IR 05000334/1990025
| ML20029A204 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/16/1991 |
| From: | Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029A198 | List: |
| References | |
| 50-334-90-25, 50-412-90-25, NUDOCS 9102050050 | |
| Download: ML20029A204 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-334/90-25 50-412/90-25 Docket Nos.
50-334 50-412 License No.
DRP-66 NPF-73 Licensee:
Duquesne Light Comoany P.O. Box 4 Shippingocrt. Pennsylvania Pacility Name:
Beaver Vallev Power Station. Units 1&2 Inspection At:
Shipningoort. Pennsylvania inspection Conducted:
November 26-30.1990 i
inspector:
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C. H. Wooila'rd, Reactor Engineer, Plant date
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Systems Section, EB, DRS
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C. J. Anderson, Chief, Plant Systems date Section, Engineering Branch, DRS Inspection Summary: Routine inspection conducted November 26 30,1990.
Arras Inspected: Inspection of the engineering and technical support program for the Ikaver Valley Unit 1 and 2 Power Stations. Areas inspected included organization and staffing, plant modification process, work control, quality assurance, training, management support and communications. Two outstanding open items from previous inspections were closed.
Rentilh: No violations or deviations were identified.
9102050050 910125 PDR ADCCK 0500
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DETAILS 1.0 Key Persons Contacted Duquesne Light Company l
- K. Halliday, Engineering Manager, Corporate Nuclear Services Unit
- R. Martin, Director, Nuclear / Mechanical Engineering
- D. Schmitt, Director, Electrical Engineering
- F. Lipchick, Senior Supervisor, Licensing
- M. Pavlick, Director, Quality Assurance
- B. Sepelak, Licensing Engineer N. Tonet, Manager, Nuclear Engineering Department R. Hruby, Engineer Nuclear Engineering Department G. Kammerdeiner, Director, Materials and Standards Engineering C. Kirschner, Supervisor, Quality Assurance R. Hansen, Director of General and Plant Engineering C. Davies, Enginect, Nuclear Engineering Department J. Starr, Engineer, Nuclear Engineering Department K. Woesener, Team Leader, Safety System Functional Evaluation United States Nuclear Regulatory Commission J. Beall, Senior Resident inspector
- P. Wilson, Resident inspector
- Denotes personnel present at the exit meeting on November 30,1990.
The inspector also contacted other administrative and technical personnel during the inspection.
2.0 Purnose The purpose of this inspection was to assess the adequacy of the licensee's program for engineering and technical support of plant operations including management support, interfaces with other internal and external organizations, staffing levels and experience, training and quality assurance in the engineering activities. Also included in this inspection was the licensee's control of design, design changes, plant modifications and temporary modifications. Two unresolved open technical issues from previous NRC inspections were closed.
3.0 QIgani7ation
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The Duquesne Light Company Nuclear Group is organized under the Vice President Nuclear into six sections for the operation of the Beaver Valley Power Station. The sections are:
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Nuclear Operations
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Nuclear Operations Services
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Corporate Nuclear Services
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Quality Assurance
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Human Resources
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Special Projects
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The Nuclear Engineering Department (NED) reports to the Vice President Nuclear through the Corporate Nuclear Services section.
NED is organized into five groups that report to the Manager, NED and include the l
following:
General and Plant Engineering
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Electrical and Control Engineering
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Nuclear and Mechanical Engineering
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Materials and Standards Engineering
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Computer Engineering
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The Safety System Functional Evaluation (SSFE) Manager reports to the Manager, NED. Stone and Webster (S&W) and other contract engineering personnel also report to the Manager, NED. Stone and Webster is contracted to provide services on a task basis and each task is supervised by the cogaizant NED engineering group supervisor.
The inspector interviewed engineering management and engineers and reviewed selected projects to ascertain the effectiveness of the organization, training of the individuals, communications between organizations and the plants, quality assurance involvement, and the adequacy of the staffing.
Conclusion Based upon this inspection, no deficiencies were observed in the licensee's organization that would impair its acequacy to provide the engineering support -
services required for proper plant operation and safety.
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4.0 Staffing i
The inspector discussed staffing with the cognizant engineering managers to determine whether the current levels were adequate. The NED general manager stated that the licensee staffs the engineering department to a level such that most (approximately 90%) of the workload can be handled by licensee personnel. The licensee uses contracted engineering organizations to provide personnel for the remaining work.
Work on contracted tasks is performed under the direct supervision of cognizant licensee engineers. Specialized engineering projects are purchased from outside
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contractors. In this manner the licensee keeps a stable engineering workforce with a j
high level of plant specific experience. There were 13 contract engineers working in l
the NED of6ces at the present time reporting to licensee management. These I
engineers were supervised as if they were licensee personnel. There are 108 professionals in NED with the average experience of the staff in the nuclear industry
of approximately 12 years. At the time of this inspection there were 13 unfilled
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engineering positions. The inspector observed few engineers working overtime during
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the inspection. However, during preparation for and during outages and in special
cases, overtime may be routinely scheduled to assure timely completion of design work and adequate coverage of installation work.
Conclusions
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The staffing of the engineering group was adequate. The licensee does not staff for coruplete coverage of all required engineering 13y purchasing the engineering for specine tasks from contractors the licensee maintains control of the work done on a
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these tasks and maintains direct supervision of the contractors.13y performing most of the engineering work in house the licensee maintains a stable engineering force with a high level of plant specific experience.
5.0 Workload The total amount of workload in each engineering area, the backlog of workload due and the backlog of workload past due are considered to be measures of the adequacy of engineering staffing and performance to support plant operations.
The workload in engineering is relatively heavy when in preparation for outage. The engineering group has as an objective to finish the engineering work 90 days prior to outage start. The 90 day objective is to provide time for outage planning and to allow procurement of the required materials and supplies in a timely manner, in meeting this objective, the workload tends to be high during preparation for the outage. The workload drops shortly before the outage starts and then increases during the outage when the actual installations begin.
Priorities are set in accordance with the Ileaver Valley Power Station Workload
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i Priority System Manual. The priority is determined through a set of weighting factors that include nuclear safety signi6cance, regulatory requirements, industrial safety, cost / benefit, efficiency, and other management considerations.
Management overview of the engineering activities is provided through periodic
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reviews of project status. These include review of the status of each project including
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problems, and verification of the priority, schedule, and cost. As a result of these
reviews, changes in emphasis are made depending on updated plant requirements. In an effort to improve engineering performance, the Corporate Nuclear Services Group
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has established the hionthly Performance Indicators Report of key engineering elements for engineering and corporate management information/ action. At the present time, this document reports the status of seven key engineering elements including Station hiodification Requests (DCR and Sh1R) Technical Evaluation Reports (TER), Engineering hiemoranda (Ehi), Vendor Technical hianual Review / Update (VThi), Records Updates, and Safety System Functional Evaluation (SSFE). Actual performance for each engineering element is tracked against established goals. Considerable improvements were noted in key elements from the date of inception of this program (hiarch 1990). For example, the Unit 1 VThi review / update backlog has been reduced from 1956 to 365 (51% ahead of goal), and the Unit 1 TER backlog shows a total decrease from 2231 to 382. The Sh1R backlog for ShiRs in the approval cycle for both units generally reflected improvements. This additional direct ongoing management attention with engineering is viewed as a positive step tov ard improvement in engineering performance.
Conclusions The licensee has established a viable system for monitoring and controlling the engineering workload, for establishing and revising priorities, and controlling the activities of the engineering organization to meet current plant requirements. Good management involvement was evident.
6.0 Communications Communications within the engineering department with operations, quality assurance and with corporate management are largely deptmdent on daily individual interactions, and discussions among the various personnel, The inspector noted during discussions with engineers that they were familiar with the plant and had a good working relationship with individuals at the plants. The effective communications within engineering, between engineering and corporate management and between engineering and operations were evident in the routine day to day verbal communications and in more formal correspondence, These communications are enhanced by the onsite location of engineering and corporate management. There is further enhancement of communications by the engineering policy which assigns a specific lead engineer to systems who is responsible not only for the design and installation of modifications but also for the ongoing operation of the affected systems.
Communications with personnel at the plant include the use of Engineering hiemoranda in establishing projects, Design Change procedure reviews, SSFE reviews, and various formal design meetings. NED is represented at the routine plant status meetings to assure they are current on the plant activities.
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Of particular note was the communications that was established for DCP 1043, the BV Unit 2 Simulator. From the inception of this project, there has been continuous
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participation and direct interface between operations, training and engineering personnel, in fact, training and operations personnel were participants with engineering in developing the specifications for the new simulator and continue to participate by direct involvement of assigned personnel at the vendor's plant.
Continued direct involvement is planned until final turnover to training. These personnel assure that each portion of the simulation provides the desired functions.
Communications during the past year between quality assurance and engineering has improved considerably since the February 5,1990 DLCQA-7388 implementation of an ongoing involvement by QA with engineering on selected DCP's (Vertical Slice Program). Quality Assurance participates with engineering from the initial phases of a project through to its completion and turnover. 'Inis provides QA critique and assessment at all phases as contrasted to just an after completion audit. This does not alter the QA inspections at selected hold pcmts on DCP's. To date, QA has partleipated on seven DCP's including the Unit 2 RTD By Pass Manifold Elimination.
Conclusions Much of the communications between engineers and plant personnel is informal which leads to close working relationships between engineering and operations. These communications are enhanced by the onsite location of the engineering offices.
Attendance of the NED representative at the daily plant status meetings assures that engineering is abreast of plant activities and status. Communications between QA and engineering is significantly enhanced by the new ongoing involvement on selected DCPs. Assigned training and operations personnel to the Unit 2 simulator DCP has provided good ongoing communication on this project. Formal communications were in accordance with established procedures and have proven effective.
7.0 Iraining The NED site training program and training regt ' ments are described by licensee Administrative Procedures AP 4.1, NEAP 1.6 agineering Directive (ED) 42.
The inspector reviewed training records and disetmed engineering teining with cognizant managers and engineers. Engineering Directive (ED) No. 6? describes the mandatory training required for the engineering staff. This directive contains a matrix of courses mandatory for individuals in various positions. Of the many courses in this matrix, not all are required for each position. Courses in Quality Assurance, Administrative Procedures, and Station Orientation are required for all positions.
Other courses such as Reactor Theory, Auxiliary Systems, and Power Generation are mandatory for selected positions only but are available to all other positions if elected by the individual. The training received by each employee is tracked and reported periodically to department directors. - The inspector reviewed the records for selected
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individuals and determined that these individuals had taken the mandatory training as required by ED-42. In addition to the mandatory courses, licensee management encourages attendance to the many other technical courses available to engineering persor.nal. The licensee has a mandatory continuing training program. This continuing training includes refresher training, plant and industry events and selected plant activities.
Most of the training of the engineering staffis conducted onsite or in the adjacent training and plant simulator facilities. The qualifications of seventeen training staff instructors were reviewed. The instructors ave aged 8 years of nuclear plant experience and 6.5 years of training experience.
In June 1990, NED held a Technical information Presentation Symposium for engineering personnel to make presentations of papers developed in their areas of
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expertise and to discuss selected activities of the engineering department. This
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symposium was open to all engineering and management personnel of the company.
Topics covered included the following:
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Boraflex Neutron Absorbers
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Charging Pump Hydrogen Entrainment
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Seismic Qualification Utility Group
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Design Basis Code Applicability Reactor Trips
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Rx Trip Comranter Analysis
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Electomagnetic Fields
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Hlectrical Relay Philosophy
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Auxiliary Feed vater Reliability
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Feedwater Valve Modification
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Feedwater Instability The purpose of this symposium was to inform management and technical personnel of activities that are in progras within the company. Many of these technical papers I
have been shared with industry and some have been published in national technical l
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Conchisions The licensee has developed and implemented a comprehensive mandatory and elective training program for engineering and management personnel. Management strongly supports these training programs as evidenced by the high number of courses available and the number of individuals participating not only in the completion of their mandatory training but also in the elective course training. The annual Technical Information Symposium with its large number of presentations to both management
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and tecScal personnel represents a significant entity in the overall training of personnel. There is ample evidence of a significant commitment to training by the licensee.
8.0 Design Change Procelure (DCP) Reviews l
Plant modifications are implemented by means of Design Change Procedures (DCP).
These procedures are prepared and implemented in accordance with Site Administrative Procedure (SAP) Chapter 45 " Design Change Control." The licensee has established a system for DCPs whereby the lead engineer on a project is responsible for that project for the duration of his assignment in the engineering department. This assures that there is continmty from inception of the project through installatiaa,md epecadon, Multidiscipline projects are assigned to a lead engineer of the princicie discipline with support of assigned engineers from other disciplines as required.
The Resistance Terapera. ire Detector (RTD) By-Pass Elimination DCPs for both plants (UCP-698, DCP-1469) were discussed in depth with the lead engineer. This j
modification was made by the licensee in order to replace the RTD bypass manifold system with a temperature measuring system using RTD's in thermowells in the
reactor coolant piping.
h The bypass had been completed in Unit I and will be completeo in Unit 2 during the 2R outage. A detailed review of the Unit 2 DCP disclosed that it was prepared, reviewed and approved as required by the licensee's program. The DCP was c0mplete with all of the basic documentation required. It also addressed other major issues associated with the modification including ALARA. The ALARA Unit 2 exposure techniques include appropriate temporary and permanent shielding, mock-up training, dry run training, work crew briefings, procedure changes, improved access, audio / visual aids, special tools ar.d fixtures. A twenty five percent reduction in personnel exposure is projected.
As a step to improve the quality of the engineering, engineering management has implemented a DCP Reverse Look/ Hindsight program. As an initial step in this program, DCP's for Unit 17R outage were reviewed to determine the root causes of all Design Change Notices (DCN) and Field Change Notices (FCN) that were needed to complete the work. All of the root causes for the engineering changes required were assessed to determine what could have been done during the initial engineering to climinate the need for changes. These assessments were applied to the engineering for the DCPs for the current 2R outage for Unit 2. The licensee reports initial indications of significant reductions in the number of DCNs and FCNs.
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In order to address changes which could provide for improvement in the overall plant modification program, plant management initiated a task force of 40 site personnel from the various plant sections to conduct a study. Changes recommended and approved include the development of a minor modiGeation procedure, a temporary modification procedure and a plant modification control procedure. The addition'
procedures are intended to provide better dennition, direction and control in the areas of plant modification. The inspector determined that the minor and temp Jy modification prccedures were prepared and in the approval process. Impleme'4ation of these procedures is planned to begin by the end of January 1991.
Other DCPs reviewed included DCP 1135 BV2 Small Bore Snubber Optimization and DCP 1043 BV2 Simulator. No dc6ciencies were observed.
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Cauditsiom The current plant modification processes and procedures are well-documented. They provide a proper vehicle for achieving plant modiGeations. As a consequence of management involvement and direction, improvements are expected in the areas of minor and temporary modifications and in the overall quality of the modification documents. -
9.0 Safety Sysyms Functional Evaluation (SSFE)
The inspector reviewed the SSFE program (implemented 1989) with its manager and determined that the evaluation of three additional systems was completed during the past year bringing the total number of systems evaluated to seven. Concern was expressed with what actions the licensee takes with the Cndings when an SSFE is completed. The inspector determined that SSFEs including the disposition of findings are handled by the director and his staff with additional control by an SSFE Management Oversight Committee. Review of the SSFE Management Oversight Committee Monthly Status Report, dated November 9,1990, disclosed that for the systems evaluated there have been 253 findings; 178 have been resolved and 75 ren ain open. Of the 75 open items,29 are shown as being overdue. The licensee's system for addressing findings assigns a specific individual to each item along with a
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schedule for resolving the item. The inspector determined that the licensee's scheduling and followup for closure of outstanding items was aggressive.
The !!ccnscc's Design B& sis Documentation (DBD) and Configuration Management Program (CMP) are tied programmatically to the SSFE program. The inspector determined that the licensee is approximately fifty percent complete in the establishment of DBD for Unit 1. As a part of this program, there are ten safety systems documents that are common to both Unit I and Unit 2 which will be completed. A review by the licensee disclosed that for Unit 2, there are a total of seventy DBD. However, only one DBD remains to be completed under this progra _ _ _ _ _ _ _ _ - _ _ _ _ _ _
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The licensee projects completion of all DBD by the end of 1992. The licensee's CMP is a five year project which is projected for completion by the end of 1993. The licensee reports that eighteen of twenty-seven CMP action items have been completed to date.
&nclusions The SSFE team approach is providing the licensee with a good management vehicle for updating the design basis documents for the plant. The licensee's aggressiveness in performing the SSFEs, promptness in addressing the findings / observations, and the good control by the Management Oversight Committee reflect significant upper level management support for this program.
10.0 Erosion / Corrosion Program The licensee's erosion / corrosion program which was formalized for both Units in 1987 is described by Engineering Standard ES M-009. This program addresses the NUMARC guidelines establishing the long term monitoring for erosion / corrosion of selected portions of single and two phase high energy safety related non nuclear carbon steel piping segments. The inspector reviewed and discussed this standard, the methods for selecting piping segments, the inspection methodology and equipment, and inspection findings for numerous piping sections.
The licensee's computerized system provides for the corrosion / erosion data from the scanning tmnsducer to be transmitted directly into the computer for analysis. The computer program provides data analyses by printing established ranges of wall thickness in various colois to visually aid in establishing areas of reduced wall thickness. In addition, this program has the feature of representing the component in three dimensions at operator-selected altitudes in colors representing wall thicknesses.
For several selected components, the inspecto, found that the computerized visual presentations of the erosion / corrosion data in multi-colors on the computer screen as well as the print outs, vividly displayed the magnitude of the erosion / corrosion. The inspector observed that the license 9 has entered 60 components from Unit 1 and 30 from Unit 2 into this analyses program. Several components from Unit I have required either replacement or repair. Now that these components have been entered into the system data base, the licensee plans to scan them periodiently to measure and trend their further erosion / corrosion.
Conclusions The licensee's continuing effective implementation of the crosion/ corrosion program reflects a long term management commitment for providing engineering support to enhance plant operation and safety.
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11.0 Ouality Assurance (OA) Audits Quality assurance audits are made of the Nuclear Engineering Department (NED) on an annual basis in order to assess the conduct of their activities. Audit Report No. BV-C-90-31, dated November 30,1990, for the audit conducted July 31 -
November 9,1990, was discussed with QA management. This audit identified two findings and fourteen observations, each of which required a prompt response from engineering relative to action taken to correct the findings, action taken to prevent recurrence, and the date when corrective actions will be implemented.
Findings are summarized as follows:
- Procedure NEAP 2.13 does not give adequate guidance or direction as to when
a Technical Evaluation Report requires a safety evaluation or OSC review.
Design concepts were observed to lack the required documented basis for the
conclusion when it was determined that the design change will neither impact compliance with f.c protection nor require upJate of the applicable fire protection report.
The audit report noted tnat engineering took prompt actions to address both of these findings during the course of the audit. The adequacy of corrective actions taken by engineering for findings and observations made during the previous (1989) Audit No.
BV-C 89-27 was addressed and included as a part of this audit.
The inspector noted that the 1989 and 1990 QA audit of engineering reflect significant improvements, particularly with regards to the prompt updating of Type I (control)
drawings. However, thne were still approximately 15 Unit I control drawings which required update at the conclusion of this audit. Although the audit did not disclose any incorrect drawings in use in the control room, the inspector expressed concern regarding the use of drawings which did not include the latest revisions.
Conclusions The inspector found that the QA audits were comprehensive and addressed NED engineering activities in considerable depth by evaluating each of the 132 characteristics included in a Quality Services Unit Audit Check List. The responses by engineering to the audit findings were prompt and provided for corrective action.
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13.0 Licensee Actions Taken on Previousiv Identified itents 12.1 iClosed) Unresolved Item 50-334/88-23 01 Aluminum Cable Termination Problems This problem was initially identified in Unit 1 on August 17, 1988, when an aluminum cable connection to a copper cable overheated at the termination junction with the resulting burning of the copper to aluminum cable conacction. This cable powered exhaust fan VS-F-4A. Inspection of redundant fan VS-F-4B cable connections revealed that the connections showed evidence of galvanic corrosion damage.
Root cause analysis revealed the following as the contributing cause for the failure:
Inadequate maintenance. During h1 arch 1985, the fan motor was
removed to allow for mechanical maintenance under hiaintenance Work Request (MWR) 856180. Although Procedures BVS-3000 and BVS-417 describe the correct method for connecting aluminum cable lugs to copper lugs, neither of these procedures were identiDed to be used in performing th:. MWIL The only instruction included was CMP-1-75-5 which is a taping procedure for motor lead terminations.
Inadequate drawings. A review of BV drawing 8700-RE-28B " Beaver
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i Valley Power Station Unit 1600 V and Below Termination and Splicing Details" revealed that it did not adequately describe the method to be used to connect aluminum cable to copper cable. (This drawing l
was not identined in the MWR).
Incomplete training. The training module " Cable, Splices and
Terminations" did not provide the details describing the differences in
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j cable types, the need for special connectors, and the special precautions and procedures needed when connecting aluminum to copper.
The inspector determined that the licensee had taken the following actions to assure proper connections of aluminum to copper cables and to prevent recurrence of improper connectors.
I'1 ring the last quarter of 1988, performed both visual and
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thermographic inspections of aluminum to copper cable connections for
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train A. No discrepancies were detected.
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Routinely conducted visual inspections of aluminum to copper
connections in switchboards and motor control centers each outage. No discrepancies were detected.
Cable splicing / connection drawings 8700-RE-28A and 8700-RE-288
were revised during May 1990 to provide detailed instructions for making aluminum to copper cable terminations.
The licensee has procured and put in service state-of-the-art
thermographic equipment. A comprehensive procedure for use of this equipment in the inspections (including cables) was issued September 16, 1990. Training of the first class of maintenance personnel in the use of the equipment was concluded July 13, 1990.
Inspection of Unit I train B cables is currently underway and is scheduled for completion by December 31,1990. Unit I train A cabics will be reinspected to obtain the proper qualitative data beginning in February 1991. Unit 2 cables will be inspected during January 1992.
(There are only 24 aluminum cables in Unit 2 with only two of these being Class lE).
The new cable inspection procedure provides for both qualitative and
quantitative evaluation of the cable terminations and provides for trending the data for any evidence of connection deterioration.
Cable connections are scheduled for thermographic reinspection at
intervals of not more than Sve years.
Based upon the licensee's actions taken to properly identify the cause of this problem, to correct the problem, and to prevent recurrence, this item is closed.
12.2 (Closed) Unresolved item 50-334/89-17-01 Emergency Diesel Generator (EDG) Fuel Oil Amlysis The NRC inspector had identi6ed the potential for EDG fuel oil degradation to occur and go undetected in stored EDG fuel oil since periodic sampling and testing of the fuel oil was not performed. The licensee has now concluded an evaluation and implemented additional initial sampling of new fuel oil for
" clear and bright" per ASTM D4176-82 and the sampling / analysis of stored EDG fuel oil each 31 days for particulate contamination per ASTM D2276-83.
The licensee's evaluation further concluded that additional fuel additives to control oxidation and biological growth would not be used since the tests for particulate contamination performed on a relatively short frequency provide assurance that degradation will not occur to the degree that would threaten l
EDG operation.
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Based upon the licensee's evaluation and corrective actions taken, this item is closed.
13.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance interview on November 26,1990. The findings of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the November 30,1990 exit interview (see paragraph I for attendees).
At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involved within the scope of this inspection.
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