IR 05000324/1987022

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

ML20237H453
Person / Time
Site:	Brunswick
Issue date:	08/21/1987
From:	Conlon T, Merriweather N, Paulk C, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237H434	List: ML20237H432 ML20237H453
References
50-324-87-22, 50-325-87-22, NUDOCS 8709030278
Download: ML20237H453 (17)

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UNITED STATES

/pe Afog 'o NUCLEAR REGULATORY COMMISslON

[s n REGION !!

g j 101 MARIETTA STRE ET, j

• c ATL ANTA, GEORGI A 30323 3 \...../

Report Nos.: 50-325/87-22, 50-324/87-22 Licensee Carolina Power & Light C Post Office Box 1551 Raleigh, North Carolina 27602 Facility Name: Brunswick Steam Electric Plant, Units 1 and 2 Docket Nos.: 50-325, 50-324 License Nos.: DPR-71 and DPR-62 Inspection Conducted: July 6-10, 1987 Inspe [ N. > _b Date M /Signed-F7 SW Merriweathe~r, Reactor Inspector V

0 2< k Sht l87 Date Signed C. W Paulk C . F . Srh

"An ik S Date

'7- / A Signed Y

j Approved B M T. E. Conlon, Section Chief dn< rv' bZ / ~b Date Signed Engineering Branch Division of Reactor Safety SUWARY Scope:This special announced inspection was in the area of previously identified Environmental Qualification (EQ) deficiencie Realts: Eight violations were identified - HPCI Speed Sensors Not Environ-mentally Qualified, paragraph 3.c.; Vulkene Wire Not Documented Environmentally Qualified, paragraph 3.d.; Whitney-Blake Wire Not Environmentally Qualified, paragraph 3.d.; SBGT Relays Not Documented Environmentally Qualified, paragraph 3.e,; Kulka Terminal Blocks Not Documented Environmentally Qualified, paragraph 3.f.; Cinch Tenninal Blocks Not Environmentally Qualified, paragraph 3.f.; SBGT Temperature Switch Leads Not Environmentally Qualified, paragraph 3.g.; HPCI Float Switches Not Environmentally Qualified, paragraph DR ADOCK0500g4

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l REPORT DETAILS Persons Contacted Licensee Employees

• C R. Dietz, General Manager, Brunswick Steam Electric Plant (BSEP)

• A. Bishop, Manager-0perations

• R. Eckstein, Manager, Technical Support l * O'Sullivan, Manager-Maintenance

• J. Groover, Project Construction Manager

• L. Parks, Supervisor, Technical Support

• L. F. Tripp, Supervisor, Radiological Controls

• L. E. Jones, Director-QA/QC

• A. Richards, Principle Engineer, QC

• J. O'Connor, Project Engineer, Technical Support

• R. M. Poulk, Jr., Senior Specialist-Regulatory Compliance W. Guarino, EQ Coordinator

• P. Salas, Senior Engineer, Corporate Licensing T. Gick, EQ Coordinator-Maintenance

• T. Parlier, Principle Engineer, Engineering and Construction

• J. May, Engineer, Engineering and Construction

• S. Callas. Engineer, On-site Licensing Licensee Contractors

• D. Dotson, Consultant, Cofer Associates R. J. Phillips, Senior Engineer, Westinghouse Resident Inspectors

• W. Ruland L. Garner

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 10, 1987, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.

Subsequent to the inspection, a telephone conversation was held on July 30,1987, between Mr. C. R. Dietz, General Manager, Brunswick Steam Electric Plant, and NRC representatives (P. Fredrickson, T. Conlon,

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M. Hunt, C. Paulk, and N. Merriweather) to inform the licensee that those unresolved items previously identified in the exit meeting as being closed ;

are being reopened and re-evaluated by the NRC. The current status of those items are discussed in paragraghs 3 belo Violation 325, 324/87-22-01, HPCI Speed Sensors Not Environmentally Qualified, paragraph Violation 324/87-22-02, Vulkene Wire Not Documented Environmentally Qualified, paragraph Violation 325/87-22-02, Whitney-Blake Wire Not Environmentally Qualified, paragraph Violation 325, 324/87-22-03, SBGT Relays Not Documented Environmentally Qualified, paragraph Violation 325/87-22-04, Kulka Terminal Blocks Not Documented Environ-mentally Qualified, paragraph Violation 324/87-22-04, Cinch Terminal Blocks Not Environmentally Quali-fied, paragraph Violation 325, 324/87-22-05, SBGT Temperature Switch leads Not Environ-mentally Qualified, paragraph Violation 325, 324/87-22-06, HPCI Float Switches Not Environmentally Qualified, paragraph . Status of Previousiy Identified EQ Items (Closed) Unresolved Item 325, 324/85-26-0 Procurement of replacement parts. The EQ inspection conducted August 12-16, 1985, identified a concern with the licensee's program for replacement equipmen This concern involved the replacement of D0R qualified equipment that did not meet the requirements of 10 CFR 50.49, Paragraph (1), in that provisions had not been established for the documentation of sound reasons to the contrar Subsequent corrective action by ths licensee has resulted in the preparation of Appendix II to Procedure PLP-02, " Program Document for Compliance with 10 CFR 50.49," Revision This appendix lists, by equipment i types, plant equipment that are qualified to Division of Operating

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Reactors (D0R) Guidelines and delineates generic reasons for not upgrading this equipment to NUREG 0588, Category Concerns were also identified by the previous EQ inspection that actual replacement of D0R equipment may have occurred that did not comply with the requirements of 10 CFR 50.49 (1). The inspectors

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I conducted interviews with licensee personnel and reviewed program documents to assess the status of selected elements of the EQ upgrade effor Paragraph 4.4.3 of Procedure PLP-02 delineates the controls for replacement of D0R qualified equipment via near term and long term policy objective Near term replacement of D0R qualified equipment that meets the requirements of 10 CFR 50.49 (1) are as defined in procedure PLP-02, Appendix II. This process is imple-mented by the replacement of like-in-kind equipment wherein the manufacturer, part number, model number, physical attributes of form-fit-function, and demonstrated qualification are the same as the original equipmen Long term objectives for upgrade of selected EQ equipment types will be implemented through a systematic and pre-planned replacement process governed by IPBS-912 " Program for Upgrading Replacement Equipment". The long term program for upgrada of D0R qualified equipment will be accomplished as follows:

- Phase A will provide the IPBS-912 program definition of the equipment scope, the upgrade methodology, and implementation direction for specific equipment. This phase will be completed through the review and approval of the program document by site managemen Phase B will perform the re on the Phase A direction) as quired preliminary well as generate theengineering IPBS-912 (based program proposal to define specific plant equipment identified for replacement, their proposed Category I replacements , their implementation (e.g. engineering / design, procurement, and installation) schedule, and their estimated budgetary require-ments (for manpower and equipment). This proposal will also receive site management review and approva Where it is definitively concluded (within the Phase A document)

that the 50.49 (1) upgrade requirement can be best accomplished (i.e. through a known replacement / refurbishment method that is cost and scheduler Budgeting, effective)

and Scheduling a separate (IPBS) activity Integrated Planning, (e.g. IPBS-912A, etc. )

may be " spun-off" from the Fhase B activities (to assure its implementation independent of the remainder of the IPBS-912 program).

IPBS-912 implementation activities, as budgeted and scheduled per the approved Phase B proposal, will be performed, as l required, consistent with other plant design change activitie This implementation process will assure that the EQ list data base and the qualification documentation packages are updated / maintained consistent with the as-LJil; plant configu-ratio _ _ _ _ - _ .

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' Review of engineering procedures and discussions with engineering L  ;

personnel verified that measures had been established to assure the I upgrade of EQ equipment during -the engineering design proces !

Additional discussions were- held with licensee personnel to assess the status of the long term equipment upgrade program. The inspec-tors determined ' that licensee management has an ongoing effort intended to establish the requirements of the IPBS-912 project. The inspectors were ' additionally informed that procedure IPBS-912 " Phase ,;

'A" was presently being developed to define the process for review of D0R qualified equipment relative to the need for upgrade per 10 CFR 50,49 (1), and to provide a management-approved basis for future IFBS-912 project development' associated with presently installed D0R qualified equipmen Appendix II to PLP-02 represents the pre-procurement and pre-installation reviews-of all D0R qualified equipment types not to be upgraded that have been performed by the licensee. To assure that'

the licensee's long term policy objectives for upgrade of D0R qualified equipment is implemented, a' commitment date was requested by the inspectors for approval of procedure IPBS-912 Phase Licensee management has committed to an approval date of January 1988, for

' Procedure IPBS-912,-Phase Besed on review of. objective evidence 'and discussions with licensee personnel, this issue is closed, (Closed) Unresolved Item 325, 324/85-26-05. Qualification status of installed equipment / establishment of EQ maintenance requirements in plant procedure During the initial EQ inspection the NRC inspectors had a concern that some installed Unit 2, 10 CFR 50.49 equipment might be unquali-fied due to the. licensee's failure to perform required EQ maintenance activities. The reasons for these concerns were:

(1) BSEP Technic &1 Support Group had not received any Qualification Data Packages (QDP) from Brunswick Engineering Support Unit (BESU) and likewise had not developed any EQ Maintenance Summary Package (2) Maintenance had not received an approved plant document identifying the Unit 2 EQ equipment ntil April 1985, Unit 2 start-up was in October 198 (3) Maintenance had no list or knowledge of the equipment require-ments related to EQ.

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As a result of these concerns, the licensee performed a detailed review of those EQ items most likely to have been invalidated due to failure to implement the required EQ maintenance. The review consist-ed of comparing the EQ Maintenance Sheets (EQMS) to existing plant procedure This review determined that EQ maintenance items specified on EQMS-35, "Rosemount 1152 Transmitters" were not address-ed in current maintenance pttcedures and that the potential existed that the qualification may have been invalidated for 80 type 1152 Transmitters on Unit 2. An analysis was performed by the licensee to document the qualified status of Unit 2 Rosemount 1152 instrument It concluded that the qualification would not have been compromised or degraded by the failure to specifically perform the maintenance l activities identified in EQMS-35. This analysis also addressed the licensee's failure to seal the conduits connected to the instrument The evaluation demon-strated qualification of the instruments without use of conduit seals by demonstrating that the terminal blocks used in the instruments were similar to a GE Terminal Block which had been type tested. The qualification file stated that the leakage current from the terminal blocks would not cause the loop error to exceed Technical Specifications. However, the analysis was lacking in that  ;

it did not address the leakage current contributed by the field cable. In order to resolve the inspectors' concern, the licensee revised the analysis (DR59.2) to show the contribution of the field cable in the total of leakage current in the instrument loo The revised analysis shows that with a worse case loop error with a maximum cable length of 1000 feet the value for leakage current is still within the acceptance values specified in Technical Specifica-tion c. (Closed) Unresolved Item 325/86-29-02, 324/86-30-02, HPCI turbine speed sensor. The licensee identified in October 1986 that the speed sensor magnetic pickups in the Unit I and Unit 2 HPCI turbines were not environmentally qualified. Subsequent corrective actions by the licensee included declaring the turbines inoperable, installirg qualified sensors, and initiating a review of the even The inspectors conducted interviews with licensee personnel and reviewed documents prepared pursuant to the event to assess the enforcement status of this issue. Engineering Evaluation Report (EER) No. 86-0485 was prepared by the licensee to determine the following:

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Is it reasonable to conclude that the installed device would perform satisfactorily through the unlikely condition of a design basis event

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- Is 'the device. that was . installed (Woodward speed sensor), in-fact, qualifiable and thereby provide assurance that plant safety was not compromised The inspectors determined that temperatures of 230 F for 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> exposure, and radfation aging of 1.1x106 rads were established by the General Electric Co. (GE) for qualification of the speed sensor These pre-test parameters imposed conditions in excess of the threshold limits for non-metallic materials used in the Woodward speed sensor, and was the basis for the need to change these speed

,' sensors'. The most critical non-metallic component of the Woodward speed sensor is Permabond 910, an adhesive used in the fabrication of the' speed sensor. A comparison of temperature and radiation values between the BSEP. plant environment (normal and postulated accident)

-and the Permabond 910 reveals the following:

Temperature BSEP Normal Service Temperature 104 F maximum BSEP Postulated Accic 9t Qualification Temperature 148 F Permabond-910 Service Temperature 165 F Permabond 910 Softening Temperature 180 F J Radiation The total integrated dose for the speed sensor is 4.3x105 rads The radiation properties for the Permabond 910 are 2x106 rads There'is a 1.57x106 rad margin (273%) over the BSEP conditions The inspectors verified that the threshold values for the Permabond-

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.910 non-metallic component was determined by a literature searc Additionally, GE has concluded that if the actual temperatures and radiation values to which the speed sensor is subjected stay below the corresponding threshold values, it is their opinion that the sensor would have perfonned its intended functio Licensee management in the EER stated that the Woodward speed sensor is qualifiable to the DOR Guideline Based on the review of objective evidence and discussions with licensee personnel, . the inspectom concluded that the Woodward speed sensor was qualifiable for the application in questio Licensee management is also presently in compliance with the requirements of 10 CFR 50.49 in that the Woodward speed sensors were replaced with Category 1 speed sensors on October 18, 1986, for Unit 1, and October 21, 1986, for L Unit 2.

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The ' inspectors determined the root cause of the licensee's failure to replace the Woodward speed sensors with qualified speed sensors provided by GE was inadequate design interface control. Discussions

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m with licensee engineering personnel revealed misunderstandings with GE regarding the scope of HPCI skid mounted components that were being environmentally qualified. GE's report NEDC 31001-1, received in October 1985, clearly identified the requirement to replace the senso Therefore, the licensee clearly should have been known the soeed sensors were not qualifie Contrary to paragraphs (d), (f), (j) of 10 CFR 50.49, from Novem-ber 30, 1985 to October 18, 1986 for Unit 1; and from June 15, 1986 to October 21, 1986 for Unit 2, the licensee (1) did not have the Woodward speed sensors on the Master List of qualified equipment; (2) did not have the speed sensors tested for qualification; (3) did not have documentation to verify qualification of the speed sensors in an auditable form. This is identified as Violation 325/87-22-01, 324/87-22-01, HPCI Speed Sensors Not Environmentally Qualifie The Unresolved Item is now considered close d. (Closed) Unresolved Item 325/86-29-03, 324/86-30-03, Limitor-que Motor-0perator Wiring. The licensee, in response to IE Notice 86-03, performed inspections on a sample population of Limitorque valve actuators. The results from 35% of the Unit 2 valves identi-fied a wire in a Limitorque valve actuator (2-E11-F024A) as being manufactured by Vulken This wire was not on their EQ list and was installed by the license The licensee immediately replaced the wire and commenced testing. Tests performed at the time indicate that the wire was cross-linked polyethylene, and subsequently the licensee has prepared an Engineering Evaluation Report in order to qualify this wire to D0R guidelines. When testing is completed on this type wire, the licensee will complete a QDP for Vulkene wir Contrary to paragraphs (d),(f) and (j) of 10 CFR 50.49, at the time of the inspection the licensee (1) did not have the Vulkene wire on the Master List of qualified equipment, (2) did not have the wire tested for qualifications, and (3) did not have documentation to verify qualification of the wire in an auditable form. This is identified as Violation 324/87-22-02, Vulkene Wire Not Documented Environmentally Qualified, The licensee found another instance of improper wire in a Unit i valve (1-Ell-F024A) during its sample inspection. This wire was made by Whitney-Blake, was not on the qualified list, and was licensee installed, as was the Vulkene wire discussed abov Contrary to paragraphs (d), (f) and (j) of 10 CFR 50.49, at the time of the inspection, the licensee (1) did not have the Whitney-Blake wire on the Master List of qualified equipment, (2) did not have the wire tested for qualification, and (3) did not have documentation to verify qualification of the wire in an auditable form. This is identified as Violation 325/87-22-02, Whitney-Blake Wire Not Enviro-mentally Qualified.

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Considering the fact that another unqualified wire was found, the '

licensee took inadequate corrective action after identifying the .

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

action was inadequate in that the incident was waved off as being "an isolated case." The licensee further stated that it was their policy to " purchase and stock only environmentally qualified wire / cable for use on Q-list sa fety-related applications," and that any

" modifications or corrective maintenance activities would have used an acceptable qualified wire / cable." Due to the fact that no corrective action was taken to insure there was no additional licensee installed wire that was not qualified (e.g. a 100% check of Limitorque valve operators), the Whitney-Blake wire remained undetected until identified during maintenanc The results of the licensee's sampling program show that potential for additional unqualified components in the Limitorque valve actuators still exists, whether installed by the vendor or the license In order to ensure that no valves contain unqualified l components or wire, an inspection of all -qualified valves is required. With the identification of the above violation, this unresolved item is now considered close (Closed) Unresolved Item 325/86-32-01, 324/86-3?-01, Standby Gas Treatment (SBGT) Systems Relays not Documented E On November 21, ,

1986, during a review of the electrical components on the SBGT skid, i the licensee discovered that o" Tication documentation for four )

control relays per SBGT unit v's ' ' Mrtently omitted from the BSEP EQ Progra The control rela,3 - ~ , .stion were CR9A, CR9XA, CR98, j and CR9X These relays prnviae the logic for alignment of j valves / dampers associated with the SBGT operatio EER 86-0516 ras I prepared by the licensee to justify continued operation of Units 1 and 2 with the relays that were installed. The evaluation concluded that the relays will perform their safety function before the harsh environment could potentially affect the accomplishment of the safety function and subsequent foilure of the relays will not disable a required safety function. The licensee determined that the relays installed in Unit I were the same (GE Type 2810) as those which were qualified with the unit's motor control center. QDP-68 was revised to document the qualification of Unit I relays (GE Type CR2810) which were identical to qualified relays in the unit's motor control cente For currently installed Unit 2 relays (GE Type CR120) a PNSC Action Item was established to replace the SBGT relays CR9A, CR9XA, CR98, CR9XB during a future outage of sufficient length commensurate with procurement of replacement relays and scheduling of the work activitie Expected completion date is April 22, 1988.

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During the periods, December 1985 until November 1986 on Unit 1 and May 1986 until November 1986 on Unit 2, the licensee was in violation with the requirements of 10 CFR 60.49, in that the SBGT relays (CR9A, CR9XA, CR98 and CR9XB) were not identified on the EQ list as being used on EQ equipment and the licensee did not have documentation to demonstrate qualification. This violation was identified by the licensec ss part of corrective actions for a previous EQ program deficiency on HPCI skid mounted component The licensee was conducting a re-review of the as-built configurations of all skid mounted EQ components to verify that they match existing EQ docu-mentation. The licensee's corrective actions included documenting a justification for continued operations, evaluating the deficiency for deportability, establishing qualification for Unit I relays and scheduling replacement of the Unit 2 relay Subsequent to this finding the licensee identified on March 11, 1987 that Unit 1, Train 8 SBGT temperature switches (1-VA-TS-5296, -52971, -52298-1, and -5298-2) were terminated using an unidentified hookup wire with blue colored insulation. In Ladition, the licensee found unqualified Vulkene wire used on the other three trains of SBGT. This item appears to indicate that the !icensee's re-review of skid mounted components was inadegnt The above item is identified as Violatian 325, 324/87-22-03, Standby Gas Treatment Relays Not Documented Environmentally Qualified. With the identification of this violation, the unresolved item is now considered closed, f. (Closed) Unresolved Item 325, 324/87-06-05 RCIC steam admission valve terminal block. During the sampling of Limitorque valves in response to IE Notice 86-03, the licensee found on March 10,1987, a Kulka terminal block in the actuator for Valve 1-E51-F04E. Kulka terminal blocks were not on the master list and the licensee did not have any test reports that qualified the terminal block The licensee subsequently qualified the 'Kulka terminal blocks in the

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timitorque valve actuators by comparison to the Marathon 300 terminal blocks. The Marathon blocks were qualified in QDP-28 and QDP-29, and 4 reference to the Kulka termir.al blocks was included in order to permit the Kulka blocks to remain until the valve actuators are upgraded to Categcry Contrary to paragraphs (d), (f), and (f' of 10 CFR 50.49, at the time of the discovery of the Kulka termin 1 . lock, the licensee (1) did not have the Kulka terminal blocks on the Master List of qualified equipment, (2) did not have the terminal block tested for qualifi-cation, and (3) did not have documentation to verify qualification of the terminal block. This identified as Violation 325/87-22-04, Kulka Terminal Blocks Not Documented Environmentally Qualified.

During this inspection, the licensee discovered Valve 2-E11-F004A

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with an unqualified terminal block manufactured by Cinch that was installed by the vendor. Contrary to paragraphs (d), (f;, and (j) of l

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10 CFR 50.49, at the time of the inspection, the licensee (1) did not have the Cinch terminal block on the Master List of qualified equip-ment, (2) did not have the terminal bicek tested for qualification, and (3) did not have documentation to verify qualification of the .

terminal block.- The licensee should have known the potential for non-environmentally qualified terminal, blocks existed. (IE Notice 83-72 addressed underrated terminal blocks as well as IE Notice 84-78.) Due to an inadequate verification by receipt inspection and/or field walkdown, the non-qualified terminal block was not discovered until this inspectio This item is identified as Viola-tion 324/87-22-04, Cinch Terminal Blocks Not Environmentally Quali-fle g.- (Closed)UnresolvedItem 325, 324/87-06-05b. 'SBGT system temperature switch leads. With the unit defueled, the licensee found on March 11, 1987, that leads connected to the 18 SBGT system deluge system temperature switches (TS1, TS3, TSS, and TS6) were terminated using unidentified hookup wire for extending the lead wires of the four temperature switches. The unidentified wire was not qualified for this application at BSEP. Therefore, the wire was replaced with qualified Rockbestos FW III single-conductor wire. The other SBGT trains on Units 1 and 2 were field inspected to confirm use of qualified wire. The licensee also identified unqualified Vulkene wire used on the other trains of SBGT for both unit The licensee developed Engineering Evaluation Report No. 87-0179 to document their evaluation of the unidentified hookup wire utilized for Unit 1 Train 8 SBGT temperature switches to determine system +

operability and to assist in determining deportability. The licensee j

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determined that it was not reportable. However, subsequent review by NRC indicates that it is reportable under 10 CFR 50.73, paragraph (a)(2)(V). ]

Samples of the unidentified wire were sent to the Harris Environ-mental and Energy (E&E) Center for chemical and material evaluatio It was concluded from this analysis that the material was a flouro-carbon polymer, similar to teflon or a teflon-like compound. For analysis purposes, the licensee considered that the material was pure teflon. The licensee concluded that the operation of the IB SBGT skid would be unaffected ur. der High Energy Line Break (HELB) condi-tions, because of good high temperature dielectric properties of teflon insulation materials. However, under post-LOCA conditions it was concluded '. hat the wire insulation could degrade after 11 days causing loss of the IB train of SBGT. The EQ Equipment List speci-fies a "Long" operation time for the SBGT filter skid of 30 days. It is concluded that this unidentified wire is not qualifiable for post-LOCA operations beyond 11 day In addition, the Vulkene wire h identified on the other three trains is also not considered qualified but the licensee considers it to be qualifiable, t

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l Technical Specification 3/4.6.6, Containment Atmosphere Control I Standby Gas Treatment System, LCO 3.6.6.1, states that "two (2)  !

independent standby gas treatment subsystems shall be operable in  !

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

the secondary containment." The licensee did verify that the other 1 SBGT trains on both units did not contain unqualifiable jumper wire .

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

a list of electric equipment important tr safety be prepared, and infurma tion concerning performance specifications, electrical characteristics and postulated environmental conditions for this j equipment be maintained in a qualification file; (2) each item of '

electric equipment important to safety shall be qualified by testing of, or experience with, identical or similar equipment, and qualifi-cation shall . include a supporting analysis to show that the equip-ment, and the qualification shall include a supporting analysis to show that the equipment to be qualified is acceptable; and (3) a f record of the qualification of the electric equipment shall be maintained in a qualification file in an auditable form to permit verification that the required equipment is qualified and that the equipment meets the specified performance requirements under postu-lated environmental condition Contrary to the above, on March 11, 1987, and as far back as December 1985 this unidentified teflon, type wire was not on the EQ list as being used on EQ equipment and the licensee did not have documentation to demonstrate qualificatio The above is identified as Violation 325, 324/87-22-05, SBGT Temperature Switch Leads Not Environmentally Qualifie This unre-solved item is considered close (Closed) Unresolved Item 325, 324/87-11-0 HPCI Condensate Float Switches not EQ Documente The licensee, pursuant to the identi- .'

fication of the Woodward speed sensor problem, conducted a thorough review of HPCI skid mounted components to verify their EQ statu During the course of this review, Units 1 and 2 condensate float switches were demonstrated to be not environmentally qualified by existing documentatio The switches do not perform a safety function, however they are connected to the HPCI turbine 125 VDC actuation circuit. A failure mode and effects analysis performed by licensee revealed that should a ground develop as a result of the condensate high level float switch failure, no loss of function of the HPCI turbine would resul Licensee management has also prepared Engineering Evaluation Report (EER) No. 87-0137, Revision 0, and 1, to present evidence that the switches are qualifiabl Further, the switches were successfully environmentally qualified by GE as documented in Attachment I for EER No. 87-0137.

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Information concerning maintenance activities l required to ensure L qualification of the switches was. requested by the inspectors during-the inspection of July 6-10, 1987. This information which was not readily available at the time has been addressed in revision 1 to EER No. 87-0137. The licensee has determined that there are no specific maintenance ' activities required to maintain the EQ status- of ~ the

. switches. An operating (mechanical) qualified life of 18 years has been calculated for the switche '

Corrective actions developed and implemented by licensee management '

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

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ration (JCO) documented in EER 87-0137. Long term corrective action l may either be the implementation of a plant modification to remove l the HPCI gland steam exhauster condensate high level switch from HPCI l actuation / control circuity; or the procurement of the required documentation from GE. The inspector was informed tht correctiv action in the form of a plant modification has been scheduled for a plant outage (planned / unplanned) of appropriate lengt Contrary to paragraph (d) and (j) of 10 CFR 50.49, as far back as November 30, 1985, the. licensee (1) did not have the HPCI condensate i float switches on the Master List of qualified equipment;-(2) did not have documentation to verify qualification of the HPIC compensate float switches in an auditable form.' This is identified as Violation 325/87-22-06,324/87-22-06. HPCI Float Switches Not Documented Environ-mentally Qualified.~ (Closed) Unresolved Item. 325, 324/87-11-05, SBGT Accident Radiation Levels. The licensee discovered that post-accident radiation levels assumed for qualification of the SBGT skid and documented in QDP-68 failed to account for the increase in radiation levels due to the accumulation of. radioactive gas and particulate within the carbon .

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filter QDP-68, Rev. O, spec 1fied a total integrated dose reen by the SBGT skids of only 1 x 105rads. However, as stated above, the accumulation of radioactive gas and particulate would cause the radiation levels to increase significantly beyond this total inte-grated dose, gheFSAR,Section 15.6.4.5.3, specified an integrated dose of'4 x 10 rads post-LOCA for the fan moto To resolve this qualification problem and to document justification 1 for continued operation of BSEP Units 1 and 2, the licensee, in EER l 87-0133, Rev. O, performed additional calculations of integrated j irradiation dose for the SBGT skid and reviewed existing EQ quali-fication data to confirm that SBGT skid components were still qualified to the newly calculated doses. No deficiencies were J identifie This iter is considered close _-__ ___

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1 1 Licensee Actions on Previously Identified Inspector Followup Items (Closed) Inspector Followup Item 50-325, 324/85-14-01, Q-List Program t Change During the above inspection, the inspectors observed that the Q-List Group had been classifying as Q or non-Q, piece parts of

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major tions onplant comp three (onents 3) part and documenting memorandum These evaluations the resultswere of their beingevalua-used by plant staff in classifying as Q or non-Q replacement compo-

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L nents on maintenance and procurement request; however, this method of evaluations was not procedurally addressed. The licensee committed during this inspection to revise Volume XI, Book 2, of the Plant )

Operating Manual to incorporate steps for processing component parts evaluations. Subsequently, (in revision 28 of Volume XI, Book 2)

h the licensee incorporated instructions for component / plant evalu-

) ations by inclusion of a three page form entitled "Q List J Evaluation." The procedure now requires that each evaluation receive an independent review. In addition, if the evaluation constitutes the downgrade of an item from Q to non-Q status, the evaluation must include the basis used in determining that the subject change will not constitute an unreviewed safety question raise a potential safety concern for the other unit. The inspectors considered this to be acceptabl Another concern identified during the subject inspection was that Engineering Evaluation Reports (EERs) contain information regarding Q-List classification of components . However, the Q-List Group who had responsibility for revising the Q-List was not on the required distributions for copies of the EER The licensee indicated that although the Q-List Group was not on the required distribution they

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has been receiving copies of EER The licensee has subsequently revised the Engineering procedure (ENP-12) that specifies distributions of EERs to include the Q-List )

_ Coordinator on the required distribution list for all EER j l

This item is now considered close (Closed) Inspector Followup Item 50-325, 324/85-26-01, Sign-offs of Qualification Data Packages. The licensee completed all required actions to satisfy the commitment to have the QDPs completed prior

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to the restart of Unit This action was verified to have been  !

completed in October 198 This item is now considered close (Closed) I*spector Followup Item 50 325, 324/85-26-02. Completion of Qualification Data Packages. The licensee completed all required actions to satisfy the commitment to have the QDPs completed prio- to the restart of Unit This action.was verified to have been completed in October 198 This item is now considered closed.

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14 (Closed) Inspector Followup Item 50-325, 324/85-26-03, Generic File Improvemen The licensee revised ENP 34.3, " Qualification Data Package (QDP) Control Procedure," in order to clarify the instruc-tions and wording of the EQ Evaluation Form, the resolution of Information Notices, and the EQ Maintenance Summary. The procedure

- provides for adequate and consistent evaluations for QDPs. This was verified by review of the document. This item is considered closed.- (Closed) Inspector Followup Item 50-325, 324/85-26-06, Damaged Cable on Installed NDT International Accelerometer. The damaged cable was repaired under PM-84-180 on 9/3/85. Additional cable damage was found and repaired at the same time. This was verified by review of the plant modification work package. This item is now considered close (Closed) Inspector Followup Item 50-325, 324/85-26-07, Westinghouse Electrical Penetration Assemblies (EPAs). The licensee ' revised QDP-14. " Westinghouse Electrical Penetrations Class B, C, E, and F", l to include functional requirements analysis for the EPAs. This was verified by review of the document. This item is now considered closed, (Closed) Inspector Followup Item 50-325, 324/85-26-09, Qualification

.of NDT International Accelerometer. The licensee prepared QDP-58 on October , 17 1985 to qualify the NDT International accelerometers and associated coaxial cable to NUREG 0588, Category I. This QDP was prepared and approved prior to the Unit I restart in 1985. This was verified by review of the document. This_ item is' considered closed, (Closed) Inspection Followup Item 50-325, 324/85-26-08 Barten Model 289A Switches Design Basis Accident (DBA) Operating Tim The EQ inspection conducted August 12-16, 1985, iden, ,4ed incon-sistencies in the DBA operating time used by the 1. .asee for radiation environmental qualification of Barton Model 289A switches 1 Ell-PDIS- N021A and B and E21-FS-N006A ar# B. Qualification Docu-mentation Package (QDP) 38 showed a DBA operating time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, while the EQ list showed the DBA operating time as "Long", (Long being defined as 30 days). Licensee management was unable to provide documentation substantiating this chang Licensee's corrective action regarding the above was reviewed during the EQ followup inspection. The inspectors determined that an evaluation of post-accident operating item requirement for the RHR and Core Spray Mini flow bypass valve controls had been performed.

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

that it was performed outside of the controls of licensee engineering desiga prugram,' and a 10 CFR 50.59 safety evaluation was never performed for changes to design basis information en the EQ list.

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l Licensee management subsequently prepared EER 87-0320, revision 0, to

address the above deficiencies. The inspectors reviewed this report and determined that an analysis of the RHR LPCI'and Core Spray system ,

operations, with reference to appropriate sections of the FSAR, had  !

been performed for LOCAs with large break design basis accident (DBA)

and small steam line breaks. The licensee had documented and justified the basis for the short time DBA operating time used for radiation environmental qualification of the pressure switche Additionally, a 10 CFR 50.59 safety evaluation was performed to address the safety significance of the change in the operation time of the pressure switches. Based on the review of this report, this  :

item is considered close t l

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