IR 05000282/1986012
| ML20212E055 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/24/1986 |
| From: | Gautam A, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212E022 | List: |
| References | |
| 50-282-86-12, 50-306-86-14, NUDOCS 8701050232 | |
| Download: ML20212E055 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-282/86012(DRS); 50-306/86014(DRS)
Docket Nos. 50-282; 50-306 Licenses No. DPR-42; DPR-60 Licensee:
Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 Facility Name:
Prairie Island Nuclear Generating Plant, Units 1 and 2 Inspection At:
Red Wing, Minnesota Glen Ellyn, Illinois Inspection Conducted: November 17 through December 2, 1986 bw$ tW
' S Inspector:
Anil S. Gautam
(1/24/8k; Reactor Inspector, RIII
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Date Also participating in the inspection and contributing to the report were:
R. J. Smeenge, Reactor Inspector, RIII S. Alexander, Engineer, I&E J. Grossman, Technical Staff Engineer, Sandia National Laboratories W. Carpenter, Consultant Engineer, Idaho National Engineering Laboratory R. Vanderbeek, Consultant Engineer, Idaho National Engineering Laboratory bwh NW Approved By:
J. W. Muffett, Section Chief M
N !Mkb Plant Systems Section Date Inspection Summary Inspection on November 17 through December 2, 1986 (Reports No. 50-282/86012(DRS); 50-306/86014(DRS)
Areas Inspected:
Special announced safety inspection of the environmental qualification (EQ) of electric equipment within the scope of 10 CFR 50.49.
The inspection included licensee action on previous EQ inspection findings; action on SE1/TER commitments; EQ program compliance to 10 CFR 50.49; adequacy of EQ documentation; and a plant physical inspection of EQ equipment (Modules No. 30703 and No. 25176).
Results:
The licensee has implemented a program to meet the requirements of ID CW50.49.
Certain deficiencies were identified in the areas inspected and are summarized below.
0701050232 861229 PDR ADOCK 05000202 O
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POTENTIALLY ENFORCEMENT / UNRESOLVED ITEMS-Ites Numbers Description Report Section 50-282/86012-01(DRS)
Various discrepancies in 6a(1)
50-306/86014-01(DRS)
the installation of Raychem Heat Shrink Tubing on EQ cable splices in Units 1 and 2 50-282/86012-02(DRS)
Eleven Limitorque Actuators 6b 50-306/86014-02(DRS)
in Unit 1 and 2 Containments had plastic shipping caps on their Gear Case relief valves, in conflict with EQ tested configurations OPEN ITEMS Item Number Description Report Section 50-282/86012-03(DRS)
Corrective action on 6a(2)
50-306/86014-03(DRS)
deficient Raychem splices in Unit 1.
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DETAILS 1.
Persons Contacted a.
Northern States Power Company (NSP)
- E. Watzl, Plant Manager
- L. Eliason, General Manager, Nuclear Power
- G. Goering, Manager, NTS
- D. Mendele, Superintendent (E&R)
- C. Kinney, Superintendent Quality Assurance (QA)
- P. Kamman, Superintendent (QA)
- J. Hoffman, Superintendent, (TE)
- K. Beadell, Superintendent (QE)
- B. Fraser, Lead Engineer Production
- G. Sundberg, Lead Engineer Production
- E. Burke, Sr. Production Engineer
- B. Linde, Operations Engineer
- J. Bystrzycki, Quality Control Engineer
- P. Suleski, Quality Assurance Engineer
- L. Bruce Anick, Quality Assurance Engineer
- D. Krech, Quality Assurance Engineer
- R. Pond, Sr., Electrical Engineer
- R. Sitek, Quality Assurance Engineer
- R. Gelschlazer, Engineer, NTS A. Hunstad, Staff Engineer b.
Consultants
- T. Maxey, Project Manager (TERA)
- M. Lawrence, Project Manager (IMPELL)
c.
U.S. NRC
- J. E. Hard, Senior Resident Inspector
- M. Moser, Resident Inspector
- Denotes those attending the interim site exit interview on November 21, 1986.
Denotes those attending the exit interview on December 2, 1986.
2.
Action on Previous Inspection Findings (Closed) Open Item (282/86003-03; 306/86003-03):
This item addressed the use of unqualified wires in various 10 CFR 50.49 designated Limitorque Actuators at the Prairie Island Plant.
The licensee subsequently performed a 100 percent inspection of Limitorque Actuators in Units 1 and 2 and replaced any unidentifiable or unqualified wires with qualified wires.
During the current review the inspectors reviewed records of the licensees inspection and performed an additional physical
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inspection of four Limitorque Actuators to verify the qualification ofjumperwires.
This review is also discussed in Section 6b of this report.
No violations of NRC requirements were identified. Any enforcement action in regard to the timeliness of this licensee corrective action has been addressed separately in NRC Inspection Reports No. 50-282/86003(DRS); No. 306/86003(DRS).
3.
Licensee Action on SER/TER Commitments The NRC inspection team evaluated the implementat. ion of the licensee's EQ corrective action commitments made as a result of EQ deficiencies identified by the NRC in the March 29, 1983, FRC/TER; April 25, 1983 SER; and March 25, 1985 final SER.
The majority of the deficiencies identified in the FRC/TER addressed documentation, similarity, aging, qualified life and replacement schedules.
All open items identified in the FRC/TER and the April 25, 1983, SER were discussed with the NRC staff, and the licensee's proposed resolutions to these items were found acceptable by the NRC, as stated in their March 25, 1985, SER.
The primary objective of the RIII EQ audit in this area was to verify that the appropriate analyses and necessary documentation to support the licensee's proposed and accepted resolutions to NRR were contained in the licensee's EQ files.
During this review the NRC inspection team reviewed EQ documentation relevant to prior discrepancies identified in SER's, including licensee corrective action on Limitorque Actuators, Endevco Accelerometers, Gould Century Motors, General Electric Motor Control Centers, Allen Bradley Terminal Blocks, Rosemount and Foxboro unqualified transmitters.
No discrepancies were found.
The NRC inspectors reviewed licensee actions in regard to the qualifica-tion of equipment in the Auxiliary Feed Water (AFW) pump rooms.
The licensee in their November 28, 1984, and January 25, 1985, letters to NRR had committed to relocating the turbine driven AFW pump stop valves outside the AFW pump rooms so as to eliminate a steam environment in these rooms during a HELB.
The inspectors reviewed the modifications performed and verified the appropriate relocation of the stop valves CV31999 and CV31998 outside the pump rooms.
The inspectors also reviewed the plant modifications to the containment spray caustic addition system to assure that the spray pH did not exceed 10.5 during certain accident conditions.
These changes were in response to the licensee's April 30, 1982, letter and a subsequent change to the plant Technical Specification TS 3.3.B.1.C.
These changes assured that the pH limit to which the electrical equipment in the containment was qualified, would not be exceeded.
All modifications were verified to have been completed.
No violations of NRC requirements were identified.
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4.
EQ program Compliance to 10 CFR 50.49 The inspectors reviewed selected areas of the licensee's EQ program to verify compliance to 10 CFR 50.49.
The licensee's methods for establishing and maintaining the environmental qualification of electrical equipment were reviewed in the followirg areas:
a.
EQ Program Procedures The inspectors examined the adequacy of the licensee's policies and procedures for establishing and maintaining the environmental qualification of equipment within the scope of 10 CFR 50.49.
The licensee's EQ program was reviewed for procurement of qualified equipment; maintenance of qualified equipment; modifications to plant that could affect qualified equipment; updating of the EQ master list; and review and approval of EQ documentation.
Procedures reviewed included the following documents:
N1ACD 8.11, " Environmental Qualification," Revisim 0, dated
December 31, 1985 and Revision 1, dated November 21, 1986.
N1AW1 5.1.3, " Design Inputs," Revision 1, dated March 14, 1986.
- N1AW1 5.1.12, " Modification Review Package Preparation, Review,
and Approval," Revision 1, dated March 14, 1986.
N1AW1 6.1.5, " Requisition Contents," Revision 0, dated
August 22, 1985.
SACD 3.1, " Prairie Island Plant Organization," Revision 11,
dated September 15, 1986.
SACD 3.2, " Work Control," Revision 13, dated September 15, 1986.
- SACD 3.11, " Training" Revision 4, dated September 15, 1986.
- SAW1 3.11,5 " Engineering and Technical Staff Training Plan,"
Revision 0, dated September 30, 1986.
SACD 3.12, " Nuclear Plant Maintenance", Revision 6, dated
September 15, 1986.
QA Audit Report AG 85-9-12
QA Audit Report AG-86-34-12
SP1223, " Unit No. 1 I&C Surveillance Calibration Procedure
Event Monitoring Transmitter Calibration," Revision 2, dated February 11. 1986.
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SP2223, " Unit No. 2 I&C Surveillance Calibration Procedure
Event Monitoring Transmitter Calibration," Revision 1, dated September 5, 1985 and Revision 2, dated November 20, 1986.
Plant Procedure D18, " Equipment Lubrication," Revision 15,
dated October 23, 1986.
Specific areas reviewed in these procedures included definitions of harsh and mild environments, equipment qualified life, service conditions, periodic testing, maintenance and surveillance, and upgrading of replacement equipment purchased after February 22, 1983.
The licensee's EQ program was found to identify methods for equipment qualification;.rovide for evaluation and maintenance of EQ documentation in an auditable form, including maintenance records; provide for updating of replacement equipment and control of plant modifications.
Based on the above review the inspectors determined that the licensee had established an adequate EQ program in compliance with the requirements of 10 CFR 50.49.
No violations of NRC requirements were identified.
b.
10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment IE Bulletin No.79-01B required licensees of all power reactor facilities with an operating license to provide a master list (MEL)
that identified each Class IE electrical equipment item relied upon to perform a safety function during a design basis event.
10 CFR 50.49 Paragraph (d) required licensee's to prepare a list of electric equipment important to safety and within the scope of the rule.
The NRC inspectors reviewed the Prairie Island MEL for compliance to 10 CFR 50.49.
Areas reviewed included adequacy of the MEL, technical justifications for removal of items from the MEL, and licensee reviews of the MEL for changes due to field modifica-tions.
The inspectors verified the completeness / adequacy of the list in terms of equipment needed under accident conditions through review of Piping and Instrumentation Drawings, Emergency Procedures, Technical Specifications and FSAR's.
The inspectors reviewed the deletion of ASCo solenoid valves and FCU Damper limit switches for the Containment Fan Cooler Units from the MEL, and found adequate technical justifications for the items removed from the list documented in Safety Evaluation No. 179.
Items removed were verified not to initiate any automatic spray functions or require any subsequent safety actions by the operator.
Additions or deletions to the list due to field modifications were found acceptable and adequate reviews had been performed.
The licensee identified no other additions or deletions to the MEL due to field modifications.
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The inspectors reviewed equipment needed to function under accident conditions, including equipment used during a steam generator tube rupture, loss of emergency cooling recirculation, and a loss of secondary heat sink.
Equipment needed for these accidents were identified in the Plant Emergency Procedures 1ECA-3.1, Revision 1, 1.1 Revision 0, and 1FRH.1 Revision 0 respectively.
All applicable equipment in the procedures were reviewed for applicability and inclusion in the MEL.
The MEL was found accurate for all items sampled.
No violations of NRC requirements were identified.
c.
EQ Maintenance Program The inspectors reviewed specific maintenance, replacement, surveillance tests, and inspections necessary to preserve the environmental qualification of EQ equipment on the MEL.
The NRC inspectors found no deficiencies in the licensee's methods for scheduling maintenance and surveillance, with the exception of the following:
(1) During review of maintenance activities performed by the licensee on Unit 2 transmitters, the inspectors observed that the housing cover of a Foxboro wide range transmitter 7.PT 718, for wide range of containment pressure, had been removed for maintenance.
When the cover was reinstalled, however, the license failed to replace the "0" ring gasket as required by qualification maintenance requirements in the EQ file.
On further review the inspectors also found that the Unit 2 maintenance Procedure No. SP 2223, Revision 1, required replacement of "0" rings only "as necessary," which was in conflict with established EQ maintenance requirements.
The Unit 1 maintenance Procedure SP 1223 was found to correctly require the replacement of "0" rings every time the housing cover was removed.
The licensee was informed that the Foxboro transmitter ZPT 718 was not qualified in its installed condition.
The licensee took immediate corrective action and installed a new "0" ring in ZPT 718, as well as revised their Procedure SP 2223 to require replacement of "0" rings every time the housing cover was removed.
The licensee also reviewed past maintenance records and reported that no maintenance activity requiring the removal of a transmitter housing had been performed during Unit 2 operation since the last Unit 2 outage.
The inspectors concluded that since Unit 2 did not operate with unqualified transmitters relative to this maintenance deficiency, past the November 30, 1985, EQ deadline, and the procedure had been revised prior to Unit 2 startup, the licensee's corrective action was adequate to satisfy this concern.
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No violations of NRC requirements were identified.
d.
Plant Procurement and Upgrading of EQ Replacement Equipment Licensee procedures were found to adequately address upgradina of replacement equipment purchased after February 22, 1983.
Procurement procedures and documents were found to adequately address appropriate quality and regulatory requirements regarding the environmental qualification of equipment within the scope of 10 CFR 50.49.
Checklists were observed to have been used to provide evidence of reviews and approvals.
For example, procurement packages for Limitorque motor operators, Raychem splices, Rosemount transmitters, Foxboro transmitters, Conax RTD's, ASCO solenoid valves and Reliance motors were found to properly address upgrading of replacement equipment to the requirements of IEEE 323-1974.
The NRC inspectors also reviewed modifications made in the field for the upgrading of Limitorque motor operators and Reliance motors used in Fan Unit Coolers which were found to have been replaced with qualified upgraded replacement equipment.
No violations of NRC requirements were identified.
e.
Quality Assurance (QA) and Training Program Relevant to EQ Activities During this review the inspectors determined that the licensee had implemented a significant effort in monitoring the quality of EQ activities through surveillance and review of plant modification records and files.
The inspectors noted that the plant corporate QA personnel had conducted detailed EQ reviews during their QA audits in January 1985 and September 1986.
The inspectors found the methodology and results of these QA audits very acceptable.
The inspectors also reviewed the licensee's staff training program and associated training records relevant to the performance of EQ activities. Training records indicated that the licensee had implemented a well defined training program for key personnel responsible for EQ activities, including management and operations personnel.
The training program was found to address key aspects of 10 CFR 50.49 requirements.
No violations of NRC requirements were identified.
5.
Detailed Review of Qualification Files IE Bulletin No. 79-018 required licensees of all power reactor facilities with an operating license to provide written evidence of the environmental qualification of each piece of electrical equipment listed on their HEL( Master Equipment List).
10 CFR 50.49 Paragraph (f)
requires records of qualification of equipment on the MEL to be maintained in an auditable form for the entire period during which the equipment is installed in the plant or stored for future use, to permit verification of qualification and specified performance for accident conditions.
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The licensee qualified their EQ equipment to the requirements of the D0R Guidelines (10 CFR 50.49 Paragraph K).
The inspectors reviewed 25 equipment qualification files for evidence of the environmental qualification of equipment within the scope of 10 CFR 50.49 and evidence of equipment qualification to the 00R Guidelines.
Files were found to include a full description of the equipment; similarity analysis of tested equipment to that installed in the plant; allowed mounting methods and orientation; qualification of interfaces (conduit housing, seal etc.); evaluation of aging effects on equipment; performance / acceptance criteria for the qualification of equipment; description of test sequence and methodology; environmental conditions for the equipment during an accident; qualification for submergence of applicable equipment; resolution of test anomalies; and maintenance / surveillance criteria for the preservation of the qualified status of the equipment.
The inspectors selectively reviewed the above areas, as applicable, including special reviews for the required duration of operability of equip 4 nt; licensee evaluation of tested materials and configurations relat.e to actual plant installations; adequacy of test conditions; aging calculations for qualified life and replacement intervals; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy; and licensee evaluations of discrepancies identified in IE Information Notices and Bulletins.
EQ files were reviewed for Electrical Cables, Cable Splices, Terminations, Terminal Blocks, Motor Operated Valve Actuators, Electric Motors, Solenoid Valves, Electrical Penetrations, Seals, Lubricants, Heaters, Transmitters, Detectors, Sensors, Monitors, Control and Indication Switches, Load Centers, Distribution Cabinets, and Hydrogen Recombiners.
During this review in most cases the inspectors found the files well organized and very auditable.
In almost all cases the files allowed verification of equipment qualification to a specified performance for accident conditions.
Exceptions are noted below:
a.
Boston Insulated Wire /Bostrad 7 (BIW)
During review of the EQ file 0.6.2 the inspectors were concerned that the licensee was applying a test of Hypalon insulated cable conducted by Franklin Laboratories for another cable manufacturer, to generically qualify BOSTRAD 7 CSPE insulated cable for accident conditions at Prairie Island.
The Franklin test did not identify the specific Hypalon formulations used in the test.
The above EQ package also included BIW LOCA test reports for specific BOSTRAD 7 CSPE formulations, however, these test reports established a duration of only 24-hours and could not justify a required post DBE operating time of one year.
The licensee stated that the BIW test reports were meant to qualify the plant BIW cable for plant accident conditions and that the Franklin test was meant to only justify post DBE operability.
Since the 00R Guidelines identify CSPE to be Hypalon, and allows a shorter test duration if specific analysis is provided to damonstrate that the materials involved would not experience accelerated thermal aging, the
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Franklin test was considered an acceptable analysis for justifying the post DBE operating time of BOSTRAD 7 cable. The licensee subsequently revised their file to further clarify the application of the Franklin and BIW tests.
No further concerns were identified, b.
GeneralElectric_EB2_5_TerminalBlo_cks_jTBs).
During review of EQ file D.23.3 the inspectors observed that the licensee had in the past based their qualification of these tbs on a letter from another utility to the NRC, describing a test conducted by the utility. The licensee was informed that a report of this test should be inserted in the EQ package to facilitate auditibility. The licensee took immediate corrective action and acquired this report from the other utility and included it in their files.
The inspectors also questioned certain aspects of a thermal lag analysis referenced in calculations in the EQ package, and the post DBE operating times for the GE Terminal Blocks. The licensee provided additional clarifications to the inspectors to facilitate review of the post DBE operating calculations and the thermal lag analysis. The inspectors determined that sufficient information had existed prior to these clarifications to justify the qualification of these terminal blocks. No further concerns were identified.
c.
D. G. 0' Brien Containment Penetration During review of EQ file D.7 2B the inspectors observed that the EQ documentation for the D. G. O' Brien penetrations contained a list of recommended modifications that had been performed on the penetrations installed at the plant. The inspectors were concerned that these modifications would cause the configuration of the installed penetrations to be outside the qualified configuration of the tested specimens. The licensee reported that the modifications in question were only performed on the low voltage connectors not used in EQ applications in the plant, and that the EQ file was intended to qualify only the co-axial and tri-axial connectors. The inspectors had no concerns on the qualification of the co-axial and tri-axial connectors. The licensee took immediate corrective action and further clarified their files to facilitate auditibility. No further concerns were identified.
MINC0 Resistance Temperature Detector _('RTD),, T361~~~~
Model No. 58810 and d.
8ARQh DifferentiaT PFe{s[u~r~e7Siiis~o]r[hodel NO e
The inspectors reviewed EQ Package No. N1ACO 8.11, file 0.26.1 for the MINC0 RTD and the Barton DPS, which are both part of the Reactor Vessel Level Indication System (RVLIS). Additional qualification was provided in the Westinghouse Test Report WCAP-8687, Revision 1.
dated January 1985. During review of these EQ documents the inspectors observed that the SCEW sheet required the post accident operability of both the MINC0 and the Barton Sensor to be four
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months, while the qualified duration on the SCEW sheet was one After applying the Arrhenius method the inspectors determined year.
that the qualified duration was only four months plus a margin.
The licensee took corrective action and revised their SCEW sheet to reflect the correct post accident operability.
Since these components were qualified for their installation prior to the revision of the SCEW sheet, no further concerns were identified.
The inspectors also observed that the post accident condition at Prairie Island requires the MINC0 RTD to be environmentally qualified for submergence.
The only documentation in the files satisfying this requirement was a letter from Westinghouse stating that the RTD would operate submerged.
The licensee provided evidence that the RTD sensor was qualified for submergence because of the construction of the platinum wire wound element which was insulated with MG0 mineral insulation and installed in a solid stainless steel 347 sheath.
The RTD sheath is then inserted into a plated copper saddle block which is strapped on a process or impulse line.
In manufacture the saddle block is added after the sealed RTD assembly is complete and does not contribute to the environmental protection.
Also during testing the RTD was subjected to a chamber pressure of 80 psig.
Based on review of details of construction of
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the sensor and verification that the electrical terminations at the I
other end would not be submerged, the inspectors determined that this equipment was qualified.
The licensee has added more details of the RTD construction and further clarification of qualification for submergence in the RTD EQ file.
No further concerns were identified.
e.
Lubricants - Chevron SRI-2 Limitorque EQ Calculation File No. 0910-200-LIM-01 stated that the lubricants used in Limitorque MOVs at the site were EXXON Nebula EP0 and EP1, Sun Oil 50 EP, Humble Oil Beacon 325, and Mobil Oil 28.
In the discussion of IN 79-03 Limitorque limit switch gear box lubricant problems in the EQ file, however, the licensee stated that the lubricants used were Mobil 28 in the limit switch and Chevron SRI-2 in the main gear case.
Further review of maintenance documentation by the inspectors confirmed the use of Chevron SRI-2 as stated.
The licensee reported that they had separately qualified the SRI-2 in their Qualification Summary D.11.1 and during the inspection produced documentation to demonstrate its suitability for the Limitorque main gear case application.
The licensee took i
immediate corrective action to correct this file discrepancy and no
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further concerns were identified.
6.
Plant Physical Inspection The NRC inspectors selected over 140 items on the MEL for examination in the plant.
The EQ file of each item had been reviewed, and information regarding the location, manufacturers, model/ serial number, mounting, orientation, environment, and interfaces had been noted.
The inspectors
examined the selected items in the field, as accessible, and verified that the method of installation of each item was not in conflict with environmental qualification.
of installed items to EQ files, ambient environmental conditions, S qualification of interfaces, (connectors, wires, seals, insulation, drainage, mounting methods, physical conditions and almost all cases items examined in the field were found to meet thei In i
appropriate EQ requirements.
Exceptions are noted below.
a.
Raychem Splices s
(1)
The licensee performed an evaluation to address the qualification issues addressed in IE Information Notice No. 86-53, " Improper Installation of Heat Shrinkable Tubing," dated June 26, 1986.
This evaluation included a plant physical inspection of 320 applicable EQ splices in Unit 2 and identified five generic deficiencies regarding improper, installation of Raychem splices in both units.
Safety Evaluation SE No. 181 and SE No. 183These deficiencies, included exceeding the "use range" of two times the fully recov,ered inside diameter of the Raychem tubing; less than required seal lengths of 2 inches over splices; exceeding bending radius of five times the outside diameter of a splice; installation of Raychem tubing over a woven substrate, and one instance of the misapplication of a shim.
The licensee is taking corrective action by performing splice replacements using Raychem installation recommendations on all above deficiencies with the exception of seal lengths and "use range" requirements.
The licensee stated in SE 183 that the seal lengths at the site are a minimum of 1.5 inches rather than the 2 inches minimum recommended by Raychem, and that the use range is a maximum of three times the fully recovered inside diameter rather than the two times factor recommended by Raychem.
The licensec considered these installations qualified in their current configurations, based on industry testing of Raychem splices outside the manufacturer's recommendations.
The inspectors reviewed relevant test reports and evaluations of Raychem testing presented by the licensee for aging, radiation, maximum temperature, duration, and tested configurations to determine if the testing simulated service conditions at Prairie Island.
Based on thic review, the inspectors determined that there was sufficient evidence to justify continued operation with the installed seal lengths and use range configurations in Unit 2.
The licensee also performed a safety evaluation, SE No. 181 for the EQ Raychem splices in the operating Unit 1.
The licensee determined in this evaluation that based on their Unit 2 walkdown, Raychem splices in NAMCO limit switches, penetration cabinets, ASCO solenoid valves, RTD's, and transmitters would
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have deficiencies.
These deficiencies were based on the consistency of installation methods and personnel used for both units.
The licensee stated that postulated failures of splices due to moisture intrusion would only occur in the ASCO Solenoid valves and instrumentation circuits. ASCO valves were determined to fail to an accident safe position on loss of power, with the exception of ASCO Valves on the MSIV's and PORV's where safety valves and check valves are available to mitigate accident conditions.
Independent indications are also available for valve positions.
Installation concerns associated with instrumentation circuits included use ranges and seal lengths.
These concerns were determined to have been evaluated and justified by industry testing as noted earlier in this section.
In addition to the above, the licensee stated that there was adequate redundancy of instrumentation available to avoid compromising any post accident safety actions related to these circuits.
An ongoing review is being performed by the NRC relative to the operability of the equipment associated with these splices.
During this review, the inspector determined that adequate Raychem instructions were available for proper installation of these splices; apparently these instructions were not followed.
The licensee was informed that in accordance with the Guidance in Generic Letter 85-15, enforcement action may be taken, in that the licensee should have known these splices were unqualified prior to the November 30,1985,EQ deadline.
Pending further review this is a Potentially Enforceable Unresolved Item (50-282/86012-01(DRS);
50-306/86014-01(DRS)).
(2) During this review, the inspectors examined over (100) repaired Raychem splices in Unit 2 penetration cabinets, solenoid valves and transmitters; no discrepancies were found.
The licensee is currently in the process of performing inspections on most Raychem splices in the operating Unit 1, where accessible.
The licensee stated that this review will
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provide an adequate assessment of any discrepancies in the installation of Raychem splices in Unit 1.
A detailed plant
walkdown for Raychem splices will also be performed by the l
licensee during the upcoming Unit 1 outage in April 1987.
l Pending NRC review of the results of this walkdown and the licensee's corrective action, this is an Open Item (50-282/86012-03(DRS); 50-306/86014-03(DRS)).
l b.
Limitorque Valve Motor Operator MV 32410 The inspectors examined Limitorque Operator MV 32410 in the plant l
for qualified components and reviewed concerns identified in IE j
Notice 86-03.
During examination of Limitorque Operator MV 32410 l
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in the Unit 2 containment the inspectors noted that the plastic gear case relief cap (dust cap) had not been removed from the actuator.
The licensee was informed that this installation was in conflict with the tested configuration in the EQ files and that further-inspections were required to identify any other such installations.
The-licensee immediately initiated a walkdown of both units and identified 11 more Limitorque Operators with installed plastic gear case relief caps. All caps were subsequently reviewed during the walkdown and no additional. qualification concerns were identified.
The NRC inspectors determined that the 11'Limitorque Operators identified during the walkdown had been unqualified in their installed configurations due to the presence of the dust cap.
An ongoing review is being performed by the NRC regarding the operability of the Limitorque Operators, relative to a new technical analysis performed and submitted by the licensee subsequent to this finding.
The licensee was informed that in accordance with the
guidance in Generic Letter 85-15, enforcement action may be taken, in that the licensee should have known.these splices were unqualified prior to the November 30, 1985, EQ deadline.
Pending further review, this is a Potentially Enforceable / Unresolved Item (50-282/86012-02(DRS); 50-306/86014-02(DRS)).
c.
ASCO Solenoid Valve 208-448 During the Unit 2 walkdown, the inspectors noted that the ASCO Solenoid Valve Model No. K206-380 was not installed in the plant as noted on the EQ Master List.
The plant installed Model was 208-448, which was confirmed by the inspectors to be the correct model and to be qualified for the installation.
The licensee took immediate corrective action to reflect the correct ASCO Model 208-448 in their Master List.
No concerns were identified.
d.
Endevco Accelerometer 2273 AM20/Unholtz Dickey Amplifier RCA-2TR (2XQ-443) (2XE-443)
These two components are discussed together because they both are part of the Pressurizer Valve position monitoring system.
During the Unit 2 plant walkdown, the inspectors noted that the Unholtz
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Dickey Model 22CA-2TR was not installed in the plant as.noted in
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the EQ Master List.
The plant installed Model was RCA-2TR which was verified by the inspectors to be the correct model and qualified for
the installation.
The licensee took immediate corrective action to reflect the correct model number RCA-2TR for the Unholtz Dickey j
Amplifier in their Master List. No_ concerns were identified.
e.
Rosemont Transmitter 1154HP5RC (2FT-467)
i This transmitter was reviewed in Unit 2 for traceability to
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qualification documentation.
The inspectors observed that this i
transmitter had been replaced with a Foxboro Model E13DH transmitter during the current outage, but that this Foxboro transmitter had not
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yet been included in the EQ Master List. Qualification _ documentation for the Foxboro transmitter was available but had not yet been incorporated:into the system.as.the licensee was in the process of completing their' review cycle. -Since Unit 2 was currently in an outage and work was still in progress no concerns were identified.
f.
Cables During the Unit 2 walkdown, the NRC inspectors selected two sets of field cable associated with EQ equipment in the plant for traceability to qualification documentation.
The field markings on these cables identified them to be Rockbestos Firewall III and Rockbestos Firewall EP. -These cables were traced from the field to the plant Cable Identification and Routing List (CI & RL)
NC-40499, which erroneously identified the appropriate cables to be.0konite Okoprene and Boston Insulated Wire Cable respectively.
Apparently modifications made in the field had not yet been reflected in the CI & RL microfiche files.
The inspectors determined that the plant drawings, cable pulling records and cable purchase orders correctly identified the cable number and routing, and that the field cables were qualified for their installation.
The. licensee took immediate corrective action and placed a cautionary sign on the CI & RL microfiche reader to warn' users not to use that information for design and construction.
No EQ activities'were determined to be affected, and the licensee corrective action was considered adequate.
7.
Open Items
.0 pen' Items are matters which have been discussed with the' licensee, which will be reviewed further by the inspector, and.which involve some action on the part of the NRC or licensee or both.
An Open Item disclosed during this inspection is discussed in Paragraph 6.a.(2).
8.
Potentially Enforceable / Unresolved Item An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation.
Potentially Enforceable / Unresolved Items are unresolved items, which.if ascertained to be a violation will be followed up with enforcement action in accordance with NRC enforcement guidance on environmental qualification.
Potentially Enforceable Unresolved Items l
are discussed in Paragraphs 6.a.(1) and 6.b.
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9.
Exit Interview i
The Region III inspectors met with the licensee representatives (denoted under Paragraph 1) during an interim exit on November 21, 1986, and i
i discussed findings by phone at the conclusion of the inspection on December 2, 1986.
The inspectors summarized the purpose and findings of the inspection and the licensee acknowledged this information.
The
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licensee did not identify any documents / processes reviewed during the
inspection as proprietary.
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