ML20151W171

Insp Rept 50-354/88-03 on 880126-29.Violation Noted.Major Areas Inspected:Licensee Environ Qualification Program & Licensee Response & Resolutions to Equipment Concerns Identified in SER

ML20151W171
Person / Time
Site:	Hope Creek
Issue date:	04/09/1988
From:	Anderson C, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151W163	List: ML20151W159 ML20151W166 ML20151W171
References
50-354-88-03, 50-354-88-3, IEIN-83-72, IEIN-84-44, IEIN-84-57, IEIN-85-039, IEIN-85-040, IEIN-85-052, IEIN-85-39, IEIN-85-40, IEIN-85-52, IEIN-86-003, IEIN-86-053, IEIN-86-3, IEIN-86-53, NUDOCS 8805030316
Download: ML20151W171 (15)

See also: IR 05000354/1988003

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-354/88-03

Docket No. 50-354

License No. NPF-57 Priority - Category C

Licensee: Public Service Electric & Gas Company

P.O. Box 236

Hancocks Bridge, New Jersey 08038

Facility Name: Hope Creek Unit 1 Nuclear Power Plant

Inspection At: Hope Creek Unit 1

Inspection Conducted: January 26-29, 1988

Inspectors: //h U/-2 /

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R.J~. f aolino, Senior Reactor Engineer PSS/EB

Other Participants and Contributors to the report include:

D. Brousseau, Consultant - Sandia National Laboratory

R. Carpenter, Consultant - Idaho National Engineering Laboratory

A. Finkel, Senior Reactor Engineer - OPS /RI

R. Moist, Equipment Qualification and Test Engineer - NRR/HQ

R. Vanderbeek, Consultant - Idaho National Engineering Laboratory

Approved by: . . /

C.J. AKderson, Chief, Plant Systems date

Section - EB/0RS

Inspection Summary: Inspection on January 26-29, 1988 (Inspection Report

Number 50-354/88-03)

Areas Inspected: Announced inspection to: 1) review licensee's Environmental

Qualification Program and verify its implementation in accordance with

10 CFR 50.49 requirements for maintaining the qualification status of

electrical equipment in a harsh environment; 2) review licensee's response

and resolutions to equipment concerns identified in the NRC Safety Evaluation

Report; and, 3) verification of installed configuration for EQ electricat

equipment selected from EQ Master List.

'805030316

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PDR ADOCK 05000354

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Results: The licensee's EQ program was examined in detail and found to be in

compliance with the requirements of 10 CFR 50.49 except for certain

deficiencies identified as follows:

a) EQ files (J-313, J-601 and E-171) were identified with whiteout and changes

that were not initialed or dated by person making the changes as required

by procedure No. VPN-NSP-07, section 8.2.1. This item is a violation

of 10 CFR 50, Appendix B, Criterion V.

b) Files are identified by purchase order numbers, making them dif ficult to

audit since the EQ files contain unrelated items purchased on that

particular purchase order. Qualification support data is lumped into the

one file and are not segregated according to application. This item is

unresolved pending NRC review of licensee corrective action.

c) Dirt and debris was identified in junction boxes. This item is

unresolved, pending NRC review of licensee determination of extent of

problems.

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DETAILS

1.0. Persons Contacted

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1^.1 Public Service Electric & Gas Company

E. Addill, Electrical Planner

R. Beard, Procurement Engineering S'upervisor .:

P. Benini, Principal Engineer

P. Blum,~ Observer ,,

• J.T. Boettger, Assistant Vice President '

• R.H. Burricelli, General Manager Engineering and Plant Betterment

• R. Donges, Licensing Engineer

• J. Duffy, Senior Engineer

R. Fein, Procurement Engineer

J. Fisher, Station QA.-Supervisor

• S.F. Hilditch, Jr; Senior-Staff QA Enginee'r

• C.W. Lambert, Nuclear Engineering Sciences Manager

• S. La_Bruna, General Manager Hope Creek Station i

M. La Vecchia, Principal QA Engineer

R. Leach, Electrical Planner

• L.K. Miller, Manager Nuclear Engineering Services

• W.E. Mokuid, Senior Maintenance Supervisor '

• I. Nag, Senior Staff Engineer

B.A. Preston, Manager Licensing and Reliability

L.A. Reiter, General Manager Licensing and Reliability ,

M. Rosensweig, Manager QA Engineering and Procurement '

• J. Rucki, I&C Systems Engineer - Electrical ,

, R.J. Smith, EQ Engineer

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M. Sullivan, I&C Group Leader

J. Thompson, Systems Engineer  ;

• F.Y. Thomson, Principal Engineer

• D.J. Vito, Senior Licensing Engineer  ;

M. Woloski, Senior Staff Engineer [

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1.2 Consultants [

j * K.L. Bar, Asta Engineering

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• J. Bruce, Asta Engineering

j' * D.P. Ganguly, Asta Engineering

• J. Lariviere, Proto-Power Corporation

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' U.S. Nuclear Regulatory Commission

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• R.W. Borchardt, Senior Resident Inspector

• C.J. Anderson, Chief, Plant System Section - EB/DRS

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' * Denotes personnel present at exit meeting of January 29, 1988.

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2.0 Purpose

The purpose of this inspection was: 1) to review the licensee's

implementation of a program to meet the requirements of 10 CFR 50.49 for

the Hope Creek Unit 1 facility; 2) to review licensee's response to NRC's

Safety Evaluation; and, 3) verify component installed configuration of

specific EQ equipment selected from the Master List.

3.0 Background

In February 1980, the NRC asked near-term operating license (0L) applicants

to review and evaluate the environmental qualification of each item of

safety-related electrical equipment and to identify the degree to which

their qualification programs were in compliance with the staff positions

discussed in NUREG-0588.

A final rule on environmental qualification of electrical equipment

important to safety for Nuclear Power Plants became effective on

February 22, 1983. This rule, 10 CFR 50.49, specifies the requirements

to be met for demonstrating the environmental qualification of electrical

equipment important to safety located in a harsh environment. In ,

conformance with 10 CFR 50.49, electrical equipment for Hope Creek may be

qualified according to the criteria specified in Category II of NUREG-0588.

To document the degree to which the environmental program complies with

the NRC environmental qualification requirements and criteria, the licensee

provided equipment qualification information in letters dated June ?S,

July 29 and 31, August 15, and December 5,1985; and, January 7,

February 25, and March 26 and 31, 1986 to supplement the information in

FSAR Section 3.11.

In letters dated February 25, March 26 and 31,1986, the licensee stated

that all equipment within the scope of 10 CFR 50.49 was qualified except

for 53 transmitters included in the harsh environment qualification

program. These transmitters were replaced with qualified transmitters

before initial criticality.

On July 15-18, 1985, the NRC staff with assistance from contract personnel

conducted an audit of qualification documentation and equipment installed

in the plant.

On the basis of the results of the above review, the NRC staf f concluded

that the licensee's program was acceptable for plant startup.

4.0 E0 Program

The Hope Creek EQ program was begun by Bechtel Power Carporation and has

since been transferred to the Engineering and Construction Department of

PSE&G. The EQ responsibility lies with the Controls and Electrical

Division under the guidance of a Principal Engineer.

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Nuclear Procedure Number VPN-EDP-04 describes the primary requirements and

responsibilities for the establishment and implementation of the Nuclear

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Departmental Environmental Qualification (EQ) Program. The General

Manager, Engineering and Plant Betterment, has overall responsibility for

policy relating to the EQ program and to provide engineering support

for- equipment qualification activities. The Assistant General Manager,

Project Engineering provides direction for maintenance of EQ equipment,

performs evaluations and analyses, and establishes engineering methods

relating to equipment qualification. The basic functions involved in the

EQ program include: a) identification of equipment subject to 10 CFR

50.49 requirements; b) verifying and documenting qualification of the

identified EQ equipment; and, c) ensuring that equipment qualification

guidelines have been provided and are followed to maintain the

qualification of EQ identified equipment.

The approach taken by the licensee takes into consideration the complexities

of the system interaction and the resulting affects on associated equip-

ment. The Systems Analysis Group (SAG) under the Assistant General

Manager, Project Engineering is responsible for determining which

equipment requires qualification.and provides the working interface

between Engineering and Plant Betterment, Systems Engineers and respon-

sible station departments in matters involving the EQ program.

The inspector reviewed the foregoing program and associated documents

to verify that the program is comprehensive, controlled and meets the

intent of 10 CFR 50.49.

Control documents established for maintaining and implementing the

environmental qualification program include: 1) VPN-EDP-02 Design Change

Control; 2) VPN-PLP-06, Nuclear Department Maintenance; 3) VPN-EDP-06,

Engineering Support Activities; 4) VPN-MSP-07, Records Management; and,

5) Hope Creek Generating Station Environmental Qualification Summary

Report.

Within the scope of the above review, no deficiencies were identified.

5.0 EQ Master List

10 CFR 50.49(d) requires that a licensee operating a nuclear power plant

prepare a list of electrical equipment important to safety with

l supporting documentation on file. Licensee Procedure No. VPN-EOP-04

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defines the Environmental Qualification Master List in general terms and

assigns overall responsibility for development, maintaining and control

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to the Systems Analysis Group (SAG).

Types of equipment specifically subject to the EQ Master List include:

< * Safety related electrical equipment located in a harsh environment

that is required to mitigate the accident which caused the harsh

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environment.

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Safety related electrical equipment located in a hirsh environment

that is not required to operate, but whose misoperation could have a

deleterious effect on the mitigation of the accident which caused

the harsh environment.

• Safety related electrical equipment, although not renuired to

mitigate the accident, whose malfunction could misicad the operator

and result in inappropriate actions.

Post-accident monitoring equipment used tc assess accident severity

and plant conditions during and after the accident.

• Safety related electrical equipment located in a harsh environment

which is required to operate in order to implement an Emergency

Operating Procedures.

Hope Creek has established a comprehensive, systematic program for

identifying electrical equipment required to be environmentally qualified.

Reviews /walkdowns have been conducted on a room-by-room basis. Components

whose failure would prevent attainment of the safety function objectives

were identified and placed on the Master List. Component classification

was based on the FSAR, P&ID's, System Descriptions, Logic / Loop Drawings

and Electrical Diagrams.

As a validation check of the Master List, the NRC inspector selected

several items of electrical equipment required to be used with the emer-

gency operating procedures for a loss-of-coolant accident (LOCA) and

verified that they were all on the Master List or they were exempt for

valid reasons. Based on the above review, no deficiencies were identified.

6.0 EQ Procurement Program / Spare Parts and Replacement Control

VPN-PRP-01, Revision 2, establishes requirements and responsibilities

regarding the Nuclear Department procurement control process. This

procedure applies to all activities by Nuclear Department personnel

involved in the initiation of purchase requirements, classification of

items, and control of the procurement process for obtaining EQ

equipment.

The NRC inspector reviewed the following procedures relating to the

procurement srocess.

• GM3-EMP-011 Revision 0, Item Classification Guidelines.

• GMS-EMP-013 Revision 1, Nuclear Department Purchase Requisition

Processing.

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DE-AP-ZZ-0016(Q) Revision 0, Procurement Classification Guidelines

(draft).

• Site Engineering Instruction 3G-Revision 1 - Hope Creek spare parts

quality determination.

SA-AP.ZZ-019(Q) - Revision 1 - Station Materials Procurement and

Control Program.

• QAP-4-1-Revision 6 - Receiving Inspection.

QAP-3-1-Revision 6 - QA Planning for Procurements.

The inspector reviewed the procurement process for both station originated

purchase orders (P0s) and for Engineering and Plant Betterment Department

(E&PBD) Purchase Specifications. All approved Nuclear Department Purchase

Requisitions (NDPRs) are transmitted to the Nuclear Department Procurement

Core Group (NDPCG). This group is a matrix of Engineering, Quality

Assurance, Purchasing and Spare Parts personnel. Engineering reviews

NDPRs and Inventory Material Requisitions (IRMs), supplies item classifi-

cation as required, assigns procurement specifications, approves changes

to NDPR packages and processes design change requests when replacement

parts are no longer commercially available. Quality Assurance reviews

NDPRs and IRMs, assigns quality provisions as appropriate, conducts

material receipt inspection and reviews and processes NDPRs and IRMs and

issues P0s. Spare Parts personnel are responsible for updating and

maintaining the managed maintenance information system (MMIS).

Procurement of parts of environmentally qualified equipment are procured

from the original supplier (OES) because of the OES's knowledge of the

parts application and its technical and QA requirements. The utilization

of non-0ES supplier requires the Program Analyses Group concurrence to

assure compatibility with original qualification.

The inspector verified implementation of the above listed procedures to

assure the EQ requirements were satisfied by randomly selecting the below

listed procurement packages.

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IMR-0191730 Rockbestos Cable

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P0-P1-242364 Rosemount Transmitter (two models)

• P0-P2-190663 ASCO Solenoid Valve

• PO-P2-184356 T&B Terminal

• PO-P1-152753 ASCO Valve Kits

• PO-P2-179029 NAMCO Limit Switch

• PO-P1-136312 Peerless D.C. Motor

+ PO-P2-179585 NAMC0 Limit Switch Gasket (Top Cover)

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The inspecter reviewed, where applicable, Equipment Evaluation Summary

Sheets (EESS), Procedure Requisitions, Certificate of Conformances,

Receiving Inspection Sheets, Quality Group Classification Checklists and

Receiving Nonconformance Reports.

Within the scope of this inspection, the inspector determined that the

procurement program for procuring EQ spare and replacement parts was

adequate and implemented in accordance with current procedures.

7.0 EQ Related Maintenance and Modifications

VPN-PLP-06, Revision 1, establishes responsibilities and requirements for

maintenance activities within the Nuclear Department. This procedura

applies to all maintenance activities performed by the Nuclear Department

organization or outside organizations working in support of Nuclear

Department operations. It applies to both preventive and corrective

maintenance.

The inspector reviewed the following implementing procedures relating to

the maintenance program.

MD-AP.ZZ-009(Q) - REV 6 - Control of Station Maintenance.

SA-AP.ZZ-009(Q) - REV 12 - Control of Station Maintenance.

MO-AP.ZZ-010(Q) - REV 1 - Preventive Maintenance.

SA-AP.ZZ-010(Q) - REV 7 - Station Preventive Maintenance program.

• GM9-QAP1-1 - REV 6 - PS&G Nuclear Qaulity Assurance Organization.

• GM9-QAP-5-4 - REV 1 - Completed Work Package /Non-EQ Listed Work

Order Review.

• Site Engineering Instruction (SEI) 2.6-Preparation and distribution

of EQMIS.

Each EQ file has an EQ Maintenance and Surveillance Information Sheet

(EQMIS) which outlines required maintenance activities including equip-

ment and parts replacement frequency based on EQ test reports. vendor

technical manuals and aging calculations. The overall EQ Preventative

Maintenance Program invo!"es periodic surveillance and replacement of

qualified electrical equipment. The testing, inspection, and replacement

cycles for equipment or parts are conducted in accordance with the

applicable procedures under the cognizance of the maintenance

supervisor.

EQ related corrective and preventative maintenance are performed through

Maintenance Work Requests. The Managed Maintenance Information System

(MMIS) is an integrated information processing system designed to create,

update status and archive work orders and information related to completion

of Work Orders. Preventative maintenance is set up by recurring tasks

which ;s identified in the MMIS and which generate a Work Order for each

task as it comes due.

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The inspector randomly selected six EQMIS sheets for review from EQ

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Binders, as follows:- '

1-SB-PS-N005A - Barksdale Pressure Switches

• 1-AV-215 ~ Blower Motor Rockwell/ Reliance i

• --l-EA-SV-2237 - Valcor Solenoid Valve

1-BB-SV-4310 - Valcor Solenoid Valve energized)

• i-BB-SV-4311 - Valcor Solenoid Valve energized)  :

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• 1-FC-LSH-NC10 - Magnetrol. Level ~ Switch

The inspector reviewed, as applicable; Work Orders, Station Deficieticy ,

Reports,' Maintenance Procedures, Calibration Check / Data Sheets, t

Signatures of applicable mechanics., Quality Assurance / Quality Control i

Representatives and Maintenance Supervisor to verify implementation of '

the above listed procedures.

Two Procedures were reviewed relating to-site and operaticr.a1 design ,

change control. Site Engineering Instructions 4.2 Revision-2, and  ;

GM8-EMP-009 Revision 2, Operational Design Change Control. Both f

procedures establish a uniform method of controlling design changes ,

relating to methodology'of initiation, preparation, review and approval -

of modification and maintenance work packages. The changes and revisions ,

to Design Change Packages undergo the same review and approval process as ,

the originals. .

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To assure that EQ requirements are satisfied, and verify implementation

of the above procedures, the inspector reviewed two design . change

packages, one relating to the replacement of the Tobar transmitter with a  ;

, qualified Rosemount transmitter and the other pertaining to the -

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replacement of the Peerless D.C. Motor in a Limitorque Motor Operated

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Valve.

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Within the scope of this inspection, no deficiencies were identified.

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8.0 EQ Personnel Training [

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Procedure No. GMS-EMP-022 revision 1; Paragraph 9.2 states, that: "Station l

personnel will be introduced and indoctrinated to the Environmental  :

, Qualification Program by means of video presentation by the NTC. These  :

i films will become a standard portion of the General Employee Training -

(GET). One film will provide all employees with a general overview and ,

description of EQ, and the others will be more specific for those

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employees wh will have a definitive function within the program."

Course material for the EQ Training program include: 1) EQ Equipment - .

Introduction to EQ equipment. !.essen Plan No. 607-153.20-801-04 (2 hr.); i

and, 2) EQ Equipment - Lesson Plan No. 607HC-000.00-850-00 (4 hr.).

There was no evidence of any training being given during 1986. An >

> internal memo (NTC-86-21.15) from the Manager, Nuclear Training indicates

i that the Environmental Qualification (EQ) training program which was to "

begin on December 1, 1986 had been indefinitely postponed.

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The licensee indicated that EQ personnel become familiar with EQ through

the use of internal procedures which implement and administrate the EQ

program as part of their normal indoctrination. In addition, EQ

personnel are hired or contracted based on their education and level of

experience in the EQ area. -Personnel records examined by the NRC

inspector confirm experience and knowledge in the area of EQ.

The EQ training program was re-established in late 1987. Training

sessions were given to I&C and Maintenance personnel on December 14-18,

1987 and January 18-25, 1988.

Within the scope of this review, no deficiencies were identified.

9.0 EQ Related NRC Information Notices and Bulletins

PSE&G has established a Response Coordination Team (RCT) to evaluate and

record the applicability and impact of NRC Bulletins, Circulars,

Information Notices and Industry Experiences. The Response Coordination

Team consists of representatives from Nuclear Reliability and Regulation,

Engineering, Quality Assurance and Hope Creek Operations Personnel. The

RCT chairman receives, reviews and assigns responsibility for

investigation of various NRC Bulletins, Circulars, Information Notices and

Industry Experience Documents. A detail review and analysis to determine

potential impact is done by the responsible originator. This review

process is designed to analyze, identify and address the potential impact

of these documents as they partain to Hope Creek as well as the EQ

program. Actions committed to in response and reports are tracked by the

RCT,

Licansee administrative controls for satisfying the requirements of

Bulletins, Circulars, Information Notices and Industry Experience is

A <ined in Procedure No. GMB-EMP-008 entitled "NRC IE Bulletins, IE

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Int e matie Notices and INPO Documents." This procedure defines the

progr m ,ed by the Engineering and Plant Betterment Department to

coordinate the review and action taken when responding to the NRC,

Institute of Nuclear Power Operations (INP0), Significant Event Reports

(SER), and Operations and Maintenance Reminders (0 & MRs).

To assure licensee implementa:. ion of established controls, the NRC

inspector examined licensee rasponse and actions taken for Information

Notice Nos. IN 85-39, IN 85-40, IN 85-52, IN 84-44, IN 84-57 and IN ~

83-72.

Within the scope of this inspection, no deficiencies were identified.

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10.0 Information Notice No. 86-53 (Raychem Heat Shrink Tubing)

In response to Information Notice No. 86-53, the licensee reviewed the

Hope Creek Unit 1 Raychem Heat Shrink tubing application documents. The

results of the licensee recommendation to inspect Raychem Heat Shrink

Splices, in accordance with the guidelines of the Information Notice 86-53 '

are documented in licensee Report Nos. RC-87-015 and RC-87-103, and

Station QA Surveillance Report No.87-254.

The random sampling performed by the licensee outside the drywell and the

inspection performed by the NRC during this inspection indicates that the

Raychem 'nstallation conforms with manufacturer's recommended practices

except in the a ea of cable bend radius, as defined in Section 3.4.6 of

Raychem Application Guide No. H 51211 (revised August 1983). The

specific bend radius requirement was not part of Raychem's splice

instructions prior to August 1983. The licensee's review of Bechtel

Drawing No. E-1000-0 indicate that a few splices may have been installed

in a harsh environment with a two times cable bend radius instead of the

recommended five times cable bend radius specified by Raychem. To

resolve the issue, the licensee performed a safety evaluation on April

14, 1987 using Wyle NEQ test Report No. 17859-028 dated March 11, 1987

which had qualified severely bent Raychem splice installed at Commonwealth

Edison Nuclear Facilities. The licensee's review indicated that the Hope

Creek environmental profile falls within the tested profile and that the

test results are applicable to Hope Creek.

The inspector verified that the Hope Creek cable bend radius deficiencies

were qualified by the Wyle Report.

The inspection of Raychem Heat Shrink Splices inside Containment is

scheduled for the 1988 outage.

Within the scope of this review, no deficiencies were identified.

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11.0 Evaluation of Information Notice 86-03 (Limitorque Motor '

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Operator Valve Wiring)

The inspector reviewed the actions of the licensee relating to Limitorque

motor operator valve wiring. Several inspections were made by the

licensee during the construction phase of Hope Creek. Limitorque wiring

was first inspected by the licensee to Bechtel General Technical Specifi-

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cation during the 1984-1985 time frame. Another inspection series was

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performed in 1985-1986 using Bechtel Specific Work Plant / Procedure

SWP/P-E-18 "Appendix A" which specified the criteria used by Bechtel for

inspection of Limitorque op3rators. Limitorque operators were also

inspected during the regrease effort (October 1985 to March 1986), and

during fine tuning of the operators (1985-1986). A sample of five operators

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was inspected for wiring in response to IN 86-03. The inspector reviewed

inspection records relating to the inspections and determined that only

Rockbestos SIS or Raychem flametrol wiring was used. The NRC inspection

team reviewed three Limitorque MOVs during the walkdown and determined

that qualified wiring (Rockbestos/Raychem) was installed. It was deter-

mined by the inspector that the licensee demonstrated adequate review and

actions prior to the issuance of IN-86-03 and after the notice was issued.

12.0 Equipment / Component Environmental Qualification File

The licensee's EQ files were examined to verify the nualified status of

the safety-related class IE equipment within the score of 10 CFR 50.49.

The review consisted of comparing plant service conditions with

qualification test conditions and verification of f.he basis for these

conditions. The inspectors selectively reviewed areas such as required

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, component materials,

tested configuration versus installed configuration and documentation for

both); evaluation of adequacy of test conditions; aging calculations for

qualified life and replacement interval determination; effects of decreases

in insulation resistance on equipment performance; adequacy of demonstrated

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equipment accuracy; evaluation of anomalies; and applicability of EQ

problems reported in IE Information Notices / Bulletins and their

resolutions.

The inspectors sampled 13 EQ files. The EQ files selected, covered such

areas as electrical cables, limitorque motor operated valves, pumps, cable

splices, radiation detectors and pressure / level transmitters. These files

contain documentation utilized by the licensee to provide a basis for

demonstrating that the equipment type is qualified, the equipment type

being a specific component or equipment, designated by the manufacturer

and model number, which is representative of all identical

equipment / components in a plant area exposed to the same or less severe

environmental service conditions.

In reviewing the files, the inspector identified EQ file Nos. J-601, J-373

and E-171 that contained deletions and whiteout changes to the original

text which had not been initialed or dated. The licensee was informed

that this item was in violation of Section 8.2.1 of procedure No.

VPN-NSD-07 which states that: "the use of whiteout and/or obliteration is

not permitted on Quality Assurance Records. Changes shall be made by a

single line drawn through the item with new information written in,

initialed and dated." This item is a violation of 10 CFR 50, Appendix B,

Criterion V which states, in part, that: "Activities affecting quality

shall be accomplished in accordance with instructions, procedures...."

(354/88-03-01)

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During the file review, the team concluded that the EQ files were

difficult to audit. The EQ files are listed by purchase order number and

contain all the qualifying documents / reports applicable to each item of

equipment / component procured under that purchase order number. This makes

the file difficult to audit for equipment qualification in that the

individuals performing the audit must search out the applicable document

and determine its applicability. The EQ file index references each

section within the file generically, such as, reports, calculations,

correspondence, i.e. The licensee acknowledged the NRC concern and stated

that this was also a finding in their own audit (number NM-87-09) of the

EQ program, and is being considered as part of the programmatic develop-

ment of EQ within the new Engineering and Plant Betterment organization. ,

The licensee indicated that the EQ files will be restructured into a

generic equipment based system. The licensee has committed to provide a

plan and implementation schedule by April 15, 1988 to the NRC as to when

this task will be completed.

This item is unresolved pending NRC receipt and review of licenses's

completion schedule and action taken to simplify and improve EQ file

auditability (88-03-02).

13.0 Specific File Deficiencies

13.1 EQ File No. P301/p302 (Limitorque Motor Operated Valves)

The inspector reviewed the EQ file package for equipment / components

procured against purchase order Nos. P-301 and P-302. Thes3 EQ

files contained documentation used to support qualification of

Limitorque Motor Operated Valves (MOVs). During the file review,

two MOVs were identified in containment which used the Marathon 1600

Terminal Block. The inspector questioned the adequacy of the

Limitorque Test Report No. B-0119 to qualify the Marathon 1600

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Terminal Block for in containment use.

The B-0119 report indicates the test configuration included a group

of terminal blocks in an operator (MOV) compartment enclosure. A

Marathon 300 Terminal Block and several Marathon 1600 Terminal

Blocks were used in the test group. Only the Marathon 300 Test

Block was energized during the LOCA testing. The Manufacturer of

Limitorque had concluded in their review and acceptance criteria

that the Marathon 300 Terminal Block was representative of other

Terminal Blocks in the test group. A similarity analysis was not on

file for comparison of the Marathon 300 Terminal Block and the other

test Blocks. However, a letter, dated January 29, 1988 was obtained

f rom Marathon Specialty Products company confirming similarity of

the Marathon 300 Terminal Block and the Marathon 1600 Terminal

Block.

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During the course of the inspection the licensee was able tc provide

a copy of a proprietary test report which qualifies the Marathon

1600 Terminal Block for limited use in containment. The test was

performed by Wyle Laboratories to satisfy the intent of IEEE-323-1974.

The Terminal Blocks were subjected to the environmental test program

specified in Wyle Test Procedure No. 6110-06-1 and described in test

Report No. 6110-06-2.

The LOCA test profile envelopes the Hope Creek profile. The

inspector concluded that the Marathon 1600 Terminal Blocks were

qualified to function in the LOCA environment for the time period

specified.

14.0 Plant Physical Inspection of Electrical Equipmpnt

The plant physical inspection consisted of an examination of safety-related

electrical equipment selected from the EQ Master List. Since the plant

was operational, the equipment selected was located and installed in

areas outside the containment. The equipment selected included:

Limitorque Motor Operated Valves, Pressure / Level Transmitters, Solenoid

valves, and electrical cable splices.

The inspector examined characteristics such as mounting configuration,

orientation, connection interfaces, moisture seals, model/ type, bend

radius, accessibility, cleanliness and physical condition.

Electrical cable splices were examined in four junction boxes located on

elevation 54'-0 and /7'-0. The inspector observed that all four junction

boxes (one safety-related 1F-DLV-F025) contaired dirt and debris. Some of

the debris appeared to be left over from construction. The licensee was

not able to explain the presence of the dirt / debris stating that each

system is inspected prior to turn over of the system by construction

personnel.

This item is unresolved pending NRC review of licensee review and

evaluation of the extent of the problem (354/88-03-03).

No other deficiencies were identified.

15.0 Unresolved Items

Unresolved items are matters which require more information in order to

ascertain whether they are acceptable items or violations. Unresolved

item (s) are discussed in Details, Paragraphs 12 and 14.

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16.0 Exit Meeting

The inspector met with licensee corporate and site personnel (denoted in

Details, paragraph 1) at the conclusion of the inspection on

January 29, 1988 at the plant site. The inspectors summarized the scope

of the inspection and the inspection findings at that time.

At no time during this inspection was written material provided to the

licensee.