ML20205T191
| ML20205T191 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/16/1987 |
| From: | Ireland R, Andrea Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205T102 | List: |
| References | |
| 50-289-86-28, 50-298-86-28, IEIN-86-003, IEIN-86-3, TAC-42486, TAC-68378, NUDOCS 8704070233 | |
| Download: ML20205T191 (35) | |
See also: IR 05000298/1986028
Text
APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-298/86-28 License: DPR-46
Docket: 50-298
Licensee: Nebraska fut'ic Power District
P. O. Box 45)
Columbus, N wraska 68601
Facility Name: Cooper fluclear Station
Inspection At: Brownsville, Nebraska
'
Inspection Conducted: November 3-7, 1986
Inspector: 8 Y M 8/s3/87
A.(R. Jo nson, Reactor Inspector (Nuclear Date ' /
E ~ r), Team Leader, RIV
Also participating in the inspection and contributing to the report were:
't. Heishman, Chief, Vendor Program Branch, DQAVT, IE
R. Ireland, Chief, Engineering Section, RSB, DRS/P, RIV
D. Norman, Reactor Inspector (Nuclear Engineer), RIV
R. Lasky, Equipment Qualification & Test Engineer, VPB,
DQAVT, IE
J. Grossman, Member of Technical Staff, Sandia Normal
Laboratories (SNL)
M. Yost, Consultant Engineer, Idaho National Laboratory (INEL)
A. Nolan, Consultant Engineer, INEL
Approved By:
R. E. Ireland, Chief, Engindering Section
3//4 /77
D(te '
Reactor Safety Branch
Inspection Summary:
Inspection on November 3-7, 1986 (Report No. 50-298/86-28)
Areas Inspected: Special, announced inspection to review the licensee's
implementation of a program for establishing and maintaining the qualification
of electric equipment within the scope of 10 CFR 50.49. The inspection also
, included evaluations of the implementation of equipment qualification (EQ)
corrective action commitments. These commitments were made by the licensee as
a result of (1) the January 30, 1985 Safety Evaluation Report (SER); (2) the
December 9, 1982, SER and November 24, 1982, Franklin Research Center Technical
8704070233 870401
i PDR ADOCK 05000289
G PDR
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Evaluation Report (TER) enclosed with it; and (3) the licensee's proposed
method of. resolution for each of these EQ deficiencies documented in Nebraska
Public Power District (NPPD) response letter to NRC of April 24, 1984,
regarding the agreements reached during the March 29, 1984 meeting between NPPD
and NRC.
Results: The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49 except for certain deficiencies as
listed in the following tables I and II.
No deficiencies were found in the licensee's implementation of corrective
action commitments made as a result of identified deficiencies in the
(1) January 30, 1985, SER; (2) December 9, 1982, SER/ November 24, 1982, FRC
TER; and (3) NPPD response letter of April 24, 1984, documenting corrective
action commitments as a result of the March 29, 1984 meeting between NPPD and
NRC.
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Table I
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Potential Enforcement / Unresolved Items:
Report Item
j Name Paragraph Number
1. Boston Insulated Wire (BIW), 4.f(1) 298/8628-01
Bostrad 7E Cable; functional
} performance requirements not
1 demonstrated
I 2. BIW Coaxial Cable, 4.f(2) 298/8628-02
i RG59B/4; documentation
i not auditable
3. Kerite 600 Volt Cable, Type HTK/FR; 4.f(3) 298/8628-03
j failed acceptance criteria
! 4. Raychem Coaxial Cable, 4.' f(5) 298/8628-04
l Rayolin R and F; similarity
1
not demonstrated
I
j 5. Electrical Penetrations, 4.f(6) 298/8628-05 ;
General Electric Co.
l Model 238X600NSGI; similarity
j not demonstrated
,
! 6. Various Pressure / Level Switches 4.f(7) 298/8628-06
and Transmitters; mounting,
- orientation, and interfaces in
l the EQDP, inadequately documented
t ~
1 7. Fenwal/Patel Temperature Switch 4.f(8) 298/8628-07' l
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Model 01-170020-090; Thomas &
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Betts STA-KON Cable Splices; ,
qualification not based on full
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accident conditions
I 8. Limitorque Motor Operators, 4.g 298/8628-08
- Series SMB, Internal Wiring;
l (1) polybutadiene analysis,
!
(2) undocumented test results,
- (3) Scotch tape and blind barrel
splices; similarity not
established
9. Limitorque Motor Operators, 4.h(1)(a) 298/86028-09
Series SMB; Okonite
! Motor Lead Splices; similarity
l not demonstrated
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-. - _ - . - . - _ . . -. .- _ . - . - . _ _ _ . . _ _ _ . . _ _ . - . _ . . - . .
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j Table II
- Open Items
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Report . Item
Name Paragraph Number
1. Rockbestos Cerro Firewall III 4.f.(9) 298/8628-10
Cable; documentation deficiencies
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2. Microswitch Limit Switches, 4. f. (10)(b) 298/8628-11
Models OP-N; maintenance
identified in EQDP inadequate
3. Microswitch (Limit Switches) 4.f.(11)(b) 298/8628-12
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Model DTE6-2RQ62; 4.f.(11)(c)
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documentation deficiencies
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4. Microswitch Limit Switches 4.h.(5) 298/8628-13
Models OP-N and DTE 6-2RQ62;
I walkdown deficiencies
5. ASCO Solenoid Valves, 4.f.(12)(b) 298/8628-14
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Type HVA-90-405-2A, 4. f. (12)(c)
WPHT-8316E-36, and NP-1; 4.f.(12)(d)
- documentation deficiencies 4.f.(12)(e)
! 6. ASCO Temperature Switch, 4.f.(13)(b) 298/8628-15'
i Model SA11AR and 4.f.(13)(c)
- OJ 11A4R; 4.f.(13)(d)
l documentation deficiencies
i 7. ASCO Solenoid Valves, Type 4.h.(4)(a) 298/8628-16
l HVA-90-405-2A, WPHT-8316E-36, 4.h.(4)(b)
J and NP-1;
j walkdown deficiencies
I.
i 8. Target Rock Solenoid Valves, 4.f(14)(b) 298/8628-17 !
.
Model 1/2-SMS-A-01-01; 4.f(14)(c) i
i documentation deficiencies 4.f(14)(d) '
, 9. Static-0-Ring Pressure 4.f.(15) 298/8628-18
Switches, TA Series;
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(1) venting of replacement switch
housings
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(2) documentation deficiencies
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Open Items (continued):
Report Item
Name Paragraph Number
j 10. Barksdale Pressure Switch, 4.f.(16) 298/8628-19
, Model 82TM1255 and
documentation deficiencies
11. Rosemount Transmitters 4.f(17) 298/8628-20
Model 1153 Series B;
additional analysis for
, synergistics effects required.
12. Rosemount Transmitter, Model
j 1153D B/11590P, 4.f(18) 298/8628-21
- with Remote Seal System;
additional analysis to include
capillary insulation is required.
13. Limitorque Motor Operators 4.f(19) 298/8628-22
, Model SMB-00 and SMB-2;
documentation deficiencies
14. Limitorque Motor Operators 4.h(1)(b) 298/8628-23
Model SMB-4; broken wire lead
15. Limitorque Motor Operators 4.h(2) 298/8628-24
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Model SMB-3 and SMB-00;
removal of grease relief
shipping caps.
i 16. Reliance Motors; 4.f(20) 298/8628-25
l: documentation deficiencies
17. GE Motor, Model 4.f(21) 298/862P-26
5X6346XC74A and
, 5X6346XC84A; ,
i' documentation deficiencies l
1
18. GE Motors, Model 5K6346XC74A 4.h(3)(a) 298/8628-27 i
and 5K6346XC83A; inadequate
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4.h(3)(b) l
maintenance 1
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19. EQ Cable Identification; 4.f(4) 298/8628-28 l
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generic cable traceability
a
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problem
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-.--en-- - - - - - ,m. - . - -,,n. -- - - - - - . , , - -
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DETAILS
1. Persons Contacted:
J. M. Pilant, Technical Staff Manager, Nuclear Power Group
G. A. Trevors, Division Manager, Nuclear Support
K. Walden, Licensing Manager
G. Horn, Division Manager of Nuclear Operations
J. M. Meacham, Sr. Manager of Technical Support Services
E. M. Mace, Engineering Manager
G. E. Smith, QA Manager (Acting)
R. Brungardt, Operations Manager
D. M. Norvell, Maintenance Manager
J. V. Sayer, Radiological Manager
J. R. Flaherty, Plant Engineering Supervisor
R. Minadeo, EQ Coordinator (Acting)
H. A. Jantzen, I&C Supervisor
J. Hackney, Electrical Supervisor (Acting)
G. R. Smith, Licensing Engineer
G. Cook, Licensing Specialist
T. Browne, Engineering Specialist
N. R. Dingman, Engineering Specialist
J. Hinz, General Employee Instructor / Training Department
NPPD Consultants
R. Minadeo, Patel Engineers (NPPD, Acting EQ Coordinator)
R. A. Hamric, Patel Engineers
S. J. Jobe, Patel Engineers
'j E. A. Troncelliti, Patel Engineers
P. A. Bender, ECS, Inc.
R. K. Ho, EPM, Inc.
M. T. Watson, Stone & Webster
U.S. NRC
D. L. DuBois, Senior Resident Inspector I
E. A. Plettner, Resident Inspector
2. Purpose
i
The purpose of this inspection was to review the licensee's implementation 1
of the requirements of 10 CFR 50.49, and the implementation of corrective
action commitments made as a result of identified deficiencies in the
(1) January 30, 1985 SER; (2) December 9, 1982 SER and November 24, 1982
TER; and (3) NPPD response letter to NRC of April 24, 1984, regarding the
March 29, 1984 meeting between NPPD and NRC.
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3. Background
On March 29, 1984, the NRC held a meeting with the licensee to discuss a
TER which had been prepared for the NRC staff by Franklin Research Center.
The discussion centered on open issues regarding environmental
qualification at CNS, including acceptability of environmental conditions
for EQ purposes. The meeting covered NPPD's proposed methods to resolve
the EQ deficiencies identified in the December 9, 1982 SER and
November 24, 1982 TER. Discussions also included NPPD's methodology for
compliance with 10 CFR 50.49, and justification for continued
operation (JCOs) for those equipment items for which EQ was not yet
completed. The minutes of the meeting and proposed methods of resolution
for each of the EQ deficiencies were documented in NPPD's response to the
NRC on April 24, 1984, which addressed each item for which EQ was not yet
completed (see Section 4.d). Earlier and subsequent responses to these
identified deficiencies were documented in licensee submittals to the NRC
on January 2,17, and 24, May 20, and June 24, 1983, December 26, 1984,
February 15 and March 26, 1985, July 21, August 8 and September 8, 1986.
NPPD requested a schedular exemption to the 10 CFR 50.49 (g) requirements
(e.g. , identify the EQ equipment, and schedule a goal for final EQ by the
second refueling outage after March 31, 1982) by letter to NRC dated
June 24, 1983, and was granted the exemption until March 31, 1985 (NRC
letter to NPPD, October 3, 1983). FM lowing this date, NPPD further
requested exemption beyond March 31, '985, for reactor equipment
cooling (REC) pump drive motor replauments due to procurement lead time
(NPPD letter to NRC dated February 15, 1985). The extension of the
March 31, 1985, exemption date to November 30, 1985, for REC pump drive
motor replacements, was granted (NRC letter to NPPD dated March 26, 1985).
On January 28, 1985, NPPD certified (affirmed to NRC by letter in response
to NRC Generic Letter 84-24) compliance to 10 CFR 50.49 in that (1) the EQ
program at CNS satisfies the 10 CFR 50.49 requirements by formal
implementation through CNS procedures; (2) CNS has EQ equipment for both
paths to safe shutdown fully qualified; and (3) all other EQ equipment
within the scope of 10 CFR 50.49 (other than the REC pump drive motor
exemption) is fully qualified, or will be qualified (JC0's) prior to
completion of his current outage and startup during late May 1985. This
excludes equipment related to the Regulatory Guide (RG) 1.97 program which
would be qualified under a separate implementation schedule.
On January 30, 1985, the SER for final resolution of EQ of electrical
equipment important to safety for CNS was issued by the NRC. This SER
found (1) NPPD's proposed resolutions of EQ deficiencies acceptable;
(2) NPPD's approach for compliance with the 10 CFR 50.49 requirements
acceptable; and (3) JCO's for those equipment items for which EQ was not
yet complete, at that time, acceptable. The January 30, 1985, SER listed
33 equipment items currently under JCOs for which completion of EQ was
required prior to the end of the May 1985 startup date.
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NPPD's letter and submittals to NRC on March 1 and April 16, 1984,
provided a separate status and schedule for implementation of a program to
provide instrumentation to monitor plant variables and systems during and
following an accident (RG 1.97, Revision 2). A review of this submittal
by INEL (Contractor for NRC) concludes CNS has an explicit commitment to
conform to the RG 1.97 guidelines (letter NRC to NPPD dated March 11,
1985). Subsequent NPPD letters of March 6 and May 24, 1985, reflect
further changes in this separate impleaentation schedule (cited for
completion in 1988-89).
The above identified documents were reviewed by the inspection team
members and used in preparation for this inspection.
4. Findings
a. 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
qualified status of electrical equipment. Based on the inspection
findings, which are discussed in more detail below, the inspection
team determined that the licensee has implemented a program to meet
the requirements of 10 CFR 50.49 for the CNS although some
deficiencies were identified (Refer to Sections 4.f and 4.h),
b. EQ Program Procedures
The inspection team examined the implementation and adequacy of
corporate and site policies and procedures for establishing and
maintaining the environmental qualification of electrical equipment
in compliance with the requirements of 10 CFR 50.49. The licensee's
o thods for establishing and maintaining the environmental
qualification of electric equipment were reviewed in the following
documents:
CNS Operations Manual - Engineering Procedures
Proc No. Title
3.4 Station Design Changes, Revision 4.
3.4.4 Temporary Design Changes, Revision 0.
l 3.11 Vendor Contact for Verification of Manuals, Revision 0.
l 3.12.1 EQ Program Implementation, Revision 0.
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3.12.2 EQ Data Package, Revision 3.
3.12.3 EQ File Control, Revision 1.
3.12.4 EQ Equipment Replacement Evaluation
Procedure, Revision 2.
3.12.5 EQ Age Related Degradation Equipment
Evaluation, Revision 2.
3.12.6 EQ Evaluation Guidelines, Revision 1.
r
3.13 Equipment Classification, Revision 1.
CNS Operations Manual - Procedures
Proc No. Title
0.20 Equipment Qual *fication, Revision 0.
0.24 Generating and Dispositioning Vendor Manual Change
Requests, Revision 1.
0.25 Vendor Manual Change Order Review and Approval, Revision 0.
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O.26 Surveillance Programs, Revision 1.
CNS Operations Manual - Administrative Services Procedures
,
Proc No. Title
1.4 Requisitioning, Revision 4.
1.8 Wareh'ouse Issue and Return, Revision 2.
1. 9 Control and Retention of Records, Revision 5.
1.10 Document Control, Revision 1.
1.11 Essential Spare Parts 1 Program, Revision 1. !
CNS Operations Manual - Maintenance Procedures
Proc No. Title
7.0.1 Work Item Tracking - Corrective Maintenance, Revision 5
7.0.2 Work Item Tracking - Preventative Maintenance, Revision 1
7.0.5 Maintenance Quality Control Program, Revision 3.
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6.2.2.3.6 HPCI Pump Low Suction Pressure Calibration and Functional /
Functional Test, Revision 13
6.2.2.4.4 CS Loops A and B Core Spray Initiation (Pump and Valve
Control) Functional Test, Revision 11
7.2.50.1 EQ Inspection Procedure for Limitorque Operators,
Revision 1.
7.3.24 HFA Relay Coil Replacement, Voltage Pickup, and Contact
Adjustment, Revision 2
7.3.25 MSIV Namco EA-180 Limit Switch Maintenance, Revision 2.
7.3.26 Qualified Electrical Splice and Motor Termination
Insulating, Revision 0.
7.3.26.1 Environmental Qualified Okonite Tape Wrapped Splices and
Terminations (Bolted), Revision 0.
7.3.26.2 Environmental Qualified Okonite Tape Wrapped Splices and
Terminations (Crimped)
7.3.33 Electrically Disconnecting and Connecting Limitorque Valve
Operators, Revision 2
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CNS Operations Manual - Instrument and Control Procedures
Proc No. Title
7.5.5.4 Scram Pilot Valves, Revision 7
The inspection team reviewed the above licensee's procedures for
meeting the requirements of 10 CFR 50.49 including (1) qualified
life; (2) service conditions; (3) periodic testing; and
(4) maintenance and surveillance. The licensee's EQ program was also
reviewed with regard to establishment of an auditable documentation
file, including such documents as EQ audit reports, maintenance and
surveillance records, supporting documents which establish EQ
training of personnel, and supporting documents which control plant
modifications, procurement, and installation of replacement equipment
to the requirements of 10 CFR 50.49.
The licensee's EQ program procedures and policies are established and
are being adequately implemented to control and maintain the ,
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environmental qualification at electrical equipment at CNS for
compliance with the requirements of 10 CFR 50.49.
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c. EQ Surveillance / Maintenance / Replacement Parts / Control of Plant EQ
Modifications / Training / Audit Programs
The following programs were effectively in place at CNS:
(1) EQ Surveillance Programs
The CNS plant engineering supervisor is responsible to recommend
through the CNS maintenance and operations manager, the required
preventative maintenance activities, to maintain EQ items by the
surveillance schedule, which are implemented through CNS
maintenance procedures, preventative maintenance system
procedures, and surveillance procedures. The preventative
maintenance (PM) section of the work item tracking system (WITS)
is used at the CNS plant to provide station personnel with a
means to schedule and document PM. PM items are scheduled at
frequencies of months, refueling cycles, or plant outages.
However, CNS PM's are scheduled at fixed calendar intervals
based on initial date. Some test equipment are on a slip
schedule based on their last completion date. PM activities are
categorized into PM types such as calibration, lubrication,
visual observations, etc. PM's performed are documented for
scheduling purposes and recorded in the CNS equipment history
file. When a need for corrective maintenance arises, during the
PM activities, an authorized maintenance work request (MWR) is
issued for immediate action. The safety classification of
equipment is identified on the PM request which requires the
essential EQ components qualified to 10 CFR 50.49.
The NRC inspection team reviewed the procedures (paragraph 4.b
above) and controls for the CNS surveillance program to verify
that this program is effectively being implemented. Further
verification will be accomplished during a subsequent NRC
inspection.
No Potential Enforcement / Unresolved Items or Open Items were
identified.
(2) EQ Haintenance Program l
The CNS maintenance supervisor is directly responsible for the .
proper maintenance, calibration, and testing of all )
electrical EQ systems and components, and is directly
responsible to the CNS maintenance manager. The WITS is used to
identify work items at CNS that require maintenance and repair,
and is the mechanism to enforce their orderly accomplishment
using MWR's. The WITS forms are initiated by CNS personnel to
fully describe corrective maintenance activities, obtain all
pertinent information, and identify available reports, control
room work item file records, and computer information. The
safety classification of equipment is identified in the WITS j
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form requiring essential EQ electrical components to be
qualified to 10 CFR 50.49 requirements. The MWR's are compiled
by computer using the WITS form. Emergency maintenance work
activities are initiated by shift supervisors using the
emergency maintenance work request (EMWR) in lieu of the WITS
form. Results of EQ corrective maintenance (CM) ac ;ities are
under review of the CNS system engineers, operations
supervisors, and maintenance supervisors. CNS has their
systematic quality control activities established within their
maintenance quality control program.
CNS has an ongoing program to evaluate EQ equipment, in a
historical data file (HDF), which reviews the surveillance and
maintenance records and calibration test data to identify
potential age-related degradation mechanisms. Reports of
significant findings are completed and published in 3-month
intervals to CNS personnel,
i
The NRC inspection team reviewed the procedures (paragraph 4.b )
above) and controls for the CNS maintenance program, to verify j
that this program is effectively being implemented. Further
verification will be accomplished during a subsequent NRC
inspection.
No Potential Enforcement / Unresolved Items or Open Items were
identified.
(3) EQ Replacement Parts Program
CNS has a replacement evaluation program which ensures that EQ
components and equipment maintain their qualification status by
proper replacement of parts and documentation. The replacement
evaluation (RE) forms are initiated by the CNS responsible
system engineers when replacements for EQ equipment have been
purchased. EQ equipment and spare parts (SP) checklists are
used with the RE form to evaluate qualification of components
and materials used as replacement parts. Once approval of the
RE is complete, the RE information is entered into the CNS
inventory purchase order (IPO) file. The SP checklist /RE forms
are used as the appropriate controls to assure qualification for
EQ applications. Unresolved items of the SP checklist /RE forms
consider the replacement components unqualified.
Requisitioning of essential EQ materials, parts, and components
requires CNS to complete a purchase requisition (PR) in
agreement with the equipment spare parts inventory. PR's are
required to provide information pertaining to material types.
Documentation for EQ qualification are to be specified on the
prs. The PR originator is required to verify that the vendor is
..
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on the CNS QA approved vendor list. The PR's are logged into
the CNS purchase order tracking system. Field purchase orders
are not permitted for EQ purchases.
No Potential Enforcement / Unresolved Items or Open Items were
identified.
(4) Control at Plant EQ Modifications
Technical reviews, technical justifications, and safety analyses
are performed at CNS associated with EQ plant modifications,
reflecting changes to the USAR and CNS Technical Specifications.
Interim documents are reviewed by the operations supervisor,
completed reviews by engineering are transmitted to the
licensing department, and the CNS training manual is updated by
the operations training supervisor. CNS engineering has the
responsibility to complete a design change completion report
pending EQ plant modifications. An independent review is also
performed by an EQ coordinator, and random audits are performed
to verify plant EQ modification activities.
Also CNS procedures control and document temporary design
changes (TDC) for EQ safety-related equipment. CNS procedures
control the necessary review, technical justification, and
safety analysis associated with TDCs. The TDC package is not
considered permanent, but may be left installed longer than
6 months. TDC's are reflected on control room drawings and
incorporated in station operating procedures. Installation of
TDC's will be reviewed on a 6-month frequency for continued
applicability. When removed a TDC completion report is
prepared. When a TDC is determined to be permanent, the TDC
will be documented by an approved plant modification requiring
further technical review, technical justification, and safety
analysis. This includes an equipment specification change
followed by an approved temporary design change completion
report. CNS plant engineering is responsible for maintaining a
complete file on TDC's.
The NRC inspection team reviewed the procedures (paragraph 4.b
above) and controls for the CNS EQ plant modifications and TDC
program to verify that this program is effectively being
implemented. The TDC program covered EQ activities but did not
specifically address EQ in the CNS proceduras. Further
verification will be accomplished during a subsequent NRC
inspection. ,
No Potential Enforcement / Unresolved Items or Open Items were
identified.
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(5) EQ Personnel Training Program
The CNS training department is responsible for administering the
EQ training program to CNS personnel and documenting the
completion of personnel training. CNS was in the process of
formalizing their training program by written procedures during
the time of this NRC inspection. The NRC inspection team
interviewed CNS personnel to verify that this program was
established. .EQ training was in process with the crafts,
engineering personnel, and selective operations personnel.
Further verification will be accomplished during a subsequent
NRC inspection to review records of the formal EQ training
program.
No Potential Enforcement / Unresolved Items or Open Items were
identified.
(6) EQ Audits
CNS has in place an audit program which prescribes planned and
periodic EQ audits to verify that the EQ program is consistent
with the requirements of 10 CFR 50.49. The EQ audit program is
an integral part of CNS's quality assurance (QA) program to meet
the requirements of 10 CFR 50, /-ppendix B. The CNS EQ audit
program includes EQ audits performed at CNS by EQ contractors.
The NRC inspection team interviewed CNS personnel to verify that
the EQ audit program was established as part of the CNS
QA program. The NRC inspection team verified that the EQ audit
program is effectively being implemented by reviewing one
QA audit report of the CNS EQ program No. G85-09, July 3 through
August 6, 1985, and two followup QA audit reports, dated
January 9 and October 20, 1986. The NRC inspection team i
concluded the EQ audit program was effectively being l
implemented. Further verification, however, will be '
accomplished during a subsequent NRC inspection.
No Potential Enforcement / Unresolved Items or Ope 1 Items were
identified,
d. SER/FRC TER, and Licensee Response Commitments
The NRC inspection team evaluated the implementation of EQ corrective
action commitments made as a result of (1) the January 30, 1985, SER;
(2) the December 9, 1982, SER/ November 24, 1982, TER; (3) the
licensee's proposed method of resolution for each EQ deficiency
documented in the NPPD response letter to NRC of April 24, 1984,
regarding the March 29, 1984, meeting between NPPD and NRC; and
(4) the licensee's proposed method of resolution for each EQ !
deficiency documented in subsequent NPPD response letters to NRC i
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dated December 26, 1984, February 15, and March 26, 1985. The NPPD
response letter of April 24, 1984, included the following key
enclosures:
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I. Methodology for TER Deficiency Resolution
II. Response to TER Generic Items
III.A. TER Equipment Qualification Open Item Resolution
III.B. Non-TER Equipment Qualification Status
IV. Justifications for Continued Operation
V. NPPD/CNS Master Equipment List
The majority of deficiencies, identified above, involved
qualification documentation errors and omissions, deficient and
incomplete qualification by similarity analyses, incomplete aging
documentation, and incomplete replacement schedules to maintain
qualified life of components. Also, many of the identified
deficiency corrective action commitments by NPPD required additional
equipment shielding or relocation, and exempting equipment now
located in mild environment.
The NRC inspection team verified that the licensee's EQ documentation
file contained the appropriate analyses and necessary documentation
to support qualification of electrical equipment, by review of
analyses and type test qualification documentation, including
verification of numerous equipment replacements, and partial
i
replacements of equipment. Also, the licensee shielded and
reevaluated numerous component locations from harsh environment
conditions (now classified as mild environment) and removed them from
the 10 CFR 50.49 Master Equipment List (MEL). The NRC inspection
team verified the licensee's efforts to reexamine, upgrade, add, and
delete JCOs in effect earlier. The numerous JC0 deletions which were
indicated at this time were a result of the licensee's replacement
i equipment programs prior to the 10 CFR 50.49(g) extension deadline
date of November 30, 1985. The licensee had in effect programs to
replace, partially replace, test, and perform additional analyses on
equipment, earlier identified in JCOs.
l Based on review of EQ documentation files and of the MEL, the NRC
i inspection team identified no deficiencies in the licensee's
implementation of SER, TER, and licensee response commitments listed
above. Ongoing review of the licensee's RG 1.97 program
implementation may result in additional equipment being added to the
MEL (see Section 4.e).
Additional implementation of the licensee EQ corrective action
commitments was reviewed by the NRC inspection team with regards to
the licensee's response to IE Information Notice 86-03 " Potential
Deficiencies in Environmental Qualification of Limitorque Motor Valve
Operator Wiring, January 14, 1986," (see Section 4.g). I
i
l
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. _ _ - - _
- . -- . _ - . - , -
_ ______ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
16
e. 10 CFR 50.49 Master Equipment List
The NRC inspection team reviewed the Master Equipment List (MEL),
Revision 7, August 20, 1985, and associated documents, to verify the
adequacy of the implementation of NPPD's master list development and
maintenance methods as accepted in the SER for final resolution of
equipment important to safety issued on January 30, 1985. In
addition to the MEL and SER, the following procedures were reviewed
by the NRC inspection team:
CNS Operations Manual - Engineering Procedures
Proc. No. Title
3.12.3 Equipment Qualification File Control, Revision 1.
3.13 Equipment Classification, Revision 1.
I
CNS Operations Manual - Procedures
Proc. No. Title
0.20 Equipment Qualification, Revision 0.
The source document for the MEL origin is contained in EQ data
package (EQDP) No. 45, Revision 2 reviewed by the NRC inspection
team. The methodology used to control and maintain the MEL is
described in the CNS operations manual, engineering procedure
No. 3.12.3 Equipment Qualification File Control, Revision 1,
Section I. The EQ documentation file is required to be updated,
including the changes to the MEL as applicable, each time a
configuration change to EQ equipment occurs, or to the environmental
profiles for which the equipment must be functional. Specific
updating of the MEL is required (1) when equipment repair or
refurbishment using nonidentical parts occurs; (2) equipment
replacements are required; (3) equipment additions or deletions occur
due to station modifications; and (4) equipment relocation and
revisions to environmental specifications occur. These procedures
were reviewed by the NRC inspection team and no deficiencies were
found in maintaining the MEL.
The 10 CFR 54.49 MEL review consisted of emergency operating
procedure (EOP) reviews to determine what equipment is required to
support and carry out these E0P and associated safety functions.
Eight components were selected from equipment identified in the
following E0P and verified against the MEL. All were found on the
MEL.
- _ _ - - . . _ _ . _- - _ _ .-
l
l 17
l
l
l
Emergency Operating Procedures
'
E0P-2, Revision 2, April 4, 1986
-Primary Containment Control
l -Suppression Pool Temperature Control
!
-Drywell Temperature Control
-Primary Containment Pressure Control
-Suppression Pool Level Control
-Makeup to Suppression Pool from Condensate Storage Tank
E0P-2, Revision 2, Attachment 1, April 4, 1986
-Drywell and Suppression Pool Temperature Calculations
Post accident monitoring (PAM) equipment is yet to be completed in
the MEL. Some PAM equipment has been added since some upgrades to
the RG 1.97 program have been accomplished in the CNS plant
configuration. The CNS RG 1.97 program completion is targeted for
1988/89.
Based on this review, the 10 CFR 50.49 MEL is considered to be
satisfactorily implemented.
f. EQ Documentation Files
The licensee's environmental qualification file (EQF) at CNS has been
established and is being maintained to meet the requirements of
10 CFR 50.49. The requirements for establishing, controlling,
routing, and filing EQ data are contained in CNS engineering
procedure No.'s 3.12.1, 3.12.2, 3.12.3, 3.12.4, 3.12.5, and 3.12.6.
Additionally, equipment classification is controlled by CNS
engineering procedure No. 3.13, Revision 1, and station design
modifications by CNS engineering procedure 3.4. EQ information
entered into the CNS plant equipment management (PEM) system,
provides automatic update of information as changes occur. The EQ
information contained within the PEM system and EQDPs comprise the
body of information referred to as the EQF. The EQ coordinator is
responsible for ensuring that the EQDPs are maintained current and
are revised as changes occur.
The EQF consists of four sections as follows: (1) MEL;
(2) environmental parameters; (3) EQDPs; and (4) reference
documentation. The MEL is arranged by component identification
code (CIC) numbers and provides summary information identifying each
EQ equipment item along with its system, manufacturer, model number,
function, location, and environmental requirements.
The environmental parameters section provides specifications for the
parameters which must be evaluated to environmentally qualify EQ
equipment.
l
l
l - . - - - . .. . _ ._. _ _ _ . - . ,, . - - .
- . - - - - - - - - - - - - - - _
,
18
The EQDP section of the file is arranged by manufacturer and
summarizes qualification specifications and evaluation results for
each EQ equipment item, in addition to its mair.tenance and
surveillance requirements controlled by CNS Engineering
Procedure 3.12.2. Each EQDP is numbered and identified by
manufacturer and model number. The EQDP log is maintained by the
plant engineering department. Each EQDP is controlled by a record of
revision. All references contained in the EQDP's are found in the
reference documentation section of the EQF. The PEM system provides
the remainder of the information necessary to complete the EQ file.
Specifically, the following computer systems are required for file
information: (1) WITS which addresses maintenance actions required
to upgrade equipment; (2) equipment spare parts inventory (ESPI);
(3) equipment data file (EDF) which provides detailed records for all
plant components including EQ items; and (4) purchase order
tracking (P0T) system which provides a method of processing and
tracking purchases at CNS.
The NRC inspection team examined files for 63 selected equipment
items (EQDPs) to verify the qualified status of equipment within the
scope of 10 CFR 50.49. In addition to comparing plant service
conditions with qualification test conditions and verifying the bases
for these conditions, the inspectors selectively reviewed areas such
as (1) required post-accident operating time compared to the duration
'
.
of time the equipment has been demonstrated to be qualified;
(2) similarity of tested equipment to that installed in the plant;
(3) evaluation of adequacy of test conditions; (4) aging calculations
for qualified life; (5) replacement part schedules; (6) the effects
of decreases of insulation resistance on equipment performance;
(7) adequacy of demonstrated accuracy; (8) evaluation of test
anomalies; and (9) applicability of EQ problems as reported in IEN's
and IEB's and their resolution. The files adequately documented
qualification of equipment and were readily auditable, complete, and
l accurate.
l
t
During this review of the EQF the inspection team identified the
Potential Enforcement / Unresolved Items and Open Items, described
below.
(1) EQDP 6, BIW Cable, Bostrad 7E
'
The qualification criteria for this file is the 00R Guidelines.
This cable is used at various locations in the plant. The types
of cable in this file are identified using plant identification
numbers J1, K1, L2, and J2. The material used in the cable is
ethylene propylene rubber (EPR) with Hypalon (chlorosulfonated
polyethylene,CSPE) jacket.
There was a concern identified with the functional analysis that
is generic. Insulation resistance (IR) values for cable
measured in tests are for lengths of 20 ft, to 50 f t. To use
~
- - - - _ - . _ - _ - - -.. - _.- -. - -_ - -.-.--
.
i
'
!
19
l
l
these values in an analysis, the value must be converted to a
per foot basis. The acceptable leakage current or IR value must ,
- be determined for the overall circuit, including length of i
4
cable, splices, penetrations, and any other probable leak path. ;
1
The EQDP 6 file documented the IR values directly from the type .
l
test report to determine acceptability and did not consider i
>
analysis of the entire circuit. According to the 00R -
1 Guidelines, operational modes tested should be representative of
- ! the actual application requirements (e.g., electrical cable
loading during the test should be representative of actual ;
operating conditions). Failure or acceptance criteria during *
1
type testing should be based on the maximum error assumed in the
l plant safety analyses. Tl.e BIW Bostrad 7E Cable, in EQDP 6 !
'
l file, did not adequately demonstrate qualification because of
1 failure to show that the cable functional performance
i requirements were satisfied. The analysis using the 20-foot
J cable length from the type test, rather than the fully installed
i cable length (including considerations given to splices and ,
'
penetrations in the cable runs) of the installed configuration, '
- is therefore considered a Potential Enforcement / Unresolved Item ;
(50-298/8628-01).
(2) EQDP 6A, BIW Coaxial Cable, RG 598/4
,
J The qualification criteria for this file is 10 CFR 50.49,
l NUREG-0588, Category I. This cable is used for the high range
l radiation monitor outside of containment.
)
The file contained BIW test report 76J049. The test report
consisted of only a single page summary with no other
supplemental data attached. According to NUREG-0588, Category I
J
I
requirements, a record of the qualification, including .
'
documentation must be maintained in an auditable form for the
entire period during which the covered item is installed in a ;
nuclear power plant or is stored for future use to permit ;
! verification that each item is qualified for its application. ;
i The EQDP 6A file for BIW Coaxial Cable RG598/4, contains a test l
) report which was not auditable to the extent that the !
l documentation was incomplete, not understandable, and not ;
traceable to permit independent verification of conclusions. :
The test report does not support qualification, and is therefore '
.
I
considered a Potential Enforcement / Unresolved Item
- (50-298/8628-02).
j (3) EQDP 5 Kerite 600/1000 Volt Cable, Type HTK/FR
i The qualification criteria for this file is the 00R Guidelines.
] The cable is used throughout the plant. Cable types in this
i file are identified using plant identification numbers H1 l
! through H4.
!
._
. _ _ _ _ _ _ _ _ _ . - , _ _ . . . _ _ . _ _ _ _ _._.-- _ _ __ -
. _ _ _ __ _ _ _ . - ._ _ ._ - _ _ _ _
1
20
The EQOP references Franklin test report F-C4020-2 to support
4
qualification. The IR measurements listed in test report
F-C4020-2 were very low (<1 x 1060) for the 50 ft. 600V cable
samples (H1 and H2) tested. Measurements were accomplished
, using a vacuum tube voltmeter (V0M) indicative of these
'
.
extrimely low measurements. The test report also indicated
numer1us failures in the high pot tests of the 600V cable (H1
and H2) samples.
According to the 00R Guidelines, operational modes tested should
, be representative of the actual application requirements (e.g.,
electrical cable loading during the test should be
i
representative of actual operating conditions). The 600 Volt,
Kerite HTK/FR cable test data, in the EQDP 5 file, documented IR
readings too low for acceptance during the DBE test, and
documented numerous failures during the post DBE high pot test,
and is therefore considered a Potential Enforcement / Unresolved
l Item (50-298/8628-03).
J
The 1000V cable samples (H3 and H4) however, maintained their
current and voltage during the DBE test and passed the high pot
tests. Qualification of the 1000V cable is supported by the
- Franklin test report F-C4020-2.
(4) EQ Cable Identification and Traceability
CNS does not hase the capability to identify the cable
manufacturer of type of cable interfacing with their equipment
important to u fety as listed on their MEL. For example, if CNS
is given a cab'e tag number connected to an EQ equipment item, l
! CNS has no way of identifying the cable type or cable
i manufacturer. Cable pull cards and termination cards have not
i been retained tince CNS has been built, and qualification of all
l EQ cables is based on a generic qualification to the worst case
i
' harsh environment conditions that exist at CNS. CNS has an
apparent breakdown in their record system with regards to
traceability from component to EQDP files and identification on
[ the MEL. This is considered an Open Item (50-298/8628-28).
(5) EQDP 4, Raychem Coaxial Cable, Rayolin R and F
The qualification criteria for this file is D0R Guidelines. The
cable is used throughout the plant including containment. The
file references the Franklin Test Report F-C4033-1. The concern
identified in this file is with the similarity analysis. Five
, types of Raychem coaxial cable (M1 through M5) are identified in
this file as being installed in the plant. M1 through M3 are
i listed as containing Rayolin F insulation. M4 and M5 are listed
as containing Rayolin R. Documentation in the EQF is confusing
and references Rayathon R as cross linked polyethylene (XLPE),
Rayfoam F as XLPE foam dielectric, Rayolin F as a foam
,
)
21
dielectric coax cable, and Flametrol as an XLPE insulated cable.
The type test report identifies specimens as follows:
Specimen 2 is Flametrol XLPE Cable
Specimen 5 is Rayolin R Coax Cable
Specimen 6 is F.ayfoam F Triax Cable
' The EQF is unclear in that it identifies type M3 as containing
Rayolin R, not Rayolin F. The EQF is unclear in that similarity
is claimed between specimen 2 and M1 through M3 (Rayolin F, not
FlametrolXLPE). Therefore, the claim of similarity is not
clear or well supported. Additionally, the exact material in
the cable is not clearly established.
According to the DOR Guidelines, the test specimen should be the
same model as the equipment being qualified. The type test
should only be considered valid for equipment identical in
design and material construction to the test specimen. Any
deviation should be evaluated and be incorporated as part of the
- qualification documentation. The EQDP 4 file for Raychem
'
Coaxial Cable, does not clearly establish qualification of
construction materials by similarity and is therefore considered
a Potential Enforcement / Unresolved Item (50-298/8628-04).
(6) EQDP 8, General Electric Electrical Penetration, Model
238X600NSGI
General electric penetrations Model 238X600NSG1, Tag
Nos. PC-Pent-X100A, PC-Pent-X100E, PC-Pent-X100G, PC-Pent-X102,
PC-Pent-X105A and PC-Pent-X105D are located in various positions
which penetrate the primary containment wall, and are used for
electrical power and control of various safety-related equipment
within the drywell. Documentation pertaining to qualification
,
of these electrical penetrations is contained in EQDP 8 with
, numerous GE electrical penetration assembly reports referenced
l in the EQDP.
I
The EQF for the General Electric electrical power and control
penetrations did not adequately establish qualification because
of failure to demonstrate similarity between the tested and
installed components. The EQDP, test report, and analysis,
contained in the EQF, could not demonstrate traceability between
the electrical penetrations installed at CNS, to those specimens
typetested(F01-NS02,NS03,andNSO4)inthatnopositive
identification link could be established between tested and
installed items.
This item is considered a Potential Enforcement / Unresolved Item
(50-298/8628-05).
r
22
(7) Mounting, Orientation, and Interface Requirements of EQDP's
(Generic) for Barton, Square D, Barksdale, Pressure Controls,
Static-0-Ring, Robert Shaw, and Rosemount Pressure / Level
Transmitters / Switches, and Conduit Seals.
The NRC inspection team in examining EQDP No 's 9, 12, 13, 33,
33A, 36, 37, 49, 76, 81, 217, 222, and 228 identified
generically that these packages do not address mounting,
orientation, and interfaces of the equipment requiring
environmental qualification. From the EQF it could not be
verified that this equipment at CNS was installed as type
tested. The licensee agreed that this was a weakness in the
EQF's and committed to correct it. The licensee however, showed
evidence that mounting, orientation, and interfaces were
addressed in the installation instructions for EQ equipment
contained in other files. These generic omissions in the EQF
are considered file deficiencies. Failure to generically
address mounting, orientation, and interface requirements in the
EQF is contrary to the D0R Guidelines, Section 5.2.2 and is
considered a Potential Enforcement / Unresolved Item
(50-298/8628-06).
(8) EQDP 220 and 220A, Fenwal/Patel Temperature Switches,
Models 01-170020-090 and 01-170230-090
These switches are located throughout the plant and are placed
near the main steam lines. The switch monitors the ambient
temperature and in the event of a steam leak will actuate when
the area temperature reaches 190 F increasing. The switches are
used for a high energy line break (HELB) accident and must
operate for one hour post accident.
EQDP No. 220A, did not adequately establish qualification
because of failure to base the qualification of the interfacing
cable splices on full accident conditions including service life
for radiation and aging effects. The splices are constructed by
using Thomas & Betts STA-KON friction fit crimped connectors
with loose black barrel sleeves covering the connections. The
EQDP documented these splices qualified to interface Class 1E
instruments to field cables with the qualification based on a
steam test only. Contrary to Section 5.1 of the D0R Guidelines,
there was no documentation or data to support a full accident
environment with an analysis or subsequent test reports which
would be required to completely qualify these splices for their
application. Also, during the NRC walkdown inspection it was
noted that the field installation of the interfacing cable
splices is dependent upon the confined space inside of the
conduit to keep the loose barrel sleeve in place over the
electrical connection; this represents poor design and
installation practice. This item is considered a Potential
Enforcement / Unresolved Item (50-298/8628-07).
_ _ _ _ _
23
(9) EQDP 7A and 205, Rockbestos Cerro Firewall III Cable
The qualification criteria for these files are 00R Guidelines ;
for EQDP 7A and 10 CFR 50.49 NUREG-0588, Category I, for '
EQDP 205. The types of cable in EQDP 7A are identified using
plant identification numbers H1, H2, J1, K1, K2, L1, L2, and L3.
For EQDP 205, the numbers are H1, H2, G1, G2, J1, L1, and Kl.
These files indicate that both radiation and chemically XLPE are
used (NPPD has not determined which formulations of the
chemically crosslinked material were supplied). NPPD's intent
was to qualify all formulations of Firewall III. The proper
test reports were available in other files, but were not
referenced in these EQF's. These files are required to be j
revised to include the proper documents and references to
demonstrate that the plant environmental profiles are enveloped
by the type test conditions.
Both files were prepared af ter November 30, 1985. EQDP 7A on
January 7, 1986, and EQDP 205 on April 1, 1986. Documentation
was not in place since November 30, 1985 as required by
IEN 84-44. IEN 84-44 indicated the courses of action to support
qualification of Rockbestos Cable products prior to the
November 30, 1985 deadline. EQDP files 7A and 205 were not
considered auditable; however, all required documentation was
available for these files, and numerous errors reflected
improper references.
These deficiencies in the EQF for EQDP 7A and 205 are considered
an Open Item (50-298/8628-10).
(10) EQOP 33, Microswitch Limit Switches, Model OP-N
(a) Microswitch limit switch, Model OP-N, is used on the high
pressure core injection (HPCI) system turbine exhaust drain
valve. The limit switch is located in the HPCI room at
elevation 859 feet. EQDP 33 claims qualification for a
40 year service life by similarity, and the switch must
operate up to 6 months following a LOCA.
Qualification of model OP-N limit switch is based on the
similarity of materials to Model BZ-2R. The model BZ-2R
radiation test report includes model OP-N qualification.
The service life thermal qualification of model OP-N
switch, however, is based on calculations and analyses.
(b) The OP-N switch contains gaskets, seals, and "0"-rings made
from BUNA-N material. The EQDP demonstrates that these
materials have a service life of 2.78 years. The licensee
however considers these components of the limit switch as
rionsafety related in their application, and therefore the
- - - - . - I
24
EQDP indicates that a scheduled maintenance and replacement
parts program is not necessary in order to satisfy the
switch's 40 year service life. The concern of the NRC
inspection team is that deteriorating gaskets, seals, and
"0" rings could impact the safety-related performance of
the OP-N limit switch. As identified in section (b)(2) of
10 CFR 50.49, the effect of failure of nonsafety-related
electric equipment on satisfactory performance of
safety related equipment must be considered.
The EQF will be required to address the surveillance,
maintenance, and replacement parts aspects of the BUNA-N
components identified in (b) above. Also, the limit switch
mechanism should be periodically checked for its physical
position relative to the open or clnsed limits of the valve, to
verify that the plunger is still operative. These deficiencies
are considered an Open Item (50-298/8628-11).
(11) EQDP 33A, Microswitch Limit Switch, Model DTE6-2RQ62
(a) Microswitch limit switch, model DTE6-2RQ62, is used on the
radioactive waste system sump pump discharge valve. The
limit switch is located in the NW torus area at elevation
881 ft. of the reactor building.
(b) No type test documentation was available in the EQF to
demonstrate qualification of this model limit switch.
Qualification documentation contained in the EQDP for the
DTE6-2RQ62 limit switch was a qualification for a 40 year
service life plus 6 month post accident operability time by
engineering analysis only. The EQDP demonstrates that the
contacts on switch model DTE6-2RQ62 were similar to the
contacts of the BZR series switches, in meeting normal
operational test requirements only. However, the files did
not contain qualification documentation which demonstrates
similarity between the DTE6 and BZR switches by type test.
(c) The EQDP indicated that a scheduled surveillance and
maintenance program are not necessary in order to satisfy
the 40 year service life and 6 month post accident
requirements for reasons similar to model OP-N (see
paragraph 4.f(10)(b)). During its life the limit switch
mechanism should be periodically checked for its physical
position relative to the open or closed limits of the
valve, to verify that the plunger is still operative.
l
The above deficiencies (b) and (c) are considered an Open
Item (50-298/8628-12).
,
.
- _ _ _
!
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25
i
.
(12) EQDP 9, EQDP 9A and EQDP201, ASCO Solenoid Valves, Models
HVA-90-405-2A, WPHT8316E36, and NP-1.
(a) ASCO solenoid valve models HVA-90-405-2A and WPHT8316E36
'
are used on the control rod drive system.
Model HVA-90-405-2A solenoid valves are normally energized
'
and are deenergized upon receipt of an accident signal.
Model WPHT8316E36 are normally deenergized and are
energized upon receipt of an accident signal. The solenoid
valves are located in the south and southeast areas of the
reactor building at elevation 903 ft. ASCO solenoid
valves, Model NP-1 are currently scheduled to replace the
ASCO model WPHT8316E36. Model NP-1 are used for the
primary containment, residual heat removal system, standby
gas treatment system rad waste system, and the control rod
drive system. Model NP-1 valves must survive a LOCA and
have accident operation times ranging from one hour to six
months.
(b) The EQF, EQDP 9 (HVA-90-405-2A) file review by the NRC
inspection team disclosed that the post accident service
requirements in the file were not very well defined in that
there was some confusion as to whether these solenoid
valves were energized or deenergized following an accident.
The licensee is required to clear up confusing statements
contained in this EQDP.
(c) The EQF, EQDP 201 (NP-1), review by the NRC inspection team
disclosed a file deficiency in regard to the licensee's
methodology in his use of calculations to determine
accelerated thermal aging temperatures. The NRC inspection
team, using the same methodology calculated apparent
discrepant temperatures as high as 376.2*F and 408.2 F.
- The calculation methodology should be reviewed and
corrected by the licensee.
(d) The EQDP documentation regarding type testing showed the
solenoid disk softening at 295 F and it could not hold
pressure. As a result, the maximum operating pressure
differential was changed from 200 psig to 150 psig during
the type test. The licensee stated that this valve is
normally used with an air system pressure of 100 psig (125
psig maximum) in the CNS plant application. The NRC
concern here is that these derated valves should not be
used in systems capable of pressures higher than 125 psig.
An analysis is required in the EQDP to demonstrate that air
service to the NP-1 model solenoid valves cannot exceed
125 psig.
(e) The licensee should address the published ASCO temperature
vs coil life curve No. VE2926RY for the NP-1 solenoid coils
. _ - _ _ _ _ - _ _ _ .
..
26
listed in the EQDP. The service temperatures stated in the
EQDP are not on the curve and appear discrepant.
(f) The EQDP 201 (NP-1) review by the NRC inspection team
disclosed a file deficiency with regard to the functional
type testing documentation in the file, where the liquid
tight flexible conduit failed during the type test,
allowing the spray solution to enter the solenoid and
degrade the coil insulation. As a result of this conduit
failure it was never determined during the type functional
testing if the coils were operable. The test coil
documentation in the file showed that the coils were
allowed to dry out for seven c'ays at room temperature at
which time they were found to be operable. After a total
of 89 days drying time the coils passed the insulation
resistance and hypot tests, and it was concluded that the
coils were qualified. This documentation in the EQDP fails
to support qualification, and other test results to qualify
the NP-1 solenoid coils should be placed in the file.
The above EQDP 9 and 201 deficiencies (b), (c), (d), (e), and
(f) above are considered an Open Item (50-298/8628-14).
(13) EQDP 77, ASCO Temperature Switches, Models SA11AR and QJ11A4R
(a) ASCO temperature switch models, SA11AR and QJ11A4R, are
used in the Standby Gas Treatment System (SGTS) located in
the SGT room of the reactor building at elevation 976 ft.
(b) The NRC inspection team reviewed EQDP 77 and determined
that the EQF had no documentation to support that the
temperature switch had a qualified life of 40 years with a
switch replacement every 9.68 years.
!
!
(c) Clarification of the EQDP is needed as to the type of
i fluid-fill used so that its resistance to radiation
j exposure can be evaluated.
l
(d) The EQPD documented that during type testing of the switch, I
a failure during the vibration / wear aging test occurred.
This documented failure was accepted by NPPD on the basis
that installed units would not experience the same type of
rapid cycling, and consequent vibration failure. An
analysis to justify these effects is required in the EQDP.
The above documentation deficiencies (b), (c), and (d) are
considered an Open Item (50-298/8628-15).
. .. .. . .
.
_ _ _ _
.
27~ .
,
,
s
(14) EJDP Sb -Target Rock Solenoid Valve, Model 1/2-SMS-A-01-1
(a) Target, Rock solenoid valve, model11/2-SMS-A-01-1, is used
on theimain steamline as a pressure relief valve. The
valve is located in the east section of the drywell at
i elevation 921'ft. This model has an installed life of 5.8
, years', and must operate up to 6 months following a LOCA.
_
!
(b) Review of EQDP 51 by the NRC inspection team identified
_
,
cocumentation deficiencies. The documents necessary,
referenced in the EQF, to support the test results were not
.found in the file.
(c) The EQDP called for a 5.8 year replacement interval for
BUNA-N (nitrile rubber) raterial and inconsistently stated
that the material has an expected life of 1.451-years.
, (d) The EQDP did not address installation and replacement
I ,e procedures, nor qualification of replacement kits.
,
The above documentation deficiencies (b), (c), and (d) are
, considered an Open Item (50-298/8628-17).
f
(15) EQDP 228, Static-0-Ring Pressure Switches, Model STA, 9TA, and
,
12TA
f ,
Static-0-Ring models 9TA, STA and 12TA pressure switches are
/ t' located in the reactor building. An adequate qualification for
,
'
their required safety-related functions were demonstrated by
4
this EQDP EQF.
Static-0-Ring pressure switches which are presently installed at
Cooper are supported by EQDP 37 and 222. These packages qualify
the installed pressure switches to the D0R guidelines and do not
require the venting of the switch housings. The replacement
,
',
Static-0-Ring pressure switches are qualified by EQDP 228 to the
',,
requirements of NUREG-0588, Category I. This requires the
- 1 switch housings to be vented. At the time of the inspection the
licensee had not determined how the new replacement switches
, will be vented and installed.
,,
'
The NRC inspection team identified a file deficiency in that the
-
principal qualification test report was not referenced in the
EQDP. The EQDP, however, referenced a follow up to the
!
qualification test report which in itself was inadequate to
,
j qualify the equipment. The licensee in discussions with the NRC
r inspection team used both test reports to demonstrate
qualification of this equipment.
i
?
i
_ _ __ . _ _ , . - - _ _
, -- , . , _ __ -
28
The above CNS modifications for venting of replacement pressure
switch housings, and the above EQDP file deficiency in the EQF
are considered an Open Item (50-298/8628-18).
(16) EQDP 12, Barksdale Pressure Switch, Models B2T-M12SS and
Barksdale models B2T-M12SS and B2T-A12SS pressure switches are
located in the reactor building. An adequate ~ qualification for
their intended safety-related functions was demonstrated by this
EQDP and the EQF.
The NRC inspection team identified an auditability problem with
EQDP 12 in that the file qualified the same type of equipment to
different environments. The EQDP was established to qualify all
of the equipment types contained in the file to the most severe
environmental parameters, with the exception of pressure. The
EQDP did not identify actual pressure conditions for which this
equipment was to be qualified. Discussions with the licensee
demonstrated to the NRC inspection team that the equipment was
qualified for its pressure environment application as well.
EQDP 12 was not auditable however, to the extent that this
documentation was not readily understandable and traceable to
permit independent verification of conclusions. This item is
considered an Open Item (50-298/8628-19).
(17) EQDP 81, Rosemount Pressure / Level Transmitters, Model 1153
Series B
The qualification criteria for this file is 10 CFR 50.49,
NUREG-0588, Category I. The instruments are located outside
containment and are used to measure flow, pressure, differential
pressure, and level. The file references Rosemount test report
108025.
The NRC inspection team identified a generic concern with
respect to synergistic effects being too general as documented
in the EQDP. No reference was made to the specific materials
used in the equipment when identifying synergisms.
Identification of synergisms also were not referenced especially
those reported by industry. When synergisms are identified, a
discussion of the effect this has on the testing should be
documented in the EQF. As an example, this file identifies
sequential synergisms as existing, but no reference is made to
the statements in the test report which indicate that no
sequential effects were observed in the test series. This
generic inadequacy of the EQF EQDP's is considered an Open
Item (50-298/8628-20).
4
- ~ ~ - - .m., ,
29
(18) EQDP 226, Rosemount 1153 08/1159 DP Transmitters with Remote
Seal Systems
The qualification criteria for this file is 10 CFR 50.49,
NUREG-0588, Category I. The equipment is used for remote level
indication of sumps outside containment. The test report
referenced in the tile is the Rosemount test report D8300151.
The test report found in EQDP 226 indicated that capillary fill
fluid (water) when heated to boiling in thermal environments
causes erroneous instrument readings. Recommendations in the
test report are made to mitigate this problem. The EQF does not
address this problem even though temperatures are as high 283 F
15 F at the transmitters environmental location in the plant.
During the inspection however, the CNS staff provided an
existing analysis which showed that the capillaries could be
insulated to keep the temperature in an acceptable range. The
additional anaiysis and calculations are to be added to the EQF
to support qualification of the Rosemount 1140308/1159 DP
Transmitters with remote seal systems. This inadequacy of the
EQF is considered an Open Item (50-298/8628-21).
(19) EQDP 318, Limitorque Motor Operators, Models SMB-00 and SMB-2
Limitorque valve operator, SMB-00, Tag No. PC-MO-231MV, is
located in the reactor building and is used in the primary
containment system. Valve operator, SMB-2, Tag No. CS-M0-M0128
is located in the heat exchanger room and is used in the core
spray system. Documentation supporting qualification of these
valve operators for the environmental conditions at CNS is
contained in Limitorque test report B0003.
The NRC inspection team identified a documentation deficiency
during this file review regarding the EQ data log which
referenced test report F-C3271 as supporting qualification of
the above valve operators. The F-C3271 test profile does not
envelope the accident profile. Limitorque test report B0003,
referenced in EQDP 31B, however, supports the qualificatior of
the above valves. This deficiency is considered an Open Item
(50-298/8628-22).
(20) EQDP 219, Reliance Motor, Model No. Class H, Type RH
EQDP 219 was reviewed by the NRC inspection team. The EQDP
presents the basis of qualification for Reliance AC motors,
model number class H, type RH, which are installed in the
standby gas treatment system at CNS. The EQDP presented a
description of both normal and accident environment to which the
motors were required to be qualified and a description of the
functional requirements for both environments. Both motors
documented in this EQDP were replaced in 1984 and 1985,
__
/
,
30
therefore the motors presently installed were qualified to the
provisions of 10 CFR 50.49. The basis of qualification was
Reliance Electric Company Summary Report NUC-9, " Nuclear Power
Motor Systems, Type Test Support Analysis, Random Wound Motors,"
dated July 1, 1978. The basis of qualification of the motors
was documented by referencing and discussing applicable test
reports in the EQDP.
Serial numbers of the motors were not included in the EQDP;
therefore traceability between the documentation and installed
equipment was not possible. The absence of adequate
. documentation in the EQDP is identified an as Open Item
(50-298/8628-25).
(21) EQDP 23, General Electric ECCS Motor, Model No's 5K6346XC74A and
SK6346X83A
The qualification criteria for this file is the 00R Guidelines.
The EQDP presented a description of both normal and accident ,
environments to which the motor was required to be qualified and
a description of the functional requirements for both
environments. The ECCS motors were evaluated by the licensee in
accordance with Enclosure 4 of IEB 79-018 (DOR Guidelines). The I
basis of qualification was GE Report NEDM-10672, " Environmental
Qualification Test of Vertical Induction Motor for ECCS Service
in Nuclear Power Plants," dated August 1972 and GE Design
Report 22A4722, "ECCS Motor Qualification Program," dated
January 1977. Models tested in the above reports were
SK6339XC94A and 5K6339XC166A. Similarity between the models
tested and those installed at CNS was established by GE Report
NEDC 30067, " Comparison of RHR and Core Spray Pump Motor Data
with Qualification Test Data for Similar Motors," dated
February 1983. Based upon results of the qualification analysis
tne licensee concluded that the motors are qualified to perform
their safety function during a 40 year life.
The equipment was well described except serial numbers of the
motors were not included in the EQDP and therefore traceability
between the documentation and installed equipment was not
possible. This documentation deficiency in the EQDP is
identified as an Open Item (50-298/8628-26).
g. IE Information Notices and Bulletins
The NRC inspection team evaluated the licensee's activities related
to the review of EQ related IE Information Notices (IENs) and IE
Bulletins (IEBs). The inspector's review included examination of the
licensee's procedures and EQ documentation files relative to
applicable IENs and IEBs. NPPD does not have a formal dedicated
procedure for tracking and addressing NRC IENs and IEBs, however,
those IENs and IEBs that may potentially impact the qualification of
31
electrical equipment, as outlined in 10 CFR 50.49, are monitored by
specific CNS EQ program procedures. (See Section 4.b). NPPD does
track issues of potential irrpact via the INP0 nuclear network,
industry standards, and news letters.
NPPD's response and actions with regard to IEN 86-03 " Potential
Deficiencies in Environmental Qualification of Limitorque Motor Valve
Operator Wiring," January 14, 1986, were documented in letters to the
NRC Region IV dated July 21, August 8, and September 8, 1986. NPPD
had ongoing inspections of safety-related EQ Limitorque operators
located inside the drywell prior to the issuance of IEN 86-03. The
NPPD inspections looked at motor insulation, wiring, terminal blocks,
T-drains, torque switch settings, etc., with no deficiencies
identified. Following the issuance of IEN 86-03, NPPD issued a
special test procedure (STP) to inspect the balance of Limitorque
MOVs subject to the requirements of 10 CFR 50.49, primarily outside
the drywell. During this CNS walkdown inspection effort,
unidentified internal wiring was detected in 25 M0Vs located outside
the drywell in the HPCI, REC, RHR, MS, RCIC, and RWCW systems. NPPD
immediately replaced the undocumented wire with known qualified
Rockbestos Firewall SIS wire, and submitted an equipment operational
analysis (E0A) for each of these Limitorque MOVs, to NRC Region IV
(letter dated August 8, 1986). Attachment B to this E0A, correlated
like internal wiring removed from similar equipment at CNS. NPPD
determined that these 25 MOVs had similar interconnecting wire types
of (1) ITT Royal SIS XLPE; (2) polyvinylchloride (PVC) insulated; (3)
Raychem Flamtrol or Rockbestos Firewall; and (4) glass braided butyl
rubber (polybutadiene).
The NRC inspection team reviewed the E0As Attachment B analyses, and
identified deficiencies with one wire type; glass braided butyl
rubber insulated, used internal to these motor operators. The
documented analysis for glass braided butyl rubber insulation did not
fully support qualification, in that the HELB accident conditions
outside the drywell were not considered in the supporting
calculations of the analysis.
Also the NRC inspection team reviewed the timeliness of licensee
actions to correct the above deficient conditions in the Limitorque
valve operators. The NRC inspection team identified the following
'
additional deficiencies during this inspection:
i
(1) The qualified life of internal wiring removed and tested had not
been documented.
(2) Licensee internal wire samples removed from five operators
inside containment and four outside containment were examined by
the NRC inspection team, with the following results:
(a) All types of wires which had been removed were not
addressed in the E0A (attachment B) of August 8, 1986.
_ ___
_ _ - _ _ _ - .
32
(b) All types of wires which had been removed had not been
tested.
(c) Taped splices (identified as Scotch by the licensee) and
unidentified blind barrel splices had no documentation to
show qualification.
The documentation deficiencies identified above and the failure of
NPPD to demonstrate similarity between the tested and installed
operating configuration, with respect to the internal wiring on
Limitorque MOVs is considered a Potential Enforcement / Unresolved Item
(50-298/8628-08).
h. Plant Physical Inspection
The NRC inspection team, walked down and physically inspected
approximately 39 components. The inspection team examined attributes
and characteristics such as mounting configuration, orientation,
interfaces, model numbers, ambient environment, and physical
condition.
(1) Limitorque Motor Operators, Plant ID HPCI-M0-020, PC-MO-306 MV
MS-M0 078, and RHR-MO-M027A
The NRC inspection team performed a walkdown inspection of the
Limitorque valve operators located inside and outside the
drywell. In addition to ensuring that installed operators were
identical to the operators described in EQDP 31A, the inspection
scope included provisions of IEN 83-72 and IEN 86-03. The
following deficiencies were identified:
(a) Operators HPCI-M0-020, PC-M0-306MV, and MS-M0-078 had
Okonite taped splices used in applications for splicing
braided jacket motor leads to power leads. The Okonite
splice configuration had no documentation to support
qualification over a braided jacket. The NRC inspection
team's concern is the possibility that the braid under the
splice may become saturated with water and potentially
short circuit to the switch compartment housing, or short
between leads of the power cable, preventing operation of
the valve. Okonite motor lead splices, EQDP No. 31A (B0003
qualification series), did not adequately establish
qualification because of failure to demonstrate similarity
between the splice type tested and those installed in motor
operators installed in the plant. No evidence was
contained in the EQF which could demonstrate qualification
of Okonite splice installations over braided jacket Totor
leads. The EQDP in the EQF only demonstrates Okoaite motor
lead splice testing over unjacketed insulated cable. This l
item is considered a Potential Enforcement / Unresolved
Item (50-298/8628-09).
_.
33
(b) Operator RHR-M0-M027A (SMB-4) had a broken jumper wire.
The wire connects terminal 45 of the torque switch to the
limit switch. This item is considered an Open
Item (50-298/8628-23).
(2) Limitorque Motor Operators, Plant ID No's RHR-M0-M025B and
REC-M0-1329MV
Limitorque Valve Operator SMB-3, Tag No. RHR-M0-M0258, is
located in the injection valve room and is used in the residual
!
heat removal system. The documentation supporting qualification
of these valve operators s contained in EQDP 31G, and
i
Limitorque Test Reports 80009 and B0003. The documentation
review was adequate to support qualification of these operators.
A piant walkdown was performed on valve operator RHR-M0-M025B.
The grease relief valve still had the shipping cap installed.
Valve operator, SMB-00, Tag No. REC-M0-1329MV is located in the
reactor building and is used in the reactor equipment cooling
system. Documentation supporting qualification of this valve
operator for the environmental conditions at CNS is contained in
Limitorque Test Reports B0058 and 6000376. The documentation
was found to be adequate to support qualification of these
operators. A plant walkdown was performed on valve operator
REC-M0-1329MV. This valve operator still had the grease relief
shipping cap installed.
Installation of grease relief valve shipping caps on valve
operators RHR-M0-M025B and REC-M0-1329 MV indicates a generic
problem with the removal of shipping caps and is considered an
Open Item (50-298/8628-24),
(3) General Electric ECCS Motors, Model 5K6346XC74A and 5K6346XC83A,
Plant 10 CS-MOT-CSP 1B and RHR-MOT-RHRP1A
The NRC inspection team performed a walkdown inspection of the
GE ECCS motors to verify compliance with the provisions of
EQDP 23 and for housekeeping, maintenance, and workmanship
practices. It was not possible to establish traceability
through equipment serial numbers; however, the equipment model
numbers were ideatical to those in the EQF. The following
additional items were identified by the NRC inspection team
during the walkdown:
(a) CS-MOT-CSPIB
Grills protecting motor openings have slipped
permitting large unprotected open areas.
The ledge created by the motor flange, just below the
lower motor air inlets, was covered with fuzz, dust
. _.
. _ . .
34
and dirt. The ledge also contained a piece of
wadded-up tape; another contained a piece of he
protective grill which had been cut or broken.
One heater lead was bearing hard against a sharp edge
on the motor case, causing the jacket to be badly
- dented. It could not be determined if the jacket or
l insulator had been permanently damaged.
Heater leads were in contact with the heater and the
jacket appeared to be damaged. Condition of the
wiring insulation could not be determined.
(b) RHR-MOT-RHRP1A
The ledge created by the motor flange, just below the
lower motor air inlets, was dirty, and one screw
(approximately 10/32 X 1") was lying on the ledge
where it could possibly be pulled into the motor
inlet.
Items (a) and (b) above are considered an Open
Item (50-298/8628-27).
~
(4) ASCO Solenoid Valves, Models HVA-90-405-2A and WPHT-8316E-36:
l Plant 10 No's CRD-50V-50117 (06-19), CRO-S0V-S0118 (10-47),
and CRD-50V-S0140A
t
(a) The NRC walkdown inspection identified the CRD-50V-S0117
(06-19) and CRD-50V-S0118 (10-47) solenoid pigtails
connected to the field wiring using crimp type butt splices
covered with black electrical tape. The butt splices were
not identified in the EQF and could not be established as
'
qualified for their application. The licensee's positien
was that the splices were non-safety related and that this
was acceptable in that the solenoids deenergized during an
c accident. A determination of operability regarding these
components is required in the EQF, EQDP 9, if these
ASCO HVA solenoids, being normally energized during their
operational service life and deenergized during the DBA
accident are classified as EQ components. If however,
these solenoids are classified as Non-EQ components, they
should be removed from the MEL.
(b) Also the NRC walkdown inspection identified CRO-50V-50140A
solenoid pigtails connected to the field wiring with
in-line bolt splices covered with black electrical tape.
The ASCO WPHT solenoid in-line splices were not identified
in the EQF and could not be established as qualified for
! their application. Since these valves and their
replacements (ASCO NP-1) must energize following the DBA
1
_, _ . _ _ _ . __ _ _ . , _
_ - . __ _ _ _ . _ _ -
_ - _ . _ . , . . . .- -. - . _ _ . - _- .-- - - .
I
)
35
.
and post DBA, the field splice should be a qualified
1- splice. ASCO solenoid valves, model NP-1, are currently
- scheduled to replace 711 WPHT8316E36 models in EQ
i applications. The licensee has proposed thac the existing
i conduit system is to be modified to incorporate the NP-1
!
'
type replacements and nuclear field splice configurations
documented in EQDP 201. The licensee will address the
field splice to field cable applications in EQDP 201 and
l
determine their suitabilility for application.
l The above items (a) and (b) are considered an Open item
l (05-298/8628-16).
!
i (5) Microswitch Limit Switches, Models OP-N and DTE6-2RQ62 Plant ID
j No's HPCI-LMS, A070(0/C), HPCI-LMS-A071 (0/C), RW-LMS-732-AV,
i and RW-LMS-733-AV
'
The above model OP-N and DTE6-2RQS2 limit switches were examined
during the walkdown of the plant. They are located in the HPCI
room of the Reactor Building at elevation 859, and in the NW
torus at elevation 881.
, The switches were mounted horizontally on flat steel plates.
- The licensee, for the purpose of the inspection, had removed the
i switch cover plates exposing the internal structure of the limit
l switches. Limit switch HPCI-IMS-A071 (0) had a torn rubber boot
indicating a need for preventative maintenance. The rubber boot
'
, protects the area where the switch's actuation plunger enters ;
the switch body. *
!
Also on Plant ID No. HPCI-IMS-A070 (0/C) the field termination
i'
box No. TB-220, ESS DIV II containing electrical connectors was
opened. The raised ends of the ring tongue type terminations
appeared to have been flattened indicating questionable handling
i
practices. Plant ID No's RW-IMS-732A and RW-IMS-733-AV also had
- the raised tips of the ring tongue type terminations flattened.
j The above observations by the NRC inspection team are considered
l an Open Item (50-298/8628-13).
!
4 5. Exit Interview
j An exit interview was conducted on November 7, 1986, with NPPD in which
- the scope of the inspection and findings were summarized.
l
1
_ - _ _ _ _ _ _ _ _ _ _ _ _ - _ . - _ - _ _ . . - . . . _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ -