IR 05000280/1990011
| ML18153C154 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/14/1990 |
| From: | Conlon T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C153 | List: |
| References | |
| 50-280-90-11, 50-281-90-11, NUDOCS 9003270175 | |
| Download: ML18153C154 (9) | |
Text
Report-Nos.:
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 50-280/90-11 and 50-281/90-11 Licensee: Virginia Electric and Power Company Glen Allen, VA i3060 Docket Nos.:
50-280 and 50-281 Licensee Nos.: DPR-32 and DPR-37 Faci 1 i ty Name:
Surry 1 and 2 3/; t;J 9D Date 1/gned
,/14 !'10.
Date Signed SUMMARY Scope:
This special, unannounced inspection was conducted in the areas of employee concerns regarding inadequate maintenanc~ of the Reactor Protection System, incorrect module found in steam generator control loop for feedwater control and questionable Raychem splices installed on 50 Rosemont transmitters in containmen Results:
One non-cited violation was identified in th~ area of Procedural Controls for Storage, Repair, and Control of Installation of Control System Component The employee concerns were partially substantiated*
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- Persons Contacted Licensee Employees REPORT DETAILS W. R. Benthall, Supervisor~ Licensing
- S. R. Burgold, Supervisor, Instrumentation and Controls (I&C)
H. D. Collar, Supervisor, Quality Control
- D.S. Hart, Supervisor, Quality Assurance
- M. R. Kansler, Station Manager
- J. W. Ogren, Supervisor, Plant Maintenance
- E. R. Smith, Jr., Manager, Quality Assurance
- T. B. Sowers, Superintendent, Engineering E. Watts, Supervisor, Onsite Engineering-Electrical Other licensee employees contacted during this inspection included engineers, and technician NRC Resident Inspectors
- W. E. Holland L. Nichol son J. York
- Attended exit interview Employee Concerns Inadequate Maintenance of Reactor Protection System (RPS)
(RII-90-A-0008), and Incorrect Module Found in the Steam Generator Control Loop for Feedwater Control (1)
Concern The NRC (RII) received an employee concern regarding inadequate maintenance of the RPS by the use of non safety related, non traceable and non qualified parts and lack of procedures. Also, an inoperative module was found in the feedwater control syste The module required revisions before the control loop would function properl *
(2)
Discussion These two concerns were examined together due to their commonalit Interviews were held with several I&C
- Technicians and supervisors, QA auditors and QC inspectors. The I&C maintenance shop and the storage area were examined during
- this inspectio The inspectors observed several work bench drawers which contained printed circuit (PC) boards that had been cannibalized to obtain certain components needed to repair other PC board There were also drawers that contained resistors, diodes, capacitors **. etc., which were not controlled in any manne The repairs of the PC boards were accomplished using the manufacturer's troubleshooting procedure The testing of the repaired modules is performed usually by the individual perform-ing the repair after which the module is placed in unlocked storage cabinets located in the same room as the reactor control system cabinet There was no procedure found which identified the acceptance criteria or required any veri fi cation for repaired module acceptance. The repaired modules were tagged to indicate the date of repair and placement of the module in the storage cabinet The inspectors were advised that when a module is taken from these storage cabinets to replace a failed module, *t~e repair tag is attached to the work request document and eventually the serial number of the replacement module is entered into a loop folder for that instrumentation loo No other document is generated to indicate where the module has been p 1 aced or why the action was necessar There is no procedure that directs these activitie Quality Assurance Audit S88-20, dated March 17, 1988, identified w~aknesses in administrative control of procedures, predictive maintenance and material storag As a result of these findings Administrative Procedure No. SUADM-ADM-47, Operation of the Instrument Department~ was issued September 18, 198 This procedure gives general directions for instrumentation personnel performing maintenance activities but does not provide specific instructions regarding control for repair parts for PC boards and modules, or specify any acceptance testing or peer verificatio Quality Assurance Audit No. S89-25 dated January 31, 1990, again identified that preventive maintenance (PM) procedures had not been deve 1 oped and; therefore, traceability of e 1 ectroni c components is not maintained, instructions for repair of process modules were not provided and electronic components were not stored in the proper environmen Management has addressed these problems but had not yet completed the corrective actions which require the development of additional procedure *
Discussions were held with various technicians and supervisory personnel regarding these employee concerns. It should be noted that the technicians are well versed in the methods for performing I &C maintenance, both planned and emergency even though no procedures exist to control their total activitie A 11 those interviewed stated that they performed I&C maintenance in a similar manner with regard to module repair and replacemen The inspectors were advised that control modules
- had been interchanged between uni ts when one unit was not operating and the other unit was in operation and required emergency repairs. The only documentation was the issuance of a repair work order for the defective module that was reinstalled into the non non-operating unit control system. It was stressed that* never have modules been exchanged when both units were operatin Additionally, the inspectors were informed that an I&C supervisor had to approve the exchanging of modules between unit No documentation was developed other than a repair work request during these exchange From these interviews along with the examination of the I&C shop facilities and storage areas, it is apparent that there is a lack of procedural contra ls for:
contra l of mi see 11 aneous electrical parts such as diodes, resistors,, transistors, capacitors, etc.; repair, testing and storage of repaired modules; cannibalization of parts from rejected PC boards; and the interchanging of modules between unit It was strongly emphasized by the I&C technicians and *
supervision that any time a repaired module is installed a performance test (PT) is conducted to insure proper operation of the instrumentation or control loo By this testing, there was a verification check of the adequacy of the module repair but this appeared far removed from the actual repair cycle and may or may not test the entire functions for the repaired modules since certain modules have varied application (3)
Conclusions The concern regarding inadequate maintenance of the reactor protection system was partially substantiated in that there were insufficient procedural controls in place to provide assurance that PC boards and control modules were repaired with qualified parts, that testing of repaired modules was adequate, and that storage of repaired modules was controlle In view of the fact that instrument and control loop performance testing is performed when a module is replaced, the safety significance is greatly reduce In addition, the licensee through QA audits has identified the weaknesses in the I&C maintenance department
and.has committed to have in place by April 20,1990, procedures to control those activities found deficient by the QA audits and further emphasized by this inspectio CFR Part 50 Appendix B, Criterion Vin part requires activities affecting quality shall be perscribed by documented instructions, procedures, or drawings, of a type. appropriate to the circumstances *.. Contrary to this requirement the licensee did not have adequate procedures to control the maintenance and repair of componets in the reactor proteGtion and control system This condition is identified as a non-cited violation (NCV) 50-280,281/90-11-01, Lack of Procedural Controls for Storage, Repair and Control of Installation of Control System Component This licensee identified violation is not being cited because criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfie The second concern was not substantiated because the feedwater control loop in question was non safety-related; therefore, no documents were* generated and the module in question was not available for revie However, the fact that the module did not function properly and was later modified could be attributed in part to the previously discussed concern and violatio Raychem Splice on Cable to Rosemount Transmitter Inside Containment (RII-90-A-0015)
( 1)
Concern The NRC (RI!) received information on the possibility of inadequate Raychem splices on approximately 50 Rosemount transmitters located inside containment (see attachment).
(2)
Discussion
{3)
The licensee phoned Raychem to obtain informatfon about ordering an engineered kit for a specific Raychem splice that was designed by VEPCO engineer Raychem informed VEPCO that they (Raychem) would riot have designed the splice, for this
- application, like VEPCO had don Also, the inline butt splice would not be an effective seal due to the difference in wire diameter The wire from the transmitter is approximately 0.042 inches in diameter and the field were is approximately 0.133 for
- 14 AWG and 0.108 for #16 AW Raychem declined the request to furnish an engineered kit with all the parts as shown on the VEPCO drawin Findings The inspector reviewed the VEPCO designed splice configuration and held discussions with engineering personnel at the site and
1-~
the corporate office in Richmond, Virgini Also, discussions were held with appropriate I &C supervision and QC personne The following information was obtained:
(a)
Engineering (b)
The Raychem splice, as shown in the attachment, is used on Rosemount conduit seal connectors inside containmen There are six (6) of these splices in Unit 1 and fifteen (15) splices in Unit This splice design is used whenever the licensee replaces an existing Conax conduit seal connector with a Rosemount, model 353C, conduit seal connector (CSC).
This occurs whenever the transmitter is replace Both the Conax and Rosemount CSCs are EQ qualified but the Conax is difficult to disassemble in the field; therefore, the licensee is replacing the The Raychem splice is an unusual design that was neces-sitated by the unqualified inline butt splice (items 1 and 2 in the attachment) and the fact that the licensee did not want to seal on the jacket of the incoming field cabl The inspector considers the splice to be qualified because all the Raychem parts that make it up are individually qualified in similar application The term
"splice" as used is somewhat of a misnomer when.in actuality the design should be called an enclosur I&C Supervision Discussions were held with I&C supervisors and specifi-cally the supervisor that particip_ated in the telephone call to Rayche To the best of his memory and with the aid of notes, Raychem did point out that the butt splice (items 1 and 2) would be considered unqualified by them (Raychem).
With respect to furnishing "engineered kits",
Raychem pointed out that the VEPCO design was unusual and that they would not have designed it as such for the particular applicatio Furthermore, "engineered kits" furnished by Raychem are kits involving designs done by Rayche The supervisor stated that Raychem did not pass judgement on the adequacy of the overall configuratio (c) Quality Control Discussions were held with QC personnel to determine the extent of inspection given to the installation of the subject splice. The install at ion was done in accordance with NUS-2030 and Engineering Work Requests (EWRs)89-338
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and 89-42 The EWR has a QC hold point on line item Procedure SUADN-QA-03 defines hold point as a preselected step in a procedure that requires QC witnessin Interviews with several QC inspectors verified that Raychem splices in containment are always witnesse (4)
Conclusions The inspector agrees with the licensee that the subject splice, even though it is an unusual design, is qua 1 i fi ed for the intended use as a water/moisture proof enclosure for the.two (2)
unqualified inline butt.splice The concern was not substan-tiate.
(Closed) Violation 50-280/89~12-0l, Failure to Maintain Cable Tray Covers in Place as Required by Appendix The licensee submitted a response dated July 16, 1989, which stated that procedures have been revised or written to insure that cable tray covers are reinstalled after construction and maintenance activities are completed; and cable trays will be marked to indicate where covers must be in plac Walk downs by the regional and on-site inspectors verified that this work is nearing completio * Licensee Event Report (LER) Review (92700)
(Clos~d) LER 280/89-37, 11A 11 S/G Header to Line SF Channel IV Declared Inoperable Due to Malfunctioning Pressure Comparato This issue involved a failure of a comparator module and the failure of the replacement module after approximately four hours in servic As the result, a commitment was made to review the repair and testing methods associated with module refurbishment* in the I&C sho Additionally a QA audit identified a finding regarding traceability of electronic components not being maintaine In view of the commitments made by the licensee in the exit meeting for this inspection, this item is close.
Exit Interview The inspection scope and results were summarized on February 16, 1990, with those persons indicated in paragraph The inspectors described the areas inspected and discussed in detail the inspection results listed belo Proprietary information is not contained in this report and dissenting comments were not received from the license The non-cited violation 50-280/281/90-11-0l, Lack of Procedural Controls for Storage, Repair and Control of Installation of control System Components was discusse The licensee committed to develop and have in place by April 20, 1990, procedures for:
U V
Co~trol of miscellaneous electrical parts such as:
diodes, resi~tors, transistors, capacitors, et Repair testing and storage of repaired modules Cannibalization of parts from reject printed circuit (PC) boards Interch~nging of components between units Attachment:
Specification for Electrical
.Installation
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ATTACHMENT
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Pa *.28 VIRGIN I A POWER STANDARD N NUS~2030 'NAS*3014 SPECIFICATION FOR ELECTRICAL INSTALLATION 2 ---11....i RAYCHEM BREAKOUT SPLICE WITH ROSEMOUNT CONDUIT SEAL FIGURE N /16 ~,...._
MINIMUM h
1/16 MI *
MINIMUM i,.,.,.---.~---
L NOTE 5-2..
I MINIMUM--,
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NOMINAL INCOMING FIELD CABL 2C/16 WITH SHIELD MATERIALS
< SEE' a NOTE 3 >
1>
BUTT SPLICE** BURNOY YSV1418 FOR AWG 22 * 14 WIRE< 2 * REQUIRED >
2)
BUTT SPLICE JACKET* RAYCHEM NO, WCSF*070*N < 2 *REQUIRED>
< FOR ELECTRICAL PROTECTION ONLY )
3>
SHIM SLEEVE* RAYCHEM NO. WCSF*115*N 4)
SHIM SLEEVE* RAYCHEM NO. WCSF*200*N OR WCSF*200*U S>
CABLE BREAKOUT* RAYCHEM NO. ~02A812*52/144 6)
OVERALL SEALING SLEEVE - RAYCHEM NOo WCSF*300*N NOTES 1>
SEE* C DETAIL A> OF FIGURE 1aA FOR INSTALLATION OF ITEMS N AND N0.2 ABOVE 2)
SEE* C DETAIL B > OF FIGURE 10A FOR DESCRIPTION OF ITEM N )
SHIELD ON INCOMING CABLE TO BE TAPED BACk AND INSULATED FROM GROUN 4)
SEALING SLEEVE ( ITEM NO. S > TO EXTEND PAST BREAKOUT A MINIMUM 5 >
DIMENSION 'L' IS TO BE CHOSEN SUCH THAT THE NOMINAL PRE-SHRUNK LENGTH ai::: wr.~~ - ~c:1i,i. ~ T ~ ~, 1Jrucc
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