IR 05000387/1989027
| ML17156B417 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/10/1989 |
| From: | Anderson C, Della Greca A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B416 | List: |
| References | |
| 50-387-89-27, 50-388-89-24, IEIN-86-003, IEIN-86-053, IEIN-86-3, IEIN-86-53, NUDOCS 8911010032 | |
| Download: ML17156B417 (10) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/89-27 50-388/89-24 Docket Nos.
50-387 50-388 License Nos.
NPF-14 NPF-22 Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns 1 vani a 18101 Facility Name:
Sus uehanna Steam Electric Station Inspection At: Allentown Penns lvania Inspection Conducted:
Au ust 21-25 1989 Inspector:
A. L. Oella Greca eactor Engineer
/o P'ate Approved by:
C.
. Anderson, Chief, Plant Systems Section date Ins ection Summar
- Ins ection on Au ust 21-25 1989 Combined Ins ection Re ort No. 050-387/89-27 and 050-388/89-24 Areas Ins ected:
Announced inspection by regional personnel to review the status of previously identified open items and to determine the adequacy of the licensee's actions to resolve them.
Results:
The inspector determined that the licensee has satisfactorily responded to twelve equipment qualification items previously identified for each plant.
One item, common to both plants, was unresolved pending the licensee's reevalua-tion and updating of its calculations associated with the qualified life of the Target Rock solenoid valves.
8911010082 8910.4 PDR ADOCK 05000887 PDC
DETAILS 1.0 Persons Contacted Penns lvania Power and Li ht Com an A. M. Male, C. T. Coddington, W.
W. Williams, T. A. Gorman, G.
D. Miller, A. P. Oerkacs, D.
B. Bockstanz, V.
E.
Lombardo, D. Glockner, A. Konstantinov, F. A. Curry, Manager Nuclear Design Engineering Sr.Project Engineer - Licensing Project Licensing Specialist Supervisor Engineer Civil Supervisor Engineer Mechanical Sr. Project Engineer -
EQ Project Engineer - Nuclear Design Project Engineer - Nuclear Design Project Engineer - Parts Design
& Analysis Project E.gineer Parts Design
& Analysis Staff Analyst
" Denotes personnel present at the exit meeting on August 25, 1989.
2.0
~Per ose The purpose of the inspection was to review the status of previously identified equipment qualification items and to determine the adequacy of the licensee'orrective actions in resolving each issue.
3.0 Status of Previousl Identified Items 3. 1 Closed Unresolved Item Nos. 50-387/86-11-02
& 50-388/86-11-03 regarding potential deficiency in the environmental qualification of control wiring in Limitorque valve motor operators.
In response to IE Information Notice No. 86-03, "Potential Deficiencies In Environmental Qualification of Limitorque Motor Valve Operator Wiring," the licensee performed an inspection of the Limitorque valve operators in harsh environments of both units.
The inspection included all safety-related valve operators located inside containment and
safety-related valve operators located ouside containment for each plant.
As a result of that inspection, 31 of the 34 inside containment valve operators were found to contain unqualified or unidentifiable limit switch jumper wires.
Of the 34 outside containment valve operators inspected, 33 contained unqualified torque switch wires and 29 contained unqualified limit switch jumpers.
The finding resulted in the immediate replacement of all unqualified or unidentifiable wiring and an evaluation of the potential safety consequences of the discrepancies identified.
These deficiencies were reviewed during the September 1986 NRC inspec-tion and left unresolved pending completion of the valve inspection by the licensee and review of the results by the NRC staf.2 Review of NonConformance Report No. 86-0359, Technical Specification No. C-1065, and random sample Work Authorizations (e.g WA No.V-60645)
indicates that the reevaluation of the Limitorque valve operators was completed and the required rewiring was also'completed.
This item is further addressed under paragraph 3. 12 below.
The licensee's corrective actions in response to the Information Notice are acceptable and the item is considered closed.
Closed Violation Nos.
50-387/86-21-01 4 50-388/86-22-01 regarding the improper sealing of flex conduits entering electrical equipment.
Ouring the September 1986 physical inspection of Unit 2 motor operated valves, the NRC inspector observed that the fl'ex conduit used for electrical cable entry into MOV HV-2F008 was not sealed.
In addition, the flex conduits entering MOVs HV-2F002, HV-2F003, and HV-21210B contained varying amounts of sealant material with large voids between the cable and the conduit.
The inspector pointed out that the lack or improper installation of conduit sealant was not in accordance with the licensee's Field Procedure No. FP-E-ll, Rev.
2, and paragraph 4.2.15 of drawing E.49, which requires, in part, that "conduits and trays entering locally mounted control equipment...from cable trays located above or below aforementioned equipment shall be effectively
~
seal'ed against entry of dust, dirt, moisture, or flaxoap with sealant material..."
In its response to the Notice of Violation, the licensee contended that its Specification E-49 had not been violated, stating, 'in part, that "Paragraph 4.2. 15...
exempts sealing on certain short conduit runs which meet other specified conditions..."
The licensee's response was reviewed by the NRC and the violation was subsequently for'mally withdrawn in a letter dated August 18, 1988.
Evaluation of note 2.b. to paragraph 4.2. 15 of Specification E-49 states that "flex, conduit and or nipples between TB's/JB's and local devices" are excluded from the requirements of paragraph No. 4.2. 15.
This item is closed.
3.3 Closed Violation Nos.
50-387/86-21-02 8 50-388/86-22-02 relative to the lack of qualification for the Marathon Series 1600 terminal blocks.
In the process of performing an Eg field inspection, the licensee replaced several Marathon 300 and 6000 Series terminal blocks used in Limitorque valve operators with equivalent Marathon 1600 Series blocks.
The Limitorque affected were located both inside and outside the primary containment of both station.4 During the September 1986 inspection, the NRC inspector reviewed the Limitorque EQ file and determined from notations on the SCEW sheet that Limitorque operators with Marathon 1600 type, terminal blocks are qualified for outside containment use only.
In addition, the inspector determined from the related Wyle report that the terminal blocks with an applied voltage of 528 VAC did not meet the requirements specified for maximum leakage current and minimum insulation resistance.
Since the report contained no data to support qualification of the terminal blocks at 480 VAC, the voltage used for motor power in several Unit 1 and Unit 2 valve operators, the blocks were considered unqualified for the application.
In response to the NRC finding, the licensee issued two NCRs to replace the unqualified Marathon 1600 Series terminal 'blocks inside containment with qualified Raychem Heat Shrinkable splices.
Review of NCR Nos.
86-0635 and 86-0636, as well as sample Work Authorizations, shows that 15 terminal blocks per Unit were replaced with Raychem splice kits.
The licensee's resolution of the finding is acceptable and this item is considered closed.
Closed Unresolved Item Nos. 50-387/86-25-01
& 50-388/86-28-01 pertaining to the updating of the.
EQ master list and the needed revision of the Replacement Item Equivalency Evaluation (RIEE)
procedure.
During the Equipment Qualification (EQ) inspection of November 1986, the NRC determined that procedure NDI-QA-15.2. 10 allowed a component to be replaced with an equivalent device subject to equivalency evaluation via the RIEE procedure.
The process, however, did not require the subsequent update of the EQ master list.
In addition, the RIEE procedure allowed the replacement of components without specific consideration of EQ requirements pertaining to the items being replaced.
Revision 3 of the RIEE procedure, NDI-QA-15.2. 10, paragraph 6.6. 1(2)
requires that "If other design documentation (e.g.,
EQ files) must be updated to reflect the equivalent item, change mechanisms shall be developed and issued..."
Although the requirement does not specifically address the updating of the EQ master list, it ensures that any modifications to the EQ equipment are properly documented and included in the EQ file.
Complete replacement of a device with an equivalent device is addressed in the same manner.
The EQ master list is revised by the EQ group which is responsible for its updating.
H
Regarding the NRC concern that the RIEE allowed replacement of components without consideration of EQ requirements, procedure NDI 15.3.2 was revised to require upgrading of the replacement equipment from Category II to Category I, unless sound reasons to the contrary exist.
The procedure also requires that the reasons for the category of the replacement items be documented whenever the replacement is not updated.
To ensure that no downgrading of equipment would occur as result of RIEEs, procedure NDI-QA-15.2. 10 was revised to remove the requirement that RIEEs'e reversible.
Category II to Category I upgrades are specifically mentionqd as a specific instance in which the requirement of non-reversibility applies.
An evaluation of the revised procedures, sample RIEEs, and the latest version of the EQ master list indicates that adequate control exist on the RIEE process to ensure that EQ requirements for replacement equip-ment and components are addressed and that the master list is updated to include new and revised equipment at the equipment level.
In addi-tion, discussions with the licensee indicate that plans are being made to address plant configuration cont> ol.
The licensee'
resolu-tion of the NRC concerns are acceptable and the item is considered closed.
3.5 Closed Unresolved Item Nos. 50-387/86-25-02 5 50-388/86-28-02 pertaining to the lack of review requirements of design change packages by individuals with formal EQ training, In reviewing the documents which control EQ related modifications, the NRC inspector observed that the engineers responsible for the modifications were not required to have training in EQ requirements and that the procedure governing design change packages, DC 030.0, did not require review of the modifications by an individual with EQ training.
The inspector's concern was that, given the complexity of the EQ requirements, the lack of review by an EQ trained individual would provide no assurance that the EQ requirement had been properly addressed.
In response to the NRC concern the licensee revised the Design Change Package procedure DC 030.0 (number and title changed to EPM-QA-209 and Modification Package, respectively) to include a 'checklist to be completed by the responsible engineer and to be added to the Modifica-tion Package.
The checklist questions the applicability of specific requirements (e.g.,
environmental and dynamic qualification, ALARA, separation, Appendix R, etc.)
and directs the responsible engineer to the applicable procedure and cogn'izant engineer.
If applicability of the specialized discipline is establiqhed, the checklist requires signature of the lead reviewe Although a specific requirement for EQ review was not added to the procedure, in consideration of the fact that modification packages are usually reviewed by several disciplines, supervisors, and committees, the use of a checklist to address EQ and other equally important design issues is considered acceptable.
This item is closed.
Review of two EQ related modification packages (87-9142 and 87-9215)
revealed that the EQ issues, including update of master list, had been given adequate attention.
3.6 Closed Violation Nos.50-387/86-25-03 5 50-388/86-28-03 pertaining to inadequate qualification documentation for.the Valcor high tem-perature wire.
During the November 1986 inspection, the NRC inspector observed several items of concern regarding the Wyle test report for the Valcor high temperature wire.
The items included unrealistically high insulation resistance measurements, failure of post-test dielectric withstand test and removal of test samples from program because of insulation cracking.
Following the inspection, the licensee obtained from Wyle the appropriate justification for the anomalous insulation resistance measurements.
In addition, the licensee conducted new qualification tests for the Valcor high temperature wire.
Review of the qualification plan and of the results from the new Wyle test demonstrates qualification of the wire for the intended applica-tion.
This item is considered closed.
3.7 Closed Unresolved Item Nos. 50-387/86-25-04 8 50-388/86-28-05 regarding the inadequate documentation for insulation resistance of Rockbestos coaxial cable.
The November 1986 review of the qualification package for the Rockbestos coaxial cable revealed that it contained no data relative to the cables insulation resistance during a
LOCA, when temperatures exceed 225'F.
The installation manual for High Range Radiation Monitors specifies a required insulation resistance of 10'hms.
Following the inspection, the licensee pe~formed an analysis to establish the system accuracy requirements and capabilities.
These were addressed in the licensee's calculation No. J-MDS-132 and added to the qualification package by means of Binder Change Notice No. 6.
As a result of the analysis, the licensee changed Emergency Procedure No. EP-IP-001 to require the manual addition of 24 R/Hr and 25 R/Hr to the actual readings when the containment post-accident radiation indication exceeds 200 R/Hr and 400 R/Hr, respectively.
The correction factor is required when the primary containment temperature exceeds 225'.8 The licensee's resolution of the NRC concern regarding the accuracy of the High Range Radiation Monitor is acceptable and the item is closed.
Closed Violation Nos. 50-387/86-25-05 5 50-388/86-28-05 pertaining to the lack of similarity analysis between the tested and installed Target Rock solenoid valves.
During the November 1986 inspection, review of the Target Rock solenoid valve Eg binder revealed that no similarity analysis existed to demonstrate qualification of the installed Model 75KK solenoid valves.
The qualification report indicated that the solenoid valves tested were Target Rock Model Nos.
75G and 77CC.
Prior to the end of the inspection the licensee generated a similarity analysis which identified the non-metallic materials used in the valves and justified the differences.
The similarity analysis and justifications were found to be adequate to establish qualification.
Notice of Violation II.A.2 was issued, nonetheless, since no analysis was found at the time of the inspection.
The lack of similarity analysis constituted a viola-tion of 10 CFR 50.49(f) which requires that each item of electrical equipment important to safety be qualified by testing of identical or similar equipment with supporting analysis, where appropriate, to show that the equipment to be qualified is acceptable.
In its response to the Notice of Violation the licensee contested the finding, stating that "Comments, resolutions, and qualification checklist notes dating back to 1982 show that the difference between the tested and installed models was recognized and addressed.
Additionally, a 1984 letter from the vendor establishes that the design differences between the two models involved are not signi-ficant to the qualification."
A detailed review of the documentation supplied by the licensee in support of its claim and a search of the qualification package during the subject inspection indicate that the licensee was, in fact, aware that the tested and installed valves were different.
However, the letter which appears to have been used for the closure of the comment to the vendor on 4/15/82 and on 4/24/82 could not be found in the qualification package.
In addition, the January 16, 1984 letter from the vendor only addresses the similarity of the coils involved.'he other materials involved were only generically addressed by the vendor's statement relative to Model 75KK-206 - "TRP 2375 can be used as the qualifying document for the Models 75KK-206 due Co the similarity in design manufacture and materials to the qualified valve" - without supporting documentation.
For the other 75KK models involved the difference between the materials other than the coils was not mentioned.
Based on the above, the violation imposed is justified and stands as state As previously stated, the analysis performed by the licensee during the November 1986 inspection is acceptable.
Its addition to the qualification report by means of Binder Change Notice No.
9 was verified during this inspection.
Therefore, this violation is considered closed.
3.9 Closed Unresolved Item Nos. 50-387/86-25-06
& 50-388/86-28-06 regarding the qualified life of the normally energized Target Rock solenoid valves.
During the November 1986 inspection, the licensee completed an evaluation of the self heating effects on the qualified life of the normally energized Target Rock solenoid valve.
The analysis was added to the qualification package by means of Binder Change Notice No. 7.
However, the SCEW sheets, qualification checklist and the Component Maintenance/Surveillance Information Report were not revised at that time.
Review by the inspector of the above stated documents indicates that the required revisions were performed, This item is closed.
3. 10 Closed Violation Nos. 50-387/86-25-07
& 50-388/86-28-07 relating to the replacement of four transmitters without the required addition of the RIEE to the EQ binder.
During the plant walkdown of the November 1986 inspection, the NRC inspector noted that four Rosemount Model 1151 transmitter had been replaced with equivalent Model 1153 transmitters.
The change had been performed by means of an RIEE.
However, no Binder Change Notice had been issued to add the RIEE to the EQ binder, as required by the licensee's Procedure DC 151.0 and Memorandum SS-2129k.
3.11 Review of EQ binder BB39 during this inspection showed that the licensee had revised the EQ binder and had added the RIEE by means of Binder Change Notice, BCN No. 5.
This item is closed.
Closed Violation Nos. 50-387/86-25-08
& 50-388/86-28-08 pertaining to the lack of qualification of installed variations of Raychem splices.
In response to Information Notice (IN) 86-53, the licensee conducted an inspection of randomly selected Raychem splices installed at the Susquehanna Steam Electric Stations.
As a result of this inspection, the licensee identified several installations which were not in accordance with those qualified by the manufacturer.
By using inde-pendent qualification tests already performed by Wyle, the licensee was able to qualify most of the variations found in the plant.
Some variations which could not be qualified were replaced and one variation which was considered to be qualifiable was being tested at the time of the November 1986 inspectio Review of the results obtained from the completed test, Wyle Report No. 48579-01,
'shows successful qualification of the questionable installation.
In addition, Procedure MT-GE-010 was revised to add specific vendor installation instructions and installation acceptance criteria.
This item is closed.
3.12 Closed Unresolved Item Nos. 50-387/86-25-09
& 50-388/86-28-09 relative to the identification and qualification of installed jumper wires in Limitorque valve operators.
As discussed under paragraph 3. 1 above, in response to Information Notice (IN) 86-03, the licensee conducted an inspection of all the Limitorque valve operators installed at both Stations.
As result of that inspection, a major portion of the internal control wires could not be identified and were therefore replaced with qualified wires.
Review of applicable documentation shows that the required inspection and modifications were completed.
This item is closed.
4.0 uglified Life of Tar et Rock Solenoids The inspector reviewed the qualification package for the Target Rock solenoids to verify acceptability of the licensee'
corrective actions in response to the issues discussed under paragraphs 3.8 and 3.9, above.
During such review, the inspector discovered that BCN No. 7, which had been issued to evaluate the qualified life of normally energized Target Rock solenoid valves, had been superseded by BCN No.
12.
This was later complemented by BCN Nos.
16 (also superseded)
and 18.
Review of these BCNs revealed that the qualified life of the normally energized solenoid valves had been extended from 8 years to 60 years except for that of the rectifier and of a relay which had been calculated to be 42. 18 and 9.4 years, respectively.
The above results are considered to be generally unacceptable since life extension was primarily based upon an analysis which took into account the Class H rating of the solenoid coil insulation and field temperature measurements which appear not to have considered
'worst environmental and process conditions.
Specifically:
l.
Use of analysis based upon the NEMA Class rating of insulation to establish the solenoid coil's qualified life is not an acceptable substitute for accelerated aging in the case of equipment located in harsh environments, unless it can be unquestionably demonstrated that the insulation is not age sensitive during the installed life of the coils 2.
The calculation of the temperature rise of the energized coil by means of resistance measurements should allow for hot spot temperature since resistance measurements provide only average temperature ris.
The calculation for the temperature rise of the coil should take into account environmental conditions (normal, abnormal and accident),
installation requirements (e.g'.,
heat tracing, heat buildup inside solenoid enclosure, etc.),
and process conditions.
4.
Measurements whether taken in a laboratory or in the plant should be controlled and must meet all of the IEEE 323-1974 requirements.
5.
Self heating of other components (e.g., rectifiers and relays)
should be equally addressed.
6.
All.nonmetallic materials and relative activation energies should be addressed by the calculation.
7.
8.
To take advantage of the NEMA rating of the insulation, the analysis should equally demonstrate that all materials are not sensitive to other aging elements, such as radiation, relative humidity, cyclic aging, normal and seismic vibration, etc.
Bases for calculation and assumptions should be appropriately justified.
9, The calculation should clearly identify the solenoid valves within the scope of the analy'sis.
The Target Rock solenoid valves are currently acceptable for operation based on the analysis performed during November 1986 and added to the qualification report as Binder Change Notice No. 9.
However, the extension, as discussed above, of the qualified life of the normally energized Target Rock solenoid valves is unresolved pending the licensee's revision of applicable calculations and associated documents.
(50-387/89-27"01, 50-388/89"24-01)
5.0 Unresolved Items Unresolved items are matters about which additional information is necessary in order to determine whether it is acceptable or a violation.
Unresolved item is discussed in paragraph 4.0.
.0
~E The inspector met with the licensee's personnel denoted in paragraph 1.0 of this report at the conclusion of the inspection period on August 25, 1989.
At that time the scope of the inspection and the inspection's results were summarized.
At no time during the inspection was written material given to the licensee.