IR 05000333/1986014
| ML20236T254 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/23/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fitzpatrick J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 8712010097 | |
| Download: ML20236T254 (2) | |
Text
{{#Wiki_filter:___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -- n . NOV 2 3 W Docket No. 50-333 Power Authority of the State of New York James A. FitzPatrick Nuclear Power Plant ATTN: Mr. Radford J. Converse Resident Manager P. O. Box 41 Lycoming, New York 13093 Gentlemen: Subject: Inspection No. 50-333/86-14 This refers to your letter dated October 13, 1987, in response to our letter dated September 11, 1987.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely, 10" * Or: clul 0 W iam V. Johnston, Acting Director 1 vision of Reactor Safety cc w/ enc 1: J. Phillip Bayne, President Mr. John C. Brons, Executive Vice President A. Klausmann, Senior Vice President - Appraisal and Compliance Services R. L. Patch, Quality Assurance Superintendent George M. Wilverding, Manager Nuclear Safety Evaluation Gerald C. Goldstein, Assistant General Counsel ' R. E. Beedle, Vice President Nuclear Support S. S. Zulla, Vice President Nuclear Engineering R. Burns, Vice President Nuclear Operation NRC Licensing Project Manager Dept. of Public Service, State of New York Public Document Room (POR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector j State of New York , B712010097 871123 \\\\ l ADDCK0500g3 \\ DR ' 0FFICIAL RECORD COPY RL FITZ 86-14 - 0 01.0.0 ' 11/17/87 l _ _ _ ___ - -_-_____ _ ____ _ _ _ _ _ _ _ _ _ _ - _ _ _ _
- - _ .. Power Authority of the State - of New York
l bec: Region I Docket Room (with concurrences) Management Assistant, DRMA (w/o encl) Section Chief, DRP Robert J. Bores, DRSS .
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- St s ' et 11/19/87 11//f/87 f(F/61 0FFICIAL RECORD COPY RL FITZ 86-14 - 0002.0.0 11/17/87 l
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" * " ' * " * ' 4# Authority October 13, 1987 JAFP 87-0814 U. S. Nuclear Regulatory Commission , Document Control Desk i Washington, D.C.
20555 SUBJECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333: INSPECTION NO. 86-14 - NYPA RESPONSE TO NOTICE OF VIOLATION Reference: a) NRC Letter (W. V. Johnsten to R. J. Converse) dated September 11, 1987 transmitting Inspec. tion Report Violation Notice 50-333/86-14 b) NRC Letter (S. D. Ebneter to R. J. Converse) dated October 1, 1986 transmitting Inspection Report 50-333/86-14 Enclosure: 1) Response to Notice of Violation (3 pages) 2) Response to Other Inspection Findings (3 pages) Gentlemen: provides the Authority' provisions of 10CFR2.201, Enclosures response to Appen In accordance with the (1) Violation, transmitted by Reference (a).
The inspection findings j resulting in the subject violation are contained in reference
(b).
This refers to the inspection conducted by Mr. L. S. Cheung of the NRC Region I office on August 25-28, 1986 at the James A.
FitzPatrick Nuclear Power Plant, j Reference (a) requires the Authority to submit to the Region I office a written response to the violation, which includes (1) the corrective steps which have been taken, and the results achieved (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
The Authority considers this instance of electrical splice insulation non-conformance to be an isolated case.
An inspection of all Limitorque actuators in the EQ program, both inside and , ' outside primary containment, has failed to turn up any more cases ' of this kind.
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._.. ._ ._ _ - __ _ - - __ I y i ) - U. S',-Nuclear Regulatory Commission October. 13, 1987 - ' - - FROM:. - R. ' CONVERSE.- JAFP 87-0814 SUBJECT: NRCI 86-14 . The Authority.has since successfully. completed'an additional
' - qualification test program to accident environments exceeding -- postulated Reactor Building accident conditions for a variety of' Okonite splice insulation configurations.. This test program further demonstrates the qualification of the subject insulated i splices. -The splice configuration on 27MOV-122 and 27MOV-113
- discovered during.the subject inspection would,.therefore, have - performed its intended safetyifunction during any applicable postulated accidents.
. Enclosure (1) contains-a detailed response to NRC's notice of ~ - violation in Reference-(a), and to the' applicable finding contained in paragraph 4.2.A of Reference-(b).
This response ! - describes the Authority's actions with respect to' questions (1), - (2),.and (3) of Reference (a),~ Appendix A.
Enclosure--(2) cont'ains a detailed response to NRC findings
- contained in paragraphs-4.2.B, 4.2.C., ' (b).
' and 5.1.3 of Reference , . MW o RADFORD.'J. CONVERSE RJC:MH:ls ' - ENCLOSURE CC:. NRC Region I Office, Attn..Mr. W. V. Johnston W. Fernandez V.~Walz R. Baker R. Patch NRC Resident: Inspector J. Gray,-WPO- , RMS, WPO
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_ - - _ _ _ _ _ __ _ _ _ _ _ _ _. _ _ _ _ _ _ - _ _ _ _ _ ._ " JAFP 87-0814 ' 4l C ENCLOSURE'(1) RESPONSE TO NOTICE OF VIOLATION (INSPECTION 86-14)
"- i - H 1A.
NOTICE OF VIOLATION - As.a result ; of the inspection conducted on August 25-28, - 1986,..the following violation was identified: i '10CFR50.49(f) requires that qualification of eachL-component be. based. on-resting or-experience with identical-equipment. or with similar equipment. with a . supporting analysis to show that the equipment 1 to be i qualified is acceptable, a Contrary to the ab'ove, during the course of the-inspec- 'cion on-~ August 27, 1986, the inspector identified two Limitorque operators located in the Reactor Building at elevations 326' and 338', containing 9 cable splices whose - qualification was not established, either by test, analysis or combination of'both.
B.
. INSPECTION-REPORT'86-14' FINDING - PARA. 4.2.A - , . 'During t h e -. c o u r s e o f the inspection, the inspector '. iden- .tified two Limitorque-operators (27MOV-122, 27MOV-113)g located in the Reactor Building at elevations 326' and 338 containing nine potentially unqualified cable splices, 6 in' one. operator anc 3 in the other operator.. These splices.
covered with PVC electrical tapes.
Upon notification.
were - by the inspector, the licensee's craf tsman removed.' the' PVC-tapes, revealing red colored tapes, identified by the licensee to be Okonite T-95 tapes.
, The test samples used to qualify Okonite cable splices were constructed in accordance with the instructions detailed in JAF. Document SK-00/20248-1, dated' June ' 18, 1984, which required the application of both Okonite T-95 (red tape) and Okonite~ No.
(black' tape)._ Hence, the environmental qualification of the-identified cable splices. was.not established.
The licensee was told that the above 9 splices constituted a potential violation of 10CFR50.49 requirements (50-333/86-
14-01).
Subsequent to this finding, the licensee initiated corree-tive action to replace the PVC electrical tapes with Okonite' No.
tapes.
However, installation and QC inspection records were not available for NRC's review before com-l pletion of this inspection.
Since the post-accident environment inside the Drywell is more severe than that outside, the licensee was told of the NRC's concerns that the Limitorque operators inside the Drywell might contain 'similar cable splices.
The licensee committed to conduct full inspection on the cable splices in the Limitorque operators inside the Drywell during the mini-outage scheduled in September, 1986.
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JAFP 87-0814 v ENCLOSURE (1) ' ' RESPONSE TO NOTICE OF VIOLATION (INSPECTION 86-14) . . ! - C.
RESPONSE TO NOTICE OF VIOLATION j C.1 Authority Response f ! The Authority agrees with this finding.
The fundamen-I tal_cause of the violation was a procedural non-com- ! pliance as a result of modifications to the subject ! valves in the 1981 time period.
Also, - the non-con- ! forming splice design was _ not detected during later ' environmental qualification' verification inspections.
As previously discussed during the inspection, the outer tape used in the subject splice design serves the function of " jacketing" the inner. red tape (Okonite ! T-95).
The inner tape. provides the actual electrical-insulation of the splice connection.
This jacketing tape provides abrasion protection during installation, similar to that provi(ed by a cable jacket.
Based'on a j previous Authority qualification program of Okonite tape splices to containment environments, the outer.
tape covering is not required 'to maintain electrical integrity of the connection.
This information was provided during the inspection.
period, however the inspector was concerned with possible synergistic effects between the outer PVC electrica.1 tape and the inner Okonite T-95 insulating ! tape, and the fact that this combination. comprised an.
untested configuration.
There are no known synergistic ! , effects between PVC (outer tape material) and' ethylene propylene rubber (inner Okonite T-95 material).
C.2 Immediate Corrective Actions for Untested ' Splice Configuration ! The immediate corrective action for this violation was to resplice the non-conforming splices.
JAF Work Request No. 00/42597, dated August 8, 1986, shows that on valve 27MOV-122 and 27MOV-113, limit switch cover was removed, leads disconnected, leads respliced per Installation Specification Electrical - IS-E-07, and the splices insulated per Specification IS-E-08.
The valves were then cycled per Maintenance Procedure (MP) 59.3 and returned to service.
The Authority also confirmed that the non-conforming splice configuration was not present in any primary containment Limitorque actuators during the October, 1986 outage.
This confirmation is documented under JAF Work Request 00/37017.
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gun 1 Q JAFP 87-0814 - ' m .,9 a' ENCLOSURE'(1) RESPONSE TO NOTICE OF VIOLATION (INSPECTION 86-14) .- '., C.3 Permanent Corrective Actions to Prevent Recurrence-The permanent corrective actions are as followsh'h av 1.
In 1984, the Authority implemented a ' system - of
plant-wide installation specifications fo:r~the p pose of achieving closer control over'instialla-ti w work, whether performed by plant persocnel or by outside contractors.
The splice insulation procedureg_itially IS-E-08, was a result of this e effoix and was in issued in March, 1986.T Since that time, all splice insulation work has been-performed in accordance with IS-E-08.5> These-specifications include appropriate sign-yfis. fo*;- -verification of splicing materials,,end for! safe-ty-related applications, include 'QC inipector r
verification.
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2.
Training programs for the' plant' staff electricians ' and contractor electricians have been revised ' to include specific traf ning on Installation Specqfi ^ ! L , cation IS-E-08 (Insulation of Electrical Tepaina-
L tions and Splices) ' y
,, C. 44 Date When Full Compliance is Achi.eved [. The Authority considered itselh in full comp'liancelon ' <' the date of 'the immediate correktive actions which was a; Aughst 26, 1986.
However, qualification of the as-in-stalled splice configuration was later verified to be, acceptable by type testing.
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_ _ _,,. - - - _-- M JAFP 87-0814 ' l-i" ENCLOSURE (2) ' RESPONSE TO OTHER INSPECTION FINDINGS (INSPECTION 86-14) , . A.
INSPECTION REPORT 86-14 FINDING - PARA. 4.2.B .. p During; the course of physical inspection of outside contain- , ! ment 11mitorque operators, the inspector observed that the rotor shafts of the limit switches and the limit switch
bodies were made of different materials.
There are four V types of materials (red Durez, black Durez, white Melamine and brown Fibrite) used by the manufacturer for the rotor shafts and limit switch bodies.
Two of these materials (red Durez and black Durez) were not qualified for inside con-tainment application.
Procedure M1-86-024, IP
- 1 (Inspection / Upgrades of MOV Inside Drywell), Appendix II, Item H.6, rec uired the torque ovitches and limit switch to be verifiec (identified by colors).
However, verification of the rotor shaft materials were not specifically addressed.
Absence of this verifica-tion requirement in the procedure could lead to undetected rotor shafts made of unqualified materials even though the limit switch bodies were made of qualified materials.. Discussion with one of the licensee's craftsmen revealed the t fact that verification of the color shaft materials might be ignored when the limit switches were being inspected.
This t confirmed NRC's concern of possible unqualified rotor shaft.
material inside the Drywell.
' , ' This item is unresolved pending NRC's review of licensee's b '; corrective action: 1) verification of limit switch rotor . shaft materials in Limitorque operators inside the Drywells , ,.. 2) verification requirement of limit switch rotor shaft material be included in procedure M1-86-024 IP
- 1 (50-333/86-14-02).
, AUTHORITY RESPONSE TO FINDING PARA. 4.2.B 1.
Verification of Drywell Limitorque Rotor Materials i During the JAF plant outage in October, 1986, all Livatorque actuators in the Drywell were inspected per ' ' Work Request No. 00/37317.
The inspection addressed . specifically four items: limit switch base color, ifmit switch rotor color, torque switch color, and splices.
The remits of this inspection show that the only switch materials installed in Drywell actuators are Melamine (white) and Fibrite (brown), both of which are qualified for postulated containment accident con-t ditions.
' It should be noted that the inspection also showed that the installed splice insulation was in conformance with IS-E-08.
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JAFP 87-0814 i .14 ! , ENCLOSURE (2) ., ', 'fp RESPONSE TO OTHER INSPECTION FINDINGS (INSPECTION 86-14) 1) 2.
Steps to Prevent' Installation of Incorrect Switch l c Material in Drywell ,
The Authority only stocks as spare / replacement parts, I , r Fibrite limit switch and torque switch material.
In g3 t addition, the Limitorque actuator maintenance procedure (MP) 59.3 states specifically the materials which are ., > ) acceptable for internal Limitorque parts.
Therefore,
l L the possibility of installing unqualified switch , niatorials in any Limitorqu6 actuators does not exist.
..v1 c ' B.
INSPECTION REPORT 86-14 FINDING - PARA. 4.2.C ,, .,, During the course of site inspeation, on August 26, 1986, the inspector noticed a safety elated Rosemount transmitter ' (27PT-102B, Rosemount Model 1151, not required for EQ) in operating st;at ts with a plastic cap (used for shipping only) at the alternate conduit entry point.
The installation section of Rosemount Instruction Manual 4260/4261 dated February, 1986, requires the plastic cap be replaced with, plugs and sealing compound,-in order to prevent moisture accumulatica in the electronic housing.
Subsequent to this findin!;, the licensee identified one other Rosemount trans-mitter (27FT-664) with a similar condition.
. The licensee promptly to$k corrective action to replace these plastic; caps with stainless steel plugs and sealing compound.
The record of these activities were documented in their Work Request Form Nos. 27-043219 and 27-0432201, both , dated August 27, 1986.
The inspectors did not identify any other similar plastic caps in Rosemount transmitters and had no further questions at this time.
AUTHORITY RESPONSE TO FINDING PARA. 4.2.C 1.
Corrective Steps'to Install Missing Plugs JAF Work Requests 27/43219 and 27/43220 replaced plastic caps with stainless steel plugs on the two Rosemount transmitters.
The Authority has found no other transmitters with incorrect sealing of transmit-ter hcusing.
This action was completed on August 27, J986.
> 2.
Corrective Steps to Pro'ent Recurrence The subject transmitters were installed during initial construction, and are not required to be qualified pursuant to 10CFR50.49. Turing subsequent maintenance and calibration actions by the plant staff, this deviation from the applicable technical manual require-ments was not identified or corrected.
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-, -. 'JAFP,87-0814- ,
.- . . ENCLOSURE-(2) Q LRESPONSE TO OTHER-INSPECTION FINDINGS (INSPECTION 86-14) . ' [," personnel' are continually _ encouraged to identify discrepancies between design documentation, including technical manuals and actual installed configurations.
. All Rosemoun't transmitters, included in the.JAF 'EQ-Program have qualified -conduit seal. assemblies and plugs installed. - This was the case' at the time of Inspection 50-333/86-14.
C.
INSPECTION REPORT 86-14 FINDING, PARA. 5.1.3 The Okonite cable splice samples used for the qualification test were constructed using procedures-described in - JAF Document. SK-00-20248-1, which required a minimum of four layers. (equivalent to two half-lapped layers). of Okonite T-95 tape over. exposed metal surfaces.. However, in Section-H.1.8 of Installation Specification No. IS-E-08, no minimum number of' layers was specified.- This procedure could lead to construction of unqualified cable splices-by-the crafts-men.
The. procedure is relatively new.(dated March :14, 1986).. The inspector also reviewed the old procedure MP ~ , 71.1, dated November 17, 1981 (used before March 14, 1986)' ' Section 7.1.12 of ' this procedure did state the requirement of three half-lapped-layers of Okonite T-95 tape, which is.
more conservative than the test samples.
L This item is unresolved pending NRC's review of licensee's ~ . corrective actions: 1) the cable splices constructed using the new procedure is equal to or more-conservative than the rested samples.
AUTHORITY RESPONSE TO FINDING PARA. 5.1.3 It is noticed that paragraph H.1.11 of IS-E-08 does use:the words: "... a minimum of two...", and also that the. Figures in' Appendix B which apply to Section H.1, all specify two half-lapped layers minimum.
It is, therefore, concluded that the omission of the words "A minimum of two" in para-graph H.1.8 was an' inadvertent omission.
Adequate installa-tion requirements were stated in the splice specification.
This error in t.he specification'was corrected in Revision 3 of IS-E-08.
The Authority considers this item resolved and no further action will be taken on this issue.
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