Text

Insp Rept 50-293/85-35 on 851209-13.Deviations Noted:Failure to Fully Document Qualification of Barton 288A Main Steam Flow Switches & GE EB-25 Terminal Blocks.Three Open Items Also Noted,Including Documentation Revs
	ML20155D615
Person / Time
Site:	Pilgrim
Issue date:	04/08/1986
From:	Potapovs U, Wilson R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	;
Shared Package
ML20155D594	List: ML20155D590; ML20155D615;
References
	50-293-85-35, IEB-79-01B, IEB-79-1B, NUDOCS 8604170377
	Download: ML20155D615 (16)
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U.S.' NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

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Report No.: 50-293/85-35

Docket No.: 50-293

License No.: DPR-35

Licensee: Boston Edison Company

800 Boylston Street

Boston, Massachusetts 02199

Facility Name: Pilgrim Nuclear Power Station Unit 1

Inspection At: Braintree and Waterford, Massachusetts

Inspector: M deE- --

R. C. Wilson, Equipment Qualification & Test Engineer

f!E!K

'Da te

Also participating in the inspection and contributing to the report were:

l U. Potapovs. Chief, Fquipment Qualification Inspection Section, IE

S. Alexander, Engineer, IE

R. G. LaGrange, Section Leader, NRR

E. H. Richards, Member of Technical Staff, Sandia National Laboratories

M. J. Jacobus, Member of Technical Staff, Sandia National Laboratories

M. Trojovsky, Consultant Engineer, Idaho National Engineering Laboratory

L. S. Cheung, Reactor Engineer, RI

l P. J. Schaeffer, Reactor Engineer, RI

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J. P. Durr, Chief Engineering Branch, RI

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Approved by: M 18

U. Potapovs, Chief, Equi pment Qualification Section

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Office of Inspection and Enforcement

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{ INSPECTION SUMMARY

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l Inspection on December 9 to 13,1985 (Inspection Report No. 50-293/85-35)

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Areas Inspected: Special, announced inspection to review the licensee's

implementation of a program per the requirements of 10 CFR 50.49 for

establishing and maintaining the qualification of electric equipment within

the scope of 10 CFR 50.49.

Results: The inspection determined that the licensee has implemented a program

to meet the requirements of 10 CFR 50.49, except for certain deficiencies

listed below.

Report

Name Paragraph Item Number

Potential Enforcement / Unresolved Items:

1. Barton 288A main steam flow switches 4.D(1) 50-293/85-35-1

2. General Electric EB-25 terminal blocks 4.D(2) 50-293/85-35-2

Open Items: ;

3. Documentation revisions 4.A 50-293/85-35-3

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4. Completion of maintenance procedures 4.B 50-293/85-35-4

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S. File corrections 4.D 50-293/85-35-5

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DETAILS

! 1. PERSONS CONTACTED:

1.1 Boston Edison Company (BECO)

i *W. D. Harrington, Senior Vice President, Nuclear

J. E. Howard, Vice President, Nuclear Engrg. & QA

u *A. L.-0xsen, Vice President, Operations

R. Velez, Project Manager, EQ

R. N. Swanson, Manager, Nuclear Engineering Dept.

R. V. Fairbank, Deputy Manager, NED

T. A. Venkataraman, Pr. Licensing Engineer

M. N. Brosee, Chief Maintenance Engineer

i *J. K. Keyes, Group Leader, Regulatory Affairs

! *S. Dasgupta, Group Leader, NED I&C

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R. D. Andrew, Engineer, NED I&C

l *J. Pawlak, Group Leader, NED Power Systems

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L. A. Perfetti, Engineer, NED Power Systems

*P. Antonopoulos, Group Leader, Nuclear Analysis

J. F. Crowder, Senior Engineer, Compliance

, *R. E. Grazio, Group Leader, Systems and Safety Analysis

! *F. Mogolesko, Engineer, Systems and Safety Analysis

L. Mcdonald, Group Leader, PS&CC

R. M. Sheets, Engineer, PS&CC

A. V. Morisi, Assistant Director, Outage Management

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H. F. Brannan, Manager, QA

i *D. A. Mills, Group Leader, Construction Management

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E. T. Graham, Group Leader, Compliance

T.~ Ferris, Engineer, Licensing

W. Stowe, Counsel

i *D. A. Whitney, Sr. Engineer, Methods Training and Compliance

C. E. Bowman, Acting Group Leader, ERHS

R. Sherry, Assistant Chief Maintenance Engineer

R. M. Titcomb, Senior Engineer, QA

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S. Das Engineer, NED Power Systems

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R. J. Orkin, Senior Engineer, QA

D. A. Diotalevi, Senior Engineer, QA

J. C. Mattia, Group Leader, QA Audits

R. L. Stefan, Engineer, Outage Management

J. L. Jerz, Engineer, NED Civil / Structural

P. Karatzas, Senior Engineer, Radiological

! F. L. Sche 11enger Jr., Group Leader, Quality Engrg.

J. Gerety, Engineer, Systems & Safety Analysis

F. Famulari, Group Leader, Site Quality Control

! J. Irens, Engineer, Site Quality Control

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J. Poorbaugh, Senior Engineer, Site QA

l P. J. Moraites, Engineer, I&C Maintenance

l M. Maguire, Engineer, Electrical Maintenance

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1.2 Consultants

R. Bennett, Resident Engrg. Supervisor, Wyle Labs

J. Gleason, NES Manager, Wyle Labs

T. Brewington, BECO Program Manager, Wyle Labs

J. W. Anderson, Sr. Nuclear Qual. Engr., Wyle Labs

N. Eisenmann, BECO Resident Engineer, Cygna Energy Services

J. A. Voe1xen, Manager, Systems Engrg. Dept., Cygna Energy Services

U. Rieder, Sr. Engineer, Bechtel

J. C. Waal, Consultant, J. C..Waal Engineering Co.

J. N. Hamawi, Radiation Consultant, Entech Engineering Inc.

R. K. Ho, Consultant to Nuclear Utility Group on EQ, EPM

1.3 NRC

M. McBride, Pilgrim Resident Inspector

Denotes those present at exit meeting in Braintree on December 13, 1985.

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2. PURPOSE

The purpose of this inspection was to review the licensee's implementation

of a program to meet the requirements of 10 CFR 50.49.

J. BACKGROUND

The NRC held a meeting with BECO on May 22, 1984 to discuss BEC0's

proposed methods to resolve the EQ deficiencies identified in the

April 13, 1983 Safety Evaluation Report and Janua*y 19, 1983 FRC TER.

Discussion also included BEC0's general methodology for compliance with

10 CFR 50.49 and justification for continued operation (JCO) for those

equipment items for which environmental qualification was not completed.

The minutes of the meeting and proposed method of resolution for each of

the EQ deficiencies were documented in BEC0 submittals dated July 9,

August 3, and September 24, 1984 and January 21 and 29,1985. The final

SER transmitted March 26, 1985 identified that certain equipment was still

under JCO. At the time of the inspection no JCOs or extensions applied.

BEC0 did request oualification deadline extensions for five types of

equipment until February 8,1986, but the requested extensions were not

granted. All five equipment types were included in the review sample

selected for this inspection.

4 FINDINGS l

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The NRC inspectors examined the licensee's program for establishing the

qualification of electric equipment within the scope of 10 CFR 50.49.

The program was evaluated by examination of the licensee's qualification

documentation files, review of procedures for controlling the licensee's

EQ efforts, verification of adequacy and accuracy of the licensee's

10 CFR 50.49 equipment list, and examination of the licensee's program

for maintaining the cualified status of the covered 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, although some

deficiencies were identified.

A. EQ Program Procedures

The NRC inspectors reviewed the Pilgrim EQ program as defined in

Nuclear Operations Procedure NOP 84A9 dated November 29, 1985, which

establishes the recuirements of 10 CFR 50.49 and delegates

responsibility to various departments. The inspectors reviewed the

following Nuclear Engineering Department (NED) and Nuclear Operations

Department (N00) procedures and work instructions which establish

and implement the EQ documentation program:

NED Procedures:

- 2.01 Preparation, Issuance and Control of Department Procedures,

Rev. 6 dated November 28, 1985

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2.02 Preparation, Review and Issuance of NED Work Instructions,

Rev. I dated February 10, 1983

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3.02 Preparation, Review, Verification, Approval, and Revision

of Design Documents for Plant Design Changes, Rev.14 dated

November 18, 1985

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3.08 Specifications and Reports, Rev. 7 dated November 1,1985

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3.09 Design Review to Determine Conformance to Regulation

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3.11 Calculation Method for Determining Component Lifetime in

Event of Excess Drywell Temperature

- 4.01 Procurement of Items and/or Services, Rev.10 dated April 4,

1985

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6.03 Maintaining the Environmental Qualification Master List,

Rev. I dated November 29, 1985

- 17.02 Disposition of Quality Assurance Records and Departmental

Correspondence, Rev. 4 dated November 26, 1985

- 20.01 Glossary Terms and Definitions

NED Work Instructions:

- NEDWI #271 Preparation of Environmental Qualification Master

List, Rev. O dated March 8, 1983

- NEDWI #277 Preparing Justifications for Continued Operations

for Environnental Qualification, Pev. I dated May 6,

1984

- NEDWI 8278 Preparing Equipment Qualification Evaluation Sheets.

Rev. 2 dated July 19, 1985

- NEDWI #279 Incorporating Environmental Qualification Requirements

into Procurement Documents, Rev. O dated May 1, 1984

- NEDWI 8280 Review of Vendor Test Reports and Qualification Reports

for Environmental Qualification, Rev. I dated Pay 1,

1985

- NEDWI #281 Performing Record Search /Walkdown Verification for.

u Environmental Qualification, Rev. O dated May 1, 1984

- NEDWI #284 Resolution of Outstanding Items, Rev. O dated May 1,

1984

- NEDWI #285 Review of Maintenar.ce Requests for Equipment

Qualification, Rev. O dated May 1, 1984

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- NEDWI #310 Preparing, Maintaining and Updating Documentation

Files, Rev. O dated November 6,1985

N0D (Station) Procedures:

- 1.3.24 Failure and Malfunction Reports, Rev. 11 dated

February 6, 1985

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1.3.31 Procurement of Items and Services, Rev. O dated

November 13, 1985

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1.5.3 Maintenance Requests, Rev. 16 dated March 4, 1983

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1.8 Master Surveillance Tracking Program, Rev. 4 dated

August 8, 1984

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1.8.2 PM Tracking Program, Rev. I dated June 8, 1983

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NOP 8305 Regulatory Communication and Commitment Control

process

The NRC inspectors were also given a well-prepared presentation

describing the licensee's EQ program on December 9 and 10, 1985

during which the above procedures and work instructions were

discussed.

The licensee's program was reviewed to verify that adequate

procedures and controls had been established to meet the

requirements of 10 CFR 50.49. Areas of the program reviewed

included methods and their effectiveness for:

(a) Requiring all equipment that is located in harsh environments

and is within the scope of 10 CFR 50.49 to be included on the

list of equipment requiring qualification (EQ Master List).

(b) Controlling the generation, maintenance, and distribution of

the EQ Master List.

(c) Defining and differentiating between mild and harsh

environments.

(d) Establishing harsh environmental conditions at the location of

equipment through engineering analysis and evaluation.

(e) Establishing and maintaining a file of plant conditions.

(f) Establishing, evaluating, and maintaining EQ documentation.

(g) Training personnel in the environmental qualification of

equipment.

(h) Controlling plant modifications such as installation of new and

replacement equipment, and providing for updating replacement

equipment to 10 CFR 50.49 criteria.

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The NRC inspectors identified one concern regarding procedural

control of changes to the EQ documentation. NEDWI #310 Section 6.1.2

states that the master EQ Evaluation Sheet is considered a " working

copy" and will contain " white-out," correction tape, erasures, etc;

the record copy used for documenting qualification is a copy of the

master and is to be considered the original. The inspectors did

observe such changes in documents presented for review. Paragraph

17.3.5 of the BEC0 Quality Assurance Manual states, in part:

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... Quality Assurance records are corrected or supplemented according

to precedures which provide for appropriate review of approval...the

correction or supplement includes the date and identification of the

person authorized to issue such corrections or supplements." The

licensee agreed to change procedures to be consistent with the QA

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Manual and to review the EQ documentation and correct as necessary.

A future NRC inspection will verify that these actions are take ..

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Documentation revisions constitute Open Item 50-293/85-35-3.

NEDWI #279 described steps for incorporating EQ requirements into

the procurement documents. Attachment 3 of NEDWI #279 provided a

l flow chart for equipment replacement, upgrading EQ requirements

from DOR Guidelines to 10 CFR 50.49. Station procedure 400 1.3.31

implements these requirements. The inspectors reviewed these

procedures and concluded that they contain sufficient information

to implement 10 CFR 50.49 requirements in the licensee's procurement

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activities.

The inspector discussed with the licensee the organizational

structure for both corporate and site concerning QA/QC activities

involving EQ. The Nuclear Quality Assurance Manager directs

i QA/QC activities at the site and corporate. The Quality Engineering

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Group Leader and the Audit Group Leader are located in Braintree.

The site contains on-site auditors and the Operations Quality Control

group leader. This group leader is directly responsible for

the Quality Control Engineering personnel involved in reviewing

Field Change Packages (FCP's) and Maintenance Requests (MR's), both

EQ and non EQ related. The inspector verified that the QC Engineers

are certified to ANSI N45.2.6-78 in accordance with established

requirements.

In addition to discussing with the licensee the role of the QC

Engineers, the inspector reviewed the following Equipment

Qualification audit reports and their associated checklists:

- Audit Report No. 84-48 " Equipment Qualification," conducted

i December 21, 1984 through January 11, 1985.

- Audit Report No. 85-11 " Equipment Qualification Program,"

conducted April 29 through May 17, 1985.

Both audits encompassed selected portions of the Equipment

Qualification program implemented by BECO including:

l - Preparation and maintenance of a Master List of equipment

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- Identification of service data requirements of affected equipment.

- Documentation of environmental qualification for qualified

equipment.

- Justification for Continued Operation (JCO) for qualification

pending f urther action or additional documentation.

- Documentation, reporting, and disposition of equipment for which

the JC0 has been evaluated and determined to be unacceptable.

- Identification of maintenance requirements and establishment of

a program to implement these requirements.

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Procedures and instructions which implement BECO Equipment

Qualification comitments.

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Completed Equipment Qualification. files including backup

documentation.

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Maintenance and plant modification activities which impact

Equipment Qualification status.

The inspector concluded that the audits were timely and thorough

in determining compliance to 10 CFR 50.49, the auditors involved

were knowledgeable of the EQ requirements, and the checklists were

very detailed.

The inspector interviewed corporate end site personnel concerning

the depth to which individuals were trained in accordance with

10 CFR 50.49 reouirements. Cocuments reviewed by the inspector

included:

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Nuclear Policy Manual, Policy No. 5 " Nuclear Training Policy"

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NED Procedure 2.03, " Indoctrination and Training Program"

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NOP 1.3.14 " Indoctrination and Training"

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NMSP Procedure 2.01, " Indoctrination and Training"

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QAD Procedure 2.02, " Indoctrination and Training"

Discussions with the licensee revealed that BECO sent personnel

involved directly or indirectly in the Environmental Qualification

process to various IEEE EQ seminars beginning with the first one.

These sessions covered various IEEE standards dealing with the

qualification of Class IE equipment necessary to function in DBE

conditions. In addition, BECO personnel attended two EPRI seminars,

one dealing with EQ; the other, plant maintenance. Further, the

inspector was given objective evidence that 90 licensee personnel

(QA, QC, maintenance, stores, nuclear operations, NED, etc.) were

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given formal two to three day plant-specific EQ training by Wyle

Laboratories and BEC0 personnel in March and April,1985. Ongoing

EQ training will continue in accordance with the policy and procedures

listed above.

. The NRC inspectors concluded that with the exception of the Open

Item cited above, the licensee has implemented a well planned

and thoroughly documented EQ program meeting the requirements of

10 CFR 50.49.

B. E0 Maintenance Program

The NRC inspectors reviewed the licensee's provision for preserving

the qualified status of equipment qualified to 10 CFR 50.49. The

EQ Documentation Files described in Section 4.D below include E0

Evaluation Sheets which identify required maintenance. Paragraph

7.10 of N0P 84A9 requires incorporation of these requirements into

the Pilgrim Qualification Maintenance Program (QMP). The inspectors

reviewed the N0D procedures listed in section 4.A above, which cover

implementation of the EQ requirements in the QMP. The CMP is

administered by N00, and includes replacement parts procurement,

handling and storage, installation and replacement, and 0A

verification. The QMP also includes tracking provisions to ensure

that specific activities are performed within scheduled time spans.

The licensee prepares an EQ Process Checklist for each type of

equipment, based on reviewing the applicable Documentation File.

The EQ Process Checklist includes information such as the following:

- Equipment identification, specification, vendor manual,

qualification level, etc.

- Parts requiring maintenance, activity, and frequency

- Applicable procedure identification

- Parts procurement information such as availability, shelf

life, and dc .umentation

A separate EQ maintenance procedure is prepared for each Process

Checklist. The Checklist is also used for tracking. The licensee

stated that as of December 12, 1985 all of the 72 required component-

specific procedures were written. Thirty-five were issued as of that

date; the remainder were in review and were expected to be issued

within one month. On an interim basis pending issue of the remaining

component-specific procedures, maintenance for the affected components

is performed by directly using the information in the EQ Evaluation

Sheets and Process Checklists.

The inspectors selected the following equipment-specific maintenance

procedures for review:

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- N00 Procedure No. 8.E.65-2 " Torus Water Level Monitoring

System Calibration" in draft form, not yet approved. t.

- N00 Procedure No. 8.Q.2-1 " Recirculation Water Sample Solenoid

Valve EQ Repair" in draft form, not yet approved.

- N00 Procedure No. 8.Q.3-2 "RHR/ Core Spray Pump Motor EQ

Maintenance and Monitoring," in draf t form, not yet approved.

- NOD Procedure No. 8.Q.3-5 "Namco Limit Switch EQ Repair," in

draft form, not yet approved.

The inspectors found that these procedures adequately addressed the

required maintenance activities. Maintenance records for certain

equipment types were also reviewed by the inspectors with no concerns

identified. The inspectors found the Pilgrim program for preserving

equipment qualification to be acceptable, including sae interim

treatment of component-specific maintenance procedures, subject to

verification of the concerns addressed in the following Open Item.

The inspectors noted that when reviewing Maintenance Requests to

determine whether they are safety-related, the maintenance et.gineer

had only oral instructions to compare with the EQ Master List. In

response to the inspectors' concern, on December 12, 1985 the chief

maintenance engineer issued an office memorandum stating that NOD

1.5.3

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... presently requires the " Staff Engineer" to identify

the work scope when processing the individual Maintenance

Requests. Although the present procedure only references

the Q-List, it is implicit within this assigned responsibility

that the applicable requirements (including EQ) are to be

addressed." ,

"To clarify the present administrative direction, each

individual staffing a Maintenance Request will determine if

the activity is EQ-related and, if it is, will include the

appropriate technical requirements within the defined work

scope."

A future NRC inspection will verify that (1) these changes are

incorporated into maintenance request procedure N00 1.5.3 and (2)

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that the remaining EQ component maintenance procedures have been

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issued. Completion of maintenance procedures constitutes Open Item

50-293/85-35-4. l

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C. E0 Master List

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The licensee is required to maintain an up-to-date list of the

eouipment that must be qualified under 10 CFR 50.49. This list is

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entitled " Pilgrim Nuclear Power Station Environmental Qualification

Master List," restsion 7, dated November 1, 1985. Considered in

the preparation of this list are environmental effects resulting

from all postulated design-basis accidents documented in the

licensee's Final Safety Analysis Report, locations within the

plant subject to a harsh post-accident environment, technical

specification limiting conditions for operation, emergency operating

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procedures, Piping and Instrumentation Diagrams, and whether

electrical power is required for operation of the equipment. The

EQ Master List was produced as defined in NEDWI #277 and is

maintained per NED procedure 6.03. These procedures were reviewed

and determined to provide suitable guidance.

The inspectors selected nine items as an audit sample to verify

the completeness of the current EQ Master List. In order to compile

this audit sample, a review was conducted of the following

Emergency Operating Procedures (E0Ps) and Piping and Instrument

Diagrams (P& ids).

Emergency Operating Procedures

E0P-01, RPV Lev 9 ano Pressure, Rev. 1, dated July 29, 1985

E0P-03, RPV Level Restoration, Rev.1, dated August 21, 1985

l E0P-04, Primary Containment Control, Temperature, Rev.1, dated

July 29, 1985

E0P-05, Primary Containment Control, Pressure, Rev. 1, dated

July 29, 2985

E0P-06, Primary Containment Control, level, Rev. O, dated March 15,

j 1985

P& ids

M-207 Rev. E9, sheet 1, June 29,1984 " Condensate & Feedwater

l System"

M-207 Rev. E7, sheet 2, January 3,1985 " Condensate & Feedwater

System"

M-241 Rev. E12, sheet 1, March 22, 1985 " Residual Heat Removal

System"

M-242 Rev. E8, December 14, 1984 " Core Spray System"

M-252 Rev. E8, sheet 1, September 4,1985 " Nuclear Boiler"

The audit sample was selected to verify that those items required

to be on the Master List were in fact on the list. The sample

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also included an item required for implementation of R.G.1.97

(torus water level).

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! EQ Master List is satisfactory.

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D. Environmental Qualification Files

The Pilgrim EQ Documentation Files are divided into two parts', the

EQ Master Reference File (MRF) and the EQ Data Files (EQDF). The

MRF contains documentation that is used ts the basis for qualifying

components: test procedures, test reports, analyses, Qualification

Verification Reports, etc. The EQDF documnts the qualification

of equipment identified in the EQ Master t.ist. The FQDF is indexed

by individual component identification numbers or generic equipment

types. Individual EQDFs document cor,ponent qualificatior, by

information contained in the EQDF and by referencing information

in the MRF or other NED records.

Each EQDF contains the following: ,

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An EQ Evaluation Sheet, a multi-page form whose first sheet is

a modified IEB 79-01B SCEW sheet and which provides a detailed -

summary of the qualification, including maintenance requirements

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A walkdown record and/or record search report, as appropriate

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Optional material as available, such as maintenance requests,

Wyle review and analysis documentation such as Qualified

Life and Caveats sheet, Certificates of Compliance, etc.

- A cover sheet with the equipment ID number (s), an index of the

EQDF contents, and applicable signa,tures

The NRC inspectors examined files for 20 equipment itens, where an

iten is defined as a specific typ'e of electrical equiement,

designated by manufacturer and model, which is representative of

all identical equipment in a plant area exposed to ,the samrt

environmental service conditions. The items were selected in advance

by the inspection team and identified 'o t the licensee during

the entrance meeting.

The files were examined to verify the qualified status of equipment

within the scope of 10 CFR 50.49. In addition to comparing. plant

service conditions with qualification test conditions and verifying

the bases for these conditions, the inspectors selectively rhiewed

areas such as required post-accident operating time compared to'the

duration of time the equipment has been demonstrated to be

qualified; similarity of tested' equipment to that installed i,n the

plant (e.g., insulation class, materials of components of the

equipment, tested configuration compared to instalibd configuration,

and documentation of both); evaluation of adequacy'of test conditions;

aging calculations for qualified life and replacement interval

determination; effects of de. creases in insulatten' resistance on

, equipment performance; adequacy of demonstrated accuracy; evaluation

' of test anomalies; and applicability of EQ prordems reported in

IE ins / Bulletins and their resolution.'

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The files adequately documented qualification of the equipment

except as described below. The files were readily auditable and

with the exceptions described below were complete and accurate. No

generic documentation deficiencies were found.

(1) Barton 288A main steam flow switches,10 #DPIS 261-2A through

25 - Earlier in 1985 BEC0 modified 16 Barton 278 flow switches

to become model 288A flow switches, and prepared EQDFs for the

modified switches. During November and early December,1985,

as many as 11 of the modified flow switches were found to exhibit

setpoint drifts approaching plant Tech Spec. limits. This

inspection Nport addresses the EQ aspects of these modified

flow switches. The non-EQ aspects have been addressed separately

by the NRC.

The model 278 flow switch consisted of a model 224 differential

pressure sensing unit and a mercury switch transducer unit.

The conversion performed by BECO replaced the mercury switch

unit with a snap action switch unit. BECO used Barton repair

procedures to perform the modification, and in response to

questioning by the NRC inspectors obtained a letter from Barton

dated Dececher 12, 1985 which states that "a skilled Instrument

Technicien can successfully install and calibrate" the

replacement switches using the manual instructions provided by

Barton. RECO also documented a comparison between the Barton

manual procedures and the procedure written by BECO for the

modification, showing equivalence. For environmental

qualification purposes the inspectors concluded that similarity

between the modified plant equipment and the type test specimen

was adequately established under the 00R Guidelines, and the

setpoint drift was not caused by a basic difference in the design

or materials of construction.

The inspectors did determine that the EQDF did not demonstrate

sufficient setpoint accuracy to meet the Tech Spec requirement

of 2%; in fact, the type test unit showed approximately 5%

of full scale error for the main steam line break (MSLB)

environmental conditions specified in the EQDF. The E0ES shows

a temperature increase of 156.5F, to a peak of 246.5F. In

response to this concern, which was identified late by the

inspection, the licensee provided evidence indicating that the

specified environment was overly severe. Specifically, the flow

switches are located on a balcony in RCIC compartment No. 3,

far from the MSLBs addressed in Bechtel analyses PBOC-7

(condenser bay) and PBOC-8 (steam tunnel). PBOC-7 does not

model the flow switch location, and PB0C-8 models it only short

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term, showing a 5.9F increase in 2.46 seconds. The test specimen

had no accuracy problems for such conditions. The EQES shows a

required operating time of 61 minutes, whereas the actual time

of operation is about 0.5 seconds. Considering this additional

input from BECO, received just before and af ter the exit meeting,

. the inspectors conclude that the files did not demonstrate

qualification of these flow switches because of the accuracy

concern, but that the licensee could reedily correct tl:e

documentation.

The inspectors also noted that Rev. 2 of the E0ES states with

proper justification that a previously imposed 15 year 0-ring

life limitation could be removed, but the qualification main-

t tenance document and maintenance requirement sumary sheet were

l not changed accordingly. During revision of the EQDF to correctly

l specify accuracy and environmental conditions, this discrepancy

i should also be corrected. Barton 288A main steam flow switches

l constitutes Potential Enforcement / Unresolved Item 50-293/

85-35-01.

, (2) General Electric EB-25 terminal blocks, file C158 - These terminal

blocks are used in panel C158. The basis for qualification

l was a report on terminal blocks for use in Limitorque valve

operators. This report cited insulation resistance measurements

l as icw as 500 ohms during the test of an EB-5 terminal block

I

subjected to a more severe environment. Similarity was adequately

established between the EB-5 and EB-25 terminal blocks, but the

effect of low insulation resistances on the performance in the

plant's 4-20 mA circuit was not covered in the file. Discussions

with utility personnel indicated that they also based the EB-25

qualification on an Electroswitch control switch test report

for switches located in the same panel as the terminal blocks

i

and tested to the environment of the panel. This report showed

, negligible leakage currents between the contacts of the phenolic

switch when connected in an actual 4-20 mA pressure transmitter i

circuit, and thus it could be used to establish terminal block

suitability for the plant environment. However, the Electroswitch

report was not referenced in the terminal block qualification

nor was applicability or similarity of the report established

for use with EB-25 terminal blocks. After further discussions

with BEC0 personnel, they decided to reference a separate report

and do further analysis to cover terminal block qualification.

Brief review of the modified file revealed no problems. General

Electric EB-25 terminal block constitutes Potential Enforcement /

Unresolved Item 50-293/85-35-2.

(3) File corrections - Three files contained relatively minor discrep-

ancies that are grouped into a single Open Item.

(a) Yarway level indicating switches LIS263-57A et al - This

file was assembled shortly before the inspection, and

covers equipment whose qualification deadline was extended

until November 30, 1985 based on acceptable JCO. It lacks

a note relating the tested and installed terminal blocks,

i

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i

t

(b) Fenwal temperature switches TSW-1A, 1B - This file was also

assembled shortly before the inspection under a November 30

deadline. Note 10 of the EQES requires modification to

clarify that it refers to the snap action switch and not {

the terminal block. The Isomedix certificate of testing

is also lacking.

(c) Static-0-Ring pressure switch, ID 8PS-1360-9B - Shortly

before the exit meeting the inspectors noted that a hand

calculation contained a temperature written as "105 C"

which did not correspond to the Kelvin temperature

subsequently used in an Arrhenius calculation. The effect

of this error would be to significantly overestimate the

qualified life of the component. Subsequent to the

inspection the licensee advised that the calculation was

indeed correct; the engineer had erred by transposing two

digits in writing "150 C " a number which appeared in an

earlier stage of the calculation.

A future NRC inspection will verify that these changes are

incorporated into the files. File corrections constitutes

Open Item 50-293/85-35-5.

(4) IE Information Notices (IN) and Bulletins - The NRC inspectors

reviewed and evaluated the licensee's activities concerning the

review of EQ-related IE ins and Bulletins. The inspectors'

review included examination of procedures and EQ documentation

packages relative to Information Notices and Bulletins. The

procedures review determined that the licensee does have a

system for distributing, reviewing, and evaluating ins and

Bulletins relative to equipment within the scope of 10 CFR 50.49,

and that the ins and Bulletins are addressed in appropriate

component EQ files as described above. During the review of

individual component qualification files the NRC inspectors

evaluated the licensee's actions with respect to ins and Bulletins.

The inspectors particularly examined BEC0's actions with regard

to existing and forthcoming ins involving Limitorque operators.

These actions included upgrading all qualifications to NUREG

0588 Cat. I; replacing all internal wiring with wires known to

be qualified and by means of procedures that establish

traceability; and identifying all operator motors with magnesium

rotors and verifying that qualification is based on appropriate

test specimens. No concerns were identified during this review.

E. PLANT PHYSICAL INSPECTION

The NRC inspectors, with component accessibility input from licensee

personnel, established a list of eleven component types for physical

inspection. All were accessible at the time of inspection. The inspectors

examined characteristics such as mounting configuration, orientation,

, interfaces, model number, ambient environment, and physical condition. No

concerns were noted during the walkdown inspection.

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