IR 05000413/2019010

Reissue Catawba - Design Basis Assurance Inspection (Programs) Inspection Report 05000413/2019010 and 05000414/2019010

ML20028D021
Person / Time
Site:	Catawba
Issue date:	01/09/2020
From:	James Baptist NRC/RGN-II/DRS/EB1
To:	Simril R Duke Energy Carolinas
References
IR 2019010
Download: ML20028D021 (23)

Text

ary 9, 2020

SUBJECT:

REISSUE - CATAWBA NUCLEAR STATION - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000413/2019010 AND 05000414/2019010

Dear Mr. Simril:

On December 20, 2019 the U.S. Nuclear Regulatory Commission (NRC) issued the Design Basis Assurance Inspection (Programs) report for Catawba Nuclear Station, Units 1 and 2 (ADAMS Accession No. ML19354A856). In review of this report, it was identified that administrative (typographical) errors were present. Specifically, Non-cited Violations (NCVs)

05000413,05000414/2019010-02 and 05000413,05000414/2019010-03 (pages 7 and 9 of the report, respectively) contained incomplete action request (AR) numbers. AR 023011023011(page 7)

and AR 0203601 (page 9) have been corrected to ARs 02300311 and 02303601. We request that the cover letter and report be replaced with the Enclosures to this letter.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 Public inspection, exemptions, requests for withholding of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room, of the Publicly Available Records (PARS) component of NRCs ADAMS; accessible from the NRC Website at https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Please contact me at 404-997-4506 with any questions you have regarding this letter.

Sincerely,

/RA/

James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety ber 20, 2019

SUBJECT:

CATAWBA NUCLEAR STATION - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000413/2019010 AND 05000414/2019010

Dear Mr. Simril:

On November 21, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Catawba Nuclear Station and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Catawba Nuclear Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Catawba Nuclear Station.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the Enclosure NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 05000413 and 05000414 License Nos. NPF-35 and NPF-52

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000413 and 05000414 License Numbers: NPF-35 and NPF-52 Report Numbers: 05000413/2019010 and 05000414/2019010 Enterprise Identifier: I-2019-010-0029 Licensee: Duke Energy Carolina, LLC Facility: Catawba Nuclear Station Location: York, SC Inspection Dates: October 28, 2019 to November 21, 2019 Inspectors: B. Collins, Senior Reactor Inspector C. Franklin, Reactor Inspector M. Greenleaf, Senior Reactor Inspector M. Riley, Reactor Inspector Approved By: James B. Baptist, Chief Engineering Branch 1 Division of Reactor Safety Enclosure 2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at Catawba Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Failure to Qualify GEMS Level Transmitters for Submergence Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N Systems NCV 05000413,05000414/2019010-01 Open The inspectors identified a Green finding and Non-cited Violation (NCV) of 10 CFR 50.49(f)when the licensee failed to demonstrate the GEMS containment sump level transmitter NILT5270 would meet its specified values for one year post-accident during submerged conditions in accordance with Section 6.5.4 of IEEE 323-1974, the standard the licensee chose in order to meet environmental qualification requirements.

Failure to Demonstrate Qualification of Conduit Sealant Compatibility for Electrical Wires and Cables Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N Systems NCV 05000413,05000414/2019010-02 Open The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50.49(f) when the licensee failed to demonstrate the qualification of the conduit sealant and cable/wire interfaces utilizing Scotchcast Epoxy 9 in accordance with NUREG-0588 Section 2.2(7).

Failure to Assess Radiation and Thermal Degradation Effects of Replacement Sealant Equivalency Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.21N Systems NCV 05000413,05000414/2019010-03 Procedure Open Adherence The inspectors identified a Green finding and Non-cited Violation (NCV) of 10 CFR 50.49(f)when the licensee failed to demonstrate that the qualification of Scotchcast Epoxy 9 was applicable to Scotchcast Epoxy 9N in accordance with Section 5.5.7 of procedure AD-EG-ALL-1612.

Additional Tracking Items None

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

===71111.21N - Design Bases Assurance Inspection (Programs)

The inspectors evaluated Environmental Qualification program implementation through the sampling of the following components:

Select Sample Components to Review - Risk Significant/Low Design (Inside/Outside Containment) (IP Section 02.01) ===

(1) 1NDPUAMR, 1A Residual Heat Removal Pump Motor (Westinghouse)

(2) Commodity Item, Okozel Low Voltage Power/I&C Cable (Okenite)

(3) Commodity Item, Scotchcast 9 and 9N Epoxies (3M)

(4) Commodity Item, Terminal Blocks (States- and Stanwick-types)

(5) 1TBOX0019, Terminal Block Enclosure (Hoffman)

(6) 2TBOX0656, Terminal Block Enclosure (Hoffman)

(7) 2CFHP0330, Main Feedwater Pneumatic-Hydraulic Isolation Valve (Borg-Warner)

(8) 1YC362/MO, Hot Gas Bypass Valve Actuator (Jamesbury)

Select Sample Components to Review - Primary Containment (Inside Containment) (IP Section 02.01) (2 Samples)

(1) 1NILT5270, Unit 1 Containment Sump Level Transmitter (DeLaval/GEMS)

(2) 2VXPS5110, Pressure Switch (Solon)

INSPECTION RESULTS

Failure to Qualify GEMS Level Transmitters for Submergence Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N Systems NCV 05000413,05000414/2019010-01 Open The inspectors identified a Green finding and Non-cited Violation (NCV) of 10 CFR 50.49(f)when the licensee failed to demonstrate the GEMS containment sump level transmitter NILT5270 would meet its specified values for one year post-accident during submerged conditions in accordance with Section 6.5.4 of IEEE 323-1974, the standard the licensee chose in order to meet environmental qualification requirements.

Description:

The purpose of GEMS level transmitter 1NILT5270 is to provide post-accident monitoring of Unit 1 containment sump level. EQMM-1393.01-P04-00, Environmental Qualification Maintenance Manual Equipment Type: Level Transmitter Manufacturer: Delaval, Gems Model/Series: XM54852, XM54853, XM60620, XM60625, Rev. 0, stated that the post-accident operating time for the transmitter was one year. The transmitters could be submerged in the containment sump solution during the one-year post-accident requirement.

During the review of the qualification package for the transmitter, the inspectors identified that the loss of coolant accident (LOCA) testing did not simulate submerged conditions and that the post-LOCA testing only simulated a submerged condition for 30 minutes. The inspectors also identified that the EQMM did not analyze how failing to submerge the transmitter during the LOCA test and for only 30 minutes during Post-LOCA testing proved the transmitters could perform their intended function for up to one year post accident.

Additionally, on August 25, 2016, a 10 CFR Part 21 Notification was supplied to the NRC by NTS Huntsville notifying NRC that the qualification tests for the GEMS transmitters did not simulate the submergence depth of 15-16 ft. to the junction box as stated during the 30 minute submergence test. The Part 21 notification stated that the wire conduit was not sealed to the test chamber, but instead was left unattached to the test chamber accident environment. As a result, the submergence test did not demonstrate the junction box gaskets ability to prevent moisture intrusion into the internal components of the GEMs transmitter. In response to the Part 21, the licensee completed an evaluation in AR 02149240 which stated that the GEMS transmitter remained qualified due to the silicon oil fluid in the transmitter acting as a general barrier between any potential moisture intrusion into the transmitter junction box and the junction box wiring internals and that the wiring and splices used in the junction box were installed using Raychem splice products which had been qualified as an EQ environmental seal boundary. Due to questions from the inspectors, the licensee reviewed their evaluation of the Part 21 notification and determined that the failure of the unqualified junction box seal could allow sump fluid to displace the oil and submerge subcomponents of the transmitter. The licensee determined that of the subcomponents installed, only the Raychem Spec 44-insulated transmitter lead wires were not demonstrated to be qualified for submergence in post-LOCA sump conditions by other test reports or analysis.

The EQMM stated that the transmitter was qualified in accordance with IEEE 323-1974.

Section 6.5.4 of IEEE 323 states, The electric equipment type shall be considered to be qualified by demonstrating that the equipment performance will meet or exceed its specified values for the most severe environment or sequence of environments in the equipment specification during its qualified life. The inspectors determined that the qualification package for the GEMS 1NILT5270 transmitter did not demonstrate its ability to perform its function under the most severe conditions (e.g., submergence).

Corrective Actions: The licensee entered this issue into their corrective action program and performed an operability evaluation which determined that there was reasonable assurance that the transmitter could perform its intended safety function based on operating experience and the military specification of the wire which demonstrated the insulations ability to withstand different adverse chemicals.

Corrective Action References: AR 02303851

Performance Assessment:

Performance Deficiency: The failure to demonstrate the GEMS level transmitter would meet its specified values for one year post-accident during submerged conditions in accordance with Section 6.5.4 of IEEE 323-1974, the standard the licensee chose in order to meet environmental qualification requirements.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to qualify the transmitter lead wires by testing or analysis for submergence did not ensure the wires could perform their function under wetted conditions for up to a year post accident.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Att. 4, "Initial Characterization of Findings," issued October 7, 2016, for the Mitigating Systems cornerstone, and IMC 0609, App. A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012, and determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the qualification of a mitigating structure, system, or component (SSC) and the SSC maintained its operability.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR 50.49(f) required, "Each item of electric equipment important to safety must be qualified by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions."

Contrary to the above, since the earliest date of record for the EQMM package in 1991, the licensee failed to qualify the GEMS containment sump level transmitter NILT5270 for submergence by test or analysis for post-accident conditions of one year.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Demonstrate Qualification of Conduit Sealant Compatibility for Electrical Wires and Cables Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71111.21N Systems NCV 05000413,05000414/2019010-02 Open The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50.49(f) when the licensee failed to demonstrate the qualification of the conduit sealant and cable/wire interfaces utilizing Scotchcast Epoxy 9 in accordance with NUREG-0588 Section 2.2(7).

Description:

Duke EQ Files EQMM-1391.01-M01-01, Rev. 3 and CNM 1364.00-0007.001, Rev. D3 contained the licensee's basis for environmental qualification (EQ) of conduit seals utilizing Scotchcast Epoxy 9. In the EQ files, the licensee documented a test report that utilized the epoxy as a sealant to prevent moisture intrusion into equipment electrical conduits in accordance with Category II of NRC NUREG-0588. The focus of the testing was to demonstrate the sealing ability of the epoxy around a pair of tefzel-insulated wires in a Swagelock QF quick-connect pipe fitting by testing a mock-up conduit sealing configuration. The testing generally demonstrated the capability of the epoxy to provide a moisture barrier - but due to the use of de-energized wiring - failed to demonstrate that the interface between the epoxy and wires/cables installed in the field were compatible and capable of performing their functions of providing for the necessary transmission of signals or power. By not demonstrating that the sealant was compatible (i.e. did not adversely impact the electrical function of the wire/cable) with the field configurations, the licensee failed to demonstrate that the field configurations were qualified in accordance with 10 CFR 50.49.

For the conduit sealant locations in the station scoped into the licensee's EQ program, the licensee adhered to Category II requirements of NRC NUREG-0588 for qualification and qualification testing to meet 10 CFR 50.49. Section 2.2(7) of the NUREG states that "performance characteristics be verified before, after, and periodically during testing throughout the range of required operability." By testing the sealant's mechanical sealing function without confirming that the epoxy and wire/cable did not adversely impact their electrical function of passing power/signals to/from important to safety equipment, the licensee failed to demonstrate that the sealant was qualified for the installed configurations in the field.

Corrective Actions: The station entered this into their Corrective Action Program (CAP) as ARs 02300311 and 02303697. Although environmental qualification had not been demonstrated and documented, the licensee identified other tests that had been performed on other wire types with Scotchcast Epoxy 9 (e.g. NAMCO limit switch lead wire and Mark WPA 14 gauge hookup wire). The licensee's review of this additional testing provided reasonable assurance that the installed configurations in the plant would be capable of performing their intended safety functions.

Corrective Action References: AR 02300311 and 02303697

Performance Assessment:

Performance Deficiency: The failure to verify the Scotchast Epoxy 9 sealant cable/wire interface would meet its electrical performance characteristics before, after, and periodically during testing throughout the range of its required operability in accordance with Section 2.2.7 of NUREG-0588 (Category II) was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to ensure that the cable/wire interface with the sealant would not adversely impact the safety function fails to ensure the availability, reliability, and capability of the electrical equipment important to safety that must send or receive power/signals when challenged with the deleterious effects of aging and harsh environmental conditions.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Att. 4, "Initial Characterization of Findings," issued October 7, 2016, for the Mitigating Systems cornerstone, and IMC 0609, App. A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012, and determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the qualification of a mitigating structure, system, or component (SSC) and the SSC maintained its operability.

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: 10 CFR 50.49(f) required, "Each item of electric equipment important to safety must be qualified by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions."

Contrary to the above, since the qualification file for Scotchcast Epoxy 9 had been performed in 2001, the licensee failed to qualify the epoxy by any of the four methods described above.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Assess Radiation and Thermal Degradation Effects of Replacement Sealant Equivalency Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.8] - 71111.21N Systems NCV 05000413,05000414/2019010-03 Procedure Open Adherence The inspectors identified a Green finding and Non-cited Violation (NCV) of 10 CFR 50.49(f)when the licensee failed to demonstrate that the qualification of Scotchcast Epoxy 9 was applicable to Scotchcast Epoxy 9N in accordance with Section 5.5.7 of procedure AD-EG-ALL-1612.

Description:

3M Corporation changed the chemical composition of the Part B of its Scotchcast Epoxy 9 two-part formulation from a nonylphenol component to formulation of cashew, nutshell liq.ccidentale, anacardiaceae, and toluene components. In 2018, the licensee generated an equivalency evaluation in engineering change EC 144757, Rev. 0 to evaluate the differences between the original formulation (Scotchcast Epoxy 9) and the new formulation (i.e. Scotchcast Epoxy 9N). The focus of the evaluation was to determine if the environmental qualification (EQ) performed for the original epoxy was applicable to the new epoxy. The licensee reviewed the material safety data sheets (MSDSs) of the two epoxies, performed durometer testing of representative samples of both epoxies, and performed Fourier Transform Infrared (FTIR) Spectroscopy to determine if the materials were similar enough to warrant the use of the Scotchcast Epoxy 9's qualification file to that of the Scotchcast 9N's. Based on a FTIR high percentage match (>80%) and similar durometer testing, the licensee concluded that the materials were similar enough and qualification of Scotchcast Epoxy 9 was applicable to Scotchcast Epoxy 9N.

The inspectors reviewed the engineering change and noted that FTIR spectroscopy and durometer testing would provide information showing similarity between the chemical constituents and discrepancies in hardness between the two epoxies (respectively), but neither test individually (nor combined) could provide detailed information on how these different epoxies would behave when subjected to the deleterious effects of nuclear radiation and thermal degradation (i.e. aging). Inspectors reviewed the licensee's EQ procedure, AD-EG-ALL-1612, Revs. 3 and 4, and noted that Section 5.5.7(11)(b)(4)(a) stated, in part, that:

"materials of construction shall either be the same or equivalent and differences shall be shown not to adversely affect performance of the safety function." Furthermore, the procedure states that the evaluations should, "evaluate the differences in material properties.

Minor chemical differences can cause significant variations in properties (e.g. radiation-withstand capability, dielectric strength, thermal aging, chemical interactions, and changes in material activation energy."

The licensee's technical review of the differences between the two epoxies lacked the necessary level of detail to demonstrate that the Scotchcast Epoxy 9N - which is chemically different - will age and withstand nuclear radiation in the same (or better) manner than the qualified Scotchcast Epoxy 9. As a result of the inspection, the licensee contacted 3M and determined that mechanical and electrical properties were similar between the two epoxies, however, no radiation or thermal degradation comparisons had been made between the materials.

Corrective Actions: The licensee entered this issue into their corrective action program (CAP)as AR 02303601. The licensee determined that the Scotchcast Epoxy 9N had only been used in four recent work orders and based on a review of the material data sheets and on the technical opinion of the licensee's subject matter experts, the licensee concluded that the four seals in question were capable of performing their safety function.

Corrective Action References: AR 02303601

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to perform an evaluation that appropriately considered the effects of nuclear radiation and thermal aging in accordance with procedure AD-EG-ALL-1612, Section 5.5.7(11)(b)(4)(a) was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform the necessary evaluation of Scotchcast 9N's capability to withstand nuclear radiation and thermal aging failed to ensure the reliability and capability of the Scotchcast Epoxy 9N to perform its safety function of protecting equipment important to safety from the deleterious effects of potential steam and moisture intrusion in the four locations where it had been applied to electrical conduits for the span of their designated life.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Inspection Manual Chapter (IMC) 0609, Att. 4, "Initial Characterization of Findings," issued October 7, 2016, for the Mitigating Systems cornerstone, and IMC 0609, App. A, "The Significance Determination Process (SDP) for Findings At-Power," issued June 19, 2012, and determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the qualification of a mitigating structure, system, or component (SSC) and the SSC maintained its operability.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. This finding is indicative of current performance because the finding occurred within the last 3 years. This finding was assigned a cross-cutting aspect of H.8 because the licensee's failure to adhere to their EQ procedure AD-EG-ALL-1612, Section 5.5.7(11)(b)(4)(a) was the most significant contributor to the performance deficiency.

Enforcement:

Violation: 10 CFR 50.49(f) required, "Each item of electric equipment important to safety must be qualified by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test data that supports the analytical assumptions and conclusions."

Contrary to the above, since the issuance of EC 144757 in 2018, the licensee failed to qualify the Scotchcast Epoxy 9N by any of the four methods described above.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On November 21, 2019, the inspectors presented the design basis assurance inspection (programs) inspection results to Robert Simril and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N Calculations CGD-3007.02-04- Acton Environmental Testing Corporation Test Report: Rev. 5

0001 Attachment States Terminal Blocks and Test Switches

CNC-1206.03-00- Flood Level for Structures Outside the Reactor Building Rev. 26

0001

CNC-1206.03-00- Environmental Effects Due to Pipe Rupture Outside Rev. 3

0004 Containment

CNC-1381.05-00- FWIV Life Extension Rev. 3

0158

CNS-1465.00-00- Design Basis Specification for the Flooding from Internal Rev. 1

20 Sources

CNS-1591.CF-00- DESIGN BASIS SPECIFICATION FOR THE FEEDWATER Rev. 34

0001 (CF) SYSTEM

DPC-1381.05-00- Qualified Life of AGASTAT E7000 Series Timing Relays Rev. 5

0009

DPC-1381.05-00- Electrical Enclosure Latching Environmental Qualification Rev. 0

0017 Analysis

DPC-1381.05-00- Qualified Life Analysis for Brand Rex Flame Retardant Rev. 2

0032 Cross-Linked Polyethylene Insulated Instrument Cable

DPC-1381.05-00- Environmental Qualification (EQ) Evaluation of Equipment Rev. 1

0050 Installed in the Doghouse Buildings

DPC-1381.05-00- Environmental Qualification (EQ) Qualified Life Analysis Rev. 0

0077 (TLAA) for Trane Chiller Controls Supporting CNS License

Renewal

DPC-1381.05-00- Environmental Qualification (EQ) Qualified Life Analysis Rev. 0

0082 (TLAA) for DeLaval, GEMS Level Transmitters Supporting

MNS and CNS License Renewal

71111.21N Calculations DPC-1381.05-00- Environmental Qualification (EQ) Qualified Life Analysis Rev. 1

0087 (TLAA) for Okonite Flame Retardant Ethylene Propolene

(Okonite-FMR) Low Voltage, Control and Instrument Cable

Supporting MNS and CNS License Renewal

DPC-1381.05-00- Environmental Qualification (EQ) Qualified Life Analysis Rev. 0

0093 (TLAA) for Scotch 130C Insulating/Jacketing Tapes

Supporting MNS and CNS License Renewal

DPC-1381.05-00- Environmental Qualification (EQ) Qualified Life Analysis Rev. 000

0104 (TLAA) for Terminal Blocks Supporting MNS and CNS

License Renewal

Corrective Action AR01528008 At Risk Procurement of 3M Scotchcast Resin No. 9 11/13/2014

Documents AR02016420 EQ Rev Tracking 03/31/2016

AR02096602 2017 NRC EQ Program Inspection - Cable/Splice EQML 02/01/2017

Question

AR02149240-01

AR02165587 Fleet License Renewal EQ TLAA Additional Action Tracking 11/14/2017

AR02172829 Tracking of FLRIT EQ TLAA questions to Fleet EQ 12/18/2017

AR022242460 PE-003, Environmental Qualification (EQ) Transformation 11/09/2018

AR02233927 EQ Program Documentation Inefficiencies 09/29/2018

AR02235165 Assignment 1: Develop and execute an EQMM deficiency 10/11/2018

recovery plan

AR02253701 EQ Equipment in a Non-EQ Zone 01/22/2019

AR02275149 Evaluation of WL Sump Pumps Support of CA Operability 05/30/2019

AR02275671 Complete all prep activities associated with CNS EQ NRC 06/04/2019

DBAI

AR02275676 EQ DBAI Self-Assessment - EQML Deficiency 06/04/2019

AR02275676 EQ DBAI Self-Assessment - EQML Deficiency 06/04/2019

AR02275785 2019 CNS EQ DBAI Self-Assessment - EQ Master List 06/05/2019

Data Gaps

AR02276144 EDB discrepancy found during EQ program self- 06/06/2019

assessment

AR02280114 2019 CNS EQ DBAI Focused Self-Assessment AFI#1 07/02/2019

AR02280116 2019 CNS EQ DBAI Focused Self-Assessment AFI#2 07/02/2019

AR02280118 2019 CNS EQ DBAI Focused Self-Assessment AFI#3 07/02/2019

AR02280121 2019 CNS EQ DBAI Focused Self-Assessment AFI#4 07/02/2019

71111.21N Corrective Action AR02280125 2019 CNS EQ DBAI Focused Self-Assessment AFI#5 07/02/2019

Documents AR02283803 2019 CNS EQ DBAI Focused Self-Assessment AFI#8 07/25/2019

AR02284923 2019 CNS EQ DBAI Focused Self-Assessment AFI#6 08/01/2019

Corrective Action AR02294978 2019 DBAI EQ Mechanical Components Incorrectly 10/02/2019

Documents Labeled EQ=H

Resulting from AR02295176 2019 DBAI EQ Housekeeping and Material Condition in U2 10/02/2019

Inspection DH

AR02296270 Update EQMMs to Incorporate EQ Document Package 10/09/2019

AR02296584 Items Listed in EQMM not in EDB 10/10/2019

AR02298945 1CFHP0660, Armored Cable Pulled out of Junction Box 10/24/2019

AR02298957 2CA-66B; Armored Cable Pulled from Junction Box 10/24/2019

AR02298964 2BB-148B, Connector Pulled back from Elbolet 10/24/2019

AR02298990 2CF SV 0901; Missing Screw on Junction Box Cover Panel 10/24/2019

AR02299853 2019 NRC DBAI EQ - DPC-1381.05-00-0104 10/29/2019

Documentation Error

AR02299853 2019 NRC DBAI EQ - DPC-1381.05-00-0104 10/29/2019

Documentation Error

AR02299853 2019 NRC DBAI EQ - DBC-1381-05-00-0104 10/29/2019

Documentation Error

AR02300081 2019 NRC DBAI EQ - NCR 02233927 Screened Incorrectly 10/30/2019

AR02300307 2019 NRC DBAI EQ - EQ procedure Issues with Sealant 10/31/2019

Use

AR02300311 2019 NRC DBAI EQ Scotchcast 9 Resin Testing Issues 10/31/2019

AR02300347 2019 NRC DBAI EQ: Lack of EQMM for TBOX enclosures 10/31/2019

AR02300347 CNS 2019 NRC DBAI EQ - EQ Documentation for 10/31/2019

Electrical Enclosure Latches Missing Information

AR02300415 2019 NRC DBAI EQ: EQMM clarification report for 11/01/2019

submergence

AR02300438 2019 NRC DBAI EQ, DPC 1381.05-00-0104 has error in 11/01/2019

table

AR02300438 2019 NRC DBAI EQ - DPC 1381.05-00-0104 Error in 11/01/2019

Tabled Data

AR0230081 2019 NRC DBAI EQ - NCR 02233927 Screened Incorrectly 10/30/2019

71111.21N Corrective Action AR02303599 2019 NRC DBAI EQ - EQMM-1393.01-P04-00, DeLaval, 11/20/2019

Documents Gems

Resulting from AR02303601 2019 NRC DBAI EQ Scotchcast 9N Equivalency 11/20/2019

Inspection AR02303602 2019 NRC DBAI EQ - EQMM-1393.01-G04-00, 11/20/2019

Westinghouse Motors

AR02303697 2019 NRC DBAI EQ Electrical Continuity Testing Not 11/20/2019

Performed

AR02303697 2019 NRC DBAI EQ Electrical Continuity Testing Not 11/20/2019

Performed

AR02303851 2019 NRC DBAI EQ: Raychem Spec 44 Wire No 11/21/2019

Submergence Qualification

AR02306022 2019 NRC DBAI EQ - Scotchcast 9/9N EQ File 12/05/2019

AR02306022 2019 NRC DBAI EQ - Scotchcast 9/9N EQ File 12/05/2019

Drawings CN-1499-CF.12-00 SG Feedwater Isolation Instrument Detail Rev. 9

CN-1702-02.01 One-Line Diagram 4160V Essential Auxiliary Power System Rev. 18

(EPC) 4160V Switchgear No. 1ETA

CN-1721-21.09 Catawba Nuclear Station Panel Cutout Sheet, Stanwick- Rev. 7

Type DG Sliding Link Terminal Blocks

CN-1721-21.21 Catawba Nuclear Station Panel Cutout Sheet, States Co. Rev. 1

Type-ZWM-Sliding Link Terminal Block

CN-1734-01.04 Connection Diagram Safety Injection System (NI) B-Train Rev. 15

Motor Operated Valves 1NI010B, 1NI005B, 1NI178B,

1NI183B & 1TBOX0019

CN-2747-01.02-16 Connection Diagram Feedwater System (CF) Doghouse Rev. 001

Level Switches

CNEE-0151-01.03 Elementary Diagram Safety Injection System (NI) B.I.T. Rev. 10

Discharge Isolation Valve 1NI010B

CNEE-0151-01.45 Elementary Diagram Safety Injection System (NI) ND HDR Rev. 13

to N.C. Cold Legs A and B Valve 1NI178B

CNEE-0151-01.46 Elementary Diagram Safety Injection System (NI) NS HDR Rev. 12

to N.C. Hot Leg Isolation Valve 1NI183B

CNEE-0245-01.05- Elementary Diagram Main Feedwater Sys. (CF) Doghouse Rev. 9

Safety Level Switches Train A

CNM 1210.04- 323 Transmitter Bottoming/Transfer Type, Bracket MTD., 12/16/1993

0434 001 J/Box Output

71111.21N Drawings CNM 1210.04- Installation Specifications Transmitter Wiring and Mounting 7/27/1995

0438 001

CNM-1205.12- Operator Pneumatic Hydraulic Rev. 6

0050.002

CNM-1205.12- Operator Pneumatic Hydraulic Unit 1&2 Valves Rev. 9

0050.003 1(2)CF33,42,51,60

CNM-1205.12- Cylinder Assembly Hydraulic Operator Rev. 3

0050.004

CNM-1205.12- Reservoir Assembly Hydraulic Operator Rev. 7

0050.005

MCM 1210.04- Splicing & Sealing Procedure Rev. DC

215 001

Engineering EC0000094280 CD201315 - CMP - Revise FWST Level Set-Points and Rev. 3

Changes Annunciators

EC0000408141 Revise EQMM to Include New Sections for EQ Cables & Rev. 0

Splices

EC0000408781000 CN/MC/ON, CGI, PQL2, various Type ZWM Terminal Rev. 0

Blocks, States, MIR/RWF

EC0000411757 CN/M/

O. EE. PQL2, 9230027814, Electrical Resin, 3M, Rev. 0

WB/DT

EC400046 C, CGI, Q2, Various, Enclosures, Hoffman, LFC/KCM Rev. 0

Hoffman Enclosures

Engineering CGD-3007.02-00- Stanwick Electrical Products, Terminal Block Pole Rev. 0

Evaluations 0004

CGD-3010.02-06- 3M Company Scotchcast Electrical Resin No. 9 Rev. 19

0001

CGD-3010.02-13- Attachment 7: Environmental Qualification Parameter Rev. 1

0001 Summaries for the various Dow Corning products

CGD-3015.01-01- Technical Evaluation: Commercial Grade Evaluation - Rev. 2

0001 Enclosures

Miscellaneous ADAMS Accession Potential Part 21 on Wyle Laboratories Test Report Nos. 04/25/2016

No. ML16155A354 45700-1 Rev. A dated November 21, 1988, and 45700-2

Rev. A dated November 21, 1988, Submergence Test of

Gems Liquid Level Transmitter

CNLT-1780-03.02 Response to NUREG-0588 Rev. 8

71111.21N Miscellaneous CNLT-1780-03.03 Environmental Qualification Criteria Manual (EQCM) Rev. 35

CNM 1210.04- Wyle Labs Test Report 45700-2 Rev. 2

0433.001

CNM 1211.00- Qualification Report for Traine CH531 Chiller Controls Rev. 3

2492.037

CNM 1318.00- Motor Qualification Report, WCAP 8754 Rev. 4

0004.001

CNM 1354.00- Qualification Test of Instrument Cable in a Simulated SLB & Rev. 2

0070.001 LOCA Environment

CNM 1362.00- Test Report on the Environmental Evaluation of Terminal Rev. 02

0004, TR-028 Blocks for McGuire Nuclear Station

CNM 1364.00- Environmental Qualification of Electrical Insulating Tape for Rev. 1

0005.001 McGuire and Catawba Nuclear Stations

CNM 1364.00- EQR of Quick-Connect Fittings Used as Cable Entrance Rev. D3

0007.001 Seals

CNM-1205.12- Feedwater Isolation Valve Pneumatic-Hydraulic Operator Rev. 26

0013.001 O&M Manual

CNM-1205.12- Environmental Qualification Report for BWFC FWIV Rev. 7

26.001 Actuators

CNM-1354.00- Engineering Report No. 344 - Main Steam Line Break Rev. 1

26 Qualification Test on Okozel Insulation

CNM-1399.05- 3m Scotchcast Electrical Resin 9N Data Sheet Rev. 0

0366.001

CNS- Elector-Hydraulic-Pneumatic Actuator and Spare Parts for Rev. 2

205.12.00.0002 Feedwater Isolation Valves

CNS-1354.04-00- Specification: Shielded and Unshielded 600 Volt Rev. 0

0006 Switchboard and Hook up Wire

DPM-1393.01- Environmental Qualification Package For Raychem Rev. D04

0001 Corporation WCSF-U Heat Shrink Tubing

DPM-1393.01- EQ Test Summary for Solon Pressure Switches Rev. 000

0040.001

DPM1393.01- Duke Power Test Summary For: Equipment Type: EGS Rev. 1

0019.001 Tape Splices Manufacturer: SAIC/EGS Division

Model/Series No: SCOTCH 130C Insulating/Jacketing

Tapes Report #EGS-TR-399.16-16

71111.21N Miscellaneous EGS-TR-880707- Test Report for Submergence Qualification of Raychem 10/05/1990

WCSF-N Nuclear Line Cable Splice Assemblies for

Shearon Harris Nuclear Plant

EQMM-1393.01- ENVIRONMENTAL QUALIFICATION MAINTENANCE Rev. 10

A04-00 MANUAL EQUIPMENT TYPE: FWIV ELECTRO-

HYDRAULIC-PNEUMATIC-ACTUATOR:

MANUFACTURER: BORG-WARNER MODEL/SERIES:

PART NO. 37981

EQMM-1393.01- Environmental Qualification Maintenance Manual - Low Rev. 0

C03-00 Voltage Power, Control and Instrumentation Cable /

Okenite / Okozel Tefzel (280) Extruded Insulation System

EQMM-1393.01- Environmental Qualification Maintenance Manual Rev. 3

M01-00 Equipment Type: Commercial Grade/Approved Vendor

Items

EQMM-1393.01- Environmental Qualification Maintenance Manual Rev. 3

M01-01 Equipment Type: Connector Manufacturer: Swagelok Model

Series: QF Series Quick-Connect

EQMM-1393.01- Environmental Qualification Maintenance Manual Rev. 2

M01-04 Equipment Type: Electrical Enclosure Latches -

Manufacturer: Hoffman - Model/Series: A-L31, A-

FC412SS, A-FT44XSS

EQMM-1393.01- Environmental Qualification Maintenance Manual Rev. 8

N04-00 Equipment Type: Differential Pressure Switch Inside

Containment; Manufacturer: Solon; Model/Series:

7PS1ADW / 7PS11DW / 7PSW11D2 / 7PSW1AD2

EQMM-1393.01- Devals, GEMS Level Transmitter Environmental Rev. 10

P04-00 Qualification Maintenance Manual

EQMM-1393.01- ENVIRONMENTAL QUALIFICATION MAINTENANCE Rev. 2

R02-00 MANUAL - EQUIPMENT TYPE: CHILLER CONTROLS -

MANUFACTURER: TRANE (SUPPLIED BY: NUCLEAR

LOGISTICS, INC. (NLI)) - MODEL / SERIES: CH531 &

ASSOCIATED COMPONENTS

MCM 1211.00- Nuclear Environmental Qualification Report: Solon Rev. 0

1505-001 Differential Pressure Switches for McGuire Nuclear Power

Station, Units 1 & 2

71111.21N Miscellaneous MCM 1211.00- Addendum 1 to CCL Report on Envir. Qual. of Solon DP Rev. 002

1505-002 Switch

MCM 1393.02- Test Report on the Effects of Radiation Exposure on Some Rev. 00

0007, TR-047 Class 1E Electrical Components for the McGuire Nuclear

Station

Procedures AD-EG-ALL-1103 Procurement Engineering Products Rev. 4

AD-EG-ALL-1612 Environmental Qualification (EQ) Program Rev. 4

AD-EG-ALL-1612 Environmental Qualification (EQ) Program Rev. 3

AD-PI-ALL-0100 Corrective Action Program Rev. 21

IP-0-A-3010-021 Nitrogen System Charging for Main Feedwater (CF) Isolation Rev. 23

Valve Operators

IP-0-A-3010-022 Removal and Installation of Rev. 9

Main Feedwater (CF) Isolation Valve Operators

IP-0-A-3190-004 Maintenance Procedure for YC System Hot Gas Bypass Valve Rev. 5

Actuator

IP-2-A-3010-020 Unit 2 Main Feedwater (CF) System Calibration of Feedwater Rev. 10

Isolation Valves Pneumatic-Hydraulic Operators

IP/0/A/0200/029 A Sealing Cable Entrance Fittings on Class 1E Devices Rev. 35

IP/0/A/3820/020 Q Namco Limit Switch Replacement for Utilizing Quick Rev. 13

Connectors

IP/0/A/3850/013 A Procedure for Cable Termination Sealing Rev. 64

IP/0/A/3850/013 B Procedure for Sealing Rigid Steel Field Run Conduit Rev. 13

MP-0-A-7200-008 Feedwater Isolation Valve Corrective Maintenance Rev. 22

MP-0-A-7450-024 YC CHILLER HOT GAS BYPASS VALVE REMOVAL AND Rev. 11

REPLACEMENT

OP.0.A.6450.011 Control Room Ventilation/Chilled Water System Rev. 146

PT-2-A-4200-009 Engineered Safety Features Actuation Periodic Test Rev. 170

PT-2-A-4200-018B CF Valve Inservice Test (CS) Rev. 21

Self-Assessments 02276400 Focused SAST: CNS EQ Program DBAI NRC inspection 06/06/2019

Work Orders 01713620

01810701

2073010

2079985

20033963

18