQD 6.8). Therefore, credit can be taken for the thermal lag analysis.
The  qualification documents have also been revised                                                   to address          (
submergence.                                                                                                              l 1

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* i Attachment 0-7
;                       Rockbestos Firewall III Cables Rockbestos Firewall III cables, chemically and irradiated crosslinked are                                    f both interchangeable and are qualified for 40 years at plant worst case                                     i conditions. Full card system has been in existence and is utilized when identifying individual installations at Waterford 3.
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o Attachment 0-8 Rosemount RTV Plus Seals The replacement schedules were not included in the files. Station Modification 1675 has been completed to eliminate the use of RTV plus seals by replacement in Rosemount and Barton transmitters with qualified conduit seals as describes below.
At Waterford 3. components identified in the plant EQ list (EEQ'001 Revision 4) were inspected by walkdown to confirm that the installation was in accordance with its tested / qualified configuration. Those devices requiring a "qualified" environmental seal but not having one were sealed pursuant to Station Modification 1675 during the 1986-87 refueling outage.
The Rosemount environmental seals qualified for use at Waterford 3 are Rosemount 353C Conduit Seals (EQA 14.4). Devices which were previously sealed with RTV plug seals were resealed using a "qualified" seal.
Components which have been resealed pursuant to Station Modification 1675 are listed below.
CB-IPT-6702 SMB                                  SI-ILT-0311 CB-TPT-6702 SMC                                  SI-ILT-0321 CB-IPT-6702 SMD                                  SI-ILT-0331 ESF-IPT-6750 A                                   SI-ILT-0341 EST-IPT-6750 B                                   SI-IPT-0311 MS-IFT-0300 A                                    SI-IPT-0321 MS-IFT-0300 B                                    fI-IPT-0331
                                                                                                                                    !,I-IPT-0341

  ** , e Attachment 0-9 ITT Barton 763/764 RTV Plug Seal During the inspection, the auditors observed that file 8.2 did not contain a replacement schedule for RTV plug seals.
Upon review of the qualificatien requirements for these instruments RTV plug seals are not required. The qualification package has been addressed to clarify this item.

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Attachment 0-12 CA Radiation Detector RD-23 File 8.3C needs insertion of the Rockbestos report and the performanca data for BIW coax cable. Copy of revised page 11 of EQA 8.3C is attached for your review and resolution.

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       ., o REPORT NO.:     LPL-EQA-8.3C R;v. 1 i
SECTION III:                        QUALIFICATION DOCUMENTATION ASSESSMENT III.1          QUALIFICATION DOCUMENTATION
: a.

==Title:==
Test Report Class lE Design Qualification
(
Testing of Analog High Range Radiation Monitor (RD-23, RP-2C, RP-23 and RP-20-01)_
Report No.: E-254-960 Waterford 3 Document No.:                                EQ Package 8.3 W3 Source: Waterford 3 Location:                          Waterford 3
: b.

==Title:==
Rockbet*.os cable (Firewall III Irradiation
)
Cross-Linked Polyethylene Constructions).
Waterford 3 Document No.:                                    LPL-EQA-6.3A             ,
Source:                          Waterford 3 Location:                          Waterford 3 i
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: c.

==Title:==
BIW Coaxial Cable (Flame & Radiation 1
]
Resistant, Cross-Linked Polyethylene Construction)
!                              Waterford 3 Document No.:                                   LPL-EQA-6.6 I                              Source:                          Waterford 3 l                               Location:                          Waterford 3 i
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