IR 05000275/1986033
| ML20204E271 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/17/1987 |
| From: | Alexander S, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20204E236 | List: |
| References | |
| 50-275-86-33, 50-323-86-31, NUDOCS 8703250660 | |
| Download: ML20204E271 (22) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report Nos.:
50-275/86-33, 50-323/86-31 Docket Nos.:
50-275, 50-323 License Nos.:
DPR-80(11/2/84),DPR-81(8/26/85)
Licensee:
Pacific Gas and Electric Company ATTN: Mr. James D. Shiffer Vice President, Nuclear Generation Departrient 77 Beale Street, Room 1435 San Francisco, California 94106 Facility Name:
Diablo Canyon Power Plant, Units 1 and 2 Inspection At:
Diablo Canyon Power Plent, San Luis Obispo County, California Post Office Box 56 Avila Beach, California 93424 Inspection Conducted:
December 15 through 19, 1986
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lob k hbwo 3-D-67 Inspector:
WS. D. Alexandet, Equirrent Qualification Date (
InspectionSection(EQIS)
Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, IE
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D. Willett, Reacter Engineer, NRC Region V J. Burdoin, Reactor Engineer, NRC Region V W. Carpenter, Consultant Engineer, Idaho National Engineering Laboratory R. Vanderbeek, Consultant Engineer, Idaho National Engineering Laboratory M. Jacobus, Member of Technical Staff, Sandia National Laboratories V. Nicolette, Member of Technical Staff, Sandia National Laboratories
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~8-M- fi' 7 Approved by:
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U. Potapovs, Chief, EQIS, Vendor Program Date Branch, Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement F2703250660 870320 gD DOCK 0500
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INSPECTION SUMMARY:
Inspection on December 15 to 19, 1986 (Inspection Report Nos. 50-275/86-33, 50-323/86-31)
Areas Inspected: Special, announced inspection to review Pacific Gas and Electric Company's (POSE) implementation of a program for establishing and raintaining the environmental qualification (EQ) of electrical equipment important to safety at Diablo Canyon Power Plant (DCPP) in compliance with 10 CFR 50.49. The inspection also included evaluation of implementation of EQ corrective action commitments made by PGt.E as a result of deficiencies identified in Supplemental Safety Evaluation Reports (SSER).
Results: The inspection determined that PG&E has inplemented a program te meet the requirements of 10 CFR 50.49 except for certain deficiencies listed below. No deficiencies were identified in PG&E's implementaticn of SSER corrective action commitments.
Report Item Paragraph (s)
Item Numbers Potential Enforcement / Unresolved Items:
1.
Conax RTDs Functional 4.D(1),
50-275/86-33-01 Performance Requirements 50-323/86-31-01 2.
Minco RTDs Unqualified for 4.D(2)
50-275/86-33-02 50-323/86-31-02 Submergence 3.
Limitorque Gear Case Grease 4.D(4)
50-275/86-33-03 Relief Valves and 4.E(4)
50-323/86-31-03 4.
3M Scotch 33+ Tape /Scotchco Putty 4.E(6)
50-275/86-33-04 Cable Splice Insulation Systen 50-323/86-31-04 Level of Qualification Open Items:
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Limitorcue Semiannual Cycling 4.B(3)
50-275/F6-33-05 50-323/86-31-05 Requirement 6.
Linitorque Heaters (IN 86-71)
4.B(1),
50-275/86-33-06 and 4.D(P)
50-323/86-31-06 7.-
Internal EQ Audit Corrective 4.A(5)
50-275/86-33-07 50-323/86-31-07 Actions S.
Conax RTD Qualified Life 4.D(1)
50-275/86-33-08 50-323/86-31-08
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Revision i
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DETAILS 1.
Persons Contacted 1.1 Pacific Gas and Electric Company (PG&E)
J. R. Harris, Audit Administrator, DCPP R. D. Cramins, Senior QC Inspector R. W. Taylor, QA Engineer
- B. D. Smith, EQ Coordinator. NECS R. K. Jones, Procurenent Specialist, Electrical S. R. Ortore, Procurement Specialist, 18C B. D. Guilbeault, Supervisor, Procurement Speciality Group D. A. Taggart, Director. Quality Support QA
- C. L. Eldridge, Manager, Quality Control
- R. L. Watson, Supervisor, Quality Support QA
- D. L. Bauer, Senior Engineer, Maintenance
- M. L. Smith, Power Production Engineer T. L. Grebel, Supervisor, Regulatory Compliance W. J. Kelley, Engineer, Pegulatory Compliance M. J. Jacobson, Project Ouality Engineer, NECS D. R. Geske, Lead Planner, Quality Control T. Grey, I&C Training Engineer, DCPP M. Curtis, I&C Technician, DCPP M. Woloshansky, I&C Technician, DCPP J. Bognum R. C. Thornberry, Plant Manager D. R. Lampert, Engineer F. Mori, Sr. Mech. Engineer D. Miklush, Maint. Mgr.
T. Maxey, PM T. W. Pellisero, Operations Engr J. Hjalnerson, TN L. F. Womack, Operations Mgr.
T. Nelson, Reg. Compliance D. D. Malone, Sr. IAC Eng.
D. R. Clifton, Training Superviser R. C. Washington, Nuc. Gen. Eno.
S. C. Siegel, ISC Engr T. N. Crawford, Sr. Mech. Engr K. L. Herman, I&C Engr. Supervisor J. Blakley, Senior Engineer J. A. Sexton, Plant Superintendent G. H. Moore, Mgr NECS J. M. Giollon, Asst. Plt. Mgr/ Tech.
R. P. Powers, Sr. Engr - C&RP D. W. Shelly, Sr. Engr - NOS W. G. Crockett, I&C Manager K. A. Levitt, MAL's Manager R. B. Goel, Engineer Tren P. Lee, Engineer
- Denotes thnse present at the exit meeting at the plant site Decenber 19, 19P6.
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1.2 Consultants to PGAE
- R. G. Oman, EQ Task Force Coordinator, Bechtel B. K. Dilodare, Equipment Qualification Supervisor, Bechtel G. E. Quitariano, HVAC Engineer, Bechtel T. Maxey, Tera Corporation 1.3 NRC
- FT Narbut, Senior Resident Inspector, Diablo Canyon Power Plant
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H. Schierling, PAD 3/NRR, DCPP Project Manager
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- Denotes those present at the exit meeting at the plant site December 19, 1986.
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2.
Purpose The purpose of this inspection was to review PG&E's implementation of the requirements of 10 CFR 50.49 for DCPP, implementation of corrective action commitments for EQ deficiencies identified in the DCPP Safety Evaluation Report EQ related supplements, and to verify compliance with licensing conditions related to E0.
3.
Backaround Under the provisions of Commission Memorandum and Order CLI-80-21 of May 23, 1980 and based on Construction Pernit (CP) dates of 4/23/68 and 12/9/70 for Units 1 and ? respectively, and Operating Licenses (OLI issued 11/2/84 and 8/26/84, PG&E was recuired to qualify applicable DCPP equip-ment under NUPEG-0588, Category II.
Prior to this determination, PG8E responded to IE Bulletins 79-01,79-01A, 79-01B and their supplements as required.
Results of the NRC Staff reviews of PG&E's development of the EQ program for DCPP during the licensing process are documented in DCPP's Licensing Safety Evaluation Report (SER), NUREG-0675, Supplements (SSER)
No.15 (September,1981), No. 31 (April,1985) and NO. 32 (July,1985).
The NRC staff concluded in SSER 31 that the EQ Program for DCPP was in compliance with 10 CFR 50.49. PG&E has qualified the post-accident monitoring eouipment identified in Peculatory Guide (RG) 1.97 and required
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to be qualified under 10 CFR 50.49 (b)(3) with the exception of the boric
acid charging flow meter and the primary coolant radicactivity ccccentra-
tion monitor. These two items are commercially unavailable as environ-rentally qualified equionent. PG&E has committed to install the qualified equiprent when available. The NRC staff found the schedule for compliance with RG 1.97 acceptable ir SSER 32.
EQ certification persuant to Generic Letter 84-24 for DCPP was made by PG&E in their letter DCL-85-072 dated February 22, 1985. SSER 15 required implementation of surveillance and maintenance procedures for qualified equipment susecptible to aging degradation for trending and replacerent or
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refurbishment as required to preserve its cualified status prior to DCPP going to full power operation. PG&E reported completion of inplementation of these procedures in compliance with License Condition F.C.(5), item (c)
in their submittal DCL-84-201 of June 5, 1984 Compliancewithitems(a)
and (b) of License Condition 2.C.(5) relating to qualfication deficiencies in equipment identified in Appendix B of SSER 15 was certified in PG&E letter DCL-84-237, 4.
Findings:
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The NRC inspectors examined PG8E's program for establishing the qualifi-cation of equipment within the scope of 10 CFR 50.49. The progran was evaluated by exanination of PGLE's qualification documentation files, review of procedures for controlling PG&E's EQ efforts, and verification of adequacy and accuracy of PG8E's program for maintaining the qualified status of the applicable equipment at DCPP.
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Based on the inspection findings, which are discussed in more detai'.
below, the inspection team determined that PG&E has implemented a program to meet the requirements of 10 CFR 50.49 for DCPP though seme deficiencies were identified. No deficiencies were identified in PG&E's implementation of DCPP SSER EQ corrective action commitments and compliance with E0 license conditions.
A.
E0 Program and Procedure Review To evaluate the PG&E's " Equipment Environmental Qualification Program" as required by 10 CFR 50.49, the inspectors interviewed personnel of the following groups and examined the listed instructions / procedures and reccrds of these organizations:
(1) Nuclear Engineering crd Construction Services (a) Project Instructinn (PI) 48, Revision 0, deted December 13, 1984, " Maintenance, Surveillance, Procurer.ent, Receipt and Storage for Environmentally Qualified Eauipment" (b)
Procedure No. 3.6 ON, Revision TR-59, dated August 4, 1986,
" Operating Nuclear Power Plant Design Changes" (c) Procedure No. 3.12, Revision TR-58, dated July 1, 1986,
" Spare and Replacement Parts Evaluation"
(d) Procedure No. 3.13, Revision 0, dated October 15, 1986,
" Environmental Qualification Review" (e)
Instruction No.18, Revision 1, dated February 14,19E6,
"Envirennental Qualification Review" (f) Master Equipment List, Drawing 050909, Revision 8, dated December 6, 1986 (2) Cuality Control (a) Administrative Procedure (AP) C-800, Revision 3, dated February 11, 1986, " Quality Control Inspection and Surveillance Program" (b) AP C-800S1, Rev. 6, dated April 21, 1986, "DCPP Quality Control Department Activities" (c) AP C 40S3, Rev. 2, dated August 5, 1986, "Use of PIMS
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Corrective Maintenance Work Order Module" (d) Quality Control Procedure (QCP) 10.2, Revision 3, dated April 11, 1986, " Inspection Activities" (e) Action Request No. A-0049578, dated November 25, 1986, "Q.C.
Inspection of Safety Related EQ Preventive Maintenance" (f) Planning Group memorandum, dated Octnber 25, 1986, subject:
" Environmental Cualification Inspection"
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(3) Quality Support (a) Surveillance Report (SR) QS-85-0007, dated August 23, 1985,
" Electrical Maintenance (E0 Equipment)"
(b) SR QS-85-008, May 31, 1985, " Control of Materials at DCPP" (c) SR QS-86-0026, dated March 17, 1986, " Control of Materials in Warehcuse A" (d) SR 05-86-0027, dated March 21, 1986, " Control of Materials in Warehouse B" (e) SR QS-86-0052, dated June 27,1986, " Control of Materials in Warehouse A" (f) SP. 0S-86-0053, dated June 27, 1986, " Control of Materials in Warehouse B" (9) SR 0S-86-0160, dated December 4, 1986, "DCP-J-35185 Replacement of Contairnent Wide Range Level Transmitters" (h) SR QS-86-0161, dated December 10, 1986, "Barton/Rosemount Pressure Transnitter (PT) Change Out (DCI-J-31923)"
(4) Procurement Speciality Group (a) AP D-530, Revision 1, dated March 10, 1986, " Plant Procurement and Job Estimate Program" (b) AP D-532, Revision 2, dated November 18, 1985, " Preparation of Procurement Documents and Contracts at [DCPP]"
(c) AP D-533, Revision 2, dated November 18,1985, " Processing, Review and Approval of Procurement Documents at DCPP" (d) AP D-534, Revision 2, dated November 18,1985, "Classifi-cation of Items and Services for Procurement" (e) AP D-535, Revision 2, dated November 18, 1985, " Procurement Documents Requirements" (f) AP D-536, Revision 2, dated November 18, 1985, " Evaluation and Control of Suppliers" fg) AP D-537, Revision 2, dated November 18, 1985, " Receipt of
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Materials at DCPP" (h) AP D-538, Revision 2, dated November 18, 1985, " Control of Materials at DCPP" (i) AP D-539, Revision 2, dated November 18, 1985, " Issuance of Materials at DCPP" (j) NECS Interoffice Menorandum dated January 16, 1985, subject:
" Spare Parts Procurement and Installation"
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(5)
Internal Audit Group (a)
"Comprehsnsive Audit System Plan - Internal Auditing,"
dated January 31, 1986 (b) " Internal Comprehensive Audit Program" (draft)
(c) Audit 85-033P, dated May 29, 1985, "Procurerent Document Control" and " Control of Purchased Material, Equipment, and Services" (d) Audit 85286S, dated December 16, 1985, "Environnental Qualificatien Program" (e) QA Audit Findings Report 85-549, " Audit of I&C Environ-mental Qualificatinn (EQ) Files" (f)
Interral Audit EQ-8604, dated June 2,1986, " Environmental Qualification Program" (0 pen Items 50-275/86-33-07 and 50-323/86-31-07. See conclusion at bottom of page.)
Review of the above documents indicated that PG&E's EQ program provides for the following requirements:
(1) Developing and maintaining an EQ master equipment list (2) Review and approval of documentation te establish qualification (3) Controlled procurenent of spares parts and replacement equipment to ensure qualification prict to plant installation (4) Procedures for monitoring of replacement equiprent required to be qualified to a higher level (5)
Procedures for plant modifications and their effect on qualified equipment (6)
Indoctrination of personnel who work on qualified equipnent in EQ requirements and procedures (7) Quality Assurance (QA) and Quality Control (OC) documentation of surveillance and inspection of the various functional aspects of the E0 Program (8)
Periodic internal audits of the EQ Program functions such as procurement, receipt / storage, maintenance / surveillance, docu-mentation, training, and plant modifications.
The inspectors concluded, based on the above review, that PG&E has implemented a program that satisfies the requirements of 10 CFR 50.49 for Diablo Canyon Units 1 and 2.
Review of internal EQ audit EQ-8604 and DCPP's response indicated that corrective actions and implemen-tation of preventive reasures are in progress.
A future NRC irspection will confirn completion and continued compliance.
This is identified as Open Items 50-275/86-33-07 and 50-323/86-31-07.
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B.
EQ Information Handling, Training and Maintenance (1) IE Information Notices and Bulletins PG&E has established procedures for handling and tracking of NRC Inspection and Enforcement (IE) Information Notices (IN) and-Bulletins (IEB) and their responses or other actions as required.
They also cover handling of industrial / technical information and dissemination of all of the above information to the cognizant personnel. The process includes ensuring that EQ personnel will review this information for relevance to E0 so they can take the appropriate action.
PG&E had reviewed IN's and IEB's 79-01 through P6-71 related to EQ for DCPP applicability and the files corc;ained documentation of PG&E's resulting actions.
In addition to a general review of PG&E's systen_for handling EQ-related IN's and IEB's, the inspectors examined documentation relating to specific IN's.
This review resulted in the following comments:
IN 83-72 concerns multiple E0 issues.
EQ Notice No. 24 contained in IN 03-72 deals with qualification prcblems with Linitorque valve actuators (Limitorques) including potentially unidentified (and unqualified) deoradable materials such as wiring insulation. Bechtel DCPP Project Engineering had evaluated the problems identified in IN 83-72 concluding in an internal letter dated February 16, 1984, that EQ Notice 24 did not impact DCPP. The letter further stated: " Concerns raised under this item are not valid since the materials used in the actuators have all been aualified by Limitorque." This position was based in part on a Limitorque letter to PG&E, dated August 25, 1981 which claimed SMB style Limitorques are qualified per IEEE Standards 323-74 and 382-72 and discussed some materials, but did not mention wiring.
In an internal letter dated August 15, 1984, Project Engineering stated that no further action needed to be taken on EQ Notice 2a based on a Limitorque letter to Bechtel, dated July 19, 1984 This letter claimed internal wiring other than motor leads could be identified by manufacturers' markings.
IN 86-03, dealing directly with identified Limitorque wiring deficiencies, prompted a comprehensive Limitorque evaluation inspection, and upgrade progran. The NRC inspectors reviewed documentation used by PG&E in evaluating IN 86-03 impact on DCPP.
The records showed that all but six Limitoroues in each unit had been rewired in 1978 using qualified ICORE EFTE (Tefzel 200)
(E0 file (CER) No. EH-06) and Raychem Stylan (CER EH-10) wire.
Based on shop order numbers for the 12 Limitorques provided by PGSE, Limitorque informed PG&E that two had been reworked by them in 1980 using Rockbestos Firewall SIS, two had been sold to the NSSS (Vestinghouse) and the other 10 had been sold to valve manufacturers.
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The DCPP Electrical Maintenance Engineer inspected five of these in March of 1986, including at least one from each valve supplier, to verify installation records. The installation records of the seven which had not been inspected by PG&E were provided to the NRC for review subsequent to the inspection and showed that qualified wire (including the use of some from field
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run cable) had been put in by PG&E when the MOVs were installed and were consistent with the records of PG&E's inspections and with results of the walkdown during this NRC inspection.
Four other M0Vs, from the group rewired in 1978 had been replaced in 1984 and PG&E had documentation frcm Limitorque indicatinc they were wired with qualified Rockbestos Firewall SIS.
(See para-graph 4.E(5) for NRC walkdown inspection results en this issue.)
IN 84-90 Concerns Cualification Problems resulting from the superheated stean environment which is created when, during a large MSLB, stean generator tubes are uncovered by the resultfrg blowdown producing superheated stean.. This issue was addressed in PG&E letters dated March 8, 1985 and April 3, 1985.
SSEP 31 dated May 2,1085 was issued concurring that the PGLE analysis shows that the combined effects of higher enthalpy and lower mass flow rate are not significant and are bounded by the original temperature profile for equipnent qualification. The existing qualification temperature profiles were considered adequate. The relatively small changes in actual accident profiles were attributed to the effects of the Boron Injection System which limits re-criticality during the MSLB scenario.
However, the revised conditions did result in revision of HVAC EQ file (CER) numbers HH-1 through HH-7 and the creation of new electrical CERs EH-2, 3, 4 and 11 and instrumentation and control CERs IH-12, la, 16 and 17 due to the affected equipment being considered now in a harsh environment.
Internal EQ audit report No. 85286 S, dated December 16, 1985 identified the fact that not all affected files had been revised by the deadline of March 31, 1985 for compliance with 10 CFR 50.49. However, it noted that preliminary review showed that the equipment would remain qualified under existing c,ualification test paramenters.
No indications to the contrary were nnted in those files of the above groups which were reviewed as part of this NRC inspection.
IN 86-53 deals with Raychem heat-shrink splice insulation slee-ving in unqualified configurations.
Region V inspectors had previously verified satisfactory procedures with respect to this issue in conducting inspections in accordance with the pr6 visions of TI 2515/77.
No unqualified configurations of
[aychem splices were found durirg this inspection.
IN 86-71 identifies long term EQ and immediate operational concerns about energized space heaters in Limitorques. The resulting elevated ambient temperatures within the motor and limit switch compartments could affect component qualified lives and, more significantly, there is the possibility that wiring in contact with or in close proxinity to the heater elements could be burned possibly rendering the Limitorques inoperable.
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The NRC inspectors determined that PG&E's evaluation of the
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impact of these concerns on DCPP was in progress. PG&E provided documentation which showed that Limitorque qualified life calcu-lations at DCPP were based on 170 F ambient temperature. This bounding temperature was chosen based on measurements nade with peak recording temperature strips placed inside Limitorques with energized heaters. However, since heaters were deemed to be unnecessary inside buildings, PGAE committed to deenergize all heaters except those outside. The appropriate heaters will be discennected during the next maintenance cycle.
To address these and more immediate concerns, PG&E had initiated an inspection program for premature degradation and burned wire and to take more temperature measurements. Two Limitorques considered to be worst case examples (an SMB-04 with a 65W heater and an SMB-00 with a 25W heater) were selected to be the first inspected. The records indicated that they showed no premature degradation or burning / melting of wires. Temperature measurements revealed that temperature falls substantially at heater clearances greater than i inch. The bounding temperature at the wire closest to the 65W heater was 160' F.
PG&E committed to complete the inspection of all Limitorques with heaters during the next maintenance cycle. Arrhenius calculations showed that the 125 C wire used in these appli-cations could withstand 175 C(347 F) for 1.5 more years providing assurance that, even with heaters energized, the wires' qualified lives would not be exceeded before they could be inspected. PG&E also committed to ensure that the condition of materials susceptible to thermal aging degradation in those Limitorques with heaters they select to remain energized will be trended and components replaced as required as part of the surveillance and maintenance program instituted for this purpose.
Although PG&E stated that DCPP maintenance training instructors caution trainees to avoid close wire-heater proximity, they cemnitted to revise maintenance and training procedures to specifically address this point.
See paragraph 4.E(3) below.
The resolution of this issue involves commitments to complete inspections, disconnect heaters, revise procedures, and ensure that all affected Limitorques are trended.
Implementation of these measures will be reviewed in a future inspection and is identified as Open Items 50-?75/86-33-06 and 50-323/06-31-06.
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(2) EQ Training PG&E developed training lessons for DCPP Instrument and Control (I & C) technicians and electrical maintenance personnel which instruct technicians in the background, and requirements of 10 CFR 50.49 and review the procedures which govern EQ related activities. These procedures are NPAP C-41 Maintenance and Surveillance of EQ Equipment at DCPP, AP D-756 Maintenance and Surveillance of EQ Equipment, AP C-760 Maintenance of EQ (Main-tenance Dept.), AP C-761 Condition Monitoring of EO Electrical Equipment and AP C a51 Maintenance of EQ (I & C). This training and retraining is to be provided on a biannual schedule. The maintenance training journeyman program provides personnel with hands on training using approved procedures in a classroom environment.. This program is scheduled for INP0 accreditation in the summer of 1987. The inspector interviewed two I&C tech-nicians who had performed EQ an surveillance and found that one had received training appropriate to maintaining EQ eouipment and the other had not. The inspector determined that there was also a program for instruction in E0 requirements for certifi-cation of DCPP QC inspectors.
(3) EQ Maintenance Program DCPP site is responsible for maintaining qualified equipment in a qualified condition by incorporating EQ naintenance requirements intn station maintenance programs. Review of the procedures listed in paragraph 4.A abcve indicated that these requirements have been, in general, properly incorporated into site and departrent procedures.
PG&E has placed all plant equipment on a computerized scheduling system which monitors and manages corrective maintenance, planned maintenance and surveillance testing. The old system, preventive maintenance and testing schedule, has been phased out for this new system. Currently, the equipment requiring surveil-lance testing'for Units one and two, the EQ eouipment for Units 1 & 2, and the equipment scheduled for planned maintenance at linit I have been put into the new Plant Interaction Management System (PIM's). The remaining Unit 2 equipment is scheduled to be entered in the program in the first quarter of 1987.
The inspector interviewed Quality Control Engineers on PG8E's prooram to verify that qualification would be maintained for qualified equipment that undergoes corrective or routine m_aintenance and surveillance testing.
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The Equipment Information Data base identifies components as EQ in the data base and on work orders. The DCPP QC staff was in the process of reviewing all equipment on the master EQ list scheduled for routive maintenance and surveillance testing and adding QC hold points and special instructions. Upon completion of these activities, a 100% review of each completed job for all quality related work, is to be performed by the QC staff.
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The inspector reviewed, on a sample basis, equipment identified in appendix C to SSER 15. The licensee was reouired to insti-tute a continuing program to review surveillance and maintenance records to identify potential age-related degradatiens and establish component maintenance schedules which include considerations of aging characteristics. The inspector verified that this electrical equipment was being trended. Currently, all'but two systems for Unit I have been reviewed and trending has been initiated. Unit 2 equipment trend data should be generated and placed in the equipment files by mid 1987. DCPP procedure MP E-57.4 titled EQ Maintenance and Surveillance of Containment Penetrations, Electrical Cable and LOCA splices provides necessary guidance for inspection as equipment ages.
Project Engineering's positions on maintenance requirements are outlined in PG&E memo Sig Auer to D. L. Bauer, August 12, 1926.
I & C equipment: transmitters, solenoids, switches, RTO's, Rad.
Monitors, etc. are trended by NPRDS (Nuclear Plant Reliability Data System) upon failure. The inspector reviewed the last surveillance test (STP I-6B) for the pressurizer pressure calibration of Unit I channels 455, 456, 457 and 474, finding conditions satisfactory.
During the review of the plant maintenance program to preserve
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the qualified status of qualified eouipnent it was noted that s
certain Limitorque valve actuators were not being cycled twice a
year as Limitorque calls for to keep the grease mixed and parts coated to enhance long term intermittent operation reliability.
The inspectors determined that the manufacturer's recommendation as documented in the EQ files had not been effectively communi-cated to plant maintenance personnel for incorporation into surveillance schedules.
PG&E provided information which justified not cycling the affected Limitoroues due to plant nperational restrictions. This was documented in DCPP's In-Service Testing Program document: "Pequest For Relief Fron Code Requirements" which had been accepted by the NRC.
In this document, PG&E committed to performing alternative types of exercising, surveillance and testing cf the listed components which included a number of qualified Limitorques. Maintenance records did not indicate that any loss of operability, degraded performance or evidence of lubrication problems such as grease separation, hardering or drying / wiping of parts as a result of less frequent cycling had been identified.
PG&E showed that other Limitorques routinely get cycled more frequently than semiannually due to normal operations but agreed to incorporate the requirement into maintenance procedures to ensure that qualified Linitorques are exercised at least semiannually. This area will be reviewed in a future NRC inspection to confirm that these commitments are being net for qualified Limitoroues and is identified as Open Items 50-275/86-33-05 and 50-323/86-31-05.
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C.
Environmental Qualification Master List (EQML)
The NRC inspection team reviewed the DCPP Units 1 and 2 EOML, PG&E Drawing No. 050909, Revision 8, dated 12/06/86 and associated docu-ments discussed below to verify the adequacy of the implementation of DCPP's EQML development and maintenarce procedures.
The EQML was based on a review of Technical Specifications, Emergency Operating Procedures (EOP), Flow Diagrams, Electrical Diagrams and Regulatory Guide 1.97, Revision 3. Categories 1 and 2 confirmed by field verification walkdowns.
The procedures listed in paragraph 4.A above establish procedures and responsibilities of company organizations for maintenance and control of the ECML. Review of these documents indicated that all types of equipment required to be qualified under 10 CFR 50.49 would have been covered.
As a validation check on DCPP's EQML, Erergency Operating Procedures (E0P) were reviewed with DCPP operations experts. The inspectors verified that selected equipment identified in the procedures as required during the accident were on the EQML. Records pertaining to EQML deletions were reviewed with no unjustified removals identified.
D.
Environmental Qualification Documentation Files PG&E's DCPP EQ documentation files are established at PG8E offices with duplicate files to be maintained at DCPP. The files are called Component Evaluation Reviews (CER) and consist of review and approval pages, system-cceponentevaluationworksheets(SCEW)), Environmental Zone Description (EZD), reference lists, parameter evaluations, accident profiles, installation and maintenance requirements, NRC IE IN and IEB reconciliations, and references including EQ test reports and supporting analyses, and related correspondence.
A CER is prepared for each specific type of qualified component designated by manufacturer and model, in a plant area exposed to the same environmental service conditions.
The NRC inspectors examined files for 21 selected equipment types.
In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selectively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified, similarity of tested equipment to that fnstalled in the plant (e.g., insulation class, materials of components of the equiprent, tested configuration compared to installed configuration, and documentation of both), evaluation of adequacy of test conditions, aging calculations for qualified life and replacement interval determination, effects of decreases in insulation resistance on equipment performance, adequacy of demonstrated accuracy, evaluation of test anomalies, and applicability of EQ problems reported in NRC IE Information Notices and Bulletins and their resolutions.
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The files were found to be generally well prepared and auditable.
Specific documentation findings were as follows:
(1) Conax RTDs, model number 7K45-10000-01 and 7K46-10000-01 (IH-36)
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The qualification basis was NUREG-0588. Category I.
Test specimen sinilarity to installed units was established using a letter form Conax documenting and justifying differences.
There were some deficiencies noted in the file: (a) Several of the RTDs used to measure containment sump temperature were subject to submergence. Qualificaton was based on a ten minute submergence test at 10 psig on an unaged. sample. PG&E produced another test report they had on file which included a 30 day submergence test on a similar sample.
(b) The qualified life cf the RTD was calculated based on an ectivation energy of 3.9 eV for polysulfore and did not consider the limiting material in the RTD.
PG8E committed to recalculate the qualified life using an appropriate activatien energy based on Kapton and a revised operating temperature. The initial calculation used 250 F.
Revision to this calculatier will be reviewed in a future NRC inspection and is identified as Open Itens 50-275/86-33-08 and
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50-373/86-31-08.
(c) One of two channels of RTDs used in the LOCA test went out of tolerance by over 100 F.
This occurrence was not addressed in the file or test report.
PGEE cited discussions with Conax resulting in the determination that the chamber penetration had caused the accuracy problems. They contended that the initial part of the test on the one channel combined with the whole test on the second channel demonstrates qualification.
It was also noted that the LOCA data showed several instances in which some RTD readings deviated from the others by more than the required accuracy of 1.75 F.
However the data could not be properly evaluated against this specification because it was rot estab-lished how the specification was to be applied.
In response to this concern, PG&E performed an analysis which showed that the funtional performance requirement (accuracy) for the applica-tions of tne RTD in question should be relaxed to values appropriate for their service. The recalculated accuracy specifications wi tin which required instrument loop accuracy
for the most limiting application (RCS loop temperatures) would still be met, 2.75 F, now bounded the maximum deviation from one RTD specimen LOCA test reading to another (other than the anomalous 100*F) which provided sore assurance that the RTDs were operable and would be cualifiable. PGAE stated that they believed that the direct LOCA test RTD readinos were insuf-ficiently reliable for judging RTD performance due to thermal gradients and lack of a tenperature standard in the test. They proposed to demonstrate that the RTDs had met the accuracy under LOCA conditions by performing a loop accuracy analysis of the most limiting accuracy application using pre-and post-LOCA test RTD calibration values and then applying loop insulation resistance (IR) values measured under LOCA conditions and corrected for voltage and cable length to calculate the resultant RTD sianal error due to parallel leakage paths. A preliminary rough calculation indicated that RTD performance
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should be able to be shown within tolerance. This provided the
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basis for a determination of operability of the RTDs with respect to plant technical specifications and a JC0 which was being prepared for the NRC Resident Inspector's review.
Subsequent to the inspection, PG&E provided the final results of this analysis which confirmed that that the RTDs had met the accuracy. specifications for their various applications stating that it was being incorporated in the EQ file. However due to the lack of adequate functional performance requirenents and acceptance criteria in the file as reviewed, this constituted an EQ file deficiency and is identified as Potential Enforcement /
Unresolved Items 50-275/86-33-01 and 50-323/86-31-01.
(2) Minco Type S-8809 resistance temperature detector (RTD) (CER IH-30) This component is used.as a temperature sensor for density (compensation for the Reactor Vessel Level IndicationThe System RVLIS).
level for its DBE. Submergence was not adequately addressed in the file which contained a letter from Westinghouse. claiming the unit housing constitutes a water-tight conduit containing the electrical equipment. Qualification depended on showing the housing is water tight rather than demonstrating flooded perfor-Vestinghouse cited successful testing which subjected mance.
i the housing to 100%. humidity at 75 psig and successful helium
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leak tests.
However. the watertight integrity of the housing, f,
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was not demonstrated by a submergencence type testc
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Basedonthisconcern,PG&EdeclaredtheRVLISinohable pending an operability evaluation. The information in the EQ file formed the basis for a determination that the RVLIS Was operable in conjunction with a failure modes and ef facts r
analysis in which the assumed loss of RVLIS referen e and
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r variablelegdensitycompensationwouldnot{ produce' intolerable AJC0wasbeingpreparedtothiseffestforthe/RC
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Resident Inspector's review.
Subsequent to the inspection, PG8E submitted additional'infor-
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mation to attempt to demonstrate the' watertight integrity of the,
>v RTD housing.
It showed that the' cable entrance at thestop of
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the stainless steel tube is sealed with a type of epoxy potting compound and included information on testing of this material
to show satisfactory performance under submergence.
It was not clear, however, that the. testing cited wascon a similar applica-
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tion of the material such that its perforr,.wce in the plant
application could be assured. This issue is' identified as
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Potential Enforcement / Unresolved Items 50-275/86-33-02 and
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50-323/86-31-02.
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(3) Rotork 14NA2 valve actuators FCV-356 and FCV-363 (CER IH-28)
outside Unit 1 containment.
FCV-356 closes to provide containment isolation for a large break LOCA when containment pressure reaches 22 psi. The actuator functions to close the line between Component Cooling Water Supply and the reactor coolant pumps.
FCV-363 functions the same as FCV-356 except it provides containment isolation for the reactor coolant pump component coolant water return. Only the position indication switches on these actuators require environmental qualification under Rotork test report No. N14/2. The valves are outside containment and have been. exempted from EQ except for high radiation which could occur during post-accident recirculation.
Only the position indication switches which drive the monitor units are qualified for recirculation produced radiation. The justification for the qualification of the switches only is based on the fact that containment isolaticn is not required during HELBS outside containment. To further assure that failure of valves FCV 356 and FCV 363 has no impact on safety, a failure analysis was performed. Theradiationspecifgcationsforthe valve position indication switch is 6.06 x 10 rads. Test report XN14/2, " Actuator Radiation Subjection" for the Rotogk model 14NA2 indicates a radiation exposure level of 30 x 10 rads without degradation of the equipment which would affect its functionability. The documentation supported the radiation
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qualification of the position indication switch. Arrhenius analysis of thermal aging had been calculated based on 104 F, but revised to 140 F due to internal temperature rise and process fluid. Both calculations showed that thermal aging requirements are net.
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-(4) Limitorque SMB-00, ID No. M0V-8703, File CER IH-7A, in Unit I containment, opens the Residual Heat Removal (RHR) system return line to the Hot Leg for Emergency Core Coolant System (ECCS) change over from Cold leg to Hot Leg recirculation within
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24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a design basis Loss of Coolant Accident (LOCA).
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/ 1 Limitorque Test Reports B0058, 600456, 80027, and 80212 apply.
Oualification level is NUREG 0588 Category II. There was no
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grease relief in the main gear box of this Limitorcues (See paragraph 4.E(4).) and documentation to support qualification of ich this Limitorque without a grease relief was not present in the I
file.
PG&E referenced and provided a copy of Westinghouse report WCAP 7410-L dated December 1970. This report showed goed
behavior of the Limitorque main cear housing grease after a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> temperature test at 325*F.
However, WCAP 7410-L failed to identify the type and si:e of the Limitorques and whether it bad
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r grease relief. This is identified as Potential Enforcement /
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Unresolved Items 50-275/86-33-03 and 50-323/86-31-03 and is
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discussed further in paragraph 4.E(a).
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(5) Limitorque SMB-00 actuators (CER IH-16) (Class B, H and DC Motors) TAG No. 8805A located outside of Unit 1 containment and 8805A located outside of Unit 2 containment open on a safety )-
injection signal to supply refueling water storage tank (RHST water to the suction inlet of charging pump for high pressure injection and injection of the boron injection tank. They close
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.approximately 30 minutes after LOCA to shift from the injection mode to ECCS recirculation mode. After ECCS recirculation is
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established, their safety functions are complete. Limitorque m
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valve actuator Qualification Reports B0058, B0003, B0009, and B0027 apply. The qualification level of these MOVs is NUREG-0588, Category II. No file were deficiencies noted.
(6) Limitorque SMB-00 TAG No. 8976 (CER IH-16) outside Unit 1 con-tainment cJoses the line between the RWST and the Safety injection pumps on changeover:to ECCS recirculation mode.
Limitoro.ue Test Reports B0058', B0003, B0009, and B0027 apply.
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. Qualification level is NUREG 0588 Category II. No deficiencies
were noted.
(7) Limitorque SMB-00, Tag No. FCV 66'8 (CER IH-16) located outside
Unit 2 containment operates the Hydrogen Purge System outside containment isolation valve in the line to the plant vent in
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the event that the hydrogen recombiners inside containment are unable to maintain hydrogen levels below the post accident limits
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to provide a filtered path from the. containnent atmosphere to the
.x plant vent. Limitorque Test Reports B0058, B003, B009, and 80027.
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apply. The qualification level of this MOV is NUREG 0588, Category II. No file or walkdown deficiencies were noted.
(8) PG&E indicated that several Limitorques inside and outside containment had heaters in their switch compartments which introduce a potential burn harard to adjacent wiring in close proximity. Additionally, the higher ambient tenperature resulting from energized heaters may invalidate Arrhenius qualified life calculations unless the higher service
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PG&E provided documentation prior to the exit which showed that
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actual ambient temperatures with heaters energized were-bounded by 170 F based on temperature indicating strips in the switch compartments.
Qualified life calculations were verified to have taken this tenperature into account. This issue is dicussed in detail in paragraph 4.B(1) above under IN 86-71.
(9) festinghouse core exit thent.ocouple reference junction enclosure (EH-24) The qualification basis was 10CFR50.49. The originally supplied Westinghouse junction box was modified by PG&E to seal it from the harsh environment. The test specinen was identical to the installed enclosures and the plant profile was enveloped
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by the test, but was of significantly shorter duration.
It was
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noted that the gasket used on the test specimen was not thermally
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or radiation l aged prior to the accident test. An analysis
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was included in the file to justify the lack of aging. The I
inspectors examined the plant installation, findings it~ satis-
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factory. The lifetime of the thermoccuple reference junction was specified as 20 years with the gasket specified as 10 years.
Replacement of the gasket was called for in the maintenance replacement section of the file, but replacement of the reference junction was not. A revision to the file was prepared,
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approved, and will be incorpcrated in the file to include replacement of the reference junction.
(10) Westinghouse incore thermocouple connectors (EH-25). The qualification basis was NUREG-0588, Category _II.
The test specimens were identical.to the installed connectors and the plant profile was enveloped by the test. The entire corrector assemblies are to be replaced every 5 years.
Insulation resistance values measured during the test were typically above 100K ohms. A statement that these values were acceptable was included in the file without any specific justification other
than that these' values are quite high and would not be expected
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to cause problems..PG&E demonstrated to the inspectors' satis-faction'that irs greater that about 50 ohms had an insignificant effect on thermocouple output indicating that the values in the file were sufficient.
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(11) Rockbestos Firewall III radiation cross-linked polyethylene (RXLPE) cable and coaxial cable (CER EH-4). The current Rockbestos report on RXLPE was included in the file along with the current coax report. The cable is used for power, control, and signal applications. The plant conditions are easily enveloped by the tests. A special test was run at 540 F to qualify the cable for MSLB direct steam impingement on conduit.
Performance requirements were addressed for the non-coaxial cable for 4-20 mA transmitters and for RTDs. No specific performance criteria have yet been developed for the coaxial cables because they are only used outside containment where they are not required to mitigate any accidents; the cualification
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the cable.
i (12) Continental signal and thermocouple cable.
(EH-08)The qualification criteria was NUREG-0588 Category II. The Plant employs 2 conductor #16AWG with 25 mil silicone insulation and 45 mil-silicone jacket all of which is in conduit. The test
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l spdcimens were single conductor, #12 AWG, with 45 mil s11icone insulation. A discussion of the similarities is
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provided. The LOCA test environment enveloped the plant conditions. An analysis was provided to shnw that the MSLB environment would not heat the cable beyond the LOCA test
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temperature (due to the relatively short duration of the MSLB scenario). This analysis was based on a conduction analysis
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which assumed the conduit acted as a barrier be-tween the steam t
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and the cable. The question arose as to how effective a barrier the conduit really is. Additional analysis was provided which showed that the cable temperature would remain at or below the LOCA temperature even if the conduit allowed for steam penetration.
(13) Gamma Metrics Neutron Flux Monitor System (IH-33) The qualification criteria was IOCFR50.49. The system consists of a neutron detector (one guarded fission chamber, one unguarded fission chamber), a junction box, coaxial and triaxial cables, cable connectors, an amplifier, and a signal processor.
The first three components are located inside containment in a high radiation environment. The others are outside containment.
The installed components are identical to tested specimens.
The test environmental conditions enveloped those of the plant.
A question arose corcerning the lack of a submergence test because the detector is located below the flood level (by 6 ft, 6 inches). The issue was resolved when it was pointed out that the lower 10 ft of the detector were in a welded stainless steel enclosure. The Position of the detector where electrical connections are made is 3 ft 6 inches above the flood level and thus not subject to a submergence cordition.
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E.
Plant Walkdown Inspection EQ list equipment at DCPP has individual oranga tags which identify the equipment as qualified and reference the DCPP procedure that pertains to activities which nay affect the equipment. The inspectors conducted a physical inspection of 12 selected pieces of equipment and field wiring inside and outside containment in Unit 1 and outside containment in Unit 2.
Equipment was checked for nameplate data or other identifying marking, mounting location and orientation, material condition and preservation, installation interfaces, normal service ambient envirormental and functional conditions and any special features or attributes to verify that all conditions were consistent with the requirements identified in the EQ documentation files including evidence where applicable that required EQ-related maintenance had been performed. The inspectors also performed an inspection of Limitoque valve actuator internal wiring in accordance with NRC Temporary Instruction 2515/75 to assess the existing condi-tions and licensee action relative to IE Information Notice 86-03.
The results of the walkdown inspection are discussed below:
PG&E had committed to correct deficiencies associated with equipment listed in Appendix B of SSER 15 as a licensing condition and had certified to the NPC that the conditions had been made.
The inspector verified, on a sample basis, by physical inspection, and by review of documentation that appropriate corrective action had been completed including replacement of the Barton 763 suppressed range pressurizer
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pressure transmitters with Rosemount 1153 transmitters. The inspector noted also that remaining Barton 763 and 764 transmitters have had the special modification kits installed where required. Some of these transmitters are being replaced with equivalent Rosemount models when other corrective maintenance is required.
The following comments pertain to individual pieces of equipment that were examined during the walkdown inspection:
(1) -Barton 763 and 764 transmitters (CER IH-24) Unit 2 Steam generator and main stean pressure transmitters Tag Nos.: PT-534, and 535 and PT-544,545 and 546 were examined along with other equipment listed in Appendix B of SSER 15. No deficiencies were identified.
(2) Plant walkdown of Rotorks on valves FCV 356 and FCV 363 fourd that valve FCV 356 contained a compartment heater which was functioning. The file was checked to determine if the ambient temperature due to temperature rise from this one compartment heater had been considered in the aging qualification of the switches. PG&E provided documentation showing cualification based on 140 F and confirmed that the valves carry component cooling water with temperatures at or below 104 F anbient temperature.
(3) Linitorque valve actuators 8805A, 8976, and FCV 668 outside Unit 1 containment (SMB-00s) Motor heaters were connected and energized. Motors had brakes. There were no compartment heaters.
All wiring to the limit switch and torque switch and any jumper wire was either ICOR ETFE, Raychem XLPE, Raychem Flamtrol, or Rockbestos Firewall SIS. There were no terminal blocks.
Terminations consisted of bolted ring-tongue terminals which were insulated with Scotch No. 33 tape qualified in file No. 137.014, CER No. EH-26 for use in Limitorques.
(4) Limitorque SMB-00, ID No. 8703, (CER IH-7A) (Class H/ Type RH)
located inside containment Unit 1 opens the Residual Heat Removal system hot leg return line to shif t ECCS from cold to hot leg recirculation. The main gear case did not have a grease relief. Documentation of qualification without a grease relief was not present in the CER.
Internal wiring was Raychem Stylan.
Raychem splices were used instead of terminal blocks.
No heaters were in the motor or switch comparment. Two "T"-drains were on the motor. Limitorque Qualification Reports B0050, 6_00456, B0027, 80212 pertain to this M0V.
PG&E determined which Limitorques in containment did not have grease reliefs based on previous inspection records. They stated that the particular actuators in question are mounted with the valve stems vertical and limit switch compartments en the side, i.e. the switches oriented horizontally, such that
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grease which might seep through seals into the limit switch compartment would most likely collect at the bottom of the compartment cover rather than jeopardize operation of the linit or torque switches. They further stated that based on their standard maintenance practice of providing an expansion volume for the grease it was unlikely to penetrate the seals into the limit switch or motor compartments to begin with. These factors formed the basis for their determination that the Linitorques were nnt rendered inoperable due to the lack of grease reliefs.
Subsequent to the inspection, PGEE submitted an engineering analysis based on the standard 20% expansion volume in use and calculations of the expected thermal expansion of the grease using a conservative time / temperature profile, which showed that there would be sufficient expansion margin to provide reasonable assurance that grease reliefs would not be necessary. This analysis was reportedly being incorporated in the EQ file to justify this dissimilarity between installed equipment and tested samples. The lack of this analysis in the file at the time of the inspection represents a file deficiency and consti-tutes Potential Enforcement / Unresolved Items 50-275/86-33-03 and 50-323/86-31-03 as discussed in paragraph 4.0(5) above.
(5) The NRC inspectors examined internally two limitorques in Unit 1 in containment (including FCV-8112 replaced in 10P4) and two outside containment. Two M0Vs outside Unit 2 containment were also examined (including FCV-668 previously inspected by PG&E). The results were consistent with the records and PG&E's inspections confirming that DCPP Limitorques contained qualified internal control wiring as of 11/30/85.
(6) 3M Scotch 33+ PVC Tape /Scotchco Putty splice insulation system was qualified to (CER EH-26) NUREG-0588, Category II. During the walkdown inspecticn, it was found to have been used in the installation of some NAMC0 limit switches that were purchased after the effective date of the EQ rule (10 CFR 50.49),
February 22, 1983. The limit switches were reouired to be qualified to the level of 10 CFR 50.49. Under paragraph (1) of 10 CFR 50.49, the qualification of the splices should have been upgraded to that of the components they served. This is identified as Potential Enforcement / Unresolved Items 50-275/
C6-33-04 and 50-323/86-31-04.
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