IR 05000206/1986045

Insp Repts 50-206/86-45,50-361/86-34 & 50-362/86-33 on 861115-1220.Violation Noted:Failure to Comply W/Station Procedures for Calibr of Radiation Monitoring Equipment

ML20212J119
Person / Time
Site:	San Onofre
Issue date:	01/09/1987
From:	Huey F, Johnson P, Stewart J, Tang R, Tatum J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212H986	List: IR 05000206/1986045 ML20212H979 ML20212J063
References
50-206-86-45, 50-361-86-34, 50-362-86-33, NUDOCS 8701280090
Download: ML20212J119 (17)

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U.S. NUCLEAR REGULATORY COMISSION REGION V 1

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Report No /86-45, 50-361/86-34, 50-362/86-33 Docket No :206, 50-361, 50-362 License No DPR-13, NPF-10, NPF-15 Licensee: Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 92770 Facility Name:: San Onofre Units 1, 2 and 3

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Inspection at: San Onofre, San Clemente, California Inspection. conducted: vember'15 through December 20, 1986

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Inspectors:dcF~ '

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! ey, Senior Resident Date Signed In , U its 1, 2 and 3

[7 kJ. ewart, Resident. Inspector Date Signed

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.h tum, esident Inspector Date Signed

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hcR.C. (ng, Resident Inspector Date Signed (thro D No ember 28, 1986) ,

Approved By:

P. H 6M ohnson, Chief YY{7 Date Signed

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) Reac Projects Section 3 I

Inspection Summary Inspection on November 15 through Deceros - 20 ,186 (Report No /86-45, 50-361/86-34, 50-362/86-313 ~~' ~

Areas Inspected: Routine resident inspection of Units 1, 2 and 3 Operations Program including the following areas: operational safety verification, evaluation of plrnt trips and events, monthly surveillance activities, monthly maintenance activities, independent inspection, licensee events report review, and' follow-up of previously identified items. Inspection procedures 30703, 35751,~36700, 37701, 61726, 62703, 64704, 71707, 71710, 72700, 92700, 92701 and 93702 were covere PDR ADOCK 05000206 G PDR

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i Results': Of the areas examined, one violation was identified involving .a

. failure-to comply with' station procedures for calibration of radiation monitoring equipment (paragraph 9.b).

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. DETAI LS -- Persons Contacted Southern California Edison Company

_ H. Ray, Vice President, Site Manager

• Moody, Deputy Site Manager G. Morgan, Station Manager

• M. Wharton, Deputy Station Manager

• D. Schone, Quality Assurance Manager D. Stonecipher, Quality Control Manager R. Krieger, Operations Manager

.D. Shull, Maintenance Manager J. Reilly, Technical Manager P. Knapp, Health Physics Manager

• B. Zint1, Compliance Manager

• D. Peacor, Emergency Preparedness Manager P. Eller, Security Manager W. Marsh, Operations Superintendent, Units 2/3 J. Reeder, Operations Superintendent, Unit 1 V.' Fisher, Assistant Operations Superintendent, Units 2/3

. B.-Joyce, Maintenance Manager, Units 2/3 H. Merten, Maintenance Manager, Unit 1

• T. Mackey, Compliance Supervisor C. Couser, Compliance Engineer San Diego Gas & Electric Company R. Erickson, San Diego Gas and Electric

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• Denotes those attending the exit meeting on December 19, 1986.

The. inspectors also contacted other licensee employees during the course of the inspectio'n, including operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health physics engineers and technician , Operational Safety Verification

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The inspectors performed several plant tours and verified the operability of selected emergency systems, reviewed the Tag Out log and verified proper return to service of affected components. Particular attention was given to housekeeping, examination for potential fire hazards, fluid leaks, excessive vibration, and verification that maintenance requests had been initiated for equipment in need of maintenanc Noble Gas Problems (Units 2/3)

During this inspection period, the inspector noted an increased frequency of detection of noble gas activity in the Unit 2 and 3

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'Radwaste. Building. 'The inspector discussed.thi~s. concern with the^

Llicensee.and the licensee feelssthat the increased fre'quency of;

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noble gas detection is due'to :installationVof: portal frisking booths, -

Ethat are more sensitive than previously:used hand held frisker The inspector noted that theilicensee hasynot, implemented any1 convenient program for trending noble' gas related problems and the

.results of investigation and correction of those problems. Such a

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. program may be useful-for evaluating the effectiveness of 'correcti.ve actions and assessing the adequacy"of the material condition of the m

waste processing system.~ The licensee agreed to trend noble gas-~

, detection over the next quarter, and to evaluate.the usefullness of c this data as an indicator of plant condition'.- This is an open item

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-(50-361/86-34-01).'

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- Containment Tour (Unit 2)

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-Prior' to Unit 2 return to service on December 14, 1986, the-4 , ; . inspector toured containment to assess the condition of equipment inside containme'nt and to verify proper penetration isolation valve >

alignment. -Housekeeping inside Unit 2 containment appeared to be

excellent, and' plant material condition appeared to be good. The

. inspector n'oted two vent valves that were leaking and a 2" check

" valve;that had a body to bonnet leak. Ther,e items were pointed out

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-to the licensee so they'could be evaluate No violations or deviations were note .- Evaluation of Plant Trips and Events Plant Tam)ering On November-29, 1986 (Unit 1) and December 2,1986 ( Jnit 3)

At 2:00 p.m. on November 29, 1986, a Unit 1 plant operator determined that the red and green indicating light' lenses had been reversed for five ventilation fan switches in the 4KV switchgear roo Inspection also determined that similar. indicating light lenses had been reversed for one diesel generator output breake The operator who identified the anomalies had been in the room at'

8:00 a.m. on the same day and knew that the lenses had been correctly positioned at that tim An immediate inspection of the 4KV and 480 volt switchgear rooms and both diesel generator rooms identified no other mischief, and determined that no manipulation of plant components had occurre An investigation was initiated by corporate security investigators, including interviews of 25 individuals who had been logged into the area (by the security computer) during'the time period of concern. The Senior Resident Inspector also conducted independent inspections of other important plant areas, including battery room On December 2, 1986, the licensee determined that unauthorized manipulation of ten non-safety related circuit breakers-had occurred in Unit 3. The time period during which the manipulations occurred I was between 7:15 and 8:00 a.m. on December 2, based on a related annunciator received in the Control Room. The ten circuit breakers

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c ' ' were' associated'wiih oil lift pumps and cooling water throttle-valves-related to reactor coolant pumps:(RCPs); ventilation fans;

, space. heaters for electric motors; the in-core probe drive motor;

, .and sump pumps in the fuel' handing buildin The11icensee's J . security computer identified 38 individuals who had access to the

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Unit 3 area during_the. time period of concern. The license investigationLwas expanded to include ~ interviews of these additional

, persons, particularly-three individuals who were common to ~both

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event'se The licensee, initiated the.following actions to assure-appropriate levels.of safety, s~ecurity, and plant system integrity u,

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o The FBI.was requested to aid in the investigatio ~

, o Comprehensive component and system verification inspecti_ons were conducted for all three units to determine whether othe tampering has occurred. No further.. indications of apparent tampering were identifie ,

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o The 60 individuals who had access to the affected areas at the estimated times:of apparent tampering had their s'ecurity badges-

? withdrawn to prevent their entry into' protected and vital areas

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un til investigations or other appropriate actions were complete S As;of the close of the inspection period,'the licensee and FBI investigations of these events were continuing; however, progress-to

date had confirmed that most.of the above mentioned individuals were

not involved and their badges had been-returned. Further results e from the investigation of the remaining few involved individuals'

% will be included in a subsequent report following completion of the investigation No violation's'or,devi,ations were identifie D Reactor Trip On December 10, 1986'(Onit 2) 3

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Vn'it 2 tripped from 93% reactor power at 1037.on; December- 10, 1986, due!to operator error during transfer of powerito the turbine plant non-1E uninterruptable power suppl The power supply transfer was being performed in conjunction with troubleshooting of the inverte Loss of power to'the turbine control circuits and steam bypass control system.c'aused a turbine trip and resulted in lockout'of th steam bypass control system. The. turbine trip and malfunction of m the steam bypass system resulted in a reactor trip and lifting of

. main steam safety valve The licensee's investigation of the event concluded that operator

. informality and failure to comply with station procedures were the

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primary contributors of the tri In particular:

,(1) The plant equipment operator (PE0) who performed the power

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supply ~ transfer performed additional actions beyond those which

--he had been authorized to perform by the control room operator

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-(CO). Specifically, the PE0 was only authorized to transfer 1 the power-supply. He was not authorized to secure power to the

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inverter, which he did on his own when asked by the maintenance e technician who was performing trouble shootin '

L ~(2) The C0 did not properly review the planned evolution with the

. PE0 pri,or to performanc (3)' The PE0 did not have the applicable procedure with him when performing the transfer and he omitted a step which would'have ,

prevented the power transient which resulted in the tri ~

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(4) The C0 did not inform the control room supervisor (CRS) of the-

. planned power supply transfe .The licensee has implemented actions to re-emphasize procedure compliance and operations formality with cognizant plant per.sonne The licensee diagnosed and corrected the malfunction of the steam bypass control system. The plant was returned to power. operation on December 14, 198 Since the above concerns were identified and appropriate correctiv '

actions were initiated by the licensee, no enforcement action was take This issue is discussed further in the letter which forwards this inspection repor . Monthly Surveillance Activities Unit 1 The inspector observed a surveillance test of the electric auxiliary feedwater pump following identification of discolored bearing lubricating oil. The test was properly performed and verified satisfactory pump and bearing" operation. The licensee specifically

. monitored the pump bearings for vibration and temperature, which were both noted to be nominal. The licensee was having the oil

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analyzed and was to address further actions based on the results of the analysis. In addition,.the licensee was making preparations to

, disassemble,and inspect the pump bearing Unit 2 Theinspectorobservedthefollowingsurveillance:

S023-3-3.25 Once-A-Shift Surveillance (Modes 1-4) ' Unit;3 -

The inspector observed the following surveillance:

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S023-II-1.1.1 -Surveillance Requirement, Reactor Plant Protection System, Channel A, Channel Functional Test (31 day interval)

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s No violations'or-deviations were note .

Monthly Maintenance Activities

~ Saltwater' Cooling Pipe Repair'(Unit 1)

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Thesinspector observed licensee activities-' associated with preparations ~to repair. the damaged rubber liner in the saltwater cooling supply to the component cooling water heat exchangers. The licensee performed an extensive) safety evaluation of the

~ :> capabilities for ensuring adequate plant cooling under normal'and plant accident conditions during the' repair sequence. The licensee

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convened the Onsite Review Committee to review the specific _ .

? preparations for repair. The Committee reviewed several selec_ted-options for performing the repair, the plant modes under which the .

' repair could be accomplished and the' safety consequences for each option. The licensee technical organization did an excellent job of-evaluating and documenting the basis ~ for performing the saltwater ,

cooling pipe repair.. Station management implemented a conservative '

repair approach and the repair was successfully accomplished the weekend of December-13, 198 Leakage of Reactor Coolant into the Post Accident Sampling

' System (PASS) Pit (Unit 1)

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The inspector reviewed the maintenance activity associated with

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leakage of reactor coolant into the PASS pit.~ Maintenance order S, 86013047001 was written to repair valve CV-2027, which was< damaged during cleaning and inspection of the PASS inlet wye: strainer

1. .(SI-PAS-YS-2028). Plant operators initiated a work authorization permission (1-8603129) to provide fluid system isolation boundaries for the maintenance effort. The leak into the PASS pit occurred during a reactor coolant sampling evolution when valves CV-2023 and CV-2024' leaked by, allowing reactor coolant to leak out of disassembled component fittings. The inspector noted the~following with regard to the above problem:

(1) The work authorization did not specifically require valves CV-2023 and CV-2026 to be closed in order to ensure double valve isolation during a coolant sampling evolutio (2) The work authorization did not ensure isolation valve integrity under pressurized. conditions prior'to releasing the maintenance work activity to procee ' TheJinspector. reviewed the above comments with the unit operating superintendent who agreed to re-emphasize the importance of ensuring maintenance boundary integrity under actual planned working-

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conditions, Repairs Associated with Valve 1301-MU-229 (Unit 2)

The inspector observed repair effort on valve 1301-MU-229, which is t a 1/2" blowdown-valve for steam trap F-209. Steam trap F-209

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removes moisture from the steam generator code' safety steam leads and steam supply piping to the auxiliary feedwater pump' turbin Valve MU-229 had developed a body-to-bonnet steam leak and the licensee planned to replace the valve oy cutting it out of the system. After the' pipe upstream of valve MU-229 was cut and the-pressure boundary was penetrated,' steam blew out of the 1/2" IPS piping where the cut was made, due to excessive seat leakage past isolation valves. Since the valve could not be isolated, the licensee initiated action to patch the steam trap blowdown pipe until permanent: repairs could be made. Similar to the instance described above, involving maintenance on the Unit 1 PASS system,

-the inspector noted that the valve clearance did not call for opening MU-229 prior to starting work to verify that the valve was isolated by observing the blowdown piping for the presence of stea Atmospheric Dump' Valve 2HV-8419 (Unit 2)

While preparing to return Unit 2 to service following the reactor

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trip on December 11, 1986, the licensee discovered that atmospheric dump valve 2HV-8419 was not working._ The inspector observed the troubleshooting effort involved with continuity checking of'the valve electrical circuits. Licensee troubleshooting was properly controlled and performe Boric Acid Makeup-(BAMU) Pump 3MP-175 Heat Trace Circuit (Unit 3)

The inspector observed the maintenance activity to restore boric acid heat trace circuits 10P&S on panel 3L266-1. The leads were lifted in preparation to perform preventive maintenance on boric acid makeup pump 3MP-175. The activity was satisfactorily conducted in accordance with M0 #8611147 No violations or deviations were note . Engineered Safety Features Walkdown (Unit 2)

During this inspection period, the inspector walked down the Unit 2 saltwater cooling (SWC) system and component cooling water (CCW) syste The systems were found to be aligned as required by the Technical Specifications and station procedures. However, the inspector observed the following deficiencies: Several valves in these systems are no longer locked in position as a result of a revision to the administrative locking requirement These changes were not included on the P& id The material condition of certain components in the SWC system appeared to be degrade Specifically, fasteners associated with the CCW heat exchangers were severely rusted, one of the air baffles on SWC pump 2P-112 was bent out of shape and the air filters for the

motor air intake were not properly installed or secured and the pressure regulator for 2HV-6200 was not regulating properly.

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.# . . 7 The valves associated with reverse SWC flow were not properly

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labelled.- CCW flow indicators 2F1-6346 and 2F1-6262 were both off scale at greater than 2500 gpm. These are associated with containment

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emergency coolers 2E-400 and 2E-40 The CCW pipe in 2P-025 pump room near 2HV-6218 was improperly labelled as "CCW Train B" instead of "Non-Critical Loop." The oil monitoring sheet for CCW pump 2P025 indicated bearing oil leaks on November 28 and December 1 The leak on November 28 was described as "large", however the inspector was not able to determins if this condition had been evaluated by cognizant technical personnei. The inspector noted that this concern is similar to that described in report 50-206/86-43, associated with the Unit 1 main feedwater pump The licensee stated that the. inspector's comments would be evaluated and corrective actions taken as appropriat No violations or deviations were note . Independent Inspection Storage of Combustible Materials in Safety Related Areas During thi inspection period, the inspector noted that quantities of combustible materials were being stored in the tool decontamination room in the Unit 3 penetration building on the 30'

elevation (Fire Area 3-FH-30-127). The combustible materials included approximately twenty 12-ounce aerosol spray cans with flammable contents, an inventory of health physics protective clothing, cardboard boxes, respirator materials, paper tape and

. paper towels, rolls of plastic sheeting materials and rolls of yellow polyethylene bags. The operating licenses for Units 1, 2 and 3 currently prohibit the storage of combustible materials in safety related areas. The tool decontamination room is in a safety related area (the 30' penetration area contains piping and valves for Train B of the component cooling water system and ductwork common to Trains A and B of the Fuel Handling Building HVAC). The Updated Fire Hazards Analysis states that there is no fire loading in this room, and states that the maximum permissible fire loading is 160,000 BTU /sq. ft. The inspector examined other areas in Units 1, 2 and 3 and found additional examples where combustible materials were being stored in safety related areas. These included the following:

(1) Unit 1 Diesel Generator Building, South End (20' 6"), Fire Zone 1-DG-20-18: One 1 gallon container of oil, several polyethylene bottles of fuel oil samples and 5 boxes of air filters were stored in the roo . - -

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(2) Auxiliary Building (Control Area) Units' 2 and 3 (70'. O'!), . Fire '

Zone 2-AC-70-64A:'- Five'5 gallon cans of waste oil and two-

5 gallon cans of flammable materials were being store ,

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(3)? Auxiliary ~Buildingl(Radwaste Area) Units 2 and'3 (37' 0"), Fire Zone 2-AR-37-102A: 'A storage area was established in the i vicinity of~ Fire Zone 2-AR-9-90 which contained two~ flammable liquids 1ockers, several 5 gallon cans of waste oil, several

'5 gallon cans <of flammable coating materials,.several compressed gas cylinders and some cardboar (4) Unit 2 Containment Penetr$ tion Building (45' 0"), Fire Zone 2-PE-45-3A: A flammable ~ storage locker was installed at the south wall next to Train A radiation monitoring circuit (5) Unit 2 Fuel Handling Building (30' 0"), Fire Zone 2-FH-30-127:

Miscellaneous combustible materials, including several' boxes of contaminated materials, were being store (6) Auxiliary Building (Radwaste Area) Units 2 and 3 (9' 0"), Fire

. Zone 2-AR-9-76: Three flammable liquids lockers were located near the Unit 3 penetration area at the east wal (7) Unit 3 Fuel Handing Building (9' 0"), Fire Zone 3-FH-15-125:

Quantities of torn radiological protective clothing were being store (Note that the Updated Fire Hazards Analysis

' improperly located the fire zone at the 15' 0" elevation);

(8) Unit 3 Containment Penetration Building (45' 0"), Fire Zone 3-PE-45-3A: A flammables storage locker was installed at the north wal The inspector reviewed licensee procedures to evaluate implementation of the license requirements associated with fire protection. The requirements, as imposed by the operating license, state-that controls must be established to govern:

(1) The handling of and limitation on the use of combustibles...

and to ensure that these items are not stored in safety related area (2) The transient fire loads during maintenance and modifications... in buildings containing safety related equipment. .This control should require an in plant review of proposed work activities to identify potential transient fire loads...

(3) The removal of... combustibles resulting from the work activity, following completion of the activity or at the end of

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,each work shift, whichever is soone (4) Periodic inspection for accumulation of combustible ,

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, (5') A117 wood used in safety related areas to assure that it-is treated with flame' retardan ~

The. following procedure's were reviewed by the inspector:

(1) ;S0123-VI-23.0'ImplementationofSite

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Housekeeping and Cleanness

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Controls, TCN 2-5 dated May 16, 198 ~

(2) ~ S0123-FP-1 Fire. Protection Program, Revision 0 dated March 21, 198 (3) S0123-XIII-13 Weekly Inspection for:the Control of Combustibles and Transient Fire Loads, TCN 2-3 dated January 14, 198 The inspector also reviewed the Topical Quality Assurance Manual, Chapter 8A, " Quality Assurance Program Requirements for the Fire Protection. Program," Revision 6 dated April 14, 1986. The licensee's quality assurance program and implementing procedures did not make reference to the license requirements applicable to Units 1, 2 and 3 for fire protection, and implementation of appropriate controls was questioned in that combustibles were apparently being routinely stored in safety related areas. This item remains unresolved pending additional review (50-206/86-34-02).

b. Fire Boundary Isolation On several occasions, the inspector noted that the double doors which provide access to the recently installed auxiliary building (located at the 68 foot elevation on top of the Radwaste Building and between the Units 2 and 3 Penetration Buildings) were left open such that a fire barrier was not established between Units 2 and The auxiliary building provides laundry services for protective clothing and respirators, personnel' locker facilities, and a storage location and issue point for protective clothing. The inspector reviewed the Updated Fire Hazards Analysis (UFHA) and found that the auxiliary building was not depicted in the UFHA. The auxiliary building is located between Fire Zones 2-PE-63-3B and 3-PE-63-3B, and above Fire Zones 2-AR-9-73, 2-AR-37-102A and 3-AR-9-7 The UFHA identifies the walls where the double doors have been installed as a " Technical Specification Wall (Area)" and the Technical Specifications require that the licensee take compensatory actions when these doors are left open. The inspector requested the licensee to provide documentation to demonstrate that compensatory actions were being taken while the fire doors were inoperable. This item remains unresolved pending additional review (50-361/86-34-03).

c. Separation of Equipment Required for Safe Shutdown (Units 2 and 3)

The inspector noted that the auxiliary feedwater (AFW) system containment penetration isolation valves for both trains were located in the same fire area. 10CFR50, Appendix R, Section II requires that specific measures be taken to protect redundant trains

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of safe shutdown equipmen Since two of the four valves on each unit'are electrohydraulic and could pose a fire hazard, fire

. barriers may be required. The-valves are located in Fire Zones 2-TK-(-2)-161B and 3-TK-(-2)-161B, and the Updated Fire Hazards Analysis does not recognize the possibility that both trains of AFW-could be disabled by a fire in the area. This item remains unresolved pending additional review (50-361/86-34-04). Interpretation of Technical Specification Requirements DJring a review of licensee Compliance with.the requirements of technical specifications for monitoring of liquid radioactive effluents, the inspector noted that the licensee was making'

technical specification interpretations possibly beyond the scope of the specification, as writte Technical Specification 3.3. requires liquid radwaste effluent monitor 2/3 RT-7813 to be operable at all times, but provides the following action statements:

" With less than the minimum number of radioactive liquid effluent monitoring instrumentation channels OPERABLE, take th ACTION shown in Table 3.3-1 Additionally, if the inoperable-instruments are not returned to OPERABLE status within 30 days, explain in the next Semi-annual Radioactive Effluent Release Report why the inaperability was not corrected in a timely manne " The provisions of Specifications 3.0.3...are not applicable."

Action 28.in Table 3.3-12 states the following for liquid radwaste effluent monitor 2/3 RT-7813:

"With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases may continue for up to 14 days provided that prior to initiating a release:

" At'least two independent samples are analyzed in accordance with Specification 4.11.1.1.3, and

" At least two technically qualified members of the Facility Staff independently verify the release rate calculations and discharge line valving;

"Otherwise, suspend release of radioactive effluents via this pathway."

The licensee has implemented a policy which allows continued release via the pathway monitored by channel 2/3 RT-7813 with the channel out of service beyond the 14 days indicated in the technical specification. In this particular instance, the inspector noted that the licensee had made six releases with the liquid effluent monitor out of service longer than 14 day w

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Tiie licensee provided.the following basis for allowing releases to be'made with the monitor' inoperable more than 14 days: '

(1)' Parts. procurement problems have at times prevented repair of the effluent monitor within 14 days. The licensee recognized this problem and requested a change to the technical specification in 1984, which has not yet been approved by the NR (2) Suspension of effluent releases would necessitate plant shutdown, which is not the intent of the technical specifiation (in that action statement c. states that specification 3.0.3 is

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not applicable).

(3) The NRC approved a similar technical specification change applicable to gaseous radioactive effluent monitor The inspector questioned whether the licensee's actions were consistent with the technical specifications, and stated that NRR assistance in interpreting the requirement would be requested. It was noted that monitor channel 2/3 RT-7813 was operable at the time of this repor The inspector stated that this item will remain unresolved pending resolution by NRR and final action on the licensee's proposed technical specification change. The inspector noted that the licensee has documented numerous interpretations and clarifications of technical specifications applicable to units 1, 2 and 3. The licensee committed to review other licensee interpretations of technical specifications and take immediate action, if warranted, to obtain necessary technical specification change approval (50-362/86-33-01) Review of Licensee Event Reports Through direct observations, discussions with licensee personnel, or review of records, the following Licensee Event Reports (LERs) were closed:

Unit 2 86-02 Fuel Handling System Isolation Actuation 86-03 Control Room Isolation System Train "B" Actuation Unit 3 86-03-R1 Pressurizer Instrument Nozzle Leak Follow-Up of Previously Identified Items (0 pen) IE Information Notice 86-03, Potential Deficiencies in Environmental Qualification of Limitorque Valve Motor Operator Wiring (Units 2 and 3)

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As previously discussed in paragraph 10.t of inspection report 50-361/86-32, some jumpers have been found in Limitorque MOVs that

,do not appear to be environmentally qualified. The licensee provided a memo dated November 14, 1986, addressing this issu As stated in the memo, the licensee considers that all internal jumpers

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removed to date from the Units 2 and 3 EQ MOVs were either Rockbestos Firewall III, Raychem Flamtrol, CSA Type TEW (or equivalent) or qualified wire that was installed in the fiel The inspector examined the following Environmental Qualification Document Packages (EQDPs) to determine the qualification status of internal jumpers:

M37626 Rockbestos Firewall III (EQCN-1)

M37619 Raychem Flamtrol (Original)

M37605 Limitorque Valve Motor Operator, SMB Series with Class B Insulation, Various Locations Inside and Outside Containment (EQCN-5)

M37706 Limitorque Valve Motor Operator, SMB and SB Series with Class RH Insulation, Various Locations Inside and Outside Containment (EQCN-3)

M37708 Limitorque Valve Motor Operator, SMB Series with Class B Insulation, Various Locations Outside Containment (EQCN-4)

M37627 Rockbestos Firewall III Instrumentation Cable, Various Locations Inside and Outside Containment (EQCN-1)

M37628 Rockbestos Firewall III Control Cable, Various Locations Inside and Outside Containment (Original)

M37607 Galite Thermocouple Extension Cable with Halar 300 Insulation, Inside Containment (EQCN-1)

M37602 Anaconda Power Cable with Ethylene Propylene Rubber Insulation, Auxiliary Feedwater Pump Room (Original)

M37612 General Electric Power Cable with Vulkene Supreme Insulation, Various Locations Inside and Outside Containment (Original)

M37613 General Electric Power Cable with Ethylene Propylene Rubber Insulation, Various Locations Outside Containment (Original)

Based on EQDP review and an examination of internal jumpers that have been replaced in Limitorque MOVs that are designated as EQ, the inspector made the following observations:

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4 . 13 (1) The qualification basis for C5A Type TEW wire was added to EQDPs M37605, M37706 and M37708 by EQCN-1 dated July 15, July 20 and July 20, 1986 (respectively). The licensee referenced a utility group study, " Insulations and Jackets for Control and Power Cables in Thermal Reactor Nuclear Generating Stations" by Robert Blodgett and Robert Fisher, published in IEEE Transactions on Power Apparatus and Systems, Vol. PAS-88, N , dated May, 1969. This study was generic in nature and did not address specific vendor qualifications, spliced wire considerations or plant specific applications. Therefore, the qualification of CSA Type TEW wire has not been establishe This matter was discussed with the licensee, and the licensee agreed that CSA Type TEW wire is not acceptable for permanent use. This wire is already being replaced as discussed previously in paragraph 9 of Inspection Reports 50-361/86-19 and 50-362/86-1 (2) The qualifications of the crimp-on wire connectors has not been established by the EQDPs, in that the connectors were not addresse The licensee stated that a separate EQDP is available for licensee installed connectors. The inspector requested that the licensee provide a copy of the EQDP for review, and provide the basis for qualification of Limitorque installed crimp on wire connector (3) Environmental qualification o the internal space heaters was addressed in EQDPs M37605, M37706 and M37708 by EQCN-5, EQCN-2 and EQCN-4 dated November 27, November 7 and November 6, 1986 (respectively). The continuous operation of the space heaters was evaluated to consider the effect on valve motor insulation, but the effect on the internal jumper wiring was not evaluate In addition, the effect of continuous heater operation on valve service life was not evaluated and factored into the Arrhenius calculation, and potential failure mechanisms of the heater were not addressed. The licensee is currently reviewing the environmental qualification of internal heater (4) Components internal to the Limitorque valve operators such as terminal blocks, switches, seals and lubricants do not appear to have been qualified by the licensee. The licensee is currently reviewing this matte (5) Qualification of slidewire position transmitters was addressed in EQDPs M37605 (EQCN-3) dated October 16, 1986, and M37708 (EQCN-2) dated August 26, 1986. Although the technical evaluation appeared to be adequate, human factors considerations were not included assuming various failures of the slidewire position transmitter The licensee was asked to evaluate if human factors considerations should be include (6) The inspector noted several instances in which substitution of numerical values into the Arrhenius equation in place of variables ty , t , T , and T was not done correctl However, 2 1 2

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t'he correct value of activation energy was calculated because theLsubstitution errors wer~e self correctin '

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'(7)'Theinspectorndtednumerousinstancesinwhichindeterminate

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- jumpers have been found by the licensee in EQ Limitorque valves

'and have been replaced with Rockbestos. SIS switchboard wire with Firewall III insulation. The inspector requested that the'

licensee document the specific basis under which he believes that the types of removed wire found to date do not adversely impact the operability of other EQ MOVs that have not yet been inspecte (8) Several of the jumpers that were examined appeared deteriorated due to heat in that the jumpers were discolored'in places and the insulation was brittle. These conditions are contrary to the qualification requirements, but were not evaluated. The following valves had deteriorated jumpers:

o 2HV-9322 o 3HV-0396 o- 3HV-8150 The inspector has reviewed the above observations with the licensee, and the licensee is currently preparing a response addressing each of the identified concerns. This item remains unresolved (50-361/86-34-05). (Closed) Unresolved Item 50-361/86-32-01, Improper Use of Procedure for Radiation Monitor Calibration This item involved the observation of a routine calibration of the liquid radioactive waste effluent monitor (2/3 RT 7813). The inspector noted the following deficiencies:

(1) The instrument technician was in the process of completing calibration of the monitor in accordance with procedure 5023-XXV-9.343; however, the applicable maintenance order and procedure were not at the job site as required by station administrative procedures, and required valve position verifications had not been recorded as required by the procedur (2) The instrument technician had signed off prerequisite 3.14 of procedure 5023-11-4.16, prior to performing all of the actions required by the prerequisit Additional review of these observations with cognizant licensee personnel showed that the above actions were improper and in apparent violation of station procedures (50-361/86-34-06). The licensee was implementing corrective actions to preclude recurrenc . Exit Meeting

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On December 19,'1986, an exit meeting was conducted with the licensee

representatives identified in Paragraph 1. The inspectors summarized'the

, inspection scope.and findings as described in this report, ,

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