ML20153E763

Insp Rept 50-395/88-01 on 880111-15.Violations Noted.Major Areas Inspected:Environ Qualification of Electrical Equipment

ML20153E763
Person / Time
Site:	Summer
Issue date:	04/22/1988
From:	Conlon T, Ruff A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20153E752	List: ML20153E750 ML20153E759 ML20153E763
References
RTR-NUREG-0588, RTR-NUREG-588 50-395-88-01, 50-395-88-1, NUDOCS 8805100095
Download: ML20153E763 (21)

See also: IR 05000395/1988001

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.y" *4 UNITED STATES

g .j NUCLEAR REGULATORY COMMISSION

o * REG!ON 11.

101 MARIETTA ST., N.W -

,,,,, ATLANTA. GEORGl#. 30323

Report No.: 50-395/88-01

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Licensee: South Carolina Electric an'd Gas Company

Columbia, SC 29218

Docket No.: 50-395 License No.: NPF-12

Facility Name: Summer

Inspection Conducted: January 11-15, 1988

Inspector: 0 kf

A. Ruff,ReactorTgpector,RegionII,

Y.n.97

Date Signed

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Team Leader ,

EQ team members and participating inspectors:

B. Levis, Region II <

C. Paulk, Region II l

C. Smith, Region II

R. Wilson, NRR

D. Brosseau, Sandia National Laboratories l

i J. Hanek, Idaho National Engineering Laboratory (INEL)  ;

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J. Stoffel, EL l

Approved b h

C E. Conlon,~ Chief

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Date Signed.

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Plant Systems Section

Division of Reactor Safety

SUMMARY

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l Scope: This special, announced inspection was in the area of Environmental

I Qualification (EQ) of Electrical Equipment. It included a review of South

Carolina Electric and Gas Company's (SCE&G) implementation of the requirements  ;

of 10 CFR 50.49 for V. C. Summer Nuclear Station (VCSNS) and an in-plant j

physical inspection of electrical equipment within the scope of 10 CFR 50.49.

Because the plant was operating, the in-plant physical was not made on

i equipment in the containment. An in containment inspection of EQ equipment

will made at some future plant outage. )

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l Environmental Qualification (EQ) for electrical equipment at VCSNS was

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initially required to meet NUREG 0588 Category II requirements. '

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l The Electrical Equipment requiring Environmental Qualification at Sumer are '

l qualified to the requirements of NUREG 0588 Category I or Category II. The NRC

l inspectors examined SCE&G's program for establishing the qualification of

equipment within the scope of 10 CFR 50.49. The program was evaluated by an

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8805100095 880502

PDR ADOCK 05000395

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examination of SCE&G's qualification documentation files, review of procedures

for controlling the EQ effort, and verification of adequacy and accuracy of the

program for maintaining the qualified status of the applicable equipment at

Summer.

Based on the inspection findings, which are discussed in the repor;, the

inspection team determined that SCE8G has implemented a program to meet the

requirements of 10 CFR 50.49 for VCSNS although some d*ficiencies were

identified.

Results: Three violations were identified: (1) Missed EQ Maintenance

Requirements, Paragraph 6; (2) Insufficient Infonnation in Qualification Files.

for Lubricants, Paragraph 13.c(1); and (3) Insulation Resistance (IR) Values for  !

Performance Characteristics Not Properly Established in Environmental Qualification

Files (EQF), Paragraphs 13.c(4) and (5).

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• S. H. Bailey, Associate, Manager Procurement Engineer

• C. W. Bowman, Manager Scheduling

• 0. S. Bradham, Director, Nuclear Plant Operations, SCE&G

• S. G. Carroll, Engineer

• R. Clary, SCE&G Manager, Nuclear Engineer

• M. W. Clonts, Manager, Modification and Contractor Services

• S. T. Crumbo, Senior Engineer

• H. I. Donnelly, Senior Licensing Engineer

• W. R. Heggins, Associate Manager Regulatory Compliance

• D. O. Hicks, Electrical Engineer

• S. R. Hunt, Nuclear Quality Control Manager

• J. S. Jordan, Engineer

• D. K. Kelly, Principal Electric Engineer

• J. C. LaBorde, Senior Er.gineer L&C I&C

• D. A. Lavigne, Manager, Materials and Procurement

• F. J. Leach, Quality Assurance Manager

• F. A. Miller, Jr. , IT&R

• G. Moffatt, Associate Manager - Nuclear Engineer, SCE&G

• D. R. Moore, Director Quality and Procurement Services

• A. A. Morris, Jr. , NCSG

• G. J. Mundy, Senior Engineering Technician

• D. Nauman, SCEG, Vice President Nuclear Operations

• J. Nesbitt, Electrical Maintenance Supervisor

• K. W. Nettles, Group Manager Technical Services

• C J. Osier, Associate Manager Maintenance Engineering

• A. M. Paglia, Manager, Nuclear Licensing

• C. A. Price, Manager Technical Oversight

• J. Proper, QA Supervisor, Operations

• M. D. Quinten, Manager, Maintenance Services

• A. R. Roun, Manager, Technical Support

• J. L. Skolds, Deputy Director, Operations and Maintenance

• G. G. Soult, Manager, OPS

• J. A. Wactor,,, Senior Electrical Engineer

• D. C. Warner, Manager, Nuclear Fuel Management

• R. J. Waselus, Electric Supervisor - Nuclear Engineer, SCE&G

• T. L. Wessner, Nuclear Engineering

• V. H. Willems, Controls System Engineering

• F. H. Zander Manager, Nuclear Technical Education and Training

Other licensee employees contacted included craftsmen, engineers,

technicians, operators, mechtnics, security force members, and office

personnel.

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Other Organizations

• J. P. Durham, Impell, Corporation, Section Manager

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• B. A. Karrasch, Impell Corporation, Division Manager l

• S. Pauly, Impell Corporation, Supervising Engineer

• T. L. Penland, Engineering and Project /GPC

• W. A. Williams, Jr., Sp2cial Assistant, Nuclear Operations - Santee Cooper

NRC Personnel and Resident Inspectors

• D. M. Verrelli, Chief, Reactor Project Branch No. 4, Region II

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• J. J. Hayes, Jr., NRR Project Manager

) *R. Prciatte, Senior Resident Inspector

• P. H4, kins, Resident Inspector

• Attended exit interview

l 2. Ex.' Interview

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The inspecMon scope and findings were summarized on January 15, 1988,

with those persons indicated in Paragraph 1. The inspector described the

areas inspected and discussed in detail the inspection findings. No

diesenting coments were re.eived from the licensee. The following new

items were identified during this inspection:

, a. Violation 50-395/88-01-01, Missed EQ Maintenarce Requirements,

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b. Unresolved item 50-395/88-01-02, Mixed Grease in Limitorque Valve

Operators, Paragraph 6.

c. Unresolved Item 50-395/88-01-03, Resolution of NCN-2852 and NCN-2661,

Paragraph 12. .

d. Violation 50-395/88-01-04, Insufficient Inform tion in Qualification

File for Lubricants, Paragraph 13.c.(1).

e. Violation 50-395/88-01-05, IR Values for Performance Charccteristics +

Not Properly Established in the EQFs, Paragraphs 13.c.(4) and (5).  ;

f. olvea item 50-395/ 88-01-06, Re-evaluation of Instrument Loop

t tracy Cr' 'ation Concerning Negative Margin, Paragraph 13.c.(9).

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'acify some material as praprietary during this

r < < . aterial is not' included in this inspection report.

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3. Lice - 5 'cevious Enforcement Matters

NRC Viokttr 95/87-30-01, Raychem splice,, kLC Unresolved Items

00-395/86 *b-w , Limitorque Wirina Qualification, and 50-?95/87-30-03,

i Ambient Temperatur? Greater than Design, are closed with this repnrt.

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These items are discussed in paragraphs 13.c.(3),13.c.(6) and 14

respectively.

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4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. Three unresolved items identified during this inspection are ,

discussed in paragraphs 6, 12, and 13.c.(9).

5. Electrical Equipment Environmental Qualification (EQ) Program and

Procedure Review

a. General

The inspectors reviewed procedures that are used to implement the

requirements of 10 CFR 50.49. Discussions of individual procedures

will be in the appropriate sections that follow. Management

Directive 31, Revision 0, defines the requirements of the EQ program

for VCSNS. ,

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, The management and staff at VCSNS have been taking actions to improve

and upgrade their EQ . program. Overall responsibility for the EQ  !

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program belongs to the Nuclear Enginecring Section of the Technical

Services Group. For the most part, the EQ program was keeping up

with industry trends; however, after a reactive itspection at VCSNS

4 in October 1987, management decided that extra effort was needed to

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stay abreast of EQ developments. Consequently, an extensive upgrade

program was initiated and the early results have been very positive.  ;

An effort as extensive as that undertaken at VCSNS would not be ,

possible without the complete backing of management and the

dedication of the staff. )

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b. Safety Evaluation Report (SER) Commi'unents

Supplement 4 (August 1982) to the VCSNS SER identified four equipment

types that were not yet qualified. Supplement 5 dated November 1982

stated that the plant could be safely operated until the first major ,

shutdown or refueling outage after June 1983 pending nualification of i

this equipment. A licensee submittal dated May 17, 1983, identified 1

one more item requiring additional documentation to support  !

quali fir.a tion. The licensee's January 31, 1985, response to Generic

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Letter 04-24 stated that qualification of all five items was l

completed.

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l c. Regulatory Guide 1.97 Eq;'ipment

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The SER for RG 1.97 was issued November 13, 1987 and received by the

licensee on November 19. The SER accepted the licensee's RG 1.97

program except for three areas requiring further action; licensee

response was required within 90 days. The licensee stated that the

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response was being prepared and would be submitted on schedule.

Except for those three areas, all other equipment required by the >

RG 1.97 SIR to be qualified was identified as qualified.

6. EQ Maintenance Program

In 1982, the Computerized History and Maintenance Program System (CHAMPS)

was established and included EQ related activities. This system contains

information on maintenance history, required preventive or surveillance

maintenance, and task sheets for maintenance. The CHA"PS system also

furnishes the EQ maintenance schedule.

EQ maintenance, in general, is input as a required maintenance and does

not, therefore, have a grace period applied. One example was found where

the grace period was applied to the lubrication of the Emergency Feed

Water Pump, MMP-0021A. The CHAMPS records show that the motor lubrication

maintenance was performed November 1984, October 1985, December 1986, and

had not been performed ',ince. The last two periods exceed the annual time

period specified in ECJ-M01-G0S0682. This is identified as Violation

50-395/88-01 01, Missed EQ Maintenance Requirements.  !

The licensee provided justificat'on to show that the motor in question  !

remained qualified and would be operable until the maintenance is next i

performed. The licensee committed to perform a review of the maintenance i

history of all EQ equipment to ensure all activities necessary to support

the qualification of equipment has been performed within the required time ,

interval.

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Review of the maintenance requirements for the Victoreen High Range

Radiation Monitors did not include sending the detector back to the vendor

at a five year frequency. Initial investigation of this apparent

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discrepancy indicated that the detector was designed for a forty year

life, but that the five year cycle was imposed in response to a vendor

suggestion. The five years could be exceeded provide the detector

! exhibited satisfactory calibrat'on rescits. Subsequently, the licensee

was informed by the vendor that the five year requirement bad.been removed

i from the technical manual in Revision F in November 1985. T(- inspectors

j were aware of the five year requiremer.ts, however, they, as well as the

licensee, were not aware of the rescinding of the requirements. The

vendor documented the change to the licensee in a letter dated January 14,

1988. It should be noted that this change was effective more than two

years ago and few licensees appear to be cognizant of the cha.ge.

A potential of mixed greases w6s identified by the licensee in 1984 and

documented in NCN-1673. The licensee was not able to provide any evidence

that NRC was informed of the issue. NCN-1673 was closed out in 1987. As

a resuit of questions regarding the mixed grease issue, the licensee did

further research and found that not all Limitorque operators that were in

a harsh environment had the grease changed out by November 15, 1985, as ,

NCR-1673 indicated. Due to finding the additional operators, the licensee ;

initiated NCN-2852-46 in January 1988, to address these particular valves / l

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operators. Also, the licensee comitted to perform a follow-up review to ,

verify that all Limitorque operators in a harsh environment have had the ,

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grease changed. This is Unresolved Item 50-395/88-01-02, Mixed Grease in '

Limitorque Valve Operators.

The results of testing prescribed in NCN-2852-46 will be required to close -

this item. The testing is scheduled to be completed prior to start-up

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after the Fall 1988 refueling outage.

As part of the enhancement program, the licensee has reviewed the

preventive maintenance tasks loaded into the CHAMPS program and compared

them to the vendor manual recommended activities. Some discrepancies were ,

discovered and the licensee committed to correcting the discrepancies and

is in the process of making the corrections.

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7. IE Information Notices (IEN)s and Bulletins (IEBs)

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Prior to June 1987, IENs and IEBs along with other industry operating

experiences were handled by the Nuclear Licensing Section. Since June

1987, these have been handled by the Nuclear Safety Section of Technical  ;

Services. The procedures governing review of these items were reviewed <

and found to be acceptable except for procedure TS-301, Revision 0,

"Industry Operating Experience Review." TS-301 did not have any -

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provisions for routing EQ related reviews to the appropriate Equipment

Qualification File (EQF). IEN sumaries for EQ related items have been

placed in the EQFs as part of the enhancement program during the past few .

months. The licensee cemitted to revise TS-301 to ensure IEN summaries

are placed into the EQFs.

The Senior Engineer, Nuclear Safety, is responsible for the handling of  !

IENs and industry experiences relating to EQ. Discussions with the Senior  ;

Engineer, Nuclear Safety, indicated that there had been no formal training i

provided. Further discussion of EQ training is in Paragraph 11.

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8. Environmental Qualification Master List

- 10 CFR 50.49(d) requires that each licensee prepare a list of electrical

equipment important to safety that is required to be environmente ly

qualified by 10 CFR 50.49. The original equipment list for VCSNS 3

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submitted to NRC in May 1983. In developing the list SCE&G determined, by i

i review of FSAR Chapters 5 througP 11 and 15, those systems and electrical

equipment required for safe shutdown and accident mitigation. These

equipment items are listed in FSAP Tables 3.11-0 and 3.11-0A. The (

equioment was then further categorized to list specific f.ational I

requirements, the required accident for which it must operate, and harsh '

. environmental conditions which could Le experience;. Those equipment

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items which are classified as Category A or B are required to be

environmentally qualified. Revisions to the list are controlled in

accordance with the plant's design control process a "' require a Saf3ty

Evaluation be performed in accordance with 10 CFR SC.M.

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To assess the completeness of the equipment list, the Safety Injection

i System was selected as the system for review. Associated flow diagrams

I (E-302-691 R7, E-302-692 R3, E-302-693 R4, and E-302-675 R4) were reviewed

to determine the system components such as motor operated valves (MOVs),

solenoid valves (S0Vs), motors, and instrumentation that are required to

bring the plant to a safe shutdown condition and which experience harsh

environmental effects of Design Basis Accidents. All equipment items

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which were identified as requiring qualification were included on the

l equipment list in FSAR Tables 3.11-0 and 3.11-0A with the excepticn of

l those equipment items which were designated by the licensee as RG 1.97

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Category D2 items. Specifically, transmitters FT-940, FT-943. FT-605A and

l FT 605B, and temperature elements ITE 606A and ITE 606B were not included

on the equipment list. These items are monitored by the operator during

accident mitigation to verify proper system operation. The licensee

stated that these items were not included on the FSAR list because the

FSAR list included only 1E equipment. The specific equipment iteras noted

above were non IE devices. However, the items, including ancillary

equipment, were environmentally qualified and equipment qualification

files existed which established their qualification. RG 1.97 equipment

appeared on another list included in Tsble 1 to Technical Requirements

Package No. TRP-17 Post Accident Monitoring System (PAMS)

Instrumentation. In addition, appropriate controls were in place such

that these environmentally qualified devices were treated as quality

related equipment. To alleviate possible confusion, however, the licensee

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agreed, as part of its EQ enhancement program to revise the %AR equipment

list to include all RG 1.97 Category 2 environmentally qualified ,

instruments. l

9. EQ Modification Program

The licensee's design control program provides controls to ensure

applicable regulatory recuirements and design bases are correctly ,

translated into specifications, drawings, procedures, and instructions to I

form a Design Change Package (DCP). The following procedures delineate

the design control measures to ensure incorporation of ?nvironmental ,

qualification considerations dt. ring the design process: l

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l Technical Services Procedure No. TS-137, P.ogram for Review and

l Maintenance of Environmental and Seismic Qualifications for Safety-

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related Systems, Revision 4.

Technical Services Procedure No. TS-129, Design Development / Design I

Package, Revisio.18. l

Technical Services Procedure No. TS-131, Design Varification,  ;

Revision 4.

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Procedure No. TS-137 requires review of new or modified equipment required

to support plant modifications to ensure the requirements of 10 CFR 50.49

are met. Responsibility for performance of these reviews has been

assigned to the Technical Services group which has cognizance of the

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engineering design program. Detailed instructions for assessment of

environmental qualification requirements have been provided in Appendix 1

of procedure TS-137. This review, performed during the design process,

documents the status of qualification to the requirements of 10 CFR 50.49

and establishes baseline qualification data.

The preparation of the Design Change Package (DCP) and the method for

verifying the adequacy of the design /modificaH on change are addressed in

procedures TS-129 and TS-131. Considerations for the effect of the design

change to 10 CFR 50.49 requirements are part of the design input. The

lead engineer is further required to determine documents affected by the

design change such as Environmental Qualification Report and EQ File

Index. These documents are listed or referenced on the Modification

Request Form (MRF). Other aspects of the design process with potential

for having an impact on the environmental qualification status of

equipment are appropriately controlled, e.g. updating of vendors technical

manual, and revising or updating the data in the CHAMPS program used for

equipment maintenance. Environmental considerations are included within

the design review process employed for verification of the design. The

verification process also includes an inspection of the installed

equipment using a Field Inspection Checklist. This inspection is intended

to (1) provide a traceable link between the equipment installed and the

equipment that was tested, and (2) verify the tictual installed

configuration relative to the as-tested equipment configuration.

The inspector reviewed two DCPs, MRF-20801, and MRF-20720, that were

implemented to meet the requirements of Regulatory Guide 1.97. Discussion

with the cognizent engineers and review of the 0:Ps revealed no

environmental qualification deficiencies.

10. EQ Equipment Replacement and Spare Parts Procurement

The licensee accepted QA program, FSAR Section 17.2.4, establishes

requirements for the inclusion of technical and QA requirements on

purchase requisitions. It further mandates that procurement documents for

spare and replacement parts of safety related structures, systems, and

components shall be subjected to controls at least equivalent to those

used for the original equipment. Technical Services procedure, TS-137,

Section 7.3.3, imposes the above administrative controls for the

procurement of material within the scope of 10 CFR 50.49, ana establishes

requirements for procurement of environmentally qualified material to be

performed in accordance with procedure TS-126, Safety-related and Quality

Related Procurement by Requisition-Interface with Nuclear Purchasing

Procedures Manual.

Technical Service procedure TS-126 delineates the administrative process

for the procurement of equipment that ensures applicable regulatory

requirements, design bases, and other technical and quality requirements,

are included on procurement documents. It provides for the classification

of structures, systems, and components in accc-dance with the guidelines

contained in procedure TS-114, Structures, Systems, an. Equipment

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Classification. The three basis classifications are safety-related (SR),

non-nuclear safety (NN), and quality related (QR). Specific guidance is

provided in Exhibit 1-3 to procedure TS-114 which addresses the

classification of equipment within the scope of Regulatory Guide 1.89,

Qualification of Class IE Equipment of Nuclear Power Plants. Quality

Assurance program requirements are dets.rmined by the classification of the

equipment / component to be procured, and are imposed on the procurement

documents in accordance with Appendix A to tvocedure TS-126.

Procurement technical requirements are developed for new procurement,

replacement-in-kind procurement, and for spares and replacement parts in

accordance with procedure TS-113, Procurement Technical Requirements

Development, Review and Processing. These technical requirements may be

imposed on the requisition package by use of (1) NP-5/SA form which states

the technical requirements and/or reference documents that contain the

requirements; or (2) NP-2A form which states the technical requirement for

"Dedication" of comercial grade procurement. A Technical Work Record

(TWR) is prepared to document the basis for dedication, and is made a part

of the procurement document record.

The dedication process for comercially procured equipment / component is

delineated in Design Guide Number PR-03. This procedure provides guidance

to the Procurement Engineering and Technical Services Staff for developing

dedication criteria for spare or replacement parts whose function could

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affect safety-related or quality related equipment or systems. Procedura l

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guidance has also been provided to these personnel for performing

(1) critical to function attributes determination, (2) equal to/better

than evaluations, and (3) on-site certifications.

Responsibilities for implementation of the procurement program for EQ

equipment has been assigaed to the Director, Quality and Procurement

Services. Within the Materials Procurement Section, the Associate

Manager, Procurement Engineering, and his staff interfaces with the

Technical Services group to ensure that design basi ~s and other applicable

regulatory requirements are not degraded during the procurement process.

Additionally, the Quality Engneering staff reviews procurement documents

to verify imposition of quality requirements, commensurate with the

, classification and end use of the mterial being procurad.

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The inspector reviewed nine purchase orders for various equipment types

and/or spare replacement parts. No EQ deficiencies were identified.

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Based on the review of the above procuremant documents and review of the

procurement program procedures, the inspector determined that licensee had

established a program that provides for the procurement of equipment

within the scope of 10 CFR 50.49.

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11. EQ Personnel Training

The licensee accepted QA program, FSAR Section 17.2, establishes

requirements for job specific technical indoctrination and training of

both onsite and offsite personnel. It further requires that the

proficiency of personnel performing quality-affecting activities be i

maintained through retraining, re-examination, and/or recertification.

The inspector conducted interviews with the Manager, Nuclear Craft

Training, and other licensee staff members and verified that both onsite

and offsite personnel had been provided training in the requirements of

VCSNS EQ program.

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Objective avidence in the form of lesson plans, attendance sheets, and

results of written examination was reviewed by the inspe. tor. Pursuant to

these reviews, the inspector determined that the Electrical and

Instrumentation and Control (I&C) personnel had been indoctrinated and

trained in tne requirements of the EQ program. Additional specialized

training such as "Raychem Basic Installer / Inspector Training Course" had

also been provided.

Discussions with licensee management revealed that a formalized training

program had not been established for indoctrination and training of

Quality Engineering, Quality Assurance, Nuclear Engineering, and

Procurement Engineering personnel. From review of objective evidence,

however. the inspector determined that EQ awareness training had been

provided to select members of the above groups. Gilbert Commonwealth

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memorandum dated August 21, 1986, from K. E. Nodland to V. C. Swnmer .

Project Personne;, described a training class that addressed equipment

qualification and appropriate design control measures. Further objective

evidence in the form of Technical Services Training forms verified that EQ

training had been provided to Procurement Engineering staff members.

After an NRC EQ inspection of October 20-23, 1987, the licensee developed

a:.d is presently implementing an "Equipment Qualification Enhancement

Prog ram. " Task 9 of this enhancement program includes activities directed

towards the prnvision of EQ training for Engineering, Procurement and QA '

personnel. Other activities address specific component training for the

craft, eg. Raychem, and the establishment of general EQ training for

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maintenance craft and QC personnel. The inspector discussed the enhanced

EQ training program with licensee management and requested information

concerning its status. The scheduled completion date for implementation

of the EQ training program for all personnel is April 1,1988. Based on

the discussions with licensee management and review of objective evidence. *

this effort appears to be on schedule.

l Within this crea inspected, no violations or deviations were identified.

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12. QA EQ Interface -

The inspector determined that the QA organization had performed audits and

surveillances of the EQ program to verify its compliance with 10 CFR 50.49

and applicable codes and standards. The report of a QA audit of the EQ

program conducted November 15, 1982 through August 12, 1983 was reviewed

by the inspector. The objective of this audit was to detennine the status

and adequacy of the licensee's effort to environmentally qJalify Class 1E

electrical equipment for the VCSNS. The audit identified deficiencies in

the implementation of the EQ program as delineated in Nuclear Engineering

Procedure NE-137 (May 21,1982). Corrective Action plans developed to -

address the identified orogrannatic deficiencies appeared adequate.

A Type II surveillance, II-15-86-CC, Class IE Equipment Qualification, was

conducted May 14-30, 1986, in the performance areas of (1) maintenance of  ;

EQ files, and (2) implementation of EQ reqairements in maintenance and i

surveillance procedures, and maintenance practices. This narrow scope in  ;

depth look at the implementation of the EQ program in the performance area ,

of maintenance covered functional responsibilities and internal / external >

organizational interfaces of the following organizations: Electrical .

Services, Procurement  !

Maintenance, Maintenance Engineering), TechnicalEngineering, Records (EQ ;

, and Chemis try. A total of sixteen findings resulted from this ,

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i surveillance. A generic problem indicative of a programmatic breakdown

was identified in the performance area of EQ Training of plant personnel.

This issue was reviewed during -the NRC EQ followup inspection of  !

October 20-23, 1987, wherein the inspection team determined that a

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contributing factor to the problem of the unqualified taped splice  :

configurations was inadequate EQ training of plant personnel. Based on  ;

review of objective evidence and discussion with licensee's QA personnel, L

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the inspector determined that developed corrective action plans

implemented for the above deficiencies appeared to have been adequate.

2 Subsequent to the NRC EQ followup inspection of October, licensee

management has reviewed their EQ program to identify progransnatic  !

j weaknesses, and have performed walkdowns of equipment that is accessible i

, during plant operation to verify that installed configuration matches the ,

1 as-tested configuration documented in the EQ file. Maintenance Special

l Instructions (MSI) were prepared and used during the equipment walkdowns. l

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The inspector determined that equipment is presently being walked down on

the basis of accessibility. However, an MSI has not yet been prepared for i

. walkdown of instrumentation circuits. In response to the inspectoi , query

i regarding this issue, licensee management committed to prepare and issue

the instrumentation MSI by February 12, 1988.

As part of the continuing EQ Enhancement program, deficiencies identified ,

by the licensee during equipment walkdowns are documented on I

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Nonconformance Notice (NCN) 2852. Disposition 42 of this NCN describes i

the nature of the deficiencies found; addresses operability of the l

equipment; and provides Justification for Continued Operation (JCO) for l

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equipment not yet inspected. Licensee's actions are in accordance with  ;

the instructions contained in Generic Letter 86-15.

The nature of the deficiencies documented on NCN-2852, (Disposition 42)

involved different equipment types and affect various systems.

Additionally, NCN-2661 was prepared to identify, document, and initiate

4 corrective actions for deficient termination of solenoids pigtails.

Corrective actions for these identified problems are still incomplete.

, Because of the broad scope of the deficiencies documented on NCNs 2852 and

2661, and licensee's ongoing effort to develop and implement a corrective ,

action plan, this issue is identified as an unresolved item. Licensee i

management has committed tu provide the NRC information concerning the

continuing resolution of the above NCNs. Pending completion of the

equipment walkdowns and NRC review of the results of licensee's

inspection, this is identified as Unresolved Item 50-395/88-01-03,

"Resolution of NCN-2852 and NCN-2661."

13. Environmental Qualification Documentation Packages and in Plant Physical

Inspection

a. Environmental Qualification Files (EQF)

South Carolina Electric and Gas Conpany's EQF are prepared and

controlled by Nuclear Engineering. The packages included a Checklist  !

to evaluate the NUREG 0588/10 CFR 50.49 Qualification Status. This r

checklist contains guidelines for evaluating the qualification

methods, margin, aging, qualification documentation, equipment

interface, etc. It contains the test reports, field verification

checklist, correspondence that support environmental qualifications,

calculations and analysis, etc. An EQF is prepared for each specific

type of qualified component designated by mcnufacturer and model that

are exposed to the same environmental service conditions.

The NRC inspectors examined some 35 EQFs for selected equipment

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types. In addition to comparing plant service condition with test

conc'itions and verifying the bases for these conditions, the

3

inspectors selectively reviewed areas, such as, required post-

accident operating time compared to the duration of time the

equipment has been demonstrated to be qualified, similarity of tested

,

equipment to that installed in the plant (e.g., insulation class,

materials of components of the equipment, tested configuration

compared to installed configuraticn, and documentation of both),

evaluation of adequacy of test conditions, aging calculations for

,

qualified life and replacement interval determination, effects of

decrease in insulation resistance on equipment performance, adequacy

i of demonstrated accuracy, evaluation of test anomalies, and

j applicability of EQ problems reported in NRC IE Information Notices

and Bulletins and their resolutions. Most of conrnents/ concerns with

these EQFs wert resolved or corrected during toe inspection. Some of

these coninents/conccens and unresolved items are discussed in the

following section c.

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b. In Plant Physical Inspection ,

The NRC inspection team physically inspected 20 qualified components

and selected field run cables. The inspection team examined ,

characteristics such as mounting configurations, orientation,

interfaces, name plate data, ambient temperature, moisture intrusion

seals, splicas, terminal blocks, internal wiring and physical

conditions.

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c. Concents on EQF and Plant Walkdown Items

(1) EQF-LU2-G13-1282 Lubricants - Grease

This file was intended to qualify the various greases used at

VCSNS. The file claimed qualification to NUREG-0588 Cat II.

Review of the file indicated that qualification by similarity to

Chevron SRI 2 could be made, however, there was no statement or

argument made in the file for qualification by similarity.

Since this file was intended to qualify the Gulf products for

the majority of uses, similarity needed to be established with -

the other lubricants that the Gulf lubricants were replacing.

This was not done at the time of inspection. In addition other ,

lubricants were not included in this package. For example, the t

Dow-Corning prcducts were omitted even though the licensee had

the information elsewhere to qualify the products.

During the course of the inspection, the licensee gathered

needed information to show similarity for the Gulf products and '

committed to putting this information into the EQF and to make

tne necessary corrections in order to bring the file into

compliance. The licensee also committed to including the I

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supporting data for Dow Corning lubricants in the appropriate l

EQF(s). The file discrepancies constitute Violation 50-395/ I

88-01-04, Insufficient Information in Qualification File for  !

Lubricants.

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(2) EQF-SW4-N01-1184-1 (Model EA-180); EQF-SW4-N01-1184-2 and

Supplemental Evaluation (Model EA-740); EQF-SW4-N01-0785 (Model

EA-180); and EQF-SW4-N01-0682, two parts (Models EA-180 and

l EA-740) - Namco Limit Switches.

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One concern was noted during review of these files. Component

identification is typically provided for the valve serviced by

the limit switches. The files do not specify how many, and

which limit switches for each valve require qualification or

i which require cable entrance seals. This information is i

j contained in the CHAMPS data base, or is developed for

replacement equipment where necessary by functional review of i

elementary diagrams. The licensee agreed to revise the EQ files l

to relate individual limit. switches to the valve and to indicate

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where seals are required. In the interim, detailed review of

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several plant walkdown cases satisfied the inspectors that the

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licensee is correctly qualifying limit switches and installing

cable entrance seals where necessary.

(3) EQF-CA7-R05-0782 (Models WCSF-N splices and NMCK termination

kits); EQF-CA7-R05-0185 (NPXV connection kits); and

EQF-CA7-R05-1185 (8.7 kV termination kits) - Raychem Splices

These files were reviewed in detail, together with licensee NCN

1. 2852, which describes licensee corrective action taken with

regard to plant. splices addressed by Violation 50-395/87-30-01

from an October 1987 inspection by NRC Region II. The

inspectors concluded that the licensee's - activities for

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inspecting existing plant splices and installing new and

replacement Raychem splices are satisfactory. Approximately 75

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Raychem splices were inspected during the plant walkdown and no

deficiencies were observed. Based on the file review, walkdown

and the licensee's inspection / replacement program, which has not

identified any splices that fall outside the acceptance criteria

of industry sponsored tests. Violation 50-395/87-30-01 is

closed.

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(4) File EQF-C05-C08-1084 - Conax Corp. Electrical Penetration

Assemblies (EPAs)

The licensee claims qualification to the requirements of

NUREG-0588, Category I, based on Conax Test Reports IPS-1089,

IPS-353.1, and IPS-1146.

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The file referenced Conax Test Report IPS-325, data sheets B

through M to establish demon: trated performance characteristics ,

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for insulation resistance (IR) vslues during exposure to DBE, i

LOCA conditions. Test Report IPS-325 did not include LOCA i

testing for qualification. The Loop Accuracy Calculation, t

VCS-0423-DC15, used an IR value for Conax EPAs and referenced

Conax Test Report IPS-1146 as supporting this value with data i

taken during LOCA testing. Test Report IPS-1146 was reviewed

4 and found to contain data for IR readings taken at ambient  !

conditions (77'F and 0 psig) and not data taken during LOCA

4 conditions.

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Both of these file discrepancies were addressed by the licensee

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and resolved. The licensee stated the correct IR data could be

found in Conax Test Report IPS-1089. Test Report 1089 was

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reviewea and found to contain acceptable data. The licensee

committed to provide the correct references in the file and in  ;

VCS-0423-DC15 Loop Accuracy Calculations.

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The use of IR values provided in the instrument loop accuracy  ;

, calculation for Ccnax EPAs was not oroperly established in the ,

i EQF. This is identified as an example of Violation 50-395/ j

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88-01-05, IR Values for Perfonnance Characteristics Not Properly

Established in the EQF.

(5) EQF-C05-D01-0782 - 0682 - D. G. O'Brien EPAs

The licensee claims qualification to the requirements of

NUREG-0588, Category I, based on D. G. O'Brien Test Reports

ER-268 and ER-252.

The loop accuracy calculation VCS-0423-DC15, uses an input

resistance from D. G. O'Brien EPAs and connectors. This was

obtained by a straight line plot of two values of resistance

with respect to temperature, 58 F and 212'F, and extrapolating >

the value during LOCA conditions. The licensee stated the

linear extrapolation was supported by the volume resistivity

curve as a function of temperature for polysulfone, which is

approaching a linear curve over +.he temperature range of

concern. A review of the referenced file, D. G. O'Brien Test

Report ER-268, indicated the 58'F data point was room

temperature prior to the start of the LOCA test. The

temperature inside the test chamber (containment side of the

EPA) was 135'F. When this data point was plotteo and

extrapolated to LOCA conditions, it gave en IR value which was -

needed as an input to the loop accuracy calculttions. The 212*F

data point was not taken at the worst condition during the LOCA

test; instead, it was obtained 10 days later during the cooldown

phase at 0 psig. The licensee stated that although no IR data

were taken during the LOCA test, the test configuration

consisted of a 0.25-amp fuse, which with a test voltage of 600

volts ac and 14 pins in the connector, would blow for an IR of

less than approximately 5.0 E+05 ohms pin to shell.

The Licensee performed instrument loop sensitivity calculations

by assigning artificial IR values of 100, 200, 500, and 800

kohms for D. G. O'Brien EPAs and connectors. The sensitivity l

calculations indicated that IR value greater than 800 kohms gave

no new accuracies which did not meet requirements (AWDNMR). The

licensee also stated the AWDNMR which result with 800 kohms IR

are at the 10th of percent range.

Penetrations and connectors used at VCSNS are similar to ones l

tested for the Duke Power Company, McGuire and Catawba stations. l

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The results are documented in D. G. O'Brien Test Report ER-252.

Similarity of this equipment and the equipment installed at

VCSNS is established by D. G. O'Brien Letter N-3333 dated

July 9, 1981. The data taken in ER-252 indicate a worst cNe IR

of 1.2 E+02 megohm (pin to pin) at 300'F, 15 psig dry steam and

2.5 megohm at 250*F, 15 psig wet steam.

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From the above information, it can be concluded that the

extrapolation methodology is providing values of IR which are

consistent or supported by Test Report ER-252 for similar

connectors under LOCA conditions. Also, the sensitivity of the

actual values provides significant room for error in the

extrapolation, assuring that the impact on safety is not

signifient. Based on the additional information presented

during the inspection, the inspector concluded the D. G. O'Brien

EPAs and connectors covered by this file meet the NUREG-0588,

Category I, requirements.

The original method used to calculate instrument loop IR

contributions for D. G. O'Brien EPAs and connectors for use in

VCS-0423-0C15, Loop Accuracy Calculations, Attachment 3, page 23

of 23 is considered to be invalid. During the course of the

audit, the Licensee providad the additional calculations

discussed above and coninitted to ccqtinue to pursue test data

which contained IR readings obtained during actual LOCA test

conditions to augment the similarity of D. G. O'Brien EPAs and

connectors. Since use of IR values provided in the initial

instrument loop accuracy calculation for D. G. O'Brien EPA's was  ;

not properly established in the EQF, this is identified as an

example of Violation 50-395/88-01-05, IR Values for Performance

Characteristics Not Properly Established in EQF.

(6) EQF-V05, -L01-0782, 0385, 0682 - Limitorque Valve Operations

The inspector reviewed the EQ file for Lim 1 torque Valve

Operators. This review substantiated the licensee position that

these operators were qualified to NUREG 0588 Category II.

The file contained a section that addressed the Licensee's

-esponse to IENs pertaining tc Limitorque Valve Operators. The ,

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Hecords for licensee's action on IEN 86-03, Potential

Deficiencies in Environmental Qualification of Limitorque Motor

Valve Operator Wiring, showed that a field inspection was made

for each environmentally qualified motor operator. The l

inspection was in accordance MSI No. 20700 and NCN 2326. Any

internal wire that could not be identified as being qualified

was replaced with qualified wire. Based on the result of the

plant walkdown inspection and a review of the licensee's actions

to resolve TEN 86-03, Unresolved Item 50-395/86-15-02,

Limitorque Wiring Qualification, is closed. ,

(7) Cable Identification and Traceability to Cable EQFs

During the plant walkdown inspection,1E circuit numbers from

field wires, and four conduit numbers were collected from the

various equipment inspected. The licensee was asked to identify

and establish qualification for tha cable using the numbers

provided.

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The licensee provided drawings for the listed conduits,

electrical circuit records for the listed circuits, bill of

material sheets, cable specifications, and EQ files. This

infonnation was adequate to show traceability and qualification

for the cables and showed the inspectors that the licensee was

able to trace and establish qualification for their field

cables.

(8) EQF-IN6-V05-0682 - Victoreen High Range Radiation Monitor

The qualification for the high range radiation monitors was

based on NUREG 0583, Category I. The plant environment was

enveloped by the test conditions. Installed equipment is

identical to the tested samples.

There were questions as to the installed (versus tested)

configuration and whether triax cabit. is used versus the tested

coax cable. The licensee provided drawings and microfilm

documents which verified that installation was completed in

accordance with Victoreen recomended proccdures since the plant

was operating this could not be verified during the walkdown.

Another EQF-C05-001-0385 referenced qualification of triax

connectors which are adapted and mated to the coax cable used on

the Victoreen. This connector is shown on the "as-built drawing

(E-215-185, sheet 9) which was in the package of historical

documentation provided. The review of this file and records

indicated that qualification was established.

(9) File VCS-0423-DC15, Instrument Loop Insulation Resistance

Calculations

The preliminary file of instrument loop accuracy calculations

for Class 1E instrument loops in harsh environments was

reviewed. The analysis provides a review, on an individual

instrument loop basis, of IR affects from cabling, connectors,

and field splices. Generally, the approach and format are very

good. All calculations were summarized in individual example IR

calculation packages in Appendix H of the file, identified as

follows:

IR Error - Transmitter Loop VCS-0423-DC13

IR Error - RTD Loop VCS-0423-DC17

IR Error - In-core Thermo-

couple Loop VCS-0423-DC18

Neutron Flux Monitoring loop

Accuracy Including IR Losses VCS-0423-DC20

Loop Error - Victoreen High

Range Monitor VCS-0423-DC21

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j Other appendices in the file provided a tabulation of the ,

- safety-related equipment located in harsh environments; a

' tabulation of the circuits for those instruments with-locations,

temperatures, cable length!, and connector / splice

identification; a compilation of temperature /IR data for the

cables, connectors, splices, and terminal blocks by bill of

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< material and circuit location; and a listing of instrument

accuracy ' requirements for both inside and outside the harsh-

environment locations. These data were used, in conjunction

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with the calculation procedures above, to derive IR error

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calculations for each instrument loop. Appendices E and F

summarized the IR errors, total loop error, maximum allowable

error, and remaining margin. Though IR error effects are

directional, for conservatism this calculation provided a

non-directional error analysis. The detailed calculations are

! given in Appendix G.  !

Some of the items discussed are as follows:

(a) Unidentified terminal blocks appeared to be associated with

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the in-core thermocouples outside containment, with no

model, tag gumbers, or EQ file reference. A "conservative * ,

value of 10 ohms IR was assumed for these terminal blocks. .

The licensee response was that these terminal blocks are l

Kulka Model JN091679-02 qualified as part of the in-core

thermocouple assemblies per EQF-C05-C08-1084. Since these ,

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are only associated with thermocouples, and the assumed IR i

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value was 45% of the "worst case" data of similar terminal  !

} blocks by four other vendors, this item was resolved,

j (b) The document concluded that "positive margins remain for  ;

the instrumentation required to be operational in a harsh

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envi ronment." In Appendix F and G, many instances of

negative margins were noted. Appendix F noted that "the

margin may be positive or negative" with no explanation.

Already mentioned at'ove was that the calculation was to

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provide a more conservative non-directional analysis. The

i licensee responded thit many of the hcgative margin results

i are being "re-evaluated" with respect to allowable errors

and excess conservatism that resulted from ignoring the

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directional nature of the input data errors. Additionally,

the licensee deemed a number of the "maximum ellowable

error" results inappropriate or overly conservative and are

i in the process of reevaluating the allowable errors.

Generally, the approach in the file is good, much has been

> done tc address instrument loop accuracy, and the licensee

comitted to a continuing effort to address the

i deficiencies in the analysis and to finalize the document.

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This issue was left as an Unresolved item 50-395/88-01-06,

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Re-evaluation of Instrument Loop Accuracy Calculations

Concerning Negative Margin.

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(c) A question was posed as to whether the lowest irs taken

during LOCA conditions were always used as the input value

for "test resistarce". The licensee response was that i

either the lowest value was used or, where data was

lacking, a conservative analysis was used to input

appropriate IR effects.

(d) In conjunction with the review of the D. G. O'Brien file,

it was discovered that the IR value inputs for the D.- G.

O'Brien connectors were extrapolations from a linear curve

derived from the data points, one taken at 58'F (0 psig)

and the other taken "post-LOCA" at 212'F and 0 psig. It

was pointed out that values were not taken during the LOCA

test and that the method of linearizing irs versus

temperature, disregarding pressure and potential moisture

intrusion effects, was not considered valid. This was .

addressed as part of the D. G. O'Brien qualification file

review, which is discussed elsewhere in the report. The

licensee was eventually able to produce additional data

that substantiate the values used in the IR calculations  !

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for this file.

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(10) EQF-CA4-502-0682 Samuel Moore Instrument Cable, File l

The qualification basis is NUREG 0588, Category I. An  :

acceptable similarity analysis was provided in the supplemental  ;

evaluation for the tested cable. An extensive justification was  ;

provided explaining testing deviations from IEEE 323-1974,

stating that testing was done in accordance with IEEE 383-1974.

The plants environmental and accident conditions were enveloped

by the test profiles with acceptable margins. The supplemental

evaluation provided a good discussion of gama/ beta radiation

dose requirements and justification of beta shielding and gamma

plus data compard ions. Insulation resistance readings were

taken before, after, and during the LOCA simulation. In

addition, another 70 day extended exposure was conducted to

further verify successful qualification of the samples.

Questions were raised concerning the IR values used in the

instrument loop accuracy evaluations and the specific document

that provied this analysis. The licensee provide the needed

information. Based on this review it was considered that the

cable is qualified.

(11) EQF-CA4-820-0682 Brand Rex Coaxial Type Cable 2/c Twinax

The qualification basis is NUREG 0588, Category I. Acceptable

cable performance (IR) was monitored and demonstrated during

this test. The licensee's cables were purchased for low voltage

use in the acoustic leak monitoring system. An adequate

similarity analysis was provided, perfo-mance requirements were

defined and met, and the plant environmental requirements were

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enveloped for the tested cable. An analysis of gamma plus beta

exposure was provided, taking credit for 50% beta reduction for

c6ble tray / conduit shielding. The test cable samples were

exposed to 200 megarads gamma. The qualified life is 40 years ,

at 70*C, with aging of 7 days at 136*C. Questions were posed

regarding a "General Note 42" and the administrative control of  !

cable supplies to preclude use in voltage applications in excess

of the stated limitations. The note was from the NilREG 0588

reviews and will be added to the file. Administrative control of

cable use was established; however, it was recommended to

clearly flag and identify at the front of the file the specific

voltage limitations of these cables to help preclude inadvertent

misapplication. No findings were identified.

14. Unresolved Item 50-395/87-30-03

To address the NRC concerns expressed in Unresolved Item 87-30-03, Ambient

Temperature Greater Than Design, SCE&G investigated the cause of the high

temperatt.res noted ir, the East and West penetration areas and calculated '

the affect of the higher temperatures on the qualified lives of EQ

equipment located in those area, and then took measures to prevent

The licensee determined that higher than design

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reoccurrence.

temperatures were experienced in these areas due to personnel securing

HVAC fans in order to help control the pressure in the feedwater Isolation

Valve Nitrogen Accumulator Tanks. The licensee then performed a test to  ;

determine the maximum temperatures which could be experienced in these *

areas. The results from these measurements, with some applied

conservatisms were used to recalculate the qualified lives of affected

equipment items. The calculation, documented in Disposition 44 to

NCN 2852 dated January 13, 1988, and Gilbert Letter CGGS-36887 dated

January 8, 1988, shows that although the qualified lives for some

components had been reduced, none had been exceeded. Where required, the

replacement date for some equipment was changed as appropriate. To

prevent this condition from reoccurring the Manager of Nuclear Engineering

issued a memorandum, CGSS: 20673, File 16:0020 dated January 10, 1988,

stating that the necessary HVAC components be run on a continuous basis i

and providing actions to be taken if operational or maintenance concers

preclude the normal operation of the equipment. This unresolved item is t

clostd.  !

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