ML16161A980
| ML16161A980 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/17/1988 |
| From: | Conlon T, Ruff A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16161A981 | List: |
| References | |
| 50-269-88-03, 50-269-88-3, 50-270-88-03, 50-270-88-3, 50-287-88-03, 50-287-88-3, NUDOCS 8806080129 | |
| Download: ML16161A980 (23) | |
See also: IR 05000269/1988003
Text
REGO4
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-269/88-03, 50-270/88-03, and 50-287/88-03
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270,
License Nos.: DPR-38, DPR-47, and
and 50-287
Facility Name:
Oconee 1, 2, and 3
Inspection Conducted:
February 22-26, 1988
Inspectors:
Z_27
A. Ruff, Team Leader
D7ate Signed
Team members and participating Inspectors:
J. Jacobson, NRR
B. Levis, RII
C. Paulk, RII
C. Smith, RH
D. Brosseau, Sandia National Laboratories
W. Carpenter, Idaho National Engineering Laboratory (INEL)
J.
Stoffel, INEL
Approved by:
-7
/
/7/
o
T. !Conlon, Chief
IDate/igned
Plant System Section
Division of Reactor Safety
SUMMARY
Scope:
This special announced inspection was in the areas of Environmental
Qualification (EQ) of electrical equipment. It included a review of Duke Power
Company's
(DPC)
implementation of requirements of 10 CFR 50.49 for Oconee
Nuclear Station and an inspection of EQ electrical equipment.
The initial
Environmental Qualification of electrical equipment for Oconee Nuclear Station
was required under IEB 79-018 (DOR Guidelines).
The program was evaluated by an examination of DPC qualifcation documentation
files, review of procedures for controlling the EQ effort, and verification
of adequacy and accuracy of the program for maintaining the qualified status of
the applicable equipment at Oconee.
8806080129 880525
ADOCK 05000269
Q
2
Based on the inspection findings, which are discussed in the report,
the
inspection team determined that DPC has implemented a program to meet the
requirements of 10 CFR 50.49 for Oconee although some deficiencies were
identified.
Results:
Four violations were identified:
(1) Inadequate Maintenance
Procedures, Section 6; (2) Reactor Building Level Transmitter's Oil Level Not at
Top of Instrument Termination Junction Box, Section 13.c.(3); (3) Similarity
Analysis for Installed Cable to Tested Vendor Specimens Not Established
in EQ Files, Section 13.c.(9); and (4) Similarity Analysis for Qualification of
Installed Configuration for High Range Radiation Monitors Not Established,
Section 13.c.(10).
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- R. L. Dobson, Design Engineering (DE)/Electrical (E)
- T. L. Edwards, DE/Mechanical Nuclear (MN)
- Bill Foster, Nuclear Production Department (NPD), Oconee Nuclear
Station (ONS)
- Sherry Grier, NPD/General Office (GO)
- Paul Guill, NPD/Licensing
- Craig Harlin, Compliance Engineer, Oconee
- T. P. Harral, DE/E
- Don Havice, ONS, Instrumentation and Electrical (I&E)
- T. L. Jamerson, ONS/Maintenance Service
- Richard Ledford, ONS/Quality Assurance
(QA)
- Clay Little, NPD/GO
- Bill McAlister, NPD-ONS-I&E
- Ted McMeekin, DE/E
- Fred Owens, Regulatory Compliance, Oconee
- R. G. Sokul, DE/E
- R. J. Smith, DE/E
- P. M. Street, ONS/Maintenance Services
- Al Sweney, NPD/ONS/I&E,
- M. S. Tuckman, Station Manager
- Mike Whisnant, PTS/I&E Production Training Services/Instrumentation
Electrical
- S. H. Walker, DE
Other
licensee employees
contacted included craftsmen,
engineers,
technicians, operators,
mechanics,
security force members,
and office
personnel.
NRC Personnel and Resident Inspectors
- T. Peebles, Reactor Project Section Chief, Region II
- P. Skinner, Senior Resident Inspector
- L. Wert, Resident Inspector
- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on
February 22, 1988,
with those persons indicated in paragraph 1 above.
The inspectors
described the areas inspected and discussed in detail the inspection
2
findings.
No dissenting comments were received from the licensee except
with regard to the similarity violation for cable files indicated below.
The licensee considered that their Environmental Qualification Files were
adequate in these areas.
The following new items were identified during
this inspection:
a.
Violation 50-269,270,287/88-03-01, Inadequate Maintenance Procedures,
Section 6.
b. Unresolved
Item
50-269,270,287/88-03-02,
Operability Evaluation
Concerning Problem Investigation Report 87-0231, Section 12.
c. Violation 50-269,270,287/88-03-03,
Reactor Building Level Trans
mitter's Oil Level Not at Top of Instrument Termination Junction Box,
Section 13.c.(3).
d.
Violation 50-269,270,287/88-03-04, Similarity Analysis for Installed
Cable to Tested Vendor Specimens Not Established in EQ Files,
Section 13.c.(9).
e.
Violation 50-269,270,287/88-03-05, Similarity Analysis for Qualifica
tion of Installed Configuration for High Range Radiation Monitors Not
Established in EQ File, Section 13.c.(10).
3. Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Unresolved Items
Unresolved items are matters about which more information is required
to determine whether they are acceptable or may involve violations or
deviations.
One unresolved item identified during this inspection is
discussed in Section 12.
5.
Electrical
Equipment
Environmental
Qualifications
(EQ)
Program and
Procedures Review
The inspectors reviewed procedures that are used to implement the require
ments of 10 CFR 50.49.
Individual procedures and instruction, are
discussed in the report. Duke Power Company's Environmental Qualification
Documentation Packages
(EQDP)
are prepared and controlled by Design
Engineering in accordance with Section 11.4.5, of their Design Engineering
Department Manual,
and Duke Power Company's Response to IE Bulletin 79-01B.
The management and staff at Oconee have been actively involved in the EQ
program.
In an effort to stay abreast of the changing trends in the
industry,
Oconee has taken additional actions to improve and enhance
their program.
The EQ program as it exists meets the requirements of
3
6. Maintenance Program
EQ Maintenance requirements for the Oconee Nuclear Station are prescribed
in the Equipment Qualification Reference Index (EQRI).
The EQRI is
supposed to call out all required maintenance to ensure equipment remains
in a qualified condition.
It is from
these requirements that the
procedure writers are to develop the procedures.
Although the requirements are in the EQRI,
some items have been missed.
The omissions were due to either a misinterpretation of how to use the
EQRI and its references; or, the sheer mass of documents that must be
reviewed and interpreted; or, a lack of meaningful communication between
Design Engineering and the site; or, a combination of all of the above.
Examples of maintenance not addressed properly in procedures are the
missing requirement to ensure proper oil level in the Gem/Delaval Reactor
Building Level Switches; failure to check for T-drains and grease reliefs
on Limitorque actuators; and exceeding lubrication frequencies.
These
are examples of one violation, identified as 50-269,270,287/88-03-01,
Inadequate Maintenance Procedures.
Further discussion on the level
switches is in Section 13.c.(3); and on the Limitorque actuators in Section
13.c.(4).
The maintenance requirement for lubricating the Westinghouse High Pressure
Injection Pump in the EQRI is not spelled out. In the reference material,
the vendor states that in order to assure the equipment remains qualified
it is assumed that the vendor recommended maintenance program is being
met. This is due to the fact that the motor was
aged and irradiated
without any lubricants and the LOCA test was with new lubricant.
The
vendor recommended a six month oil replacement frequency to ensure the
motor is in "as new conditions".
The licensee's operations group was replacing the lubricant on an annual
basis.
This could not be verified prior to early 1986 due to missing
records.
An evaluation of the lubricant was in the qualification package
to show a qualified life for irradiation of 40 years.
Further evaluation
by the licensee showed that the motor's qualifications had not been
degraded while performing an annual replacement.
The licensee committed
to placing this information in the qualification package and to allow for
a maximum of nine months between replacement.
The missing lubrication documents mentioned above were noted by a licensee
audit 85-20, by NRC Inspection Report 50-269,270,287/86-16 and by licensee
audit NP 87-20(ON). The lubrication program was taken over by maintenance
around October 1987 and equipment has been or is scheduled to be lubri
cated under the new program.
While reviewing work history on Limitorque actuators, it was noted that
grease reliefs and T-drains had been installed during the week preceding
the inspection. This work was being performed due to a Problem Investiga
tion Report (PIR) that was submitted in October 1987 but that was never
4
processed.
No explanation was given for the PIR not being processed,
however, it was re-issued during the inspection.
The problem of missing
grease reliefs and T-drains was discovered by an employee familiar with
limitorques who was hired during 1987.
The employee was reviewing
procedures and noticed there were no checks for T-drains or grease
reliefs. The limitorque procedures are undergoing review and revisions.
In order to have a better interface between the EQRI and the maintenance
procedures, the licensee committed to an enhancement program to review EQ
maintenance procedures to ensure all requirements have been properly
translated from the EQRI to the procedures.
Overall the EQ maintenance program is acceptable.
It is changing and
improving as the overall maintenance program is being upgraded as a
result of prior inspections.
Procedure changes and transfer of
responsibilities have taken place that should improve the program;
however, further evaluation is required to determined the extent of the
improvement.
7. IE Information Notices (IENs) and Bulletins (IEBs)
The program for handling IENs and IEBs at Oconee is the same as that at
the Catawba Nuclear Station discussed in report 50-413, 414/88-07 and is
acceptable.
The responsibility for implementing this program was turned
over to the Operation Experience Management and Analysis Section (OEMA)
in July 1987.
Since that time, there has been only one notice issued
relating to EQ.
OEMA received IEN 87-66 in December 1987, and evaluated it per Directive
No. 4.8.1(s).
The recommended action was to route to Design Engineering
and Maintenance - Parts/Materials Inventory for information only.
It
was then transmitted via a Report Transmittal Form as Problem Awareness
Material which is "material that is disseminated for information only and
consists of those items that are "nice to know",
but which are not an
immediate concern from the standpoints of nuclear safety, economic risk,
and generating reliability."
The notice should have been transmitted as
Problem Avoidance Material with a reponse required. When the transmittal
was received by Design Engineering, an engineer recognized the error and
had a proper evaluation of the notice performed and documented.
The root cause of this problem is the lack of training in
EQ to
people who are responsible for reviewing material that is potentially
related to EQ.
EQ Personnel Training is discussed in Section 12 of this
report.
IENs reviewed included:
78-04, 79-28, 79-03, 84-44 and 84-78.
Other
notices reviewed will be covered in other sections of this report.
5
8. EQ Master List
The original list of equipment requiring environmental qualification was
submitted to NRC by Duke Power Company in their IEB 79-0IB response for
Oconee Station.
The systems and components listed in this response were
identified as those subjected to the environmental conditions resulting
from a postulated LOCA or HELB inside the Reactor Building or a HELB
outside the Reactor Building and required to function to mitigate the
consequences of those accidents.
Other systems and components which were
subsequently considered and evaluated for harsh environmental conditions
included those necessary for safe shutdown and those systems and compo
nents required to be installed as a result of Three Mile Island.
Since the original submittal,
the Design Engineering organization had
developed the Equipment Qualification Reference Index (EQRI),
document
OLT-2786-03.01, with latest revision dated May 8, 1987.
This document
serves as the interface between the design organization and the station
personnel and identifies the specific components which are required
to be environmentally qualified along with the necessary procurement,
installation, maintenance and surveillance requirements which ensure that
qualification will be maintained.
Tabs B through S of the EQRI contain
the specific equipment identification numbers of the EQ equipment and it
is this list that the design engineering organization considers to be
its masters list of EQ equipment.
Since the EQRI is a design document,
additions and deletions to the master list are controlled in accordance
with the normal design control process.
To assess the completeness of the master list the Safety Injection System
was reviewed.
Specifically, the following documents were reviewed to
determine the system components, such
as,
Motor Operated Valves (MOVs),
motors, and instrumentation that are required to
bring the plant to a safe shutdown condition.
OFD-101A-2.1 R8
OFD-101A-2.2 R4
OFD-101A-2.3 R2
OFD-101A-2.4 R9
OFD-101A-2.5 R5
OFD-102A-2.1 R3
OFD-102A-2.2 R4
OFD-102A-2.3 RI
Emergency Operating Procedure EP/1/A/1800/01 R7
All components noted as requiring qualification were included in the
appropriate section of the EQRI.
9.
EQ Modification Program
The Nuclear Station Modification Manual,
Revisions 5, is the controlling
procedure for the preparation and implementation of Design Change Packages
(DCPs) prepared by either the corporate engineering office or the site
6
based Project Services group.
Design controls have been specified that
ensure applicable regulatory requirements and design bases are correctly
translated into specification, drawings, procedures and instructions to
form
DCPs.
Considerations of the environmental qualification require
ments of equipment are included as design inputs.
Oconee Nuclear Station EQ Criteria Manual, Volume 1, Revision 10, provides
specific guidance to the responsible engineer regarding environmental
parameters applicable to buildings or rooms.
Section 5.0 of this manual
describes the environmental conditions for normal operation and post
accident operation for various locations within the plant.
These
environmental conditions are used as the basis for generation of procure
ment specification for equipment within the scope of a nuclear station
modification. Additionally, Design Engineering Department Manual Section
11.4.5,
Environmental Qualification of Electrical Equipment,
assigns
responsibilities and describes the procedure for determining the environ
mental qualification requirement of electrical equipment.
The design
process further provides for the update of vendor technical manual and
shop drawings upon implementation of a nuclear station modification.
Maintenance of the environmental qualification status of equipment
installed via a design change is assured through update of the Environ
mental Qualification Reference Index (EQRI) which specifies qualification
activity requirements, e.g., maintenance and procurement.
A review of nuclear station modification packages NSM #ON-1294, revision 1
and NSM #0N-2304, revision 1; and Exempt Change OE-931 was performed.
Because of the inadequate implementation of NSM
- ON-1294,
licensee
management has enhanced the design-engineering program in the following
ways.
Project Services Manual Section 4.6, Nuclear Station Modification,
has been revised to more clearly specify the requirements for review of
installed design change packages. Additionally, Section 5.1, Design and
Review of Modifications,
has been revised to include requirements for
referencing EQ related information on the engineering instructions for
installed design change packages.
No
EQ related deficiencies were
identified in the design-engineering program.
10.
EQ Equipment Replacement and Spare Parts Procurement
Oconee Nuclear Station Quality Standards Manual for Structures, Systems
and Components,
Section 3.6,
establishes the quality standard and
specifies the criteria to be used for environmentally qualified electrical
components.
Equipment, parts or components within the scope of 10 CFR
50.49 (b)(1), (b)(2),or (b)(3) are classified as QA Condition 1.
Administrative controls for the procurement of new equipment, identical
replacement parts and components, and upgraded equipment are specified in
the EQRI, procurement section.
7
Administrative controls applicable to the procurement process are
specified in Station Directive 2.3.1, Material Requisition. Requirements
have been established for the EQ Coordinator to review requisitions
prepared for procurement of environmentally qualified equipment.
Addi
tional requirements have also been established for a Qualified Reviewer to
verify QA Condition level and storage protection. EQ equipment are procured
as QA Condition 1 with the requirements of 10 CFR 21 imposed.
These
administrative controls ensure that applicable quality and technical
requirements are specified for procurement activities.
Technical requirements, for new equipment/components to be added to the
plant, are defined during the design engineering-process.
Environmental
parameters, as determined by equipment location in the plant, are provided
by Oconee Environmental Qualification
Criteria Manual.
These parameters
are delineated in procurement specifications with the requirements that
the equipment is to be qualified to IEEE 323-1974.
Spare
items, i.e.,
equipment/components/parts,
are procured to the
original or upgraded specification/requisition requirements.
An annual
spare parts evaluation is performed to determine the need for replace
ment equipment. Upon determination of a need for replacement equipment, a
plan is formulated and documented on the "Spares Evaluation Form".
Replacement equipment is procured in accordance with the requirements
of 10 CFR 50.49(1).
Sound reasons to the contrary for not up-grading
equipment qualification are documented on the "Equipment
Replacement
Summary" form. Upgraded procurement are performed within the controls of
the nuclear station
modification program and are processed similarly to
new equipment/component procurements.
The procurement and use of commercial grade items for use in EQ applica
tions is controlled by the nuclear station modification program. Specific
guidance on the procurement of commercial grade items for use in QA
Condition 1 applications is provided in Design Engineering Department
Manual Section 11.4.1, "Nuclear Station Commercial Grade Evaluation". A
Commercial Grade Items List consisting of a computer data base with three
categories of commercial grade items has been established by licensee
management. Responsibilities have been assigned to the Design-Engineering
organization for performing commercial grade item evaluations. Additional
requirements for conditioning prior to use, including restrictions in use
of the various categories, have been established.
A review of six purchase orders for various equipment types was performed.
No EQ related deficiencies were identified during this review.
11.
EQ Personnel Training
The Employee Training, Qualification, and Safety (ETQS) program provides
for training of craft personnel in specific tasks.
The program requires
that each craftsman be trained to a procedure prior to performing a task
3
that is implemented by use of that procedure. The ETQSs program does not
provide for training of the craft in the basics of the Oconee EQ Program.
Discussions with the Director of Maintenance Training and other licensee
personnel, revealed that a formalized training program for indoctrination
of the craft in the requirement of the EQ Program had not been estab
lished.
Licensee management stated that in a response to Internal
Investigation Report (IIR) 087-41-1,
"Procedure Violation Caused by a
Management Deficiency in Failing to Provide Adequate Training for Craft
Personnel to Properly Perform Oconee Nuclear Station Approved Procedures,"
a need was identified for a formalized EQ training program. A lesson plan
is in the preliminary stages of preparation with a commitment date of
March 18, 1988, for completion.
Interviews with staff members in the Project Services organization also
confirmed that no EQ training had been provided to this group, other than
those aspects of the EQ Program addressed in the Qualified Reviewer
training course.
Licensee management in the site QA/QC organization
presented objective evidence in the form of attendance lists which
verified that select members from this group had been provided off site
training in the requirements of the EQ program.
Based on a review of deficiencies documented in Audit Reports and PIRs, it
was determined that
significant contributing factors are inadequacies in
the work-site control process involving personnel-procedural interface
and/or personnel-hardware interface requirements.
The root cause for
the problem documented on PIR 1-087-0231,
and discussed in Section 9
(Implementation of NSM #ON-1294)
of this report,
has been correctly
identified as inadequate craft training, i.e., inadequate personnel
procedural interface.
In addition, lack of knowledge regarding EQ
equipment requirements was apparent in the personnel-hardware interface,
in that a potential moisture intrusion problem was not recognized by the
craft for the pressure transmitters they had installed.
The licensee's accepted Operational
QA Programs,
Duke Topical Report
(Duke 1-A) Amendment 11, Section 17.22; Station Directives 4.4.1, Training
and Qualifications; and Station Directive 4.4.3,
Qualification of
Interfacing Individuals, requires that necessary training be provided to
station employees to assure they will be equipped to perform their work
assignments in a safe and effective manner.
It was concluded that the
problem documented on PIR-1-087-0231 is
indicative of a programmatic
breakdown in the EQ training of station employees.
Timely corrective
action through implementation of the EQ Program lesson plan subsequent to
March 18, 1988 is required to resolve this licensee identified deficiency.
12. QA/QC Interface
Discussions with licensee management revealed that audits of the EQ
Program had been performed by the Corporate QA organization. Departmental
audit numbers SP-85-2(GO),
"Environmental Qualification of Electrical
Equipment", and VP-87-20(ON), "Maintenance and On-site Transmission" were
9
reviewed to determined the nature of the problems identified by the QA
organization. In addition, an assessment was performed of the adequacy of
the root cause analysis for identified problems, along with the adequacy
of the developed corrective action plans.
Based on this review the
inspector concluded that appropriate corrective actions had been developed
and/or implemented for the identified problems..
A review was performed of Problem Investigation Reports (PIRs)
to assess
the adequacy of the developed corrective actions, and the technical basis
for determination of equipment operability status.
One Unresolved Item
was identified during this effort and is discussed below.
PIR 1-087-0231 documents the investigation of a deficiency identified
with the installation of Unit 1 Reactor Coolant System (RCS)
wide range
pressure transmitters 1PT-21,
The pressure trans
mitters were installed on March 13, 1986, during implementation of nuclear
station modification package NSM ON-12494. They were found on October 17,
1987, in an installed configuration not in accordance with design nor the
EQ tested configuration.
Specifically, the Construction and Maintenance
Division (CMD) electrical crew did not use grafoil tape on the threaded
pipe connection to the transmitter enclosure.
In addition, they did
not torque the threaded fittings to 150 inch-pounds as specified in the
implementing procedure.
The craft also changed the configuration of the
installed transmitters by use of a 90 degree elbow between the trans
mitter and the field conduit connection.
The installation was corrected by the licensee on October 24,
1987.
An
evaluation was also performed to establish the operability status of the
transmitters while in the non-EQ tested configuration.
This operability
evaluation, however, did not consider the primary failure mechanism which
is terminal block leakage currents caused by a surface moisture film.
Additionally, the operability evaluation did not include an analysis
of the errors contributed by the terminal block leakage current to the
transmitter loop accuracy.
Further, a comparison of the transmitter loop
accuracy, including leakage current error, was never made for the plant
functional performance requirements,
i.e.,
RCS Wide Range Pressure set
points.
These transmitters provide the signals for actuation of the
Engineered Safeguards Protective System which is a 2-out-of-3 coincidence
logic system.
Licensee management concurred with the inspector regarding the inade
quacies of the operability evaluation.
They committed to revise the
evaluation in order to determine operability status of the transmitters
from April 26,
1986,
when
the Unit entered the start-up mode,
to
October 17,
1987,
when the improper installations were discovered.
Pending completion of the operability evaluation by the licensee, and
review for technical adequacy by the NRC, this is identified as Unresolved
Item 50-269,270,287/88-03-02, Operability Evaluation Concerning PIR 1
87-0231.
10
13.
Environmental Qualification Documentation Packages (EQDP)
and in Plant
Physical Inspection
a.
Environmental Qualification Documentation Packages
System
Component
Identification Worksheets
(SCIW)
and System
Component Evaluation Worksheets (SCEW)
are part of the EQDP.
The
SCIW identifies all EQ electrical equipment per system for all three
units and the SCEW provides specification and qualification require
ments and the applicable references.
In addition, a central part of
the EQDP is the EQRI.
A section of the EQRI identifies each specific
type of qualified equipment by manufacture and model number. It also
identifies the qualification activity requirements and references the
documents which allows the Nuclear Production Department to maintain
the qualification status of equipment.
This document also has
mandated maintenance/replacement requirements.
The NRC inspectors examined some 30 EQDPs for selected equipment
types.
In addition to comparing plant service conditions with
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 decrease in insulation resistance on equipment performance,
adequacy of demonstrated accuracy, evaluation of test anomalies, and
applicability of EQ problems reported in NRC IENs and IEBs and their
resolutions. Most of our comments/concerns with these EQDPs were resolved
or corrected during the inspection. Some of these comments/concerns
and unresolved items are discussed in the following section c.
b. In Plant Physical Inspection
The NRC inspection team physically inspected 20 qualified components
and selected field run cables. The inspection team examined charac
teristics such as mounting configuration, orientation, interfaces,
name plate data,
ambient temperature,
moisture intrusion seals,
splices, terminal blocks, internal wiring and physical conditions.
c. Comments on EQDPs and Plant Walkdown Items
(1) File OM 360-9-Joy/Reliance Fan Motor, Model No. 600276-3
The Joy/Reliance Fan Motors are used as Reactor Building Cooling
Fan Motors.
The file review for the motors showed that they
are qualified to requirements specified in IEB 79-018 (D.O.R.
guidelines).
Both the maintenance concerns and replacement
plans were addressed in the file.
During the walkdown inspec
tion one Reactor Building cooling fan installation was inspected
and no anomalies were noted.
(2) Rosemount Pressure Transmitters, Model No. 11530D
The Rosemount Pressure Transmitters, Model
No.
1153D recently
replaced the Motorola Model
No.
56PH.
The transmitters are
used to monitor Reactor Coolant Pressure (wide range).
The
qualification for these new transmitters were to 10 CFR 50.49
requirements which was supported by Rosemount Qualification
Report D8300040 Volumes I,
II & III Revision A and Wyle Lab
Report 45592-3. During the walkdown inspection one installation
was examined. The transmitter was properly mounted and sealed
and no anomalies were noted.
(3) File OM-26&A-47 - Gem/Delaval Liquid Level Transmitters
Model No. 60620 and XM-60625
The Gem/Delaval liquid level transmitters are used to monitor
the reactor building (RB) wide range water level.
The licensee
stated that these units are qualified to
10 CFR 50.49 require
ments
by Wyle Test Report 45700-1.
A review of the EQDP
confirmed the licensee's position.
During a plant walkdown, two level transmitters were inspected.
Both had low silicon oil level in their instrument termination
junction box.
This low oil level puts the instruments in a
condition outside the as tested qualified condition.
Since
the qualification test had the silicon oil at the top of the
junction box, this is a violation identified as 50-269, 270,289/
88-03-03,
RB Level Transmitter's Oil Level Not at Top of
Instrument Termination Junction Box.
The licensee stated
that the additional silicon oil would be added on Unit 2
transmitters prior to restart and that they would check and
fill the junction boxes as necessary on Units 1 and 3 at the
next available outage.
In addition, the licensee stated that
they would revise the maintenance procedures to clearly state
silicon oil fill requirements.
Since this condition could exist for Units 1 and 3, the licensee
provided justification for continued operation in their Problem
Investigation Report (PIR) 2-088-0033. This was evaluated and
considered to be satisfactory.
12
(4) File OM-245-0979 - Limitorque Motor Operated Valves (MOVs)
Model SMB/SB, Located Inside and Outside Containment
Test reports supporting equipment qualification of the
Limitorque MOVs at Oconee to the DOR Guidelines are Limitorque
Test Reports 100456,
600376A,
Rev. B, 600198,
B0003,
F-C3271,
and B0058, and the documentation contained in Duke File OM-245
0979. File review resulted in no open items/concerns.
Plant walkdown was performed on six Limitorque MOVs.
Three
are located inside containment and three are located outside
containment. All are in the Reactor Building Isolation System.
From the plant walkdown inspection and discussion with Oconee
personnel, the following concerns were identified.
(a) Unit #2's HP-26, an outside containment dual voltage MOV,
had a blind barrel crimp connector (nylon insulated wire
joint) for the motor connection windings.
The licensee
stated that HP-26 was the only Limitorque MOV required
to mitigate an HELB in the penetration room and that
Limitorque Test Report B0003 envelopes the postulated
accident environment in this area.
All electrical
connection for MOVs inside the containment are made by
splicing and heat shrink tubing (No blind crimp connectors
are used).
Two dual voltage MOVs in the containment were
looked at during the walkdown inspection and these were as
the licensee indicated.
(b) Discussion with the licensee disclosed that some in
containment MOVs were shipped by limitorque and installed
at Oconee without T-Drains and/or grease reliefs. The licensee
discovered this problem in October 1987 and has corrected
it in Units 1 and 2 and has committed to an inspection and
installation (if necessary) of T-Drains and grease reliefs
in Unit 3 at the next Unit 3 outage.
The licensee's JCO
states that all limitorque operated valves inside the
containment are used for containment isolation. Containment
isolation MOVs receive an ES signal and move to their safe
position within a short time before temperature and pressure
increases and no post accident operability is required of
these valves to maintain safe shutdown of the plant. Based
on the licensee position concerning containment isolation
valves as stated above, and the fact that T-Drains were not
installed in Limitorque Report 600198,
the above is not
being cited as a violation.
The licensee is installing
grease reliefs and T-Drains on these MOVs as a conservative
measure.
(c) On Limitorque 2RC-5 a badly frayed jumper wire on the limit
switch was observed.
Prior to the exit meeting,
the
licensee initiated a maintenance order to replace this
jumper and showed,
through electrical drawings, that this
particular jumper actually served a non-EQ function on the
RC-5 actuator.
13
(d)
On actuator 2HP-26, which is mounted with the limit switch
cover down,
thick oil (grease)
was observed inside the
cover and the limit switch itself appeared to have oil on
it. the licensee committed to increase the surveillance
and maintenance of the Oconee limitorque MOVs in an attempt
to isolate and reduce oil leakage.
Typically, during the course of the Limitorque EQ audit,
several generic concerns are addressed. The following is a
brief discussion of these concerns and the Oconee resolu
tion of each.
o
In-Compartment
Heaters (IEN-86-71)
-
Some
inside
containment and outside containment Limitorques at.,
Oconee have in-compartment heaters but they are all
fused and the fuses have been removed. Additionally,
warnings have been placed at the fuse locations
stating that fuses are not to be installed.
Inspec
tion of two typical electrical schematic drawings
verified the heaters are de-energized via fuse
removal.
o
Actuator Operations Under Degraded Voltage
-
Oconee
furnished documentation and representative sample
calculations showing their limitorque motors
are
adequately sized to supply the required thrust (from
MOVATs testing) at 80% rated voltage.
o
Rotors (IEN
86-02)
-
Oconee
has six
Limitorque MOVs with magnesium rotors.
Four of these
are administratively locked closed and the remaining
two are not located in areas with the type of harsh
environment necessary to degrade the MOVs.
O
Unidentified Jumper Wires
(IEN-86-03) - File investi
gation, interrogation of plant personnel,
walkdown
sheets, and maintenance/surveillance procedures showed
only qualified wires to be present in the Oconee MOV
compartments. Plant walkdown verified this.
o
Degraded Insulation on Peerless DC Motors (IEN-87-08)
There are no peerless DC motors with the suspect
Nomex-Kapton insulated leads installed at Oconee.
o
Underrated Terminal Blocks (IEN-83-72)
-
Oconee
has
nearly completed an upgraded program in which all
Limitorque terminal blocks inside containment are
being replaced with
Raychem splices.
The only
terminal blocks left are Marathon 300 which are
environmentally qualified.
14
Finally, lubrication procedures were investigated.
Only Exxon
Nebula EPO or EPI is used in the main gear box; Mobile 28 or
Beacon 325 is used in the limit switch gear box.
Lubrication
maintenance is performed at no greater than 24-month intervals.
The six-month Limitorque recommended cycling of the MOVs for
part coating and grease mixing is not performed at Oconee.
Operating experience coupled with the fact that
all MOVs are
cycled as part of the Limitorque maintenance program at least
once every 24 months justifies this position.
(5) File OM-337-0080-001 - Viking Electrical Penetration Assemblies
(EPA)
Test reports supporting qualification of the Viking EPAs to the
DOR Guideline requirements are Duke/Viking Qualification Test
Summary for Electrical Penetration Assemblies, OM-337-0080-001,
and the documentation contained in the EQ file.
File review
resulted in no concerns.
Plant walkdown was performed on Viking penetration tag numbers
2RX-CO2, 2RX-DO6, 2RX-CO4, and 2RX-EF5.
The first three were
viewed from inside containment, the last (EF5) was viewed from
the outside containment side. The outside terminations were via
four terminal boards in EF5.
The inside terminations were via
amphenol connectors directly to the penetration leads.
Both
types are environmentally qualified for the harsh environment
they are used in.
The plant walkdown resulted in one minor question. The junction
boxes covering the amphenol connectors were not water tight
and had holes in the top.
Subsequent file review showed the
environmental qualification testing was performed without the
junction boxes installed so no moisture protection credit is
taken for the boxes.
They serve mainly for physical protection
of the amphenol connectors. The inspector considers the Viking
EPAs to be environmentally qualified for their use at Oconee.
(6) Cable Identification and Traceability to Cable EQDP
During the plant walkdown inspection, nine circuit numbers from
field wires were collected from the various equipment inspected.
The licensee was asked to identify and establish qualification
of the cable, using the numbers provided.
The paper trail provided by the licensee for this identifica
tion/qualification is as follows:
(a) Connection diagram identifies the cable number serving the
device.
15
(b) Cable sheets list the cable numbers, respective cable type
number, and route.
(c) Purchase requisitions identify the vendor from whom the
cable type was procured with the purchase order number.
(d) Vendors certify that cable procured on an applicable
purchase order is environmentally qualified per the
applicable test report.
This vendor certification is
included in the test report file.
The cable numbers that were traced to the applicable EQ test
report per the above method during the Oconee EQ inspection
audit were:
2EXSF2901,
2EMI112A,
2EXSF2903A,
2EMI110A,
2EXSF2903B, 2EXI210, 2EXS85A, 2EXS85B, 2EXS85C.
This exercise showed that the licensee was able to trace and
establish qualifications for field cables.
(7) Moisture Intrusion Seals
A review of Duke Power Company report TR-069 was conducted.
This report contained information relative to the environmental
qualification of 3M Scotchcast Brand Resin No. 9 and Swagelok
connectors.
Basis for qualification was substantiated by Duke
report CNM-1364.00-0007-001
where a connector assembly was
subjected to a simulated Loss of Coolant Accident.
The tested
accident conditions were found to envelope the Oconee inside
containment accident profile.
The tested configuration allowed
no moisture intrusion before, during, or after the LOCA test.
The report qualified the connector-resin combination for all
areas inside the plant except those that could be submerged.
Equipment subject to submergence qualification is based upon
Duke report TR-063.
In this report the 3M Scotchcast Brand
Resin No. 9 was potted directly into a detector fitting.
No
Swagelok connectors were used.
The report showed that this
combination would perform acceptably for all postulated
environments at Oconee including submergence.
(8) Raychem Splice Connections
A review was conducted of the Duke files relative to the
qualification of a variety of Raychem Splice configurations.
Qualifications was based on Corporate Consulting Report No.
86-1995 and Wyle Reports 17859-02P and 17859-02B.
The Wyle
reports demonstrated qualification of a number of splice
configurations not in accordance with Raychem's recommended
16
installation instructions.
All of the Raychem samples were
shown to pass the EQ test.
The tested condit ans were found to
envelope those expected at the Oconee plant. The combination of
tests contained in this file provides a qualification basis for
many types and variations of Raychem splice configurations
installed at Oconee.
Raychem splice connections were examined
during the walkdown inspection.
No unqualified Raychem splice
configurations were observed during the walkdown inspection.
(9) Generic Cable File Similarity/Auditability Concern
None of the cable files reviewed included similarity analyses
addressing installed equipment and tested vendor specimens.
Additionally, most of the files did not specifically identify or
describe plant installed equipment.
For instance, all cable
files except the Anaconda cables left out descriptions for
installed cable insulation material,
insulation thicknesses,
formulation and other cable configuration information.
The
licensee was able to locate the similarity information in
all cases and satisfied the inspector questions on each file.
It
was recommended that these analyses be included in the
qualification files.
The licensee took exception to this
request.
They considered that this type of documentation to
be unnecessary.
The term "similarity" was questioned, with
apparent preference for such terms as auditability, trace
ability, file clarification or augmentation.
The inspector
found that similarity analyses, as required by all levels of
EQ requirements (DOR, NUREG 0588, 10 CFR 50.49), were not in
the files.
There were no technical concerns with the written
similarity analyses subsequently provided;
however,
since
the files were incomplete at the time of the inspection, this
is identified as violation 50-269,270, 287/88-03-04, Similarity
Analyses for Installed Cables to the Tested Vendor Specimens Not
Established in EQ Files.
The following is a sample of cable files reviewed:
(a) Brand Rex FR-XLPE Instrument Cable,
File No.
CNM-1354.
00-0070-001
The cable qualification basis is 10 CFR 50.49. Qualifica
tion is based on Franklin Report No.
F-C5120-4 (for Brand
Rex) dated January 11, 1982.
The test profile enveloped
plant accident environmental conditions.
An Arrhenius
analysis was provided to show one-year post-LOCA oper
ability at 125 0 F. A 40-year qualified life was shown via
Arrhenius analysis for accelerated aging conditions of 168
hours at 136 0C. Cable performance was demonstrated with
17
acceptable insulation resistance readings taken during the
LOCA simulation.
Test samples included a 2/c, 16AWG, 7
strand,
20 mil XLPE insulated, 45 mil Hypalon jacketed
cable.
The plant cable tag numbers did not provide enough
information to fully identify installed cables.
The
licensee contact traced this cable information through the
purchase order/Mill Power order/Brand Rex part number/Duke
Power file number process and identified both 25 and 30 mil
insulation thicknesses.
No findings were identified other
than that identified above.
(b) Samuel Moore EPDM/Hypalon Instrument Cable, File No.
0316-0198-001
The qualification basis is 10 CFR 50.49. The file included
an Isomedix report of June 1978 and a Franklin Report No.
F-C3683 dated November 1973.
Tested cables included 1 and
2/c, 16AWG, 7 strand, 20 and 30 mil EPDM, 45 mil Hypalon.
The licensee reports that only 20 mil
EPDM/10 mil is
installed in the plant (see first paragraph in Section 9
above). When questioned regarding which test report really
establishes qualification, the licensee responded that the
Isomedix report alone provided adequate data. Though both
test reports tested cables similar to plant installed
cables, the Franklin report includes questionable IR data.
The licensee agreed to evaluate the need for the Franklin
report and to possibly delete it
from the qualification
file. Test profiles in the Isomedix report enveloped plant
requirements.
Post-LOCA operability was met through an
Arrhenius analysis.
Insulation resistance values were
marginally acceptable.
The lowest value was used for
instrument loop accuracy calculations for loops which
include Samuel Moore cable. Aging conditions were adequate
to demonstrate 40 year qualified life.
(c) BIW
CSPE Bostrad 7 Instrument Cable,
File No. OM-0316
0050-001
Qualification basis is 10 CFR 50.49.
BIW Report No.
82E047,
dated May 28,
1982,
establishes qualification.
Plant requirements were enveloped by the simulated LOCA
environment.
The 1-year post-LOCA operability period was
analyzed by Arrhenius techniques.
Tested samples included
7/c,
16AWG,
19 strand,
30 mil
CSPE (Bostrad 7),
45 mil
Bostrand 7 jacket. As discussed in the first paragraph of
Section 9 above, the licensee verified installed configura
tion as 25 mil/45 mil thicknesses of identical material.
Due to the low voltage application, the similarity response
was accepted provided a summary is added to the qualifica
tion file. Acceptable insulation resistance data and other
performance parameters were included in the test report.
18
(d) Brand Rex FR-XLPE Coax, File No. CNM 1354.00-0021-001
Qualification basis is 10 CFR 50.49. Qualification data is
provided in Brand Rex (Franklin)
Report F-C5120-2 dated
September 2, 1980.
After a lengthy discussion of trace
ability documentation, the licensee identified the
installed plant cable as
RG 59 B/U identical to tested
samples of 60 mil XLPE insulation, Hypalon jacket.
It was
recommended that the licensee address this "similarity"
information
in the qualification package
(see first
paragraph of Section 9).
Aging conditions established a
40 year qualified life at 900C. The plant environmental
requirements were adequately enveloped with acceptable
margins.
As in all the cable files, a post-LOCA oper
ability Arrhenius analysis was provided.
Insulation
resistance readings taken periodically during the LOCA
simulation were acceptable.
(e) Anaconda Control Cable, File No. OM-0316-0065-001
Qualification basis is 10 CFR 50.49.
Qualification is
based on Franklin Report No. F-C4350-3,
July 1976.
Five
specimens of power cable and one control cable sample (7/c,
12AWG,
7 strand, 30 mil EPR,
15 mil/60 mil hypalon) were
tested.
In this case only, the file included a letter
which identified the installed cable configuration (3/c,
12AWG,
19-25 strand,
30 mil
EPR,
15 mil Hypalon and
neoprene).
In this letter, a similarity analysis was
provided which included qualification of neoprene jacketed
cable.
The test report showed enveloping of plant
environmental requirements
and included an Arrhenius
analysis for post-LOCA operability. Aging was analyzed to
justify 40 year life.
Insulation resistance readings and
post-test withstand test results supported acceptable
performance.
(10) Victoreen High Range Radiation Monitor (HRRM), File
No. OM
0333A-0106-001
Qualification basis is 10 CFR 50.49. Qualification was based on
Victoreen Report 950.301.
Numerous problems plagued the test,
resulting in a final qualified installation which required
cables and connectors to be encased in hermetically sealed
epoxied terminations and in sealed stainless steel conduit from
the monitor to the containment penetration.
The BIW cables
(assembly 878-1) and sealants were specifically excluded from
qualification by Victoreen, with reference made to other BIW
qualification reports. To preclude the problems due to moisture
19
intrusion, electrical shorting and associated failures, the file
included a termination procedure (#910077) as a modification to
the test plan which documented the methods required to install
these radiation monitors. When properly installed in accordance
with this procedure, the test report demonstrated qualification.
Plant environmental requirements are. enveloped by the test.
Operability and accuracy requirements are demonstrated in the
report.
The plant walkdown observations of the actual HRRM installation
showed that the installed configuration does not meet the tested
configuration.
The cables (Brand Rex Coax) run from the sealed
monitor connections through open cable trays to the containment
penetration. Though the terminations are sealed, this installed
configuration is similar to interim configurations in the
qualification test report which yielded unacceptable results.
With very low operating current levels subject to adverse
affects from comparable low leakage currents, the final test
configuration,
in the Victoreen
Report 950.301,
required
isolation of cable and terminations from the LOCA environment.
The licensee provided letters, dated August 15 and August 26,
1983, that were sent to the NRC, and other documents that showed
there were considerable problems in getting an operable HRRM
system.
The licensee could not get the initial installation
of the HRRM system to work even in a non-hostile environment.
The initial installations include the BIW cable supplied by
Victoreen.
A package of summarizing details for the final
installed configuration of the Oconee operable HRRM system was
provided. This included a connection procedure to the Victoreen
detector that used Scotchcast 9 sealant in the Brand Rex Coax
connector and Sylgard No. 186 in the connector at the monitor.
The Brand Rex Coaxial cable was field routed via cable trays.
The cable connection at containment Viking penetration was
sealed with Scotchcast 9.
The licensee claimed qualification
per the Victoreen test report and Brand Rex qualification
report.
No similarity analysis was provided comparing Brand Rex and BIW
cable nor was the lack of conduit in the installed configuration
addressed.
No similarity analysis was made for termination
seals and no analysis was made for the Viking EPA's or the Brand
Rex-specific IRs and their effect on instrument accuracy.
An
installation-specific analysis of IR effects and functional and
safety requirements of these monitors was requested, but because
of time restraints the official Oconee approved loop accuracy
calculation for the installed configuration could not be
provided before the exit meeting.
This item is identified as
violation 50-269,
270,
287/88-03-05, Similarity Analysis for
Qualification of Installed Configuration of High Range Radiation
Monitor Not Established in EQ file.
20
(11) States Terminal Blocks, File No. OM-360-25
The inspector reviewed the file for states terminal blocks which
are used in relatively mild, outside containment applications.
The licensee stated and verified that terminal blocks are
associated with solenoid valves.
The qualification basis is
and tested to IEEE 323-1971 requirements.
Qualification is based on QTF Report No.
TR-028 for McGuire
Station, and supplemented by Gould-Brown Boveri #33-53729-05.
The former report included tests for Stanwick, Buchanan,
and
States terminal blocks, model numbers M25104 and M25006 for the
latter.
Installed blocks were verified by the licensee as
States model M25012.
These are identical in material construc
tion to M25006,
except for the number of lugs (12 versus 6).
Plant terminal blocks are installed in a vertical configuration.
The licensee did not address either similarity or mounting
orientation in the file.
In the test, the polyprophylene
barrier plates melted. Despite this, the terminal blocks still
met test acceptance criteria and insulation resistance and
leakage currents were adequate.
Plant environments were
enveloped with significant margins.
Considering this and the
relatively mild requirements, plus the satisfactory results of
the test report, the similarity and configuration concerns
were not pursued.
The licensee agreed to document similarity,
installation and application information in the file.
(12) Instrument Loop Accuracy Calculations
The instrument loop accuracy calculations for the following
loops were reviewed:
o
Calc.
No.
OSC-2578
(2/10/88)
for Wide
Range Reactor
Building Water Level, LT90, 91.
o
Calc. No. OSC-2651 (11/13/87) for Reactor Building Normal &
Emergency Sump Level, ON-LWDLT113, 120; ON-LPILT 3P, 112
o
Calc.
No.
OSC-2876
(2/18/88)
for Core Exit Incore
Thermocouples
o
Calc.
No.
OSC-2609 (2/5/88) for Emergency Range Steam
Generator Level, FDWLT 80, 81, 82, 83
When asked why other instrument loops associated with critical
LOCA and post-LOCA functions were not included, the licensee
responded that these were the only loops identified for long
term post accident operability.
The formal
responses to
R.G. 1.97 address other loops, some of which are currently being
assessed for inclusion in the loop accuracy calculations.
21
A number of specific questions regarding the assumptions and
analyses were posed and resolved as follows:
o
Only four loops were included and analyzed in this package.
The licensee responded that these were the only 1E applica
tions involving EQ-related in-contaiment instrument loops
needed for "long-term"
post-LOCA critical monitoring.
All other circuits are either associated with mild environ
ments,
not required for long-term operability (i.e., trip
functions only),
or not associated with "environments
that produce leakage current inaccuracies". Additionally,
R.G. 1.97 modifications will include loop accuracy calcula
tions as appropriate.
o
A number of specific technical questions were posed con
cerning values for particular elements from the Westing
house methodology used in the loop accuracy analyses. In a
telecon with corporate engineers in Charlotte, N. Carolina,
all of these specific details were addressed, with a
followup written response.
All concerns were adequately
resolved.
o
One of the "partial" packages did not include the summary
of the Westinghouse methodology analysis which was provided
in other calculation packages.
In the telecon, it
was
stated that an independent analysis of the total loop had
been performed,
though not provided.
What was provided
were the calculations specific to IR effects, which are
made part of the total loop calculations.
There was no
need to review the calculations; what was needed was
clarification of what analyses are done,
where they are
located, and how the various calculation sets are related
and tied together.
There was no technical concern which
required further inquiry.