IR 05000322/1987015

Insp Rept 50-322/87-15 on 870831-1023.No Violations Noted. Unresolved Item Noted.Major Areas Inspected:Plant Operations,Radiation Protection,Security,Plant Events,Maint, Surveillance,Outage Activities & Repts to NRC

ML20236W363
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/30/1987
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236W360	List: IR 05000322/1987015 ML20236W358 ML20236W370
References
50-322-87-15, NUDOCS 8712070421
Download: ML20236W363 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-15 Docket N License N Long Island Lighting Company P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11792 Inspection At: Wading River, New York Inspection Conducted: August 31, 1987 - October 23, 1987 Inspectors: C. C. Warren, Senior Resident Inspector F. J. Crescenzo, Resident Inspector Approved By: //do-P) R.' Blofg'h, Chief, Reactor Projects Date Section 3B, Division of Reactor Projects Inspection Summary: During the period covered by Inspection Report 87-15, the facility was maintained in a cold shutdown condition. Significant work activ-ities' continued on the Colt diesel modification, Residual Heat Removal valve interlock modification and Reactor Building Ventilation maintenance. Routine maintenance and surveillance activities were also conducted. The licensee implemented a program to identify, inspect and disposition potentially defec-tive fittings installed in various plant systems. The licensee also identi-fied three unrelated instances of potentially significant material defects in installed or vendor-<.upplied safety related equipmen Specifically, these dealt with: Emergency Diesel Generator Turbocharger Diffuser cracks, poten-tially unqualified electrical splicing in containment, and improper fabrica-tion of switchgear termination lug One hundred and thd rteen (113) hours of direct inspection effort were expended for this inspectio kk

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Inspection Summary (Continued) 2

' Areas Inspected: Routine Resident Inspection of plant operations, radiation protection, security, plant events, maintenance, surveillance, outage activ-ities, and reports to the NRC. Additional inspections were also conducted in areas noted in the summary abov Results: No violations were identified. One unresolved item was identified relating to the Environmental Qualification of Okonite Splices within the primary containmen Two inspector follow items were identified to track the licensee's corrective actions related to cracks found in the Emergency Diesel Generator Turbocharger Diffuser and to track the licensee's response to issues raised following the Regional Administrator's tour of the facility on September 9, 198 k l

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l 1. Review of Facility Operations, Surveillance and Maintenance-1.1 plant' Status Summary

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During the period covered by Inspection Report 87-15, the facility remained in a: cold shutdown condition. The licensee conducted l routine surveillance and maintenance items as required by License l NPF-3 .2 Operational Safety Verification The inspector routinely toured the control room to verify proper shift manning, use of and adherence to approved procedures, and com-pliance with Technical Specification Limiting Conditions for Opera-tio Control panel instrumentation and recorder traces were observed- and the status of annunciators was reviewed. Nuclear instrumentation and reactor protection system status were examine Raciation monitoring instrumentation, including in plant Area Radia-tion monitors and effluent monitors were verified to be within al-lowable limits, and observed for indications of trends. Electrical distribution panels were examined for verification of proper lineups of backup and emergency electrical power sources as required by the Technical Specification. Eight (8) hours of this inspection effort i

were expended during backshift or weekend period The inspector reviewed Watch Engineer and Nuclear Station Operator logs for adequacy of review by oncoming watchstanders, and for proper entries. A periodic review of Night ' Orders, Maintenance Work i Requests, Technical Specification LCO Log, and other control room logs and records was made. Shift turnovers were observed on a periodic basi '

The inspector also observed and reviewed the adequacy of access con-trols to the Main Control Room, and verified that no loitering by unauthorized personnel in the Control Room Area was permitted. The inspector observed the conduct of Shift personnel to ensure adherence to Shoreham Procedures 21.001.01, " Shift Operations" and 21.004.01,

" Main Control Room - Conduct for Personnel".

1.3 Plant and Site Tours The inspector conducted periodic tours of accessible areas of the plant and site throughout the inspection period. These included:

the Turbine and Reactor Buildings., the Rad Waste Building, the Con-trol Building, the Screenwell Structure, the Fire Pump House, the Security Building, and the Colt Diesel Generator Buildin During these tcurs, the following specific items were evaluated:

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Fire Equipment - Operability and evidence of periodic inspection of fire suppression equipment;

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Housekeeping - Maintenance of required cleanliness levels;

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Equipment Preservation - Maintenance of special precautionary measures for installed equipment, as applicable;

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QA/QC Surveillance - Pertinent activities were being surveilled on a sampling ba'.,is by qualified QA/QC personnel; .

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Component Tagging -

Implementation of. appropriate equipment tagging for safety, equipment protection and- jurisdiction;

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Personnel adherence to Radiological Controlled Area rules, including proper personnel frisking upon RCA exit;

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Access control to the Protected Area, including search activ-ities, escorting and badging, and vehicle access control;

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Integrity of the Protected Area boundar i No unacceptable conditions were identifie .4 Surveillance Activities The inspector observed the performance of various surveillance tests ,

to veri fy that the surveillance procedure conformed to technical specification requirement Administrative approvals and tagging requirements were reviewed and approved prior to test initiation, testing was accomplished by qualified personnel, current approved procedures were used, test instrumentation was currently calibrated, limiting conditions. for operation were met, test data was accurately and completely recorded, removal and restoration of affected com-ponents was properly accomplished, and tests were completed within the required Technical Specification frequenc The following surveillance procedures were reviewed or observed:

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SP 24.307.01 TDI Emergency Diesel Generator Start and Load tes SP 22.008.01 Daily / Shift surveillanc SP 24.123.05 Valve line-up, and verification of " squib valve ready lights."

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SP 74.123.10 Computation of sodium penatoborate weigh l

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SP 24.123.01 SLCS operation demonstratio SP 24.123.02 SLCS loop initiation test; loop A and SP 44.654.20 Verify suction auto transfer from CST to sup-  :

pression pool on CST low-level and suppression k'

pool high-leve SP 24.202.01 HPCI Pump Flow Rate. Test (low pressure).

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SP 44.202.01 HPCI logic' initiation and functional tes SP 24.202.01 HPCI Pump Flow Rate Test (high pressure).

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SP 24.202.04 Verify high point venting, piping is filled, verify valve line-up, and correct flow controller positio No unacceptable conditions were identifie .5 Maintenance Activities The inspector observed the conduct of various maintenance activities throughout the inspection perio During this observation, the inspector verified that maintenance activities were conducted within the ' requirements of the plant's administrative procedures and tech-nical specifications, proper radiological controls were implemented and observed, proper safety precautions were observed, and that activities which have the potential to impact plant operations are properly coordinated with the control roo No unacceptable conditions were note . Licensee Reports In Office Review of Licensee Event Reports The inspector reviewed Licensee Event Reports ;LERs) submitted to the liRC to verify that details were clearly report.ed, including accuracy of the cause description and adequacy of corrective action The inspector determined whether further information was required from the licensee, whether generic implications were involved, and whether the event warranted onsite follow-u The following LERs were reviewed.

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LER 87-026: Engineered safety features actuation resulting from loss of power to the Normal Station Servicr Trans-former due to technician erro LER 87-027: Incorrect compositing of continuous liquid releases required by Technical Specification LER 87-029: Results of local leak rate test, when combined with all type B and C penetration leakages exceeded Technical Specification limit of 0.6 L LER 87-030: Primary containment vent / purge filter operated greater than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> without sampling resulting in Technical Specifications violatio Followup inspection was conducted in reference to LER 87-30. Tech-nical Specification 4.11.2.8.3.c requires the licensee to perform a laboratory analysis of a representative carbon sample from the Pri-mary Containment purge system charcoal absorber housings. This analysis is performed in .accordance with Regulatory Guide 1.52 Sec-tion C.G.b, is designed to determine filter efficiency, and is to be performed after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal absorber operation. Prior to this event, the licensee did not have a positive, real-time mech-anism for accurately monitoring total filter operating hours. The administrative controls in place to accomplish tnis tracking were effective only if the filters were operated for relatively short per-iods of time. As a resuit, on 9/10/87, the filter was found to have been in operation in excess of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> without sampling. To pre-vent future occurrences of this event the licensee has implemented corrective actions which include issuance of a Scheduled Activity Work Sheet (SAWS) thirty days (720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />) af ter a sample is take The SAWS will require the Radiochemistry Section to calculate filter run time and reissue the SAWS on a date corresponding to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> minus total filter run time. This method, if properly implemented, will ensure a sample is obtained before exceeding 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. Also, a long term corrective action will include instal-lation of a run time meter on the purge filter exhaust fa All other filter systems required by Technical Specifications have installed run time meter l The inspector had no further question related to this matter or regarding other LERs noted abov :

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l 3. Previous Inspection Items 3,1 (Update) Unresolved Item 87-16-01 Defective Fittings On August 14, 1987, the licensee identified a 10 CFR 21 reportable defect with fittings supplied by Guyon Industries and NDE inspected by X-Ray Inspection, Inc. The fittings in question were Class 1 and contained defects in the form of rejectable indication Since that date, 720 fittings supplied from Guyon Industries have been found to be installed in safety related system of these are installed in Class 1, with the remainder being installed in Class 2 ~ and 3 system The licensee has implemented a program to visually inspect all fit-tings associated with the above vendor which are installed in Class 1 systems. Any rejectable indications will be buffed out to 1/32 inch dept Engineering _ evaluation will be required for indications which exceed 1/32 inch. An inspection sample size for Class 2 and 3 systems will be determined based on the number of critical flaws ,

(those which exceed minimum wall thickness) found in Class 1 system To date, the licensee has inspected 114 Class 1 fittings and has found several surface indication Of these indications, all but four were buffed out within the 1/32 inch constraint. The licensee is continuing to evaluate the remain-ing four indication The inspector will continue to track the licensee's actions related to this issu . Significant Issues Identified During the Inspection Period 4.1 Potential Condition of Non-Compliance with Environmental Qualification (E'.Q.) Requirements On September 3, 1987, the licensee reported to the NRC a potential condition of non-compliance with the E.Q. documentation requirements of 10 CFR 50.49. The conditions noted were the existence of "back-to-back" type electrical splices using Okonite brand splicing mate-rial s found in Class 1E components within the primary containmen At the time of discovery, the licensee did not have documentation to support environmental qualification for this specific splice config-uration although qualification of "in-line" type splices using Okonite materials was adequately documente _ _ _ _ - - _ _

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The licensee identified this condition during an inspection conducted in response to NRC Information Notice 86-53 which addressed improper installation of Raychem Heat Shrinkable Tubing. A detailed descrip-tion of this inspection program can be found in NRC inspection report 50-322/87-10. Although this inspection program was originally for-mulated to identify improper installations of Raychem materials, the licensee had recently expanded the scope to include identification of Okonite back-to-back splices. This was in response to a meeting held on September 23, 1987, at Okonite facilities during which Okonite engineers informed the licensee that they (0konite) could not repre- I sent back-to-back splices as fully qualified for primary containment applications. This was due to a concern that excessive water or moisture could collect in the crotch of the splice. This was further evidenced by Environmental Qualification testing sponsored by Common-wealth Edison (CECO) during which an Okonite back-to-back splice had failed. As noted above, the licensee had previously completed testing of in-line type splices and had generically qualified Okonite materials for other configurations, including the back-to-back typ This was based on the assumption that none of the Class 1E splices in Shoreham's containment would be subjected to submergence condi-tions. As such, the in-line splice was representative of the back-to-back since the only difference would be the potential for moisture collection in the crotch of a back-to-back' splic Since discovery of the condition, the licensee has consulted with Stone and Webster Engineering (SWEC) to complete a re-analysis of the safety significance of back-to-back Okonite splices. On October 13, 1987, SWEC completed the re-analysis and concluded that the config-uration in question was still environmentally qualified. This con-clusion was based on the following: The original Shoreham specific qualification testing of Okonite materials was still applicable to all Okonite splice configura-tions used at Shoreham. This was based on the postulation that no Class 1E splices at Shoreham would be exposed to a submerg-ence condition. As such, the testing of the in-line type splice accurately represented all other splice configuration . The failure noted during the CECO tests was attributed to the splice being submerged in a puddle of highly conductive liquid (boric acid spray). This condition is considered an anomaly at Shoreham since boric acid is unique to Pressurized Water Reactor (PWR) design and none of the Class IE splices are subject to submergenc Also, other back-to-back Okonite splices had i performed acceptably during the same CECO test !

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. Preliminary results of a recent test sponsored by Alabama Power had shown that back-to-back Okonite splices performed acceptably when exposed to a LOCA environment similar to Shoreham's postu-lated LOCA condition SWEC also recommended that the licensee update 't's Environmental

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Qualification Documentation Package (EQDP) to address the recently identified Okonite concerns by: Completing the field inspection and documenting splice config-urations which could lead to moisture collecting in the crotc . Obtaining test data of the Alabama test specimens to conclude similarity to Shoreham configuration . Incorporating the CEC 0 results into the EQD The licensee has preliminarily informed the inspector that the splices in question will be replaced with Raychem type splices. This action will be based on the perception by the licensee that Raychem splices are more resistant to degradation over long periods of tim The licensee considers back-to-back Okonite splices as environmen-tally qualified for Class IE components inside the drywell. Addi-tionally, the licensee believes that proper documentation to support this was available, in the generic format, since installation of the splices in question. The inspector reviewed the licensee's commit-ments to implement an Environmental Qualification program as de-scribed in the Updated Safety Analysis Report (USAR) chapter 3.1 According to the USAR, equipment will be environmentally qualified in accordance with IEEE 323-1974 and NUREG - 0588 Category I positions, when possible. These standards require that electrical equipment be

"typetested" in specific configurations. The tests of specific con-figurations may be used to qualify similar configurations, if ade-quate analysis exists to support extrapolation of test result No such analysis existed at Shoreham prior to the SWEC analysis to sup-port extrapolation of the in line test results to the back-to-back configuration Further, other configurations, other than the back-to-back, have been qualified in the same manne The licensee's method of qualifying splice configurations by qualification of the materials appears contrary to 10 CFR 50.49 (f)(2) and 10 CFR 50.49 (j). This item will remain unresolved pending further specialist inspection (87-15-03).

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4.2. Emergency Diesel Generator 9 ycharger Diffuser Cracking While performing a visual % section in the turbocharger diffuser

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section on the Emergency. Di, 5 i Generator 101 prior to return-to-service a three inch long, hairline crack was noted in the support web-to-shell interface. Subsequent liquid penetrant inspection of L

all four web-to-shell interfaces revealed hairline cracks on each of the four area The licensee has discussed this cracking with the manufacturer, United Technologies Elliott, and based upon these discussions, and inspection by licensee engineers, it has been determined that these cracks originally formed during the casting process. The casting in question is composed cf A-297 HF 20 material and was originally cast to the specifications in ASTM A 297 8 Castings of this type require only visual inspection for surface flaws prior to acceptanc Internal cracks formed during the cooling process would, therefore, go undetected. Thermal cycling of the material during diesel opera-tion could cause growth of subsurface cracks until they became visible on the casing surfac This is currently believed to be the process that has occurred on the EDG 101 turbocharge The licensee has transported the casting to the vendors facility and the casting will be weld repaired and returned to the site. Weld repair procedures have been reviewed and accepted by the licensee's Engineering Department and the weld repairs will be made with licen-see Quality Control personnel observing all work. NRC personnel will review all repair work documentation upon return of the casting to the facilit Discussions with Regional Specialist inspectors and with licensee engineering personnel indicate that these cracks do not represent a significant safety issue. Although similar cracks have been noted at other sites with Eliot Turbocharger, no failures of the structure have been noted. Further, it would be unlikely that a critical failure would occur since the structure is not exposed to structural support stres Operability requirements prevent inspection of EDG 102 and EDG 103 turbocharger at this time; however, the licensee intends to remove the machines from service in the future for turbocharger inspectio Inspectors from the resident office will continue to monitor the licensee's corrective actions of EDG 101 and will closely follow the licensee's actions on EDG 102 and EDG 10 This item will be tracked as Inspector Follow Item 87-15-0 ____ _ _

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4.3.' Defective Crimping of Termination Lugs On ' August 19, 1987, the licensee identified deficiencies related to the crimping of termination lugs in prewired components supplied by the General Electric Compan The components were 4160 volt switch-gear equipment associated with the modification for eventual tie-in of the Colt Emergency Diesel Generators. This equipment included new switchgear circuit breaker cubicles, cubicle doors, and miscellaneous prewired device The defect involved AMP 14-16 terminal size insulated PIDG lugs which were inadequately crimped to the control wire Specifically, lugs were found with incorrect or nonexistent identification marks (dots) required to characterize the crimping ._

!- tool used in fabrication. Additionally, four lugs were found to be loose and were removed by hand from the control wire On September 3, 1987, the licensee issued a Corrective Action Request to the vendor. On September 18, 1987, the vendor informed the licen-see that the cause for the problem stemmed from " improper control of strip length when insulation was removed from the wire prior to applying the terminal lug and from improper cperator practices." As a result, all accessible terminals ' of this type supplied by General Electric have been jointly inspected by General Electric and licensee inspectors. All. unsatisfactorily crimped lugs were replaced. Approx-imately 1400 lugs were inspected and 42% required replacement. Al-though the deficiency was identified during modifications to the 101 switchgear, similar modifications to the 103 switchgear were' com-pleted earlier this yea Since the 103 switchgear is energized, some of the crimps required to be inspected remain inaccessible at this time and will be inspected at a later date. Because the Colt Diesel tie-in project is not yet complete, there is no existing safety hazard due to these potentially defective lugs in the 103 switchgea On October 19, 1987, the licensee submitted a written report in accordance with 10 CFR Part 21.21 (6), (2) and (3) to document the above problem The inspector has closely observed the licensee's actions regarding this matter. Related documentation, procedures and memorandum were reviewed by the inspecto Work activities related to inspection, identification and replacement of the subject lugs were also ob-served. The inspector found the licensee's actions to be appropriate and timel An exception to this was the relatively long period between the time the issue was noted and the evaluation for reporta-bility was complete It was noted that the licensee was at all times forthcoming with information related to this subjec The inspector will follow the licensee's corrective actions to complete inspection of the 103 switchgea l I

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1 Regional Administrator's Tour of Facility On September 9, 1987, Mr. William T. Russell, Regional Administrator, .

Region I toured the Shoreham site and the' John Dye, Jr. Training Cente i The purpose of the tour was to familiarize ' Mr. Russell with licensee facilities and management. Several items of concern were identified dur-ing the tour and were brought to the licensee's attention. These items were further highlighted in a memorandum dated September 28, . 1987 f rom Clay C. ' Warren, Senior Resident Inspector, to W. E. Steiger, Plant Manager (Attachment I).

Licensee response to the items will be tracked as Inspector Follow Item 87-15-0 . Management Meetings At periodic intervals during the course of this inspection, meetings were held with the licensee management to discuss the scope and findings of this inspectio Based on NRC Region I review of this report, and discussions with licensee representatives, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction The inspectors also attended entrance and exit interviews for inspections conducted by region-based inspectors during the perio _ - - _ _ _ _ _ . _ - . . _ .