IR 05000237/1986013

Insp Repts 50-237/86-13 & 50-249/86-15 on 860519-23. Deficiencies Noted.Major Areas Inspected:Implementation of Program for Qualification of Electrical Equipment,Per 10CFR50.49

ML17199F916
Person / Time
Site:	Dresden
Issue date:	09/04/1986
From:	Andrea Johnson, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML17199F915	List: IR 05000237/1986013 ML17199F914
References
50-237-86-13, 50-249-86-15, NUDOCS 8609120303
Download: ML17199F916 (20)

Text

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• ._:.,. :' Report. NoA,;*~~~i:-....

Docket No.:

. License _No.:

Licensee:

Faci 1 i ty Name:

Inspection At:

UNITED STATES NUCLEAR REGULATORY COMMISSION

. OFFICE OF INSPECTION AND ENFORCEMENT 50-237/86013; 50-249/86015 50-237; 50-249 DPR-19; DPR-25 Commonwealth Edison Company Post Office Box 767 Chicago, Illinoi~ 60690 Dresden Nuclear Power Station, Units 2 and 3 Inspection Conducted:

Route 1, Morris, Illinois 60450 May 19 tu 23, 1986 Inspector:

inspection and contributing to the report were:

U. Potapovs, Chief, EQIS, IE R. Moist, EQ IS, IE J. Grossman, Memb~r of Technical Staff, Sandia National Laboratories (SNL)

D. Jackson, Consultant Engineer, Idaho Nationa 1 Laboratory (INEL)

A. Nolan, Consultant Engineer, INEL A. Gautam, Reactor Inspector, Riii R. Smeenge, Reactor Inspector; RIII Westberg~ Reactor Engineer, Riil Approved By: -

~E091 20303 s6o9os

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Q R **.')DOCK 05000237~1 '. !-

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INSPECTION SUMMARY:.

to 23, 1986 Ins ection Re ort Nos. 50-237/86013;

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Areas Inspected: **Special, announced inspection to review the 1icensee 1 s implementation of a program for est~blishing and maintaining the qualifi~ation of electric equipment within the scope of 10 CFR 50.4 The inspection also included evaluations of the implementation of equip~ent q~alification (EQ)

corrective action commitment These commitments were made by the licensee as a result of (1) identified deficiencies in the February 12, 1986 Safety.*

Evaluation Reports (SERs) for Units 2 and 3 (originally identified deficiencie~

in the December 29, 1982 SERs and the corresponding Franklin Research Center (FRC) Technical Evaluation Reports (TER's) enclosed); and (2) the proposed method of re so 1 uti on for each of the i dent i fi ed deficiencies* documented in licensee responses of June 3, 6, and 11, 1983, October 5, 1983, March 30, 1984, May 21, 1984, July 2, 1984, February 14, 1985, and January 3, 1986~

Results:. The inspectio"n determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49 except for certain defi~iencies listed belo No deficiencies were found in the licensee's implementation of corrective action commitments made as a result of identified deficiencies in the (1)

February 12, 1986 SERs; (2) SERs/FRC TERs; and (.3) documented licensee response *,

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Potential Enforcement/Unresolved Items:

Report Item Name

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Paragra2h Number Amp Nylon*:'Tnsulated Butt Splices 4.F(i)

50-249/86015-01 BIW Cabl~; GE SI V~lkene C~bl.F(2)

50-237/86013-02, and Raychem Splices*

50"."24*9186015-02 AVCO Solenoid Valve 4.F(9)

50-249/86015-03 Dresser Solenoid Valve 4~F(i0)

50-249/86015-04 Limitorque Motor Operators - Preser-4.H(i)

50-237/86013-05, '

vation of Qualified-Status 50-249/86015~05 EQ Equipment Maintenance Annual 4.C(i)

50-237/86013-06 Review. and Summary Report 50-249/86015-06 02en Items*: EQ Maintenance; Surveillance and.Sit~. 4.B(i)

50-237/86013-07 Training Procedures 4.8(2)

50-249/86015-07 Master Equipment List /86013-08 50-249/86015-08 Raychem Connection/Sealing Assemblies 4.F(3)

50-237/86013-09 50-249/86015-09 1 American Pamco~ Inc. Cable Splices 4.F(4)

50-237/86013-10 50-249/86015-10 1 Rockbestos Electrical Cable 4.F(5)

50-237/86013-U 50-_249/86015-11 1 Boston Insulated Wire Cable 4.F(6)

50-237/86013-12 50-249/86015-12 1 GE Electric Cable*

4.F(7)*

50-237/86013-13 50-249/86015-13 1 Limitorque Motor Operators - Inside 4._F(8)

50-237/86013-14 Drywell 50-249/86015"."14 1 IE Information Notice Responses 4.G(l)

50-237/86013-15 50-249/86015-15 1 West~ngh6use LPCI Room Cooling Fan*

4.H(3)

50-237/86013-16

Motors; GE Co~e Spray Pump Motors -

4.H(5)

50-249/86015-16

~plice Repair/Replacement

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17 *. Chromalux Electric Aii He~ter 1 Anaconda!:.;sea l Tight Conduit

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4.H{6)..

4.H(7).

50-237/86013-17 50-237/86013-18 *

DETAILS Persons Contacted Conunonwea lth Edi son Company.

N. Kalivianakis, Division Vice-Presid_ent D. Scott, Station Manager -

.R. Flessner, Service Superintendent R. Zentner, Assistant Superintendent Maintenance Z. Boxer, Station Nuclear Engineering Department (SNED)

G. DeYoung, SNED *

R. Grams, SNED B. Viehl, SNE E. Seckinger, SNED G~ Frankovich, EQ Coordinator A. Crawford, General Foreman, Substation Consttuction R. Scweizer, Foreman, Substation Construction J; Kovic, Foreman, Sub Station Construction J. Williams, Regulatory Assurance W. Kapinus, Electrical Maintenance Staff R. Jeisy, Station.QA Supervisor D. Adam, Regulatory Assurance J. Doyle, QC Supervisor**

J. Achterberg, Technical.Staff Supervisor G. Smith, Assistant Technical Staff Supervisor J~ Clark, Engineering, Instrumentation* & Measurements L. Sebby, Master Electrician J. Wojnarowski, Nuclear Licensing Administrator S. Zunjic, SNED

• D. Cook, Quad Cities, Engineer M. Sievert, Quad Cities, Engineer D. Farrar, Director of Nuclear Licensing E. Armstrong, Assistant Technical Staff Supervisor D. Booth,* Master Instrumentation Engineer E. Harseim, Forman, Substation Construction CECo Consultants C. Crane, WESTEC Services, In C. Schwarz, WESTEC Services, In J. Wahl~ Bechtel Power Corporation U.S. NRC L. McGregor,.Resident Inspector, Dresden*

. B. Hare, Resident Insp~ctor, Dresden J. Bjorgen, Resident Inspector, LaSalle

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PURPOSE:

The purpose of this inspection was to revie~ the licensee's impleme~tation of the requirements of 10 CFR 50.49, and the implementation of corrective action.co.nunttments made as a.result of identified deficiencies in the (1)

Februar-.Yxi-12:, 1986. SERs; ( 2) SERs/FRC TERs; and ( 3) proposed method of resolution for each of the identified deficiencies documented in. the licensee's response BACKGROUND:.

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. On January 26, 1984, the NRC held a meeting with the licensee for which-TER's for Units 2 and 3 had been prepared for the NRC staff by FRC in order to discuss open issues regarding environmental qualification, including.acceptability of the environmental conditions for equipment qualification purpose The meeting discussed Commonwealth Edison Com-panies (CECo) proposed method to resolve the EQ deficiencies identified in

• the December 29, 1982 SER and June 22, 1982 FRC TER for Unit 2, and the December 29, 1982 SER and July 21, *1982 FRC TER for Unit 3. Discussions also included CECo's methodology for compliance with 10 CFR 50.49, and justification for continued operation for those equipment items for which EQ was not yet complete The minutes of the meeting and proposed method of resolution for each of the EQ deficiencies were documented in the licensee's March 30, 1984 response submittal. Earlier responses and sub-

. sequent responses to these identified deficiencies were documented in the li~ensee submittals of June 3, 6, arid 11, 1983, October 5, 1983, May 21, 1984, July 2, 1984, February 14, 1985, and January 3, 198~. The majority of deficiencies identified, inv~lved qualificatidn documentation, qualifica-tion_ by similarity, aging, qualified life_, and replacement schedlJle New incontainment pressure/temperature service conditions for Dresden Units 2 and 3 were established by a licensee submittal on September 5, 1985 in response to NRC staff p6sition. The licensee indicated that in response to the NRC staff's position, replacement of Target Rock relie*f valve solenoid seals, to accpmmodate the required temperature profiles resulting from the assumption of a thirty minute drywell spray initiation interval, would be accomplished.,Namco limit switch seals were also-required to be replace *

Limitorque motor operator wiring deficiencies, observed during a 1 icensee *

walkdown in Unit 2, were cor~ected during a Unit 2 outage in September 198 * During the September 1985 Unit 2 outage, a walkdown of bther electrical equipment.required to be qualified revealed that cable for electrical penetrations showed evidence of deterioration. All such cabling was replaced and Unit 2 was returned to service ori November 5, 1985 before the November 30, 1985 en~ironmental qualification de~dlin *

Dresden Unit 3 has completed a pipe replacement o~tage program and was*

• at the time of the inspection in.the final stages of a refueling outage, scheduled for ~tartup on July 26, 198 *

• *

The above identified documents were reviewed by the inspection team members and used as a basis for this inspectio FINDINGS*:;:.. >.

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A.*

Eq**~~aiil Compliance with 10 CFR 50.49 The NRC.inspectors examfne-d 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

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qualificatio~ 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 el~ctrical equipmen 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 Dresden Nuclear Power Sta~ion Units ~ and 1, although some deficiencies were identifie EQ Program Procedures The inspection team exami~ed the implementation and adequacy of cotporate and site policies, and procedures, for establishing and maintaining the environmental qualification of el~ctrical equipment for compliance with the requirements of 10 CFR 50.4 The licensee's methods for esta-blishing and maintaining the environmental qualification of electric*

equipment were reviewed in the following.documents:'

Station Nuclear Engineering Department Q.6, Modifications Originated by.Station Technical Staff, Revision 12, dated April 30, 198 *

Q.42, Environmental Qualification Documentation Preparation, Control and Acceptance, Revision 3, dated March 1~, 198 Administrative'Procedures OAP 11~2, Surveill~nce Program, Revision 10 OAP 11-4, Control of the Master Classification List of Safety-Related, Seismic, Environmentally Qualified, ASME Code-Related Systems, Structures and Components *and Reliability-Related Portions of Fire Protection and Security Systems, Revision 3, dated February 5, 198 *

DAP 11-6, Request for Purchases and ~eceiving Inspection Guide-1 ine OAP. 11..:7, Technical Evaluation of Parts Used In Safety-Related Components.*

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OAP 11-14, Environmental Qualification P~ogram, Revision 1, dated March 198 Quality Assurance Manual

'"QP 18.1, Quality Programs Audits, Revision *The inspectors reviewed the above licensee's procedures for implement-ation of the* requirements of 10 CFR 50.49 including

tt} definitions of harsh and mild environmertt, (2) eq~ipment qualified life, (3) service conditions, (4) periodic testing, and (5) maintenance and surveill~nce. *

The licensee's EQ program was al~o reviewed with regard to establishment,

. of in auditable documentation file, including such.documents as, system component evaluation work sheets (SCEW), test reports, maintenance records and other supportin~ document~ which establish eq~ipment *

• qualification, training of personnel, control of plant modifications, and installation of new and replacement equi~ment to the requirements of 10-CFR 50.4 (1)

The Engineering Procedure, Maintenance ~nd Surveillance Plan (EPMS) wa~ provided for each piece of equipment in the EQ docu-mentation fil The EPMS identified requirements to maintain qualification and surveillance parameters to be used to detect

• degraded materials or equipment performanc The EPMS also recommended good practices to be observed for maintaining the equipmen At the time o"f this inspection, a very limited number of maintenance procedures~- spetifically for qualified equipment, had been prepared and issued for plant uie. Maintenance and surveillance personnel are currently utilizing the EPMS to identify the work to be performed to maintain environmental qualification of the equipmen The licensee committed to have

. proc~dure~ for maintenance/surveillan~e for all qualified equip-ment issued prior to the end of.June 198 *

(2)

At the time of this inspectf6n o~er 80 percent of the pl~nt's technical staff, operators, instrument mechanics,-maintenance mechanics, electricians~ QC inspectors*, stockmen* and safety/

licensee personnel had attended at least one of two EQ train-ing progr*am One of these training programs covers site specifics and the other is a program prepared by Electrical Power Research Institute (EPRI).

No one from the site QA staf has attended these training program Records identified that at least two of the QA staff had attended the EPRI seminar during the summe~ of 198 Records could not establish the site imposed certification requirements for one of the QA inspectors, and he was removed from the list of inspectors certified to perform EQ *

inspection The licensee has committed to have all the site QA staff attend at least one of the site EQ training programs.. *

Items in paragraphs 4.B(l) and 4.B(2) above are considered Open Items and ar~ required to be closed out by~ subsequent NRC inspection.(50-237/86013-07; 50-249/86015-07).

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• '. EQ Maintenance Program All required maintenance, replacement, surveillance tests and inspec-tions. necessary to preserve the environmental qualification of EQ iden.t:i~f'ted equipment are identified on a computerized schedule. This sche'dfi1'ihas* an automatic: recall control to identify when equipment is due for maintenance/surveillance during the next mOf'.'th and provides a.

record of when work was completed or identifies when work is past du The list of work not completed on schedule is provided-to management for their* information and implementation of.necessary corrective action..

. The maintenance/surveillance group maintains records of all work per-formed on the qualified equipment for which they have the responsibilit (1)

In the review for implementation of procedural requirements, the.

NRC inspection team found that the maintenance group was not perform-ing a semi-annual review or preparing the EQ Ma.intenance Annual Sumlilary Report as required by DAP 11-14, paragraph B:3.f. The intent of thi.s review and report is to identify, to the.Plant management, qualified equipment experiencing problems~ Licensee failure to follow the requirements of* procedure OAP 11-14 regarding*

the semi-annual ~eview and the annual report on maintenance of EQ equipment is considered a violation of 10 CFR 50, Appendix B, Criterion V, (50-237/8~013-06; 50-249/86015-06).

(2)

For implementation of the EQ mafntenance program on Limitorqu motor operators, refer to paragraph.4.H of this report~

• * SER/FRC TER, and Licensee Response Conunitments The NRC inspection team evaluated the implementation of EQ corrective action conunitments made as a result of (1) the EQ identified deficiencies in the December 29,- 1982 SERs and accompanying FRC*TERs of June 22, *

1982 for Unit 2, and July 21, 1982 for Unit 3; (2} the licensee's proposed method of resolution for each of the EQ deficiencies as documented in licensee responses of June 3,.6, and 11; 1983, October 5, 1983~ March 30, 1984, May 21, 1984,' July 2, 1984, Febr!;.tary 14, 1985, and January 3, 1986;** and (3) *th*e SERs for final resolution of EQ equip-

• . ment important to safety for Uni fs 2 and 3 i S$ued on February 12, 198 The majority of deficiencies identified above involved EQ file docu-mentation pertaining to similarity, aging, qualified life, an replacement schedule The approach used by the licensee in resolution of the above deficiencies resulted in (1) replacing equipment; (2)

. additional analysis and qualification placed in the EQ documentation file beyond that reviewed by FRC; (3) obtaining additional test reports and qualifying documents; and (4) determining that some

• equipment*was outside of the harsh environment requirements (~ild environment) of the scope of 10 CFR 50.49 *

. The NRC inspection team verified that the licensee's EQ documentation file contained the approprfate analyses and necessary documentation to support*the equipment qualificatio *

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Based on review of the EQ documentation files *and the 10 CFR 50.49

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Master Equipment List (see par~graph 4.E), the NRC inspection team identified no deficiencies in the implementation of SER/TER, SE and licensee response conunitment Ongoing review of RG 1.97 implemen-tati.on may result in additional. equipment being added to the 10 CFR

• 50.49 Master Equipment Lis.

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. CFR 50.49 Master Equipment.List (MEL)

The NRC inspection team reviewed the Dresden Station 10 CFR 50.49 MEL which CECo is required to maintai The MEL for units i and 3 are maintained by th~ SNE Consider~d in

. the preparation and maintenance of this list are the environmental effects resulting from all of the postulated design basis accidents documented in the Technical Specification~ and Dresden emergency operating procedures (OEOP's).

The methodology used for produci.ng the MEL is described in a 1 i censee submittal to USNRC Revision 4 dated June 4, 1985 for both units. The MEL js maintained under pr6cedure OAP.11-4 Revision 3 and OAP 11-14 Revision 1. These procedures were reviewed and found acceptable for maintaining the MEL for both unit In order to test the completehess of th~ MEL specific EQ components were sel~cted from*the Dresden Station piping and instrumentation diagrams (P&IDs) which *are required to function during and following a postulated design basis accident (OBA).

The posttilated DBA's con-sidered were LOCA inside the drywell, MSLB in drywell, MSLB in steam tunnel, HPCI line break and RWCU line brea The following P&IDs were selected for both unft *

LOCA Inside Drywell - P&ID M28/M359-Isolation Condenser Piping -

Acutator Electric Moto MSLB in Drywe11.:. P&ID M26/M357, Ml2/M345 - Nuclear Boiler &

Reactor Recirculating *piping and.Main Steam Piping - Valve So.lenoi MSLB in Steam Ttinnel - M12/M374 - HP Coolant Injection Piping -

Actuator Electric Motor RWCU Line Break - M30/M361 - Reactor ~ater Clean-Up Piping Sheet

• 1.- Actuator Electric Motor Also the following DEOP's, contained in a binder entitled "Dresden Emergency Operating Procedures, Revision 0, October 1985, Units 2 and 3, were reviewed by the NRC inspection tea DEOP -- 100-1 Reactor Level Control (PCIS, HPCI, CS, (PCI)

DEOP - 100-3 Reactor Power Control (RPS).

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DEOP - 200-1 - Primary Containment Control (LPCI)

DEOP - 200-2 - Pr.imary Containment Pressure Control.(LPCI)

.~,*oEOP - 200-3 - Torus Water Temperature Control (LPCI)

... ; ~ ~~.;.;;.:_~~ ~.

DEOP - 400-1 - Level Restorat16n (LPCI)

DEOP 400-2 RPV Pres~ure Control (HPCI)

All of the components/e~uipment selected for review were on the ME Components were selected from Dresden IEB 79-0lB submittal Revision 4 dated June 4, 1985 to verify that these items were also on the current ME All items selected were on the current ME CECo also stated that post accident monitoring (PAM) equipment would be listed on the MEL after the NRC app~oves their PAM submittal of August 198 During the NRC inspection team's review of the documentation in the EQF, SCEW 1s could not be found fo~ the following comp6nents:

(1) Transmitter~ Rosemount (Plant ID) - D02-0263-057 BLT (2) Transmitter, Rosemount (Plant ID)

D03-0263-057 BLT (3) Valve solenoid, ASCO (Plant ID) :... D03-4741-0ll-SO Each of these components were listed on the MEL as safety related E Discussions with CECo revealed that these components were located in mild environment and should be removed from the MEL~ It should be noted that these items were not on the original IEB 79-0lB submitta The licensee pro~osed to delete these items prior to start up of

. Unit This item is considered an Open Item to be closed out by a

• subsequent NRC inspection (50-237/86013-08; 50-249/86-015-08).

Environmental Qualification Documentqtion Files The 1icensee*~ Environmental Qualification Fil~ (EQF) has been esta-blished and is being maintained to meet the requirements of 10 CFR

. 50.49 at the Dresden Nuclear Power Station. The requirements for

. establishing, controlling, routing, and filing, EQ data and maintaining the EQF*are contained in CEC9 procedure No. DAP.11-14, Revision 1, entitled "Environmental Qualification Program.

Also the EQ document-ation preparation~ control, and acceptance, is contained in Station Nuclear Enginee~ing Department (SNED) Procedure Q.42, Revision 3, dated March 17, 198 SNED prepare~ apd issues EQ documentation packages contained in the EQ The EQ coordinator is responsible for review and acceptance~ including.changes, of the EQ documentation packages including EQ report SNED is responsible for implementing all revisions to the EQ *

• .*

The NRC inspection team examined files for 24 selected equipment items

. (EQ documentation packages) to verify the *qualified status of equip-

_ment within the scope of 10 CFR 50.49~ In addition.to comparing plant serv}9e conditions with qualification test conditions and verifying th~'.c~,~\\~es for these conditions, the inspectors selectively reviewed _

area"S."Y?stJch as. (1) requ*ired *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) a~ing~calculations for qua 1 i fi ed 1 i fe; ( 5) rep 1 a cement pa rt schedu 1 es; ( 6) the effects

. of decreases of insulation resistance on equipment performance; (7)

adequac~ of demonstrated accuracy;.(8) evaluation of test anomalies; and (9) applicability of EQ problems as reported in USNRC IE Information Notices (INs)/Bulletins and their resolutio *

During this review of.the EQF the inspection t~am identified the follow-ing Potential Enforcement/Unresolved Items and Open Items~.described belo (1)

C D 014459 - AMP N lon Insulated Butt S lices used with GE ectrica Pentrat1on F 1 CECo had identified AMP (vendor supplied) butt splices on Unit 2

• penetrations which were displaying considerable degradation. These crimp splices on all EQ related circuits in Unit 2, were replaced with Raychem splice An. inspection of the Unit 3 penetrations found no splice deficiencies, how~ver, CECo had incorporated program to monitor the Unit 3.splices for degradatio There were inconsistencies with regard to the AMP splice qualifi-cation in the EQ CECo had determined that the splices supplied

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by GE with the penetration were of the nylon insulated type purchased from* either AMP or Ho 11 i ngsworth who is now out of busines QCD

. #015986, for GE FOl *penetrations, was not intended to qua 1 i fy the nylon insulated splices.* CECo maintained the splices were qu~lified by the penetration qualification test Jn QCD #01445 CQD #014459 documentation.indicated insulated spli.ces were used

- in the penetration test performed under the DO.R Guidelines and

_~hat the circuits functioned throughout this testa The QCD #014459 qualification test did not describe the splices or indicat~ their condition during or at the tonclusion of the test. The documen-tation, however, established two manufacturers (AMP and Hollingsworth) of the splices supplied to CECo.. The concern of the inspection team was that there is no documentation linking the splice tests by GE with those supplied with the FOl penetration CECo has fodicated that information was obtained.from GE indicating that nylon insulated butt splices were used in the test but this information was not included in the EQ The documentation reviewed did not support qualification of the AMP splices in that similarity

~ould not be establi~he *

( 2}

(3)

The inspection team also-observed that CECo has not been able to establish a cause for the early degradation observed in the unit 2 splices. The specific splice manufacturer for splices in

._unit 2 could_ not be determined since no samples of the splices_

-,-:-were retained._ Again GE supplied either AMP or Hollingwort _ ::0--1he splices in unit 3-do not display early degradation, as in unit 2, and a sample from Unit 3 was obtained and was clearly marked "AMP."

The GE test does not identify the manufacturer of the splice used during the tes This is a Potential Enforcement/Unresolved Item (50~249/86015-0i}.

Electrical cable and cable splice qualification files did not demonstrate that the equipment functional performance require-ments were satisfied. Cable and splice vendor qualification tests are very general performance tests. The licensee must determine the requirements for the specific application of the equipment in its installed configuration, and show how the test results demonstrate acceptable performanc The licensee is required, particularly_in the area of instrumentation, to constder high leakage currents and low insulation resistance (IR}.

No analyses were contain~d in the EQF which addresses how m~asured parameters taken during type tests would affect Dresden plant circuit CECo committed to include a statement in the qualifi-cation documents which outlines the methods used to address_

acceptance and performance criteria. This is a Po ten ti a-1 Enforcement/Unresolved Item (50-237/86013-02; 50-249/86015-02).

The qualification criteria for-this file is NUREG 0588 Category The file does establish qualification, howeve~, the file contained two test reports from Wyle Laboratory *supplied by the vendor~ The reports established qualification for model numbers -

-NEIS-2-50A, NMCK, NESK, WCSF-N, and NCBK. -There was a general statement of similarity contained in the documentation files,

- however, the file was not clear as to the degree of similarity as no discussion or analysis to support similarity existe During the inspection, CECo stated the intent of the similarity statement was that all the Raychem products which were being qualified have the same polymer materials of construction and are therefore similar. A statement to this effect was missing _

in the file. Also, a statement discussing the determination of synergistic effects was missin CECo agreed to include appropriate statements in the qualification file This item is considered an Open Item and is required to be closed ou_t by a subsequent NRC inspection ( 50-237/86013-09; 50-249/86015-09}.

(4)

• .T~e qua ll.fi cat fon criteria for this file is NUREG. 0588 Category I..

. *:~:-...Th.~ file does* establish qualification, however, there was a

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cOiH:ern in that a vendor supplied test report which establishes qualification of model 52979, could.not establish similarity between models 52979 *and 52978 and 5298 Vendor literature in the file showed the same design but for different-ifz~ wires *

. There is a general claim of similarity for models 53548, 53549~

• and 53550, however the basis for this statement was not clea This item is considered.an Open Item and is required to be closed out by a subsequent NRC inspection (50-237/86013~10; 50-249/86015-10).

(5)

CQD #015354 - Rockbestos Electrical Cable The qua 1 if i cation criteria for this f i 1 e is NU REG 0588 Category CECo has prepared a series of qualification files for cable manufacturers based upon purchase record of the* Nuclear Steam System Supplier (NSSS) for all CECo plants. They have determined that cable from these manufacturers might have been used in mod-

.ifications to EQ systems at Dresde There has been no effort,

to establish types of cable used in specific EQ circuits. Th Rockbestos file included vendor supplied test reports for Firewall..

.. SP, Firewall EP, and Firewall III. These test reports were al * referenced in NRC_Information Notice (IN) 84-4 The file con-tained an analysis which.addressed the concerns of IN 84-44 for each type of cable. During the inspection, CECo deterinined that only* Firewall EP had been purchase The file did contain an *. *

analysis of Firewall EP which addressed the generic concerns of.

IN 84-4 The plant specific conditions were* considerably less severe than the reported test conditions allowing substantial

. margin The analysis for Firewall III was being revised to include a report on a recently completed retest, and is intended to qualify the cable for future us CECo will _i.nclude.statements in the file to **c 1 a ri fy the intent.of these document This item is considered an Open Item and is req~ired to be closed

_out by a subsequent NRC inspection. (50-237/86013-1; 50-249/86015-11) ~

.

(6) _ CQD #013578 - Boston Insulated Wire The qualification criteria for this file is NUREG 0588 Category This is also a NSSS supplied cable which may have been used in modification '.

The cable is a low voltage signal cable and has a CSPE jacket with EPR insulation. The documentation file contained lengthy discussions of synergisms related to CSPE jacket but nothing on

?

EP CECo will revise the file to include a discussion of syner-gistic effects on EP *

This item is considered an Open Item and is required to be closed.

out by a subsequent rfRC inspection (50-237/86013-12; 50-249/86015-12).

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.

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(7)

CQD #014534 - General Electric Cables Model SI 57275 This file was established for the silicon insulat~d cable or1g1-nally installed in the plant outside the drywel The qualification criteria* was not clear in that statements in. the file contradicted each other as to the level of qualificatio CECo will revise the file and indicate correct qualification criteria~

This item is cdnsidered an Open Item and is required to be closed out by a subsequent NRC inspection (50-237/86013-13;* 50-249/86015-

. 13).

.

(8)

CQD-017504 - Limitorgue Motor Operators, Inside Drywell

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This EQ documentation file group represents MO's located in the drywel These have been replaced with new MO's which were fµlly qualified by the manufacturer at th~ time of purchas They are qualified with the installed configurations of 11T 11 drains and grease relief valve *

This file group used Limitorque Report No. 80058 as the basic document for.qualification, supplemented by a Sargent and Lundy analysis, to show how the 80058 report supported qualificatio The Sargent and Lundy analysis stated that after a 30 day high temperature test the motor insulation megger measurements were as low as SOK ohm This statement is incorrect as the original test report documented* it as infinity. This ana*lysis is incon-sistent with the test report results and should be reviewed and*

corrected by CEC This item is considered an Open Item and is required to be closed out by a subsequent NRC inspection (50-237/86013-14; 50-249/86015-14).

(9) :C D-015003-AVCO. Solenoid Valv~ Model C5450-5, Plant ID No. 0203-003 -S Unit 2 The AVCO solenoid valve model C5450-5 is us~d ~i a pilot soleno~d valve for the aut6matic depr~ssurization system (ADS) Target Rock over-pressure safety relief valv The valve must remain operable for 100 days following a design basis accident (OBA).

The valve has _been qualified for 40 year life as established by analysis requiring its nonmetallic parts to be replaced every 12 year '..

The EQF No. CQD-015003 contained a statement from the manufacturer that solenoid valve C5450-5 was obsolete and was to be replaced

. by solenoid va lVe C6948-120. * CE Co SNED produced Work Request No. D-42178 which indicated that on September 30, 1985.to

• .. :_October 22, 1985 solenoid valve C6948-120 was installed on

• }'-'-equipment component ID 203-3A, Unit The EQF did not contain any documentation showing that solenoid valve C6948-120 had been qualified for us The manufacturer ~ad changed the maintenance kit (necessary for the 40 year life) from a C5450-5 Rev. V/W.to K545 CECo SNED could not ascertain that the nonmetallic parts of the new kit

~ere identical to those of* the old Ki *

The EQ documentation file contained a statement from the manufact-urer recommending a maintenance interval of 12-18 months. *The.

plant had settled on a maintenance interval of 10-12 years but had not discussed maintenance intervals with the manufacture File CQD-015003 did not adequately establish tjualification for the C 6948... 120 replacement part nor provide basis for the specified maintenance interval. This is a Potential Enforcement/

Unresolved Item (50-2~9/86015-03).

(10) Dresser Solenoid Valve Model 1525VX, Plant ID No. 0203-00313 (Unit 2).

The Dresser solenoid valve model 1525VX is part of an assembly containing a GE solenoid valve and a Unimax position *limit switch..

The assembly is used on the main steam line and has been qu~lified for. a 40 year life as determine*d by analysi *

A review of DCN-6035-428 contained in the EQF showed that.the assemblies were shipped to the plant containin~ shunt wirin with PVC jacket. Documents in* the EQF stated that the 40 year analysis wa> only valid if the PVC jacketed wire was removed and replaced with a wire utilizing a qualified jacke_t. *No documenta-tion was contained in *the EQF to demonstrate that the PVC jacketed wire had been replaced with a wire that was qualified for use

at the plant. 7his item is a Potential Enforcement/Unresolved Item (50-249/86015-04). IE Information Notices and Bulletins The NRC inspection team evaluated the licensee's activities related to the review of EQ-related IE Information Notices/Bulletins: The *

inspector's review included examination of the licensee's procedures and EQ documentation files relative to 12 Information Notices and one Bulletin. The procedures review determined that the licensee does have a system for distributing, reviewing, and evaluating Information Notices/Bulletins relative to equipment within the scope of 10 CFR 50.49 (refer to parag~aph 4.B).

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During the review of the licensee's EQ documentation files, the inspet-tion team identified the following Open Items:

(1)

Limitorque motor operators on the MEL for Units 2 and 3 subject to IE Notice 86-02 and 86-03 were undergoing engineering evaluatio J.~ Notice 86-03 (undocumented internal wiring.)* has been pursued

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-_~;J).Y::-.CECo.r: All MO's in both plants have been physically inspected

.. -' <--:"'~a-ntt'.*wa l ked down and a 11 undocumented wire replaced~

This item is considered an Open Item to be closed out by a subsequ~nt NRC inspection (50-237/86013-15; 50-249/86015-15). Plant Physical Inspection The NRC inspection team, with the required tagging out of operation selected equipment and components by the licensee, walked down and physically inspected approximately 26 components/equipment.for both Units 2 and The inspection team examined attributes and characteristics such *as mounting configurations, orientation, interfaces,'. model numbers, ambient environment, and physical conditio.

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During the*NRC wa1kdown inspection the NRC inspection team identified the Potential Enforcement/Unresolved Items and Open Items described below:

(1)

Limitorgue Motor Operators The NRC inspection team performed a physical inspection of six L imi torque motor operated (MO Is) valves '(in both Uni ts) to verify that ~he EQ documentation-fjles were applicable to the installed configuration, and to obtain indication of MO's being maintained in a qualified status during the 40 year qualified life (QL), by periodic maintenance, testing, and component replacemen Plant ID No. M0-3-2301-4~ SMB-1-60, E Documentation File CQD 071504

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This MO, in Unit 3, -is located in the dryweH at the 576 f elevation; It is 6n the main steam supply line inboard *

isolation valv The plastic jacket on the sealtite conduits leading intd the limit switch housing was badly deteriorated, apparently by high temperatur Some of the plant wiring inside the housing showed evidence of deterior~tion in the form of cracked insulation. Also sleeving around the insu-lation was observed to be cracke It was observed by the NRC inspector that this MO was inspected by plant personnel and new internal wiring installed.in March of 1985. A walk-down checksheet with the work request was checked off showing no *cracking, peeling or brittleness of insulatio.*,,.

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Plant ID No. M0-2~2301-5, SMB-3-lOO; E Documentation File C D-017512 This MO, in Unit 2 is located directly above the torus at

. the 513 ft. 9 in. elevation and is on the main steam supply line outboard isolation'valve. The inspection revealed badly deteriorated jacketing over the insulation on the in-coming field wiring. *The licensee contends that the actual insulation is sound, however, the condition-of the in~ulation was difficult to inspect since it was covered by the jacke There was evidence of oil or grease leakage around the motor and inside the limit switch housing. There were scrapes and cuts on cable jackets resulting from being pulled past sharp conduit edges with no protectio_n in conduit ports to. prevent this damag *

. c *. Plant ID No. M0-2-1501-3A (EQ Documentation Fi~e CQD-017504)

. This MO,.in Unit 2 is located in the south east corner room at the 490 ft. elevation~* on the service water outlet valve in the Low Pressure Cool ant Injection ( LPCI) system. * There*

are two conduit ports on the limit switch housing both having sharp edges expose One has a bushing which apparently became loose and.slipped out onto the oncoming wir The other port has no protective bushing..

• Plant ID No. M0-2-1501-218 (EQ Documentation File*CQD-017511) This MO, in Unit 2, is located at the 521 ft. elevation in the torus roo It is part of in the LPCI system. There wa*s grease weepage at.the motor/actuator housing junction and inside the limit switch housin There appeared to be severe grease leakage around the auto/manual lever at the top of the gear bo *

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D\\,lring'--the. plant walkdown the NRC inspection. team inspected the limit switch assembly within the.limit switch housing and observed* the following:

(1) several broken lugs; (2) *

several defective lug connections~ (3) cracked, and nicked insulation on wire; (4) several corroded contacts; (5)

grease in the torque switch rotor area; and (6) on cables from a leaking torque switch cove.

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The NRC inspectiori t~am concluded that the preservation of qualified status for a 40 year QL, for th~ above Limitorque MO's, (paragraphs 4.H(l)a thru 4.H(l)e were not being ~aintained due to improper installation and/or lack of surveillance, main-tenance, and training of personnel. This is a Potential Enforce-ment/Unresolved Item (50-237/86013-05; 50-249/86015-05).

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(3) Westin house LPtI Room Coolin Fan Motors* Unit 3 Plant ID No.*

3-5746

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pu~ing the plant walkdown, the NRC inspection team examined the

_*:,IJnJt 3, LPCI room cooling fan motor, Plant ID No. 3-5746 Plant

:*'personne r.*had added several layers of tape on the motor leads to provide added protection w~ere the-leads enter the motor housin Power lead to motor lead splices were covered with Raychem splice kits. The outer sleeve of the splice kit extended*ov~r the braided motor leads, however, the work request for the installation of this motor had a note which requ i. red the braid to be removed from the wire in the area of the splice. The outer sleeve of the splice had a glossy appearance and there was a visible flow of red adhesive outside the outer sleeve, indicating a nuclear grade splice had been used and the shrinkage was complete. Without destroying the splice the NRC inspector could not determine if the braid extended into the splice ~re *

The inspector expressed concern that without QC verification that the splice had been properly assembled (braid temoved ftom the*

bond area), qualification of the installed configuration may not be assured. Splice installation inst~uctions/inspection. is

• considered an Open Item to be c 1 osed during a subsequent NRC inspection (50-249/86015-16).

(4) General Electric LPCI Pum* Motor Unit 2 and 3 Plant ID Nos. 2-1502 an 3-50 During the plant walkdown, the NRC inspection team examined the Unit 2 and 3 trains LPCI pump'motor The motor~ installed wete similar to the model and range qualified. These motors were 700 horse power, vertically mounted motors. *The splices between motor leads and plant power cables were taped.as_ they were during qualification. Maintenance records identified that additional outer layers of tape had been installed during October 198 The initially installed tape was qualified to. meet th_e plant conditions, however, the ltcensee did not have the necessary environmental

• qualification documentation in the EQ file. *Qualification docu- *

mentati~n is available for the newly installed tap (5) - General Electric Core Siray Pump Motors Units 2 arid 3, Plant ID

Nos. 2-1401A and 3-1401

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Dur~ng the 'plant walkdown, the NRC inspection team exa~ined th~

Unit 2 and 3, train A core spray pump motor The motors in-stalled were 800 horsepower, vertically mounted motors and were similar to the mode 1 and range qua 1 if i e The s pl ices between motor leads and plant power cables were taped as they were during

• type test qualification~ *Maintenance records identified that additional outer layers of tape had been instal*led during October 198 The inspector noted a pit in the cover of the Unit 2 cast tron junction box which might ~ave been caused by an insulation

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breakdown and arc over from the power cabl The tape on the phase C.power lead (which would have been the closest cable to the area where the pit in the cover was found) also appea~ed to be frayed in the general area of the cover. This area of the

_.splice was found t6 be softer when. examined._ The licensee

• • prepared a work request to perform -the necessary repairs on these s p 1 ice This item is considered an_ Open _Item and*is required-to be closed out by a subsequent NRC inspection (50-237/86013-16; 50-237/86015-1~.

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Chromalux Electric Air Heaters Model No. TDH-30C Plant ID N D007503AH10 The inspection team's review of EQ documentation:contained in the files indicated that periodic visual inspection and: functional testing was required to maintain the heater EQ status. Work Request No. 42175 which performed the required surveill~hce activities was reviewed and found acceptable. During.the physical

- inspection of the equipment the inspector f6und numerous examples of black electric tape on field run cable and termination At the time of the inspection, the function of this tape and how it came to be installed could not be determine *

This item is considered an Open Item to be closed out by a subsequent NRC inspection (50~237/86013~17).

(7)

Anaconda Seal Tight Conduit (Unit 2)

The inspection tea~ examined a l" An~conda flex seal tight conduit connected to ih~ MSIV 2-203-lB at elevation 517 in the Unit 2

drywe 1 The inspector observed a 2" di a meter ho 1 e in the outer jacket of this conduit, exposing the metal of the condui Damage

• to the conduit was determined to be due to the conduit touching a hot pip The inspector was concerned that th.e EQ cable in the conduit may have been affected; The licens~e issued a Work Request No. 54534 to correct this proble This item is considered an Open Item to be close-d out by a subsequent NRC i~spection (50-237/86013~18).

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