IR 05000458/1987021
| ML20151R716 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/05/1988 |
| From: | Andrea Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151R676 | List: |
| References | |
| 50-458-87-21, NUDOCS 8804280071 | |
| Download: ML20151R716 (35) | |
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APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-458/87-21 Operating License: NPF-47 Docket: 50-458 Licensee: Gulf States Utilities (GSU) P.O. Box 220 St. Francisville, Louisiana 70775 Facility Name: River Bend Station (RBS) Inspection At: St. Francisville, Louisiana 70775 Inspection Conducted: November 2-26, 1987 (onsite) to December 18, 1987 (NRC Region IV office) Inspector: __ M DM& '
A. R. Jofinson ' Reactor Inspector, Division of Date Reactd ty Accompanying Personnel: J. L. Milhoan, Director, Division of Reactor Safety (DRS), Region IV (RIV) , R. Maist, Equipment Qualification and Test ! Engineer, DRIS, NRR l M. Trojovsky, Consultant Engineer, Idaho National Laboratory (INEL)
- Q. Decker, Consultant Engineer, INEL
, V. Nicolette, Member of Technical Staff, Sandia National Laboratories R. E. Irelana, Acting Chief, Plant Systems Section (PSS), DRS, RIV D. E. Norman, Reactor Inspector, PSS, DRS, RIV { R. Evans, Reactor Inspector, PSS, DRS, RIV l Approved: [ N /b/ R. E. Ireland,' Acting Chieft Plant Systems ~~Date ' f/[[ Section, Division of Reactor Safety Inspection Summary Inspection Conducted November 2-6,1987, (onsite) to December 18, 1987 (NRC
- Region IV Office) (Report 50-458/87-21)
j Areas Inspected: Special, announced inspection to review the licensee's implementation of a program for establishing and maintaining the qualifict. tion l
~ ~~8804'280071'880419 PDR ADOCK 05000458 g DCD
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of electric equipment within the scope of 10 CFR 50.49. In preparation for this inspection, the NRC team included a review of GSU's implementation of equipment qualification (EQ) corrective action commitments, identified in Safety Evaluation Report, NUREG-0989, May 1984 (SER), SER Supplements 3 and 5 (August and May 1985). These documents provide the NRC staff acceptance with regard to equipment for which justification for interim operation (JI0s), were provided prior to the November 30, 1985, deadlin The NRC inspection team reviewed a sample of 45 EQ binders (job books and packages) in the EQ file (EQF) out of a total of 89, and walked down 38 components / equipmen Results: The inspection determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49, however, four violations of NRC requirements and five unresolved items about which more information is required, were identified.
l l The licensee's submittals (GSU Walkdown Question / Response Identification Forms) i to the NRC Region IV during and subsequent to the onsite inspection period, provided additional information and addressed the inspection findings presented in the exit interview by the NRC on November 6, 1987. The licensee's information and proposed methods of resolution of the inspection findings have been reviewed and were considered in preparation and issuance of this repor The deficiencies identified by the NRC inspection team involve documentation files which could not establish that this equipment was qualified. These , components were identified during onsite review of the EQ documentation files and a corresponding plant walkdown inspection. The licensee was urged to resolve these concerns and place the necessary justifications for continued operation (JCOs) in place as soon as possible in accordance with the NRC Generic Letter 86-1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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DETAILS Persons Contacted V. Bacanskas, Coordinator, Equipment Qualification Coordinator A. Soni, Supervisor, EQ T. F.- Punkett, Plant Manager J. E. Booker, Manager, RBS Oversight
*R. R. Smith, Engineer, Nuclear Licensing M. E. Walton, Technical Assistant - T. C. Crouse, Manager, Quality Assurance (QA)
D. L. Andrews, Director, Nuclear Training T. P. Anthony, Field Engineering I. M. Malik, Supervisor, Quality Systems J. E. Spivey, QA Engineer D. R. Shah, Senior EQ Engineer D. R. Derbonne, Assistant Plant Manager G. R. Kimmell. Director. Quality Service
* H. Odell, Manager, Administration *K. Suhrke, Manager, Project Management J. R. Hamilton, Director, Design Engineering C. L. Miller, Compliance Analyst P. D.. Graham, Assistant Plant Manager, Operations T. L. Weir, Director, RBS Materials R. J. King, Supervisor, Nuclear Licensing M. F. Sankovich, Manager, Engineering D. N. Lorfing, Senior Engineer, Nuclear Licensing R. B. Stafford, Director, Operations, QA A. D. Kowalczuk, Director, RBS Oversight *H. Roach, Electrical Maintenance Supervisor *C. B. Graham, Supervisor, EQ Maintenance *R. Horn, Nuclear Training Coordinator *S. V. Desai, Senior Instrumentation Engineer Other t
l A. Athelu, Senior EQ Engineer, Consultant j G. McGee, Manager, Engineering, General Electric Corporation (GE) A. K. Wadhwa, Supervisor, Engineer, Stone & Webster Engineering l Corporation (SWEC) i L. Johnson, Site Representative, Consultant i N. Luria, Manager, Qualification Engineer, GE l A. Blum, Assistant Section Manager, SWEC ' L. Illy, Lead EQ Engineer, SWEC A. S. Abella, Field Engineering, SWEC NRC W. H. Paulson, NRR Project Manager l i i
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D. D. Chamberlain, Senior Resident Inspector, RIV
* L. Madsen, Region IV, Project Inspector, RIV * Denotes attendance at the exit interview onl . Purpose The purpose of this_ inspection was to review the licensee's implementation of the requirements of 10 CFR 50.4 . Background NUREG-0588 was issued in December 1979 to promote an orderly and systematic implementation of equipment qualification programs by industry and to provide guidance to the NRC for its use in ongoing licensing review The positions contained in NUREG-0588 provided guidance on (a) how to establish environmental service conditions, (b) how to select methods that are considered appropriate for qualifying equipment in areas of nuclear plants, and (c) other areas such as margin, aging, and documentatio A final rule on environmental qualification of electrical equipment important to safety for nuclear power plants became effective on February 22, 1983. This rule, Section 50.49, of 10 CFR Part 50, specified the requirements to be met for demonstrating the environmental
< qualification of electrical equipment important to safety located in a harsh environme In conformance with 10 CFR 50.49, electrical equipment for the RBS is qualified according to the criteria specified in Category I of NUREG-058 To document the degree to which the environmental qualification program complies with the NRC environmental qualification requirements and criteria, the licensee provided equipment qualification information by letters dated March 1, October 19, and December 14, 1984; and February 15, March 12, 15, and 29; April 26 and 29; May 10, 13, and 15; June 10, 19, 24, and 26; July 19 and 23; August 13, 22, and 26; September 12 and 30; October 10, 18, and 25, 1985; and July 23, 1986, to supplement the information in FSAR Section 3.11 and Appendix A and The GSU SER, NUREG-0989 (May 1984), stated that the NRC had reviewed the adequacy of the RBS environmental qualification program for electrical equipment important to safety as defined in 10 CFR 50.49. The scope of this report included an evaluation of (a) the completeness of the list of systems and equipment to be qualified, (b) the criteria they must meet, (c) the environments in which they must function, and (d) the qualification documentation for the equipmen On January 26-28, 1985, the NRC, with assistance from EG&G Idaho, Inc., conducted an audit of GSU's qualification documentation and equipment installed at the plant. Equipment items were reviewed to determine if the documents in the qualification files supported the qualification status
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, ' determined by the license Several deficiencies were noted and discussed with GSU at the time of the audit. These deficiencies were also provided to'the applicant in June 1985 and transmitted to the applicant by letter dated July 17, 1985. The applicant responded by letters dated June 19 and , July 19, 1985, The NRC reviewed the responses and concluded that the deficiencies had been adequately resolve By letter dated March 29, 1985, GSU in response to Generic Letter 84-24, certified it was in compliance to 10 CFR 50.49 in that all equipment was either fully qualified or a justification for interim operation (JIO) had been submitted pending full qualification, and 10 CFR 50.49(1) was applicable based on their plant schedul By letter dated June 26, 1985, GSU submitted to NRC drywell and containment pressure and temperature results for limiting large break and for various small breaks. These curves showed the corresconding environmental design criteria used for the equipment qualification. SER NUREG-0989, Supplement No. 3, was issued in August 198 For safety-related items not having complete qualification documentation, GSU provided commitments for corrective action and schedules for completion. For items identified that would not have full qualification before an cperating license was issued, analyses had been performed in accordance with 10 CFR 50.49(i) to ensure that the plant could be operated safely pending completion of environmental qualification. These analyses were submitted to the NRC. The NRC reviewed the JI0's and concluded that reasonable assurance has been provided that the River Bend plant could be operated safely pending completion of environmental qualificatio RBS initial criticality occurred October 31, 198 SER NUREG-0989, Supplement No. 5, was issued in November 1985. By letters dated July 19; August 13, 14, 22, and 26; September 12 and 30; October 10, 18, and 25; and November 4, 1985, GSU provided information stating that environmental qualification has been completed on all equipment having outstanding JIO' The aging program requirements for electrical equipment at River Bend are defined in Category I of NUREG-0588. All degrading influences are considered and included in the aging program. Justification for excluding pre-aging of equipment in type testing is to be established on the basis of equipment design and application, or on state-of-the-art aging techniques. A qualified life is to be established for each equipment item. A maintenance / surveillance program is required to be implemented to identify and prevent significant age-related degradation of electrical equipment. GSU committed to follow the recommendations in Regulatory Guide 1.33, Revision 2, which defines the scope and content of a maintenance / surveillance program for safety-related equipment. Provisions for preventing or detecting age-related degradation in safety grade equipment are specified and include (a) utilizing experience with similar equioment, (b) revising and updating the program as experience is gained with the equipment during the life of the plant, (c) reviewing and
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evaluating malfunctiening equipment and obtaining adequate replacement components, and (d) establishing surveillance tests and inspections based . on reliability analyses, frequency and type of service, or age of the items, as appropriate. This maintenance / surveillance program is to be in i effect at River Ben The above identified documents were reviewed by the NRC inspection team " members and used in preparation for this inspection. The inspection involved an onsite and subsequent NRC Region IV in-office inspection of records furnished by the license . Findings 6 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 50.49. 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 status of electrical equipment. Based on the inspection findings, which are discussed in more detail below, the inspection team determined that i the licensee has implemented a program to meet the requirements of 10 CFR 50.49 for the RBS although some deficiencies were identified (refer to Sections 4.f and 4.h). EQ Program procedures
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The inspection team examined the implementation and adequacy of site policies and procedures for establishing and maintaining the qualification of electrical equipment in compliance with the requirements of 10 CFR 50.49. The licensee's methods for establishing and maintaining the qualification of electric equipment j were reviewed in the following documents: I Engineering Department procedures Manual procedure N Title EDP-EE-01 Processing of Equipment Qualification Related Documents, Revision 1 EDP-EE-02 Evaluation of Change Documents for Impact on Equipment Qualification, Revision 1 ' EDP-EE-04 Control and Maintenance of the River Bend Equipment Qualification Master Lists, Revision 1
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EDP-EE-05 Preparation and/or Revision of Equipment Qualification Maintenance and Surveillance Requirements (EQMSR), Revision 1 EOF-EE-07 Ccmpilation, Maintenance, and Updat!ng of the Equipment Qualification Job Books, Revision 0 EDP-EE-09 Control and Maintenance of System Component Evaluation Worksheet (SCEW), Revision 1 EDP-AA-30 Processing Condition Reports within Engineering, Revision 1 EDP-AA-54 Engineering Department Guidelines and Instructions for Processing Modification Requests, Revision 8 EDP-AA-64 Control and Approval of Field Change Notices (FCNs), Revision 6 EDP-AA-65 Review and Processing of Vendor Technical Information, Revision 3 E0 Maintenance procedures Procedure N Title MSP-0003 Preventive Maintenance Program, Revision 10 GMP-0093 Equipment Qualification Special Requirements, Revision 1 GMP-0015 Lubrication Procedure, Revision 3 PMP-1205 Motor Operated Valve Routine Maintenance, Revision 4 Training procedures Procedure N Titie TPP-7-013 Mechanical Maintenance Training, Revision 1 MSP-0009 Qualification of Maintenance Personnel, Revision 8 EDP-AA-10 Training Requirements for Engineering Department Personnel, Revision 6 TPP-7-025 Staff and Management Training Technical Program
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4 TAP-5-007 Training Records and Documentation, Revision 2 TPP-7-027 Quality Assurance Personnel Training, Revision 1 GAP- Quality Assurance Indoctrination and Training Program Procedure, Revision 6 Station Operating Procedures Procedure N Title E0P-0101 Emergency Procedure - RPV Control, Revision 0 Qualification Engineering Procedure Procedure N Title QUAL-85-001 On Site FDDR Oualification Review, Revision 4 QUAL-85-002 River Bend FDDR Qualification Review Check List, Revision 5 Station Support Manual Procedures Procedure N Title ENG-3-006 River Bend Station Design and Modification Request Control Plan, Revision 3 Operations Quality Procedures and Instructions Procedure N Title QAI- Audit Performance, Reporting tnd Followup, Revision 4 QAI- QA Review of Design Changes and Plant Modifications, Revision 1 The inspection team reviewed the above licensee's procedures for meeting the requirements of 10 CFR 50,49 including: (1) qualified life; (2) servict conditions; (3) periodic testing; and
(4) maintenance and surveillance. The licensee's EQ program was also reviewed with regarc 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 i modifications, and installation of replacement equipment to the requirements of 10 CFR 50.4 . - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ . .
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The licensee's EQ program procedures and policies are established and are being adequately implemented to control and maintain the environmental qualification of electrical equipment at RBS for compliance with the requirements of 10 CFR 50.4 The following programs were effectively in place at RBS:
(1) EQ Maintenance / Preventive Maintenance Program (a) The RBS EQ maintenance program has been integrated into the licensee's overall maintenance program through the following procedures which were reviewed by the NRC ,
inspection team: , MSP-0003 establishes and implements a preventive maintenance (PM) program, establishes equipment to be included in the program, monitors and adjusts maintenance activities, and establishes the EQ requirements for parts / component replacement and special maintenance , requirements. Primary features of the program, as related to EQ maintenance, include the Equipment Qualification Maintenance and Surveillance Requirements (EQMSR), issued by engineering to maintenance departments and PM task approvals (PMTA) which are initiated to comply with the EQMSRs. The program is managed by means of a computerized ' PM data base which tracks and schedules the PM activitie GMP-0093, defines EQ maintenance requirements that have not been defined with a specified frequency, but are required anytime a maintenance activity is performe EDP-EE-05 establishes the guidelines for preparing and revising requirements identified in the equipment qualification documentation that are necessary to maintain the equipment in a qualified statu EDP-EE-07 provides guidelines and instructions for compiling, reviewing, maintaining, and updating EQ Job Book > EDP-EE-01 establishes guidelines and instructions for the control, processing, review, and maintenance of EQ-related documentatio GMP-0015 provides general instructions for lubrication of plant components, including EQ items, i PMP-1205 provides instructions for the periodic maintenance of motor operated valves.
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No violations or deviations were identified by the NRC inspection team during the procedural revie (b) In addition to procedural reviews, the NRC inspection team reviewed the EQ maintenance program implementation by selecting a sample of 11 components from the EQ master list and comparing the required PM from the applicable EOMSRs to that scheduled to be performed by the PM data base. All required maintenance for the sample appeared to be adequately scheduled for 10 of these items; however, vendor recommended maintenance shown on the EQMSR for the Gould-Brown Boveri switchgear (mark number 1 ENS *SWG3A), even though included on the maintenance data base, had not been scheduled for completion during this outage, as required. The following maintenance had not been scheduled to be performed:
* -Servicing circuit breakers, *
Exercising circuit breakers,
* Inspection of primary interface connector * Inspection of primary cables, *
Exercising racking mechanism,
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Cleaning contamination from all primary insulation,
* Inspection of control wiring bundles, and *
Cleaning stationary breaker connection stub Prior to the completion of the NRC inspection, the licensee scheduled the maintenance to be completed during the outage. The PM requirement for the equipment had been addressed in Task Approval EC01113 which was added to the required PM tasks on July 27, 1987. Prior to the outage, PM tasks placed on the master outage schedule were placed on "Hold" on May 1, 1987. Since the PM for the subject item was added subsequent to the master schedule "Hold" date, it was inadvertently omitted from the schedule. The PM was due on July 27, 1987, and performed on November 11, 1987, within the 25 percent grace period permitted by MSP-0003, after being identified during the NRC inspectio GSU electrical maintenance group performed a 100 percent review of all task approvals from the "Hold" date to the present and no other missed PM tasks were identifie No violations or deviations were identified by the NRC inspection tea (2) Control of Plant EQ Modifications RBS procedures were reviewed by the NRC inspection team to ensure proper maintencnce of documentation for EQ components during plant modifications as follows:
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. (a) Procedure EDP-EE-01 provides guidelines and instructions to maintain control, processing, review, updating, and maintenance of documentation for EQ components. An EQ reviewer reviews assigned documents (including vendor technical information, modification requests (MR),
nonconformance reports (NR), condition reports (CR), EQ maintenance / surveillance requirements, NRC or INPO i correspondence and IE notices / bulletins), and determines if the document is applicable to, or affects EQ. If there is an impact, the impact is tracked on an EQ documentation , lo (b) Procedure E0P-EE-02 specifically describes the requirements for evaluation of MRs, NRs, and CRs for impact on EQ components. A copy of the attached EQ Impact Summary (EQIS) sheet, and tb EQ Impact Review Checklist (EQ1RC), are then included in the MR/CR package Any EQ documentation requiring revision and/or initiation of action as well as EQ evaluations are identified on the EQI (c) Procedure EDP-AA-54 establishes guidelines and instructions for processing MRs by engineering personnel. Most MR packages include an EQIRC (EDP-AA-54, Attachment G) to ensure that qualification is maintained if modifications to the plant are required. A checklist is required for all emergency and Q Class 1 MR (d) Procedure ENG-3-006 provides overall instructions on controlling design and modification actions at RBS. This procedure is used in conjunction with EDP-AA-54 when processing MRs. The modification completion checklist (ENG-3-006, Attachment 5) includes instructions to ensure that EQ documentation has been updated prior to final closeout of an M (e) procedure EDP-AA-64 provides directions on the control and approval of field change notices (FCNs). The FCN provides a method of incorporating a change into an existing MR design, and the FCN becomes a part of the MR package. The FCN is reviewed to determine if any previous review or evaluation is affected by the change, with regards to qualification of component (f) Procedure EDP-AA-30 provides instructions for processing CRs within the RBS engineering department. The Condition Report One Time Deviation Design Review (EDP-AA-30, Attachment B) ensures that a qualification review is performe .- j(
. (g) Procedure QAl-2.6 defines and establishes QA responsibilities for the review of design change activities including MRs, FCNs, and NRs. QA checklists (QAI-2.6, Attachment 2 and 3) are used in the review of MRs and FCNs to ensure they are in accordance with applicable procedures and requirements, including EQ engineering review No violations or deviations were identified by the NRC inspection team during review of procedure In addition to the procedure review and interviews with personnel, the NRC inspection team reviewed the implementation of the EQ modification program by selecting one MR (No. 86-1778)
to ensure the licensee was following approved procedure Controls for the EQ Modification Program appear to be adequately implemented based on the selection of this one M Further verification of the GSU EQ Modification Program, using a larger sample, will be accomplished during a subsequent NRC
- inspectio (3) Procurement of Materials and Services Including Replacement Parts The RBS EQ Procurement Program is an integral part of the licensee's overall EQ Program and is controlled by the following procedures:
Procedure N Title RBNP-003 Material Management System NuPE-AA-42 Evaluation and Justification of Commercial Grade Items EDP-AA-43 Technical Quality Documents for Procurement The RBS EQ Replacement Parts Program is integrated with the EQ , Maintenance Program (refer to paragraph 4.b(1)(a) above) which establishes the requirements for part/ component replacemen Also, the EQ Replacement Parts Program is governed by those procedures listed abov Further review of the controls and implementation of the EQ Replacement Parts Program at RBS will be accomplished during a subsequent NRC inspection, i i
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c. Training Program
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A review was conducted by the NRC inspection team to determine if a ^ training program was in place to provide necessary training to personnel involved in implementing all phases of the EQ program at RBS as follows:
(1) Technical Staff and Management - This program consists of a series of formal training courses and mandatory reading lists which are specified in Procedures TPP-7-025, EDP-AA-10, and TAP-5-007. Procedure TAF-5-007 is applicable to all RBS discipline The program for training of technical staff and management appears adequate; however, review of implementation of the program could not be completed because of an inadequate sample of training records available at the time of the onsite inspectio (2) Quality Assurance - The Ouality Assurance and Quality Control training programs consist of formal training, on-the-job training, and mandatory reading lists which are specified in Procedures QAP-1.3 and TPP-7-027. No specific EQ training or mandatory reading could be identified in this program revie Also, review of the program implementation could not be completed because of an inadequate sample of training records available at the time of the onsite inspection.
< (3) Maintenance Program - The RBS maintenance program reportedly meets INP0 accreditation standards in the areas of mechanical, electrical, and instrumentation and control (I6C). The objectives of this inspection were to review procedures which establish the program and to review the program implementation by reviewing a sample of employee training record Procedures MSP-0009 and TPP-7-013 were reviewed during the , inspection.
, Items identified in paragraphs 4.c(1), 4.c(2), and 4.c(3) above are l considered an Unresolved Item pending review of electrical and I&C j procedures and training records which were not available during the ' NRC onsite inspection (458/8721-07).
. d. 0A Audits of EO Activities ) l A review of RBS QA audits of EQ activities was performed, including interviews with key QA personne ,
(1) Procedure QAI-2.1 defines the responsibilities and the methods
- to be used by the GSU QA organization for planning, performing,
, reporting, and followup of QA audits of RBS site activities.
! Prior to an actual audit, a "Master Audit Schedule" and "Master
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Audit Plan" are developed, followed by a "Notification of Audit" letter to the specific department to be audited. The audit is performed in accordance with a GSU audit plan. Audit finding
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reports are issued within 5 working days and the formal report is issued within 30 day The NRC inspection team reviewed GSU Audit No. 87-01-I-EQAL regarding an audit of the GSU EQ program, performed during
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January 1987. The audit was conducted to provide an overall assessment of the adequacy and effectiveness of the EQ program implementation. Emphasis was placed on the capability of the program to maintain designated equipment in a qualified status in accordance with the acceptance criteria of 10 CFR 50 Appendix B, 10 CFR 50.49, and RBS procedures. A previous audit by DiBenedetto Associates (Audit Report No. GSU-01-08-01, Revision A, dated October 22,1986) focused on the adequacy of the original qualification data. The NRC inspection concentrated mainly on the maintenance of EQ qualification equipmen The NRC inspection team concluded that QA audits of EQ activities were effectively being implemented at GS No violations or deviations were identifie e. 10 CFR 50.49 Equipment Qualification Master List (EQML) ] The EQML and suoporting procedures were reviewed to determine if a , program has been implemented to generate, maintain, and distribute the EQML in accordance with 10 CFR 50.49 requirements . ' Procedure EDP-EE-04 is used to provide control and maintenance of the RBS EQML. All documents having impact on EQ activities at RBS are processed through an EQ reviewer, who determines if the documents warrant an EQML chang If an update is required, changes to the , EQML are made using EQML revision control sheet The EQML was reviewed against emergency operating procedures (EOPs) and procedure No. E0P-0101 to ensure postaccident monitoring (PAM) , components listed as part of the RG 1.97 program were included on the
- E0M Eight PAM parameters were selected and all components were l found on the EQML.
I No violations or deviations were identified.
! f. EQ Documentation Files i
The licensee's environmental qualification file (EQF) at RBS has been l' established and is being maintained to meet the requirements of 10 CFR 50.49. The requirements are contained primarily in Procedures EDP-EE-07, EDP-AA-65, and QUAL-85-001, t
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. The NRC inspection team examined files for 45 selected equipment items (E0JBs) 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 NRC inspectors selectively reviewed areas such as: (1) required post-accident operating time compared to the duration 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 IE Information Notices (IN) and IE Bulletins (IEB) and their resolutio During this review of the EQF, the inspection team identified the concerns described below:
(1) EOF Auditability and Organization of Documentation During the NRC inspection, a concern was raised with regards to the organization of documentation in that it was not readily understandable and traceable to permit independent verification of interfaces or conclusions. The auditability concerns pertained primarily to the EQJBs in the EQF having provided incomplete information in establishing qualification of equipment, as identified by the NRC inspection team as follows: (a) E0JBs 211.161 and 241.232: Hydrogen Ignitor Assemblies, Bisco Sealing Compound, Conax Electrical Conductor Seal Assembly, Raychem Heat Shrink Splices, Marathon Terminal Blocks, Okonite Tape Splices, Anaconda Power Cable, and Rockbestos Instrument Cable: File Auditability Problems Many RBS files were difficult to audi For example, in most files reviewed a similarity analysis and an evaluation of performance characteristics were not part of the fil Similarity questions arose frequently and required tracing down the trecification and purchase order, Licensee personnel often gave conflicting verbal answers to questions, and significant time was required to obtain the correct answers in writin (b) E0JBs BOP Limitorque Motor Opetator, File Auditability Problems It was not apparent in the file that cycle testing of motor operators required for RBS had been enveloped by the cycle tests contained in the file used to support qualification of the actuators installed. Discussions with licensee personnel revealed that the approach used to address this
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concern had been incorporated into the specified cycle testing of similar actuators in the GE phase III testing program. No specific references or auditable trail was - contained in the EQ When questioned whether or not the proper orientation of the motor actuators had been considered in regard to greases, which are found to migrate from the main gearbox to the motor or switch compartment, the licensee supplied the NRC inspection team with installation procedures. The procedures clearly showed that this concern had been addressed in the actuator installation and during subsequent inspections of the Limitorque actuators at RB However, no specific references or auditable trail to the SWEC installation procedures were contained in the EQ It was not evident in the EQF that either Raychem Flamtrol or Rockbestos Firewall III was used as replacement wire for internal wiring of SMB Limitorque motor operators. The HRC inspection team identified only Reckbestos Firewall III in motor operators inspected during the NRC walkdow (c) E0JB SRN 503, Limitorque SMB Motor Operators, High pressura Core Spray, Outside Containment, File Auditability Problems The basis of qualification of. these valve operators is . NUREG-0588, Category Qualification was supported by l Limitorque Report B0058, dated January 11, 1980, for SMB model actuators. Wyle Report 57675, dated April 30, 1986, extended the qualification to additional models by providing a similarity analysis for the other model Qualification of the operators was adequately established; however, audit of the qualification documentation was difficult since changes to the tested configuration had not been adequately documented in the EQJB documentation packages. This became apparent during the walkdown inspection and is discussed in greater detail in paragraph 4.h of this report. Examples of auditability problems are: 1) Taped splices made onsite, and not a part of the tested configuration, were not identified in the EQJB oualification documentation of the EQ ) Terminal blocks, which were not in the tested , configuration, had been installed and were not identified in the E0JB qualification documentation of the EQF.
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t GSU responded to the above NRC concerns by letter
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No. RBG-27213 to the NRC Region IV on December 28, " 1987, as follows: L
"The puroose of the EQJB is provided in Design .
Engineering Procedure EDP-EE-07, of which Section ' states that the EQJBs contain copies of the controlled , documents that are compiled to provide the EQ auditors with readily accessible cross-reference informatio The information contained within the EQJB job book is intended to demonstrate tFe environmental qualification of the equipment used at RB During an audit of-the EQ program at RBS performed by an independent third party consulting firm, similar questions with respect to EQJB content were raise : Since the completion of the independent audit, RBS had initiated steps to resolve the questions previously identified; however, these actions were not completed prior to the NRC inspection. GSU recognizes that the concerns raised by the NRC inspection team, with respect to auditability, were similar to those identified during the independent audit. The concerns > are being addressed on a generic basis with the files being reviewed against a checklist which requires EQ auditors to verify that the information discussed above is included in the EQJB documentation package , Specific action areas identified for RBS to upgrade the EQJBs include: (1) identification of installed i equipment interfaces, (2) addition of documentation to the EQJBs for design changes, (3) analysis of functional performance requirements, and (4) reference ; to associated calculations (i.e., instrument accuracy
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calculations, MVA reduced voltage calculations, etc.). These actions are in progress and will be completed by GSU on June 30, 1988." ; . , Items identified in paragraphs 4.f(1)(a) 4.f(1)(b), and i 4.f(1)(c) above are considered an Unresolved Item (458/8721-06).
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(2) EQJBs 228.212, 228.214. 228.216. 228.241, 228.243 and SRN 503:
BOP and NSSS Supplied Limitorque SMB/SB Motor Operators (Inside and Outside Containment)
(a) BOP Supplied Limitorque Motor Operators. Models SMB and SB f (SPEC. 228.212) t
!, ! This EQJB file contained documentation to support ! ! qualification of the BOP-supplied Limitorque motor ,
- operators installed at RBS. Valve actuator '
' Nos. 1G33*MOVF001, 1821*MOVF016, and IE51*MOVF064 documentation was reviewed by the NRC inspection team.
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Actuator IG33*M0VF001 is located inside the drywell and is used to operate the containment isolation valve for the reactor water cleanup system. Actuator 1821*MOVF016 is also located inside the drywell and is used to operate the containment isolation valve for the drain syste ~ Actuator 1E51*MOVF064 is located in Zone AB-114-2 (main steam tunnel) and is used to position the reactor core isolation cooling (RCIC) turbine steam supply containment isolation valv ) The licensee was asked to supply data which would indicate that the motor operators used in dual voltage application were properly sized for reduced voltage application at RBS. The licensee supplied motor operator calculations which showed that reduced voltage considerations were factored into the selection of these valve actuator motor operator ) A full inspection was performed by the NRC inspection team on JB21*MOVF016 which included verifying that proper components and materials internal to the limit switch compartment were installed. In addition, an external inspection was performed, with only one minor deficiency identified in that the model depicted on the EQML was SMB, whereas SB was found on the actuator nameplate. It was determined that this was a transcription error and to correct this error, the licensee committed to initiate a master list revision control (HLRC) and system compo,ent evaluation
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worksheet (SCEW) revision form to indicate the correct model and to verify the accuracy of nameplate transcriptions for other valve No violaticns or deviations were identifie (b) Okonite T95 and 35 Sp_1_ ice,hp_e Applicatiens on 80P-Supplied Motor Operators Not all of the types of splices used in Limitorque motor operators at RBS were identified in the EQJB (Limitorque) files; nor was any reference to the documentation used in establishing the qualification of these splices f0und in the file During the walkdown, the NRC identified Okonite T95 and ! 35 splice tape incorporated as the motor lead / field cable splice material. An evaluation of the EQJBs that establish qualification of the B0P-supplied motor operators revealed that the motor lead / field cable interface had not been identified (also refer to paragraph 4.h(1) of this report).
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The licensee supplied reference to the documentation file used to establish qualification of the Okonite T95 and 35 splice tape as EQJB 211.161 (fer application of motor leads and control circuits for motcr operators). This file is part of SWEC specification for nonengineered field purchased items. There were two concerns with this file as follows: 1) During the NRC walkdown, a V-shaped splice configuration was observed to be installed as well as an in-line configuration. The observed V-shaped splice configuration was not qualified by documentation contained in EQJB 211.16 By the end of the inspection, the licensee was able to demonstrate that the V-shaped configuration could be qualified, thus resolving this concern. However, documentation was not present in the EQJB during the NRC inspection, indicating that the licensee had not adequately assessed the similarity of tested and installed splices. NUREG-0588, Category I, Section 5, paragraph 1 states that the basis of qualification shall be explained to show the relationship of all facets of proof needed to support adequacy of the complete equipment. The EQJB for Okonite tape did not contain sufficient information to establish that the tested and installed specimens were identical or simila ) The NRC inspection team identified another concern regarding insulation resistance data taken during the type test for the in-line splice configuration w' ich ' were not included in the EQJB. Since these splices are used in harsh environments (including steam) in coatrol circuits, the insulation resistance data was requested. The licensee obtained this data from Okonite on November 6, 1987, during the NRC inspection ar.d presented it to the NRC. The data indicated several insulation resistance measurements which were so low that they were off the instrument scale. The vendor test laboratory attributed the low values to improper sealing (equipment apparatus) where cables entered the test chamber. Because of the timing in which measurements were taken of the low insulation resistance values (af ter the most severe temperature and moisture conditions), the NRC inspection team agreed with this explanation of the test anomalie While this observation was resolved concerning insulation resistance data, it indicated that the licensee did not have this data prior to the inspection and obviously had not reviewed it for its
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impact on the specified functional performance requiremcnts of control circuits at RB ) The NRC inspection team identified another concern regarding unidentified tape splices to motor operator replacements from Class B to RH insulation. Refer to paragraph 4.h(1) of this repor Along with the analysis that provided established similarity of the V-type tape configuration (as found in ICCP*M0V144) to the in-line shaped tape configuration, the in-line type tape splices were also the configuration found in the remaining four motor operators inspected by the NRC inspection tea The above concerns in paragraphs 4.f(2)(b)1), 4.f(2)(b)2) above, and 4.h(1) are considered an apparent violation of 10 CFR 50.49 (458/8721-01).
(c) Qualification of Terminal Blocks (tbs) used in NSSS and B0P Supplied Limitorque Motor Operators 1) B0P Limitorque Motor Operators At the time of the NRC inspection, the licensee had yet to identify all of the tbs incorporated in the power and control circuits internal to the switch compartment of these Limitorque actuators installed at RB The types of tbs that may have been used were not identified in the docementation for all the above 80P-supplied actuators; nor was the methodology incorporated in the EQJBs to establish qualification of the tbs found in motor operators at RBS. The only interface described was found in the documentation of the GE Phase III testing where Marathon 300 tbs were incorporated in the tested Limitorque actuator ) EQJB SRN S03, Limitorque Motor Operator, Outside Containment, Unidentified Terminal Blocks During the walkdown inspection, Buchanan tbs (no visible model number) were identified in Limitorque motor operators for valve actuators 1E22*MOVF001, 1E22*MOVF004, 10FR*MOV146, and no TB identification could be found on ISWP*MOV5703. The tbs were apparently not oriented in the type test configuration, or the operator and had not been addressed in the documentation file for the operator Therefore, the qualification status for these motor operators was indeterminat The licensee had no documentation at the time of the NRC inspection to [
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identify tbs which had been installed in these operator The licensee performed a walkdown~ inspection, at the time of the NRC inspection, of all safety-related Limitorque operators on November 23, 1987, at which time tbs were identified and summarized. The summary presented to the NRC did not include Buchanan tbs blocks which had previously been identified during the NRC inspection; therefore, the licensee's inspection results appear to be inconclusive. It was also stated by the licensee, concerning TB qualification, that Corporate Consulting Limited Report A-686-85 (SDDF No. 6211.161.997-138A and -139A) demonstrates qualification of tbs used at RB The above concerns in paragraphs 4.f(2)(c)1) and 4.f(2)(c)2) regarding the identification and qualification of tbs incorporated in the Limitorque motor operators at RBS is considered an apparent violation of 10 CFR 50.49 (458/8721-04).
(3) EQJB 213.161, Marathon Terminal Blocks The NRC inspection team reviewed this file on Marathon NUC 1500, 1600, and 142ST tbs. These blocks are part of the SWEC specification for nonengineered field purchased items. At RBS, these tbs are not used inside contai.nment, but can be found in harsh environments (including steam). The file contained confusing statements as to whether or not these tbs are in ' completely sealed junction boxes. Some junction boxes are completely sealed and some have 1/4-inch weep holes drilled in the bottom. A referenced talculation in the file successfully demonstrated th? abiliP,y of the completely sealed junction boxes to withstand postulated accident pressure differential The I licensee showed the NRC inspection team installation drawings and specifications indicating that top entry conduits were seale The identification of the sealant could not be confirmed during the inspection: however, after the inspection, the utility identified the sealant as Promatec Low Density Elastomer (PLDE). This sealant had been qualified as part of the mechanical equipment qualification program at RBS. Its use to protect electrical components was not addressed in the EQJ This raised a concern on the part of the NRC inspection team that the installed sealant may not be qualified for LOCA/HELB environments and may allow moisture to reach the Marathon 1600 tbs housed in junction boxes. Since these tbs are used in instrumentation and control circuits at RBS, the effects of moisture may be leakage currents in these circuits large enough to give misleading indications to the plant operato There _- _ - _ . __
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were no functional performance calculations in ene EQJB since RBS assumed the blocks would not be used in a steam environmen Since qualification of the Marathon 1600 tbs is dependent on the integrity of the seal, the licensee must oemonstrate that PLDE is an acceptable sealant for the junction boxes housing tbs. A functional performance evaluation of Marathon 1600s will be necessary if the terminal blocks are determined to be susceptible to a steam / condensate environmen This item is considered an Unresolved Item (458/8721-08).
(4) EQJB 211.161, Bisco Scaling Compound The NRC inspection team reviewed the file on the Bisco LOCA-Seal sealing compound. This compound is part of a SWEC specification for nonengineered items, field purchased. The file contained Wyle Test Report 17607, Revision A. A qualified life of greater than 40 years at 150 F was established. The type test environment enveloped the reautred RBS environment. The compound was tested in a fitting which was subjected to 187 Mrads of gamma radiation. The only concern raised with this file is that the licensee was not sure exactly where this sealing compound is used. The file contained a note that the sealant was typically used in fittings (*.d sometimes in junction boxes. RBS was able to identify, by the end of the NRC onsite inspection, that the sealant observed between cables and conduit on the NRC walkdown was not Bisco LOCA-Seal. This file was initially reviewed for qualification assuming that the sealant
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was housed in a fittin The NRC inspection team concluded that if the sealant is actually installed unrestrained, the qualification file would need further data to establish qualification of all the additional configurations for which the Bisco LOCA-Seal is use GSU responded to the NRC concern by letter No. RBG-27213 to the NRC Region IV on December 28, 1987. The Sisco LOCA-Seal used at RBS was procured under Specification 211.161, Nonengineered Items. Data Sheet No. 1144, Section D, includes a product technical description which states that the conduit entrance sealing compound is to be used for ASCO solenoid valves (Class IE located in a harsh environment) to seal out moistur Also a Babcock and Wilcox basic ceramic fiber is to be used as a damming material. The installation drawings which identify the devices sealed with BISCO LOCA-Seal are also included in the BISCO LOCA-Seal EQJ3. Review of these drawings identified the use of the BISCO LOCA-Seal on ASCO solenoid valves and thermocouples only. The additional information supplied by GSU resolved the NRC inspectors concerns for solenoid valves and thermocouples only. Data to establish qualification of
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other component applications using Bisco LOCA-Seal will be reviewed during a subsequent NRC inspectio This item is considered an Unresolved Item (458/8721-09).
(5) EQJB 211.161, Conax Electrical Conductor Seal Assembly The NRC inspection team reviewed the file on the Conax electrical conductor seal assembly (ECSA). The ECSAs are part of SWEC specification for nonengineered items which are field purchased. Conax Reports IPS-409 and -411 in the file were used to document qualification. The NRC inspection team had difficulty with the similarity analysis but was directed to the necessary information which verified that the tested and installed ECSAs are identical. There was a concern that the test profile (14 days) did not envelope the 100-day postaccident operating time, and an arrhenius calculation was performed and submitted to the NRC inspection team. This calculation was not present in the file prior to the inspection, indicating the licensee had not adequately addressed the test data for RBS application. The calculation indicated the test profile enveloped the required profile, only by using an activation energy of 3.916 eV for Kapton and polysulfone materials used in the construction of the ECSA. When questioned about the use of such a high activation energy as 3.916 eV in the calculation, the licensee referred to a letter from Conax to SWEC which referenced Conax Report IPS-325 from which the data using this high activation energy was apparently derived. Data which indicates the use of an activation energy of 3.916 eV for an ECSA containing materials which have been known to have lower activation energies, as documented in prominent test laboratory data banks (1.299 eV and 0.84 eV), will require the licensee to further review the bases for qualificatio NUREG-0588, Category I, Section 5, paragraph 1, states that the qualification documentation shall verify that c.ach type of electrical equipment is qualified for its application and meets its seccified performance requirements. The RBS Conax ECSA test data had not been evaluated to verify that the ECSA met the necessary performance requirements beyond the November 30, 1985, deadlin This item is considered an apparent violation of 10 CFR 50.49 (458/8721-03).
(6) EQJB 241.242, Rockbestos Instrument Cable 300 Volt Firewall III (FWIII) The inspection team reviewed this file for Rockbestos instrumentation cable at RBS. The file contained several of the f
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. latest Rockbestos reports including QR5804, QR5805, and QR680 There were two concerns with this fil (a) RBS did not appear to know which formulations of Rockbestos they had installed in their plant. The licensee stated initially that they had chemically cross-linked as well as irradiation cross-linked cables, and they were in the process of confirming this. Thus similarity could not be conclusively established. After the inspection, the licensee was able to provide the NRC inspector with information indicating they had Rockbestos KXL760G (irradiation XLPE). However, this information was not present in the file and required a letter from Rockbestos (November 13,1987) to clarify the questio (b) A concern arose when the NRC inspection team could not find an analysis, regarding functional performance requirements for instrumentation circuits involving cable connections to components addressed in the fil The licensee then provided a worst case calculation for irradiation cross-linked Rockbestos FWIII and Brand Rex Special Instrument cable for a typical pressure transmitter and RTD circuit at RBS. There were two problems with this submittal. First, it didn't account for any chemically cross-linked FWIII which may be in instrumentation circuits and has lower insulation resistances than the irradiation cross-linked FWIII. This concern was resolved when the licensee was able to show they.hao no chemically cross-linked polyethleyne cables at RBS. Second, the calculations were dated October 22, 1987, indicating they had been performed the week prior to the NRC inspectio The NRC inspection team asked to see any calculations which the licensee had in place before this dat The utility responded that no such calculations existed, but engineering judgement had been exercised 'n assessing applicability of the Rockoestos and Brand Rex cable for instrumentation circuit NUREG-0588, Category I, Section 5, paragraph 1, states that the qualification documentation shall verify that each type of electrical equipment is qualified for its application and meets its specified performance requirements. The RBS instrumentation cable circuits had not been evaluated to verify that they meet the necessary performance requirements until after October 22, 1987, beyond the November 30, 1985, deadline. Also thu Rockbestos Firewall III EQJB files did not contain sufficient information to establish that the tested and installed specimens were identical or simila . _ _ ______ _ -___ ____ __ _
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The concerns of paragraph 4.i(6)(a) and 4.f(6)(b) above are considered an apparent violation of 10 CFR 50.49 (458/8721-02).
(7) EQJB 242.491, GE Terminal Boards, Model EB-25 The GE tbs, Component ID IRO*TCA08, documented in this file are located in the auxiliary building in environmental zone AB-114- The tbs are in the Reactor Core Protection system. The test report referenced to demonstrate qualification is Southwest Research Institute Report No SWRI-6772-31 (a) During the review of the file, it was noted that GE TB qualification for humidity was not establishe The SCEW sheet indicated that tbs were qualified to 98 percent relative humidit In reviewing this test report no testing for relative humidity was establishe GSU personnel stated that qualification documentation was available to establish qualification of the EB-25 tbs to the specified values per NUREG-0588, Category I and they would be included in the EQJ (b) During the equipment walkdown, it was determined that Marathon tbs are also installed in the terminal cabinet referenced in this EQJB. When GSU was questioned concerning qualification of the Marathon tbs, they stated the tbs were qualified using Wyle Test Report No. NEQ-45603-1 and traceability to their qualification will be included in the EQJB by E&DCR No. C-23.13 Pending update of EQJB 242.491, as described in paragraphs 4.f(7)(a) and 4.f(7)(b) above, this is considered an Open Item (458/8721-11).
g. Review of IE Information Notices (IN) and Bulletins (IEB) The NRC inspector reviewed Nuclear Licensing Procedure NLP-10-006, Revision 1, dated October 30, 1986, titled, "Processing and Tracking of Regulatory and Industry Correspondence." The purpose of this procedure is to provide a systematic method of processing and tracking licensing correspondence from the Nuclear Regulatory Commission such as IEBs, ins, inspection reports, generic letters, and requests for additional informatio In order to assess the effectiveness of RBS program, the inspector selected ins relating to EQ issues and reviewed responses and actions for each IN. The inspector determined that appropriate actions were taken by RBS for each IN and that the implementation of their program as stated in the above procedure was followe No violations or deviations were identifie _ . _ . __ ._ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ -_
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I l Plant Physical Inspection The NRC inspection team, with the rcquired tagging out of operation i selected equipment and components by the licensee, walked down and physically inspected 38 EQ components / equipment at RBS. The inspection team examined attributes and characteristics such as mounting configurations, orientation, interfaces, ambient environment, and physical condition; the team also verified traceability of equipment identified in the EQJBs in the EQF by model and serial number During the NRC walkdown inspection, the NRC inspection team identified the concerns described below:
(1) EQJB SRN S03, Limitorque Motor Operators, Outside Containment, Unidentified Taped Splice During the NRC walkdown inspection, Limitorque valve operator IE22*MOVF001 was found to have taped in-line butt splices in the motor leads. Since there was no record of the splices in the EQ documentation defining a change to the tested configuration, the splice type and qualification status were indeterminat The NRC inspectors were provided Procedure CMP-1277, dated December 17, 1984, entitled "Low, Medium, and High Voltage Power i Cable Splicing, and Termination." It was the NRC inspection teams' understanding that splices were to be installed to the requirements of this procedure after the initial startup of RBS.
( Okonite Report NGRN-3, dated June 23, 1980, was used as a basis l of qualification for splices included in CMP-1277. The test l report was documented under SDDF 6221.161-997-009. Neither of ' these documents was in the EQF during the time of the NRC inspectio It was found that CMP-1277 had not been released for use by QA l because of procedural inadequacies; alternately, splices were ! made in accordance with Specification 248, Revision 9, Appendix The qualification status of the identified splices remained indeterminate since it was not known if the splices were identical or similar to CMP-1277 splices.
l Prior to the end of the NRC inspection, the licensee performed ! an analysis which showed similarity between the tested splices and those identified during the NRC inspection, for V-shaped l splices which were identified by the NRC inspection team in l operator ICCP*MOV144 (refer to paragraph 4.f(2)(b) of this report). The analysis was added to the Okonite tape splice l EQJB 211.161. A note was also added to the Limitorque operator l SCEW sheets, referencing the appropriate EQJB for electrical interfaces. A 100 percent walkdown was also performed by the licensee to verify splice acceptability.
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Also, Modification Report (MR) 86-0395 was included in a supplemental EQJB to the Limitorque operator EQJB SRN S03 in the EQF. This supplement had not been provided for review by the < NRC inspection team. The MR, initiated on March 7, 1987, was not approved at the time of the NRC inspectio Its purpose was to replace operator motors that had Class B insulation with equivalent motors that have RH insulation in order to extend the operator life. The replacement motor leads were spliced with the Okonite splices qualified by Okonite Report NGRM-3. The MR required splices to be made in accordance with Specification 248, Revision 9, Appendix .The concerns described above are considered part of the apparent violation of 10 CFR 50.49 identified in paragraph 4.f(2) of this repor (482/8721-01)
(2) SNR 224150 and 228212, Limitorque Motor Operators, Outside Containment, Blind Barrel Crimped Connector Splices for Dual Voltage Application During the walkdown inspection, Limitorque valve operators IDFR*MOV146 and ISWP*MOV510 were found to have blind barrel crimped connector splices in the motor leads. The operators were equipped with 230/460 volt Reliance motors with Class B insulation. These splices are factory installed during assembly of the Limitorque motor operator valve actuator and provide a dual voltage motor application which are procured for 460 Vac service. This is the manufacturers. generic configuration for all operators equipped with dual voltage motors supplied by Limitorque. Qualification test reports contained in the EQJBs for the operators did not inc1Me documentation to support qualification of these splice GSU responded to the above NRC concerns by letter No. RBG-27213 to the NRC Region IV un Decuoer 28, 1987. Limitorque has subjected the dual voltage motor design to environmental qualification testing on four separate occasion Limitorque has tested dual voltage motors with Reliance Class H, Type RH insulation (Test Report No. 600376A), and with Reliance Class B insulation (Test Report No. B0003). Limotorque has also tested dual voltage moters with Reliance Class B insulation (Test Report No. F-C3271); and with Class H, Type Rad H insulation (Test Report No. 600198). A quality assurance audit of Limotorque's facilities in Lynchburg, Virginia, which was conducted by another licensee, included within its scope a review of purchase order records for these crimp connector type splices used by Limitorque. The purchase records at Limitorque indicated a purchase of 112,000 Thomas & Betts RC-6 splices between April 1967 and May 1979; 240,000 Thomas & Betts RB-4 splices between January 1971 and June 1973; and 30,000 Thomas &
Betts RB-44 splices between June 1984 and June 1987. GSU
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believes the tests cited above included these crimp connector splices manufactured by Thomas-& Betts, even though documentation to verify this conclusion is not availabl . A qualification test for Thomas & Betts RB-4 and RB-6 nylon crimp connector splices used in dual voltage Limitorque operators was being performed by Wyle Laboratories. An 8 year screen qualification test was completed successfully in late October 1987 with a completed test summary. A 40 year qualification test is being conducted and completion and issuance of a final test report is scheduled for early 198 The results of the test program will be required to be incorporated in the EQJBs to document the qualification when the final test report is issued. At this time the type test results are preliminary and supporting analysis to show similarity to the equipment tested and environment installed at RBS has not been establishe NUREG-0588, Revision 1, Category 1, paragraph 5, requires that cualification documentation shall verify that each type of electrical equipment is qualified for its application and meets its specified performance requirements. The basis of qualification is required to be explained to show the relationship of all facets of proof needed to support adequacy of the complete equipment. Data used to demonstrate the a qualification of the equipment shall be pertinent to the application and organized in an auditable form. The documentation is required to include sufficient information to address those items identified in NUREG-0588, Appendix E, which includes splices (item 16).
I The NRC item described above is co151dered an Unresolved Item (458/8721-05).
5. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items identified during the inspection are discussed in paragraphs 4.b(1)(b), 4.c, 4.f(1)(a), 4.f(1)(b), 4.f(1)(c), 4.f(3), 4.f(4) and 4.h(2).
6. Exit Interview An exit interview was conducteo on December 12, 1987, at the conclusion of the onsite inspection, with GSU in which the scope of the inspection and findings were summarize U.S. NUCLE AR REGULATORY COMMISSION sv sC + At *Nsac cm N 4 v w <m ov ~n % , Mc sCav 766
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eo-Office of Inspection and Enforcement K- . vetuon om ot u ren w.< eo no suc envuove w eun e n ose " r uce*** une ww "-* o* uns u, ro o* non<a** i,~r n, es ro w ena.ur.,, un >
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Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and Section 5(1) of a NUREG-0588, Category I, E0JB 241.242 intheJQFforRockbestos ar :x'e, did not adequately
*
Firewall III 300-volt instrument cable a:. support qualification (1) in that similari[y between the tested 5 irradiation cross-linked insulation cable and the cable installed at RBS was not established (originally chemically cross-linked insulation cables
,
were ordered at RBS and no information was available in the EQF to clarify 7 what was installed); and (2) in that no functional performance
,
requirements on instrumentation circuits W 7e'rYormed and documented in i the EQF in consideration of cable insulation resistances. The EOF did not
' verify that these cable types had been evaluated to meet the necessary ,,
functicnal performance requicements specified [ Appendix B, paragraphs 4.f(6)(a) and 4.f(6)(b)]. 11-
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Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and Section 5(1) of NUREG-0588. Category 1, E0JB 211.161 in the EOF for Conax electrical
,
conductor seal assembly (ECSA), did not adequately support qualification
in that similarity between the tested ECSA and those installed was not established at RBS. The test profile, contained in the EQF, did not The EOF did not verify
,
envelope the 100-day postaccident operating tim > that the installed ECSAs had been evaluated to meet the necessary
,
functional performance requirements specified [ Appendix B, paragraph 4.f(5)]. e to 1 .
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~ REPORT WODULENuwBf9 IvRC 80aM 796 A DCC111 NO t8 at's> OR UCE NSE ill - NO (87 PRODUCis tt3 0ttse NO $M h[h h O 6 O O O 45 e a*7 * ~ ' ~ . ~ ' ~ ~ * $ INSPECTOR'S REPORT (Continuation) pli e , , 3 . . . y.'tc ao-Office of Inspection and Enforcement c K .. Q . votarc, on oevsa to, wn*< *o w sm enewes w eun ~~ m "a *"***n~* "****' " ~" ** """"," ***"'"* L~ "*n w u c"vwe= =un s
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Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and Section 5(1) of NUREG-0588, Category I, the EQJB B0P-Limitorque and EQJB SRN 503 for
* Limitorque motor operators, did not adequately support qualification 3 (1) in that the terminal block (TB) types used within the operators were not identified in the documentation file: (2) no methodology to establish * qualification of these TB's were in the documentation file; and (3) a ,
similarity analysis, to demonstrate qualification of tbs used in operators represented by the EQJB SRN 503 file, was not available [ Appendix B,
'
paragraphs 4.f(2)(c)l) and 4.f(2)(c)2)]. s to i tt
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tans,o on onvaron wnw ,.o ro sa cwuws w enn m o w*=t =um* *~* ~~~'. " * " nu*m, *o o*'no~~ L~ ~m ro w envuws *un s i _ a Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and Section 5(1) of -
'
NUREG-0588, Category 1, EQ Job Book (E0JB) 211.161 in the equipment 4 qualification file (EQF) for T95 and 35 tape splices, used in Limitorque
~~
SMB/SB motor operators inside and outside containment, did not adequately
* {-
-
support qualification (1) in that similarity between the tested in-line splice and the installed V-shape splice configurations was not
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established; and (2) the insulation resistance data take.n._dur.i m the - in-line splice type test were not availa Mbe'EQT and consequently
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af- not reviewed for impact with regards toVfunctional performance
-
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, { requirements of control circuits at RB .
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M O h 2 U.S. NUCLE AR REGULATORY COMMISSR
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In Reply Refer To: Docket: 50-458/87-21 Gulf States Utilities ATTN: Mr. James C. Deddens Senior Vice President, (RBNG) P.O. Box 220 St. Francisv111e, Louisiana 70775 Gentlemen: SUBJECT: EQUIPMENT QUALIFICATION INSPECTION - RIVER BEND STATION This refers to the first round special team inspection to review compliance with 10 CFR 50.49, of activities authorized by License No. NPF-47, conducted by Mr. A. R. Johnson and other NRC representatives, onsite during the period of November 2-6, 1987, and subsequently at the NRC Region IV office until December 18, 1987, concerning the River Bend Station (RBS). The team's findings were discussed with members of your staff at the conclusion of the onsite inspection on November 6,198 Areas examined during the inspection included your implementation of a program for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. In preparation for this inspection, the NRC team included reviews and evaluations of your implementation of equipment qualification (EQ) corrective action commitments identified in Safety Evaluation Report (SER) NUREG-0989 (May 1984) and SER Supplements 3 and 5 (August and Novcmber 1965). These documents provide the NRC staff acceptance of justifications for irterim operation (J10s) which you provided prior to the Novan.ber 30, 1985, deadiine for the completion of EQ as defined by 10 CFR 50.4 Within these areas, the inspection consisted of the examination of selected procedtres and records, interviews with personnel, and observations by the NRC inspectors. The inspectior. firdings are documented in the enclosed inspection repor During this inspection, it was found that certain of your activities were in violation of hRC requirement Consequently, you are required to respond to these violations, in writing, in accordance with provisions of Section 2.201 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulation Your response should be based on the specifics contained in the Notice of Violation enclosed with this lette Five unresolved items are identified in paragraphs 4.c, 4.f(1)(a), t..f(1)(b), 4.f(1)(c), 4.f(3), 4.f(4), and 4.h(2) of the enclosed inspection repor D DRS/PSS AC:PSS 0/DRS C:0RP/ D:DRP Reconcur ARJohnson;dp REIreland JLMilhoan 00Chrber..fr LJCallan REIreland
/ /88 / /88 / /88 / /88 / /88 / /88 grg o cc v7 NRR:0RIS:SPS/C UPotapovs 4/6/88 By tel call with R. Wilson NRR:0RIS:SPS
-. _ , _ . - - ___ _ . . _ _ - _ - _ _ . . - . . _ _ _ . , - _. .
In Reply Refer To: Docket: 50-458/87-21 Gulf States Utilities ATTN: Mr. James C. Deddens Senior Vice President, (RBNG) P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen: SUBJECT: EQUIDMENT QUALIFICATION INSPECTION - RIVER BEND STATION This refers to the first round special team inspection to review compliance with 10 CFR 50.49, of activities authorized by License No. NPF-47, conducted by Mr. A. R. Johnson and other NRC representatives, onsite during the period of November 2-6, 1987, and subsequently at the NRC Region IV office until Decemt,e r 18, 1987, cont -ning the River Bend Station (RBS). The team's findings were discussed with members of your staff at the conclusion of the onsite inspection on November 6, 198 Areas examined during the inspection included your implementation of a program for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. In preparation for this inspection, the NRC team included reviews and evaluations of your implementation of equipment qualification (EQ) corrective action commitments identified in Safety Evaluation Report (SER) NUREG-0989 (May 1984) and SER Supplements 3 and 5 (August and November 1985). These documents provide the NRC staff acceptance of justifications for interim operation (JI0s) which you provided prior to th: November 30, 1985, deadline for the completion of EQ as defined by 10 CFR 50.4 Within these areas, the inspection consisted of the examination of selected procedures and records, interviews with personnel, and observations by the NRC inspector The inspection fIrdings are documented in the enclosed inspection repor During this inspectior., it was found that certain of your activities were in violation of NRC requirements. Consequently, :ou are required to respond to these violations, in yriting, in accordance with provisions of Section 2.201 of the NRC's "Rules of Practice," Part 2, Title 10 Code of Federal Regulation Your response should be based on the specifics contained in the Notice of Violation enclosed with this lette Six unresolved items are identified in paragraphs 4.b(1)(b), 4.c, 4.f(1)(a), 4.f(1)(b), 4.f(1)(c), 4.f(3), 4.f(4), and 4.h(2) of the enclosed inspecticn repor ' DRS/PSS AC:P5S C:DRP/A D:DRP Reconcur ARJohnson p REIreland MJL lhoan DDChamberlain LJCallan RElreland A /5/88 j/,f/88 1/ /88 / /88 / /88 / /88 a , 3 2 n s n/c, Q , Toto p o % 4/u/% g gq mu d lvfb mo wt'54 }}