ML20151L039

Forwards Summary of 880315 Enforcement Conference Re Environ Qualification of Electrical Equipment at Facility. List of Attendees & Handouts Also Encl

ML20151L039
Person / Time
Site:	Farley
Issue date:	04/13/1988
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Mcdonald R ALABAMA POWER CO.
References
CIVP-A-013, CIVP-A-13, NUDOCS 8804210474
Download: ML20151L039 (54)

Text

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. . APR 181988 r

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' Docket Nos. 50-348, 50-364 License Nos. NPF-2 and NPF-8 ,

Alabama Power Company ATTN: Mr. R. P. Mcdonald  ;

Senior Vice President  ;

P. O. Box 2641 Birmingham, AL 35291-0400 l l

Gentlemen: ,

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SUBJECT:

ENFORCEMENT CONFERENCE SU N RY (NRC INSPECTION REPORT NOS. 50-348/87-30AND50-364/87-30) i This refers to the Enforcement Conference held at our request on March 15,  !

1988. This meeting concerned activities authorized for your Farley facility, i The issues discussed at this conference related to environmental qualification of electrical equipment. A list of attendees, a summary, and a copy of your i handout are enclosed. We are continuing our review of these issues 'to determine the appropriate enforcement action.  ;

In accordances with Section 2.790 of the NRC's "Rules of Practice," Part 2 .

Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.  ;

l Should you have any questions concerning this matter, please contact us. -

I Sincerely,  !

I r  ;

J. Nelson Grace Regional Adrainistrator  ;

Enclosures #

, 1. Enforcement Conference Summary l j 2. List of Attendees l

3. Handout ,

cc w/encls:

8. M. Guthrie, Executive Vice President

] J. D. Woodard, General Manager -

! Nuclear Plant

! W. G. Hairston, III, Vice President -

I Nuclear Support J. W. McGowan, Manager-Safety Audit i and Engineering Review s S. Fulmer, Supervisor-Safety Audit and Engineering Review bec w/encls: (See page 2) i ~ \

8804210474 880413 \\\

PDR O

ADOCK 05000348 DCD yg j

APR 1319882 Alabama Power Company 2 bec w/encls:

NRC Resident Inspector DRS Technical Assistant E. Reeves, Project Manager, NRR Document Control Desk State of Alabama

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RII [# RII NMerriweather:tm TECon1on ARHerdt e Gibson i 04/p/88 04/g /88 04/t /88 04/ 9'/88 ,

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ENCLOSURE 1

! Enforcement Conference Summary On March 15, 1988, representatives of the Alabama Power Company (APCO) met with NRC Region !! personnel and Headquarters representatives in Atlanta, Georgia, to discuss the issues of environmental qualification of electrical equipment (EQ) that derived from the NRC inspection at plant Farley during November 2-6 and 16-20, 1987.

The meeting was opened with remarks given by M.L. Ernst, Region !!, Deputy Regional Administrator. He expressed a desire that the meeting focus on the issues relating to the programatic breakdown of the EQ Program at Farley and not concentrate on one specific violation. The licensee acknowledged his '

request and stated that their presentation would address his concerns, however, they will also address each violation.

Mr. R. P. Mcdonald, Senior Vice President, APCO, began the meeting with opening '

remarks on the APC0 EQ program. He provided a chronology of how Farley EQ program was formulated. He went on to say that the basic EQ program was equipment oriented. The walkdowns performed of plant equipment were done to specifically identify name plant data and model numbers. The walkdowns did not evaluate the interconnectiig of components within each system (i.e splices, terminal boards, seals and etc). Although, the EQ Program did address special EQ maintenance requirements, it did not address the mechanical aspects, instrument loop accuracies, grease, oils and etc.

.i APC0 admitted that a breakdown did occur in the EQ Program at Farley. They believe the breakdown occurred due to a "mind-set" that developed somewhere in the 1984 time frame. APC0 believed they had a program in compliance with the 4

rule at that time. However, as a result of this "mind-set" APC0 chose not to '

a join the Nuclear Utility Group on Equipment Qualification and did not revise a their program as a function of time in spite of emerging NRC IE Notices and

Generic letters. Symptoms emerged in late 1986, that indicated there may be problems with the EQ Program. However, due to the "mind-set" established, it was not until mid 1987 that it was clear that significant deficiencies existed in the EQ program. The licensee went on to say that a six person EQ Task Team was formed in mid 1987 to review certain areas of the EQ program and at that i time an APC0 Engineer identified the V-type tape splice concern. Subsequently, i

the task team was expanded to approximately 40 personnel from APC0 and Bechtel.

j In summary, the licensee indicated that the root cause for the prograrrnatic

breakdown was principally due to a "mind-set" that their EQ program was in compliance with the rule.

1 4 Later during the meeting, the licensee provided information on the violations 1

and unresolved items discussed in the inspection report. In most cases, the

licensee did not agree with the position taken by NRC. The basis for the-licensee's positions is outlined in their handnut (Enclosure 3).

The meeting was closed with final comments from M. L. Ernst.

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., a ENCLOSURE 2 LIST OF ATTENDEES Alabama Power Company (APCO)

J. E. Garlington, Manager, Engineering and Licensing, APC0 W. G. Hairston, III, Vice President Nuclear Support, APC0

0. H. Jones, Manager, Design Engineering, APC0 R. P. Mcdonald, Senior Vice President, APC0 J. W. McGowan, Manager, Safety Audit t M Engineering Review, APC0 W. B. Shipman, Assistant Plant Manager, Farley Nuclear Plant (FNP) (APCO)

R. W. Stewart, Project Engineer, APC0 J. D. Woodard, Manager, FNP, APC0 Other Orgranization P. A. CiBenedetto, EQ Consultant, DBA, Incorporated K. Gandhi, Project Engineer, Bechtel Engineering J. Love, Assistant Project Engineer, Bechtel Engineering J. E. Sundergill, EQ Group Supervisor, Bechtel Engineering US NRC T. E. Conlon, Chief Viant Systems Section, Division of Reactor Safety (DRS), RII H. C. Dance, Chief, Project Section IA, Division of Reactor Projects M. Ernst, Deputy Regional Administrator, RII A. F. Gibson, Director, Division of Reactor Safety (DRS) RII R. J. Goddard, Regional Counsel, RII A. R. Herdt, Chief, Engineering Branch, DRS, RII G. Lainas, A>sistant Director, RII Reactors, NRR W. Levis, Reactor Inspector, RII N. Merriweather, Reactor Inspector, RII E, Merschoff, Deputy Director, DRS, RII ,

W. H. Miller, Jr. , Resident Inspector - Farley Plant, RII C. Paulk, Reactor Inspector, RII 1 U. Patapovs, Section Chief, Special Projects Inspection Section (SPIS), NRR  ;

E. A. Reeves, Senior Project Manager, NRR L. Slack, Enforcement Assistant, RII C. Smith, Reactor Inspector, RII ,

B. Uryc, Senior Enforcement Coordinator, RII I

0. M. Verrelli, Chief Projects Branch I, Division of Reactor Projects, RII R. C. Wilson, Engineer, SPIS, NRR H. Wong, Senior Enforcement Specialist, Office of Enforcement, NRC l

Enclosure 3 Q. e < h,Ppghi, of 90

. PRESENIATICH OF 'IECHNICAL ISSUES AGENDA

• DOCUMENIATION ISSUES MCfIOR OPERATED VALVE ISSUES SOLENOID OPERATED VAL \'E ISSUES SPLICE ISSUES ENTRANCE SEAL ISSUES TERMINAL BOARD IN INS'IEJMENT CIRCUIT ISSUE GREASE ISSUE .

• PROGRAM ISSUES GEMS LEVEL TRANSMITTERS ISSUES STIIAN CABLE ISSUE S

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Page 2 of 50 l Enclosure 3 l

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PK7IOR OPERATED VALVE ISSUES 1 f

• T DRAINS TERMINAL BOARDS

• ALUMIMP1 LIMIT SWITCH COVER (

• MIXED GREASE

m Enclosure 3 Page 3 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-07 I. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 3, page 20:

Some Limitorque Motor Operated Valves (MOVs) inside Unit 1 containment do not have T-drains installed. This condition is not in accordance with the tested configuration documented in the files, paragraph i 6.1.(3). '

II. Sequence of Event i

• Limitorque test reports 600456 and 600198 were in the central file prior to November 5,1985 documenting qualification of Limito'que actuators in FNP.

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• APCo identified that the MOV's in FNP did not have T-drains. J

• APCo determined that T-drains are not required for qualification. I

• Limitorque was contacted and confirmed the APCo position that T-drains are not needed for qualification.

• NRC inspecibr concluded that the T-drains were required for long term horizontally mounted operators for valve position indication and repositioning due to the potential for flooding of the limit switch compartment.

III. Innediate Corrective Action

• APCo has determined that (for both Units) all M0V's inside Containment without T-drains are qualified.

• T-drains were installed (for both Units) on all long term operating M0V's inside containnent which had provisions allocated for T-drains.

• Limitorque supports APCo's determination and conclusion.

Enclosure 3 Page 3 of 50 i NRC EQ Audit Findings Status 50/348,364/87-30-07 I. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 3, page 20:

Some Limitorque Motor Operated Valves (MOVs) inside Unit 1 containment do not have T-drains installed. This condition is not in accordance with the tested configuration documented in the files, paragraph 6.1.(3).

II. Sequence of Event

• Limitorque test reports 600456 and 600198 were in the central file prior to November 5,1985 documenting qualification of Limitorque actuators in FNP.

• APCo identified that the H0V's in FNP did not have T-drains.

• APCo determined that T-drains are not required for qualification.

• Limitorque was contacted and confirmed the APCo position that T-drains are not needed for qualification.

• NRC inspacibr concluded that the T-drains were required for long term horizontally mounted operators for valve position indication and repositioning due to the potential for flooding of the limit switch compartment.

III. Innediate Corrective Action i

• APCo has determined that (for both Units) all M0V's inside Containment without T-drains are qualified.

• T-drains were installed (for both Units) on all long term operating M0V's inside containment which had provisions allocated for T-drains.

• Limitorque supports APCo's determination and conclusion.

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Enclosure 3 Page 4 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-07 Page Two IV. Analysis of Event

• This is another example of an emerging issue.

A. Use of Test Report 600198 in combination with Test Report 600456 is ~

acceptable for qualification of Limitorque actuators without T-drains for the following reasons:

1) Test parameters of 600198 enveloped FNP accident conditions through extrapolation of the seven day test to encompass APCo's long term (thirty day) operating requirement.

2) FNP motors have class RH insulation  :

3) The limit switch compartment is not water tight. Any water I collecting in the limit switch compartment would drain out through  !

the gasket. l

4) Where bottom entrv conduits into limit switch compartment exist at FNP, any water C A. ?cted will drain out through the flex conduit.

5) Conduit is sufficiently shielded from spray to prevent spray entry via conduit.

B. Limitorque stated in a letter to APCo dated November 20, 1987 that Limitorque Qualification report 600198 is the worst mounting position.

If noisture were to enter the limit switch compartment, it would l collect in the motor which does not have a T-drain. For vertical stem mounted valves moisture would drain through the fibrous limit switch gasket material.

h Enclosure 3 Page 5 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-07

- Page Three V. Long Term Corrective Action

• None VI. Date of Full Compliance .

N/A VII. Conclusions

• This was identified by APCo and evaluated prior to the NRC EQ Audit

• There is no safety significance of this finding. T-drains are not required to establish qualification.

• APCo concludes that the MOV configurations that did not have T-drains installed are qualified and do not impact the safe operation or the ability of the units to mitigate the consequences of a design basis accident.

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Page 6 of 50 Enclosure 3 -

NRC EQ Audit Findings Status 50/348,364/87-30-09

1. Restatement of NRC's description of finding

• The NRC has designated this at, unresolved. See Paragraph 3, page 21:

EQ file did not include qualification for terminal blocks used in notor operated valves in that various terminal blocks were identified during walkdowns of limitorque operators, paragraph 6.i.(3).

II. Sequence of Events

• APCo walked down Unit 2 EQ scope MOVs during the Unit 2 fifth refueling outage to determine if qualified terminal blocks were installed by Limitorque. Aa mq M

• The Unit 2 MOVs sere found to have terminal blocks sbe covered by Limitorque Report Number B0119) qualified Raychem splices were installed.

• All Unit 1 MOVs that have a long-tem post-accident function were inspected and either found to contain terminal blocks covered by Limitorque Report Number B0119 or qualified Raychem splices were installed.

• Since it is assumed that Units 1 and 2 are similar, APCo will conduct a (

walkdown of all Unit 1 EQ scope M0Vs during the upcoming Unit 1 eighth refueling outage to verify the terminal blocks are covered by Limitorque i

Report Number B0119.

• FNP EQ Package 23C was placed in the Central File on November 24, 1987 which documents qualifications of Limitorque installed terminal blocks covered by Limitorque Report Number 80119.

III. Immediate Corrective Action

• Qualified Raychem splices were installed in Unit 2 MOVs that contained terminal blocks which may not be qualified by Limitorque Report Number .

B0119.

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Enclosure 3 Page 7 of 50 NRC EQ Audit Findings Status

% 50/348,364/87-30-09 (Page Two)

IV. Analysis of Events

• This is another example of an EQ emerging issue.

• All Unit 2 MOVs have been verified by inspection to contain terminal blocks qualified by Limitorque test report B0119 or qualified Raychem splices have been installed. .

• Inmediate corrective actions were taken on Unit 1 where found to be applicable.

V. Long Term Corrective Action ,

• N/A VI. Date of Full Compliance November 25, 1987.

VII. Conclusions

• Raychem splices have been installed in all Unit 2 MOVs that could not be positively identified by inspection to contain terminal blocks qualified by Limitorque test report B0119.

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Enclosure 3 Page 8 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-08 I. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 3, page 21:

Unqualified limit switch housing installed in a limitorque valve inside Unit 1 containment, paragraph 6.1.(3). [ NRC report identifies MOV8811A as the valve in question. This should be MOV34410. ]

II. Sequence of Events

• APCo identified this item as part of the NY walkdown associated with the response to IEN 86-03 (Limitorque internal wiring).

• An Administrative LC0 was established in November 1987.

• The limit switch was replaced on November 24, 1987 clearing the Administrative LCO.

III. Imediate Corrective Action 0: a r

• Administrative LC0 established. The limit switchAwas replaced on November 24, 1987 clearing the Administrative LCO.

IV. Analysis of Event

• This item is resolved.

• The NRC identified M0V8811 as being exposed to the Containment atmosphere. It is not exposed to Containment atmosphere. The correct )

number is M0V3441D.

• There is no safety significance associated with the failure of M0V34410. '

The normal and accident position of his valve is open. Only one of four containment coolers is required to provide adequate containment cooling.

• Corrosion of the Limit switch on M0V34410 is a long term event.

The only impact of long tenn loss of this limit switch would be lack of indication on the main control board. The operator does not rely on this indication to perfonn any subsequent safety function.

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-- . . . _ . . . Page 9 of 50 NRC EQ Audit Findings Status N 50/348,364/87-30-08 (Page Two)

V. Long Term Corrective Action N/A VI. Date of Full Compliance N/A VII. Conclusions

• This was identified by APCo as part of the field inspection conducted in 1986' to identify internal wiring for IEN 86-03. A review by the EQ Task Force in November 1987 discovered this configuration and established an Administrative LCO.

• The limit switch housing for this f0V has been replaced

• The as-found configuration at this MOV did not create a safety concern or inpact safety.

The postulated f ailure mechanism is a long tenn event

• Only one of four containment coolers is required to provide adequate containment cooling during a design basis accident .

• The normal and accident position of this valve is open.

• Based on subsequent review, this item could be removed from the EQ Master List.

Enclosure 3 Page 10 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-17 1., Restatement of NRC's description of finding The NRC has designated this as a violation. See Paragraph 3.e, page 4.

Mixed grease used in MOVs and qualification documentation not in file for Texaco MARFAK-AP prior to 11/87. [ The NRC has not reviewed qualification package on Texaco MARFAK-AP. ]

II. Sequence or En.at>

• FNP standardized on the procurement of Texaco greases for use in all FNP applications. .

• It was discovered that MOV's were' supplied with a grease using a different base material than Texaco Marfak AP.

• APCo's evaluation of the mixed grease issue determined that mixed greases was not a safety concern as documented by the JC0 dated ,

September 23, 1987.

• Texaco Marf ak AP qualification package completed September 24, 1987 and was available for NRC review during the November 1987 NRC audit.

III. Immediate Corrective Action A JC0 was written September 17, 1987.

IV. Analysis of Event This is another example of an emerging issue.

Texaco Marf ak AP was qualified by APCo.

Mixing of greases was determined to be an issue in September 1987, whereupon a JC0 was initiated.

V. Long Term Corrective Action FNP plans to change out grease in EQ Limitorques over the next two outages per unit. Currently operating und! JC0's which have been written to cover mixed grease concern. Any axtensions to the schedule will be discussed with the NRC. This effoi c requires disassembly of the MOV and therefore being coordinated with other MOV work (e.g., M0 VATS).

VI. Date of Full Compliance I

• The current schedule for replacement is by the end of Unit 1 ninth refueling outage and the end of the seventh refueling outage for Unit 2.

I VII. Conclusions

• There is no safety significance in this finding.

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Enclosure 3 Page 11 of 50

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SOLENOID OPERATED VALVE ISSUES I l

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' SOLENOID OPERATED VALVE CCNDUIT SEALS

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• i QUALIFIED LIFE CALCULATICES e

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Enclosure 3 Page 12 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-12 l

I . %- Restatement of NRC's description of finding The NRC has designated this as unresolved. See Paragraph 29, page 35.

Certain S0Vs nay not be qualified due to a lack of cable entrance seals. This is contrary to the qualification basis, paragraph 6.i.(29)

(a), (b) and (c).

II. Sequence of Events

• NRC concern on 50V seals was identified during the andit III. Immediate Corrective Action

• There are no corrective steps required.

IV. Analysis of Event

• IEN 84-90 has been addressed by evaluating the peak surface temperature caused by the revised MSLB scenario and determining that they are still enveloped by the existing FN? qualification profiles.

The NRC position that all long term acting SOVs should be equipped with conduit seals is not supported by ASCO. In a letter from ASCO to Bechtel dated November 10, 1987, it was stated that seals were not required. (This letter is contained in packages 2A and 2B in the APCo Central File). No time interval was stated as a bounding condition on the ASCO position. Therefore, seals are not required on long term acting SOVs since the ASCO testing envelopes FNP conditions.

Additionally, the valves in the main steam room are equipped with liquid tight flexible conduit connected to rigid conduit which is routed (with no openings) out of the main steam valve room.

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Enclosure 3 Page 13 of 50 NRC EQ Audit Findings Status

\ 50/348,364/87-30-12 (Page Two)

IV. Analysis of Event (Continued)

• S0Vs in Unit 2 containment have misture loups or conduit runs which slope away from the 50V which is in accordance with the ASCO installation bulletin.

The PORY pilot solenoid valves are shown on the EQ Master List as a result of NUREG 0737 requirements to ensure PORY closure. No credit for operation of the PORVs is taken in the FNP accident analysis.

V. Long Term Corrective Action

• Unit 150V's will be walked down during the upcoming Unit 1 eighth refueling outage as follows:

• For inside Containment, moisture loops or conduit runs which slope away from the S0Y will be verified.

• For MSVR, use of liquid tight flexible conduit connected to rigid conduit running out of the KSVR (with no openings) will be verified.

VI. Date of Full Compliance

• N/A - since no corrective steps are required VII. Conclusions

• Evaluation of IEN84-90 has been completed.

• There is no safety significance of this finding.

SOV's are configured to prevent misture intrusion.

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Enclosure 3 Page 14 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-13 I. Restatement of NRC's description of finding

• The NRC has designated this as unresolved. See Paragraph 29, page 35.

Automatic Switch Company Solenoid Valves installed in Unit 1 Containment exceeded their qualified life, paragraph 6.i.(29) (d). l

[ NRC requested copy of calculations for review to resolve this I issue. ] ,

II. Sequence of Events

• The EQ component, maintenance and replacement schedule for these SOVs documented an eight year qualified life based on APCo's evaluation of the test report. Based on vendor information received in 1987, it was determined that for a normal design temperature of 120*F inside containment the minimum qualified life of normally energized solenoid valves was 5.6 years.

Subsequently, actual operating temperature data was received showing that the average annual containment temper'.ture was approximately 98'F 1 1

• A revised qualified life calculation was performed using a conservative

'.emperature value o' 104*F. The result of this calculation shows that )

for normally energized solenoid valves the minimum qualified life based on actual data is 11.2 years.

The eight year replacement schedule documented in the EQ component maintenance and replacement schedule for these solenoid valves was therefore conservative.

• As a more conservative measure, an administrative qualified life based on 120'F inside containment is presently documented in the EQ component maintenance and replacement schedule.

t III. Immediate Corrective Action Completed qualified life calculation based on actual containment temperature measurements. A copy of this calculation is available for NRC review.

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._ = l Enclosure 3 Page 15 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-13 (Page Two)

IV. Analysis of Event

• Calculations have been completed showing a qualified life of a rJinimum of 11.2 years for normally energized solenoid valves. ,

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• Even though some Unit 1 SOVs exceeded the conservatively calculated 5.6 l year qualified life, they have not exceeded the eight year qualified life that was documented in the EQ component, maintenance and replacement schedule as supported by the revised calculation using actual containment temperature data.

• The solenoid valves which were replaced had been installed for eight

• years or less. Therefore the replaced valves were qualified at the time of replacement.

• There is no safety significance of this finding since the replaced valves were still capable of functioning during a DBA if it had occurred at the time of replacement.

V. Long Term Corrective Action

• There are no corrective steps required VI. Date of Full Compliance

• The calculations demonstrate that APCo has always been in compliance in this area.

VII. Conclusions The qualified life of these SOVs has not been exceeded.

Calculations have been completed.

There is no safety significance of this finding. I

Enclosure 3 Page 16 of 50 0

a SPLICE ISSUES

% RECOMBINER SPLICE

• V-TYPE ELECTRICAL TAPE SPLICES 4

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Enclosure 3 Page 17 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-16

1. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 3.a. page 4.

The licensee operated Units 1 and 2 of the Farley Plant at various power levels for some unknown period of time after November 30, 1985 without adequate documentation in their EQ files to demonstrate that the in-line 5-to-1 field to pigtail tape splice configurations used on the Hydrogen Recombiners would perform its intended function during a design basis accident.

II. Sequence of Events

• Westinghouse used a five to one taped splice as part of the Hydrogen Recombiner package.

• The FNP original installation was a five to one taped splice.

• There were no details for installing the five to one taped solice qualified by Westinghouse, at the time of installation.

• NRC questioned APCo's five to one taped splice configuration.

• APCo wrote JC0 for the Hydrogen Recombiner splice.

• The taped splice was replaced with a Raychem splice in accordance with Raychem guidelines.

• Westinghouse documented in a letter to APCo that the configuration tested was constructed with Scotch 70 tape.

III. Immediate Corrective Action

• A JC0 was written by APCo upon questioning by NRC.

• Taped splices were replaced with Raychem splices.

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Enclosure 3 Page 18 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-16 (Page Two)

IV. Analysis of Event In-line taped splices (one to one) was an approved detail as documented by the electrical notes and details. While similarity of the five to one and one to one taped splice was not documented and located in, the Central File, the five to one taped hydrogen recombiner splice is a similar configuration to the one to one taped splice.

A five to one taped splice was the Westinghouse tested configuration.

The installed five to one taped splice was superior to the tested configuration. '

APCo took prompt and effective corrective action specifically, a JC0 was written and the splices were replaced.

There is no safety significance in this finding.

V. Long Term Corrective Action None VI. Date of Full Compliance '

1 Replacement with Raychem of the Unit 1 Hydrogen Recombiner splice was completed on October 15, 1987.

Replacement with Raychem of the Unit 2 Hydrogen Recombiner splice was completed on November 5,1987.

VII. Conclusions )

1 This finding has no safety significance since the installed  !

installation was superior to the configuration tested by Westinghouse  !

in the qualification test.

Enclosure 3 Page 19 of 50 i NRC EQ Audit Findings l Status  ;

50/348,364/87-30-19

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I. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 3.g, page 5.

Unqualified V-type electrical tape splices on S0Vs, POVs and Inside Containment rans.

II. Sequence of Events

• APCo determined that a potential deficiency might exist with regard to EQ solenoid valves' pigtail to field wire connection.

• A JC0 was prepared for EQ solenoid valve V-splices which was submitted to the NRC until verification of qualification could be performed. .

• In conjunction with the above, a test program was developed for verifying qualification of taped splices.

• A systematic program was developed to replace all such EQ solenoid valve splices with Raychem splices in accordance with design.

• It was determined that certain EQ M0V mtor lead sp1'res potentially utilized the V-splice configuration

• A JC0 was developed for EQ MOV motor lead V-splices

• A systematic program was developed to replace all such EQ MOV motor lead splices with Raychem splices in accordance with design

• EQ fan motors insiae containment were inspected and all v-splices were replaced with Raychem splices as necessary.

• All EQ 4160V motor splices were inspected and replaced as necessary with Raychem splices in accordance with design.

• The test program was developed by assembling a taped splice test specimen for each configuration found during the efforts to replace taped splices with Raychem splices, or similarity to other test reports was documented. Therefore envelopment of FNP configurations was  !

ensured in the test program.

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NRC EQ Audit Findings Status 50/348,364/87-30-19 (Page Two) )

III. Inynediate Corrective Action l

)

All EQ equipment in both units required that has a long-term post accident function have been replaced.

As a conservative measure, all Unit 2 EQ V-taped splices have been replaced with Raychem splices. For any taped splices that have not been replaced on Unit 1, a JC0 exists in addition to the Wyle ,

qualification report. l

• l V-splices have been qualified by Wyle testing. I l

IV. Analysis of Event APCo does not agree as written. The V-splices referenced have been l proven to be qualified by Wyle Test Report or similarity to other test reports has been documented. Testing was completed and documented prior to the November 16,1987 audit.

The current field status is resolved based upon the Wyle Test Report.

Additionally all the V-spices on EQ equipment have been replaced in Unit 2 and are being replaced in Unit I with qualified Raychem splices.

There is no safety significance in this finding since the V-splices have been qualified by testing.

V. Long Term Corrective Action The FNP Electrical Notes and Details will be revised to document the types of splices that are acceptable for each type of EQ component.

VI. Date of Full Compliance N/A VII. Conclusions There is no safety significance in this finding. In addition, V-splices were qualified by testing.

Documentation supporting the qualification of thc V-tape splices was completed prior to November 16, 1987 audit.

Enclosure 3 Page 21 of 50 D URANCE SEAL ISSUES.

DURANCE SEAL W TARGET ROCK SOLENOID VALVE RAYCHDVCHICO SEAL ON LIMIT SWITCHES J

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nclosure 3 Page 22 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-14

1. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 31, page 37.

Qualification not demonstrated for Raychem seal installed on Target Rock Solenoid valve cable entrance seal, paragraph 6.1.(31).

II. Sequence of Events

• These valves were installed to meet the NUREG-0737 requirements an'd schedule. Installation was completed on Unit 2 prior to initial plant startup in July 1981 and on Unit 1 on May 8,1981 with power removed pending NRC approval of the Head Vent System. Design for these modifications was issued on PCN 79-463 and 2BE833 in 1980. These valves

• were shipped for Unit 2 on July 17, 1980 and for Unit 1 on April 29, 1980.

• At the time of installation, sealing was not a requirement identified by the vendor. APCo added a Raychem seal as an additional conservative measure.

Subsequent to APCo installation, Westinghouse qualified to 10CFR50.49 requirements the Target Rock Solenoid Valve with a Conax seal. The Westinghouse test report was reviewed, the seal deviation was identified, and concluded that replacing the seals was not required since FNP was a NUREG-0588, Category 11 plant.

III.! Irrrnediate Corrective Action

• PCNs 86-1-3873 and 87-2-4108 replaced these seals with 50.49 qualified Conax seals. .

I IV. Analysis of Event

• At the time of installation, there was not a design requirement for entrance seals identified by the vendor.

• FNP accident analyses do not take credit for the head vent valves and this equipment is therefore not essential to achieve a safe shutdown condition. This conclusion is documented in Alabama Power Company's submittal of May 20, 1983.

E.' ..

Enclosure 3 Page 23 of 50 NRC EQ Audit Findings s Status 50/348,364/87-30-14 (Page Two)

V. Long Term Corrective Action

• None.

VI. Date of Full Compliance

• The Raychem/ CHICO seals were replaced with Conax connectors qualified by the Westinghouse test report on 4)ecember-11,1987-end-December 15, 1987 forJakT andi2, -respect +vdyr w,r o ' ' l.

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• These valves were installed to meet the NUREG-0737 requirements and schedule.

• NUREG-0588, Category 11 requirements applied to FNP at the time of installation.

• PCNs 86-1-3873 and 87-2-4108 replaced these' seals with Conax connectors qualified by the Westinghouse test report.

• This equipment has no safety function during or following a DBA.

u . . . . . - . . - - . - .. . ...- . . . . - . . .. -- . . . . .

Enclosure 3 Page 24 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-15 I. Restatement of NRC's description of finding The NRC has designated this as a violation. See Paragraph 32, page 38.

Raychem/ Chico A Seal (Package 29G) - NUREG 0588 Category 11 qualification not demonstrated because bonding of the Raychem material to the metal pipe nipple under LOCA conditions (including chemical spray) has not been addressed, paragraph 6.i.(32).

II. Sequence of Events

• IEC 79-05 was issued to address a concern regarding moisture intrusion into limit switches.

APCo developed and tested the Raychem/ CHICO seal because no qualified conduit seal could be identified at that time.

Raychem material was used because it was qualified for the FNP envi ronment.

Chico was used as a backup material for the Raychem to provide support to withstand the pressure spike.

Subsequent to the installation of the Raychem/ CHICO seals, the present generation of conduit seals became available.

Questions concerning these seals were raised, during the NRC inspection.

• On January 8,1988 a letter was issued to the NRC addressing their concerns.

The current field status is awaiting ccmpletion of NRC evaluation.

III. Innediate Corrective Action

• Since APCo believes the existing seal configuration to be qualified, no corrective action is required.

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Enclosure 3 Page 25 of 50 NRC EQ Audit Findings Status s~ 50/348, 364/87-30-15 (Page Two)

IV. Analysis of Event

• APCo selected Raychem material because testing by Raychem in other .

configurations was done to parameter levels in excess of those at FNP.

• Documentation supporting APCo's position was in the Central File prior to November 16, 1987.

• The January 8,1988 letter provides additional information needed to address NRC's concerns raised during the audit and the November 25, 1987 meeti ng.

V. Long Term Corrective Action N/A - based on the response in section III above.

VI. Date of Full Compliance N/A - based on the response in section III above.

VII. Conclusions

• APCo's position is that this configuration is qualified based upon the qualification package in the EQ Central File prior to the November 16, '

1987 audit and additional clarification in the January 8,1988 le'6er to the NRC.

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Enclosure 3 Page 26 of 50 TERMINAL BCARD IN INSTRUPENT CIRCUIT ISSUE STATES AND GE TERMINAL BLOCK USED IN INSTRLNWT CIRCUITS 1

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Enclosure 3 .-

Page 27 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-11 I. ., Restatement of NRC's description of finding The NRC has designated this as a violation. See Paragraph 15, page 25.

Licensee EQ files did not support qualification for use of States (type NT/ZWM) and G. E. (type (CR1518) terminal blocks in instrumentation circuits, paragraph 6.1.(15).

II. Sequence of Events States terminal blocks were qualified by Wyle Test Report. The test report did not document leakage current values during the test.

Westinghouse was contracted in 1984 to consider the error associated l with the use of terminal block's and their impact on instrument loop I accuracy.

Further discussion with Westinghouse in 1987 indicated that these i errors were assumed to be negligible.  ;

Westinghouse was proviu.J a I.R.value based upon similarity to the i Connectron block for evaluation of instrument accuracy.

The NRC auditors indicated the acceptabi!ity of the instrument accuracy l analysis metnodology documented by WCAP-11658 but questioned the  !

applicability and acceptability of the Connectron blocks test report number to the FNP installed configuration.

APCo developed a JC0 for use of the terminal blocks based on test data presented in a Sandia Report.

The G. E. terminal block qualification report was placed in the central file before the November 24, 1987 meeting.

Meeting held with the NRC Region II November 24, 1987.

NRC concluded from meeting presentation that the terminal blocks may be qualifiable. For Unit 1 APCo agreed to increase shift supervisors and STA awareness and replacement of the terminal blocks with qualified splices. Such Unit 2 terminal blocks in EQ instrumentation circuits were replaced prior to startup. Unit 1 terstnal blocks were replaced in December 1987.

Additional qualification test evidence was provided by APCo letter to (

the NRC dated January 8,1988.

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Enclosure 3 Pags'28 of 50 NRC EQ Audit Findings

. Status 50/348, 364/87-30-11 (Page Two)

III. Immediate Corrective Action Replaced terminal blocks in EQ instrumentation circuits with Raychem splices.

IV. Analysis of Event

• This is another example of an EQ emerging issue.

Qualification documentation of the States terminal blocks was in the central file prior to the audit; however this test report did not document leakage current valves during the test.

Additional documentation supporting qualification was developed by APCo demonstrating that the instruments would have performed their intended function.

• The NRC auditors accepted the instrument accuracy analysis methodology documented by WCAP but questioned the similarity analysis.

To expedite resolution of this issue, the terminal blocks have been replaced with qualified Raychem splice on instrument loops in the scope cf EQ.

• The NRC did not question the basic qualification of terminal blocks -

only the IR values as they pertained to use in instrumentation circuits.

V. l.ong Term Corrective Action

• Restrict the use of terminal blocks, in instrument circuits in potentially harsh environments, by design control.

VI. Date of Full Compliance

• Replacement of terminal blocks with qualified Raychem splices on EQ instrument loops was completed on Decenber 5,1987 and December 17, 1987 on Unit 2 and Unit 1, respectively.

VII. Conclusions  !

The current field status is resolved. Terminal blocks have been I replaced with qualified Raychem splice on instrument loops in the * ,

scope of EQ.

• This was identified by APCo and additional qualification information was developed to demonstrate that the instruments would perform their intended function.

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Enclosure 3 Page 29 of 50 GREASE ISSUE

• GREASE USED CN CCRTIAIh?G2TT FAN POIORS l

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^ ~ ~ - Page 30'of 50' Enclosure 3 NRC EQ Audit Findings Status 50/348, 364/87-30-18 I. Restatement of NRC's description of finding

• The NRC has designated this as a violation. See Paragraph 3.f. page 5.

No documentation in EQ Central File to support the use of Texaco Premium RB grease on f an motors inside containment. The licensee is currently operating under JCO.

II. Sequence of Events

' Grease qualification in motors is an EQ issue identified by APCo through review of c9dit reports. .

• Joy test did not document the type of grease tested.

• APCo wrote a JCO.

• Texaco is performing qualification testing.

III. immediate Corrective Action

• A JC0 has been written. Grease is being qualified.

IV. Analysis of Event This is another example of an emerging EQ issue. ,

• While qualification documentation was not in the file justifying the use of this grease, there is no safety significance in this finding as determined by grease JC0 dated September 17, 1987.

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Enclosure 3 Page 31 of 50 4

, NRC EQ Audit Findings Status

. 50/348, 364/87-30-18 (Page Two)

V. Lcng Term Corrective Action

• Qualify Texaco Premium RB grease.

VI. Date of Full Compliance '

• December 31, 1988.

VII. Conclusions

• There is no safety significance in this finding as determined by the applicable JCO.

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j Enclosure 5 Page 32 of 50 )

l 1

PROGRAM ISSUES COMMERCIAL GRADE PARTS IN EQ APPLICATICNS UPGRADE OF REPIACDENT INUIPMENT IN ACCORDANCE WITH 10CFR50.49(L)

FAILURE TO PROMPTLY CORRECT SAER IDENTIFIED DEFICIENCIES EQ TPAINING PROGRAM l

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l Enc,osure 3 Page 33 of 50 NRC NRC EQ Audit Findings Status 50/348,364/87-30-01

1. Restatement of NRC's description of finding

• NRC designated this as an additional example of a finding documented in NRC Inspection Report Nos. 50-348, 364/87-11 and 50-348, 364/87-14. See Paragraph 6.e, page 9:

Use of unqualified comercially procured equipment in EQ applications, II. Sequence of Events

• In August 1986, APCo performed a storeroom inventory evaluation using revised procurement procedures. The evaluation was initiated to develop a data base that uniquely identified parts in the storeroom as safety-related and nonsafety-related.

NRC conducted a vendor audit inspection on May 11 - 22, June 1 - 5, and June 11 - July 10,1987.

• On June 4,1987 APCo developed an interim procedure requiring written review and approval of comercial grade parts prior to use in safety-related applications.

• In June: 1987, a historical review of work packages that may have impact on EQ equipment was initiated.

• On November 13,1987 APC0 revised procedures to require engineering review of connercial grade parts prior to installation in safety-related applications. In addition, APCo implemented a Comercial Grade Parts Dedicetion procedure, requiring a detailed dedication plan based on "criucai to function" characteristics for each item.

• The week of November 16, 1987, NRC EQ inspection team raised concerns regarding adequacy of the existing comercial part dedications program for equipment installed in EQ applications.

• APCo received a Notice of Violation (NOV) for vu dor inspection audit dated November 3,1987 and APCo responded to the NOV by letter dated ,

Deceder 17, 1987.

• NRC issued EQ inspection report dated February 4,1988 citing additional examples of a violation identified during the NRC vendor audit inspection.

Enclosure 3 _

Page 34 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-01 Page Two III. Immediate Corrective Action

• Prior to completion of the vendor inspection audit, on June 4,1987, plant procedures were revised to require written evaluation and approval of comercial grade parts prior to their use in safety-related applications. This action was an interim measure untti a dedication program was approved.

• Procedures were revised on November 13, 1987 requiring engineering review of comercial grade parts prior to installation in safety-related applications. In addition, procedures were revised to incorporate a comercial grade parts dedication program. The dedication plan which is a part of this program include) acceptance criteria when tests or measurements are required for dedication.

IV. Analysis of Event

• The current procurement process now requires an up-front engineering evaluation of procurement documents for all safety-related applications which includes EQ equipment applications.

• Based upon a review of approximately 11,000 historical packages (MWR, MIF, P.O.'s) to date and physical inspections conducted by ADCo, no degradation of safety functions have been identified based on the use of commercial grade parts in EQ applications. ,

• The two examples referenced in the NRC report (States type ZWM terminal blocks and Okonite T-95 insulating tape and No. 35 overlay tape) have been evaluated by APCo and found to be acceptable for use in EQ applications.

• In discussions with many of the original equipment manufacturers during the 1970's and 1980's it was a common practice to buy replacement parts .

through the OEM as connercial grade since many of these parts were supplied comercial grade. The significance of the dedication program l for comercial grade parts has recently become an industry issue. The NRC and industry have comittees that are currently developing postions; therefore, this is an emerging issue.

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. Enc,losure 3 Page 35 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-01 Page Three V. Long Term Corrective Action

• APCo will work with the NRC and industry comittees in an effort to finalize guidelines for dedication of comercial grade items for use in safety-related applications.

VI. Date of Full Compliance -

• June 4,1987 VII. Conclusions

• Since regulatory guidance has not been provided relative to this new, emerging area, APCo does not believe that it is appropriate to require the industry through enforcement proceedings to implement programs for dedication of comercial grade items.

• This is not a new violation upon which additional enf orcement action should be based (NRC Inspection Report Nos. 50-348, 364/87-11 and 50-348,364/87-14). Corrective actions have been taken to prevent future occurrences.

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l Enclosure 3 'Page 36 of 50 l l

NRC EQ Audit Findings Status 50/348,364/87-30-02 I. Restatement of NRC's description of finding

• NRC designated this as an additional example of a finding documented in NRC inspection Report Nos. 50-348, 364/87-11 and 50-348, 364/87-14. See Paragraph 6.e.2, page 13:

Failure to procure replacement equipment in conformance with 10CFR50.49(L).

II. Sequence of Events On January 11, 1984, a meeting with NRC staff in Bethesda, Maryland was held to discuss APCo position on maintaining equipment qualification.

• On February 29, 1984, APCo documented, via letter to the NRC, minutes of the January 11, 1984 meeting where APCo's position on procurement of

• replacement equipment was described. Specifically, APCo will procure "identical components" as replacements unless identical components cannot be obtained.

• On December 13, 1984, NRC issued an SER specifically referencing the February 29, 1984 APCo letter and concluding that APCo's EQ program is in accordance with the requirements of 10CFR50.49.

• During EQ inspection conducted during the period of Septent>er 14 - 18, 1987, a concern was identified that the requirements of 10CFR50.49(L) were not documented.

• On November 16, 1987, APCo revised FNP-0-ETP-4108 requiring replacement equipment be upgraded to 10CFR50.49 or "sound reasons to the contrary" be documented.

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Page 37 of 50 l Enclosure 3

• i NRC EQ Audit Findings l Status 50/348, 364/87-30-02 Page Two III. Innediate Corrective Action On November 16, 1987, APCo revised procedures requiring replacement equipment to be upgraded to 10CFR50.49 or sound reasons to the contrary be documented.

A review of store-room inventory was conducted prior to issuance of the revised procedures to determine the level of qualification of all. items in inventory. This review resulted in a determination that all replacement components in inventory designated for EQ applications were:

- procured to the requirements of 10CFR50.49; or "sound reasons to the contrary" exists.

IV. Analysis of Event

• APCo informed the NRC through a meeting and by letter of its intended

~

actions on maintaining qualification of equipment; specifically replacement equipment.

• The NRC SER documented that APCo's EQ program including APCo's definition of replacment equipment, was in compliance with 10CFR50.49 requirements. ,

• APCo procured equipment in accordance with its documented and NRC approved EQ program.

NRC, Region II, did not interpret the requirements of 10CFR50.49(L) as they were approved by NRC in 1984.

APCo revised the procedures on November 16, 1987 to resolve the NRC concerns. l The replacement of EQ components since February 1983 has been reviewed and determined that all items were qualified to 10CFR50.49 requirements or "sound reasons to the contrary" exists.

Replacement components qualified as a minimum to NUREG 0588 were installed. Equipment qualified to NUREG 0588 will functica properly in a design basis accident.

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Enclosure 3 Page 38 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-02 Page Three N

V. Long Term Corrective Action

• N/A k

VI. Date of Full Compliance .

Procedures were revised November 16, 1987. ,

VII. Conclusions

• Historically, APCo's position was that the NRC provided a SER which r.t epted the APCo EQ program definition of an upgrade.

• To resolve ongoing NRC concerns, plant procedures were modified November 16, 1987 to require the procurement of replacement equipment qualified to 10CFR50.49 requirements or "sound reasons to the contrary" be documented.

• There is no safety significance in this finding.

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L En' closure 3 Page 39 oll0' NRC EQ Audit Findings Status 50/348,364/87-30-03 1.' Restatement of NRC's description of finding

• NRC designated this as a Violation. See Paragraph 6.f, page 13: ,

Failure to take prompt and timely corrective action for EQ progrannatic deficiency identified by SAER staff in 1983,

11. Sequence of Events

• On December 2,1983, noncompliance Fn'P-NC 48 83/19(S) issued.

Failure to indicate instruction books and vendor drawings for EQ

• equipment, which require reyisio1 as a result of design changes.

• On December 29,1983, CAR 830 written with estimated completion by April 1, 1984. .

• In March 1984, VETIP was finali:ed by NUTC addressing G.L.83-28 .

painting out that all Mendar insnuals and drawings would not require retrofit.

• On April 9,1984, CAR 810 was espanded to address all vendor mnuals and drawings by meo0 from W. G. H41ritor,, !!! to 0. D. Kingsley, Jr.

• On June 25, 1984 APCo submitted final response to G. L. 83-28 section 2.2.2 to NRC.

• On August 8,1984, CAR E30, Roh 1 was hsued stating the following:

1) Vendor annis and drawing will not N updated

2) List will be developed foi equirmant wnich has EQ limit switches or solenoirh valves atthebed.

3) Planners, will in instructed en the EQ requirements to appropriately stamp MMis.

• On August 27, 1984, as a result of G.L.63-28 CAR 830, Rev>2 wat issued i by FNP to state that appropriate vendor mar.usl5 and drawings will be revised henceforth. In addition, to prevent recuersnce, 1

1) For EQ equipment, the desigra or9mit3 tion Mll belep a cro$s index of appropriate druin(p ad manuals for each ite:r on the EQ alaster list.

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2) Non - EQ equipment retrofit changes to vendor drawings and manuals identified during routine activities will be ude m en as-requira6 l basis. , l l

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NRC EQ Audit Findings Status 50/348,364/87-30-03 Page Two II. Sequence of Events (continued)

• On December 18, 1984 NS advised FNP that Design Organizations had completed review and update of procedures to ensure that manuals are updated.

• On March 11, 1985, NRC letter to APCo stated that G.L.83-28 concerns were incomplete.

• On April 4,1985, a meeting between NRC staf f and APCo (R. P. Mcdonald) to discuss the APCo position and NRC concerns.

• On April 22, 1985, APCo letter to NRC stating that a response to the March 11,1985 NRC request for additional information on Section 2.2.2 of Generic Letter 83-28 was not required based on the April 4,1985 meeting between the NRC and APCo.

• On July 5,1985, estimated completion date for CAR 830 revised from July 1,1985 to January 1,1986. Reason stated in CAR is that the solution requires revision of vendor manuals. NETS was requested to coordinate.

• On January 3,1986, esti.nated completion for CAR 830 revised from January 1,1986 to July 1,1986. Reason given was that FNP, NS and designer are developing recomendations to improve the update process for vendor manuals. Recomendation will be presented to management.

• On February 13,1986 ES 86-575 issued to Bechtel and SCS for pilot program to revise vendor manuals and drawings to their current status.

Pilot program enveloped 25 or 250 such documents.

• On June 30, 1986, estimated completion date for CAR 830 revised from July 1,1986 to December 15, 1986. Reason stated that cross index had not been satisfactorily resolved.

• On August 20,1986, ES 86-696 issued to Bechtel with an authorization of 3800 manhours to:

Phase 1) Develop cross reference between each EQ item on the Master List and all applicable domestic drawings, vendor manual's and vendor drawings. Completed January 30, 1987.

Phase 2) Research all PCNs with WCNs to determine those which could impact the EQ Master List and revise documents to reflect the WCN. Scheduled for completion March 31, 1988. .

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, Enclosure 3 Page 41 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-03 Page Three II. Sequence of Events (continued)

• On September 18, 1986, completion date for CAR 830 revised from December 15, 1986 to October 1,1987 based on requested dates given in ES 86-696.

• On December 15, 1986, NRC SER on Section 2.2.2 of Generic Letter 83-28 issued accepting the APCo program with exception. The exception consists of a requirement for APCo to expand the formal vendor contact -

program with vendors.

' On January 30,1987 Phase 1 (cross reference) completed by Bechtel and transmitted to APCo.

• On March 17, 1987, APCo letter to NRC stating objection to the SER on Section 2.2.2 of Generic Letter 83-28. The objection was to the requirement imposed by the SER for APCo to expand the APCo formal vendor contact program.

• On October 1,1987, estimated completion date for CAR 830, Revision 2, revised from October 1,1987 to March 31, 1988 due to ongoing work by Bechtel on Phase II of ES 86-696.

III. Immediate Corrective Action

• Designers were required to review procedures to ensure that adequate controls exisc and are applied to guarantee vendor drawings and manuals are revised to reflect design changes henceforth. (Ref.: letter NT-84-1274 from W. G. Hairston, III to J. D. Woodard, dated 12/18/84).

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Enclosure 3 Page 42 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-03 Page Four IV. Analysis of Events

• APCo has been actively involved with the NRC and NUTAC on the issues identified by G. L. 83-28. This is an emerging area and APCo does not believe that it is appropriate to identify a violation for untimely corrective action in EQ audit for an issue that is of broader scope than EQ and remains in negotiations between the NRC and industry.

• APCo did not close the CAR when original was satisfied; however the scope of the CAR was expanded at each revision. NRC accepted the NUTAC position on 2.2.2 as documented by NRC letter dated December 15, 1986.

The only issue remaining open* (per NRC letter referenced above) was key vendor contact program. Review by Region II inspectors found no violation as documented in inspection report dated April 23, 1985.

V. Long Term Corrective Action

• None.

VI. Date of Full Compliance ,

• The CAR 830 should be completed by March 31, 1988.

VII. Conclusions

• APCo does not agree that this finding is a violation.

• CAR 830 addresses G. L. 83-28 issues which are outside the scope of EQ.

A violation for untimely corrective action in an EQ audit inspection to a CAR that addresses issues outside EQ is not valid.

• Additionally, based on a review of work history and physical inspections conducted by APCo, no safety issues resulted from the use of these vendor manuals or documents while performing maintenance on EQ equipment.

• As items were closed, new issues were identified that related to the issue. To facilitate tracking, APCo decided to revise the existing CAR as additional items were identified, rather than close the CAR and initiate others.

• Notwithstanding all of the above, APCo decided within one year to revise all manuals on design change work henceforth. This completed the root cause corrective action. Enhancements, such as the cross reference index, were completed subsequent to this date and the retrofit work of updating technical manuals from pre-1984 design changes was initiated (to be completed March 1988). It should be noted that this exceeds the comitments made for G. L. 83-28 Section 2.2.2.

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Enclosure 3 Page 43 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-04 i

I Restatement of NRC's description of finding

• NRC designated this as unresolved. See Paragraph 6.h, page 17.

Failure to train personnel involved in EQ activities in the requirements of the EQ program.

II. Sequence of Events

• Craft personnel were trained on EQ prior to the audit.

• NRC EQ audit identifled a concern related to failure to train Technical Staff and Management personnel in EQ activities.

III. Insnediate Corrective Action

• Plant training plan has been revised and requires training for Technical Staff and Managers.

• The FNP QC engineer and his staff, and the Plant Modifications group have been trained since the EQ audit.

• Appropriate G. O. staff personnel have also been trai*iet since the EQ audi t.

• Licensed operators will be trained as part of upcoming requalification training.

IV. Analysis of Event

• N/A V. Long Term Corrective Action

• N/A VI. Date of Full Compliance

• Training plan, "Technical Staff and Manager Curriculum Guide" was revised on February 8,1988 to address EQ training for the Technical Staff and Managers.

VII. Conclusions

• There is no safety significance in this finding. This is an enhancement to the EQ program. l

• It is APCo's position that this item can be closed based upon corrective ection listed in Section III.

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Enclosure 3 Page'44 of 50 N

GDiS LEVEL 17N4SMITTERS ISSUES OIL, SEALS M1D SPLICES

• AGItG EFFECTS l

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Enclosure 3 Page 45 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-05 and

% 50/348, 364/87-30-06

1. Restatement of NRC's description of finding

• 50/348, 364/87-30-05 NRC designated this as unresolved. See Paragraph 6.1.(1), page 19:

Thermal and radiation effects not evaluated for lead wire insulation, terminal blocks and resistors for the GEM's level transmitter (XM-36495 Wide Range).

• 50/348, 364/87-30-06 NRC designated this as a violation. See Paragraph 6.i.(1) page 19:

The licensee found wide range and narrow range containment sump level ,

transmitters on both units, in a configuration that was not considered qualified by existing test dsta.

II. Sequence of Events GEMS Wide Range transmitters documented qualification configuration was based on a test report which used a junction box with a terminal block and RTV-60 to seal the conduit entrance to the junction box. G. E. type F-50 silicon fluid was used in the junction box and transmitter housing. (If the RTV-60 had failed, the silicon fluid would have still covered all age sensitive parts [by approximately 1/8").)

• The Narrow Range transmitter's configuration was based on the GEMS test report which used a junction box with a Raychem splice rather than a terminal block. The junction box had a ninety degree elbow at the conduit entrance rather than RTV-60 to contain the Dow Corning 710 silicon fluid which covered the age sensitive parts.

• Walkdown of Unit 2 Wide Range transmitters on October 10, 1987 discovered that the only deviation from the tested configuration was that there was no fluid in the junction box or transmitter housing. ,

4

• Walkdown for Unit 2 Narrow Range transmitters discovered low fluid l levels; however, sufficient fluid levels were found to exist in the '

junction boxes to cover all age sensitive parts.  ;

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Enclosure 3 Page 46 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-05 and 50/348, 364/87-30-06 Page Two II. Sequence of Events (continued)

• Walkdown for Unit 1 Wide Range and Narrow Range transmitters on October 10, 1987 discovered the following deviations from the tested configuration:

- For the Narrow Range transmitters, V-taped splices were found in lieu of the Raychem splice.

- For both the Narrow Range and Wide Range transmitters, fluid levels were found to be low; however,' sufficient fluid levels were found to exist in the Narrow Range. transmitter junction boxes to cover all age sensitive parts.

- For the Wide Range transmitter junction boxes, approximately one ,

inch of the lead wire and terminal block was exposed.

III. Innediate Corrective Action

• Unit 2 Wide Range transmitters were replaced with identical transmitters prior to startup from the Unit 2 fif th refueling outage.

• Fluid was added to the Unit 1 Wide Range transmitter junction box on October 13, 1987 and October 14, 1987.

• Additionally, the Wide Range transmitters on both units were upgraded by PCNs 87-2-4583 (November 19,1987) and 87-1-4587 (December 10, 1987) to provide the same cable elbow entrance into the transmitter junction box that was used on the Narrow Range transmitter junction boxes and all transmitters have Dow Corning 710 silicon fluid.

• Fluid was added to the Unit 1 Harrow Range transmitter junction box and '

Y-tape splices were replaced with Raychem splices on December 10, 1987 and December 12, 1987.

• Note: Unit 2 Wide Range transmitters were replaced under APCo WR's 138990 and 138991.

r IV. Analysis of Event

• This item was identified prior to the NRC audit by APCo and corrective actions were initiated and described in III. ,

Enclosure 3 Page 47 of 50

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NRC EQ Audit Findings Status 50/348,364/87-30-05 and 50/348,364/87-30-06 Page Three IV Analysis of Event (Continued)

Emergency procedures were reviewed to identify usages for the wide and narrow range containment sump level indications during accident conditions. Evaluation of the usages concluded that they were either limited to accident scenarios which were beyond design basis accidents or their usage was redundant to other indications listed in the procedure which would be available to the operator.

V. Long Term Corrective Action -

• Maintenance procedures have been revised to require fluid level inspections at each refueling outage for each unit. The applicable

• procedures are STD 206.1, 206.2, 224.2, and 224.3.

VI. Date of Full Compliance November 14, 1987 VII. Conclusions

• The as-found condition of these instruments did not impact safe operation or create a condition adverse to safety.

• The wide range instruments say be used by the operator as an additional source of information to terminate safety injection. The primary source is RWST level indication.

• The narrow range instrument's function is leak detection. They have no active safety function to perform during or following a design basis accident. .

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Enclosure 3 Page 49 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-10

1. . Restatement of NRC's description of finding

• The NRC has designated this as unresolved. See Paragraph 14, page 24:

Raychem Stilon [ sic] cable test data does not support qualification for the use of this cable in instrument circuits, paragraph 6.1.(14).

11. Sequence of Events

• NRC had questions on the Stilan cable qualification report and questioned where it is used. The test report identified a "less than" insulation resistance value which has no meaning.

• This was identified late in the audit and did not allow sufficient time for APCo to pursue the question.

• Af ter further investigation with Rajchem, additional documentation to address the question was not available due to the age of the report.

III. Immediate Corrective Action

• N/A 1'. Analysis of Event

' The >nly EQ system which utilizes Stilan cable at FNP is the core exit thermocouple system ,

• The core exit thermocouple system is required to be environmentally qualified by Reg. Guide 1.97. APCo comitted to ensure compliance with Reg. Guide 1.97 by the end cf the Unit 1 eighth and the Unit 2 fif th refueling outages, respectively as documented by APCo response to Reg.

Guide 1.97, dated March 30, 1984 for Unit 2 and June 29, 1984 for Unit 1.

• The NRC issued an order dated June 12, 1984 requiring implementation (installation or upgrade) of Reg. Guide 1.97 parameters by March 1988 (eighth refueling outage) for Unit 1 and by October 1987 for Unit 2.

• The NRC issued an SER on Reg. Guide 1.97 dated January 7,1987 that enclosed the EG&G Idaho TER. The conclusion was that APCo conforms to or is justified in deviating from Reg. Guide 1.9h

• The Stilan cable has been replaced as part of the Reg. Guide 1.97 i upneade for Unit 2 and will be for Unit 1 du-ing the eighth refueling  ;

outage. ,

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• Stilan is on the EQ Master List in error.

• The core exit thermocouple system will be added to the EQ program documents af ter the Unit 2 fif th and the Unit 1 eighth refueling outages j respectively.

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Enclosu're 3 Page 50 of 50

. o NRC EQ Audit Findings Status 50/348,364/87-30-10

% (Page Two) l V. Long Term Corrective Action

• The Stilan cable package will be removed from the EQ central file af ter replacement of the cables.

l VI. Date of Full Compliance .

• N/A VII. Conclusions .

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• There is no safety significance of this finding. This is an enhancement  !

to EQ program required hy RG.1.97.

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