IR 05000440/1987013
| ML20237C621 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/01/1987 |
| From: | Gardner R, Guatam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20237C619 | List: |
| References | |
| 50-440-87-13, NUDOCS 8712220037 | |
| Download: ML20237C621 (28) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-440/87013(DRS)
Docket No. 50-440 License No. NPF-58-Licensee: The Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio Glen Ellyn, Illinois Inspection Conducted: Ji!1y 13 through November 10, 1987
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Inspector: A. S. Gautam Reactor Inspector, Region III Date Also participating in the inspection and contributing to the Report were:
l M. Kopp, RIII
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J. Gavula, RIII J. Jacobson, NRR T. Colburn, NRR
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T. McGee, Idaho National Engineering Laboratory (INEL)
M. Trojovski, INEL T. Humphrey, INEL M. Jacobus, Sandia Laboratories
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l V. Bacansskas, Franklin Laboratories l
Approved By:
bb b R. N. Gardner, Chief 'l//!87 l
Plant Systems Section, Region III Date Inspection Summary Inspection on July 13 through November 10, 1987 (Report No. 50-440/87013(DRS))
Areas Inspected: Special announced safety inspection of the environmental qualification (EQ) of electric equipment within the scope of 10 CFR 50.4 The inspection included licensee action on SER/TER commitments; EQ program 8712220037'sf1217 DR. ADOCK0500g0
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I compliance to 10 CFR 50.49 and requirements of Regulatory Guide 1.97; adequacy of EQ documentation; and a plant physical inspection of EQ equipment (Module Nos. 30703, 25576, and 25587).
Results: The licensee has established, but not adequately implemented a program to meet the requirements of 10 CFR 50.49. Deficiencies in the areas inspected are summarized below:
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POTENTIALLY ENFORCEABLE / UNRESOLVED ITEMS Item N Description Report Section 50-440/87013-03(DRS) Failure to perform maintenance 4c(1),(2),(3)
a, b, c, d, and e activities necessary to maintain (4), and (5)
the EQ of 10 CFR 50.49 designated Pyco temperature elements, WEED thermocouple, Rosemount (
transmitters, MSIV Blower Motors, and Target Rock Solenoid valve /87013-05(DRS) Failure to qualify by test and/or Sa(1),(2),(3)
a, b, c, d, and e analysis 10 CFR 50.49 designated (4), and (5)
Valcor Solenoid valves, Pyco temperature elements, ITT General Control actuators, ASCO solenoid valves, and various terminal blocks in Limitorque actuator /87013-07(DRS) Failure to install 10 CFR 50.49 6a,b,c,d,e,f a, b, c, d, e, and f designated Target Rock solenoid valves, Limitorque actuators, WEED resistance temperature detectors, and Pyco thermocouple in a configuration qualified by test and/or analysi ,
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OPEN ITEMS Item No., Description Report Section 50-440/87013-01(DRS) Licensee committed to upgrade 2 neutron monitoring instrumentation to Regulatory Guide 1.97 Cat I requirement /87013-02(DRS) Regulatory Guide 1.97 reactor vessel 3 level instrumentation does not meet :
Category I requirements up to the main steam line centerlin /87013-04(DRS) Further implementation of 4e the licensee's EQ training progra /87013-06(DRS) Licensee to supplement lubricant 5d file with qualification report for Mobil Grease 2 .
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DETAILS 1. Persons Contacted Cleveland Electric Company (CEI)
+ Kaplan, Vice President, Nuclear Operations
- Edelman, Vice President, NOC
- E. Riley, Manager
+M. D. Lyster, Manager l
+C. M. Shuster, Manager, Nuclear Operations
- J. J. Sheehan, Manager, Operations and Installation ;
- R. A. Stratman, General Superintendent, OPS
- D. R. Green,' General Supervisor, Elect Design
- K. R. Pech, General Supervisor, Engineering
- T. Swansiger, Supervisor, Material Services
- R. Leidich, General Supervisor, Outage Planning
- D. J. Takacs, General Supervisor, Maintenance S. J. Wojton, General Supervisor, Rad Protection W. J. Kanda, General Supervisor, I&C
+*R. A. Newkirk, General Supervisor, Technical
+B. D. Walrath, General Supervisor, EPSS
- V. K. Higaki, General Supervisor, Engineering
+E. Buzzelli, General Supervising Engineer, Licensing and Compliance
- T. Oleksiak, Lead Supervisor, Maintenance
- R. G. Solt, Supervisor, QA
- R. Segan, Lead Electrical, PQE
- S. Tulk, Supervisor, NQAD
- W. Humphries, Supervisor, NQAD M. Cohen, General Supervisor, Material Services S. F. Kenskki, Technical Superintendent J. E. Staffeira, DCP Coordinator
- T. A. Boss, Supervisor, NQAD
- B. S. Ferrell, Operations Engineer
- G. Dune, Compliance Engineer
- S. Litchfield, Senior Engineering Technologist
- T. Stear, Lead Engineer
- T. J. Stec, Lead Administrator, NED
- L. Gardner, Lead Equipment Engineer
- R. J. Tadych, Training
- B. P. Stetson, Licensing Engineer
+*K. A. Matheny, Senior Project Engineer
- J. R. Novak, I&C Unit Supervisor L. Wynn, Engineer, Procurement L. P. Lawrence, I&C Engineer R. J. Tanney, I&C Engineer L. J. Kulkofen, I&C Engineer R. J. McCarthy, Assistant Engineer, EQ l
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. Consultants to tne Licensee
- R. D. Raheja, Supervisor, Mechanical, Sargent and Lundy
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L. E. Wise, Electrical Engineer, G/C In R. H. Simmons, CAT P. W. Jacobsen, Davis-Besse U.S. Nuclear Regulatory Commission (USNRC)
+ J. Paperiello, Deputy Regional Administrator
+ J. Miller, Director, Division of Reactor Safety
+J. J. Harrison, Chief, Engineering Branch
+ J. Virgilio, Program Director, NRR
+B. Berson,' Regional Counsel
+J. A. Grobe, Director, Enforcement
+ N. Gardner, Chief, Plant Systems Section
+0. Potapovs, Section Chief, VPB, NRR G. O'Dwyer, Resident Inspector
- Denotes those attending the interim site exit meeting on July 17, 1987.
+ Denotes those attending the November 10, 1987 enforcement conference and exit interview at the conclusion of the inspectio . Licensee Action on SER/TER Commitments The NRC inspection team evaluated the implementation of the licensee's EQ corrective action commitments made as a result of EQ deficiencies identified by the NRC in the Perry FSAR Chapter 3.11 and SSER 3, 4, 5, and The deficiencies identified in SSER 5, January 1985, were discussed with the NRC staff. The licensee's proposed resolutions to these items were found acceptable by the NRC, as stated in SSER 7, November 198 The primary objective of the Region III EQ Audit in this area was to verify that appropriate analyses and necessary documentation to support the licensee's proposed and accepted resolutions were contained in the licensee's EQ files, and that appropriate modifications or replacements of equipment had been implemente During this review, the NRC inspection team selectively reviewed EQ documentation and examined equipment in the plant relevant to prior SER commitments. One SER 6 (Section 7.5.2.2) commitment remains to be implemented. This commitment is in regard to Regulatory Guide 1.97, Revision 2, and requires the licensee to submit a plan to upgrade their neutron monitoring instrumentation to Category I prior to startup from their first refueling outage. The Perry Station has not yet had a refueling outage. Pending the licensee's implementation of this commitment, this is considered an Open Item (50-440/87013-01(DRS)).
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- '(Closed - TI 2515/87) Review of Licensee Implementation of Regulatory Guide 1.97
- The inspectors reviewed the licensee's effort in qualifying Regulatory Guide 1.97 equipment-within the scope of-10 CFR 50.49, Paragraph (b)(3).
During this review, the inspectors observed that the_ licensee had submitted their Regulatory Guide'1.97 responses on July 19 and April 15',
1983 to NRR, and that the NRC had issued a final SER in December'1984 in regard to:the licensee's'conformance to Regulatory Guide 1.97.
! The inspectors performed a Regulatory Guide 1.97 review in accordance with the requirements of NRC Temporary Instruction 2515/87. Areas reviewed included verifying the adequacy of the licensee's Regulatory Guide 1.97 list; inclusion of the Regulatory Guide 1.97, Category I
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and II items in the licensee's 10 CFR 50.49 list; verification that selected Regulatory Guide 1.97 items had redundancy, physical separation, isolation, and uncompromised independent power supplies; field examination of selected Regulatory Guide 1.97 items; and verification of maintenance and surveillance activities performed on Regulatory Guide 1.97 items installed in the plan The following variables were selected for the Regulatory Guide 1.97 l
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audi * Reactor Water Level, Category 1, Types A and B
- Reactor Pressure, Category 1, Types A, B, and C
- High Pressure Core Spray System Flow, Category 2, Type D
- Drywell Pressure, Category 1, Types A, B, C, and D
- Standby Liquid Control Pressure, Category 2, Type D
- Suppression Pool Water Level, Category 1, Types A and C
- Primary Containment Pressure, Category 1, Types A, B, and C
- SRV Position Indication, Category 2, Type D
- Suppression Pool Water Temperature, Category 1, Types A and D
- Containment and Drywell Hydrogen Concentration, Category 1, Types A and C The inspectors reviewed the environmental qualification files, drawings,
. portions of the Perry technical specifications, Perry Final Safety Analysis Report, and Safety Evaluation Reports to verify the qualification of the above equipmen The equipment was confirmed to be listed on the Master Equipment List; the Category 1 equipment and variables were verified to be in redundant channels and separated in accordance with the requirements l of Regulatory Guide 1.75; and the power sources for the above equipment
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were from redundant sources. The inspectors verified that the Regulatory Guide 1.97 equipment was not shed from its power source during loss of offsite power, and that the instruments would not be compromised in regard to their power supplies during an accident. Post accident tracking of information was reviewed in FSAR Paragraph 7.5.1.4.2. The use of signal isolation was verified on process and instrumentation diagrams (this prevents failure in non-Class 1E instrumentation from degrading the indication for the audited variable).
A visual inspection of the indicators in the main control room was performed to insure that the ranges of the indicators enveloped the I
required ranges. These indicators were also i'spected to ensure that they were properly identified as required by negulatory Guide 1.9 The 1.97 indicators in the control room were found to be properly identified by a gold diamond on the indicator housin ,
Table 4.3.7.5-1 of the licensee's Technical Specifications, which -O specify the calibration and channel check frequencies, were reviewed to ensure that a test program was in place to ensure the proper operation of the Regulatory Guide 1.97 instrumentation. The calibration data sheets that resulted from loop calibrations were reviewed to ensure that the instrumentation was tested to the required ranges. Physical separation of the sensors in redundant instrument loops was also verified during the '
walkdown along with verifying sensor ranges, manufacturer, make, and mode The following deviation was noted:
Regulatory Guide 1.97 Rev. 2, Table 2, BWR variables requires reactor water level instrumentation between the bottom of the core support plate and the lesser of the top of vessel or centerline of the main steam line to meet Category 1 requirements (Regulatory Position 1.4). Contrary to the above, the reactor water level instrumentation at the Perry Plant meets Category I requirements only up to 40 inches below the main steam line centerline, and Category III requirements for the remaining distance up to the main steam line centerline. The licensee stated that this issue had been accepted by NRR, however, the Perry Regulatory Guide 1.97 SER did not acknowledge this deviation. Pending further review of this deviation with NRR, this is considered an Open Item (50-440/87013-02(DRS)).
4. EQ Program Compliance to 10 CFR 50.49
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The inspector reviewed selected areas of the licensee's EQ program to verify compliance to 10 CFR 50.49. The licensee's EQ program was found to identify methods of equipment qualification; provide for evaluation and maintenance of EQ documentation in an auditable form, including maintenance records; and provide for updating of replacement equipment, ,s and control of plant modifications. The licensee's methods for establishing and maintaining the environmental qualification of electrical equipment were reviewed in the following areas:
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a. EQ Program Procedures .
The inspectors examined the adequacy of the licensee's policies and procedures for establishing and maintaining the environmental qualification of equipment within the scope of 10 CFR 50.49. The licensee's EQ program was reviewed for procurement of qualified equipment; maintenance of qualified equipment; modification to the plant that could affect qualified equipment; updating of the EQ master list; and review and approval of EQ documentatio Procedures reviewed included the following documents:
- PNPP Equipment Qualification Program for Safety-Related Equipment, POP 0701, Revision * Equipment Qualification Program, NEDP 0701, Revision . . .
- Equipment Qualification Process, NEI 0701, Revision * Perry Procedure Systems, POP 0503, Revision _
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- Plant Instrument Calibration and Maintenance, IAP 0503, --
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- NED Indoctrination and Training, NEDP 0204, Revision * Design Control Program, NEDP 0301, Revision * Procurement Documents, NEDP 0401, Revision * Procedure / Instruction Review, Approval, and Control, NEDP 0503, Revision * Nonconformance Reports, NEDP 1501, Revision * NED Records Management Program, NEDP 1701, Revision * Procedure and Instruction Training, PAP 0211, Revision * Preparation, Review and Approval of Administrative Procedures, PAP 0502, Revision * Work Order Process, PAP 0905, Revision * Control of Mechanical / Electrical Preventative Maintenance, PAP 0906, Revision * Specification Deviation Authorization, NEI 0310, Revision * Safety Evaluations, NEI 0332, Revision * Technical Portions of Procurement Documents, NEI 0351, Revision __
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- Quality Items List, NEI 0355, Revision * Design Change Packages, NEI 0357, Revision * Wraparound Design Change Packages, NEI 0358, Revision * Design Change Notice, NEI 0363, Revision * Preparation of Procurement Specifications, NEI 0403, Revision * Quality Item List Parts Level Evaluation, NEI 0404, Revision * Procurement Requirements Evaluation, NEI 0407, Revision * Evaluation of Spare Parts Stock Code Changes and Non-Identical Replacement Parts, NEI 0411, Revision * Field Disposition Instruction / Field DLviation Disposition Requests, NEI 0602, Revision * Master Parts List, NEI 0801, Revision * Evaluation of Lubricant Application, NEI 0830, Revision Specific areas reviewed in these procedures included definitions of harsh and mild environments, equipment qualified life, service conditions, periodic testing, maintenance and surveillance, and upgrading of replacement equipment purchased after February 22, 198 No violations of NRC requirements were identifie b. 10 CFR S0.49 Master Equipment List (MEL) of EQ Equipment 10 CFR 50.49, Paragraph (d), requires licensees to prepare a list of electric equipment important to safety and within the scope of the rule. The NRC inspectors reviewed the licensee's MEL for compliance to 10 CFR 50.4 Areas reviewed included adequacy of the MEL, technical justifications for removal of items from the MEL, and licensee reviews of the MEL for changes due to field modification The inspectors verified the completeness / adequacy of the list in terms of equipment needed during accident conditions through review of piping and instrumentation drawings (P& ids), emergency procedures, technical specifications, and FSAR Because Perry Emergency Operating Procedures do not generally reference specific plant instruments or equipment when describing required operation actions, safety-related equipment located in a harsh environment and needed by the operators to satisfy the PEI requirements was selecte Plant Emergency Operating Procedures
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reviewed with the Master EQ List incloded Containment Temperature Control-(PEI-D-23-2), Reactor Pressure Vessel Control (PEI-B13),
and Radioactivity Release Control (PEI-D17). P& ids for Containment Atmosphere Monitoring System (D23), Recirculation System (B33),
Residual Heat Removal System (E12), Low Pressure Core Spray System
! (E21),Leaka System (G33)ge Detection were reviewed System and compared (E31), and to the Reactor Master Water Cleanup EQ Lis Selected equipment was verified by procedure and drawing to be part of the Perry Plant Equipment Qualification Program.
l During this review the inspectors observed that the Reactor Water Cleanup Leak Detection instrument, 1E31-PT-N075A was not identified on the MEL. This transmitter was identified by the licensee to be located in a mild environment. Recent plant modifications, however, had moved the instrument into the containment and into a harsh environment, but no corresponding change had been instituted by the licensee to add this instrument to the MEL. An identical instrument, 1E31-PT-N075B, was already on the EQ list and the instrument model number in question was verified to be qualified under the new environmental conditions. The plant personnel verified the error and took immediate corrective action to correct the MEL. No further concerns were identifie EQ Maintenance and Surveillance Program The inspectors reviewed specific maintenance, replacement, surveillance tests and inspections necessary to preserve the environmentalqualIficationofEQequipmentidentifiedonthe ME EQ requirements in the licensee s maintenance procedures and EQ binders were reviewed against maintenance records of selected equipment to verify performance of maintenance and surveillance activities at prescribed intervals, including gasket inspection, lubrication, torquing of housing covers and installation of replacement part CFR 50.49, Paragraph (f) requires equipment installed in the plant to be qualified by test or analysi Equipment for which maintenance requirements have not been performed are considered to be unqualified if they are installed in a configuration that has not been tested or analyze CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by and accomplished in accordance with documented procedures. The following equipment was found to be in apparent violation to 10 CFR 50.49, Paragraph (f) because of the licensee's failure to perform appropriate maintenance activities and/or 10 CFR 50, Appendix B, Criterion V because of the licensee's failure to incorporate EQ maintenance requirements into procedure (1) The maintenance section contained in the EQ file for PYC0 temperature elements and the plant maintenance procedures failed to address the need for 'O' ring replacement when the cover housings are removed and replaced on PYC0 temperature elements. The licensee could not provide evidence that these maintenance activities were performed in the plant when require A loose cover found on installed PYC0 temperature element IE31-N001A further confirmed that these maintenance activities were not being performed. (50-440/87013-03a(DRS))
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(2)' The maintenance section contained in the EQ file for WEED thermocouple and the plant maintenance procedures failed to address 'O' ring inspection; application of WEED radiation sealant (Part No. 0102-004-0012) to the 'O' ring, threaded portions of the body, and cover housing; and torquing of the cover housing. The licensee could not provide evidence that these maintenance activities were performed in the plant when required. Loose covers on several WEED thermocouple including AD23N50A and B further confirmed that these activities were not being performe (50-440/87013-03b(DRS)) ;
(3) The licensee's Rosemount transmitter maintenance requirements had failed to address '0' ring replacement each time the cover housing is removed and replaced; application of Dow 55 M silicone grease to the Rosemount body and cover housing threads; and application of Nebula 100 grease to Rosemount housing pipe plugs used to seal unused conduit openings. These maintenance !
requirements were incorporated into Plant Maintenance Procedure ICI-82-2 on May 23, 1987 and June 12, 1987, however, the licensee could not provide evidence that these maintenance activities were performed in the plant prior to these date (50-440/87013-03c(DRS))
(4) The maintenance section contained in the EQ file for MSIV Blower Motors 1E32-C0001, IE32-C002B, and 1E32-C002F requires replacementofthegasketonthemotorjunctionboxeachtime the cover is removed and replaced. This requirement was not part of the licensee's EQ maintenance program. Review of licensee Work Order 86-05531 indicated that the-cover of MSIV Blower Motor IE32-C0001 had been removed, but there was no evidence of replacing the '0"ing'. (50-440/87013-03d(DRS))
(5) Target Rock Solenoid valve qualification documentation (File E-597-000-01) requires replacement of seals and gaskets every time the housing cover is removed. The inspectors noted that this requirement had not been included in the licensee's maintenance progra The licensee performed a review and determined that no Target Rock Solenoid valve had been disassembled since the plant commenced operation. The 1 licensee included this requirement in their maintenance i progra (50-440/87013-03e(DRS))
Subsequent to these findings, the license took immediate corrective l action and reviewed all appropriate equipment maintenance records {
l and activities. The licensee also incorporated the appropriate j maintenance requirements into their EQ maintenance program as well i as performed any appropriate rework necessary to be in conformance j with this program. Pending further review of the licensee's EQ maintenance and surveillance program and the apparent violations identified in Sections 4c(1) through (5), these findings are considered part of one Potentially Enforceable Unresolved Item (50-440/87013-03(a, b, c, d, and e)(DRS)).
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. Plant Procurement of EQ Spare Parts and Replacement Control The inspectors conducted a review of the Perry procedures for the purchase and replacement of EQ parts and equipmen Procurement procedures and documents were found to adequately address appropriate quality and regulatory requirements regarding the environmental qualification of equipment within the scope of 10 CFR 50.49. Checklists were observed to have been used to provide evidence of reviews and approval No violations of NRC requirements were identifie Quality Assurance (QA) and Training Program During this review, the inspectors determined that the licensee had implemented a program to monitor the quality of EQ activities thrc>gh surveillance, audits, and reviews of the records and files for plant modifications and equipment procurement. NRC inspectors found the methodology, results, and followup corrective action relative to QA activities acceptabl The NRC inspectors also reviewed the licensee's staff training program and associated records relative to the performance of EQ activitie The training records indicated that the licensee'had conducted three seminars for training key personnel, including management, operations, and maintenance personnel responsible for EQ activitie The inspectors noted that no formal training program was being implemented by the licensee to address key aspects of 10 CFR 50.49 requirements and that there also was no training for contractor personnel hired during outages. Since various EQ maintenance deficiencies were identified during this inspection, the inspectors were concerned that these deficiencies may have been a result of inadequate EQ training of key personnel. The licensee agreed to enhance their EQ training activities and subsequent to this finding developed a training course (QA-1010) to ensure that appropriate work groups, including subcontractors, received adequate EQ training during the current pre-refuel outage training cycl Pending review of the licensee's training activities, this is an Open Item (50-440/87013-04(DRS)).
5. Detailed Review of Qualification Files The licensee qualified their EQ equipment to the requirements of NUREG-0588 Cat I (10 CFR 50.49, Paragraph K). The inspectors reviewed over 50 equipment qualification files for evidence of the environmental qualification of equipment within the scope of 10 CFR 50.49 and evidence of equipment qualification to IEEE 323/1974. Files were found to include a full description of the equipment; similarity analysis of tested equipment to that installed in the plant; allowed mounting methods and orientation; qualification of interfaces (conduit housing, seal, etc.,);
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I evaluation of aging effects on equipment; description of test sequence and methodology; environmental conditions for the equipment during an accident; qualification for submergence of applicable equipment; resolution of test anomalies; and maintenance / surveillance criteria for the preservation of the qualified status of equipmen The inspectors selectively reviewed the above areas as applicable, including special reviews for the required duration of operability of equipment; licensee evaluation of tested materials and configurations l relative to actual plant installations; adequacy of test conditions; aging calculations for qualified life and replacement intervals; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy of equipment and interfaces during an accident; and licensee evaluations of discrepancies identified in IE Notices and Bulletin EQ files were reviewed for electrical cables, cable splices, terminations, terminal blocks, electric motors, solenoid valves, electrical penetrations, seals, lubricants, transmitters, temperature elements, radiation monitors, control and position switches, switchgear, control panels, and miscellaneous electrical device The inspectors identified various deficiencies in the EQ documentation contained in the licensee's EQ files. Details are noted below: The following files were found to contain inadequate documentation to qualify their respective 10 CFR 50.49 equipment. In each case, subsequent to the NRC finding, the licensee could provide new reports or evaluations to demonstrate that the equipment was qualifiable for accident conditions at the Perry Statio (1) Valcor Solenoid Operated Valves (S0Vs)
The equipment qualification file contained Test Report No. NEDC-30735 to demonstrate the qualification of Valcor SOVs for service at Perry. The inspectors noted that the thermal aging exposure of the Valcor S0Vs was performed using nitrogen as the process fluid. The S0Vs at the Perry plant are used in the instrument air system. The licensee did not provide any correlation between the degradation of the organic materials used in the 50V when aged in air as opposed to aging in a nitrogen environmen The licensee took immediate corrective action and during the course of the inspection provided additional information on the activation energies used to calculate the qualified life of the Valcor S0Vs, and performed additional aging calculations to account for the difference between aging in air and nitroge The equipment qualification file was revised during the inspection to calculate a new shorter qualified lif The licensee incorporated this new qualified life in their maintenance schedules for replacing the equipmen The
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licensee was informed that the above finding was considered f), failure anapparentviolationof10CFR50.49, to qualify equipment by test or analysi Paragraph (50-440 (/87013-05a(DRS))
(2) ASCO Solenoid Valves, File E-641-001-01, E-641-000-01, l E-607-001-01 This file was used to demonstrate the qualification. of ASCO Model No. NP8316 S0Vs used at Perry. The qualification documentation consisted of ASCO Test Report AQR-67368. The licensee's SCEW sheet stated that the S0Vs were qualified for a 40 year service life with no maintenance required. The licensee provided calculations which stated that the aging of the 50V was evaluated using the thermal aging reported in the test program combined with Jortions of the DBE test exposure.
, The. licensee was informed tlat the use of the DBE exposure to l simulate thermal aging is not accepted where equipment items are required to be qualified for an accident environment since the thermal aging must be performed prior to the accident exposur In addition to the above deficiency, the inspectors noted that during performance of testing on ASCO Models NP8316 and 8320, reported in AQR-67368, nitrogen was used as the process fluid for the thermal aging simulation. The difference between thermal aging in air and thermal aging in nitrogen had not been addressed in the fil The licensee performed additional calculations during the course of the inspection to correct the above two deficiencies noted in the thermal aging analysis, and took immediate corrective action by establishing a new shorter qualified life, as well as updating their maintenance schedules for the replacement of this equipmen The licensee was informed that this finding was an apparent violation of 10 CFR 50.49, Paragraph (f), failure to qualify equipment by test or analysis. (50-440/87013-05b(DRS))
(3) PYC0 Temperature Element, File E-301-C03-01
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The file provided the licensee's basis for considering PYC0
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Model No. 102-9039-11 temperature elements qualified for service at Perry. Review of the GE test report, NEDC-30169 revealed that the housing cover of the device had been torqued to 50 ft-lbs after completion of the aging, and just rior to the LOCA test. The qualification test procedure states:
p'Significant repairs shall not be made to the test specimen (s)
after the start of the test sequence." The inspectors determined that the torquing of the housing cover was a significant repair made after the start of the test, and that the subsequent test results were therefore invali ______ ______ ____-______ ____ _ _ _ -
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. Subsequent to this finding, the licensee submitted a ne evaluation to demonstrate that the PYC0 temperature elements were qualifiable without being sealed. This evaluation was based on a Wyle Lab Test Report No. 145C3224, dated November 11, 198 In this test Wyle tested four-PYC0. thermocouple whose conduit connections were unsealed and terminated inside the-LOCA chamber. No failure was recorded. The licensee also stated that since the PYC0 thermocouple were voltage devices, effects of leakage resistance would be negligibl (50-440/87013-05c(DRS))
(4) ITT General Controls Electrohydraulic Actuator, E File E-245-00-001 This. file contained documentation relative to the qualifications of two electrohydraulic actuators located inside the containmen The specified environment for the actuators had a peak temperature of 180 F and 10.3 psig. Qualification, however, was based upon ITT Reports 734-79-012 and 721.77.095 for actuators outside the containment. The tested actuators experienced a peak pressure of only 0.3.psig during the test, much lower than the 10.3 psig postulated to occur for the Perry station actuators under accident conditions. The licensee performed a new evaluation and stated that if the actuators failed during an accident, they would fail to an accident safe position; would not be required to stroke again during or after the accident; and would not compromise the operation of any associated equipment important to the safety of the plan The licensee agreed to update their files to reflect this new basis for qualification of the actuator The licensee was informed that the above finding was an apparent violation of 10 CFR 50.49, Paragraph (f), failure to qualify equipment important to the safety of the plant by test and/or analysis. (50-440/87013-05d(DRS))
(5) Terminal Brards in Limitorque Actuators, File No. E-568-000-04 Deficiencies in this file could not be justified by the licensee during the course of this inspection. This file contained documentation relative to the qualification of Marathon 300, Marathon 1600, Buchanan 200 and General Electric EB-5 terminal boards installed in Limitorque Actuator Qualification was based upon Limitorque Report B0119 which addresses the testing of all the above Limitorque supplied terminal boards for use inside the containment. In this test, one sample of each of the above terminal boards was mounted in the test chamber ,
along with one Limitorque Actuator. A Marathon 300 terminal board was used to power the Limitorque Actuator motors. This terminal board was subjected to an appropriate LOCA environment and shown to adequately transmit power to the subject motor at selected periods throughout the LOCA portion of the testin i
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Resistance readings of the Marathon 300 terminal board (terminal to terminal and terminal to ground) were taken by disconnecting the motor immediately after energization. The lowest reading during this test for the Marathon 300 terminal board was 900 ohm Since the motor performed adequately with the 900 ohm measured insulation resistance, this IR value was established as the acceptance criteria for the remaining terminal boards in the tes The IR readings were taker using a Biddle 21159 megge Inspection of this megger revealed that readings in the 900 ohm range could only. have been read on the megger's " ohms" scale. Consequently, the applied output voltage to the terminal boarc would have been as low as 6 volts. The other tested boards exhibited IR readings better than 900 ohms, however, since these IR values were also obtained at 6 volts they did not reflect the stresses the terminals would be subjected to at 480 vcSts or 120 volt The inspectors concluded that the ability of the Marathon 1600, Buchanan 200 and GE-EB-E type terminal blocks to adequately transmit 480 or 120 voli powersto motor or control circuits during an accident had not been demonstrated by the Limitorque Report B0119. The qualification of the Marathon 300 terminal board to adequately transmit power to a 480 V Limitorque motor during an accident was demonstrated, however, its suitability for use with 120 V control circuits was considered indeterminate.
l The licensee took immediate corrective ahtion and replaced the l terminal blocks in question. Subsequent to the inspection, the licensee provided new evidence to demonstrate'the.t the terminal l blocks in question were qualifiable by test and analysis. This l evidence, however, was not contained in the licensee's EQ files y during the site inspectio (50-440/87013-05e(DRS)). i Pendingfurtherreviewofthelicensee's'EQprogramandtheapparent violations identified in Sections Sa(1) through (5), these findings are considered part of one Potentially Enforceable / Unresolved Item
- (50-440/87013-05(a, b, c, d, and c)(DRS)).
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' Seitz Solenoid Valves, File E-301-502-01 4
The file provides the licensee's basis for qualification of Eugen Seitz A.G. solenoid valves used for the automatic depressurization system (ADS). The qualification was based upon GE Test Report NEDC-31014. A complete ADS valve was included in the test program which contained two solenoid valves similar to the configuration found in the plant. The initial test program was marred by the failure of seven solenoid coils during the loss-of-coolant-accident (LOCA) exposure. Re-design of the solenoid coil enclosure was performed and the ADS valve was reteste During
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the retesting, a'nother solenoid valve failed. This failure was attribuwd to moisture intrusion by the testiag organi:atio The test organization (General Electric) had a failure analysis performed on the' failed solenoid. The failure analysis provided the following concluQon: "No definite / obvious evidence of moisture could he found and the test report (Solenoid C<til LOCA failure i'; investigation, Memo Report'CI-1135 by General Electric Turbine
.,,
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T"chnology Lat'oratoryt Scher,ectedy, New York, by W. R. Schultz, Jr.)
.sdggested ar: indeterminate lause of solenoid failure." The licensee
, was advised that the"EITZ valve has not qualified based on J, ,
ir3dequate information in their EQ file. The licensee then provided an additional test report (which the licensee stated was available
, onsitr6 'to demonstrate the adequacy of the solenoid coil for use at
, Perr The licensee's file will te re. vised to include the additional test repor No further conc yns were identifie Pressure Control Inc. , Pqs, pure Switch, EQ Fi,le EM01-M2-00 The file contained GeaeralMectr-ic Test Report NEDC-30739 and a
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states (nt~that these'switchef were qualified ta the requirements of 10 CFR 50.4 Tett parameters enveloped the specified parameters by an adequate margin with the exception of the operating time. The required operating time is 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, however, the file showed a test operating time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with no analys13 extending the operating time to the rm:Jired 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This was brougnt to the attention of the licensee a00 prsvided a riew calculation exunding the operating time to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> by acelysis. The licensee stayed that the
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calculation would be mad *
part of the EQ file. No further concerns were identifie .-
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- Lubricants, File E-301-510-00 .
A review of the Perry Power Plant Lubrication Manual and Perry
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,,( Procedure NEI-0803, Rev. O, Evaluation of Lubricant Application,
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was performed in order to verify qualification of lubricants used in EQ designated equipment. Selected files were reviewed to verify if the lubricant identified in the EQ file was the lubricant u. sed during the qualification tes. tin '
I The intpectors observed thct the licensee had s ostituted the qualified Amoco Rykra Premium Grease No. 2 used in General Electric i (GE) motors, with Mobii @ ease 28. The EQ fO c contained a letter from GE quoti,ng testr the" ualified Mcbil Grease 28, ito m er, no test reporto were includa .r the fi The licenree agr?cd to suppibrient their files with t!w eppopriate reports. Pending further review'of the upgraded file 41s .s considered an Open Ite (50-4404/013-06(DRS)j i i Limito'eque Motor Actuators, EQ File E-568-000-00, This file contained documentation relative to the m,alification of a number of motor actuators with AC motors, located inside
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s V i the containment. Qualification was based upon Limitorque Test W N' "
u Report 6000376A which was found to envelope the calculated l[(' + temperature, urassure, and radiation at Perr %~s o
pf; m The inspectors observed that the system component evaluation 14' '
worksheet (SCEW) in this file %entified the actuators to be subject to submergence during certain design basis events. Upon further
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$" review the inspectors determined twelve EQ designated Limitorque 6 actuators would be subject to submergence for five seconds during a postulated pool swell under accident conditions. No testing or s
f*i ,
analysis was contained in the file to justify the qualification of N. . .
these 6ctuators for submergence.
3 Subsequent to this finding, the licensee provided new evaluations p'* (PYGAL /CEI-1911) dated July 27, 1987- to demonstrate that the actuators would not be subject to submergence, in that the motor and switch o ,
internals were adequately encased. The licensee stated that the
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actuators inrquestion would be r,ubject to a brief splash effect, butduetei,bqdesignandconfigurationoftheTdrainsandconduit h,< \ connectigr t would occu$ r.. bm.sentially no of ever, i', view leakage of water the NRC concerns intolicensee the actuators installed
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seals on i Q the con & t connections to the actuators prior to startu *
< No further concernt were identified in regard to the submergence
'of t%se actuator . Plant Physical Inspection -
The NRC inspectors selected over 50 items nn the MEL for examination in the plant. The EQ file of each item N4 been reviewed, and information regarding the location, manufacturer, model/ serial number, mounting, orientation, environment, and interfaces had been noted. The inspectors
- examined the selected items in the field, as accessible, and verified that the method of installation of each. item was not'in conflict with its environmental: qualificatio Specific areas reviewed included traceability o9 fnstalled items of EQ files, ambient environmental conditions, quBification of interfaces (connectors, wires, seals, insulation, labricants, etc.), evidence of significant temperature rise from procw s, drainage, mounting methods, physical conditions, and housekeepirh. Seyeral items examined in the field during this walkdown did not meet their appropriate EQ installation requirement :
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10 CFR 50.49, Paragra'ph (f) requires all EQ designated equipment to be
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qualified by test or analysis. Equipment installed in a configuration other than that qualified by test or analysis is considered unqualifie The~ following equipment was found instally'in an unqualified conMgeratio 'Ta'thet Rock Solenoid Valve (SOV), Tyfo.1E12-F075B
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- " DUring inspection of Target Rcck Solerdd Valve Model 77JJ-006 SOV, three (3) bolts were noted missing from the solenoid enclosur ,
,% No work was being performed on the 50V at the time and the S0V was b -
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!z not tagged out of service. The qualification of the 50V required ,
-a ll eight (8) of the solenoid enclosure screws to be in place; l consequently, the 50V was determined by the inspectors to be in j an unqualified configuratio The licensee took immediate corrective action and performed a 100% ,
walkdown of all Target Rock Solenoid Valves installed in a harsh l environment. Four other Target Rock Valves were found with missing ,
bolts. All deficiencies were reworked. The licensee also performed amechanicaltesttodetermineifthemissingboltswouldhave caused a sufficient gap between the actuator s gasket and flange to compromise their sealing function. This test did not meet any standard EQ requirements nor did it simulate aging or accident conditions, however, it provided some information to suggest that even without the three bolts, the gasket may have remained significantly depressed. The licensee was informed that the above Target Rock Solenoid Valve was unqualified based on inadequate documentation to qualify the installed configuratio (50-440/87013-07a(DRS)) Limitorque Actuator 1P51-F652T Drain The above actuator is located inside the containment. The inspectors noted that the actuator motor was oriented such that it was at a higher elevation than the actuator housing. A T-drain, however, was found installed on the elevated actuator motor casing rather than at the lowest point of the actuator housing. The inspectors were concerned that in the event of a HELB accident, fluid would not be drained and would accumulate in the actuator housing and possibly short out the electrical internals. The licensee took immediate corrective action and installed a proper drai The licensee stated that the actuator was not subject to saturated steam conditions, and that-the conduit connection to the actuator precludes any runoff due to a 90 bend. The licensee took immediate corrective action and examined all other Limitorque actuators located in a harsh environment and reported that all T drain connections were found properly located (CEI response PY-CIE-01E-0282L, dated July 27, 1987). The inspector informed the licensee that Limitorque Actuator IP51-F652 was unqualified as found for accident conditions, based on inadequate documentation to qualify the installed configuration. (50-440/87013-07b(DRS)) Limitorque Actuator IP51-F652 - Shipping Cap During examination of Limitorque Actuator IP51-F652, the inspectors observed that the plastic shippiryg cap on the grease relief valve had not been removed. This configuration had not been tested in the licensee's EQ documentation. The inspectors were concerned that the shipping cap could prevent a pressure buildup inside the actuator from being relieved under accident conditions. The licensee performed
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an immediate walkdown of other actuators and found thirty one other shipping caps in similar configurations. All caps were remove The inspectors considered these actuators to be unqualified as found L
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for accident conditions based on inadequate documentation to qualify the installed configuratio (50-440/87013-07c(DRS)) Limitorque Actuator Deflector Plates During review of NRC concerns regarding the postulated submergence of 12 Limitorque Actuators-(discussed in Section 5f of this report), the licensee discovered and reported that they had failed to install deflector plates on the actuators. These deflectors were designed to direct suppression pool hydrodynamic impact load from the operators during the postulated suppression pool swell under accident conditions. The licensee took immediate corrective action and installed the deflectors prior to startup. The licensee also provided calculations to demonstrate that the actuators would have performed their safety function under the postulated hydraulic impact during an accident. The inspectors reviewed the following calculations:
VQ-2, " Seismic Qualification of Actuator to Valve Adapter for Seven Valves (Contromatics)," Revision 01, January 7, 198 D43-6, " Pool Swell Protectors for M0V Actuators - P43F0355, F0400, F0410," Revision 0, November 14, 198 EA-0058, " Valve Adapter Plate Subject to Pool Swell," Revision 0, August 6, 198 The results of calculation 043-6 indicated that in order for the MOV actuator attachment bolts to meet AISC allowable stresses, some type of support would be required. This requirement came from consideration of drag forces due to pool swell loading. Since the deflectors were not installed as directed by the D43-6 calculation, a third calculation EA-0058 was performed to determine if catastrophic failure of the attachment bolts would occur. The licensee concluded that although the bolts in question exceeded their design stress limit, they had not exceeded the minimum yield strength of the material; and that although the bolts were not qualified to the conservative margins required by AISC code the valve actuators could have performed their safety functio (50-440/87013-07d(DRS))
e. WEED Resistance Temperature Detector, Series 611 During examination of WEED RTDs, the inspectors observed that six RTDs had loose housing covers thereby compromising the sealing of the terminal board and the bare wires from a postulated accident environment. Subsequent to this finding, the licensee performed a walkdown of all EQ WEED RTDs and performed appropriate rework on all identified discrepancie (50-440/87013-07e(i>RS))
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! . PYC0 Thermocouple 1E31N001A During examination of the above PYC0 thermocouple in the plant, the inspectors observed that the housing cover was loose and could be rotated by hand. The PYC0 EQ documentation requires a 50 foot lb. torque on these housing covers. The licensee performed an immediate walkdown of all EQ PYC0's and found several other loose PYC0 housing covers. Rework of all the PYC0 thermocouple was accomplished under Work Order Nos. 87-06357, 87-06358, and 87-06359 prior to the startup of the plant. (50-440/87013-07f(DRS))
Pending further review of the licensee's EQ program and the apparent violations identified in Sections 6a, b, c, d, e, / Unresolved Itemand f, these findings Enforceable are considered part of one Potentially(DRS)).
(50-440/87013-07(a,b,c,d,e,andf) Enforcement Conference On November 10, 1987, an Enforcement Conference was held in Region III between the licensee and the NRC to discuss the identified EQ program deficiencies and the licensee's proposed corrective actions. During the conference the licensee agreed with the inspection findings and discussed actionsbeingtakentoresolvethefindings. Attached to this report is the licensee s presentation made at the conferenc . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during this inspection are discussed in Paragraphs 2, 3, 4e, and 5 . Potentially Enforceable / Unresolved Item An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a_ violation. Potentially Enforceable / Unresolved Items are unresolved items, which if ascertained to be a violation may be followed up with enforcement action in accordance with NRC enforcement guidance on environmental qualification. Potentially Enforceable / Unresolved Items are discussed in Paragraphs 4c, Sa, and . Exit Interview The Region III inspectors met with the licensee's representatives (denoted under Paragraph 1) during an interim exit on July 17, 1987, and discussed their findings during an enforcement conference at the conclusion of the inspection on November 10, 198 The inspectors summarized the purpose and findings of the inspection and the licensee acknowledged this information. The licensee did not identify any documents / processes reviewed during the inspection as proprietar _ _ _ _ _ _ _ _ _ _ _ _
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. w-AGENDA
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l Utility introduction Al Kaplan issue Analysis Ken Matheny I
i Corrective Actions Bart Walrath Summary Al Kaplan
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ISSUE ANALYSIS Failure to implement maintenance practices e Identified NRC concerns:
"O" ring and gasket replacement and torquing of covers e Response:
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- Demonstrated operability on the
"as found" condition
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- Immediate corrective action l
e Utility Conclusion:
- Operability not impacted
- Program has always contained input to maintenance program for specific E.Q. requirement Program enhancements are being implemented to address routine vendor manual practice _ _
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1 Inadequate testing / analysis within l E.Q. files i
L e Identified NRC concerns: 1
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- Use of Thermal Gravimetric
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Analysis
- Use of N2 in testing-Terminal block insulation resistance
. 1 e Responses:
- Demonstrated operability on the
" as - found " condition ~
-Immediately corrective action
- Utility Conclusion:
- Operability not impacted-Generic industry concern Will address with NUGEQ at future meetings
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i Failure to install equipment per configuration e identified NRC concerns:
- Missing bolts
- T - drain-Grease relief shipping cap
- Loose caps temperature elements
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- Response:
- Demonstrated operability on the
"as -found " conditions -
-Immediate corrective action a Utility Conclusion:
- Operability not impacted l - Program enhancements implemented to prevent recurrence l
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J CORRECTIVE ACTIONS
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e MAINTENANCE E.Q. ACTIVITIES l
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Definition of E.Q. Requirements 1
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Work Instructions
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Computerized Maintenance Information System
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E.Q. Report / Vendor Manual Review Program Enhancements
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E.Q. Procedures
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Work Procedures
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QA Procedures
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Training
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e E.Q. FILE ADEQUACY
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Review of E.Q. Files
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Contracting of specialized consultant e INSTA,LLED CONFIGURATION
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