IR 05000298/1986028
| ML20205T191 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/16/1987 |
| From: | Ireland R, Andrea Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205T102 | List: |
| References | |
| 50-289-86-28, 50-298-86-28, IEIN-86-003, IEIN-86-3, TAC-42486, TAC-68378, NUDOCS 8704070233 | |
| Preceding documents: |
|
| Download: ML20205T191 (35) | |
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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-298/86-28 License: DPR-46 Docket: 50-298 Licensee: Nebraska fut'ic Power District P. O. Box 45)
Columbus, N wraska 68601 Facility Name: Cooper fluclear Station Inspection At: Brownsville, Nebraska
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Inspection Conducted: November 3-7, 1986 Inspector: 8 Y M 8/s3/87 A.(R. Jo nson, Reactor Inspector (Nuclear Date ' /
E ~ r), Team Leader, RIV Also participating in the inspection and contributing to the report were:
't. Heishman, Chief, Vendor Program Branch, DQAVT, IE R. Ireland, Chief, Engineering Section, RSB, DRS/P, RIV D. Norman, Reactor Inspector (Nuclear Engineer), RIV R. Lasky, Equipment Qualification & Test Engineer, VPB, DQAVT, IE J. Grossman, Member of Technical Staff, Sandia Normal Laboratories (SNL)
M. Yost, Consultant Engineer, Idaho National Laboratory (INEL)
A. Nolan, Consultant Engineer, INEL Approved By:
R. E. Ireland, Chief, Engindering Section 3//4 /77 D(te '
Reactor Safety Branch Inspection Summary:
Inspection on November 3-7, 1986 (Report No. 50-298/86-28)
Areas Inspected: Special, announced inspection to review the licensee's implementation of a program for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. The inspection also
, included evaluations of the implementation of equipment qualification (EQ)
corrective action commitments. These commitments were made by the licensee as a result of (1) the January 30, 1985 Safety Evaluation Report (SER); (2) the December 9, 1982, SER and November 24, 1982, Franklin Research Center Technical 8704070233 870401 i PDR ADOCK 05000289 G PDR
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Evaluation Report (TER) enclosed with it; and (3) the licensee's proposed method of. resolution for each of these EQ deficiencies documented in Nebraska Public Power District (NPPD) response letter to NRC of April 24, 1984, regarding the agreements reached during the March 29, 1984 meeting between NPPD and NRC.
Results: The inspection determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49 except for certain deficiencies as listed in the following tables I and II.
No deficiencies were found in the licensee's implementation of corrective action commitments made as a result of identified deficiencies in the (1) January 30, 1985, SER; (2) December 9, 1982, SER/ November 24, 1982, FRC TER; and (3) NPPD response letter of April 24, 1984, documenting corrective action commitments as a result of the March 29, 1984 meeting between NPPD and NR _ . _ _ _ . _ . _ _ _ . . . . . . _ _ _ . _ _
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Table I l
Potential Enforcement / Unresolved Items:
Report Item j Name Paragraph Number Boston Insulated Wire (BIW), 4.f(1) 298/8628-01 Bostrad 7E Cable; functional
} performance requirements not 1 demonstrated I BIW Coaxial Cable, 4.f(2) 298/8628-02 i RG59B/4; documentation i not auditable Kerite 600 Volt Cable, Type HTK/FR; 4.f(3) 298/8628-03 j failed acceptance criteria
! Raychem Coaxial Cable, 4.' f(5) 298/8628-04 l Rayolin R and F; similarity
not demonstrated I
j Electrical Penetrations, 4.f(6) 298/8628-05 ;
General Electric Co.
l Model 238X600NSGI; similarity j not demonstrated
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! Various Pressure / Level Switches 4.f(7) 298/8628-06 and Transmitters; mounting,
- orientation, and interfaces in l the EQDP, inadequately documented t ~
1 Fenwal/Patel Temperature Switch 4.f(8) 298/8628-07' l
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Model 01-170020-090; Thomas &
i Betts STA-KON Cable Splices; ,
qualification not based on full l
accident conditions I Limitorque Motor Operators, /8628-08
- Series SMB, Internal Wiring; l (1) polybutadiene analysis,
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(2) undocumented test results,
- (3) Scotch tape and blind barrel splices; similarity not established Limitorque Motor Operators, 4.h(1)(a) 298/86028-09 Series SMB; Okonite
! Motor Lead Splices; similarity l not demonstrated i
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- Open Items
I Report . Item Name Paragraph Number Rockbestos Cerro Firewall III 4.f.(9) 298/8628-10 Cable; documentation deficiencies
i Microswitch Limit Switches, 4. f. (10)(b) 298/8628-11 Models OP-N; maintenance identified in EQDP inadequate Microswitch (Limit Switches) 4.f.(11)(b) 298/8628-12 i
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Model DTE6-2RQ62; 4.f.(11)(c)
documentation deficiencies
!' Microswitch Limit Switches 4.h.(5) 298/8628-13 Models OP-N and DTE 6-2RQ62; I walkdown deficiencies ASCO Solenoid Valves, 4.f.(12)(b) 298/8628-14 l
Type HVA-90-405-2A, 4. f. (12)(c)
WPHT-8316E-36, and NP-1; 4.f.(12)(d)
- documentation deficiencies 4.f.(12)(e)
! ASCO Temperature Switch, 4.f.(13)(b) 298/8628-15'
i Model SA11AR and 4.f.(13)(c)
- OJ 11A4R; 4.f.(13)(d)
l documentation deficiencies
i ASCO Solenoid Valves, Type 4.h.(4)(a) 298/8628-16 l HVA-90-405-2A, WPHT-8316E-36, 4.h.(4)(b)
J and NP-1; j walkdown deficiencies I.
i Target Rock Solenoid Valves, 4.f(14)(b) 298/8628-17 !
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Model 1/2-SMS-A-01-01; 4.f(14)(c) i i documentation deficiencies 4.f(14)(d) '
, Static-0-Ring Pressure 4.f.(15) 298/8628-18 Switches, TA Series;
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(1) venting of replacement switch housings
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(2) documentation deficiencies i
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Open Items (continued):
Report Item Name Paragraph Number j 1 Barksdale Pressure Switch, 4.f.(16) 298/8628-19
, Model 82TM1255 and B2T-AISS; documentation deficiencies 1 Rosemount Transmitters 4.f(17) 298/8628-20 Model 1153 Series B; additional analysis for
, synergistics effects require . Rosemount Transmitter, Model j 1153D B/11590P, 4.f(18) 298/8628-21
- with Remote Seal System; additional analysis to include capillary insulation is require . Limitorque Motor Operators 4.f(19) 298/8628-22
, Model SMB-00 and SMB-2; documentation deficiencies 1 Limitorque Motor Operators 4.h(1)(b) 298/8628-23 Model SMB-4; broken wire lead 1 Limitorque Motor Operators 4.h(2) 298/8628-24 l
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Model SMB-3 and SMB-00; removal of grease relief shipping caps.
i 1 Reliance Motors; 4.f(20) 298/8628-25 l: documentation deficiencies 1 GE Motor, Model 4.f(21) 298/862P-26 5X6346XC74A and
, 5X6346XC84A; ,
i' documentation deficiencies l
1 GE Motors, Model 5K6346XC74A 4.h(3)(a) 298/8628-27 i and 5K6346XC83A; inadequate
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4.h(3)(b) l maintenance 1 i
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1 EQ Cable Identification; 4.f(4) 298/8628-28 l i
generic cable traceability a
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problem
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DETAILS 1. Persons Contacted:
NPPD J. M. Pilant, Technical Staff Manager, Nuclear Power Group G. A. Trevors, Division Manager, Nuclear Support K. Walden, Licensing Manager G. Horn, Division Manager of Nuclear Operations J. M. Meacham, Sr. Manager of Technical Support Services E. M. Mace, Engineering Manager G. E. Smith, QA Manager (Acting)
R. Brungardt, Operations Manager D. M. Norvell, Maintenance Manager J. V. Sayer, Radiological Manager J. R. Flaherty, Plant Engineering Supervisor R. Minadeo, EQ Coordinator (Acting)
H. A. Jantzen, I&C Supervisor J. Hackney, Electrical Supervisor (Acting)
G. R. Smith, Licensing Engineer G. Cook, Licensing Specialist T. Browne, Engineering Specialist N. R. Dingman, Engineering Specialist J. Hinz, General Employee Instructor / Training Department NPPD Consultants R. Minadeo, Patel Engineers (NPPD, Acting EQ Coordinator)
R. A. Hamric, Patel Engineers S. J. Jobe, Patel Engineers
'j E. A. Troncelliti, Patel Engineers P. A. Bender, ECS, In R. K. Ho, EPM, In M. T. Watson, Stone & Webster U.S. NRC D. L. DuBois, Senior Resident Inspector I E. A. Plettner, Resident Inspector 2. Purpose i
The purpose of this inspection was to review the licensee's implementation 1 of the requirements of 10 CFR 50.49, and the implementation of corrective action commitments made as a result of identified deficiencies in the (1) January 30, 1985 SER; (2) December 9, 1982 SER and November 24, 1982 TER; and (3) NPPD response letter to NRC of April 24, 1984, regarding the March 29, 1984 meeting between NPPD and NR __ -
l 7 l 3. Background On March 29, 1984, the NRC held a meeting with the licensee to discuss a TER which had been prepared for the NRC staff by Franklin Research Cente The discussion centered on open issues regarding environmental qualification at CNS, including acceptability of environmental conditions for EQ purpose The meeting covered NPPD's proposed methods to resolve the EQ deficiencies identified in the December 9, 1982 SER and November 24, 1982 TER. Discussions also included NPPD's methodology for compliance with 10 CFR 50.49, and justification for continued operation (JCOs) for those equipment items for which EQ was not yet completed. The minutes of the meeting and proposed methods of resolution for each of the EQ deficiencies were documented in NPPD's response to the NRC on April 24, 1984, which addressed each item for which EQ was not yet completed (see Section 4.d). Earlier and subsequent responses to these identified deficiencies were documented in licensee submittals to the NRC on January 2,17, and 24, May 20, and June 24, 1983, December 26, 1984, February 15 and March 26, 1985, July 21, August 8 and September 8, 198 NPPD requested a schedular exemption to the 10 CFR 50.49 (g) requirements (e.g. , identify the EQ equipment, and schedule a goal for final EQ by the second refueling outage after March 31, 1982) by letter to NRC dated June 24, 1983, and was granted the exemption until March 31, 1985 (NRC letter to NPPD, October 3, 1983). FM lowing this date, NPPD further requested exemption beyond March 31, '985, for reactor equipment cooling (REC) pump drive motor replauments due to procurement lead time (NPPD letter to NRC dated February 15, 1985). The extension of the March 31, 1985, exemption date to November 30, 1985, for REC pump drive motor replacements, was granted (NRC letter to NPPD dated March 26, 1985).
On January 28, 1985, NPPD certified (affirmed to NRC by letter in response to NRC Generic Letter 84-24) compliance to 10 CFR 50.49 in that (1) the EQ program at CNS satisfies the 10 CFR 50.49 requirements by formal implementation through CNS procedures; (2) CNS has EQ equipment for both paths to safe shutdown fully qualified; and (3) all other EQ equipment within the scope of 10 CFR 50.49 (other than the REC pump drive motor exemption) is fully qualified, or will be qualified (JC0's) prior to completion of his current outage and startup during late May 1985. This excludes equipment related to the Regulatory Guide (RG) 1.97 program which would be qualified under a separate implementation schedul On January 30, 1985, the SER for final resolution of EQ of electrical equipment important to safety for CNS was issued by the NRC. This SER found (1) NPPD's proposed resolutions of EQ deficiencies acceptable; (2) NPPD's approach for compliance with the 10 CFR 50.49 requirements acceptable; and (3) JCO's for those equipment items for which EQ was not yet complete, at that time, acceptable. The January 30, 1985, SER listed 33 equipment items currently under JCOs for which completion of EQ was required prior to the end of the May 1985 startup date.
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NPPD's letter and submittals to NRC on March 1 and April 16, 1984, provided a separate status and schedule for implementation of a program to provide instrumentation to monitor plant variables and systems during and following an accident (RG 1.97, Revision 2). A review of this submittal by INEL (Contractor for NRC) concludes CNS has an explicit commitment to conform to the RG 1.97 guidelines (letter NRC to NPPD dated March 11, 1985). Subsequent NPPD letters of March 6 and May 24, 1985, reflect further changes in this separate impleaentation schedule (cited for completion in 1988-89).
The above identified documents were reviewed by the inspection team members and used in preparation for this inspectio . Findings EQ Program Compliance with 10 CFR 50.49 The NRC inspectors examined the licensee's program for establishing the qualification of electric equipment within the scope of 10 CFR 50.4 The program was evaluated by examination of the licensee's qualification documentation files, review of procedures for controlling the licensee's EQ efforts, and verification of adequacy and accuracy of the licensee's program for maintaining the qualified status of electrical equipment. Based on the inspection findings, which are discussed in more detail below, the inspection team determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49 for the CNS although some deficiencies were identified (Refer to Sections 4.f and 4.h), EQ Program Procedures The inspection team examined the implementation and adequacy of corporate and site policies and procedures for establishing and maintaining the environmental qualification of electrical equipment in compliance with the requirements of 10 CFR 50.49. The licensee's o thods for establishing and maintaining the environmental qualification of electric equipment were reviewed in the following documents:
CNS Operations Manual - Engineering Procedures Proc N Title Station Design Changes, Revision . Temporary Design Changes, Revision 0.
l 3.11 Vendor Contact for Verification of Manuals, Revision 0.
l 3.1 EQ Program Implementation, Revision 0.
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3.1 EQ Data Package, Revision .1 EQ File Control, Revision .1 EQ Equipment Replacement Evaluation Procedure, Revision .1 EQ Age Related Degradation Equipment Evaluation, Revision .1 EQ Evaluation Guidelines, Revision r 3.13 Equipment Classification, Revision CNS Operations Manual - Procedures Proc N Title 0.20 Equipment Qual *fication, Revision .24 Generating and Dispositioning Vendor Manual Change Requests, Revision .25 Vendor Manual Change Order Review and Approval, Revision i
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O.26 Surveillance Programs, Revision CNS Operations Manual - Administrative Services Procedures
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Proc N Title Requisitioning, Revision .8 Wareh'ouse Issue and Return, Revision . 9 Control and Retention of Records, Revision .10 Document Control, Revision .11 Essential Spare Parts 1 Program, Revision !
CNS Operations Manual - Maintenance Procedures Proc N Title 7. Work Item Tracking - Corrective Maintenance, Revision 5 7. Work Item Tracking - Preventative Maintenance, Revision 1 7. Maintenance Quality Control Program, Revision 3.
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6.2.2.3.6 HPCI Pump Low Suction Pressure Calibration and Functional /
Functional Test, Revision 13 6.2.2.4.4 CS Loops A and B Core Spray Initiation (Pump and Valve Control) Functional Test, Revision 11 7.2.50.1 EQ Inspection Procedure for Limitorque Operators, Revision 1.
7.3.24 HFA Relay Coil Replacement, Voltage Pickup, and Contact Adjustment, Revision 2 7.3.25 MSIV Namco EA-180 Limit Switch Maintenance, Revision 2.
7.3.26 Qualified Electrical Splice and Motor Termination Insulating, Revision 0.
7.3.26.1 Environmental Qualified Okonite Tape Wrapped Splices and Terminations (Bolted), Revision 0.
7.3.26.2 Environmental Qualified Okonite Tape Wrapped Splices and Terminations (Crimped)
7.3.33 Electrically Disconnecting and Connecting Limitorque Valve Operators, Revision 2
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CNS Operations Manual - Instrument and Control Procedures Proc N Title 7.5. Scram Pilot Valves, Revision 7 The inspection team reviewed the above licensee's procedures for meeting the requirements of 10 CFR 50.49 including (1) qualified life; (2) service conditions; (3) periodic testing; and (4) maintenance and surveillance. The licensee's EQ program was also reviewed with regard to establishment of an auditable documentation file, including such documents as EQ audit reports, maintenance and surveillance records, supporting documents which establish EQ training of personnel, and supporting documents which control plant modifications, procurement, and installation of replacement equipment to the requirements of 10 CFR 50.49.
The licensee's EQ program procedures and policies are established and are being adequately implemented to control and maintain the ,
l environmental qualification at electrical equipment at CNS for compliance with the requirements of 10 CFR 50.4 _
c. EQ Surveillance / Maintenance / Replacement Parts / Control of Plant EQ Modifications / Training / Audit Programs The following programs were effectively in place at CNS:
(1) EQ Surveillance Programs The CNS plant engineering supervisor is responsible to recommend through the CNS maintenance and operations manager, the required preventative maintenance activities, to maintain EQ items by the surveillance schedule, which are implemented through CNS maintenance procedures, preventative maintenance system procedures, and surveillance procedures. The preventative maintenance (PM) section of the work item tracking system (WITS)
is used at the CNS plant to provide station personnel with a means to schedule and document P PM items are scheduled at frequencies of months, refueling cycles, or plant outage However, CNS PM's are scheduled at fixed calendar intervals based on initial date. Some test equipment are on a slip schedule based on their last completion date. PM activities are categorized into PM types such as calibration, lubrication, visual observations, et PM's performed are documented for scheduling purposes and recorded in the CNS equipment history file. When a need for corrective maintenance arises, during the PM activities, an authorized maintenance work request (MWR) is issued for immediate action. The safety classification of equipment is identified on the PM request which requires the essential EQ components qualified to 10 CFR 50.4 The NRC inspection team reviewed the procedures (paragraph above) and controls for the CNS surveillance program to verify that this program is effectively being implemented. Further verification will be accomplished during a subsequent NRC inspectio No Potential Enforcement / Unresolved Items or Open Items were identifie (2) EQ Haintenance Program l The CNS maintenance supervisor is directly responsible for the .
proper maintenance, calibration, and testing of all )
electrical EQ systems and components, and is directly responsible to the CNS maintenance manage The WITS is used to identify work items at CNS that require maintenance and repair, and is the mechanism to enforce their orderly accomplishment using MWR's. The WITS forms are initiated by CNS personnel to fully describe corrective maintenance activities, obtain all pertinent information, and identify available reports, control room work item file records, and computer informatio The safety classification of equipment is identified in the WITS j l
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-.-_ form requiring essential EQ electrical components to be qualified to 10 CFR 50.49 requirements. The MWR's are compiled by computer using the WITS form. Emergency maintenance work activities are initiated by shift supervisors using the emergency maintenance work request (EMWR) in lieu of the WITS for Results of EQ corrective maintenance (CM) ac ;ities are under review of the CNS system engineers, operations supervisors, and maintenance supervisors. CNS has their systematic quality control activities established within their maintenance quality control progra CNS has an ongoing program to evaluate EQ equipment, in a historical data file (HDF), which reviews the surveillance and maintenance records and calibration test data to identify potential age-related degradation mechanisms. Reports of significant findings are completed and published in 3-month intervals to CNS personnel, i
The NRC inspection team reviewed the procedures (paragraph )
above) and controls for the CNS maintenance program, to verify j that this program is effectively being implemented. Further verification will be accomplished during a subsequent NRC inspectio No Potential Enforcement / Unresolved Items or Open Items were identifie (3) EQ Replacement Parts Program CNS has a replacement evaluation program which ensures that EQ components and equipment maintain their qualification status by proper replacement of parts and documentation. The replacement evaluation (RE) forms are initiated by the CNS responsible system engineers when replacements for EQ equipment have been purchase EQ equipment and spare parts (SP) checklists are used with the RE form to evaluate qualification of components and materials used as replacement parts. Once approval of the RE is complete, the RE information is entered into the CNS inventory purchase order (IPO) file. The SP checklist /RE forms are used as the appropriate controls to assure qualification for EQ applications. Unresolved items of the SP checklist /RE forms consider the replacement components unqualifie Requisitioning of essential EQ materials, parts, and components requires CNS to complete a purchase requisition (PR) in agreement with the equipment spare parts inventory. PR's are required to provide information pertaining to material type Documentation for EQ qualification are to be specified on the pr The PR originator is required to verify that the vendor is
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on the CNS QA approved vendor list. The PR's are logged into the CNS purchase order tracking system. Field purchase orders are not permitted for EQ purchase No Potential Enforcement / Unresolved Items or Open Items were identified.
(4) Control at Plant EQ Modifications Technical reviews, technical justifications, and safety analyses are performed at CNS associated with EQ plant modifications, reflecting changes to the USAR and CNS Technical Specification Interim documents are reviewed by the operations supervisor, completed reviews by engineering are transmitted to the licensing department, and the CNS training manual is updated by the operations training supervisor. CNS engineering has the responsibility to complete a design change completion report pending EQ plant modifications. An independent review is also performed by an EQ coordinator, and random audits are performed to verify plant EQ modification activitie Also CNS procedures control and document temporary design changes (TDC) for EQ safety-related equipment. CNS procedures control the necessary review, technical justification, and safety analysis associated with TDCs. The TDC package is not considered permanent, but may be left installed longer than 6 months. TDC's are reflected on control room drawings and incorporated in station operating procedures. Installation of TDC's will be reviewed on a 6-month frequency for continued applicabilit When removed a TDC completion report is prepared. When a TDC is determined to be permanent, the TDC will be documented by an approved plant modification requiring further technical review, technical justification, and safety analysis. This includes an equipment specification change followed by an approved temporary design change completion repor CNS plant engineering is responsible for maintaining a complete file on TDC' The NRC inspection team reviewed the procedures (paragraph above) and controls for the CNS EQ plant modifications and TDC program to verify that this program is effectively being implemented. The TDC program covered EQ activities but did not specifically address EQ in the CNS proceduras. Further verification will be accomplished during a subsequent NRC inspectio ,
No Potential Enforcement / Unresolved Items or Open Items were identifie (5) EQ Personnel Training Program The CNS training department is responsible for administering the EQ training program to CNS personnel and documenting the completion of personnel training. CNS was in the process of formalizing their training program by written procedures during the time of this NRC inspection. The NRC inspection team interviewed CNS personnel to verify that this program was established. .EQ training was in process with the crafts, engineering personnel, and selective operations personne Further verification will be accomplished during a subsequent NRC inspection to review records of the formal EQ training progra No Potential Enforcement / Unresolved Items or Open Items were identifie (6) EQ Audits CNS has in place an audit program which prescribes planned and periodic EQ audits to verify that the EQ program is consistent with the requirements of 10 CFR 50.49. The EQ audit program is an integral part of CNS's quality assurance (QA) program to meet the requirements of 10 CFR 50, /-ppendix B. The CNS EQ audit program includes EQ audits performed at CNS by EQ contractor The NRC inspection team interviewed CNS personnel to verify that the EQ audit program was established as part of the CNS QA program. The NRC inspection team verified that the EQ audit program is effectively being implemented by reviewing one QA audit report of the CNS EQ program No. G85-09, July 3 through August 6, 1985, and two followup QA audit reports, dated January 9 and October 20, 1986. The NRC inspection team i concluded the EQ audit program was effectively being l implemente Further verification, however, will be '
accomplished during a subsequent NRC inspectio No Potential Enforcement / Unresolved Items or Ope 1 Items were identified, d. SER/FRC TER, and Licensee Response Commitments The NRC inspection team evaluated the implementation of EQ corrective action commitments made as a result of (1) the January 30, 1985, SER; (2) the December 9, 1982, SER/ November 24, 1982, TER; (3) the licensee's proposed method of resolution for each EQ deficiency documented in the NPPD response letter to NRC of April 24, 1984, regarding the March 29, 1984, meeting between NPPD and NRC; and (4) the licensee's proposed method of resolution for each EQ !
deficiency documented in subsequent NPPD response letters to NRC i I
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dated December 26, 1984, February 15, and March 26, 198 The NPPD response letter of April 24, 1984, included the following key enclosures:
. Methodology for TER Deficiency Resolution I Response to TER Generic Items II TER Equipment Qualification Open Item Resolution II Non-TER Equipment Qualification Status I Justifications for Continued Operation NPPD/CNS Master Equipment List The majority of deficiencies, identified above, involved qualification documentation errors and omissions, deficient and incomplete qualification by similarity analyses, incomplete aging documentation, and incomplete replacement schedules to maintain qualified life of components. Also, many of the identified deficiency corrective action commitments by NPPD required additional equipment shielding or relocation, and exempting equipment now located in mild environmen The NRC inspection team verified that the licensee's EQ documentation file contained the appropriate analyses and necessary documentation to support qualification of electrical equipment, by review of analyses and type test qualification documentation, including verification of numerous equipment replacements, and partial i
replacements of equipment. Also, the licensee shielded and reevaluated numerous component locations from harsh environment conditions (now classified as mild environment) and removed them from the 10 CFR 50.49 Master Equipment List (MEL). The NRC inspection team verified the licensee's efforts to reexamine, upgrade, add, and delete JCOs in effect earlier. The numerous JC0 deletions which were indicated at this time were a result of the licensee's replacement i equipment programs prior to the 10 CFR 50.49(g) extension deadline date of November 30, 1985. The licensee had in effect programs to replace, partially replace, test, and perform additional analyses on equipment, earlier identified in JCO l Based on review of EQ documentation files and of the MEL, the NRC i inspection team identified no deficiencies in the licensee's implementation of SER, TER, and licensee response commitments listed abov Ongoing review of the licensee's RG 1.97 program implementation may result in additional equipment being added to the MEL (see Section 4.e).
Additional implementation of the licensee EQ corrective action commitments was reviewed by the NRC inspection team with regards to the licensee's response to IE Information Notice 86-03 " Potential Deficiencies in Environmental Qualification of Limitorque Motor Valve Operator Wiring, January 14, 1986," (see Section 4.g). I i
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e. 10 CFR 50.49 Master Equipment List The NRC inspection team reviewed the Master Equipment List (MEL),
Revision 7, August 20, 1985, and associated documents, to verify the adequacy of the implementation of NPPD's master list development and maintenance methods as accepted in the SER for final resolution of equipment important to safety issued on January 30, 1985. In addition to the MEL and SER, the following procedures were reviewed by the NRC inspection team:
CNS Operations Manual - Engineering Procedures Proc. N Title 3.1 Equipment Qualification File Control, Revision .13 Equipment Classification, Revision I CNS Operations Manual - Procedures Proc. N Title 0.20 Equipment Qualification, Revision The source document for the MEL origin is contained in EQ data package (EQDP) No. 45, Revision 2 reviewed by the NRC inspection team. The methodology used to control and maintain the MEL is described in the CNS operations manual, engineering procedure No. 3.12.3 Equipment Qualification File Control, Revision 1,Section I. The EQ documentation file is required to be updated, including the changes to the MEL as applicable, each time a configuration change to EQ equipment occurs, or to the environmental profiles for which the equipment must be functional. Specific updating of the MEL is required (1) when equipment repair or refurbishment using nonidentical parts occurs; (2) equipment replacements are required; (3) equipment additions or deletions occur due to station modifications; and (4) equipment relocation and revisions to environmental specifications occur. These procedures were reviewed by the NRC inspection team and no deficiencies were found in maintaining the ME The 10 CFR 54.49 MEL review consisted of emergency operating procedure (EOP) reviews to determine what equipment is required to support and carry out these E0P and associated safety function Eight components were selected from equipment identified in the following E0P and verified against the MEL. All were found on the ME _ _ - - . . _ _ . _- - _ _ .-
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Emergency Operating Procedures
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E0P-2, Revision 2, April 4, 1986-Primary Containment Control l -Suppression Pool Temperature Control
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-Drywell Temperature Control-Primary Containment Pressure Control-Suppression Pool Level Control-Makeup to Suppression Pool from Condensate Storage Tank E0P-2, Revision 2, Attachment 1, April 4, 1986-Drywell and Suppression Pool Temperature Calculations Post accident monitoring (PAM) equipment is yet to be completed in the MEL. Some PAM equipment has been added since some upgrades to the RG 1.97 program have been accomplished in the CNS plant configuration. The CNS RG 1.97 program completion is targeted for 1988/8 Based on this review, the 10 CFR 50.49 MEL is considered to be satisfactorily implemente f. EQ Documentation Files The licensee's environmental qualification file (EQF) at CNS has been established and is being maintained to meet the requirements of 10 CFR 50.49. The requirements for establishing, controlling, routing, and filing EQ data are contained in CNS engineering procedure No.'s 3.12.1, 3.12.2, 3.12.3, 3.12.4, 3.12.5, and 3.1 Additionally, equipment classification is controlled by CNS engineering procedure No. 3.13, Revision 1, and station design modifications by CNS engineering procedure 3.4. EQ information entered into the CNS plant equipment management (PEM) system, provides automatic update of information as changes occur. The EQ information contained within the PEM system and EQDPs comprise the body of information referred to as the EQF. The EQ coordinator is responsible for ensuring that the EQDPs are maintained current and are revised as changes occu The EQF consists of four sections as follows: (1) MEL; (2) environmental parameters; (3) EQDPs; and (4) reference documentation. The MEL is arranged by component identification code (CIC) numbers and provides summary information identifying each EQ equipment item along with its system, manufacturer, model number, function, location, and environmental requirement The environmental parameters section provides specifications for the parameters which must be evaluated to environmentally qualify EQ equipment.
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The EQDP section of the file is arranged by manufacturer and summarizes qualification specifications and evaluation results for each EQ equipment item, in addition to its mair.tenance and surveillance requirements controlled by CNS Engineering Procedure 3.12.2. Each EQDP is numbered and identified by manufacturer and model number. The EQDP log is maintained by the plant engineering department. Each EQDP is controlled by a record of revision. All references contained in the EQDP's are found in the reference documentation section of the EQF. The PEM system provides the remainder of the information necessary to complete the EQ fil Specifically, the following computer systems are required for file information: (1) WITS which addresses maintenance actions required to upgrade equipment; (2) equipment spare parts inventory (ESPI);
(3) equipment data file (EDF) which provides detailed records for all plant components including EQ items; and (4) purchase order tracking (P0T) system which provides a method of processing and tracking purchases at CN The NRC inspection team examined files for 63 selected equipment items (EQDPs) to verify the qualified status of equipment within the scope of 10 CFR 50.4 In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selectively reviewed areas such as (1) required post-accident operating time compared to the duration
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of time the equipment has been demonstrated to be qualified; (2) similarity of tested equipment to that installed in the plant; (3) evaluation of adequacy of test conditions; (4) aging calculations for qualified life; (5) replacement part schedules; (6) the effects of decreases of insulation resistance on equipment performance; (7) adequacy of demonstrated accuracy; (8) evaluation of test anomalies; and (9) applicability of EQ problems as reported in IEN's and IEB's and their resolution. The files adequately documented qualification of equipment and were readily auditable, complete, and l accurate.
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During this review of the EQF the inspection team identified the Potential Enforcement / Unresolved Items and Open Items, described belo (1) EQDP 6, BIW Cable, Bostrad 7E
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The qualification criteria for this file is the 00R Guideline This cable is used at various locations in the plant. The types of cable in this file are identified using plant identification numbers J1, K1, L2, and J2. The material used in the cable is ethylene propylene rubber (EPR) with Hypalon (chlorosulfonated polyethylene,CSPE) jacke There was a concern identified with the functional analysis that is generic. Insulation resistance (IR) values for cable measured in tests are for lengths of 20 ft, to 50 f t. To use
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these values in an analysis, the value must be converted to a per foot basis. The acceptable leakage current or IR value must ,
- be determined for the overall circuit, including length of i
cable, splices, penetrations, and any other probable leak pat ;
The EQDP 6 file documented the IR values directly from the type .
l test report to determine acceptability and did not consider i
>
analysis of the entire circui According to the 00R -
1 Guidelines, operational modes tested should be representative of
- ! the actual application requirements (e.g., electrical cable loading during the test should be representative of actual ;
operating conditions). Failure or acceptance criteria during *
type testing should be based on the maximum error assumed in the l plant safety analyses. Tl.e BIW Bostrad 7E Cable, in EQDP 6 !
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l file, did not adequately demonstrate qualification because of 1 failure to show that the cable functional performance i requirements were satisfied. The analysis using the 20-foot J cable length from the type test, rather than the fully installed i cable length (including considerations given to splices and ,
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penetrations in the cable runs) of the installed configuration, '
- is therefore considered a Potential Enforcement / Unresolved Item ;
(50-298/8628-01).
(2) EQDP 6A, BIW Coaxial Cable, RG 598/4
,
J The qualification criteria for this file is 10 CFR 50.49, l NUREG-0588, Category This cable is used for the high range l radiation monitor outside of containment.
)
The file contained BIW test report 76J049. The test report consisted of only a single page summary with no other supplemental data attache According to NUREG-0588, Category I J
I requirements, a record of the qualification, including .
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documentation must be maintained in an auditable form for the entire period during which the covered item is installed in a ;
nuclear power plant or is stored for future use to permit ;
! verification that each item is qualified for its applicatio ;
i The EQDP 6A file for BIW Coaxial Cable RG598/4, contains a test l
) report which was not auditable to the extent that the !
l documentation was incomplete, not understandable, and not ;
traceable to permit independent verification of conclusion :
The test report does not support qualification, and is therefore '
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I considered a Potential Enforcement / Unresolved Item
- (50-298/8628-02).
j (3) EQDP 5 Kerite 600/1000 Volt Cable, Type HTK/FR
i The qualification criteria for this file is the 00R Guidelines.
] The cable is used throughout the plant. Cable types in this i file are identified using plant identification numbers H1 l
! through H4.
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20 The EQOP references Franklin test report F-C4020-2 to support
qualificatio The IR measurements listed in test report F-C4020-2 were very low (<1 x 1060) for the 50 ft. 600V cable samples (H1 and H2) tested. Measurements were accomplished
, using a vacuum tube voltmeter (V0M) indicative of these
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extrimely low measurements. The test report also indicated numer1us failures in the high pot tests of the 600V cable (H1 and H2) sample According to the 00R Guidelines, operational modes tested should
, be representative of the actual application requirements (e.g.,
electrical cable loading during the test should be i
representative of actual operating conditions). The 600 Volt, Kerite HTK/FR cable test data, in the EQDP 5 file, documented IR readings too low for acceptance during the DBE test, and documented numerous failures during the post DBE high pot test, and is therefore considered a Potential Enforcement / Unresolved l Item (50-298/8628-03).
J The 1000V cable samples (H3 and H4) however, maintained their current and voltage during the DBE test and passed the high pot tests. Qualification of the 1000V cable is supported by the
- Franklin test report F-C4020- (4) EQ Cable Identification and Traceability CNS does not hase the capability to identify the cable manufacturer of type of cable interfacing with their equipment important to u fety as listed on their MEL. For example, if CNS is given a cab'e tag number connected to an EQ equipment item, l
! CNS has no way of identifying the cable type or cable i manufacturer. Cable pull cards and termination cards have not i been retained tince CNS has been built, and qualification of all l EQ cables is based on a generic qualification to the worst case i
' harsh environment conditions that exist at CNS. CNS has an apparent breakdown in their record system with regards to traceability from component to EQDP files and identification on
[ the MEL. This is considered an Open Item (50-298/8628-28).
(5) EQDP 4, Raychem Coaxial Cable, Rayolin R and F The qualification criteria for this file is D0R Guideline The cable is used throughout the plant including containment. The file references the Franklin Test Report F-C4033-1. The concern identified in this file is with the similarity analysi Five
, types of Raychem coaxial cable (M1 through M5) are identified in this file as being installed in the plant. M1 through M3 are i listed as containing Rayolin F insulation. M4 and M5 are listed as containing Rayolin R. Documentation in the EQF is confusing and references Rayathon R as cross linked polyethylene (XLPE),
Rayfoam F as XLPE foam dielectric, Rayolin F as a foam
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dielectric coax cable, and Flametrol as an XLPE insulated cabl The type test report identifies specimens as follows:
Specimen 2 is Flametrol XLPE Cable Specimen 5 is Rayolin R Coax Cable Specimen 6 is F.ayfoam F Triax Cable
' The EQF is unclear in that it identifies type M3 as containing Rayolin R, not Rayolin F. The EQF is unclear in that similarity is claimed between specimen 2 and M1 through M3 (Rayolin F, not FlametrolXLPE). Therefore, the claim of similarity is not clear or well supported. Additionally, the exact material in the cable is not clearly establishe According to the DOR Guidelines, the test specimen should be the same model as the equipment being qualified. The type test should only be considered valid for equipment identical in design and material construction to the test specimen. Any deviation should be evaluated and be incorporated as part of the
- qualification documentation. The EQDP 4 file for Raychem
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Coaxial Cable, does not clearly establish qualification of construction materials by similarity and is therefore considered a Potential Enforcement / Unresolved Item (50-298/8628-04).
(6) EQDP 8, General Electric Electrical Penetration, Model 238X600NSGI General electric penetrations Model 238X600NSG1, Tag Nos. PC-Pent-X100A, PC-Pent-X100E, PC-Pent-X100G, PC-Pent-X102, PC-Pent-X105A and PC-Pent-X105D are located in various positions which penetrate the primary containment wall, and are used for electrical power and control of various safety-related equipment within the drywell. Documentation pertaining to qualification
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of these electrical penetrations is contained in EQDP 8 with
, numerous GE electrical penetration assembly reports referenced l in the EQDP.
I The EQF for the General Electric electrical power and control penetrations did not adequately establish qualification because of failure to demonstrate similarity between the tested and installed components. The EQDP, test report, and analysis, contained in the EQF, could not demonstrate traceability between the electrical penetrations installed at CNS, to those specimens typetested(F01-NS02,NS03,andNSO4)inthatnopositive identification link could be established between tested and installed item This item is considered a Potential Enforcement / Unresolved Item (50-298/8628-05).
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(7) Mounting, Orientation, and Interface Requirements of EQDP's (Generic) for Barton, Square D, Barksdale, Pressure Controls, Static-0-Ring, Robert Shaw, and Rosemount Pressure / Level Transmitters / Switches, and Conduit Seal The NRC inspection team in examining EQDP No 's 9, 12, 13, 33, 33A, 36, 37, 49, 76, 81, 217, 222, and 228 identified generically that these packages do not address mounting, orientation, and interfaces of the equipment requiring environmental qualification. From the EQF it could not be verified that this equipment at CNS was installed as type tested. The licensee agreed that this was a weakness in the EQF's and committed to correct it. The licensee however, showed evidence that mounting, orientation, and interfaces were addressed in the installation instructions for EQ equipment contained in other files. These generic omissions in the EQF are considered file deficiencies. Failure to generically address mounting, orientation, and interface requirements in the EQF is contrary to the D0R Guidelines, Section 5.2.2 and is considered a Potential Enforcement / Unresolved Item (50-298/8628-06).
(8) EQDP 220 and 220A, Fenwal/Patel Temperature Switches, Models 01-170020-090 and 01-170230-090 These switches are located throughout the plant and are placed near the main steam lines. The switch monitors the ambient temperature and in the event of a steam leak will actuate when the area temperature reaches 190 F increasing. The switches are used for a high energy line break (HELB) accident and must operate for one hour post acciden EQDP No. 220A, did not adequately establish qualification because of failure to base the qualification of the interfacing cable splices on full accident conditions including service life for radiation and aging effects. The splices are constructed by using Thomas & Betts STA-KON friction fit crimped connectors with loose black barrel sleeves covering the connections. The EQDP documented these splices qualified to interface Class 1E instruments to field cables with the qualification based on a steam test only. Contrary to Section 5.1 of the D0R Guidelines, there was no documentation or data to support a full accident environment with an analysis or subsequent test reports which would be required to completely qualify these splices for their application. Also, during the NRC walkdown inspection it was noted that the field installation of the interfacing cable splices is dependent upon the confined space inside of the conduit to keep the loose barrel sleeve in place over the electrical connection; this represents poor design and installation practice. This item is considered a Potential Enforcement / Unresolved Item (50-298/8628-07).
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(9) EQDP 7A and 205, Rockbestos Cerro Firewall III Cable The qualification criteria for these files are 00R Guidelines ;
for EQDP 7A and 10 CFR 50.49 NUREG-0588, Category I, for '
EQDP 205. The types of cable in EQDP 7A are identified using plant identification numbers H1, H2, J1, K1, K2, L1, L2, and L For EQDP 205, the numbers are H1, H2, G1, G2, J1, L1, and K These files indicate that both radiation and chemically XLPE are used (NPPD has not determined which formulations of the chemically crosslinked material were supplied). NPPD's intent was to qualify all formulations of Firewall II The proper test reports were available in other files, but were not referenced in these EQF's. These files are required to be j revised to include the proper documents and references to demonstrate that the plant environmental profiles are enveloped by the type test condition Both files were prepared af ter November 30, 1985. EQDP 7A on January 7, 1986, and EQDP 205 on April 1, 1986. Documentation was not in place since November 30, 1985 as required by IEN 84-44. IEN 84-44 indicated the courses of action to support qualification of Rockbestos Cable products prior to the November 30, 1985 deadlin EQDP files 7A and 205 were not considered auditable; however, all required documentation was available for these files, and numerous errors reflected improper reference These deficiencies in the EQF for EQDP 7A and 205 are considered an Open Item (50-298/8628-10).
(10) EQOP 33, Microswitch Limit Switches, Model OP-N (a) Microswitch limit switch, Model OP-N, is used on the high pressure core injection (HPCI) system turbine exhaust drain valve. The limit switch is located in the HPCI room at elevation 859 feet. EQDP 33 claims qualification for a 40 year service life by similarity, and the switch must operate up to 6 months following a LOC Qualification of model OP-N limit switch is based on the similarity of materials to Model BZ-2R. The model BZ-2R radiation test report includes model OP-N qualificatio The service life thermal qualification of model OP-N switch, however, is based on calculations and analyse (b) The OP-N switch contains gaskets, seals, and "0"-rings made from BUNA-N materia The EQDP demonstrates that these materials have a service life of 2.78 year The licensee however considers these components of the limit switch as rionsafety related in their application, and therefore the
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EQDP indicates that a scheduled maintenance and replacement parts program is not necessary in order to satisfy the switch's 40 year service life. The concern of the NRC inspection team is that deteriorating gaskets, seals, and
"0" rings could impact the safety-related performance of the OP-N limit switch. As identified in section (b)(2) of 10 CFR 50.49, the effect of failure of nonsafety-related electric equipment on satisfactory performance of safety related equipment must be considere The EQF will be required to address the surveillance, maintenance, and replacement parts aspects of the BUNA-N components identified in (b) above. Also, the limit switch mechanism should be periodically checked for its physical position relative to the open or clnsed limits of the valve, to verify that the plunger is still operative. These deficiencies are considered an Open Item (50-298/8628-11).
(11) EQDP 33A, Microswitch Limit Switch, Model DTE6-2RQ62 (a) Microswitch limit switch, model DTE6-2RQ62, is used on the radioactive waste system sump pump discharge valve. The limit switch is located in the NW torus area at elevation 881 ft. of the reactor buildin (b) No type test documentation was available in the EQF to demonstrate qualification of this model limit switc Qualification documentation contained in the EQDP for the DTE6-2RQ62 limit switch was a qualification for a 40 year service life plus 6 month post accident operability time by engineering analysis only. The EQDP demonstrates that the contacts on switch model DTE6-2RQ62 were similar to the contacts of the BZR series switches, in meeting normal operational test requirements only. However, the files did not contain qualification documentation which demonstrates similarity between the DTE6 and BZR switches by type tes (c) The EQDP indicated that a scheduled surveillance and maintenance program are not necessary in order to satisfy the 40 year service life and 6 month post accident requirements for reasons similar to model OP-N (see paragraph 4.f(10)(b)). During its life the limit switch mechanism should be periodically checked for its physical position relative to the open or closed limits of the valve, to verify that the plunger is still operative.
l The above deficiencies (b) and (c) are considered an Open Item (50-298/8628-12).
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(12) EQDP 9, EQDP 9A and EQDP201, ASCO Solenoid Valves, Models HVA-90-405-2A, WPHT8316E36, and NP- (a) ASCO solenoid valve models HVA-90-405-2A and WPHT8316E36
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are used on the control rod drive syste Model HVA-90-405-2A solenoid valves are normally energized
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and are deenergized upon receipt of an accident signa Model WPHT8316E36 are normally deenergized and are energized upon receipt of an accident signal. The solenoid valves are located in the south and southeast areas of the reactor building at elevation 903 f ASCO solenoid valves, Model NP-1 are currently scheduled to replace the ASCO model WPHT8316E36. Model NP-1 are used for the primary containment, residual heat removal system, standby gas treatment system rad waste system, and the control rod drive syste Model NP-1 valves must survive a LOCA and have accident operation times ranging from one hour to six month (b) The EQF, EQDP 9 (HVA-90-405-2A) file review by the NRC inspection team disclosed that the post accident service requirements in the file were not very well defined in that there was some confusion as to whether these solenoid valves were energized or deenergized following an acciden The licensee is required to clear up confusing statements contained in this EQD (c) The EQF, EQDP 201 (NP-1), review by the NRC inspection team disclosed a file deficiency in regard to the licensee's methodology in his use of calculations to determine accelerated thermal aging temperatures. The NRC inspection team, using the same methodology calculated apparent discrepant temperatures as high as 376.2*F and 408.2 : The calculation methodology should be reviewed and corrected by the license (d) The EQDP documentation regarding type testing showed the solenoid disk softening at 295 F and it could not hold pressur As a result, the maximum operating pressure differential was changed from 200 psig to 150 psig during the type tes The licensee stated that this valve is normally used with an air system pressure of 100 psig (125 psig maximum) in the CNS plant application. The NRC concern here is that these derated valves should not be used in systems capable of pressures higher than 125 psi An analysis is required in the EQDP to demonstrate that air service to the NP-1 model solenoid valves cannot exceed 125 psi (e) The licensee should address the published ASCO temperature vs coil life curve No. VE2926RY for the NP-1 solenoid coils
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listed in the EQDP. The service temperatures stated in the EQDP are not on the curve and appear discrepan (f) The EQDP 201 (NP-1) review by the NRC inspection team disclosed a file deficiency with regard to the functional type testing documentation in the file, where the liquid tight flexible conduit failed during the type test, allowing the spray solution to enter the solenoid and degrade the coil insulation. As a result of this conduit failure it was never determined during the type functional testing if the coils were operable. The test coil documentation in the file showed that the coils were allowed to dry out for seven c'ays at room temperature at which time they were found to be operable. After a total of 89 days drying time the coils passed the insulation resistance and hypot tests, and it was concluded that the coils were qualified. This documentation in the EQDP fails to support qualification, and other test results to qualify the NP-1 solenoid coils should be placed in the fil The above EQDP 9 and 201 deficiencies (b), (c), (d), (e), and (f) above are considered an Open Item (50-298/8628-14).
(13) EQDP 77, ASCO Temperature Switches, Models SA11AR and QJ11A4R (a) ASCO temperature switch models, SA11AR and QJ11A4R, are used in the Standby Gas Treatment System (SGTS) located in the SGT room of the reactor building at elevation 976 f (b) The NRC inspection team reviewed EQDP 77 and determined that the EQF had no documentation to support that the temperature switch had a qualified life of 40 years with a switch replacement every 9.68 years.
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(c) Clarification of the EQDP is needed as to the type of i fluid-fill used so that its resistance to radiation j exposure can be evaluated.
l (d) The EQPD documented that during type testing of the switch, I a failure during the vibration / wear aging test occurre This documented failure was accepted by NPPD on the basis that installed units would not experience the same type of rapid cycling, and consequent vibration failure. An analysis to justify these effects is required in the EQD The above documentation deficiencies (b), (c), and (d) are considered an Open Item (50-298/8628-15).
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s (14) EJDP Sb -Target Rock Solenoid Valve, Model 1/2-SMS-A-01-1 (a) Target, Rock solenoid valve, model11/2-SMS-A-01-1, is used on theimain steamline as a pressure relief valve. The valve is located in the east section of the drywell at i elevation 921'ft. This model has an installed life of , years', and must operate up to 6 months following a LOC _
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(b) Review of EQDP 51 by the NRC inspection team identified
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cocumentation deficiencies. The documents necessary, referenced in the EQF, to support the test results were not
.found in the fil (c) The EQDP called for a 5.8 year replacement interval for
BUNA-N (nitrile rubber) raterial and inconsistently stated that the material has an expected life of 1.451-year , (d) The EQDP did not address installation and replacement I ,e procedures, nor qualification of replacement kit ,
The above documentation deficiencies (b), (c), and (d) are
, considered an Open Item (50-298/8628-17).
f (15) EQDP 228, Static-0-Ring Pressure Switches, Model STA, 9TA, and
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12TA f ,
Static-0-Ring models 9TA, STA and 12TA pressure switches are
/ t' located in the reactor building. An adequate qualification for
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their required safety-related functions were demonstrated by
this EQDP EQ Static-0-Ring pressure switches which are presently installed at Cooper are supported by EQDP 37 and 22 These packages qualify the installed pressure switches to the D0R guidelines and do not require the venting of the switch housings. The replacement
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Static-0-Ring pressure switches are qualified by EQDP 228 to the
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requirements of NUREG-0588, Category I. This requires the
- 1 switch housings to be vented. At the time of the inspection the licensee had not determined how the new replacement switches
, will be vented and installed.
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The NRC inspection team identified a file deficiency in that the
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principal qualification test report was not referenced in the EQD The EQDP, however, referenced a follow up to the
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qualification test report which in itself was inadequate to
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j qualify the equipment. The licensee in discussions with the NRC r inspection team used both test reports to demonstrate qualification of this equipment.
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The above CNS modifications for venting of replacement pressure switch housings, and the above EQDP file deficiency in the EQF are considered an Open Item (50-298/8628-18).
(16) EQDP 12, Barksdale Pressure Switch, Models B2T-M12SS and B2T-A12SS Barksdale models B2T-M12SS and B2T-A12SS pressure switches are located in the reactor building. An adequate ~ qualification for their intended safety-related functions was demonstrated by this EQDP and the EQ The NRC inspection team identified an auditability problem with EQDP 12 in that the file qualified the same type of equipment to different environments. The EQDP was established to qualify all of the equipment types contained in the file to the most severe environmental parameters, with the exception of pressure. The EQDP did not identify actual pressure conditions for which this equipment was to be qualified. Discussions with the licensee demonstrated to the NRC inspection team that the equipment was qualified for its pressure environment application as wel EQDP 12 was not auditable however, to the extent that this documentation was not readily understandable and traceable to permit independent verification of conclusions. This item is considered an Open Item (50-298/8628-19).
(17) EQDP 81, Rosemount Pressure / Level Transmitters, Model 1153 Series B The qualification criteria for this file is 10 CFR 50.49, NUREG-0588, Category The instruments are located outside containment and are used to measure flow, pressure, differential pressure, and leve The file references Rosemount test report 10802 The NRC inspection team identified a generic concern with respect to synergistic effects being too general as documented in the EQDP. No reference was made to the specific materials used in the equipment when identifying synergism Identification of synergisms also were not referenced especially those reported by industry. When synergisms are identified, a discussion of the effect this has on the testing should be documented in the EQF. As an example, this file identifies sequential synergisms as existing, but no reference is made to the statements in the test report which indicate that no sequential effects were observed in the test serie This generic inadequacy of the EQF EQDP's is considered an Open Item (50-298/8628-20).
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(18) EQDP 226, Rosemount 1153 08/1159 DP Transmitters with Remote Seal Systems The qualification criteria for this file is 10 CFR 50.49, NUREG-0588, Category The equipment is used for remote level indication of sumps outside containment. The test report referenced in the tile is the Rosemount test report D830015 The test report found in EQDP 226 indicated that capillary fill fluid (water) when heated to boiling in thermal environments causes erroneous instrument reading Recommendations in the test report are made to mitigate this proble The EQF does not address this problem even though temperatures are as high 283 F 15 F at the transmitters environmental location in the plan During the inspection however, the CNS staff provided an existing analysis which showed that the capillaries could be insulated to keep the temperature in an acceptable range. The additional anaiysis and calculations are to be added to the EQF to support qualification of the Rosemount 1140308/1159 DP Transmitters with remote seal systems. This inadequacy of the EQF is considered an Open Item (50-298/8628-21).
(19) EQDP 318, Limitorque Motor Operators, Models SMB-00 and SMB-2 Limitorque valve operator, SMB-00, Tag No. PC-MO-231MV, is located in the reactor building and is used in the primary containment syste Valve operator, SMB-2, Tag No. CS-M0-M0128 is located in the heat exchanger room and is used in the core spray system. Documentation supporting qualification of these valve operators for the environmental conditions at CNS is contained in Limitorque test report B000 The NRC inspection team identified a documentation deficiency during this file review regarding the EQ data log which referenced test report F-C3271 as supporting qualification of the above valve operators. The F-C3271 test profile does not envelope the accident profile. Limitorque test report B0003, referenced in EQDP 31B, however, supports the qualificatior of the above valves. This deficiency is considered an Open Item (50-298/8628-22).
(20) EQDP 219, Reliance Motor, Model No. Class H, Type RH EQDP 219 was reviewed by the NRC inspection tea The EQDP presents the basis of qualification for Reliance AC motors, model number class H, type RH, which are installed in the standby gas treatment system at CN The EQDP presented a description of both normal and accident environment to which the motors were required to be qualified and a description of the functional requirements for both environments. Both motors documented in this EQDP were replaced in 1984 and 1985,
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therefore the motors presently installed were qualified to the provisions of 10 CFR 50.4 The basis of qualification was Reliance Electric Company Summary Report NUC-9, " Nuclear Power Motor Systems, Type Test Support Analysis, Random Wound Motors,"
dated July 1, 1978. The basis of qualification of the motors was documented by referencing and discussing applicable test reports in the EQD Serial numbers of the motors were not included in the EQDP; therefore traceability between the documentation and installed equipment was not possible. The absence of adequate
. documentation in the EQDP is identified an as Open Item (50-298/8628-25).
(21) EQDP 23, General Electric ECCS Motor, Model No's 5K6346XC74A and SK6346X83A The qualification criteria for this file is the 00R Guideline The EQDP presented a description of both normal and accident ,
environments to which the motor was required to be qualified and a description of the functional requirements for both environments. The ECCS motors were evaluated by the licensee in accordance with Enclosure 4 of IEB 79-018 (DOR Guidelines). The I basis of qualification was GE Report NEDM-10672, " Environmental Qualification Test of Vertical Induction Motor for ECCS Service in Nuclear Power Plants," dated August 1972 and GE Design Report 22A4722, "ECCS Motor Qualification Program," dated January 1977. Models tested in the above reports were SK6339XC94A and 5K6339XC166A. Similarity between the models tested and those installed at CNS was established by GE Report NEDC 30067, " Comparison of RHR and Core Spray Pump Motor Data with Qualification Test Data for Similar Motors," dated February 1983. Based upon results of the qualification analysis tne licensee concluded that the motors are qualified to perform their safety function during a 40 year lif The equipment was well described except serial numbers of the motors were not included in the EQDP and therefore traceability between the documentation and installed equipment was not possible. This documentation deficiency in the EQDP is identified as an Open Item (50-298/8628-26).
g. IE Information Notices and Bulletins The NRC inspection team evaluated the licensee's activities related to the review of EQ related IE Information Notices (IENs) and IE Bulletins (IEBs). The inspector's review included examination of the licensee's procedures and EQ documentation files relative to applicable IENs and IEBs. NPPD does not have a formal dedicated procedure for tracking and addressing NRC IENs and IEBs, however, those IENs and IEBs that may potentially impact the qualification of
electrical equipment, as outlined in 10 CFR 50.49, are monitored by specific CNS EQ program procedures. (See Section 4.b). NPPD does track issues of potential irrpact via the INP0 nuclear network, industry standards, and news letter NPPD's response and actions with regard to IEN 86-03 " Potential Deficiencies in Environmental Qualification of Limitorque Motor Valve Operator Wiring," January 14, 1986, were documented in letters to the NRC Region IV dated July 21, August 8, and September 8, 1986. NPPD had ongoing inspections of safety-related EQ Limitorque operators located inside the drywell prior to the issuance of IEN 86-03. The NPPD inspections looked at motor insulation, wiring, terminal blocks, T-drains, torque switch settings, etc., with no deficiencies identified. Following the issuance of IEN 86-03, NPPD issued a special test procedure (STP) to inspect the balance of Limitorque MOVs subject to the requirements of 10 CFR 50.49, primarily outside the drywell. During this CNS walkdown inspection effort, unidentified internal wiring was detected in 25 M0Vs located outside the drywell in the HPCI, REC, RHR, MS, RCIC, and RWCW system NPPD immediately replaced the undocumented wire with known qualified Rockbestos Firewall SIS wire, and submitted an equipment operational analysis (E0A) for each of these Limitorque MOVs, to NRC Region IV (letter dated August 8, 1986). Attachment B to this E0A, correlated like internal wiring removed from similar equipment at CNS. NPPD determined that these 25 MOVs had similar interconnecting wire types of (1) ITT Royal SIS XLPE; (2) polyvinylchloride (PVC) insulated; (3)
Raychem Flamtrol or Rockbestos Firewall; and (4) glass braided butyl rubber (polybutadiene).
The NRC inspection team reviewed the E0As Attachment B analyses, and identified deficiencies with one wire type; glass braided butyl rubber insulated, used internal to these motor operators. The documented analysis for glass braided butyl rubber insulation did not fully support qualification, in that the HELB accident conditions outside the drywell were not considered in the supporting calculations of the analysi Also the NRC inspection team reviewed the timeliness of licensee actions to correct the above deficient conditions in the Limitorque valve operators. The NRC inspection team identified the following
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additional deficiencies during this inspection:
i (1) The qualified life of internal wiring removed and tested had not been documente (2) Licensee internal wire samples removed from five operators inside containment and four outside containment were examined by the NRC inspection team, with the following results:
(a) All types of wires which had been removed were not addressed in the E0A (attachment B) of August 8, 198 _ ___
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(b) All types of wires which had been removed had not been teste (c) Taped splices (identified as Scotch by the licensee) and unidentified blind barrel splices had no documentation to show qualificatio The documentation deficiencies identified above and the failure of NPPD to demonstrate similarity between the tested and installed operating configuration, with respect to the internal wiring on Limitorque MOVs is considered a Potential Enforcement / Unresolved Item (50-298/8628-08).
h. Plant Physical Inspection The NRC inspection team, walked down and physically inspected approximately 39 components. The inspection team examined attributes and characteristics such as mounting configuration, orientation, interfaces, model numbers, ambient environment, and physical conditio (1) Limitorque Motor Operators, Plant ID HPCI-M0-020, PC-MO-306 MV MS-M0 078, and RHR-MO-M027A The NRC inspection team performed a walkdown inspection of the Limitorque valve operators located inside and outside the drywell. In addition to ensuring that installed operators were identical to the operators described in EQDP 31A, the inspection scope included provisions of IEN 83-72 and IEN 86-03. The following deficiencies were identified:
(a) Operators HPCI-M0-020, PC-M0-306MV, and MS-M0-078 had Okonite taped splices used in applications for splicing braided jacket motor leads to power leads. The Okonite splice configuration had no documentation to support qualification over a braided jacket. The NRC inspection team's concern is the possibility that the braid under the splice may become saturated with water and potentially short circuit to the switch compartment housing, or short between leads of the power cable, preventing operation of the valve. Okonite motor lead splices, EQDP No. 31A (B0003 qualification series), did not adequately establish qualification because of failure to demonstrate similarity between the splice type tested and those installed in motor operators installed in the plant. No evidence was contained in the EQF which could demonstrate qualification of Okonite splice installations over braided jacket Totor lead The EQDP in the EQF only demonstrates Okoaite motor lead splice testing over unjacketed insulated cabl This l item is considered a Potential Enforcement / Unresolved Item (50-298/8628-09). (b) Operator RHR-M0-M027A (SMB-4) had a broken jumper wir The wire connects terminal 45 of the torque switch to the limit switch. This item is considered an Open Item (50-298/8628-23).
(2) Limitorque Motor Operators, Plant ID No's RHR-M0-M025B and REC-M0-1329MV Limitorque Valve Operator SMB-3, Tag No. RHR-M0-M0258, is located in the injection valve room and is used in the residual
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heat removal syste The documentation supporting qualification of these valve operators s contained in EQDP 31G, and i
Limitorque Test Reports 80009 and B000 The documentation review was adequate to support qualification of these operator A piant walkdown was performed on valve operator RHR-M0-M025 The grease relief valve still had the shipping cap installe Valve operator, SMB-00, Tag No. REC-M0-1329MV is located in the reactor building and is used in the reactor equipment cooling system. Documentation supporting qualification of this valve operator for the environmental conditions at CNS is contained in Limitorque Test Reports B0058 and 600037 The documentation was found to be adequate to support qualification of these operator A plant walkdown was performed on valve operator REC-M0-1329M This valve operator still had the grease relief shipping cap installe Installation of grease relief valve shipping caps on valve operators RHR-M0-M025B and REC-M0-1329 MV indicates a generic problem with the removal of shipping caps and is considered an Open Item (50-298/8628-24),
(3) General Electric ECCS Motors, Model 5K6346XC74A and 5K6346XC83A, Plant 10 CS-MOT-CSP 1B and RHR-MOT-RHRP1A The NRC inspection team performed a walkdown inspection of the GE ECCS motors to verify compliance with the provisions of EQDP 23 and for housekeeping, maintenance, and workmanship practices. It was not possible to establish traceability through equipment serial numbers; however, the equipment model numbers were ideatical to those in the EQF. The following additional items were identified by the NRC inspection team during the walkdown:
(a) CS-MOT-CSPIB Grills protecting motor openings have slipped permitting large unprotected open area The ledge created by the motor flange, just below the lower motor air inlets, was covered with fuzz, dust
. . _ . .
and dirt. The ledge also contained a piece of wadded-up tape; another contained a piece of he protective grill which had been cut or broke *
One heater lead was bearing hard against a sharp edge on the motor case, causing the jacket to be badly
- dente It could not be determined if the jacket or l insulator had been permanently damage *
Heater leads were in contact with the heater and the jacket appeared to be damaged. Condition of the wiring insulation could not be determine (b) RHR-MOT-RHRP1A The ledge created by the motor flange, just below the lower motor air inlets, was dirty, and one screw (approximately 10/32 X 1") was lying on the ledge where it could possibly be pulled into the motor inle Items (a) and (b) above are considered an Open Item (50-298/8628-27).
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(4) ASCO Solenoid Valves, Models HVA-90-405-2A and WPHT-8316E-36:
l Plant 10 No's CRD-50V-50117 (06-19), CRO-S0V-S0118 (10-47),
and CRD-50V-S0140A t
(a) The NRC walkdown inspection identified the CRD-50V-S0117 (06-19) and CRD-50V-S0118 (10-47) solenoid pigtails connected to the field wiring using crimp type butt splices covered with black electrical tape. The butt splices were not identified in the EQF and could not be established as
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qualified for their application. The licensee's positien was that the splices were non-safety related and that this was acceptable in that the solenoids deenergized during an c accident. A determination of operability regarding these components is required in the EQF, EQDP 9, if these ASCO HVA solenoids, being normally energized during their operational service life and deenergized during the DBA accident are classified as EQ components. If however, these solenoids are classified as Non-EQ components, they should be removed from the ME (b) Also the NRC walkdown inspection identified CRO-50V-50140A solenoid pigtails connected to the field wiring with in-line bolt splices covered with black electrical tap The ASCO WPHT solenoid in-line splices were not identified in the EQF and could not be established as qualified for
! their application. Since these valves and their replacements (ASCO NP-1) must energize following the DBA
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and post DBA, the field splice should be a qualified 1- splice. ASCO solenoid valves, model NP-1, are currently
- scheduled to replace 711 WPHT8316E36 models in EQ i applications. The licensee has proposed thac the existing i conduit system is to be modified to incorporate the NP-1
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type replacements and nuclear field splice configurations documented in EQDP 201. The licensee will address the field splice to field cable applications in EQDP 201 and l
determine their suitabilility for application.
l The above items (a) and (b) are considered an Open item l (05-298/8628-16).
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i (5) Microswitch Limit Switches, Models OP-N and DTE6-2RQ62 Plant ID j No's HPCI-LMS, A070(0/C), HPCI-LMS-A071 (0/C), RW-LMS-732-AV, i and RW-LMS-733-AV
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The above model OP-N and DTE6-2RQS2 limit switches were examined during the walkdown of the plant. They are located in the HPCI room of the Reactor Building at elevation 859, and in the NW torus at elevation 881.
, The switches were mounted horizontally on flat steel plates.
- The licensee, for the purpose of the inspection, had removed the i switch cover plates exposing the internal structure of the limit l switche Limit switch HPCI-IMS-A071 (0) had a torn rubber boot indicating a need for preventative maintenance. The rubber boot
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, protects the area where the switch's actuation plunger enters ;
the switch bod *
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Also on Plant ID No. HPCI-IMS-A070 (0/C) the field termination i'
box No. TB-220, ESS DIV II containing electrical connectors was opened. The raised ends of the ring tongue type terminations appeared to have been flattened indicating questionable handling i
practices. Plant ID No's RW-IMS-732A and RW-IMS-733-AV also had
- the raised tips of the ring tongue type terminations flattened.
j The above observations by the NRC inspection team are considered l an Open Item (50-298/8628-13).
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4 5. Exit Interview j An exit interview was conducted on November 7, 1986, with NPPD in which
- the scope of the inspection and findings were summarized.
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