IR 05000369/1989017

Insp Repts 50-369/89-17 & 50-370/89-17 on 890605-09.No Violations or Deviations Noted.Major Areas Inspected: Responses to Previous Insp Findings,Including Followup on NRC Bulletins 88-001 & 88-003 & on 10CFR21 Rept on Breakers

ML20246Q075
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/10/1989
From:	Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246Q068	List: IR 05000369/1989017 ML20246Q063
References
50-369-89-17, 50-370-89-17, IEB-88-001, IEB-88-003, IEB-88-1, IEB-88-3, NUDOCS 8907200423
Download: ML20246Q075 (11)

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UNITED STATES

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[ REGION 11 L' > <t .101 MARIETTA STREET. Ci/ [5 f ATLANTA. GEORGI A 30323

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Report Nos.: -50-369/89-17 and 50-370/89-17

' Licensee: Duk'e Power Company .

v 1422: South Church Street

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. Charlotte, NC: 28242?

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Docket Nos.- 50-369 and 50-370 License Nos.: NPF-9 and NPF-17 ,

Facility hame: . McGuire 1 and 2 Inspect".on Conducted: June 5-9, 1989-Inspector T. Merriweathe >// o b'

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. E. Conlon, Cliief Date Signed Plant Systems Section Engineering Branch Division'of Reactor Safety SUMMARY Scope:

This routine, announced inspection was conducted to review, what actions, if any,' the licensee had taken in response to previous inspection findings. . The items inspected involved Environmental Qualification (EQ) of electrical equipment,_ followup on NRC' bulletins 88-01 and 88-03, followup on' a 10 CFR part 21 report concerning' problems with BBC Brown Boveri K600/K800 circuit

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breakers, and followup on an open item concerning electrical cable separatio Results:

In the areas inspected, violations or deviations were not' identifie The licensee's actions in response to previous inspection findings appeared to j be acceptabl The only area that appeared to be weak was ~ the licensee's l hasidling .of- the cable performance requirements (Violation 369,370/86-20-84). ,

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With accurac the exception calculationofhadthenot containment been completed sumpforlevel channels, all long a complete term (post accident loop)

EQ instruments. Only cables and penetrations were considered in the error analysis. Thus, -it was very difficult to reach a conclusion regarding the acceptability of all components in the loop (i.e. , cables, penetrations and devices) as far as meeting the required performance characteristics provided in setpoint documents and emergency procedure A preliminary evaluation was made

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by.the licensee when the IR calculations for cables and penetrations were being ,

formulated in 1987. However loop accuracy calculations, setpoint documents and/or emergency procedures have not' yet been revised to incorporate this

.information. .The licensee was made aware of the concern and has committed to updates setpoint documents, emergency procedures and/or loop accuracy

' calculatf ons to include the error contributions 'from cables / penetrations given in the calculations. The licensee. committed to ~ have. this _ completed in accordance with the schedule provided in paragraph 2.ci

. The licensee' informed the inspector that they have initiated a design study to enhance the EQ Master -List and Maintenance Reference Index (EQRI). Plans are to create a EQ Maintenance Manual which will address maintenance requirements for all- three nuclear station The licensee is currently reviewing all station procedures to verify that appropriate EQ maintenance has been properly incorporate These changes will make the EQ List and Maintenance manual more user friendly'and will simplify revisions to the manuals 'to maintain configura-tion control when design changes are made at the plant. These. enhancements were also initiated as a result of comments received during previous NRC EQ inspections regarding the difficulty in understanding the licensee's EQ documentation. If properly implemented these changes will greatly improve the

' licensee's EQ Program documentation. This is judged to be a strengt One unresolved item (see paragraph 2.c.(5)) was identified because the High Range Radiation Monitor does not meet the factor of 2 accuracy requirements specified by R.G. 1.97.

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REPORT DETAILS Persons Contacted Licensee Employees:

• N. Atherton, Production Specialist III E. Burchfield, Nuclear Engineering Support Section

• W. T. Byers, Nuclear Security Specialist (NESS) Representative

• R. L. Dobson, Engineering Manager A. Johnson, I&E Specialist

• T. A. Ledford, Engineering Supervisor J. Lee, NESS Representative

• D. W. Murdock, Division Manager To Niggel, NESS Representative

• R. J. Smith, Design Engineer

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• J. E. Thomas Engineering Manager NRC Resident Inspectors K. VanDoorn, Senior Resident

• Attended exit interview Action on Previous Inspection Findings (92701) and (92702) (Closed) IFI 50-370/85-24-01, Violation of Electrical Separation Criteria The concern identified was that the 'electray (cable support tray) for certain train "B" safety related cable was disconnected from its supports and was laying on the "A" train cable tray belo It appears from an investigation of the circumstances that the electray may have been disconnected to allow werk on hanger 2MCARF#290 back on December 29, 1982. Afterwards on January 7,1983 the hanger was inspected by Quality Control. A little over two years later on May 22, 1985 a QC inspector found the cable tray unsupporte NCI (MC-729) was documented on May 28, 1985 some six days later. A Work Request (657891AE) was written to reinstall the electray to achieve cable separation. The electray was reinstalled and inspected. The area was also inspected as part of the corrective action to determine if there had been any recent work on supports (see NCI-MC-729).

Other actions taken by the licensee to prevent recurrence were to reinforce the importance of adequate work planning controls (work request) and appropriate procedures for all personnel performing work in the plan Additionally, the NCI was discussed with the I&C groups at each statio . _ - _ _ _ _ - _ _ - _ _ - _ _ -

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The NRC inspector accompanied by a Duke representative of the I&E department performed a walk-through inspection of the McGuire Unit 2 Cable Spreading Room, Electrical Penetration Room, ETA Switchgear Room and Battery Room with a copy of procedure IP/0/A/3250/54, Separation Requirements Cables and Associated Equipment. ' o cable 1 separation violations were identified. Based on the above this item is considered closed.

. (Closed) SL4 Violation 369,370/86-20-02, Limitorque Gear Case Grease Relief Caps A violation was identified because the gear case grease reliefs on the installed MOVs were covered with shipping caps. The valve operators identified in the report were Tag. Nos. IVX0001A, IVX00028, INSSV5570, ICA00508, ICA0054AC, and 1CA0066A The licensee response to the violation is dated November 4, 1987. In this response the licensee acknowledged the violation occurred as stated and discussed the reasons for the violation. The licensee indicated that neither the Limitorque installation manual nor the Limitorque qualification report specifically required removal of the grease relief shipping caps. As a result, some shipping caps had not been removed during construction. Subsequently, all limitorque M0V's have been inspected and shipping caps, if found, were removed. The licensee has revised the limitorque Instruction tnd Maintenance manual (MCM 1205.00-0938001) to require the remova's of dust caps when operators are being wired for power and warns against painting over T-drains or grease relief valve It also requires during lubrication inspections that T-drains and grease relief valve passages be inspected for obstruction. Additionally, PM procedure IP/0/A/3190/10 was revised to incorporate a precaution statement concerning the remeval of grease caps. All inspections for dust caps were completed August 1987. Similar problems were also corrected at other Duke sites. Based on the above, this item is considered close (Closed) SL4 Violation 369, 370/86-20-04, Cable Performance Requirements The violation resulted because Duke's qualification documentation for generic cable files did not demonstrate that the cables met performance requirements in that the appropriate functional performance requirements were not established and the required analysis was missing from the fil In response to this violation, Duke Power has performed calculations to address leakage current effects of specific cables ana penetrations used in post accident EQ circuits. The calculations performed are identified as follows:

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'(1)-MCC-1381.05-00-0177, PRZR LEVE (2) MCC-1381.05-00-0176, S/G LVL (NR)

(3) MCC-1381.05-00-0180, CNTMNT SUMP LEVEL

• (4) MCC-1381.05-000179, RCS TEMPERATURE (WR)

(5) MCC-1381.05-00-0178, RVLIS RT0'S - MINC0 (6) MCC-1381.05-00-0171/0172, HIGH RANGE RAD MONITORS

• (7) MCC-1381.05-00-0181, INCORE THERMOCOUPLE-CE

• Notes Calculations not reviewe The above calculations were reviewed to determine if cable and penetration-leakage currents met functional performance requirement The calculations appeared to be acceptable. They identified errors for accident environments as follow (1) MCC-1381.05-00-0177, Percent error in signal:

+3.09% (0 to 8.8 hrs) i

+2.76% (8.8 hrs to =)

(?) MCC-1381.05-00-0176, Percent error in signal:

+1.50% (0 to 2 hrs)

+3.04% (after 2 hrs)

(3) MCC-1381.05-00-0* 78, (MINC05), Percent error in signal:

Case I (0 to 8 hrs)

Change in signal .190 Percent Error (signal) .25%

Temperature Change .94 F Percent Error (Temp) .26%

Case II (8 hrs to a)

Change in signal .320 Percent Error (signal) .41%

Temperature change - 1.57 F Percent Error (temp) .42%

Case III (0 to 8 hrs)

Change in rignal .150  :

Percent Error (signal) .19%

Temperature change .73 F Percent Error (Temp) .20%

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Case IV (8 brs to =)

. Change in signal ~- 1.640'

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Percent Error (signal) - 2.11% error signal Temperature Change - 8.05 F

' Percent Error (Temp) - 2.18% error tem (4) MCC-1381.05-00-0180., change in signal / percent error .is 0.196V/3.60 percent of- range. The actual change in the L

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parameter in inches due to percent error is. 8.63" or 3.60% of ,

rang (5) MCC - 1381.05-00-0171/0172.- Cable resistance is 6.29 x 109 ohm and penetration resistance is 7 x 105 ohm Conclusions monitor readings ' below 150 r/hr should; be corrected by correlation to analyzed samples or can be conservatively corrected by the addition of 150 r/hr to the monitor' readin Duke Power's response to NUREG 0588 for the McGuite . Nuclear Station (MCLT-1780-03.02, Rev 5) states that "the' High Range Radiation Monitor overall system accuracy should be within a factor of 2 over the entire range as stated in R.G.I.97, Rev. The _ calibrat.ed accuracy of the system is 120% of the system range." The calculations for the HRRM show that on the low end of the scale it-does not meet the factor of. 2 accuracy due to a low penetration leakage resistance (7x105 ohms). The manufacturer's minimum allowable insulation resistance is 5x108 This does not appear to be in accordance with R.G. 1.9 Discussions with licensee representatives. revealed that they are working with the vendor to develop an acceptable fix. Some of the things being considered are to replace the cable and the penetration. This issue will be tracked as an unresolved item (50-369,370/89-17-01) pending repair of the HRRM or an exemption from R.G. 1.97 for the required factor of 2 accurac The above calculations only considered error contributions from cables and penetrations and do not account for all components in the-loop. Thus, it is difficult to determine if the cables / penetrations meet the- required performance requirements for the loops. The licensee was made aware of the concern 'and has committed to update setpoint documents, emergency proredures and/or loop accuracy calculations to incorporate the error due to environmental affects on cables / penetrations.. DPC has committed to complete this review in accordance with the following Loop Accuracy Calculations Completion Schedul l

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Loop Ncuracy Calculations C_ompletion Schedule Calculation Number Instrument Scheduled Completion Date MCC-1381.05-00-0176 S/G Level (NR) 7/31/89 MCC-1381.05-00-0177 Pressurizer Level 7/31/89 MCC-1381.05-00-0178 RVLIS RTD's NOTE 1 MCC-1381.05-00-0179 RCS Temperature (WR) 1/30/90 MCC-1381.05-00-0180 Containment Sump Level Completed MCC-1381.05-00-0181 Incore Thermocouple 1/30/90 NOTE 1: Design Study MGDS-0129 is currently re-evaluating the McGuire RVLIS system which involves input from Westinghous The completion of the design study is scheouled for 1/30/9 Conclusion DPC performed a preliminary review of loop errors in 1987 when cable and penetration calculations were being formulated. However, the results were never formalized into appropriate setpoint documents and or emergency procedures. To resolve this concern the licensee has committed to complete the calculations in accordance with the schedule abov The licensee has already included performance requirements for EPAs in the EQ file and has added appropriate references in these files to the IR calculations for both the cable and penetrations. Furthermore, Electrical Division Procedures have been revised to require that EQ Loop Accuracy Calculations be reviewed and revised if necessary for Nuclear Station Modification Based on the above, this item it now considered close (Closea) SL4 Violetion 369,370/86-20-05, ITT Barton 386A Pressure Transmitter Test Anomalies The violation resulted because Duke had not adequately established qualification for safety-related Barton 386A pressure transmitter The licensee scrapped Wyle Test Report 43904-1 which had previously been used to qualify the transmitte By using Barton Transmitter Report R3-764-9 (for Model 764 transmitters) and a letter from the vendor dated March 28, 1983 the licensee was able to establish qualification for the model 386A based on similarity to the qualified 76 The vendor states that there are no material differences between the two models. The same parts and materials are used in the construction of both. These particular 386A transmitters are used in

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the annulus where they see no containment spra Therefore, they will not be subject to similar failures of the leads due to

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intergranular corrosion of the copper wire strands which occurred on the 764 during testin Based on the above, this concern is considered close (Closed) SL4 Violation 369, 370/86-20-06, Rockbestos Silicone Rubber Insulated Cable /IN 84-44 IN 84-44 impuned the validity of original Rockbestos cable EQ test reports and.for cases where no other basis for qualification could be obtained, provided guidance foi augmenting qualification based on those reports. However, Duke considered the original test conclu-sions to be valid. The only action taken by Duke was to follow the retest progra The NRC considered that this was unacceptable and cited as a violation pursuant to 10 CFR 50.49 that qualification was not established for Rockbestos "Firewall SR" Silicone Rubber Insulated Cable. Duke's qualification was based solely on existing Rockbestos test reports which were considered inconclusiv The licensee responded to the violation in a letter dated November 4, 1987. The Licensee admitted the violation and committed to update the Rockbestos qualification file Design Drawing MCM 1354.00-0042001, Environmental Qualification Package for Rockbestos Firewall SR, Silicone Insulated, Low Voltage Power, Control, and Instrumentation, Revision 3 was last revised July 12, 198 The Qualification Package was revised to incorporate Tabs 8, 9 and 10 which includes Rockbestos' Report, " Qualification Tests for Rockbestos Firewall SR Generic Nuclear Incident for Class 1E Service in Nuclear Generating Stations," dated January 21, 1988. Tab 8 includes an Environmental Qualification Test Report / Analysis Summary of the Rockbestos Repor The Report indicates that the test was run fcr 28 days before it was terminated after all the specimens faile The root cause for the failures was assessed to be due to carbonization and failure of the extension leads which were believed to have seen temperatures as high as 454 F. The test report analyzes the affects c f the 454 F temperature on the Rockbestos FW III extension leads (see QR-5805),

and this exposure was converted into the following equivalent exposures at 90 C and 150 C. respectively:

Equivalent Exposure at 90 C = more that 2000 years Equivalent Exposure at 150 C = 5.6 years l

The test report therefore concludes that all samples passed the LOCA (28 day) test. However, the Duke file requires a 1 yr post DBE. A l Post-LOCA operability time evaluation was performed and is included in Tab 10 to qualify the cable for 1 yr Post LOCA at 125 F maximum by utilizing the Arrhenuis E and calculating the actual demonstrated aging (200 F) quation at 24 days. Based on review of the above documents this item is considered close !

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7 (Closed) SL4 Violation 369, 370/86-20-07, Samuel Moore (Eaton) PVC Cable Similarity The previous concern was that the licensee did not adequately show similarity between Samuel Moore PVC cable and Brand Rex PVC cabl In response to this concern the licensee revised the file MCM 1354.00-0022001, Environmental Qualification Package for Samuel Moore and Brand-Rex PVC Insulated Instrumentation Cable - For Outside Reactor Building use only. The licensee incorporated a Duke Test Report No. TR-017, dated September 19, 1980, which tested Samuel Moore Cable. The peak temperature, pressure and humidity in the test envelope required environmental conditions of 212 F, 29.3 PSIG and-100 percent relative humidity. The problem with the test report is-that it does not specifically address which specimens.are the Samuel Moore Cable. So you can't determine what Rad level they were exposed to or ' if they were pre-aged. As far as radiation exposure the licensee is using generic radiation data to support qualification in a: Rad area of 6.6E6 Rad (TID) - one year accident dose plus 40 years of normal operation. Based on the lower peak temperatures versus the-actual tested temperatures this appears to be acceptable, thus this item is considered close (Closed) IFI 369, 370/86-20-08, EQ Procurement The' previous concern related to the fact that the EQ Coordinator was required to review a copy and not the original of all "QA Condition 1" requisitions. Subsequently, McGuire Nuclear Station Material Handling Procedure 1.2 has been revised to require QA Condition 1, 2, 3 or 4 requisitions be reviewed by an exempt employee in the Mechanical Maintenance, I&E, Planning or Support Groups for E Based on the above this item is considered closed, (Closed) IFI 369, 370/86-20-09, EQ Personnel Training The previous concern was that EQ Training had not been given' to experienced technicians or QC personnel on EQ. Duke had agreed to review the need to provide this training. Since that inspection Duke has provided EQ training to I&E technicians, Construction Maintenance Department Craf t, and QC Inspectors. This training was given on September 25, 1986 and November 27, 1986 (Training Summary MC-1179);

and July 30 thru October 30,1987 (Training Summary MC-1360). The i licensee is also providing annual EQ training for Design Engineering Staff. The last training for engineering was given in December 198 Based on the above this item is now considered close . (Closed) IFI 369, 370/86-20-10, Electrical Penetration Assembly Performance Requirements Functional performance requirements have been included in the qualification files for EPAs. In addition appropriate references to the leakage current calculations for cables / penetrations have also i

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been include For more discussion on performance data of cables and penetrations see paragraph 2.c. above. This item is now considered close . Followup on hAC Bulletins 88-01 and 88-03 (92703) (Closed) IEB 88-01, Defects in Westinghouse Circuit Breakers Duke Power responded to the bulletin in a letter to the NRC dated April 5, 1988. The licensee indicated in this letter that all 8 05-416 breakers were replaced with new breakers containing pole shafts fabricated and inspected under the criteria described in the Westinghouse Tech Bulletin and NRC Bulletin 88-01. They also committed to revise the breaker maintenance procedure to include weld inspections, and mechanism alignment verification. The procedure was revised on September 2, 1988. Based on the above this item is considered close (Closed) IEB 88-03, Inadequate tatch Engagement in HFA Type Latching Relays Manufactured by General Electric (GE) Company The licensee responded to the bulletin in a letter to the NRC dated July 13, 1988. The licensee determined that the subject GE HFA relays with latching mechanism- are not used in any safety-related applications at McGuire, Catawba or Oconee Nuclear Stations. Based on the above this item is close . 10 CFR Part 21 Report on Potential Defect af BBC K600/K800 Circuit Breakers (Closed) 369, 370 P21 86-02, BBC Brown Boveri K600/K800 Circuit Breakers wire harness packing gear in contact w/ wiring harness and wore a hole thru insulation and severed a wir l Brown Boveri identified this concern to the NRC pursuant to 10 CFR Part 21 reporting requirements in a letter dated June 30, 1986. On the same date a letter was also provided to DPC from Brown Boveri. The results of the licensee's investigation of this problem are discussed in a letter from Fred Siurua, Associate Engineer Nuclear Maintenance to Mr. R. Futrell, Manager Nuclear Safety Assurance dated, July 18, 1986. The following information was provided:

(1) Personnel that perform maintenance on these breakers at McGuire Station have been aware of the problems for years and inspect the harness as part of breaker maintenanc (2) Where needed, rerouting of harnesses has already been don (3) McGuire Nuclear Station uses these breakers in non-safety applications onl _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ l

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R Based.on the above this item is considered close . ._ Exit Interview Tt.e inspection scope .and resul'ts were summarized on June 9,1989,Jwith ;

those persons indicated in paragraph 1. The inspector described the areas'

inspected and discussed in detail the inspection results listed belo l Although reviewed during this inspection, proprietary.information 'is not contained in this. report. Dissenting comments'were not received from the licensee. However, the licensee did commit to _certain actions' as described in' paragraph 2.c regarding loop accuracy calculation (0 pen) ' Unresolved Item 50-369, 370/89-17-01, High Range Radiation Monitor Does Not Meet R.G.1.97 requirements for accuracy, paragraph 2.c.(5). (Closed) All open items as discussed in paragraphs 2 thru 4 abov . Acronyms and Initialisms DPC Duke Power Company ,

EPA- Electrical Penetration Assembly 1 EQ Environmental Qualification i EQRI Environmental Qualification Reference Index '

FWIII Firewall III GE General Electric HRRM' High Range Rad Monitor i I&E Instrumentation and Electrical IFI Inspector Followup Item Information Notice

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IN 1 IR Insulation Resistance i M0 Motor Operated Valve l NCI Nonconforming Item Report l PM Preventive Maintenance i QA Quality Assurance j RAD Radiation j RCS Reactor Coolant Sys'.em j RID Resistance Temperature Detector  ;

RVLIS Reactor Vessel Leeel Indication System l SL4 Severity Level 4 )

TID Total Integrated Dose  !

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