IR 05000313/1988029

Ack Receipt of 881228 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-313/88-29 & 50-368/88-29.Violation a Reviewed & Determined to Have Occurred as Stated

ML20235Y689
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/03/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8903140502
Download: ML20235Y689 (2)

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iIn: Reply Refer To:

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2 .- Dockets: 50-313/88-29

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' "g Arkansas Power & Light Company ATTN: Mr. Gene Campbell Vice President', Nuclear

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'Little Rock, Arkansas 72203 Gentlemen:

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Thank you for your letters of December 28, 1988, and January 27, 1989, in

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. response to our letter and Notice of Violation (NOV) dated November 28, 1988.

-We have reviewed your reply and find it responsive to the concerns'reised in

.Our NOV for Violations B, C,.and D.

1With regard to Violation A, we have noted your denial and have reviewed your.

basis for the denial.~ We have conducted additional reviews of this issue and discussed the findings with the NRC inspectors involved in the original inspection. As=a result of these reviews and discussions, it is our opinion that the violation occurred as cited. We have also reviewed your corrective actions 1for this violation and have determined that these actions are responsive to'our concerns. Therefore, no further response to this

' violation.is'necessary.

We will review the implementation of your. corrective actions during & future inspection to determine,that full compliance has been achieved and will be maintained.

Sincerely, Original Shued By A. B. Ecach L. Director Division of Reactor Projects CC:

Arkansas Nuclear One ATTN: J. M. Levine, Executive l Director, Nuclear Operations P.O. Box 608 Russellville, Arkansas 72801 Arkansas Radiation Control Program Director RIV:RI* C:PSS* D:DRS* D: !

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RRI :R..D. Martin, RA RPB-DRSS- ;SectionChief(DRP/A)

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C. Poslusny, NRR. Project Manager (MS: 13-D-18)

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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 [501) 377-4000 December 28, 1988

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DCAN128811 ,

U. S. Nuclear Regulatory Commission

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Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 ATTN: Mr. Robert D. Martin Regional Administrator SUBJECT: Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Notice of Viol & tion Contair,ed in Inspection Report 313/368/88-29 -

Equipment Qualification Gentlemen:

Your correspondence of November 28,1988(0CNA118822) which transmitted a Notice of Violation regarding activities associated with the Environmental Qualification (EO) Program of Arkansas Nuclear One (ANO), requested a response by December 28, 1988.

Due to the extent of engineering resources necessary to complete the required responses, the Arkansas Power & Light Company (AP&L) requests that the response submittal date be extended to January 20, 1989. This additional time will allow us to complete the assimilation of necessary information for the responses to the violation notice. This request was discussed with Dwight Chamberlain on December 27, 1988.

Very truly yours,

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Dan R. Howard Manager, Licensing DRH:MT:de

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I ARKANSAS POWER & LIGHT COMPANY January 27, 1989

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IdCANB18906 U. S. Nuclear Regulatory Commission Revion IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 ATTN: Mr. L. J. Callan, Director Reactor Projects Division SUBJECT: Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Reports 50-313/E8-29 and 50-368/88-29

Dear Mr. Callan:

Pursuant to the provisions of 10CFR2.201, a response to the violations identified in the subject inspection report is submitted.

Very truly yours,

kUk y J/M.levine fxecutiveDirector, Nuclear Operations JML:MWT: de Attachment cc: U. S. Nuclear. Regulatory Commission Document Control Desk Mail Station P1-137 Washington, DC 20555

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RESPONSE TO NOTICE OF VIOLATION A. VIOLATION REGARDING INSTRUMENT ACCURACY: ..

(Violation No. 313/8829-01; 368/8829-01)

The staff alleges that the EQF and other file information provided to the NRC during the EQ inspection failed to adequately address the effects of low cable insulation resistance (IR) and ancillary equipment accuracy value in-instrument accuracy calculation no. 86-EQ-00101.

AP&L's Position Regarding The Violation:

AP&L denies the violation. As the basis for its denial, AP&L maintains that prior to November 30, 1985, it should not have " clearly known" that failure to include error contributions from cables and ancillary equipment in comparison of tested vs. requirtid instrument accuracy constitutes a violation of 10CFR50.49 and the DDR guidelines.

Accordingly, pursuant to Generic Letter 88-07 as discussed in our submittal of August 19, 1988 (0CAN088807),-this finding should not be cited by the staff as a violation subject to enforcement action.

In addition to our August 19, 1988 submittal, AP&L relies on the attached Nuclear Utility Group'on Environmental Qualification (NUGEQ)

position paper and supporting affidavit on instrument accuracy which was recently submitted to NRC (letter to Mr. James M. Taylor from Messrs. Reynolds, Phillips and Ms. Gelman of October 3, 1988) as support for our position.

AP&L agrees that if a violation existed, the issue is properly characterized by the notice of violation with regard to safety significance as a severity level IV, An inaccuracy does exist in the wording of pcragraph 2.2 of the Notice of Violation, however, which needs clarification. AP&L did prepare calculations prior to the inspection which compared demonstrated instrument accuracy to safety analysis requirements for each Isop as discussed in the D0R guideli,,es.

These calculations were included in the EQ files prior to the inspection of 1986 and were reviewed by the EQ inspection team members at that time. Also, the AP&L calculation referred to in the Notice of Violation was calculation 86-EQ-0001-02 not 86-EQ-00101. Calculation 86-EQ-0001-02 was used to determine insulation resistance effects on typical safety-related instrument loops in use at Arkansas Nuclear One.

Calculation 86-EQ-00101 addresses a subject unrelated to loop accuracy.

Corrective Action:

l Notwithstanding our denial of the existence of a violation, AP&L agrees that loop accuracy has evolved into a valid technical concern today.

We believe that our efforts to date fully address the staff's concern j in this area and constitute a significant upgrade in the documentation l

of our EQ Program. As stated in the Notice of Violation, AP&L has

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g completedfullLintegrationoftheeffectsofinsulationresistanceon-instrument accuracy in all EQ error calculations. It.should be noted-that such actions did not result in any modification of equipment.

This supports our original conclusions (presented in the inspection in 1986) that,' even. including all. quantifiable effects of IR-from cable and ancillary. components, the qualification and safety function of

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these loops were assured. The reviews have been included in the AP&L

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EQ' files.

Actions To Prevent Recurrence:

AP&L believes that the actions described above and in our submittal of.

August 19, 1988 fully satisfy the staff's concern on this issue.

Therefore no further action is planned.

i Date of Full Compliance:

' Full compliance with our understanding of the staff's position on instrument accuracy was achieved in August, 1988.

B. VIOLATION REGARDING MOTOR OPERATOR SPLICES:

(Violation No. 313/8829-02; 368/8829-02)

The staff alleges that during the period September 29 through October 17, 1986, EQ files did not contain qualification documentation for Okonite T95/35 tape cable splices to Series SMB Limitorque motor operator motor leads with fiberglass braided jackets. The Okonite splices were not qualified by test and/or analysis in accordance with the D0R guidelines in that similarity between the splice type tested and those installed in motor operators was not established.

.AP&L', Position Regarding The Violation:

AP&L admits that the EQ files did not contain a documented similarity analysis specifically addressing the qualification basis for the previously approved use of Okonite T95/35 taped splices in place of nylon crimp connectors for splicing Limitorque motor leads. As discussed in our submittal of August 19, 1988 to Region IV regarding potential EQ enforcement action (0CAN088807), it is our contention that under the requirements of the D0R guidelines only a functional analysis was required. Such analysis was inadvertently not included in the EQ files prior to the inspection due to the belief at the time that 1) the separate qualification data available in the EQ files demonstrated that Okonite tape was fully qualified for inside containment use, and 2)

Limitorque motor lead connection was a straightforward application of this product which was clearly superior to nylon insulated crimp splices.

Corrective Action:

As acknowledged in the notice of violation, the EQ files now contain a specific similarity analysis and qualification review of all methods currently being used for splicing Limitorque motor leads in EQ applications. These reviews, document the qualification basis for use

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of Okonite tape and Raychem WCSF-N heat shrink material in these applications.

Action To Prevent Recurrence:

Other EQ applications of Okonite tape at Arkansas Nuclear One have been reviewed and have been found to be fully qualified based on information presently in the EQ files. AP&L Electrical Design Engineers are now fully aware of the need to review and document in the EQ files the application of interface products such as Okonite tape in new and unique applications. No further actions related to this violation are planned.

Date of Full Compliance:,

Partial compliance was achieved in August, 1988 when Okonite application reviews were completed. Full compliance was achieved in November, 1988 when the results of these reviews were incorporated into the EQ files.

C. VIOLATION REGARDING LIMITOROUE SPACE HEATERS:

(Violation No. 313/8829-03; 368/8829-03)

The staff alleges that during the period September 29 through October 17, 1986, AP&L's EQ files for Limitorque motor operators, Series SMB, did not adequately support qualification because of a failure to analyze all possible effects of energized space heaters used within the motor operator assembly.

AP&L's Position Regarding The Violation:

AP&L admits the violation. The use of energized space heaters was adopted during original plant construction and was considered to be a good maintenance practice for preventing condensation of moisture on internal parts and therefore minimizing corrosion. At that time, it was AP&L's judgement that the potential effects of air temperature rise due to the space heaters was enveloped by the conservatism of the Limitorque aging analysis. Furthermore, it was felt that the possibility of internal condensation was potentially more deleterious to the reliability of life of insulation and internal parts than the thermal aging effects of the space heaters. Subsequently, detailed analysis and testing did substantiate our assumption of minimal impact

on qualified life due to the presence of the heaters. In addition, AP&L remains confident that any premature aging or deterioration would have been discovered through AP&L's qualification preservation program.

Because of the acknowledged imprecise nature of aging calculations (i.e., Arrhenius methods), this calculation was not vigorously pursued in favor of more results oriented maintenance and surveillance activities. Nevertheless, AP&L did not adequately document its position regarding energized limit switch heaters for inclusion in EQ files.

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In retrospect, AP&L agrees that'it should have more explicitly addressed heater aging effects by performing new Arrhenius calculations. However, for the reasons stated above, we consider this to be an isolated oversight.

Corrective Action:

As mentioned above and in our August,1988 submittal, AP&L-has-performed extensive analysis plus. testing that' confirmed that aging would not be adversely affected. In addition, AP&L has reevaluated its concern regarding the potentihl for moisture condensation inside the Limitorque motor operator limit switch compartments. A review of the-

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applications and expected environments for the motor operators indicated a very small likelihood for moisture condensation inside the compartments, even in the absence of space heaters, In addition, the

MOVs are not installed in " cold" water piping systems which might attribute to a likelihood for such condensation. For this reason (i.e., corrosion would not normally be a_ concern), AP&L has accepted the position that operation of the motor operators without energized space heaters,.in the interest of eliminating any potential thermal aging effects or possibility of inadvertent heater contact by internal wiring, would be a more conservative policy. Accordingly, the space heaters for all EQ Limitorque motor operators have-been deenergized for both units. As implied above, the analysis performed has ensured that adequate qualified life of the Limitorque operators, as documented in the EQ files, has been maintained.

Actions To Prevent Recurrence:

AP&L design personnel have been counseled to fully document the bases for AP&L positions with calculations and/or analysis as required for any future qualification / review effort. Personnel have also been advised of AP&L's position of not operating EQ Limitorque motor optrators with energized space. heaters.

Coupled with the above described counseling already performed, AP&L will continue to include appropriate emphasis on full documentation of qualification bases during future procedure training conducted for employees.

Date of Full Compliance:

All steps required to achieve full compliance were completed in May, 1988.

D. VIOLATION REGARDING MAINTENANCE PROCEDURE ADEQUAC_Y_

(Violation No. 313/8805-04; 368/8805-04)

The staff alleges that during the period of February 29 through June 10, 1988 maintenance procedures were inadequate for performing maintenance on reactor containment building cooling unit fan motors.

As the result of this inadequacy, the repair of electrical insulation, the repair replacement of the motor bearing, and the lubrication of the motors were performed incorrectly.

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AP&L's Position Regarding the Violation:

AP&L does admit that the maintenance procedures for reactor

. building / containment cooling fan motors contained inadequacies. We maintain, however, that maintenance performed in accordance with these procedures did not invalidate the environmental qualification of the

. motors. Additionally, the specific period stated in the violation is applicable only to the replacement of bearings and, during'this period, bearing replacements were. controlled by the baseline quality

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requirements for material management and Standing Grder 3000.04, Material -End-Use Authorization, for issuance of 'aaterial. The three inadequacies were as follows:

• The use of Glyptol 1201 to touch-up minor abrasions on the insulating surfaces of'the motor windings was included in the ANO-1 motor maintenance procedure only until June 1986 and in the ANO-2 procedure until March 1987. The use of Glyptol was considered a good maintenance practice, though the use of this product was not evaluated in the environmental qualification documentation for the motors.

• The replacement of the motor bearings as controlled by the procedures was not adequate to ensure that the new bearings were identical to the original bearings in that the Anti-Friction Bearing Manufacturers Association numbers were not specified as to the number of shieles required nor as to the correct lubricant to use to grease the bearings.

• The lubricant required by the environmental qualification documentation was Chevron SRI-2.. For a period of time, maintenance procedures included an allowance for use of the Gulf equivalent-lubricant in eccordance with the ANO lubrication program. The environmental qualification requirements.for lubricants were controlled by~a Maintenance administrative procedure which took precedence over specific procedures. This procedure was issued February, 1985.

The fan and motor maintenance procedures were developed using vendor information supplied by Joy Manufacturing Company, the supplier of the fan / motor assemblies. The original procedures were issued prior to the

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environmental qualification rule (February 1983), on January 12, 1977, and May 15, 1981, for AND-1 and ANO-2 respectively. For ANO-1, maintenance such as greasing bearings perforned prior to issuance of procedures was in accordance with job orders. These motors were environmentally qualified under NRC Bulletin 79-018. The maintenance procedures have since been revised to reflect environmental qualification requirements. We believe that the items cited in the violation were of concern to the NRC inspector due to a lack of documentation in the environmental qualification files that specifically addressed the use of Glyptol, double versus single shielded bearings, and qualification of an admixture of Chevron SRI-2 and the Gulf equivalent (EP-2). These maintenance practices, however,

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were not considered to have an effect on the environmental qualification of the motors, and therefore, were not addressed in the qualification documentation at the time of qualification.

Corrective Action:

Each of the concerns were evaluated by AP&L and an engineering consulting firm. We have concluded that these concerns did not invalidate the environmental qualification of the motors. The-vendor-(Joy Manufacturing) was contacted which in turn contacted the motor manufacturer (Reliance Electric); they agreed with this assessment.

The particular items are discussed below.

Glyptol 1201:

AP&L had provisions in the maintenance procedures for the motors to touch-up minor abrasions on insulating surfaces of'the motor windings. Whereas the Glyptol provides additional dielectric strength, the primary insulation provide!, the majority of the insulating capability of the motor. The NRC expressed concerns relating to the compatibility of Glyptol with.the motor insulation, radiation resistance, and temperature limitations.

The manufacturer of Glyptol indicated that the product is compatible with virtually all insulation systems used on motors, and totally compatible if the insulating surface has already dried. As touch-ups with Glyptol at ANO were in the field, the insulating surfaces were dry.

According to an engineering testing laboratory, Glyptol has been successfully tested to 8.7 x 10E7 rads (gamma), which is far in excess of the specified worst case radiation dose at AND (40 years plus a 30-day LOCA). Therefore, this material is considered suitable for the radiation dose postulated at ANO.

A temperature limit of 266 degrees F is the continuous duty temperature for Class F insulation (155 degrees C) which is the rating of Glyptol. The worst case AN0 peak temperature is 289 degrees F and the temperature is actually greater than 266 degrees F for only approximately five minutes. Class F insulating systems have been tested for peak temperatures of up to 324 degrees F for three and one-half hours. Further, the duct enclosure for the motors installed at ANO provides additional thermal protection for the motor windings. Therefore, the limited use of Glyptol is considered acceptable for peak temperatures at ANO.

In summary, the previous use of Glyptol for minor revarnishing of the motor windings has not invalidated the environmental qualification of the subject motors, or any other motors installed

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-Bearing Replacement:

.The Baseline Quality. Requirements have been provided for these motors-specifying the double-shielded bearings recommended by.the' ' ,

motor manufacturer. The use of single-shielded bearings during a period of time was assessed. It was concluded that this would not have affected the environmental qualification of.the motors.

According to information provided by Joy Manufacturing in phone conversations following the NRC inspection, Reliance-(motor manufacturer) had recommended double-shielded bearings for many years because of concerns with dust and debris entering the-bearing. With today's cleanliness practices.and' motor enclosures, this recommendation is subject to modification. ' Additionally, examination of bearings removed after several years of service showed little wear. No bearing. failures have occurred due to debris in'the lubrication.

Bearing Lubrication:

The required lubrication for environmental qualification of the motors is Chevron SRI-2 with polyurea thickeners. 'Gulfcrown EP-2 contains lithium thickeners. These two lubricants' are' compatible and no separation of the thickeners from the oil should occur.

Nevertheless, no mixing of these lubricants has occurred stibsequent to the issuance of procedural controls for the environmental qualification requirements for lubricants in February 1985. Tha Electric Power Research Institute study on lubricants also isdicates that FP-2 will withstand environments of.

radiation and temperature comp &able to those assessed for SRI-2.

Therefore, we conclude that no adverse effects would have'resulted from the use of EP-2 for a period of time.

Action to Prevent Recurrence:

The documentation for the issue of concern will be included in the environmental qualification files for these motors. A review of representative samples of various types of environmentally qualified equipment will be conducted to assure maintenance procedures and practices are consistent with environmental qualification documenta-tion. While.we do not believe that any items will be identified which adversely affect qualification of equipment, any such identified discrepancies will be promptly evaluated and corrected. The overall results of this review effort will be evaluated to assess the need for any additional reviews or actions _

l' Date of Full Compliance l

We are currently in full compliance. The review of other maintenance practices and procedures will be completed by May 30, 1989.

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