IR 05000255/1995005
| ML18065A252 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/21/1990 |
| From: | Gardner R, Kopp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18065A249 | List: |
| References | |
| 50-255-90-05, 50-255-90-5, IEIN-89-063, IEIN-89-63, NUDOCS 9511090067 | |
| Download: ML18065A252 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION Ill Report No. 50-255/90005{DRS)
Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:
Palisades Power Plant Inspection At:
Covert, MI and Glen Ellyn, IL Inspection Conducted:
January 22 through March 2, 1990 Inspector:
M. JVKopp Also participating in this inspection and contributing to this report was:
J. F. Hanek, EG&G Approved By:
Inspection Summary 3/P1/q0 Date Ins ection durin January 22 throu h March 2, 1990 (Re ort No. 50-255/90005(DRS))
Areas Inspecte : Spec1a sa et~ 1nspect1on concerning previous y i ent1 1e environmental qualification (EQ) inspection findings; Information Notice (IN) 89-63, Submergence of Electrical Circuits Above Flood Level; and 10 CFR Part 21 concerning Gamma Metrics cable assemblies (Modules 30703 and 62705).
Results:
Of the three areas inspected, two Severity Level IV violations were identifie One violation concerned the licensee's failure to take adequate corrective action to resolve a previously identified Level IV violation. The other violation concerned the licensee's failure to qualify two EQ relays installed in the Auxiliary Feedwater (AFH) control circuitry. The inspection revealed that the licensee has implemented corrective actions to resolve previous EQ findings and concerns, except as noted in the violations.issued as a result of this inspectio Based on this inspection, the inspectors reached the following. conclusions:
The licensee's EQ files were organized and auditabl PDR ADOCK 05000255 G
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The licensee took adequate measures to resolve the majority of the previously identified EQ findings..
The licehsee's EQ engineering review process was not thoroug The installed configuration of the Auxiliary Feedwater (AFW) control circuit relays and the Viking connectors were not accurately reflected in the EQ design document *
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DETAILS Persons Contacted Consumers Power Company (CPCo)
- G. Slade, Plant General Manager
- R. Orosz, Engineering and Maintenance Manager
- D. VandeWalle, Technical Director
- R. Mccaleb, Quality Director
- K. Toner, Projects Superintendent
+*C. Kozup, Technical Engineer
+*J. Brunet, Licensing Analyst
- W~ Nummerdor, Senior. Quality Assurance Consultant M. Ferenz, Engineering and Maintenance
- P. Sondgerath, Plant Projects EQ Engineer
- R. Corbett, Plant Projects, Electrical
- B. Meredith, Instrumentation and Control
- M. Nordin, Systems Engineering United States Nuclear Regulatory Commission (USNRC)
- E. Swanson, Senior Resident Inspector, Palisades
- Denotes those participating in the interim site exit intervjew conducted on January 26, 199 +Denotes those participating in the final exit interview conducted by telephone on March 2, 199.
Licensee's Action Concerning Previously Identified EQ Findings During the period of December 8, 1986 through January 13, 1987, Re~*ion II I conducted an inspection to verify the environmental qualification {EQ) of electrical equipment at the Palisades Nuclear Plant {Reference:* NRC Inspection Report No. 50-255/86032(DRS)).
As a result of this inspection, an EQ Category B violation (50-255/90005-0l(DRS)) with a $150,000.00
civil penalty and a Severity Level IV violation ( 50-255/90005-02( DRS)) was issued to the Consumers Power Company (CPCo).
On December 23, 1988, CPCo responded to the Notice of Violation (NOV) and addressed the reasons for the violations, corrective actions taken, and the dates when full compliance was achieve Each of the items addressed in this sectiori of this.report was included as an example of either the EQ Category B or Severity Level IV violatio (Closed) Unresolved Item (50-255/86032-0l(DRS)):
This item addressed the use of ~nqualified lubricants in Limitorque valve actuators inside and outside of containmen Hardened grease was found in some actuators which could have prevented these
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actuators from performing their safety function during a Design Basis Accident (OBA).
The licensee replaced unqualified lubricants with qualified lubricants prior to startup. The inspectors determined that adequate corrective action had been complete During this inspection, the inspectors reviewed the licensee's corrective actions and confirmed that the unqualified grease was replaced with qualified Nebula EP lubricant prior to the plant restart on April 2, 198 The inspectors also reviewed the EQ files for the Limitorque actuators and verified that the files were revised and required the use of the qualified lubricant No further NRC concerns were identifie (Closed} Unresolved Item (50-255/86032-0S(DRS)):
Thi~ item concerned the failure of the licensee to install conduit seals on connections to EQ ASCO solenoid valves located in harsh environment The inspectors noted that certain ASCO test specimens identified in the EQ test report failed due to moisture instrusion into the coils of the valves and that conduit seals were required in order to avoid this type of failure. The licensee committed to installing the conduit seal The inspectors confirmed, during a walkdown of several ASCO solenoids located outside containment, that the licensee had installed the conduit seals. The inspectors were not able to verify that seals were installed on ASCO solenoid valves inside containment because the plant was operating. This action was completed by February 28, 198 In addition, the inspectors reviewed the EQ files for ASCO solenoids and verified that the files were revised to reflect the installation of the conduit seal No further NRC concerns were identifie (Closed) Unresolved Item (50-255/86032-06(DRS)):
This item concerned the auditability of the licensee's EQ file The inspectors noted discrepancies with the files in that replacement equipment was incorrectly identified as qualified to DOR guidelines in lieu of 10 CFR 50.49, revised temperature profiles were not incorporated into the EQ files, and the EQ files did not reference the qualified connection interface for Trans American level elements and Rosemount transmitter During this inspection the inspectors reviewed the NAMCO EQ file M-241A, Sheet 11; Limitorque EQ File M-92, Sheet 64; and Masonelian EQ File M-23388, Sheet 14 and verified that positive statements of qualificatiori to 10 CFR 50.49 were contained in the files. The inspectrirs also reviewed EQ Files M-234B, Sheet 41, and E-48, Sheet 6EJ and confirmed that the revised temperature profiles were incorporated into the EQ files and also that the connection
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interface for Trans American level ~lements and Rosemount transmitters was specifie No furthtr concerns were identifie (Closed) Unresolved Item (50-255/86032-0l(DRS)):
.This item concerned Rockbestos Firewall III cable qualification to DOR guidelines. The qualification file and test report were found discrepant in that specific formulations of the installed cable were not identified, NRC Information Notice (IN) 84-44 concerns were not addressed, and insulation resistance (IR) characteristics under accident conditions were not analyzed. The licensee acknowledg~d these deficiencies and committed to updating the file During this inspection, the inspectors reviewed the licensee's EQ file for Rockbestos Firewall III cable and verified that the licensee addressed the noted deficiencies. This information was incorporated into the EQ file In addition, the inspectors reviewed CPCo engineering anal~sis, :BDM-87-04, and verified that the IR values obtained during the EQ test of this cable were factored into the instrument loop accuracy calculation No further NRC concerns were identified. * (tlosed) Unresolved Item (50-255/86032-09(DRS))i This item concerned the failure of the licensee to address, in the EQ files, the effects of leakage currents on General Electric (GE)
XLPE/PVC and XLPE/Neoprene cable The licensee committed to performing an engineering analysis to demonstrate the acceptability of the cable *
During this inspection, the inspectors reviewed the EQ files for the GE cables and determined that the corrective actions taken by the licensee were acceptable. The EQ file, E-22, Sheet 1, for the GE XLPE/Neoprene cable stated that this cable was not used in instrumentation circuits at Palisade CPCo engineering analysis BDM-87-04 addressed the effects of the GE XLPE/PVC !R's and leakage currents on the overall instrument loop accurac The inspectors also reviewed the licensee's EQ file.concerning the qualification of GE butyl rubber cable used outside of containmen The licensee updated the EQ file and provided additional EQ test data to further substantiate qualification for use outside of containmen No further NRC concerns were identifie (Closed) Unresolved Item (50-255/86032-lO(DRS)):
This item concerned Bendix potted connectors used on Viking ptnetrations in EQ circuit application The inspectors determined that neither IR or leakage current measurements were taken during
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the accident portion of the EQ test. Consequently, the effects of these connectors on the accuracy of the associated instruments were not addressed in the licensee's EQ files. The licensee committed to updating their files by including appropriate evaluations in the affected EQ file During the inspection, the i~spectors reviewed the licensee's EQ files and determined that Military Specification {MIL-SPEC) C-5015G was used to establish an IR val~e for the connector Further review by the NRC inspectors determined that the MIL-SPEC required vendors to perform a dry environment temperature test to obtain the IR data..
This type of test is not representative of the wet environment that the connectors would be subjected to during an accident. Therefore, the inspectors concluded that qualification of the connectors had not been established by the licensee. This Unresolved Item is considered closed; however, further discussion concerning this issue can be found in Section 3 of this repor (Open) Unresolved Item {50-255/86032-ll(DRS)):
This item concerned the licensee's failure to demonstrate that an instrument inaccuracy of 8% for Rosemount Transmitters would not preclude the fulfillment of the safety function to be performed by the transmitters. The licensee took immediate corrective action and submitted a Justification for Continued Operation (JCO) by evaluating the effects of the demonstrated instrument inaccuracy on the setpoint
- methodolog During this inspection, the inspectors co~firmed that the licensee updated the EQ files; however, this item is under review by the Office of Nuclear Reactor Regulation (NRR) in Headquarters and remains ope (Closed) Unresolved Item (50-255/86032-12(DRS)):
This item concerned six Li~itorque actuators inside containment that were found to have plugged T drain Jhe~~ plugs had not been removed during installation, thereby placing these actuators in an untested configuration. The inspectors concluded that the actuators were not qualified in this configuratio *
During this inspection, the inspectors reviewed the licensee's corrective action response to the NOV and the EQ files for the affected actuators. The licensee's response stated that a walkdown was performed and that required T drains were verified to be unplugged or had their plugs removed by February 11, 198 The EQ files indicated that T drains were installed; however, the plant was operating and it was not possible to.inspect these actuators during the plant walkdow *
No.further NRC concerns were identified.
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Bendix Potted Connectors Used on Vikinq Penetrations The December 1986 NRC EQ *inspection at Palisades identified a Severity Level IV violation in that the licensee's EQ file for Bendix potted connectors did not address the Insulation Resistance (IR) effects on instrumen_t loop accurac IR data was not taken during the Loss of Coolant Accident (LOCA) portion of the EQ test. The licensee committed to performing an analysis to demonstrate the acceptability of the connector During this inspection, the inspectors reviewed the licensee's analysis contained in EQ file E-48, Sheet 6DR, to determine if the licensee's corrective actions were acceptabl The review of this file identified concerns regarding the source from which the IR data was obtaine Specifi5ally, the in~p~ctors not:d.tha~ the licensee obtained an IR value of 3x10 ohms from M111 tary Spec1f1 cation (MIL-SPEC) C-5015G, "General Specification for Electrical Connectors, Circular Threaded, AN Type".
According to the MIL-SPEC, one part of the connector certification prdcess required vendors to perform IR tests at 25°C and 125°C. This IR test does not include the spray or.moisture environment that the connectors at Palisades would be sµbjected to during accident condition In addition, the inspectors also noted that the licensee was unable to provide documented evidence that the installed Viking connectors were procured and tested in accordance with the MIL-SPEC. Therefore, the inspectors informed the licensee that use of the MIL-SPEC IR data was not considered acceptable to meet DOR guidelines. The licensee stated that since the connectors were protected against moisture intrusion by the use of a silicone rubber gasket at the mating connection, and a potted epoxy compound at the cable/connector interface, it was acceptable to use IR data based on the MIL-SPE The licensee further stated that the ability of the. gasket and epoxy compound to protect against moisture intrusion was demonstrate during the LOCA test conducted per Wyle Test Report No. 43913-2. This test contained four specimens, one of which failed during the test and its failure was attributed to inadequate preparation of the potted epoxy material. The inspectors informed the licensee that because IR data was not taken dµring the LOCA test conducted by Wyle, the effects of leakage currents on EQ instrumentation and low voltage control circuit connectors using the potted epoxy compound, had not been considered andtherefore did not meet DOR requirement The licensee took corrective action and submitted a Justification for Continued Operation (JCO) for the 16 EQ instrumentation and 23 EQ control circuits identified by the license In addition, the licensee committed to replace the connectors with qualified Celmark connectors during the 1990 Spring Maintenance Outage and during the 1990 Fall Refueling Outag The licensee's commitment to replace the connectors is documented in a letter to the NRC dated March 1, 199,
10 CFR 50, Appendix B, Criterion XVI, "Corrective Action" requires that measures be established to assure that conditions adverse to quality, including nonconformances, are promptly identified and correcte In the case of -significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The corrective action taken shall be documented and reported to appropriate levels of managemen,.,.
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Contrary to the above, CPCo failed to assure that the corrective action taken in response to a previously identified EQ Severity Level IV violation was adEquate in that the licensee failed to demonstrate qualification of the Bendix potted connectors used on Viking electrical penetration Insulation resistance (IR) measure~ents were not taken during the accident portion of the EQ test. These measurements are necessary to ensure that instrument accuracy requirements are met and that low voltage control circuits will perform their safety function during accident condition This is a Severity Level IV violation (Supplement ID) (50-255/90005-03(DRS)).
Auxiliary Feedwater (AFW) Control Circuit Relays The licensee identified two relays, R/0727 in junction box JL-263, and R/0749 in junction box JL-264, located in a harsh environment that were not included as part of the EQ Master Equipment List and-consequently not environmentally qualified. The relays were found installed in one channel of both trains of the AFW control circuits. The licensee stated in Deviation Report D-PAL-90-014 that the relays are not required to change -
state during a Main Steam Line Break (MSLB) or LOCA and are only needed to transfer control or indication from the control room to the C-150 auxiliary shutdown panel in the event of a control room fire. However, the inspectors were concerned that the relay contacts may fail open or short circuit if subjected to 100% humidity conditions during an accident and render the*
control circuit inoperable. The licensee performed engineering analysis EA-PAL-90-014-1 to determine if the relays would fail when subjected to the postulated accident condition As part of this analysis, the licensee performed a similarity analysis which compared the relays to a States terminal bloc The licensee also informed the inspectors that redundancy is available because of a second channel in_ each train that is environmentally qualified. Based on the availability of the second redundant channel, the inspectors had no immediate safety concern The inspectors informed the licensee that qualification of the relays must be based on type testing, or test data and analysis of a similar type rela The licensee committed to providing the qualification of the relays by June 1, 199 *
10 CFR 50.49, Paragraph f, requires each item of electrical equipment important to safety be qualified by testing or testing and analysi Contrary to the above, the licensee identified Auxiliary Feedwater (AFW)
control circuit relays R/0727 and R/0749 located in a harsh environment, that were omitted from the EQ Master List and consequently, not environmentally qualified by testing or testing analysis. Failure of the licensee to qualify the relays is considered a violation of 10 CFR 50.49 requirement This is a Severity Level IV violation (Supplement ID) (50-255/90005(DRS)).
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- - Terminal Blocks Used in EQ Circuit Applications The inspectors reviewed the licensee's use of terminal blocks in EQ applications in steam and moisture environment This review was to determine if the installed configuration was such that the blocks could be affected by direct spray or become submerged inside electrical enclosures (Reference NRC IN 89-63, "Possible Submergence of Electrical Circuits Located Above the Flood Level Because of Water Intrusion and Lack of Drainage").
The inspectors reviewed the licensee's EQ files for States, Buchanan, and Westinghouse terminal blocks. Terminal blocks used in EQ instrument circuits inside containment were replaced with Raychem splices in July 1986 per Specification Change 86-13 However, terminal blocks are used in EQ control and power circuit applications inside and outside of containmen During the walkdown of EQ equipment located outside of containment, the inspectors noted several EQ terminal boxes that had top entry conduits and no weephole The licensee performed an evaluation and determined that the terminal blocks inside_ the boxes would not become submerged or subjected to direct spra In addition, the licensee initiated Action Item Record (AIR) A-PAL-89-155 which committed to walkdowns during the next refueling outage and a review of the EQ junction boxes to ensure that required weep holes are installed and that
- conduit configurations are acceptable. Verification of the actual configuration of terminal blocks located inside containment was not performed because the plant was operatin No NRC concerns were identifie.
10 CFR Part 21 Gamma Metrics Cable* Assemblies In May 1988, Gamma Metrics identified concerns with solder connections on cable assemblies installed as part of the neutron flux monitoring syste The inspectors were concerned that the 1 i censee had 'these cab le assemb 1 i es installed in the neutron flux monitoring system and that the necessary test and repairs were not performed. The licensee informed the ~nspectors that the installation of the neutron flux monitoring system was not complete and that prior to the. installation of Gamma Metrics cable assemblies, the assemblies would be returned to Gamma Metrics for testing, in~pection and/or repai *
No NRC concerni were i~entifie ~
Exit Interview The Region III inspector met with the licensee's representatives (denoted in Paragraph 1) during an interim exit on January 26, 1990, and discussed the findings by telephone at the conclusion of the inspection on March 2, 199 The inspector summarized the scope and findings of the inspection and the licensee acknowledged this informatio The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspecto The licensee did not identify any such documents/processes as proprietar