IR 05000387/1986025
| ML20211A897 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/30/1987 |
| From: | Anderson C, Cheung L, Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211A851 | List: |
| References | |
| 50-387-86-25, 50-388-86-28, NUDOCS 8702190258 | |
| Download: ML20211A897 (18) | |
Text
,,
.
..
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/86-25 50-388/86-28 D6cket Nos.
50-387 50-388 License Nos. NPF-14; NPF-22 Priority Category C
--
Licensee: Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Susquehanna Steam Electric Station, Units 1 and 2 Inspection At: Allentown, Pennsylvania Inspection Conducted: November 17 - 21, 1986 Inspectors:
/ 27 f7
C.JfAnderson, Chief,PlantSystems date Sectio - EB/DRS Ch A
> lt7
>
L. S( Cheung, Reactor Engineer date M. Dev, Reactor Engineer R. Lasky, Engineer, IE M. J. Jacobus, Sandia National Laboratory D. E. Jackson, Idaho National Engineering Laboratory J. W.
to el, Idaho National Engineering Laboratory Approved by:
_ oA>t)
//Jed7
.
.
9.Durr, Chief,EngineeringBranch,DRS
' datt Inspection Summary:
Inspection on November 17 - 21, 1986 (Inspection Report Nos. 50-387/86-25 and 50-388/86-28).
Areas Inspected: Announced inspection to review the licensee's implementation of a program for establishing and maintaining the qualification of electrical equipment within the scope of 10 CFR 50.49.
Results: The inspection determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed below.
870219 % $ $a7 PDR A
ppn G
>
..
..
_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
Potential Enforcement Items:
Paragraph Item Number (s)
1.
Qualification of Valcor 4.2.1 50-387/86-25-03 high temperature wires 50-388/86-28-03 2.
Qualification of Rockbestos 4.2.2 50-387/86-25-04 Coaxial Cables 50-388/86-28-04
-
3.
Qualification of Target Rock 4.2.3 50-387/86-25-05 Solenoid Valves 50-388/86-28-05 4.
Rosemount Model 1151 transmitter equivalency evaluation not 4.3 50-387/86-25-07 in EQ binder 50-388/86-28-07 5.
Qualification of Raychem 4.4 50-387/86-25-08 Cable splices 50-388/86-28-08
'6.
Qualification of Limitorque 4.5 50-387/86-25-09 Valve operator wiring 50-388/86-25-09 Unresolved Items 1.
Practical method to identify 4.1.4 50-387/86-25-01 installed components and assure 50-388/86-28-01 EQ requirements addressed for RIEE equipment.
2.
Assure EQ requirements included 4.1.9 50-387/86-25-02 in modification activities 50-388/86-28-02 3.
Self-heating of Target Rock 4.2.3 50-387/86-25-06 Solenoid Valves 50-388/86-25-06 i
....
.
.
DETAILS 1.0 Persons Contacted 1.1 Pennsylvania Power & Light Company (PP&L)
- K. Backenstoe, Subgroup Leader R. Baker, Tct.hnical Procurement Supervisor
- D. Backstanz, Project Engineer, NPE I&C
- W. Barberich, Manager, Nuclear Licensing
- E. Bragger, Senior Project Engineer G. Butler, Plant Staff Technical Supervisor
F. Curry, Analyst, NPE
- A. Derkacs, NPE, Quality Engineer M. Golden, Plant Engineering Supervisor J. Graham, Senior Compliance Engineer, SSES D. Heffelfinger, Coordination Engineer, NQA
- H. Keiser, Vice President, Nuclear Operations
- R. Kichline, Project Licensing Specialist G. Kuczynski, IEG Supervisor / Plant Staff J. Laskos, Plant Electrical Maintenance
- V. Lombardo, Engineer, II D. McGann, Technical / Compliance Engineer
- A. Male, Manager, Nuclear Design T. Masteller, I&C Assistant Foreman G. Merrill, Plant Staff Operations Engineer T. Metzger, Assistant Foreman Electrical S. Montgomery, Maintenance Engineer
- R. Moyer, Mechanical Engineer
- J. Rothe, Supervising Engineer, Electrical
- A. R. Sabol, Manager, Nuclear, QA R. Sadwin, Nuclear Training Group S. Schloelz, I&C Technical Assistant Foreman
- R. Schwan, Assistant Manager, NQA D. Sutton, Material Supervisor D. Thomas, Assistant I&C Foreman G. Treven, I&C Engineer
- R. Wehry, Technical /EQ Coordinator
- Greg Wetzel, Senior Engineer
- W. Williams, Licensing Engineer F. Zalgawski, I&C Engineer Work Group
__
.
.
-
_ _.
--
.
.
1.2 Pennsylvania Power & Light Company Contractors
- George Cohazabeigie, Supervisory Engineer, Impell
- Nitin Patel, Project Engineer, Impe11
- David Stiuson, EQ Engineer, Digital Engineering
- Newell Woodard, Senior Project Manager, Tera Corp.
1.3 United States Nuclear Regulatory Commission
- Loren Plisco, Senior Resident Inspector
-
- Denotes those present at the exit meeting at the corporate office.
2.0 Purpose The purpose of this inspection was to review the licensee's implementation of a program meeting the requirements of 10 CFR 50.49 for Susquehanna Steam Electric Station (SSES) Units 1 and 2.
i 3.0 Backgrocnd The NRC previously reviewed the PP&L method for compliance with 10 CFR Part 50.49 as a part of the NRC licensing review for the Susquehanna 1&2 units. The NRC licensing review was based primarily on information supplied by the licensee on April 6, 1982, April 27, 1982, May 7, 1982, June 20, 1983, November 3, 1983, December 21, 1983, December 30, 1983, January 5,1984, and January 11, 1984. This review included the licensee's method for compliance and a review of Justifications for Continued Operation (JCO) for those items for which Equipment Qualification was not completed at the time. The NRC licensing review is documented in NUREG-0776 Supplemental Safety Evaluation Reports 3,4,5, and 6 dated July 1982, November 1982, March 1983 and March 1984 respectively. As a part of the licensing review, the NRC office of NRR performed an audit of the PP&L environmental qualification program on May 3 - 7, 1982. The audit included an onsite examination of selected Class 1E equipment, audits of qualification i
documentation, and an examination of the licensee's reports for completeness and acceptability. The 1982 audit consisted of a review of approximately
20% of the licensee's equipment; no significant deficiencies were noted at that time.
In NUREG-0776, Supplement 6 dated March 1984, the NRC concluded that, subject to the licensee's completion of several confirmatory items, the licensee had demonstrated compliance with the requirements of 10 CFR 50.49.
An NRC, Region I, inspection was conducted at SSES of Limitorque Motor Valve Operator internal wiring during the period September 15-19, 1986, combined Inspection Report Nos. 50-387/86-21, 50-388/86-22. The purpose of this previous inspection was to evaluate the equipment qualification of the wiring. Several deficiencies, were identified. A potential enforcement item resulting from this previous inspection is discussed in Section 4.5 of this report.
I
_,
_.
..
.
.
_ _, -. _ _, _....
_ _.,
_, _, -,.,
.
_ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _.
_
i l
4.0 Findings The NRC inspectors examined the licensee's program for establishing the qualification of electrical equipment within the scope of 10 CFR 50.49.
The program was evaluated by examination of the licensee's qualification documentation files, review of procedures for controlling the licensee's environmental qualification (EQ) efforts, verification of the adequacy and accuracy of the licensee's 10 CFR 50.49 equipment list, and an examination of the licensee's program for maintaining the qualified status of the covered electrical equipment.
Based on the inspection findings, which are discussed in more detail below, the inspection team determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49, although some deficiencies were identified.
4.1 EQ Program Requirements 4.1.1 The NRC inspectors examined the implementation and adequacy of the licensee's EQ program for establishing and maintaining the environmental qualification of electrical equipment in compli-ance with the requirements of 10 CFR 50.49. The licensee's program for establishing and maintaining qualification of elec-trical equipment within the scope of 10 CFR 50.49 is defined in the following procedures:
-
AP-140.0 " Classification of Q-List Materials," Revision 0
-
AP-200.0 " Engineering Training Program." Revision 3 AD-QA-160 " Station Environmental Qualification
-
Requirements." Revision 0
-
AD-QA-210 " Procurement control Activities," Revision 5
-
NDI-QA-15.2.10 " Replacement Item Equivalency Evaluation" Revision 1 NDI-QA-15.2.12 "Susquehanna Equipment Information System"
-
Revision 0 NDI-QA-15.3.2 " Qualification of Replacement Items,"
-
Revision 2 NDI-QA-15.3.4 " Environmental Qualification Program,"
-
Revision 0
-
NTI-QA-3310A " Equipment Environmental Qualification" Revision 1
-
DC-150.1 " Environmental Qualification Maintenance, Replacement, and Surveillance Requirements," Revision 2
-
DC-150.0 " Equipment Qualification," Revision 2
-
DC-150.2 " Environmental Qualification and SQRT Binder Preparation" Revision 2
-
DC-151.0 " Environmental Qualification and SQRT binder Updates,"
Revision 2
-
G-1007 " Environmental Qualification of New Design Class 1E Equipment," Revision 1
-
DC-030.0 " Design Change Package Generation," Revision 4
_
.
.
4.1.2 The licensee's program was reviewed to verify that adequate procedures had been established to meet the requirements of 10 CFR 50.49.. Program procedures were reviewed to evaluate procedural methods and their effectiveness for:
-
Requiring all equipment that is located in a. harsh environment and is within the scope of 10 CFR 50.49 be included on the list of equipment requiring qualification (EQ Master List).
.
-
Controlling the generation, maintenance, and distribution of the EQ Master List.
Defining and differentiating between a mild and harsh
-
environment.
Determining harsh environmental conditions at the
-
equipment location through engineering analysis and evaluation.
Establishing and maintaining a file of plant conditions.
-
-
Establishing, evaluating, and maintaining EQ documentation.
-
Training personnel in the environmental qualification of equipment.
Controlling plant modifications such as installations of
-
new and replacement equipment, and providing for updating replacement equipment to 10 CFR 50.49 criteria.
4.1.3 Procedures DC.1.50.0 and NDI-QA-15.3.4 establish the require-ments of the EQ program for SSES, and define the responsibilities for each group of personnel performing EQ activities. Procedures DC 150.2 and DC 151.0 provide guidance for preparing and updating EQ binders.
Four different types of binders are used by PP&L to l
document the qualification of EQ items.
They are:
a.
EQDF prepared mostly by Bechtel (65% of the EQ Binders)
b.
EQEL prepared by Torrey Pines Technology, for nuclear l
steam supply system equipment (20% of the EQ Binders)
!
c.
EQPL prepared by PP&L (10% of the EQ Binders)
i d.
Enhancement prepared by Impell (5% of the EQ Binders)
l l
.. _
._
---
-
_
.-
-
.
-
Since these binders were prepared by different organizations, EQ material content and documentation quality vary significantly.
The inspectors found that some of the binders reviewed were difficult to audit. These binders tended to be the older binders. The licensee discussed a program initiated by PP&L begun April 1986 to upgrade all of their EQ Binders. The enhanced binders noted above are a product of this effort. They were generally noted to be easy to audit and of good quality.
The licensee indicated that they planned to complete this file enhancement effort in 1987.
4.1.4 EQ Masters List The inspector reviewed the EQ Master list on a sampling basis to verify that all equipment that is located in a harsh environment and is within the scope of 10 CFR 50.49 is included on the master list of equipment requiring qualification.
In addition, the licensee's program for controlling the generation, maintenance, and distribution of the EQ master list was reviewed for its effectiveness.
The EQ master list is prepared in accordance with the requirements of AP 140.0 and PLI-47967 "Susquehanna Equipment Information System Casual User Manual" Revision 3, dated January 14, 1986.
Procedure NDI-QA-15. 210 allows an item to be replaced with an equivalency per " Replacement Item Equivalency Evaluation (RIEE)".
However,
,
there is no requirement for the master list to be updated to reflect the replacement in the plant. This was noted by the inspector during the Plant Physical inspection. During the walk-down, a Rosemount Model 1153 transmitter was observed to be installed in a location where the master list specified a model 1151 transmitter was installed. See Section 4.3 of this report for discussion of this issue.
Another deficiency was noted with the RIEE procedure. The procedure allows the replacement of items without specific consideration of EQ requirements pertaining to the item. The EQ rule 10 CFR 50.49 Section (K) specifies that equipment previously qualified in accordance with the D0R guidelines or NUREG-0588 need not be requalified. However, replacement
_ _ _ _ _ _ _ _ _ _ _ -
,
I
.
equipment must be qualified in accordance with 10 CFR 50.49 unless there are sound reasons to the contrary. The licensee needs to review their RIEE procedure and the control of replacement activities conducted under this procedure to assure that EQ requirements are properly addressed.
The two issues above pertaining to the master list and the RIEE procedure, to assure that the location of EQ equipment in the plant can be determined in a reasonable time period and to assure that EQ requirements are addressed in equipment replacement activities conducted under the RIEE procedure are an Unresolved Item (50-387/86-25-01; 50-388/86-28-01).
In reviewing the master list, the inspectors noticed that a number of items listed we.re located in areas where the environ-mental conditions (both normal and post accidents) are relatively mild, including radiation environment. The inspectors noted that 10 CFR 50.49 does not require that equipment in a mild environment be included on the Equipment Qualification Master list. The licensee indicated that the original master list for SSES contained numerous items that did not need to be included on the list.
In the past few years they have eliminated a number of unnecessary items from the list. The inspectors noted that further refinement of the list, to remove unnecessary items from the list, would make the SSES EQ program easier to control.
4.1.5 EQ Maintenance Program The NRC inspector reviewed the EQ maintenance program to determine the licensee's provisions for preserving the qualified status of equipment qualified to 10 CFR 50.49.
Procedure DC 150.1 establishes the requirements for EQ mainte-nance.
Implementation of these requirements are as follows:
The required maintenance for qualified equipment is identified by the Nuclear Plant Engineering (NPE) EQ group and documented in the maintenance and surveillance (M&S) sheets and filed in the "EQ Maintenance and Surveillance Requirement Manual." (The volume reviewed by the inspectors was identified to be Revision 2 dated November 7, 1986, applicable to both units 1 and 2).
These M&S sheets are transmitted to the Station EQ Coordinator at the plant site for processing and the Station Document Control Centers, also at the plant site for EQ maintenance tracking.
Two groups are responsible for performing the maintenance activities - the maintenance group (for electrical components) and the I&C group (for instruments).
Each group has its own coordinator to process the M&S sheets and to prepare the
- _ _ _ _ - _ _ _ _ _
l
.
.
work authorizations (WA) for the maintenance activities. The WA's are packages containing all steps and information necessary for performing the maintenance activities.
Each of the maintenance group supervisors direct their craftsmen to complete the maintenance activities.
The inspectors discussed with the licensee their method of identifying EQ equipment so that individuals conducting maintenance activities on EQ equipment are aware of the EQ requirements pertaining to this equipment. The licensee indicated that the Work Authorization forms are being revised to specifically designate equipment as EQ or non EQ.
The inspectors selected the following three WA packages (two I&C, one electrical) for review and did not identify any deficiencies:
a)
WA No. P61908 "HPCI Flow Circuit Replace" for FT-2N008, dated June 4, 1986.
b)
WA No. P6193A "RCIC Pressure Transmitter Circuit Replace" for PTE512N004, dated June 4, 1986.
c)
WA No. P54870 " Perform Routine Maintenance for EQ motor operated valve HVB21F001," dated June 12, 1986.
The Station Document Control Center is responsible for entering the required EQ maintenance activities into their computerized tracking system and to monitor the progress of each activity to avoid overdue maintenance activities.
4.1.6 EQ Equipment Replacement and Spare Parts Procurement Administrative Procedures AP-QA-200 " Material Control Activities" and AP-QA-210 " Procurement Control Activities" establish measures necessary to assure that applicable regulatory requirements are includee for the procurement of materials, equipment and services.
In addition, NDI-QA-2.4.7 " Replacement of Quality Materials and Services" delineates responsibilities and procedural requirements, and describes interfaces and conditions peculiar to the procurement of quality materials and services. All replacement items requiring EQ are properly identified, evaluated and tracked in accordance with the department instruction NDI-QA-15.3.2. The licensee has also
,
developed NDI-QA-15.2.10, which describes the requirements, responsibilities, and limitations for evaluating non-identical replacement items and approving them for use. This instruction provides a process for determining the adequacy of a replacement
. _ _ _ _ _ _ _ _ _ _ -
. _ _
_ -.- -
__. - -.
- --
_-
-
.
.
item to meet the original design requirements of the item it is to replace. The procedure dictates that if a substitution requires an update of design documentation to reflect the item actually installed, the substitution shall be accomplished as a modification. The Nuclear Plant Engineering staff conducts the RIEE. A deficiency in the control of replacement activities conducted under the RIEE procedure is discussed in Section 4.1.4 of this report.
The inspector discussed with the station Material Supervisor and the Senior Procurement Project Engineer their method to assure compliance with 10 CFR 50.49 for procurement of EQ related equipment and spare parts. The licensee has procured identical replacement items initially purchased as being environmentally qualified items by referencing the associated approved test reports. A review of the licensee's EQ related purchase orders of Agastat relays type E 7012AD002, and Bailey's SGTS electronic controllers PDSL-07550A, B and PDSHL-7553 A,B supported the adequacy of the licensee's EQ related procurement process.
No deficiencies were identified. The licensee has not issued any purchase orders for new items requiring EQ. The licensee representative stated that EQ related requirements are identified in the procurement documentation, and the attributes are verified during receipt inspection in the SSES Warehouse.
4.1.7 EQ Training Procedure AP-200 delineates the requirements for establishing and coordinating a training program for Nuclear Plant Engineering (NPE) personnel. The manager and his staff of the training department are responsible for developing, approving and implementing the training matrices for the NPE Personnel.
The NPE department is the entity responsible for developing an EQ program for the plants safety-related Class IE equipment and maintaining their qualified status. A review of the NPE personnel training documentation indicated that individuals performing EQ related activities have participated in EPRI, IEEE, Wiley's, US Nuclear Utilities and other such industries l
sponsored EQ training program and were knowledgeable of EQ requirements. A potential deficiency in the EQ training of responsible engineers that develop modification design change
,
packages is discussed in Section 4.1.9 at this report.
l The licensee has also developed training module ME 002,
" Environmental Qualification of Electrical Equipment" for station personnel, An update and revision of ME 002 is currently in the licensee's review cycle and will be implemented l
,. -.
-
__
, _ _ _... _ _ _ _ _
,- _,
.,
_
_, _,. _ -
_
_ _ - _ - _ - _ _ _
-
.
.
by mid December,1986. The inspector reviewed the training documentation of randomly-selected electrical maintenance, I&C,.
Nuclear Safety Maintenance, QA/QC, and station maintenance schedulers and found it current and adequate. The module.
.provided an overview of the licensee's EQ program requirements,
. qualification methodology, equipment testing, and implementation of regulatory guidelines and industry instructions pertaining to the licensee's EQ program.
4.1.8 QA/QC Interface The Nuclear Quality Assurance Manager and his staff had reviewed the NPE EQ program procedures and instructions to determine their adequacy and compliance to the regulatory requirements.
The QA group had independently reviewed and verified the adequacy and effectiveness of the licensee's EQ program implementation by performing audits of the EQ Master List, Qualification Binders, Surveillance and Maintenance, Plant Modification, Replacement, and training.
In addition, the licensee QA group also audits vendor and test lab qualification programs to the appropriate regulatory requirements.
The inspector reviewed three Nuclear Quality Assurance audits and one audit conducted by the Duquesne Light Company Nuclear Quality Assurance. The audits reviewed in-depth the licensee's EQ program and resulted in several audit findings, recommenda-tions and observations.
The inspector selected the following audit reports for review:
E-83-09, EQ Program Audit (NQA)
-
85-80, EQ Program Audit (NQA)
-
86-25, Duquesne Light Company Corporate Management
-
Audit Program (CMAP) - EQ 86-34, EQ Program Audit (NQA)
-
Within the scope of this review, no deficiencies were identi-fied.
4.1.9 Control of EQ Related Plant Modifications The licensee relies on two engineering documents to control EQ related modifications (DC 150.0 " Equipment Qualification")
which provides guidance for activities within Nuclear Plant Engineering that may affect the qualification of equipment and (DC 030.0 " Design Change Package Generation") which provides guidance on the preparation of Design Change Packages. These documents were reviewed to assess the adequacy of the licensee's
- _ __
.
.
control of EQ requirements in the Modification Program. The documents indicate that the responsible engineer shall specify requirements for modifications. Guidance to the responsible engineer for determining qualification requirements and methods is provided in DC 150.0.
In addition, exhibit D of DC 030.0 contains a listing of areas that the responsible engineer shall consider during the design change package development. The EQ Binders are noted in the list along with the appropriate
'
reference procedure and the Nuclear Plant Engineering, (NPE),
lead.
The inspector made the following observations regarding the licensee's control of EQ related modifications: (1) Responsible Engineers are not required to have training in EQ requirements and (2) there is no requirement that Design Change Packages (DCP)
be reviewed by individnals with EQ training. Considering the complexity of EQ requirements and the lack of a requirement in the modification procedures for DCP review by EQ trained personnel, the inspector questioned the adequacy of the procedure to assure that EQ requirements are properly considered for all modifications.
The deficiency in the modification procedures to assure that EQ requirements are adequately considered by requiring review of the Design Change Packages by individuals with EQ training is an Unresolved Item (50-387/86-25-02; 50-388/86-28-02).
The inspector reviewed three recent design change packages regarding EQ related modifications for Susquehanna 1&2 to determine if the packages were given adequate consideration for EQ requirements.
It was noted for each of these DCP's that EQ trained personnel were involved at some point in the review of the modification. No EQ related deficiencies were identified in the DCP's reviewed.
4.2 Detailed Review of EQ Binders The licensee's EQ binders were examined to verify the qualified status of equipment within the scope of 10 CFR 50.49.
In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selectively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified; similarity of tested equipment to that installed in the plant (e.g., insulation class, materials of components of the equipment, tested configuration compared to installed configuration, and documentation of both); evaluation of adequacy of test conditions; aging calculations for qualified life and replacement interval determination; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated equipment accuracy; evaluation of test anomalies; and applicability of EQ problems reported in IE ins / Bulletins and their resolution.
_
_
. -
.
--
.
.
The inspectors reviewed a selected sample of 20 EQ binders associated with 20 equipment types for both Units 1 and 2.
These 20 equipment types covered areas such as electrical cables, limitorque valve operators, pump motors, solenoid operated valves, cable splices, radiation detectors and pressure transmitters. At SSES, the qualification binders for each equipment type support qualification of the equipment for use in either unit. An equipment type is defined as a specific type of electrical equipment, designated by manufacturer and model, which is representative of all identical equipment in a plant area exposed to the same or less severe environmental service conditions.
The inspectors identified several file deficiencies consisting of inadequate information provided in the files to address equipment accuracy or performance requirements. Specific deficiencies of this type are discussed in sections 4.2.1 and 4.2.2 below. The licensee indicated that information of this type may be addressed generically outside of specific equipment binders. The licensee plans to include accuracy and performance information in specific equipment binders in the future.
The inspectors' review of the EQ binders determined that, for the binders reviewed, the binders supported qualification, except as discussed in sections 4.2 through 4.5 of this report.
4.2.1 Valcor High Temperature Wire The qualification of the wire was based on a Wyle Test report.
The NRC inspectors raised several concerns about the test. This lead to questioning the overall test acceptability. Specific concerns regarding the test included the following:
1) the insulationresistancesmgsuredonthesampleswereunrealistically i
high (on the order of 10 ohms during all test phases, including the high temperature steam environment). The test results indicated that the insulation resistance measured at 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> into the LOCA test was about 2 orders of magnitude higher I
than resistance measurements made before the test. This contradicts
!
the normal behavior of cable insulation.
2) All of the aged samples failed post-test dielectric withstand testing. However, it was noted that this testing was "for information only" and therefore was not further addressed.
3) Several extensively thermally-aged cables were removed from the program because the insulation was cracking prior to the accident simulation.
4)
Silicone rubber is known to degrade severely for radiation doses above approximately 30-50 M rads. The licensee was unable to
,
!
establish the qualification of the Valcor high temperature wire l
using the Wyle test report that was used as the qualification basis when the qualification binder was initially reviewed.
This is identified as a Potential Enforcement Item (50-387/86-25-03; 50-388/86-28-03).
t l
_- _ _ _ - -
__.
_ ___ _ _ _
._
.
______
.
.
Prior to the end of the inspection, the licensee presented a Valcor test report as an interim qualification basis for the Valcor wire. A future test of the Valcor wire had been planned prior to the inspection to try to extend the established cable life to beyond 6 years which was the qualified life established by the Valcor test. The NRC inspectors reviewed the Valcor
'
test report and concluded that it provided an adequate basis for cable qualification pending the licensee's completion of their future tests.
4.2.2 Rockbestos Coaxial Cables The installation manual of the General Atomic Containment High Range Radiation Monitor specifies a required insulation resistance of 10' ohms for the signal cables. The EQ binder for the Rockbestos Coaxial Cables that are used for the radiation monitor did not contain test data or an evaluation to meet this requirement. The licensee indicated that they could not establish that the Rockbestos coaxial cables meet this requirement, during a LOCA when temperatures exceed 225 F.
Prior to the end of the inspection, the licensee's NPE department wrote a memo to the plant site informing them of potential inaccurate reading of the radiation monitor during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a LOCA. The lack of data in the EQ binder to support qualification of the cables over the anticipated service conditions constitutes a Potential Enforcement Item (50-387/86-25-04; 50-388/86-28-04).
4.2.3 Target Rock Solenoid Valves The Target Rock Solenoid valves installed at SSES are Model 75KK and the tested solenoid valves are models 75G and 77CC. There was no similarity analysis in the EQ binder to identify the differences and similarities between these models. Prior to the end of the inspection, on November 19, 1986 the licensee generated a similarity analysis which identified the non-metallic materials used in these models and provided a justification for the differences.
The inspectors found this justification adequate. The lack of similarity analysis in the original EQ binder constitutes a Potential Enforcement Item (50-387/86-25-05; 50-388/86-28-05).
The licensee identified in June 1986, the need for an evaluation of Target Rock Solenoid Valve self heating effects on the qualified life of the solenoid.
Prior to the end of the inspection on November 20, 1986, the licensee completed this evaluation. They determined that the self-heating effect reduces the qualified life of the normally energized solenoid from 28.7 years to about 6 years.
m_
..
.
. _....U
-
.
15 The licensee issued a Binder Change Notice (BCN #7) prior to the end of the inspection on November 20, 1986. This BCN requires the component work sheets and qualification checklist to be revised.
In addition, they stated that the Component Maintenance / Surveillance Information Report (EQDF-46-I dated May 29, 1986) will be revised to account for the reduction of the qualified life of the solenoids. This item is unresolved pending NRC verification of the licensee's actions to revise these documents (50-387/86-25-06; 50-388/86-28-06).
4.3 Plant Physical Inspection The plant physical inspection consisted of an examination of eight types of safety-related equipment located outside containment on either Units 1 or 2.
Since both units were operating the day of the
.'
physical inspection, an examination of equipment inside containment was not possible. The inspectors examined characteristics such as mounting configuration, orientation, interfaces, model number, environment, and physical condition.
During the plant walkdown, it was noted that four of the Rosemont transmitters were specified on the EQ Master List as Model 1151 transmitters. The installed transmitters were actually model 1153.
'
Upon investigating this condition it was discovered that an RIEE had allowed this replacement.
Per Procedure DC 151.0 and Memorandum SS-2129k dated March 20, 1986, the RIEE is required to be incorpo-
rated into the applicable EQ binder per a Binder Change Notice (BCN).
The RIEE had not been incorporated into the Rosemount model 1151 EQ binder or the Rosemont model 1153 EQ binder per a BCN as required.
Not incorporating the RIEE into the EQ binders is identified as a Potential Enforcement Item (50-387/86-25-07; 50-388/86-28-07).
Prior to the end of the inspection, it was concluded that no technical problem resulted from the installation of the Model 1153 Rosemount transmitters, since these transmitters are qualified to the required plant service conditions.
4.4 Corrective Actions on Raychem Cable Splices The inspectors reviewed the licensee's follow-up to Information Notice (IN) 86-53 concerning improper installation of Raychem heat s
(
shrinkable tubing. This IN was issued on June 26, 1986.
In response, the licensee conducted an inspection of Raychem splices at SSES during August 1986.
In preparation for their inspection, the licensee enlisted the help of Raychem representatives to conduct training seminars for installation personnel, and QC inspectors. The inspections were performed on a sampling basis for Raychem splices installed in Unit 2.
The sample was selected by identifying the
,
_
,
_
.. _. _ _ _ _
._ _
-
..
categories of splices used, then randomly selecting approximately 10%
of each category. Since the equipment categories are the same for Units 1 and 2, the licensee concluded that the program scope was applicable to both units. Their inspection identified several installation variations from the Raychem specified installation.
Multiple instances of the variations were identified.
However, the licensee concluded that no gross workmanship failure had occurred during installation. The types of unsatisfactory installations and the licensee's corresponding Nonconformance Reports (NCR) include:
-
Splice exceeds use range (NCR Nos. 86-0460, 86-0461, 86-0483, 86-0493),
-
Sleeving over braid jacket wire (NCR Nos. 86-0460,86-0493),
-
Insufficient sleeve overlap over wire insulation (NCR Nos.
86-0460,86-0493),
Use of small sleeve over bolted splice (NCR No. 86-0493),and
-
-
Unsleeved breakout kits.
The licensee determined that some of the observed installation variations (with marginal overlap) are qualified by independent testing already performed by Wyle labs. All but une of the remaining variations not currently qualified, are believed qualifiable and are
!
being tested to establish qualification. The one final case, installation of small sleeving over a bolted splice _must be replaced.
The licensee developed five NCR's (Nos. 86-0460, -0451, -0483 -0493 and -0509) as a result of the above installation variations. As a corrective action, the licensee replaced the cable splices on the solenoid valves for the Main Steam Isolation Valves (MSIV) in Unit 2.
The corresponding MSIV splices in Unit I will be replaced during the next refueling outage. A justification for continued operation (JCO)
was developed for these splices on the MSIV solenoid Pigtail leads for Unit 1.
Raychem splices used on the SRV's were also replaced.
For the other NCR's, the licensee developed JCO's for the variations pending qualification testing of the remaining non qualified installations by June 1987.
The above mentioned unqualified installation variations in the Raychem splices constitute a Potential Enforcement Item (50-387/86-25-08; 50-388/86-28-08).
l The licensee's August 1986 inspection report, relating to Raychem i
splices, identifies recommended activities to assure future correct l
installation of Raychem splices.
The inspector questioned the licensee's follow up actions regarding these recommendations.
Prior to the end of the inspection, on November 21, 1986, the licensee issued an internal memorandum dealing with the status of their Raychem I
>
,-
__.
.
,
_-.
_ __
_
_ _.
-
_
-
.
inspection project. This memorandum identifies required Unit 1 inspection / rework.
This includes a sample inspection of Unit 1 Raychem splice installations and replacement of the Unit 1 Raychem splices on the MSIV Solenoid Pigtail leads. This memorandum reiterates the recommendation in the licensee's August 1986 Raychem inspection report that a continuing Raychem training program be developed and that this training be required for those involved with the installation / inspection of Raychem products.
The memorandum also describes a change in procedure MT-GE-010 to add specific vendor instructions and acceptance criteria for the installation of Raychem splices.
The NRC inspectors reviewed licensee documentation supporting the qualification of Raychem splices. No deficiencies were identified.
Most of the Raychem splices installed at SSES are located inside the containment buildings.
Since both of the units were in operation during the inspection, the inspector's physical inspection of splice installations was limited to outboard cables at containment penetrations from 2W106B and 2W105D. No deficiencies were identified.
4.5 Corrective Actions on Limitorque Valve Operator Wiring In response to NRC Information Notice No. 86-03 " Potential Deficiencies in Environmental Qualification of limitorque Motor Valve Operator Wiring," the licensee inspected the limitorque valve operators of both units, which require EQ in June 1986.
Subsequently, a major portion of the internal control wires were i
replaced with qualified cables, since these wire could not be identified and their qualification was indeterminate. Details of these corrective actions were discussed in NRC Combined Inspection Report Nos. 50-387/86-21, 50-388/86-22.
The licensee's failure to identify the limitorque operator control wires and establish their EQ or replace them with qualified wire is
.
identified as Potential Enforcement Item (50-387/86-25-09; l
50-388/86-28-09).
5.0 Unresolved Items l
Unresolved items are matters which require more information in order to
ascertain whether they are acceptable items, or violations. Unresolved i
items identified during this inspection are discussed in Details, paragraphs 4.1.4, 4.1.9 and 4.2.3.
-
6.0 Exit Meeting
~
i l
,
The inspectors met with the licensee and licensee representatives I
(denoted in paragraph 1.0) at the conclusion of the inspection on i
November 21, 1986 at the corporate office.
l l
!
.
-
-.
-.
-
-_
.
_ - -
-
. -
- -
-..
.o
.
The inspector summarized the scope of the inspection, the inspection findings and confirmed with the licensee that the documents reviewed by the team did not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information.
At no time during this inspection was written material provided to the licensee.
!
,
4
!l.
l i
!
l
!
-
.
.. -.
--
. -.
.. _ -.
..
. - -. -....
-.
,_ _