IR 05000298/1988026
| ML20205C479 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/18/1988 |
| From: | Andrea Johnson, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205C453 | List: |
| References | |
| 50-298-88-26, NUDOCS 8810260510 | |
| Download: ML20205C479 (7) | |
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APPENDIX 8 U.S. NUCLEAR REGULATORY COMISSION
REGION IV
NRC Inspection Report:
50-298/88-26 Operating License:
DPR-46 Docket: 50468 Licensee: NebraskaPublicPowerDistrict(NPFD)
P.O. Box 499 Columbus, NE 58601 Facility: CooperNuclearStation(CNS)
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t Inspection At:
Region IV Office
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Inspection Conducted:
June 6 through July 22, August 14-26, and i
September 19-21, 1988
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!bb Inspector:
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A. R Uohnson Reactor Inspector, Plant D4te i
Sy ems Se ion. Division of Reactor Safety
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f!ff Approved:
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T. T. Stetka, Chief Plant Systems Section DatW /
Division of Reactor Safety Inspection Sumary Ins action Conducted June 6 through July 22. August 14-26, and September 19-21,
1981 (Report 50-298/88-26)
a Areas Inspected: Licensee actions on previously identified items regarding equipment qualification (EQ) as documented in NRC Inspection Report 50-298/86-28 dated April 1, 1987. These actions were outlined in a response letter from NPPD to NRC Region IV, July 13, 1988, as a result of an
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NRC/NPPD enforcement conference held on June 20, 1988, at the NRC Region IV l
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office.
Results: One violation was identified regarding Okonite T95/3S splicing tapes
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i used to splice motor lead power connections from Limitorque SMB series motor l
operators (paragraph 2).
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j 8810260510 681019
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PDR ADOCK 05000298
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DETAILS 1.
Persons Contacted NPPD G. A. Trevors, Division Manager, Nuclear Support i
H. G. Parris, Vice President, Production S. J. Jobe. Simulator Supervisor /EQ Coordinator J. M. Meacham, Senior knager, Technical Support K. C. Walden, Licensing Manager R. E. Wilbur, Division Manager, Nuclear Engineer and Construction NRC
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J. M. Montgomery), Special Assistant to Regional Administrator,
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Region IV (RIV
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J. L. Milhoan, Director, Division of Reactor Safety. RIY L. J. Callan, Director, Division of Reactor Projects, RIY
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A. B. Beach Deputy Director, Division of Reactor Projects, RIV i
G. F. Sanborn, Enforcement Officer, RIV G. L. Constable. Chief, Reactor Projects Section C RIV W. R. Bennett, Senior Resident Inspector, RIV
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R. E. Ireland Technical Assistant Plant Systems Section, p!Y A. R. Johnson, Reactor Inspector, Division of P.cactor Safety, RIV U. Potapovs. Chief, SPIS/DRIS/NRR, Headquarters I
H. Walker, Engineer, DEST /NRR, Headquarters W. Long, NRR Project Manager, NRR/PD-IV J. G. Luehman, Senior Enforcement Specialist, Office of Enforcement
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Note: All individuals listed above attended the enforcement conference held in the Region IV office on June 20, 1988.
2.
Licensee Actions on Previously Identified Items 2.1 (Cicsed)UnresolvedItem(298/8626-09): OkoniteT95(insulation)/35
(jacket)tapesplicesandScotch130(innerinsulation)/70(onter insulation)/17 (jacket) tape splices, were used to splice motor lead i
power connections from Linittorque Model SMB-000, SMB-3, end SMB-4 motor operators to Class 1E field cables with fiberglass braided jackets outside of the drywell. Systems affected are (1) primary containment; (2) high pressure coolant injection; (3) reactor
equipment cooling; and (4) main steam.
EQ Data Package (EQDP) 31A was the applicable data package for the identified equioment. A
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review of EQDP 31A and the associated packages. EQDP 40 and 224, by the NRC indicated that there was no evidence that could demonstrate
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qualification of Okonite tape splices or Scotch taae splices for installation on cables with fiberglass braided jactets.
It was noted
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3-that IQDP No. 224 only documents the Okonite motor lead splice type testing over unjacketed insulated cable.
During the enforcement con'erence at the Region !Y office on June 20, 1988, NFPD indicated that 30 out of a total of 88 EQ motor operators had tape wrapped Okonite or Scotch splices at the time of the NRC inspection. Eight motor operators, located inside the dryweli, used the Okonite 195/35 t3pe splice applications, but these splices were not on c ble with a fiberglass braided jacket.
NPPD considered the Scotch 130/70/17 splice configutations to the fiberglass braided motor lead connections as having been maintained in a qualified status. This position was based upon a calcolation,
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NPPD/CNS Functional Assurance Program Calculation No. 40. This calculation references Franklin Research Center (FRC) Test Report No. F-C5022-2, dated November 1978, which included a December 1984 analysis in which a Scotch 130/70/17 tape splice was applied over a Rockbestos (Cerro) SF-2 fiberglass braided cable and tested during a simulated LOCA environment.
NPPD's response letter to NRC of July 13, 1988, provided the supporting documentation.
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NPPD also indicated the reluctance of Minnesota Mining &
Manufacturing Company (3M), producers of Scotch 130/70/17 splice tapec, to maintain material traceability over this product, and that 3M planned to withdr.iw these items as nuclear grade materials.
As a result of the 3M plans, NPPD's response letter of June 17, 1987, indicated that Scotch 130/70/17 tape cable splices had been removed and replaced with the Okonite T95/35 tape splices. NPPD indicated during the enforcement conference that Maintenance Work Requests (MWRs) have been used to replace Scotch 130/70/17 splices with Okonite T95/35 using CNS Procedu;'e 7.3.26.2, which was first approved for use on October 13, 1986. This approved procedure p-ovides instruction for the use of the Okonite T95/35 splices to cable jacket construction composed of either Nomex paper 1 dyers compressed with varnished fiberglass braid or composed of fiberglass
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braid over the silicone insulation. NPPD indicated all necessary replacementshavebeenaccomplishedandEQDPNo.40forScotchtape sp. ices had been removed from the EQF.
NPPD considered the documentation contained in E0DP No. 224 l
sufficient to establish qualification of the Okonite T95/35 tape
splice applications.
However, because the type test documents contained in EQDP 224 only established qualification using the
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Okonite splice tape over unjackete volated field cable, NPPD subsequently conducted type testing ukenite splice tape applications over field cable with a +1berglass braided jacket. The Ltd. (g was conducted for NPPD by Consulting and Development Company, tes tin CCL) and sponsored by Patel Engineers in late 1986 and early 1987. The test demonstrcted that the Okonite splice electrical integrity was not maintained throughout the 100-hour accident test in
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that' indications of excee6ing the acceptance ~ criteria of i
300 milliamps leakage current occurred 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> into the test. At
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53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br /> the leakage current measured 671 millamps and caused a power interruption to the test circuit thus aborting the test.
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insulaticn resistance (IR) measurements during the accident test remained above 5 megoh.ns until the power loss anomaly or. curred.
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test results addressed this anomaly as a random failure due to i
unknown causes. The type testing performed at CCL demonstrates
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acceptance for applications of Okonite splicing tape to cable with a
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braided fiberglass jacket on motor operator power leads fnr t
l postaccident operability times of less than 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br />. NPPD indicates
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that the worst-cast accident temperature / pressure profile outside the l
drywell is enveloped by the CCL type testing up to the 46-hour
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l failure. Consequently, the test results provide adequate
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qualification results. However. CNS had acen operating with j
undocumented Okonite splices in outside drywell applications until i
testing was complete in January 1987.
j As explained above, this situation occurred subsequent to the
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November 30, 1985 EQ deadline.
For record purposes, unresolved item I
(298/8626-09) is considered to be closed and this item is now l
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considered to be a violation.
Violation (298/8826-01):
Failure to comply with the requirements of 10 CFR 50.49 with respect to type testing of components.
j 2.2 (Closed) Unresolved Item (298/8628-02): The requirements of i
paragraph (j) of 10 CFR E0.49 require that i record of qualification i
must be maintained.
EQDP No. 6A in the equipment qualification
file (EQF). for BIW coaxial cable. type RG 59 B/U. did not establish
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l qualificatinn in that only a single page description of a type test.
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perfomed by BIW, was available in the file. This description could not permit verification that this item was qualified for its application.
f The description referenced BIW Test Report No. 76J049 which was
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unobtainable due to an apparent fire which consumed the test records.
i No test data or supplemental records were available to support
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qualification up to the end of its qualified life.
N?PD's response
letter to the NRC RIV of June 17. 1987, indicated that detailed backup documentation of this type was difficult to locate and obtain, since this testing was perfomed during the 1970's.
The NPPD response
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letter also indicated that BIW had been contacted and would attempt-l to provide backup data to the type test perfomed at BIW, I
i This cable ir used for the hign range radiation monitor outside containment and was installed as a TMI upgrade requirement which requires qualification to NUREG-0588. Category I and must withstand an accident environment outside the drywell. The dialectic material used in the cable construction is Tefzel which is known to qualify at high temperatures and at radiation thresholds of 200 Mrads, indicating this component is qualifiable.
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5-During the tnforcement conference of NPPD and NRC on June 20, 1988, l
NPPD indicated that the BIW coaxial cable, RG 59B/U item has been included in the NPPD Regulatory Guide (RG) 1.97 program for
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post-accident monitoring equipment.
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scheduled for completion by spring 1989 at which time this item will be fully qualified.
i 2.3 (Closed) Unresolved Item (298/8628-05): The requirements of paragre,-5s (f) and (k) of 10 CFR 50.49 and Section 5.2.2 of the 00R Guidelines requires demonstration of similarity between the tested and installed components. The NRC inspectors examined EQF, EQDP8 for
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GE electrical power and control penetrations. Type 236X600NSGI to i
assure necessary documentation was available. During the 1986 NRC inspection, verification of the qualification of these components i
could not be demonstrated in that an auditable link between tyre test
results and the analysis for the installed equipment was not i
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During the enforcement conference of June 20, 1988, NPPD again stated their position in that reference test data was available for the GE canister type penetrations, which confirm that similarity is i
established, and was available in the EQF to be verified by the NRC.
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CNS installed qualified sleeves and penetration kits to the drywell minor design change (MDC) ype electrical penetrations under NPPD's side of all essential GE t 83-065, completed in October 1983. The GE
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electrical penetration assemblies involved Nos. X100A, X100E, X100G, X100H, X102, X105A, and X1050.
The station modification replaced the existing Scotch tape s>11ces on Thomas & Betts (T&B) crimped type mechanical connectors )ecause the tape splice insulatien material had
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not been qualified for the high temperature, aging, and relative
.I humidity requirements.
The Scotch tape splice insulation material
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was replaced using upgraded Paychem WCSF-N heat shrinkable sleeves
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and end sealing kits.
The qualification for these sleeves is fully
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established by Raychem Test Report Nos. 58442-1 and 58442-2 that was i
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perfonred by Wyle Laboratories.
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The installation of the Raychem heat shrinkable sleeves brought CNS
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into compliance with the requirements of 10 CFR 50.49.
2.4 (Closed) Unresolved Item (298/8628-08): Pctential Deficiencies in
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Oualification of Limitoruge Motor Operator Internal Wiring and T&B Nylon Crimp Connector Splices, i
2.4.1 Potential Deficiencies in Qualification of Limitorqae Motor Operator internal kiring:
Following the issuance of NRC Infomation j
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Notice (IN) 86-03, NPPD issued a special test procedure to inspect i
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l Limitorque motor operators to verify the qualification of unidentified J
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internal wiring.
During a CNS walkdown inspection effort, unidentified i
internal wiring was detected in 25 motor operat< a located outside
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reactor core isolation cooling (RCIC), and reactor water cleanup (RWCU)
systems.
NPPD innediately replaced the unidentified wire with qualified Rockbestos Firewall SIS wire, and submitted an equipment operational analysis (E0A) for each Limitorque MOV, to NRC RIV in a letter dated August 8, 1986.
In all cases the required replacement of unqualified wiring has been undertaken, and the appropriate
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justifications for continued operation (JCOs) were initiated in response to NRC Generic Letter 86-15.
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The NRC, based on first round EQ program implementation inspection having been completed to date, has concluded that all licensees, through implementation of their EQ programs, should have identified the wiring qualification problems before the November 30, 1985, deadline. However, the NRC staff concluded that no violations were necassari since the safety significance of the wiring qualification issue was limited as evidenced by the fact that where these problems were identified, licensecs' were able to justify continued interim operation with the unqualified wiring until corrective action was accomplished. This item is considered to be closed.
2.4.2 T&B Nylon Crimp Cc,ntector Splices RB-4 and RC-6: At the time of the 1986 NRC inspe: tion, the NRC reviewed the timeliness of NPPD actions to correct deficient conditions in Limitorque motor operators in accordance with the guidance given in IN 86-03.
NPPD issued special test procedures, conducted a walkdown, replaced internal wiring, and submitted an E0A to the NRC RIV for each limitorque motor operator in EQ applications at CNS. This E0A was in accordance with the appropriate JC0 required by NRC Generic Letter 86-15.
The NRC reviewed EQDP 31A, for Limitorque motor operators, Series SMB, (qualification series B0003 by Limitorque) in the EQt.
The inspection team observed that inadequate documentation was contained in the EQF to establish qualification for TAB RB-4 and RC-6 nylon crimp connector splices. The use of these connector splices ere wide spread in the construction of dual voltage motor operators by the manufacturer.
The nuclear industry, including utility owner groups, have reported
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that the manufacturer has subjrcted the dual voltage motor design to environmental qualifit.ation testing on four separate occasions.
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Limitorque h.?s tested dual voltage motors with Reliance Class H.
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Type RH insulation (lest Report No. 600376A), and with Reliance
Class B insulation (Test Report Nos. B0003 and F-C3271). Limitorque
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has also tested dual voltage motors with Class H, Type Rad H
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insulation (Test Report No. 600198). A quality assurance audit of Limitorque's facility, which was conducted by another utility, included within its scope, a review of purchase order records for these crim.p connector type splices used by Limitorque. The purchase L
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records at Limitorque indicated a purchase of 112.000 T&B RC-6 splices between April 1967 and May.1979; 240.000 T&B RB-4 spli:es
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between January 1971 through June 1973; and 30.000 T&B RB-44 splictes between June 1984 and 1987.
Documentation to substantiate that the RB-4 and-RC-6 series connector splices were used in the above testing is not evailable.
Recently, another utility has,ponsored a qualification test for the T&B RB-4 and RC-6 nylon crisp connector splices used in dual voltage Lit 1 torque operators at Wyle Laboratories. An 8-year screen qualification test was completed successfully in late October 1987.
A 40-year qualification test has been conducted and completed in early 1988. As a result of this testing, these nylon crimp connectors failed part way into the accident test which indicates restrictive use of the T&B RB-4 and RC-6 connector splices. At this time, the type test results are preliminary and supporting analysis to show similarity between the equips.ent tested and the environment installed at CNS has not been fully estallished.
It is the staff's position that the licensee clearly should not have known that the T&B crimped type splices were not qualified because a detailed review of the Limitorque testing reports was not required.
Based upon this position, this potential enforcement / unresolved item has been reclassified as an open item.
This item remains open pending completion and NRC review of the final test results.
For record purposes, this unresolved item is considered to be closed, and this item is considered to be an open item.
Open Item (298/8826-02); Review final EQ test results for qualifying T&B RB-4 and RC-6 nylon crimp connector splices used in dual voltage limitorque motor operators.
29!1/8628-28): All 19 o 2.5 (Closed) Open Items (298/8628-10 through items ider.tified ir. NRC Inspection Report 50-298/86-28(Table!! pen J
have been closed out based on the licensee's response letter to NRC Region IV dated July 13,1988(298/8628-10 through 298/8628-28).
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