IR 05000237/1990020

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Enforcement Conference Repts 50-237/90-20 & 50-249/90-20 on 900810.Violations Noted.Major Areas Discussed:Failure of Environ Qualification (EQ) Program to Ensure EQ of Certain Electrical Splices
ML17202U795
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 08/16/1990
From: Gardner R, Kopp M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17202U793 List:
References
50-237-90-20-EC, 50-249-90-20, NUDOCS 9008270037
Download: ML17202U795 (48)
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U. S. NUCLEAR REGULATORY COMMISSION REG ION II I Reports No. 50-237/90020(DRS); ~0-249/90020(DRS)

Docket Nos:

50-237; 50-249 -

Lice~s~s No. DPR-19; No. DPR-25 Li~ensee: Commonwealth 'Edison Company Opus West III 1400 Opus Place Do~ners Grove, IL 60515.

. Facility Name:

Dresden Nuclear Power Station - Units.2 and 3 Meeting A.t:

U. S. Nuclear Regulatory Commissio Region III Office

Glen Ellyn, IL 60137 Meeting Cbnducted:

August. 10, 1990

  • Type of Meeting:

Enforcement Conference Inspector:

M. J.. opp

_

Appr~ved By: *~*~G.~

Plant Systems S~ction Meeting Summary

  • Date

~ l {(, J<to Date Meetin on August 10, 1990 (Re ort~ No. 50-237/90020(DRS); No. 50-249/90020(DRS))

Matters Discusse :

pparent v10 at1ons o R

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, aragrap s an (j), concerning failure of the Environmental Qualification (EQ) prdgram to~

ensure the EQ of certain ~lectrical splices. and failure to establish a record*

of qualification for certain terminal blocks.and electrical enclosures with.in the scope of 10 CFR 50.4 Based on a review of the information presented by the licensee and of the NRC Enforcement Policy, the NRC Region III staff determined that escalated enforcement actions were not warranted and categorized the discrepancies as Severity Level _IV violations. *

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DETAILS 1~

Enforcement Conference Attendees*

Commonwealth Edison Co~pany (tECo)

D. Galle, Vice President, BWR Operations L. DelGeorge, Manager, Projects and Construction R. Querio, Genera.l Manager, Quality Programs J. *Abel, Director, Engineering *

T. Kovach, Nuclear Licensing L. Gerner, Technical Superintendent

  • K. Peterman, Regu 1 atory Assurance Supervisor K. Brennan, Regulatory Assurance Superviso S. H~nsader, Licensing Administrator P. Barnes, Licensing Administrator M. Richter,.Licensing Administrator R. Williams, Senior.Quality Assurance Inspector P. Manning, Nuclear Quality Prog,rams*

R. Naylor, Senior EQ Engineer M. Habor-Kovach, R~gulatory Assurance Engine~r K. Polson, EQ Cciordinator z.. Boxer, Staff'Engineer

.. Consu 1 tan ts C. Crane, Manager of Engineering, Main Line Eilgine'erif)g U. S. Nu.clear Regulatory Commiss.ion (U. S. NRC)

C. Paperiello, Deputy Regional Administrator, Region III T. Martin, Deputy Director, Division of Reactor Safety, Region III.,

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M. Ring, Chief, Engineering Branch, Divi.sion of Reactor Safety, Region 'III R. Gardner, Section Chief, Division of Reactor Safety, Region III * *

J. Hinds, Section Chief, Division of Reactor Projects, Region IJI B. Siegel, Project Manager, Nuclear Reactor Regulition, HQS M. Kopp, Reactor Inspector, Division *of.:Reactor Safety, Region III W. Schultz, Enforcement Coordinator, Region III G.. Hausman, Reactor Inspector, Division of Reactor Safety, Region. III C. Clegg.,Engineering Intern, Division of* Reactor Safety, Region III Enforcement Conference Jh~ Enforcement Conference *was held to discuss the ip~arent EQ violations of 10 CFR 50.49 identified in NRC Inspection Reports No. 50-237/90016(DRS)

and N ~249/90015(DRS). In opening the conference,*.the NRC

~tated the purpose of the conference, presented a brief description of the.events

  • that led to the apparent violations, and summarized the inspection findings lSee Enclosure 3).

The licensee was ~equested by the NRC to discuss the fo 11 owing:

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  • '*. Mhy EQ walkdowns, audits or surveillances conducted under the Dresden Environmental Qualification Program failed to identify and ensure the qualification of all electrical components required to be within the scope of 10 CFR 50.4 How the EQ programmatic concerns at the Dresden Station relate to-other Commonwealth Edi son Company facilitie The licensee presented the results of *thei~ ~eview concerning the apparent EQ violations and stated that violations had occurred in that documentation to demonstrate Environmental Qualification (EQ) of certain terminal block~

was not in Dr~sden's EQ files, and that the EQ progra~ failed to identify and ensure qualification of certain splices *. The licensee stated that the reason for the violations was due to an improper t~chnical judgment made during the EQ program de~elopment which led to the exclusion of EQ terminal blocks and splice~ located outside.of the containment are Ih addressing safety significance, the licensee stated that their assessment of the affected EQ components indicated that there was no safety significance-associated with the current finding This was based, in part, on the licensee's determination that the affected components were located in an environment that would not cause*failure or that the operating function was accomplished prior to the onset of the harsh envirbnment.. (See Enclosure 4)

The licensee disagreed with the NRC findings concerning the submergence of the *Suppression *Pool Temperature Moni'toring (SPTM) cables, and the i~sue of required ~eepholes in electrical enclosures contatning terminal blocks or tap~d spli~es located outside of the containmen The lic~nsee stated that the periodic submergence of th~ SPTM cables is a result of.

normal environmental conditions and not as a result of ~ccident condition Therefore, the l~ce-0see considered the affects of submergence as it relates to the aging of the cables and concluded that the cables would not be adversely impacted.. In addition, the licensee stated that because.the environment outside of the containment is less severe, weepholes were not required in electrical enclosure The NRC staff stated that this approach concerning weepholes was acceptable ~rovided engineering analyses ~ere

  • performed in order to justify the discrepancy between the EQ tested configuration and the installed plant configuratio *

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The licensee addressed the N~C concern regarding how the current EQ findings at Dresden affected the other Commonwealth Edison Company facilitie The *licensee stated that they had conducted an extensive EQ review at Quad Cities and found the same type of EQ deficiencies and that.

corrective actions had been take The licensee further stated that at the Byron, Braidwood, LaSalle, and Zion plants terminal blocks and splices outside of the containment were not excluded from the EQ progra Therefore, the EQ concerns at Dresderi were not ~pplicable to these site.

. NRC Review The NRC staff considered the information presented at,the Enforcement

  • Conference regarding the EQ program, the reasons for the apparent violations, and the safety significance, and determined that a programmatic breakdown did not occur with respect to the Dresden EQ program. *The NRC

staff concluded that:th~ EQ discrepancies were *a result.of an isolated error in the technical judgment to exclude certain EQ components located outside of the contairimen The NRC review of the weephole issue concluded that while weepholes may *

not.b.e required outside of the drywell; the licensee is required to

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justify, by engineering. analyses, that d significant amount of moisture.

  • intrusion would not occur such that the contents of the enclosures would *

fail to perform their required functipn The NRC staff concluded that

~ubmergence of the SPTM cables was an issue_that NR~ is pursuing ~nd would*

be discussed in subsequent communications after additional information is received from NR.*

Enforcement Actioh Two apparent violations rif NRC requirements ~ere identified during the inspectio These apparent violations were described in Inspection Reports No. 50-237/90016(DRS) and No. 50-249/90015(DRS); however, a Notice of Violation was not issued with.that report pending NRC review of information present~6 by th~ licensee at the Enforce~ent Conferenc As stated above in Section 2, the licens~e did not*present information that wo~ld cause the NRC to reconsider its finding~. Therefore, the Notice bf Violation is being issued with this repor. 'i

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  • ENCWSURE 3 DRESDB'J 8 ~FORCEMENT CONFERENCE.

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.* * EQUI~OO.QUALIFICATION CEQ) PRCXJRAM DEFICIENCIES*.

AUGUST 10~ 1990

  • : REFERENCE:. INSPECTION REPORTS NO. 50-237/9CXll5;

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NO. 50-249/gx)l6 *

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NUCLEAR REGULATORY CXJ1'1ISSION/CCMVONWEALTH EDISON C(JV\\f>ANY DRESDH~ ENFORcrnJ IT CONFERENCE EQUIPMHIT QUALIFICATION <EQ) DEFICIENCIES AGENDA

. AUGUST 10, l~

OPENING REMAPJANY TI 0 I W\\RTIN' DEPlJTY DI RECTOR DIVISION OF REACTOR SAFETY

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EQ PROGRAM DEFICIENCIES DRESDEH NUCLEAR PU/ER.STATION BACKGROUND

  • .. * NP,C. EQ FOLLCllUP.iNSPECTiot-1. AT DRESDHI STATION IN APRIL 1989, IDENTIFIED

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CONCERNS REGARDING TI-IE LACK OF REQUIRED WEEP 80LES IN EQ JUNCTION BOXES CONTAINING W\\RATI10N *TERMINAL BLOCKS. *,

  • *. TIIE LICENSEE PERFOPJ'fi). SAMPLE WALKOOi.t~ AND IDBffIFIED 8 EQ JL~~CTION. * *

. '. BOXES WI1HOITT 1HE REQUl RED WEEP HOLES I

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TitE LICB~EE ALSO PERFO~ WALKOOWNS OF 4 DC POl/ERED HPCI f/Ov's AND IDENTIFIED 1 EQ JUNCTICJI BOX WITH A MISSING WEEP HOLE lHAT CONTAINED 1m1INAL BLOCKS OF AN UNKNCMN lYF£ I

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LER '237/8r.m5 00a.mrrtD THE CECo caiMIOOIT TO PEPf0"'1 INSPECTIONS OF ALL EQ TrnviINATIONS LOCATED IN JUNCTION-BOXES, CONDUIT BODIES, AND PULL

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BOXES TO ENSURE ENCLOSURE COfCIDITS WERE QUALIFIED AND THAT THE REQUIRED wtEP HOLES WERE INSTALLE UNIT 3 EQ INSPECTIONS HAVE BEEN C(Jviplffi] wrrn UNIT 2. INSPECTIONS TO BE

~LETED IN FALL I99o.

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I EQ PROGRAM DEFICIENCIES

  • DRESDEN NUCLEAR POilER STATION
  • POTENTIAL VIOLATIONS *

10 CFR 50 *. 49(A): REQUIRES EACH HOLDER OF A LICENSE TO OPERATE A NUCLEAR.

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PO.iJER PLANT TO ESTABLISH A PRCXJRAM FOR QUALIFYING SAFElY-RELATED ELECTRICAL EQUIFt'llliL NONSAFElY-RELATED *El_ECTRICAL EQUIWflff WHOSE FAILURE COULD PREvsff ntE SATISFACTORY FULF.ILLYENT OF A SAFETY FUNCTION, AND CERTAIN.

POST-ACCIDOO tilNITORING EQUIWO '*"\\:

  • * io* CFR 50.49CF) REQUIRES TIIAT EACH ITEM OF B£CTRICAL EQUIPf'lm. IrvPORTAr*rr * *

TO SAFETY, BE QUALIFIED BY TESTING AND/OR.*ANALYSIS OF AN IDENTICAL ITEM-OF EQUIOOff UNDER IDOOICAL CDNDITIONS, OR A SIMILAR ITEM OR UNDER.,

SIMILAR CoNDITIONS WITH A SUPPORTING.ANALYSIS TO SHCJ.vl THAT 1HE EQUIOOfl" TO BE QUALIFIED IS ACCEPTABL. CONTRARY TO THE ABOVE, THE LICENSEE'S wAL..KbcMNs IDENTIFIED THE FOLLClH~G EQ CXJ'IPCmITS WHICH WERE NOT PROPERLY QUALIFIED BY EQ TESTS AND/OR ANALYSIS:

SIX TrnUNAL BLOCKS, INSTALLED IN EQ CIRCUITS, HAVING AN UNOOWN

. MANUFACTURE.

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POIDITIAL VIOLATIONS

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  • 16 -TAPED SPLICES, INSTALLED Hl EQ CIRCUITS, HAVING AN UNKNOt/N MANUFACTURE SPLicEs MADE wrm WIRE NUTS ANP TAPE~ INSTALLED IN EQ CIRCUITS,

. HAVING AN UNKNCJiiJt~ MANUFACTUHER *.

FOUR GENERAL ELECTRIC 29ED *SERIES TE~INAL BLOCKS, INSTALLED IN EQ CIRCUITS I THAT HAD NOT BEB*J EQ 'TESTf] I SIX SPLICES MAPE WI11t VOLTREX HEAT SHRINK TUBING, INSTALLED IN EQ

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CIRCUITS, THAT HAD NOT BEB~ EQ TESTE SUPPRESS!~ POOL IB'PtRATURE ~'ONITORING CABLES, INSTALLED IN TH TORUS R00'1, WHICH HAVE BEEN SUPJIERGED AT VARIOUS TiflfS SINCE THEIR.

INSTALLATION IN 1983 FOR WHIG! THE EQ TEST DID NOT INCLUDE ADEQUATE SUPJIERGED.CONDITIONS I

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APPROXIMATaY 61 ELECTRICAL ENCLOSURES CONTAINING EITHER EQ Trn"IINAL *

BLOCKS OR EQ SPLICES WERE MI~ING THE REQUIRED WEEP HOLE ONE ru~HENOL CONNECTOR, INSTALLED rn AN rn c 1 RCUIT, HAD rm BEEN EQ TESlED.

POIDITIAL VIOLATIONS

10 CFR 50,49(J) REOUiRES-A RECORD OF QUALIFICATION BE MAINTAINED IN AN AUDITABLE F0~1 FOR THE Ef'ITIHE PERIOD IN WHICH THE COVERED IIDl IS msTALLED rn THE PLANT *

. - _ CONTRARY TO THE ABOVE, THE LICENSEE'S EQ FILE DID NOT CONTAIN EQ 1ESTS_

AND/OR ANALYSIS HHI-CH DOONSTHATED THE QUALIFICATION OF 63 GENERAL ELECTRIC TEW.IMAL BLOCKS AND 59 MARATHON 1500 TE~HNAL BLOa<s* INSTALLED

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ENFORCEMBIT CONFERENCE DISCUSS I ON TOP I CS

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DISCUSS WHY EQ WALKDOWNS,* AUDITS OR SURVEILLANCES CONDUCTED UNDER *TH DRESDEN EtNIRONl"ENTAL QUALIFICATION PRCXJRAM FAILED TO IDENTIFY AND ENSURE THE QUALIF.ICATION OF ALL ELECTRICAL OWONENTS REQUIRED TO BE WITHIN THE SCOPE OF 10 CFR 50.49 *.

. DISCUSS Ha~ THE EQ PROGRM1'1ATIC CONCERNS AT THE DRESDEN STATION PaATE TO OTHER C(Jtf<'ONWEALTH EDISON ~ANY FACILITIE I

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ENCLOSURE 4 AUGUST 10,*1990 DRESDEN ENVIRONMENTAL QUALIFICATION ENFORCEMENT CONFER.ENCE

.AGENDA INTRODUCTION OVERVIEW OF DRESDEN'S EQ PROGRA OVERALL CONCLUSIONS

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D.GALLE J.ABEL.

D.GALLE

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CECo O\\TERYIEW AREA OF AGREEMENT

A VIOLATION DID EXIST IN THAT CERTAIN DOCUMENTATION TO DEMONSTRATE ENVIRONMENTAL QUALIFICATION WAS NOT IN DRESDEN'S EQ FILE REASON: SOME TERMINAL BLOCKS WERE EXCLUDED FROM THE EQ PROGRAM BASED ON AN IMPROPER TECHNICAL JUDGMENT MADE DURING EQ PROGRAM DEVELOPMEN DOCUMENTATION DID EXIST TO DEMONSTRA.TE QUALIFICATION BUT WAS NOT INCLUDED IN DRESDEN'S EQ FILE THERE fs NO SAFETY SIGNIFICANCE SINCE THE TERMINAL BLOCKS WERE QUALIFIABL * * A VIOLATION DID EXIST IN THAT THE EQ PROGR.t\\M FAILED T IDENTIFY AND ENSURE QUALIFICATION OF SOME SPLICE REASON: EXCLUSION OF THE TERMINAL BLOCKS CAUSED

'OMISSION OF THESE SPLICES FROM. DRESDEN'S EQ PR()GRAM..

THEREFORE,.DOCUMENTATION WAS NOT AVAILABLE TO ESTABLISH QUALIFICATION OF THESE SPLICER THE DEFICIENT SPLICES WERE ASSOCIATED WI'l'H ONLY-FOUR PIECES. OF EQUIPMENT. ;. *.. _. _*f*/.*

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THE SAFETY SIGNIFICANCE:IS 'MINIMAL SINCE THE *.

AS-INSTALLED SPLICES WOULD HAVE ALLOWED THE,-... :.

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ASSOCIATED EQUIPMENT TO PERFORM ITS INTENDED SAFETY FUNCTIO *.. ~

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AREA OF APPARENT DISAGREEMENT

  • . WE BELIEVE WEEPHOLES ARE NOT REQUIRED FOR INSTALLATIONS OUTSIDE CONTAINMENT. WEEPHOLES wERE REQUIRED FOR INSID CONTAINMENT.AND EXISTE *

WE :BELlEVE THE SUPPRESION POOL TEMPERATURE MONITORING

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CABLES INSTALLED IN THE TORUS ROOM ARE QUALIFIED FOR THEIR INTENDED.FUNCTION. WE RECOGNIZE THERE IS AN.ONGOING *.

NRC/INDUSTRY REVIEW OF SUBMERGENC KEY POINTS

CECo HAD PLANNED FOR EQ C_IRCUIT WALKDOWNS TO BEGIN IN 198..

BASED ON NRC'S REVIEW OF THE WEEPHOLE ISSUE AND *cECo's.

. IDENTIFICATION OF QUESTIONABLE TERMINAL BLOCKS, IMPLEMENTATION OF THE WALKDOW~{WAS ACCELERATED. *

THE CUMULATIVE RESULTS OF. WALKDOwNS PERFORMED HAs DEMONSTRATED THE DRESDEN*EQ PROGRAM TO BE EFFECTIVE. THIS CONCLUSION IS REINFORCED BY THE LIMITED NUMBER AND NATURE OF THE DEFICIENCIES THAT WERE IDENTIFIED IN THE :MOST RECENT WALKDOW CECo's PRESENTATION WILL DISCUSS THE VIOLATIONS SPECIFIC TO DRESDEN

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THEIR APPLICABILITY :TO OTHER CECO STATIONS

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CECo's EQ PROGRAM EVALUATIONS HA VE BEEN EXTENSIVE AND NUMEROUS BOTH PRIOR TO AND FOLLOWING IMPLEMENTATION OF THEEQRUL /scl:ID146:3

EQ EQUIPMENT IDENTIFICATION MASTER EQUIPMENT LIST _

GENERAL USE COMPONENTS

EQ QUALITY VERIFICATION!I'HIRD PARTY REVIEWS

DRESDEN 1989-1990 WALKDOWN RESULTS SPECIFIC ISSUES BASIS FOR-ENVIRONMENTAL QUALIFICATION CURRENT STATUS SAFETY SIGNIFICANCE *

NRC ISSUE REGARDING IMMERSED/WETTED CABLE

APPLICABILITY OF DRESDEN CONCERNS TO OTHER CECo FACILITIES

EQ PROGRAM CONCLUSIONS -

CORRECTIVE ACTIONS

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.. EQ EQUIPMENT IDENTIFICATION IE BULLETIN 79-0lB

JANUARY, 1980-IE BULLETIN 79-0lB ISSUED WITH DOR GUIDELINES CITED AS CRITERIA TO BE USED IN EVALUATING THE ADEQUACY OF SAFETY-RELATED ELECTRICAL EQUIPMENT QUALIFICATIO NRC REQUESTED "MASTER*LIST" OF ESF SYSTEMS/COMPONENTS

  • MASTER SYSTEM LIST.

1980-1985-DRESDEN'S MASTER LIST OF. SYSTEMS AND COMPONENTS.

DEVELOPE *. * MASTER SYSTEM LIST PREPARED*

IDENTIFIED ALL SYSTEMS REQUffiED TO FUNCTION UNDER POSTULATED ACCIDENT CONDITIONS AND.PLACED THEM O 'THE MASTER LIST

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EQ EQUIPMENT IDENTIFICATION <continued)

SThTEM COMPONENT LISI' OF MAJOR ELECTRICAL EQUIPMENT PREPARED

  • . REVIEWED P&ID'S, DRAWINGS, FSAR AND OTHER DOCUMENTS TO IDENTIFY ELECTRICAL COMPONENTS AND INSTRUMENT *. COMPONENT LOCATIONS WERE REVIEWED TO*DETERMINE WHICH ITEMS
  • WERE IN A HARSH ENVIRONMEN ~.' *,

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ENVIRON~ENTAL CONDITIONS WERE ESTABLISHED FOR EQUIPMENT ON THE MASTER COMPONENT LIS VERIFICATION WALKDOWNS FOR NAMEPLATE DATAWERE PERFORMED FOR THESE COMPONENTS COMPONENTS NOT LOCATED IN A HARSH ENVIRONMENT WERE DELETED FROM THE LIST..

COMPONENTSliNSTRUMENTS REQUIRED TO PROVIDE SYSTEM.

OPERATIONAL INFORMATION REQUIRED BY-THE-STATION OPERATOR TO MITIGATE AN ACCIDENT WERE ALsO PUT ON THE MASTER COMPONENT LIS...,

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EQ EQUIPMENT IDENTIFICATION (continued)

GENERAL USE COMPONENT IDENTIFICATION

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1980-1985-THE TYPES OF GENERAL USE COMPONENTS (I.E. TERMINAL BLOCKS, SPLICES) WERE IDENTIFIE /scl:ID146:7 REVIEWED SCHEMATICS/DIAGRAMS TO IDENTIFY IT~MS THAT SUPPORT THE ELECTRICAL COMPONENT'S FUNCTIO A REVIEW OF CONTRACT FILES FOR PROCUREMENT OF GENERAL.

USE ITEMS AND DISCUSSIONS WITH PLANT PERSONNEL WAS PERFORMED TO IDENTIFY INSTALLED, SPECIFIC GENERAL USE COMPONENTS (I.E. TERMINAL BLOCKS AND SPLICES).

W ALKDOWNS WERE PERFORMED FOR AREAS EXP.ECTED T * EXPERIEi:\\~CE FULL LOCA ENVIRONMENT CONDITION ACCESSIBLE JUNCTION BOXES WERE *WALKED DOWN IN THE DRYWELL, STEAM TUNNEL AND SBGTS. GENERAL USE COMPONENTS IN THESE AREAS WERE IDENTIFIE EQUIPMENT LOCATIONS WERE REVIEWED TO DETERMINE.

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WHICH ITEMS *WERE IN A HARSH ENVIRONMENT.* ITEMS NOT*

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LOCATED IN A HARSH ENVIRONMENT WERE DELETEp FROM THE

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LIS.

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EQ EQUIPMENT IDENTIFICATION <continued)

FOR TERMINAL BLOCKS LOCATED IN AREAS NOT PREVIOUSLY WALKED DOWN, IT WAS BELIEVED THAT THEY WERE IN A RADIATION ONLY ENVIRONMENT AND MADE OF PHENOLIC MATERIAL WHICH HAD A RADIATION THRESHOLD HIGHER THAN THE HIGHEST RADIATION LEVEL TO WHICH THEY COULD BE EXPOSED IN THE PLAN * *

A TECHNICAL JUDGEMENT WAS MADE THAT, AS TO THE MATERIALS l.ISED IN THE BLOCKS, THEY WERE IN A *

RADIATION ONLY ENVIRONMENT (CONSIDERED TO BE MILD

.FOR THE TERMINAL BLOCKS) AND NOT INCLUDED IN THE EQPROGRA '*

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WALKDOWNS OF ELECTRICAL ENCLOSURES IN THESE OTHER

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. AREAs WERE NOT PERFORMED -BECAUSE THESE AREAS WERE

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CON~IDERED MILD FOR THE TYPES OF COMPONENTS INSTALLE *.

. *CONCLUSION THE PROGRAM, AS IMPLEMENTED, DID NOT INCLUDE TERMINAL BLOCKS

. OUTSIDE OF THE DRYWELL, STEAM TUNNEL AND SBGTS. BECA.USE OF THIS, THERE WERE NO WALKDOWNS TO INSPECT ELECTRICAL*ENCLOSURES IN.

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. THESE.AREAS AND, THEREFORE, SOME cb~ONENTS WERE NOT ti>ENTIFIE.

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. EQ QUALITY VERIFICATION/rHIRD PARTY REVIEWS

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CECoQAAUDITSISURVEJLLANCES ANNUAL AUDITS OF THE EQ PROGRAM BEGAN IN 1982. THE AUDIT'S

. PERFORMED WERE PROGRAMMATIC AND ADDRESSED EQ

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DOCUMENTATION TO ASSURE THAT PROGRAM REQUIREMENTS WERE BEING ME EQ RELATED SURVEILLANCES BEGAN IN 1986 AND WERE PERFORMED ANNUALLY THROUGH 1987. EQ WAS ADDED TO THE QUARTERLY

. SURVEILLANCE SCHEDULE IN MID-1988. QA COVERAGE TYPICALLY INCLUDED ACTIVITIES SUCH AS MAINTENANCE OF EQ EQUIPM~NT, EQ

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BINDER/STATION PROCEDURE REVIEWS AND HOLD POINTS FOR RAYCHEM SPLICE INSTALLATION WESTECREVIEWCDECEMBER1984)

A_ "PROGRAMMATIC REVIEW OF,THE EQ ACTIVITIES AND_DOCUMENTATION WAS PERFORMED,

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  • * BECHTEL'S QUALIFICATION _PACKAGES WERE FOUND TO BE IN GOOD ORDE *

IT WAS FOUND THAT THE PROCEDURES AND METHODOLOGY FOR DEVELOPMENT OF THE LIST WERE ACCEPTABL *

IT WAS DETERMINED THAT THERE WAS A LACK OF TRACEABILITY OF THE D~SIGN INPUT DOCUMENTATION USED TO DEVE,LOP THE MASTER LIS.

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BECHTEL REREV1EW <MARCH 1985>

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IN RESPONSE TO THE WESTEC EVALUA'fION, CECo DIRECTED BECHTEL TO

. DEVELOP AND IMPLEMENT A PROGRAM TO CONFIRM COMPLETENESS OF

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THE EXISTING MASTER SYSTEM AND *coMPONENT LISTS. THE BROAD CLASSES OF GENERAL USE COMPONENTS WERE NOT REVERIFIED AS PART OF THIS PROGRAM..

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WESTEC REVIEW <NOVEMBER 1987)

EXPERIENCE WITH SPLICE DEFICIENCIES LED CECo TO DIRECT A REVIEW OF THE ELE<";TRICAL SPLICE PROGRA A WESTEC EVALUATION CONCLUDED THAT "EQUIPMENT HAS BEEN WALKED DOWN, PROCEDURES ARE IN PLACE, TRAINING HAS BEEN CONDUCTED, AND PERSONNEL ARE KNOWLEDGEABLE CONCERNING EQ ISSUES. THEREFORE, IT IS REASONABLE TO CONCLUDE THAT FEW SPLICE ABNORMALITIES EXIST".

HOWEVER, WESTEC CITED THAT COMPLETE DOCUMENTATION WA LACKING TO SUBSTANTIATE THAT ALL EQ SPLICES HA VE BEE.N LOCATE NO SPECIFIC DEFICIENCIES HAD BEEN IDENTIFIED BY WESTE A R~PORT WAS ISSUED IN FEBRUARY 1988 RECOMMENDING THAT CECo..

PERFORM PARTIAL WALKDOWNS TO INCLUDE LOCAL AND INTE.RMEDIATE JUNCTION BOXES AND SOME CONDULET CECo <1988-1989).*

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CE Co ENGINEERING'S EVALUATION OF THE WESTEC REPORT RESULTED IN SUBMITTAL OF A BUDGET REQUEST FOR DRESDEN IN MARCH.1989 WHICH

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INCLUDED EQ SPLICE WALKDOWNS, CECO'SEXPENDITURE CONTROL COMMITTEE APPROVED ON APRIL 3, 1989, AN EXPENSE BUDGET FOR.

DRESDEN THAT INCLUDED APPROXIMATELY $150,000 FOR WALKDOWN /scl:ID146:10

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EQ QUALITY VERIFJICATIONtrH I RD PARTY BEVJEWS <continued>

NRC/CECo <APRU. 1989)

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NP..C CONDUCTED FOLLOWU_P INSPECTION *OF DRESDEN EQ PROGRAM~

BASED ON CECO;s DISCOVERY OF TERMINAL BLOCKS WITH QUESTIONABLE QUALIFICATION, THE PLANNED EQ CIRCUIT WALKDOWN WAS_

ACCELERATED AND INSPECTIONS BEGUN OF INTERMEDIATE JUNCTION.

BOXES, PULL BOXES AND CONDULETS WITHiN HARSH ENVIRONMENTS.**.

CONCLUSION

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CECo's QA REVIEWS OF THE EQ PROGRAM AND EQUIPMENT WERE BASED..

' o,:N THE EXISTING MASTER EQUIPMENT LIST AND vyouLD NOT HA VE

. IDENTIFIED GENERAL USE COMPONENTS.EXCLUDED FROM THE_ LIS THE 1985 BECHTEL 'REREVIEW DID NOT IDENTIFY THE EQUIPMENT OF.. *

CONCERN AND IDENTIFIED NO OTHER CLASSES OF EQUIPMENT EXCLUDED

'

'

FROM THE PROGRAM. REVIEW OF INTERNAL DOCUMENTATION LEADS ONE.

TO CONCLUDE THAT THE TECHNICAL JUDGMENT TO EXCLUDE TERMINAL BLOCKS BASED ON MATERIAL (PHENOLIC) AND ENVIRONMENT (RADIATION ONLY) CONTINUED TO BE HELD THROU(}H 198 THE SPLICE PROGRAM REVIEW AND suBSEQUENT W ALKDOWN WAS,.*

~ -~:. ',.

-:. ~ *.-. -"'".... -

_INITIATED BY CECo TO ENSURE THE EQ PROGRAM WAS MAINTAINED

.. ~--

CURRENT AND COMPLETE BASED ON BQTH INDUSTRY AND OUR OWN EXPERIENCE. GIVEN TIME, THE "HAND-OVER-HAND" CIRCUIT WALKDOWNS AUTHORIZED AND IMPLEMENTED BY CECo IN 1989 WOULD HAVE IDENTIFIED THE EQ FINDINGS SUBJECT TO VIOLATIO /scl:ID146:11

..

DRESDEN 1989 & 1990 WALKDOWN RESULTS.

  • *

DURING AN APRIL 1989 NRC INSPECTION OF AN ELECTRICAL

,

.

ENCLOSURE FOR WEEPHOLES CECO IDENTIFIED TWO TERMINAL BLOCKS IN A CABLE PULL BOX ASSOCIATED WITH A HPCI MOV WHICH WERE NOT COVERED BY AN EQ BINDE TERMINAL BLOCKS WERE REPLACED WITH QUALIFIED SPLICE A PLANNED CECo EQ SPLICE-WALKDOWN WAS ACCELERATED TO INSPECT JUNCTION BOXES, PULL BOXES AND CONDULET *~*

,,

A COMPLETE "HAND-OVER-HAND" W ALKDOWN WAS BEGUN OF *

INTERMEDIATE JUNCTION BOXES, PULL BOXES AND CONDULErs:

.

.

WITHIN HARSH ENVIRONMENTS.* THE UNIT 2 W ALKDOWNS AR APPROXIMATELY 68% COMPLETE AND THE UNIT 3 W ALKDOWNS ARE.

100% COMPLETE. THESE W ALKDOWNS TO DATE HA VE IDENTllflED.

THE FOLLOWING ISSUES:

.

.

TERMINAL BLOCKS NOT INCLUDED IN OR NOT COVERED BY AN EQ BINDE CABLE SPLICES NOT COVERED BY A EQ BINDE.

.

REQUIREMENTS FOR WEEPHOLES IN JUNCTION BOXES OUTSIDE CONTAINMEN /scl:ID146:12

....

\\

.

WALIIDOWN BESULTS-TERMINAL BLOCKS NRC ISSUES <JULY 1990>

EQ FILES DID NOT CONTAI~ EQ TESTS AND/OR ANALYSES WHICH DEMONSTRATED QUALIFICATION OF 63 GENERAL ELECTRIC TERMINAL BLOCKS AND 59 MARATHON 1500 TERMINAL BLOCKS WHICH WERE FOUND INSTALLED IN EQ RELATED CIRCUIT * * APPROXIMATELY SIX TERMINAL BLOCKS WERE INSTALLED IN EQ CIRCUITS FOR WHICH THE LICENSEE COULD NOT DETERMINE THE

'MANUFACTURER AND CONSEQUENTLY WHETHER OR NOT THE

.

.

TERMINAL BLOCKS HAD BEEN EQ TESTE.

.

FOUR GENERAL ELECTRIC 2960 SERIES TERMINAL BLOCKS INSTALLED IN EQ CIRCUITS WITHOUT EQ TES'l'S AND/OR ANALYSIS TO SUPPORT.QUALIFICATIO *,.*, *-*.

..

""*~Y~tiff;~:~:.. ; *

,.

. *.. *.

'*

/scl:ID 146: 13

,...,..

WALKDOWN RESULTS-TERMINAL BLOCKS <continued>

BASIS FOR ENVIRONMENTAL QUALIFICATION-NOVEMBER 1985 TERMINAL BLOCKS OF CONCER..~ ARE LOCATED OUTSIDE OF CONTAINMEN TERMINAL BLOCKS LOCATED IN AREAS*OTHER THAN THE'

.

.

DRYWELL/STEAM TUNNEUSBGTS (OUTSIDE CONTAINMENT) WERE

. NOT EVALUATED FURTHER BECAUSE IT WAS BELIEVED THAT THES AREAS WERE A RADIATION ONLY ENVIRONMENT AND, THEREFORE, DID NOT REQUIRE AN EQ BINDE THE TERMINAL BLOCKS WERE NOT ADDED TO THE MASTER

.

.

. EQUIPMENT LIST AND EQ BINDERS WERE NOT CREATED BECAUSE.

THE TERMINAL BLOCKS WERE BELIEVED TO BE MADE OF PHENOLIC'.

.

'.

MATERIAL WHICH HAD A RADIATION THRESHOLD HIGHE.R THAN THE

..

-

.

HIGHEST RADIATION LEVEL TO WHICH THEY COULD BE EXPOSED IN THE PLANT. TH"us, IN REFERENCE TO THE MATERIALS USED IN THE BLOCKS, THE TERMINAL BLOCKS WERE CONSIDERED TO BE IN A

"MILD" ENVIRONMENT AND WERE NOT ~CLUDED _IN T_HE EQ PROGRA "7*.

/scl:ID146: 14

  • *.

WALKDOWN BESULTS-TEBMINAL BLOCKS <continued>

CURRENT Sl'ATUS

THE 1989-1990 EQ WALKDOwNS HAVE IDENTIFIED THE FOLLOWING TERMINAL BLOCK DEFICIENCIES WHICH ARE LIMITED TO DOCUMENTATION CONCERN *

MARATHON TERMINAL BLOCKS (-MODEL 1500/1600) LOCATE,D IN *

HELB AND/OR RADIATION ENVIRONMENTS WERE II)ENTIFIE SPECIFIC LOCATIONS FOR THESE TERMiNAL BLOCKS WERE

. NOT LISTED IN THE EXISTING DRESDEN MARATHON EQ BINDE. TWO OF THESE TERMINAL BLOCKS WERE PROMPTLY -.

REPLACED AS SHORT TERM ACTION PRIOR TO MODEL NUMBER CONFIRMATION. THE REMAINING 62 ARE STiLL IN:

PLACE. ALL ARE ENVIRONMENTALLY QUALiFIED. *

.

'

LOCATION OF THE 28 JUNCTION BOXES ASSOCIATED WITH THESE T~RMI_NAL BLOCKS HAS BEEN INCLUDED IN A REVISION TO THE EQ BINDER.*

CONCLUSION~ MARA.THON 1500a600 TRRMTNAL BLOCKS *

THE DRESDEN EQ FILES CONTAINED ADEQUATE-DOCUMENTATION Tq:.

DEMONSTRATE ENVIRONMENTAL QUALIFIQATION OF THE MARATHON

-.-.

'....

~.~: *~

-~

......

_.1500/1600 TERMINAL BLOCKS. HOWEVER, THE SPECIFIC LOCATIONS FOR THESE TERMINAL BLOCKS WERE NOT LISTED IN THE EQ BINDE /scl:ID146:15

.*

  • I

WALKi>oWN RESULTS-TERMINAL BLOcKs (continued)

. 43 GE TERMINAL BLOCKS (MODEL CR151) LOCATED IN HELB AND/OR RADIATION ENVIRONMENTS WERE IDENTIFIED WHICH HAD NO EQ BINDER TO.SUPPORT ENVIRONMENTAL QUALIFICATIO QUALIFICATION INFORMATION DID EXIST PRIOR TO NOVEMBER 198 A NEW EQ BINDER WAS CREATED TO INCLUDE THIS DOCUMENTATIO CONCLUSION - GE CR151 THE DRESDEN EQ FILES DID NOT CONTAIN ADEQUATE DOCUMENTATION TO DEMONSTRATE ENVIRONMENTAL QUALIFICATION OF THE TERMINAL BLOCK:.

QUALIFICATION DOCUMENTATION WAS AVAILABLE PRIOR TO NOVEMBER 198 THESE TE~MINAL BLOCKS WERE QUALIFIABLE FOR THE APPLICATION. I WHICH THEY WERE INSTALLE /scl:ID146: 16

WALKDOWN RESULTS-TERMINAL BLOCKS <continued)

GE TERMINAL BLOCKS (MODEL 2960) LOCATED IN A HELB

. ENVIRONMENT WERE IDENTIFIED WHICH HAD NO EQ BINDER TO SUPPORT ENVIRONMENTAL QUALIFICATION.*

..

CINCH TERMINAL BLOCK (MODEL 141) LOCATED:IN A RADIATION ENVIRONMENT WAS IDENTIFIED WHICH HAD NO EQ BINDER TO

  • . SUPPORT ENVIRONMENTAL QUf\\LIFICATIO * MARATHON TERMINAL BLOCK (MODEL 6000) LOCATED iN A

. RADIATION ENVIRONMENT WAS IDENTIFIEffWH~CH HAD NO EQ BINDER TO SUPPORT ENVIRONMENTAL QUALIFICATIO QUALIFICATION DOCUMENTATION DIP EXISTPRIOR.TO

.

.

.

NOVEMBER 19S5 FOR EACH OF THESE TERMINAL BLOCK MODELS..,:.

NO EQ BINDER WAS CREATED FOR THESE BLOCKS BECAUSE TH~Y WERE REPLACED WITH A QUALIFIED RAYCHEM SPLICES AS SHORT TERM CORRECTIVE ACTION PRIOR TO MODEL IDENTIFICATION..

CONCLUSION-GE 2960, CINillL MARATHON 6000 Tli!RMTNAL BLOCKS TH.E DRESDEN EQ FILES DID NOT CONTAfN.~;Al>EQ~ATE DOCUMENTATION TO DEMONSTRATE.ENVIRONMENTAL QUALIFICATION OF THE SUBJECT TERMINAL

.

.

.

.

.. *i-** *.

~.

~*.. -

...

.. BLOCKS. HOWEVER, QUALIFICATION DOCUMENTATION WAS AVAILABLE PRIOR TO NOVEMBER 1985. THESE TERMIN~ BLOCKS WERE*QUALIFIABLE FOR THE.

APPLICATION IN WHICH THEY WERE INSTALLE /scl:ID146:17

'* *

!.

WAI.IO)OWN RESULTS-TERMINAL BLOCKS <continued)

TELEDYNE PENN UNION TERMINAL BLOCK (MODEL (6000)

LOCATED IN A RADIATION ENVIRONMENT WAS IDENTIFIED WHICH HAD NO EQ BINDE RADIATION QUALIFICATION DOCUMENTATION DID EXIST PRIO_R TO NOVEMBER 1985 FOR THIS MATERIA NO EQ BINDER WAS CREATED FOR THIS BLOCK BECAUSE IT WAS REPLACED WITH A QUALIFIED RAYCHEM SPLICE As SHORT TERM CORRECTIVE ACTION AT THE TIME OF IDENTFICATIO THIS TERMINAL BLOCK WAS QUALIFJABLE FOR A_

RADIATION ONLY ENVIRONMEN * CONCLUSION -TELEDYNE PENN looON.6000 TRRMINAL BwcK THE DRESDEN EQ FILES DID NOT CONTAIN ADEQUATE DOCUMENTATION TO

...

.

"

.

.

,

,-

'

DEMONSTRATE ENVIRONMENTAL QUALIFICATION OF THE SUBJECT TERMINAL BLOCK. HOWEVER, RADIATION QUALIFICATION DOCUMENTATION FOR THE BLOCK MATERIAL WAS AVAILABLE PRIOR TO. NOVEMBER 198.5. THIS TERMINAL BLOCK WAS QUAL~FIABLE FOR THE APPLICATION IN WHICH IT WAS INSTALLE SAFETY SIGNIFICANCE -AI.I. TERMINAL BLOCKS DOCUMENTATION WAS AVAILABLE TO DEMONSTRATE THAT ALL TERMINAL BLOCKS IN QUESTION WERE QUALIFIED OR QUALIFIABLE. ACCORDINGLY, THE IDENTIFIED DOCUMENTATION CONCERNS ARE NOT SAFETY SIGNIFICAN,

/scl:ID146: 18

  • .** _.,,

.,._:.4:::*::;....

~*-*: :

.

. "

WAIJIDOWN RESIJLTS.CA8I.E.SPLJCE NRC ISSUES <JULY 1990>

  • . APPROXIMATELY 12 TAPED SPLICES INSTALLED IN EQ CIRCUITS FO WHICH THE LICENSEE COULD NOT DETERMINE.THE MANUFACTURER.

AND CONSEQUENTLY WHETHER OR NOT THE SPLICES HAD BEEN EQ.

TESTE * *

TWO SPLICES MADE WITH WIRE NUTS AND TAPE THAT WERE INSTALLED IN EQ CIRCUITS FOR WHICH THE LICENSEE COULD NOT DETERMINE THE MANUFACTURER.AND CONSEQUENTLY WHETHER OR NOT THE SPLICES HAD BEEN EQ TESTED..

APPROXIMATELY SIX SPLICES MADE WITH VOLTREX HEAT SHRINK. *

TUBING INSTALLED IN EQ CIRCUITS WITHOUT EQ TESTS AND/OR_.

. *ANAJ, YSIS TO SUPPORT QUALIFICATION'..

ONE AMPHENOL CONNECTOR THAT CONTAINED A TEFLON AND REXALITE INSERT MATERIAL WITHOUT EQ TESTS AND/OR ANALYSIS TO SUPPORT QUALIFICATION.*

.-........

-

~-. *:.. :.:.

..

~... *.

/scl:ID146:19

.

,.

WALKDOWN RESULTS-CABLE SPLICES (continued}

BASIS FOR ENVIRONMENTAL QUALIFICATION - NOVEMBER. 1985

INSIDE CONTAINMENT, STEAM TUNNEL AND SBGTS AREAS, TERMINAL BLOCKS AND SPLICES WERE.IDENTIFIED AND ENVIRONMENTAL QUALIFICATION WAS DOCUMEN'.fED IN EQ BINDER *

.

.

FOR OTHER AREAS OUTSIDE OF CONTAINMENT, EQ EQUIPMENT TERMINATIONS WERE WALKED DOWN. INTERMEDIATE ENCLOSURES WERE NOT WALKED DOWN BECAUSE IT WAS BELIEVED, BASED ON

.

.

.

.

DOCUMENTATION REVIEWS, THAT SPLICES DID NOT EXIST.

.-.

/scl:ID146:20

'*

WALKDOWN RESULTS-cABLE SPLI~ (continued)

CURRENT STATUS

. THE 1989-90 W ALKDOWN IDENTIFIED FOUR PIECES OF EQUIPMENT WHICH HAD QUESTIONABLE CABLE SPLICE.MATERIAL IN THEIR ASSOCIATED CIRCUITRY. THIS EQUIPMENT IS LOCATED IN RADIATION AND/OR HELB ENVIRONMENTR

THE EQUIPMENT IDENTIFIED WITH INDETERMINATE SPLICE QUALIFICATION INCLUDE:

/scl:ID146:21 SIX SPLICES MADE OF CLOTH TAPE WRAPPED OVER PLASTIC INSULATION TAPE WERE LOCATED IN AN ASSOCIATED PULL BOX.

ON THE POWER AND CONTROL CIRCUITS OF A UNIT 2 HPCI TURBINE STEAM SUPPLY ISOLATION VALVE. THESE SPLICES WERE REPLACED DURING THE.OUTAGE IN EARLY AUGUST 1990..

TWO STUB SPLICES WITH WIRE NUTS WERE.ON A UNIT 3 REACTOR COOLAN*T POST~ACCIDENT SAMPLE VALVE. THESE.

..

.

.

SPLICES WERE REPLACED WITH QUALIFIED RAYCHEM SPLICES IN JANUARY, 199.

    • ""*

. ~-; :

WALKDOWN RESULTS;cABLE SPL.I~ <continued>

TWO VOLTREX HEAT SHRINK SPLICES WERE ON A UNIT 2 HEAT TRACE CIRCUIT TO A HYDROGEN ANAL YzER. THESE SPLICES WERE REPLACED WITH QUALIFIED RA!CHEM SPLICES IN JANUARY, 199 FOUR AMPHENOL CONNECTORS ENCAPSULATED IN VOLTREX..

HEAT SHRINK TUBING WERE INSTALLED ON INSTRUMENT CIRCUITS TO A UNIT 3 CONTAINMENT HIGH RANGE RADIATION MONITOR. A JCO HAS BEEN WRITTEN TO JUSTIFY CONTINUED.

OPERATION UNTIL REPLACEMEN *

PARTS TO REPLACE THESE DEFICIENT SPLICES HAVE BEEN ORDERED. REPAIRS WILL BE MADE, AS SOON AS

. PRACTICABLE, FOLLOWING RECEIPT OF PART CONCLUSION

THE SUBJECT SPLiCES WERE NOT IDENTIFIED AND INCLUDED IN.THE*

EQ PROGRAM. THE DRESDEN EQ FILES DID NOT CONTAIN THE NECESSARY DOCUMENTATION NOR WAS THIS DOCUMENTATION AVAILABLE TO DEMONSTRATE ENVIRONMENTAL QUALIFICATIO ~ -..

/scl:ID 146:22

,..

WALIIDOWN RESULTS-CABLE SPLICES <continued>

sAF'ETY SIGNIFICANCE

THE HPCI TURBINE STEAM SUPPLY LINE MOV IS REQUIRED TO CLOSE.

IN 34 SF.CONDS TO ISOLATE A HPCI STEAM LINE BREAK.. THERE IS NO POST ACCIDENT FUNCTIO *

  • THE PLASTIC TAPE PROVIDED THE INSULATING PROPERTIES TO SEAL THE SPLICE CONNECTION: THE CLOTH TAPE PROVIDED ABBRASION.

.

.

PROTECTION AS WELL AS INSULATING PROTECTIO * /scl:ID146:23 THE CLOTH TAPE ON THE SPLICES WAS IDENTIFIED BY

  • LABORATORY ANALYSIS TO BE A CELLULOSE MATERIAL WITH A

. WOODPITCH RESIN TYPICAL OF COMMON FRICTION TAPE..

A STEAM TEST WHICH ENVELOPES THE PLANT ENVIRONMENT (HPCI STEAMLINE BREAK> WAS CONDUCTED ON A CLOTH TAPE SAMPL *

UNDER THESE CONDITIONS THE CLOTH TAPE SHOWED NO DETERIORATION AND THE INSULATION RESISTANCE DEMONSTRATED THE LEAKAGE CURRENT WAS INSIGNIFICANT; ACCORDINGLY, CECo CONCLUDES THE MOV WOULD HA VE

.

.:.-~*..'.';~?<:;.

PERFORMED ITS INTENDED FUNCTION UNDER THE PLAN',l'

,*\\u

'

_: *
  • -;

'

SPECIFIC ACCIDENT CONDITIONS WITH THE TAPED SPLICE '.r:::. '~. '. ~-.J.t. : r:-....... *

.;.,. *

'\\.

.....

~

.-..-. ~ -

. *.-~:_-::_;~.~*:.:~ '*~*-~

~r.-

,*...

.

\\

  • . WALKDOWNRESULTS-CABLE SPLICES <continue SAFETY SIGNIFICANCE (continued>

THE REACTOR COOLANT SAMPLE SOLENOID VALVE IS A CONTAINMENT ISOLATION VALVE THAT IS REQUIRED TO FUNCTION DURIN<1.A LOCA:

-.

,*

THEV ALVE IS NORMALLY OPEN AND THE SOLENOID NORMALLY ENERGIZE FAILURE OF THE SPLICE WILL NOT PREVENT THE VALVE FRO:M PERFORMING ITS SAFETY FUNCTION,..

..

.

.

.*

THE HYDROGEN ANALYZER IS REQUIRED TO MONITOR CONTAINMENT ATMOSPHERE AFTER A LOC /scl:ID146:24 THE ANAL Y2ER WITH THE SPLICES OF CONCERN IS REQUIREP *

TO FUNCTION IN A RADIATION ONLY ENVIRONMEN THE ONE YEAR POST ACCIDENT DOSE WILL NOT EXCEED THE RADIATION THRESHOLD.DOSE FOR DAMAGE OF THE VOLTREX SPLICES:

. -.:---

__ -:..

WALKDOWN RESULTS-CABLE SPLICES (continued)

SAFETY SIGNIFICANCE (continued)

THE CONTAINMENT HIGH RANGE RADIATION MONITORIS REQUIRED TO FUNCTION TO MONITOR CONTAINMENT RADIATION LEVEL AITER ALOC THE MONITOR WITHTHE SP~ICES OF CONCERN IS &EQUIRED TO FUNCTION IN A RADIATION ONLY ENVIRONMEN THE VOLTREX SPLICES PROVIDE ENCAPSULATION AND PROTECTION FOR THE AMPHENOL CONNECTOR THE MATERIALS USED FOR THESE SPLICES.WE'ftE EVALUATED

, WITH RESPECT TO THE ONE YEAR POST ACCIDEN.T DOSE. IT WAS*

DETERMINED THAT THE MATERIAL WOULD NOT DEGRADE TO A DEGREE THAT WOULD CAUSE A FAILURE OF THE RADIATION

~ONITOR TO PERFORM ITS POST-ACCIDENT FUNCTIO CONCLUSION FOR SAFETY SIGNIFICANC BASED ON THE ANALYSES PERFORMED~ THE SUBJECT EQUIPME~T *WOULD

.. '.'-:_2 :::~' !

.

.

HA VE PERFORMED ITS INTENDED FUNCTIONS UNDER.THE PLANT

..

.

.<~:;*::~*- *:i;7)v.. ~**

--:~~*,.-. -* *..

    • .:~::*~};_--:;.?=~~-.~~~:-.

SPECIFIC ACCIDENT CONDITIONS; NOT WITHSTANDING THE * *.,~,.

.

ENVIRONMENTAL QUALIFICATION STATUS OF THE SPLICE CONFIGURATIONS AS INSTALLED. THEREFORE, THE SAFETY SIGNIFICANCE ASSOCIATED WITH THESE DEFICIENCIES IS MINI:MAL.

/scl:ID146:25

.. '

WALKDOWN RESULTS-WEEPBOLES

..

NRC ISSUES <JULY 1990>

APPROXIMATELY 61 ELECTRICAL ENCLOSURES CONTAINING EITHER TERMINAL BLOCKS OR SPLICES AND REQUIRED TO HA VE WEEP HOLES WERE FOUND INSTALLED IN THE PLANT WITHOUT WEEPHOLES..

BASIS FoR ENVIRONMENTAL QUALIFICATION - NOYJ'RRR. 1985 THE TEST CONFIGURATION DURING QUALIFICATION TESTS OF

'l'ERMINAL BLOCKS INCLUDED JUNCTION BOXES WITH WEEPHOLE THESE TESTS WERE CONDUCTEI? FORTHE MOST SEVERE ENVIRONMENT THAT WOULD BE ENCOUNTERED - A LOCA ENVIRONMENT.:

WEEPHOLES ARE INSTALLED IN ELECTRICAL ENCLOSURES TO ALLOW.

'*

.

FOR PRESSURE EQUALIZATION AND DRAINING OF MOISTURE ACCUMULATION wHICH WOULD BE EXPECTED IN A LOCA ENVIRONMEN IN DEVELOPING THE EQ BINDER FOR TERMINAL BLOCKS CE.C DETERMINED THAT WEEPHOLES WERE REQUIRED FOR INSTALLATIONS INSIDE CONTAINMENT (LOCA ENVIRONMENT).~

.

.

    • 0~

.

<.:*.:';***::.*

.

...... :*~> ~*~~-;. *.:..

SINCE WE BELIEVED THE JUNCTION BOXES OUTSIDE co:NTAINMENT WERE NOT REQUIRED *TO BE EQ, THERE WAS NO REQUIREMENT

..

ESTABLISHED *FOR WEEP.HOLES FOR INSTALLATIONS OUTSIDE CONTAINMENT.

/scl:ID146:26

- - ~~.-~-!:

  • W.ALKDOWN RESULTS-WEEPHOLES <continued)

CURRENT STATUS THE 1989-90 WALKDOWN IDENTIFIED 58 ENCLOSURES THAT.DID NOT CONTAIN WEEPHOLES. OF THE 58 ENCLOSURES IDENTIFIED: -

36 ENCLOSURES CONTAINEDQUALIFIED RAYCHEM SPLICE *

7 ENCLOSURES CONTAINED TERMINAL BLOCKS.THAT HAD CIRCUITS WHICH ARE NOT REQUIRED TO OPERATE DURING AN ACCIDEN *

4 ENCLOSURES ARE LOCATED IN RADIATION ONLY ENVIRONMENT * *

THESE 47 ENCLOSURES DO NOT REQUIRE WEEPHOLE *

THE REMAINING 11 ENCLOSURES ARE IN RADIATION/HELB

  • * *

ENVIRONMENT..

...

9 ENCLOSURES CONTAINED TERMINAL BLOCKS AN ENCLOSURES CONTAINED QUALIFIED TAPE SPLICE *

THE COMPONENTS ASSOCIATED WITH THE CIRGUITRY CONTAIN.EDIN THESE ENCLOSURES ARE REQUIRED TO

,

FUNCTION WITHIN THE FIRST 60 SECONDS OF AN ACCIDENT..

BASED ON A CONFIGURATION W ALKDOWN OF THESE

.ENCLOSURES AND CONSERVATIVE CALCULATION, A STEAM

  • ENVIRONMENT WOULD RESULT IN NO APPRECIABLE.

CONDENSATION IN THE E~CLOSURES PRIOR TO PERFORMANCE OF THE REQUIRED FUNCTIO *

SINCE A SIGNIFICANT ACCUMULATION OF WATER WOULD NOT OCCUR, WEEPHOLES ARE NOT NECESSARY TO

.

.

.

. ENVIRONMENTALLY QUALIFY THE 11 ENCLOSURES *. *.

.

.

OUTSIDE OF CONTAINMEN *

OUTSIDE CONTAINMENT, WHEN JUNCTION BOXES WITHOUT WEEPHOLES WERE IDENTIFIED b.URING THE 1989 - 1999 _WALKDOWNS,

  • ~~~ :*

WEEPHOLES WERE PROMPTLY AND CONSERVATIVELY AI)DED TO THE.

JUNCTION BOXES WITH EQ CIRCUIT *

WALKDOWNS INSIDE CONTAINMENT VERIFIED THAT WEEPHOLES.

WERE INSTALLED AS REQUIRE /scl:ID 146:27

. '

WALKDOWN ~ULTS-WO,EEPBOLES (continued)

. CONCLUSION

WEEPHOLES ARE REQUIRED FOR ENCLOSURES INSIDE CONTAINMENT AND WERE IN PLAC *

WEEPHOLES ARE NOT REQUIRED FOR ENCLOSUR;ES OUTSIDE CONTAINMENT BUT HAVE BEEN CONSERVATIVELY INSTALLE * SAFETY SIGNIFICANCE ENCLOSURESINSIDE CONTAINMENT THAT REQUIRED'WEEPHOLES HAD WEEPHOLES PREVlOUSL Y INSTALLE ENCLOSURES OUTSIDE OF CONTAINMENT DO NOT REQUIRE THE INSTALLATION OF WEEPHOLES. A CALCULATION HAS BEEN PERFORME WHICH CONFIRMS THAT AN INSIGNIFICANT AMOUNT OF MOISTURE

  • *' ACCUMULATION WOULD OCCUR DURING THE ENVIRONMENTAL CONDITIONS TO WHICH THE ENCLOSURES WOULD BE EXPOSED.. 7 *

THERE IS NO SAFETY SIGNIFICANCE FOR ELECTRICAL ENCLOSURES WITHOUT WEEPHOLES INSTALLED OUTSIDE CONTAINMEN /scl:ID 146:28

.*-':."; -

<'.

.*

IMM'.ERSED/WEITED CABLE NRC ISSUE <JULY 1990>

THE SUPPRESION POOL TEMPERATURE MONITORING CABLES INSTALLED IN THE TORUS ROOM HAD BEEN SUBMERGED A'!' VARIOUS

  • TIMES.SINCE THEIR INSTALLATION IN 1983. THE EQ TEST FOR THESE CABLES DID NOT INCLUDE SUBMERGED CONDITION BASIS FOR ENV(OONMENTAL QUALIFICATION-NOVEMBER 1985.

THE INSTALLED CABLE IS REQUIRED TO BE OPERABLE FOR THE

.

.

FIRST ONE HOUROF A DESIGN BASIS LOCA AND IS EXPOSED TO A

..

RADIATION ONLY ENVIRONMENT. THERE IS NO OTHER POST

. ACCIDENT FUNCTION FOR THE CABLE..

THE CABLE IS NOT INSTALLED BELOW THE SUBMERGENCE FLOOD *

  • LEVEL. THE CABLE WILL NOT BE.EXPOSED TO SUBMERGENCE DUE TOA DESIGN BASIS ACCIDENT. THE CABLE WILL NOT SEE THE

. HYDROS'.{'ATIC DRIVING FORCES OF A LOC THE INSTALLED CABLE WAS MANUFACTURED BY SAMUEL MOORE AND USES EPDM INSULATIO.N WHICH MEET,S CABLE INDUSTRY STANDARD ICEA S68-516, AS STATED IN THE EQ BINDER. THIS STANDARD REQUIRES THAT THE CABLE BE CAPABLE OF

.,.... *

WITHSTANDING EXTENDED PERIODS OF WETrING. WITHOW....

SIGNIFICANT DEGRADATION O~*ABSORPTION OF WATER.'. ~~RIODIC IMMERSION OF SOME CABLE MAY OCCUR EVEN THOUGH THE

.

..

~*.

ENCLOSURES ARE ABOVE THE FLOOD LEVEL DUE TO THE. LACK,OF DRAINING FROM THE ENCLOSUR SAMUEL MOORE HAS PROVIDED LONG.TERM (1 YEAR> IMMERSION TEST DATA. THE EPR TYPE (EPDM) INSULATION OF THE CABLE HAS BEEN IMMERSION TESTED FOR UP TO 10 YEAR /scl:ID146:29

..

.*,

IMMERSED/WETl'ED CABLE (continued>

BASIS FOR ENVIRONMENTAL QUALIFICATION <continued> '

.

NO DEGRADATION WOULD BE EXPECTED FROM OCCASIONAL

. WETTING DURING NORMAL PLANT OPERATION.. THEREFORE, THE

-

.

.

.

WETTED CABLE-IS EQUIVALENT TO ANON-WETTED CABLE FOR ENVIRONMENT AL TESTING AND QUALIFICATION PURPOSES. THIS.

.

.

.

CONSISTENT WITH INDUSTRY STANDARDS ON CABLE QUALIFICATION TESTING. CONSEQUENTLY, THE QUALIFICATION TESTIN(};. :

PERFORMED ON THE NON-.WETTED CABLE ENVELOPES TH:E CAsE FO A WETTED CABLE. THIS APPROACH IS CONSIS'J'ENT WITH IEEE AND REGULATORY QUALIFICATION REQUIREMENT CONCLUSION THE ENVIRONMENTAL CONDITIONS EXPECTED FOR THE CABLE ARE BOUNDED BY THE LOCA TEST FOR WHICH.THE CABLE PASSE THESE CABLES ARE ENVIRONMENTALLY QUALIFIED IN ACCORDANCE WITH IEEE 383 (1974) FOR THIS APPLICATIO. -:.:*f

~* :~-:.~ :-. :.-.. ~;*,-..;

........

/scl:ID146:30 *

.... :

....

,.

APPLICABILITY OF DRESDEN CONCERNS TO OTHER CECO*FACILJ.Tl&5'

QUAD CITIES

THE EQ PROGRAM AT QUAD CITIES IS THE SAME AS THAT AT DRESDEN. THESE WERE DEVELOPED UNDER CECo's DIRECTION BY BECHTE *

"HAND-OVER-HAND" CIRCUIT WALKDOWNS INITIATED IN 1989 HAVE BEEN PERFORMED AND COMPLETED AT quAD CITIES. THE CURRENT STATUS IS:

104 MARATHON 1500/1600 TERMINAL BLOCKS WHOSE LOCATIONS ARE NOT LISTED IN THE EQ BINDER. THESE LOCATIONS *.

HA VE BEEN LISTED IN THE EQ BINDER. THESE TERMINAL BLOC~ WERE QUALIFIED.

. 42 GE CR151 (35 TOTAL) AND MARATHON 6000 (7 TOTAL)

TERMINAL BLOCKS FOR WHICH THERE WAS NO EQ BINDER.*

THE NECESSARY DOCUMENTATION TO ESTABLISH QUALIFICATION DID EXIST. EQ BINDERS HAVE BEEN CREATED. THESE TERMINAL BLOCKS WERE QUALIFIABL DEFICIENT SPLICES IN RADIATION ONLY ENVIRONMENT THESE SPLICES HAVE BEEN REPLACED. -

14 NON STANDARD TAPE <SCOTCH 3M) TAPED SPLICES

4 IMPROPERLY CONFIQURED RAYCHEM SPLICES

~* -

,_...

6 UNCOVEREDJ.NSULATED BUTT SPLICES

_._

  • .1*

TECHNICAL EvAtt~TIONS WERE PERFORMED FOR ALL.

.... _ -.-

=~ ! *.

..

-

.~'

.......,,

-.

DEFICIENCIES AND JCO'S WERE WRITTEN AS

._,,_:--::.~-*,

APPROPRIAT~..

_- ::_*~-::;:~::\\.

-- *...

. ::;_*"~~:f~l§~\\._*.

16 JUNCTION BOXES OUTSIDE CONTAINMENT DID NOT CONTAIN A WEEPHCfLE.-::'wEEPHOLES WERE CONSERVATIVELYADDED TO THESE JUNCTION BOXE *

THE IMMERSED/WETTED CABLE ISSUE IS NOT APPLICABLE TO QUAD CITIES BECAUSE THESE CABLES ARE INSTALLED IN A -DIFFERENT LOCATION THAN AT DRESDE /scl:ID146:31

_

.-;*::~~->.:'.. >

  • . - '* 1~.

.... ~ ~

--*

--~-;:::::_:_

.... -. ;*.**.;;,.:..

..

.

..

iJ

0... APPLICABILITY OF DRESDEN OONCEBNS TO OTDERCECOFACILITIES BYRON/BRAIDWOOD/LASALLF.fLION

THE EQ PROGRAMS AT THESE SITES WERE DEVELOPED UNDER CECo's DIRECTION BY SARGENT & LUNDY. THE IMPROPER.ITJDGMENT TO EXCLUDE TERMINAL BLOCKS BASEP ON A RADIATION ONLY

_ENVIRONMENT USED IN THE EQ PROGRAM DEVELOPMENT AT DRESDEN WAS NOT FOUND IN THE SARGENT & LUNDY PROGRAM.

.

...

.

.

BYRON, BRAIDWOOD AND LAsALLE WERE DESIGNED AND CONSTRUCTED DURING THE IMPLEMENTATION OF 10 CFR 50.49. EQ REQUIREMENTS WERE INTEGRATED INTO THE DESIGN AND CONSTRUCTED INTO THE PLAN *

NUMEROUS W ALKDOWNS AT THESE SITES HA VE NOT IDENTIFIED THE

.

-

.

.

..

.

.

.

.

TERMINAL BLOCK DEFICIENCY THAT WAS IDENTIFIED IN DRESDEN'S

. EQ PROGRA *

IN,1986-19~8, ZION STATION PERFORMED WALKDOWNS OF_EQ EQUIPMENT,.ruNCTION BOXES, MOTORS AN!) OTHER POTENTIAL

.

.

SPLICE LOCATIONS AND DOCUMENTED ALL SPLICES IDENTIFIED IN

-

.

'

... ~.-
'.

.

  • .

.

. *'!-*.. ~-~

-

~:_.._-.*~~-~~~-~*-:: '.~*.:*

EQ CIRCUITS. THESE SPLICES AREDOCUMENTED IN*AND Q~ALIFIED *

BY EQ BINDER..,

~ :_... *. ;: -~~ _;,.~i:;~~~i;~t~~~';

. *

  • . -~

-.'i *.- ~..

.'!'

/scl:ID146:32

...

a*

"

EQ P~

CONCLUSIONS

THE RECENT W ALKDOWNS HA VE VALIDATED THE OVERALL

-

.

EFFECTIVENESS OF THE DRESDEN EQ PROGRAM BASED ON THE _

LIMITED NUMBER AND NATURE OF AFFECTED ITEMS IDENTIFIED.

.. *

.

-

.

.

THE CIT_ED FINDINGS AR_E THE CONSEQUENCES OF AN ISOLATED TECHNICAL JUDGMENT MADE FOR TERMINAL BLOCKS LOCATED OUTSIDE-OF THE CONTAINMENT WHICH LED TO THE OMISSION OF CERTAIN TERMINAL BLOCKS AND SPLICES FROM THE EQ PROGRA... -'. ~j:i!Ji4:~.--* c.

'..... ;.

.;..

' ~

.. -'""

/scl:ID146:33

EQ PROGRAM CONCLUSIONS <continued.>

DEFICIENCIES IDENTIFIED DURING THE RECENT DRESDEN WALKDOWNS WERE PROMPTLY CORRECTED. JCO'S WERE WRITTEN AS APPROPRIATE.

. DOCUMENTATION DEMONSTRATING QUALIFICATION OF TERMINAL BLOCKS HAS BEEN INCLUDED IN THE EQ FILE THE DEFICIENT SPLICES WERE REPLl\\CED WITH QUALIFIED RAYCHEM SPLICE WEEPHOLES WERE PROMPTLYAND CONSERVATIVELY ADDED TO JUNCTION BOXES OUTSIDE CONTAINMEN THERE IS MINIMAL SAFETY SIGNIFICANCE ASSOCIATED WITH ANY OF THE FINDINGS:

ALL TERMINAL BLOCKS WERE QUALIFIED OR QUALIFIABL THE DEFICIENT SPLICES WOULD NOT HA VE PREVENTED ASSOCIATED EQUIPMENT FROM PERFOltMING THEIR INTENDED SAFETY FUNCTION WEEPHOLES WERE INSTALLED, AS REQUIRED, FOR INSIDE

.

- :': :,::.:- -

CONTAINMENT INSTALLATION ~ ***.-..*.

. ~*~*~:* :..

THE SAMUEL MOORE CABLE IS QU~IFIED FOR ITS INTENDED.

FUNCTION PER IEEE 383 (1974) REQUIREMENT /scl:ID146:34

,4

,,,

.. '

~--

CORRECTIVE ACTIONS

DETAILED ENGINEERING ASSESSMENTS WERE PERFORMED TO DOCUMENT ITEMS WHOSE QUALIFICATION STATUS WAS

"QUESTIONABLE". DEFICIENCIES IDENTIFIED DURING THE

.

.

W ALKDOWNS WERE PROMPTLY CORRECTED OR SCHEDULED TO BE CORRECTED. TECHNICAL EVALUATIONS WERE PERFORMED FOR ALL DEFICIENCIES AND JCO'S WERE WRITTEN AS APPROPRIAT THE EQ BINDERS FOR.TERMINALBLOCKS HAVE BEEN REVISED TO*.

SPECIFY.THE OMITTED TERMINAL BLOCK LOCATIONS AND TO CLARIFY THAT ONLY JUNCTION BOXES INSipE CONTAIN;MENT RE~UIRE WEEPHOLE *. A SAMPLE W ALKDOWN ON DRESDEN UNIT 2 PERFORMED IN AUGUST, 1990, DID NOT IDENTIFY ANY DEFICIENCIES. HOWEVER, ANY FURTHER'.DEFICIENCIES IDENTIFIED DURING THE BALANCE OF THE UNIT 2 W ALKDOWN WILL. BE DISPOSITIONED IN ACCORDANCE WITH,

.* CURRENT PROGRAM *

BASED ON THE RESULTS OF THE 1989-90 WALKDOWN LER 249/89005 WILL BE REVISED TO INCLUDE THE RESULTS OF THE WALKDOWNS AND EVALUATIONS PERFORMED...

. -~

>--~-::;.,: ~ *.*.

-~.

  • ' -...

~-

,.... ~'.~:~~:{?;(..

  • -*.... -*

..

. **~;-.

.

  • "*7"- -

~

-->~:~~r:~~--~---

/scl:ID146:35

...

i').'~......,.

ii

'

f '

"

CORRECTIVE ACTIONS <continued)

PROCEDURES CONTROLLING NEW INSTALLATIONS WERE REVIEWED:

/scl:ID 146:36 NEW INSTALLATIONS ARE CONTROLLED UNDER DESIGN

~ODIFICATION PROCEDURE ENO-QE-06. THIS PROCEDURE *

PROVIDES*THE CONTROLS FOR THE IDEN:TIFICA'l'ION OF EQ COMPONENTS..

E~GINEERING PROCEDURE ENC.:QE~12.l PROVIDES THE*

CONTROLS FOR UPDATING THE MASTER EQUIPMENT LIST FROM,..

PLANT MODIFICATIONS AND PROPERLY CLASStFYING -

COM}'ONENTS*FOR SPECIAL ~EQUIREMENTS ~UCH AS E ENGINEERING PROCEDURE ENC-QE-42 ESTABLISHES THE METHOD FOR PREPARATION, REVIEW, CONTROL, AND

.

.

.

MAINTENANCE OF: EQ BINDER *

. THIS REVIEW HAS SHOWN THAT CONTROLS ARE IN PLACE'

TO ENSURE PROPER IDENTIFICATION, QUALIFICATION, AND DOCUMENTATION OF NEWLY INSTALLED EQ COMPONENT **

"*' **

..

. OTHERACTIONS IN MARCH 1989, CECo ENHANCED THE FUNCTIONS OF THE.CENTRAL

. EQ GROUP IN THE OFFSITE ENGINEERING ORGANIZATION TO FOCUS EQ EFFORT~ AND DIRECT EQ IMPLEMENTATION FOR ALL SIX SITES. *

THIS GROUP:

IS RESPONSIBLE FOR ALL TECHNICAL AND OPERATIONAL EQ ISSUE PROVIDES FUNCTIONAL CONTROL OVER THE STATION EQ COORDINATORS

CECO HAD EVALUATED THE REVIEWS, AUDITS AND STUDIES OF TH EQ PROGRAM PERFORMED FROM 198!5 THROUGH 1987 ON~

iNDIVIDUAL BASIS. ACTIONS WERE IDENTIFIED AND IMPLEMENTED:

  • TO PROVIDE ADDITIONAL ASSURANCE THAT THE DEFICIENCIES IDENTIFIED HAVE BEEN APPROPRIATELYDISPOSITIONED, AN INTEGRATED REVIEW OF THESE REPORTS TO STATUS THE

. IDENTIFIED DEFICIENCIES, RECOMMENDATIONS AND ACTIONS WILL BE COMPLETED BY OCTOBER 31, 199 /scl:ID146:37.

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