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| {{Adams | | {{Adams |
| | number = ML20153E763 | | | number = ML20195E338 |
| | issue date = 04/22/1988 | | | issue date = 06/10/1988 |
| | title = Insp Rept 50-395/88-01 on 880111-15.Violations Noted.Major Areas Inspected:Environ Qualification of Electrical Equipment | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-395/88-01 |
| | author name = Conlon T, Ruff A | | | author name = Herdt A |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| | addressee name = | | | addressee name = Nauman D |
| | addressee affiliation = | | | addressee affiliation = SOUTH CAROLINA ELECTRIC & GAS CO. |
| | docket = 05000395 | | | docket = 05000395 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | case reference number = RTR-NUREG-0588, RTR-NUREG-588
| | | document report number = NUDOCS 8806240016 |
| | document report number = 50-395-88-01, 50-395-88-1, NUDOCS 8805100095 | | | title reference date = 05-25-1988 |
| | package number = ML20153E752 | | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 2 |
| | page count = 21 | |
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| .y" *4 UNITED STATES g .j NUCLEAR REGULATORY COMMISSION o * REG!ON 1 MARIETTA ST., N.W - | | .. JUN 10/988 South Carolina Electric and Gas Company ATTN: Mr. D. A. Nauman, Vice President Nuclear Operations (Mail Code 601) |
| ,,,,, ATLANTA. GEORGl#. 30323 Report No.: 50-395/88-01 | | P. O. Box 88 Jenkinsville, SC 29065 Gentlemen: |
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| | SUBJECT: REPORT N0. 50-395/88-01 Thank you for your response of May 25, 1988, to our Notices of Violation issued on May 2,1988, concerning activities conducted at your V. C. Summer facilit We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspection We appreciate your cooperation in this matte |
| 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 l l l
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| Team Leader ,
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| EQ team members and participating inspectors:
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| B. Levis, Region II <
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| 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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| l J. Stoffel, EL l Approved b h C E. Conlon,~ Chief f? /4'f7//'
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| Y 22~$V Date Signe i l
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| Plant Systems Section Division of Reactor Safety SUMMARY l
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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 ;
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| 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 50.4 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 outag )
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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 requirement '
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| l l The Electrical Equipment requiring Environmental Qualification at Sumer are '
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| 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 50.4 The program was evaluated by an
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| 8805100095 880502 PDR ADOCK 05000395 Q DCD
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| | Sincerely, k ~ |
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| | Alan R. Herdt, Chief Engineering Branch Division of Reactor Safety cc: 0. S. Bradham, Station Manager J. L. Skolds, Deputy Director 0perations and Maintenance A. R.-Koon, Jr., Manager Nuclear Licensing J. B. Knotts, Jr., Bishop, Cook, Purcell, and Reynolds W. A. Williams, Jr., Technical Assistant, Nuclear Operations - |
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| | Santee Cooper R. E. Rainear, Executive Vice President, South Carolina Public Service Authority bec: (See page 2) |
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| | 8806240016 DR 880610 - |
| i s t 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 Summe 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 identifie Results: Three violations were identified: (1) Missed EQ Maintenance Requirements, Paragraph 6; (2) Insufficient Infonnation in Qualification File for Lubricants, Paragraph 13.c(1); and (3) Insulation Resistance (IR) Values for !
| | ADOCK 0500039 \g DCD L Z of |
| Performance Characteristics Not Properly Established in Environmental Qualification Files (EQF), Paragraphs 13.c(4) and (5).
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| | m" South Carolina Electric and-Gas Compan bec: NRC Resident Inspector DRS, Technical Assistant - |
| | J. J.' Hayes, Project Manager, NRR Document Control Desk |
| | . State of South Carolina |
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| | en Rg ,y Nee.mdp AR8 er TConlon HDance UPotapops 06/1/88 06/g/88 06/j/88 06/g/88 |
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| REPORT DETAILS Persons Contacted Licensee Employees
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| *S. H. Bailey, Associate, Manager Procurement Engineer
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| *C. W. Bowman, Manager Scheduling
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| *0. S. Bradham, Director, Nuclear Plant Operations, SCE&G
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| *S. G. Carroll, Engineer
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| *R. Clary, SCE&G Manager, Nuclear Engineer
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| * W. Clonts, Manager, Modification and Contractor Services
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| *S. T. Crumbo, Senior Engineer
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| *H. I. Donnelly, Senior Licensing Engineer
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| * R. Heggins, Associate Manager Regulatory Compliance
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| * O. Hicks, Electrical Engineer
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| *S. R. Hunt, Nuclear Quality Control Manager
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| *J. S. Jordan, Engineer
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| * K. Kelly, Principal Electric Engineer
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| *J. C. LaBorde, Senior Er.gineer L&C I&C
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| *D. A. Lavigne, Manager, Materials and Procurement
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| *F. J. Leach, Quality Assurance Manager
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| *F. A. Miller, Jr. , IT&R
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| *G. Moffatt, Associate Manager - Nuclear Engineer, SCE&G
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| *D. R. Moore, Director Quality and Procurement Services
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| *A. A. Morris, Jr. , NCSG
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| * J. Mundy, Senior Engineering Technician
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| *D. Nauman, SCEG, Vice President Nuclear Operations
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| *J. Nesbitt, Electrical Maintenance Supervisor
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| *K. W. Nettles, Group Manager Technical Services
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| *C J. Osier, Associate Manager Maintenance Engineering
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| *A. M. Paglia, Manager, Nuclear Licensing
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| *C. A. Price, Manager Technical Oversight
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| *J. Proper, QA Supervisor, Operations
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| * D. Quinten, Manager, Maintenance Services
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| *A. R. Roun, Manager, Technical Support
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| *J. L. Skolds, Deputy Director, Operations and Maintenance
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| *G. G. Soult, Manager, OPS
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| *J. A. Wactor,,, Senior Electrical Engineer
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| *D. C. Warner, Manager, Nuclear Fuel Management
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| *R. J. Waselus, Electric Supervisor - Nuclear Engineer, SCE&G
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| *T. L. Wessner, Nuclear Engineering
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| *V. H. Willems, Controls System Engineering
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| *F. H. Zander Manager, Nuclear Technical Education and Training Other licensee employees contacted included craftsmen, engineers, technicians, operators, mechtnics, security force members, and office personne . . . . -- .
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| Other Organizations
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| *J. P. Durham, Impell, Corporation, Section Manager
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| *B. A. Karrasch, Impell Corporation, Division Manager l
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| *S. Pauly, Impell Corporation, Supervising Engineer
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| *T. L. Penland, Engineering and Project /GPC
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| * A. Williams, Jr., Sp2cial Assistant, Nuclear Operations - Santee Cooper NRC Personnel and Resident Inspectors
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| * M. Verrelli, Chief, Reactor Project Branch N , Region II
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| *J. J. Hayes, Jr., NRR Project Manager
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| ) *R. Prciatte, Senior Resident Inspector
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| *P. H4, kins, Resident Inspector
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| * Attended exit interview l 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:
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| , Violation 50-395/88-01-01, Missed EQ Maintenarce Requirements, Paragraph i Unresolved item 50-395/88-01-02, Mixed Grease in Limitorque Valve Operators, Paragraph Unresolved Item 50-395/88-01-03, Resolution of NCN-2852 and NCN-2661, Paragraph 1 . Violation 50-395/88-01-04, Insufficient Inform tion in Qualification File for Lubricants, Paragraph 13.c.(1). Violation 50-395/88-01-05, IR Values for Performance Charccteristics +
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| Not Properly Established in the EQFs, Paragraphs 13.c.(4) and (5). ; 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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| . 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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| , 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 ,
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| discussed in paragraphs 6, 12, and 13.c.(9). Electrical Equipment Environmental Qualification (EQ) Program and Procedure Review 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 follo Management Directive 31, Revision 0, defines the requirements of the EQ program for VCSN ,
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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 Grou 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 positiv ;
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| An effort as extensive as that undertaken at VCSNS would not be ,
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| possible without the complete backing of management and the dedication of the staf )
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| i Safety Evaluation Report (SER) Commi'unents Supplement 4 (August 1982) to the VCSNS SER identified four equipment types that were not yet qualifie Supplement 5 dated November 1982 stated that the plant could be safely operated until the first major ,
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| 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 !
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| 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 Regulatory Guide 1.97 Eq;'ipment l
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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 day The licensee stated that the
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| response was being prepared and would be submitted on schedul Except for those three areas, all other equipment required by the >
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| RG 1.97 SIR to be qualified was identified as qualifie . EQ Maintenance Program In 1982, the Computerized History and Maintenance Program System (CHAMPS)
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| 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 schedul 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-G0S068 This is identified as Violation 50-395/88-01 01, Missed EQ Maintenance Requirement !
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| The licensee provided justificat'on to show that the motor in question !
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| remained qualified and would be operable until the maintenance is next i performe 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 ,
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| interva t 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 frequenc Initial investigation of this apparent i
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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 suggestio The five years could be exceeded provide the detector
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| ! exhibited satisfactory calibrat'on rescit 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, 198 It should be noted that this change was effective more than two years ago and few licensees appear to be cognizant of the cha.g 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 ,
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| NCR-1673 indicate Due to finding the additional operators, the licensee ;
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| initiated NCN-2852-46 in January 1988, to address these particular valves / l
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| operator Also, the licensee comitted to perform a follow-up review to ,
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| verify that all Limitorque operators in a harsh environment have had the ,
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| grease change This is Unresolved Item 50-395/88-01-02, Mixed Grease in '
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| Limitorque Valve Operator The results of testing prescribed in NCN-2852-46 will be required to close -
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| this item. The testing is scheduled to be completed prior to start-up i
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| after the Fall 1988 refueling outag 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 ,
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| discovered and the licensee committed to correcting the discrepancies and is in the process of making the correction I 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 ;
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| Services. The procedures governing review of these items were reviewed <
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| and found to be acceptable except for procedure TS-301, Revision 0,
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| "Industry Operating Experience Review." TS-301 did not have any -
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| provisions for routing EQ related reviews to the appropriate Equipment
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| : 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 .
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| months. The licensee cemitted to revise TS-301 to ensure IEN summaries are placed into the EQF The Senior Engineer, Nuclear Safety, is responsible for the handling of !
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| IENs and industry experiences relating to EQ. Discussions with the Senior ;
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| Engineer, Nuclear Safety, indicated that there had been no formal training i
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| ; provided. Further discussion of EQ training is in Paragraph 1 :
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| " Environmental Qualification Master List
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| - 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 198 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 mitigatio These equipment items are listed in FSAP Tables 3.11-0 and 3.11-0 The (
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| equioment was then further categorized to list specific f.ational I requirements, the required accident for which it must operate, and harsh '
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| . 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),
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| 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 qualificatio RG 1.97 equipment appeared on another list included in Tsble 1 to Technical Requirements Package No. TRP-17 Post Accident Monitoring System (PAMS)
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| Instrumentatio 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 ,
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| instrument l EQ Modification Program The licensee's design control program provides controls to ensure applicable regulatory recuirements and design bases are correctly ,
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| 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 ,
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| qualification considerations dt. ring the design process: l 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 Technical Services Procedure No. TS-129, Design Development / Design I Package, Revisio.1 l Technical Services Procedure No. TS-131, Design Varification, ;
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| Revision '
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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 me 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 dat 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 Inde 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 configuratio 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 deficiencie . 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 Manua 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 document 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),
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| 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-12 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
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| "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 recor 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 certification Responsibilities for implementation of the procurement program for EQ equipment has been assigaed to the Director, Quality and Procurement Service 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 proces Additionally, the Quality Engneering staff reviews procurement documents to verify imposition of quality requirements, commensurate with the
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| , 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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| _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ ._ _ _ _ . _ _ _ _ _ _ . . . _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ .
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| .i ', .:
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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 personne It further requires that the proficiency of personnel performing quality-affecting activities be i maintained through retraining, re-examination, and/or recertificatio 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 progra '
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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 provide 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 .
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| 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 member 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 '
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| 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 statu 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 evidenc *
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| this effort appears to be on schedule.
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| l Within this crea inspected, no violations or deviations were identified.
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| _ _ _ _ - _ _ . _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _____._____.________._______._..__________._____________.__._______________.__m____
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| - -- -
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| 10 ,
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| 12. QA EQ Interface -
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| 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 -
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| address the identified orogrannatic deficiencies appeared adequat 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 ;
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| EQ files, and (2) implementation of EQ reqairements in maintenance and i surveillance procedures, and maintenance practices. This narrow scope in ;
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| depth look at the implementation of the EQ program in the performance area ,
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| of maintenance covered functional responsibilities and internal / external >
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| organizational interfaces of the following organizations: Electrical .
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| Services, Procurement !
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| Maintenance, Maintenance Engineering), TechnicalEngineering, Records (EQ ;
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| , and Chemis tr 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 personne This issue was reviewed during -the NRC EQ followup inspection of !
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| 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 :
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| configurations was inadequate EQ training of plant personnel. Based on ;
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| 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.
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|
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| 2 Subsequent to the NRC EQ followup inspection of October, licensee management has reviewed their EQ program to identify progransnatic !
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| j weaknesses, and have performed walkdowns of equipment that is accessible i
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| , during plant operation to verify that installed configuration matches the ,
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| 1 as-tested configuration documented in the EQ file. Maintenance Special l Instructions (MSI) were prepared and used during the equipment walkdown 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
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| . 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, 198 As part of the continuing EQ Enhancement program, deficiencies identified ,
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| 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
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| equipment; and provides Justification for Continued Operation (JCO) for l J
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| equipment not yet inspected. Licensee's actions are in accordance with ;
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| the instructions contained in Generic Letter 86-1 The nature of the deficiencies documented on NCN-2852, (Disposition 42)
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| involved different equipment types and affect various system Additionally, NCN-2661 was prepared to identify, document, and initiate 4 corrective actions for deficient termination of solenoids pigtail Corrective actions for these identified problems are still incomplete.
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| , 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 ite 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,
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| "Resolution of NCN-2852 and NCN-2661."
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| 13. Environmental Qualification Documentation Packages and in Plant Physical Inspection Environmental Qualification Files (EQF)
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| South Carolina Electric and Gas Conpany's EQF are prepared and controlled by Nuclear Engineering. The packages included a Checklist !
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| 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, et 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 condition ; The NRC inspectors examined some 35 EQFs for selected equipment t
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| types. In addition to comparing plant service condition with test
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| ; conc'itions and verifying the bases for these conditions, the
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| 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
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| equipment to that installed in the plant (e.g., insulation class,
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| materials of components of the equipment, tested configuration compared to installed configuraticn, and documentation of both),
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| evaluation of adequacy of test conditions, aging calculations for
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| 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 iI
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| . )*,.:
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| i !
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| , In Plant Physical Inspection ,
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| The NRC inspection team physically inspected 20 qualified components and selected field run cables. The inspection team examined ,
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| 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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| i 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 VCSN The file claimed qualification to NUREG-0588 Cat I 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 similarit Since this file was intended to qualify the Gulf products for the majority of uses, similarity needed to be established with -
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| the other lubricants that the Gulf lubricants were replacin This was not done at the time of inspection. In addition other ,
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| 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 product During the course of the inspection, the licensee gathered needed information to show similarity for the Gulf products and '
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| committed to putting this information into the EQF and to make tne necessary corrections in order to bring the file into
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| ; complianc The licensee also committed to including the I
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| .l 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 !
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| 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 Switche .
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| One concern was noted during review of these file 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
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| ; replacement equipment where necessary by functional review of i
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| ; 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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| l where seals are require 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 necessar (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
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| #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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| d (4) File EQF-C05-C08-1084 - Conax Corp. Electrical Penetration Assemblies (EPAs)
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| The licensee claims qualification to the requirements of NUREG-0588, Category I, based on Conax Test Reports IPS-1089,
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| ; IPS-353.1, and IPS-114 i 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 condition Test Report IPS-325 did not include LOCA i testing for qualificatio 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 !
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| conditions (77'F and 0 psig) and not data taken during LOCA 4 condition I 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 ;
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| VCS-0423-DC15 Loop Accuracy Calculation .
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| The use of IR values provided in the instrument loop accuracy ;
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| , calculation for Ccnax EPAs was not oroperly established in the ,
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| i EQ This is identified as an example of Violation 50-395/ j i I i l l
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| - _ _ - ___________ _ _ _ _ _ _ - - . - - - _ . _ _ _ - _ . - - - - _ - - -
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| 88-01-05, IR Values for Perfonnance Characteristics Not Properly Established in the EQ (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-25 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 >
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| 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 tes The temperature inside the test chamber (containment side of the EPA) was 135' When this data point was plotteo and extrapolated to LOCA conditions, it gave en IR value which was -
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| 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 shel 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 rang Penetrations and connectors used at VCSNS are similar to ones l tested for the Duke Power Company, McGuire and Catawba station l
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| The results are documented in D. G. O'Brien Test Report ER-25 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 stea !
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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 signifien 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, requirement 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 connector Since use of IR values provided in the initial instrument loop accuracy calculation for D. G. O'Brien EPA's was ;
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| 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 EQ (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 I The file contained a section that addressed the Licensee's-esponse to IENs pertaining tc Limitorque Valve Operator 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 operato The l inspection was in accordance MSI No. 20700 and NCN 232 Any internal wire that could not be identified as being qualified was replaced with qualified wir 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 close ,
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| (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 inspecte The licensee was asked to identify and establish qualification for tha cable using the numbers provide ,.)8 a l
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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 file 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 cable (8) EQF-IN6-V05-0682 - Victoreen High Range Radiation Monitor The qualification for the high range radiation monitors was based on NUREG 0583, Category The plant environment was enveloped by the test condition Installed equipment is identical to the tested sample There were questions as to the installed (versus tested)
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| configuration and whether triax cabit. is used versus the tested coax cabl 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 walkdow 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 provide The review of this file and records indicated that qualification was establishe (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 reviewe The analysis provides a review, on an individual instrument loop basis, of IR affects from cabling, connectors, and field splice Generally, the approach and format are very goo All calculations were summarized in individual example IR calculation packages in Appendix H of the file, identified as follows:
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| 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 ,
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| ;- safety-related equipment located in harsh environments; a
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| ' 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 loo 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 analysi The detailed calculations are
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| ! given in Appendix !
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| Some of the items discussed are as follows:
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| (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 * ,
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| value of 10 ohms IR was assumed for these terminal block .
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| 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 !
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| } blocks by four other vendors, this item was resolved, j (b) The document concluded that "positive margins remain for ;
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| 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 explanatio 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
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| error" results inappropriate or overly conservative and are i in the process of reevaluating the allowable error Generally, the approach in the file is good, much has been
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| > 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 Margi . . _ _ _ . __ _ _ _ _ _ _ _ _ - _ _ - . - _ . _ -
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| . . M. s :
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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 effect (d) In conjunction with the review of the D. G. O'Brien file, it was discovered that the IR value inputs for the D.- O'Brien connectors were extrapolations from a linear curve derived from the data points, one taken at 58'F (0 psig)
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| 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 .
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| 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 fil ,
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| (10) EQF-CA4-502-0682 Samuel Moore Instrument Cable, File l The qualification basis is NUREG 0588, Category An :
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| acceptable similarity analysis was provided in the supplemental ;
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| evaluation for the tested cable. An extensive justification was ;
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| provided explaining testing deviations from IEEE 323-1974, stating that testing was done in accordance with IEEE 383-197 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 ion Insulation resistance readings were taken before, after, and during the LOCA simulatio In addition, another 70 day extended exposure was conducted to further verify successful qualification of the sample Questions were raised concerning the IR values used in the instrument loop accuracy evaluations and the specific document that provied this analysi The licensee provide the needed informatio Based on this review it was considered that the cable is qualifie (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 syste 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 ,
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| at 70*C, with aging of 7 days at 136*C. Questions were posed regarding a "General Note 42" and the administrative control of !
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| cable supplies to preclude use in voltage applications in excess of the stated limitation 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 identifie . 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 '
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| 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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| reoccurrenc 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 ;
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| determine the maximum temperatures which could be experienced in these *
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| area The results from these measurements, with some applied conservatisms were used to recalculate the qualified lives of affected equipment item 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 clost !
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