Text

Insp Rept 50-220/86-05 on 860414-18.No Violation Noted.Major Areas Inspected:Environ Qualification Files of Limitorque Valve Motors,Rosemount Transmitters & Fenwal Temp Switches & Previously Identified Items
	ML17055B747
Person / Time
Site:	Nine Mile Point
Issue date:	05/28/1986
From:	Anderson C, Cheung L, Paolino R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML17055B746	List: ML17055B745; ML17055B747;
References
	50-220-86-05, 50-220-86-5, NUDOCS 8606100074
	Download: ML17055B747 (28)
	v • d • e

(

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report

No.

50-220/86-05

- Docket No.

50-220

License

No.

DPR-63

Priority

top tier document

NT-100.C,

"Equipment Quali-

fication," Revision 0, in January,

1986.

The licensee

considered

thi s document contains sufficient detail to be used for various

categories.

Procedure

NT-100.C establishes

methods

which can

be used

by

licensee

engineering

and licensing,

in conjunction with site

technical

support,

to satisfy the requirements

of 10 CFR 50.49.

This document is used to determine

environmental qualification

criteria; identification of design

requirements

and control;

installation requirements,

EQ maintenance

requirements,

and

EQ

file requirements.

For example,

section

6. 10. 1 states

that

"zonal

maps shall

be maintained

as control documents,

and

include

peak values of temperature,

pressure

and relative

humidity that would be experienced

in each

area of the plant

analyzed for High Energy Line Break (HELB)."

JI

The licensee

has developed

individual zonal

maps

based

on

a study

by NUS (NUS-1961-SAAl).

The zonal

maps contain the required infor-

mation

as stated

in the procedure.

The procedure

(NT-100.C) references

24 documents

which may be used

in conjunction with the procedure.

Of the 24 documents

referenced,

all have

been

issued

except

seven.

The

seven

have

been written

and approved,

ready to be issued.

Their i ssuance

is pending

formal

training of personnel

in use of the procedures.

This training is

scheduled for May 1986.

The inspectors

considered this area

completed

except for the

EQ

maintenance

requirements

which are discussed

below.

E

Re uired Maintenance

and Site Maintenance

Procedures

U dates

The

EQ maintenance

requirements

are defined in paragraph

6.7 of

NT-100.C.

The

EQ required maintenance

(EQRM) for each type of

equipment is listed in the

EQRM form and transmitted to the site

for implementation.

The site personnel

are responsible

for

scheduling,

performing, inspecting,

and tracking the required

maintenance activities.

A computer

program

has

been developed

by the licensee

to track the status of each maintenance activity.

The site personnel

are also responsible

to update their site

maintenance

procedures

to include the

EQ requirements.

Two groups

are involved in these activities.

The Electrical

Equipment group

and the

18C group.

The Electrical Maintenance

supervisor

indicated that

28 electrical

maintenance

procedures

need to be updated.

Five of them are to

be used for the

EQ maintenance

during the current outage.

These

five procedures

(Nl-EPM-Cl and C2,

Nl-EPM-R1, Nl-EPM-C14 and

Nl-EPM-122-R135)

have

been drafted

and will be issued

before plant

restart

from the current outage.

The rest of the

28 procedures

will be updated

and issued

before the end'of this year.

Twenty-three

IKC mai'ntenance

procedures

need to be updated to in-

clude the

EQ requirements.

Of these

23 procedures',

all but one

have

been written and are in the review process.

One of these

has

been

approved

and is ready to be issued.

Four have

been

reviewed

and are in process for corrections prior to release.

These four

are

scheduled for issue

on April 19,

1986.

The remainder (in

various

stages

of approval) will be issued

before the

end of the

current outage.

In the interim, work is being done per Work Requests

and

EQRMs

based

on existing procedures

which form the basis for the

18C

EQ

maintenance

procedures.

The

EQ maintenance

activity involving replacement

of Rosemount

Transmitter 0-rings was confirmed by reviewing Work Request

Nos.

10100,

11009,

11010

and

11011,

dated

March 24,

1986.

2..

EttTEii

P

2.8.3.1

Site Personnel

Trainin

The inspector

reviewed

and discussed

the licensee's

EQ

training program

and implementation of training proce-

dures relating to equipment qualification.

Topics

covered in the training program will enable

licensee

personnel

to utilize a

SCEW sheet,

Environmental

Maps

from the Equipment Qualification Procedure

NT-100.C

and the

EQ Master Equipment List.

The training program is in effect for Electrical

and

Instrumentation

and Control personnel.

Training records

indicate the program

has

been in effect since

September,

1985.

The records

also indicate that personnel

are

tested

on the material

presented

and must demonstrate

an understanding

of the equipment qualification program

as evidenced

by an achievement

of 80 percent or better

in the examination.

2.8.3.2

Cor orate

Personnel

Trainin

Corporate training has

been delayed.

The Corporate

EQ

training program originally scheduled for February,

1986

has

been delayed to May, 1986.

Corporate

EQ personnel

have

been

given copies of the

EQ material

(NT-100.C, i.e.)

to read

and acknowledge receipt of this material.

The

EQ function has

been

supported

to date

by experienced

contract personnel.

Licensee

personnel will gradually

move in to perform the

EQ function as training is com-

pleted.

2.8.4

This item remains

open pending

NRC peview and evaluation of the

licensee's

completion of their

EQ maintenance

program

and Corporate

personnel

training.

2.9

0 en

0 en item 50-220/85-13-09

concerning

the oil spillage

under each

of the reactor building closed

loop cooling motors M70-01,

02 and 03.

The licensee

stated that this problem was due to lubricant overfill

during the routine maintenance.

The licensee

proposed

two steps to

prevent recurrence

of this problem:

1) to instruct the maintenance

personnel

not to overfill lube oil during the lubrication maintenance,

and 2) to adjust the motor lube oil filler level

such that any over-

filled oil will be drained to the drain pan.

The inspector verified

through training record that the first step

was completed in September,

1985.

However, the

second

step

had not yet been taken.

The licensee

stated that

one of the three motors

was being overhauled

and the other

two motors

had to run continuously.

Once the overhaul

is completed,

they would adjust the motor oil filler level.

This item remains

open.

10

2. 10

Closed

0 en item 50-220/85-13-10

pertaining to verification of procure-

ment documentation

to establish similarity for acoustic monitor coaxial

cable

and the Rockbestos

coaxial cable for which the file established

qualification.

The inspector

reviewed licensee

procurement

document

No. 52657, product

code

Nos.

?46-3422

(38/C ¹16XLPE/NED) and

146-0021

(2/C ¹16XLPE/NED)

verifying similarity of cable type

and size.

The document review

included certified test reports for the

above product

code

numbers,

cable

megger termination

and interconnecting wiring diagram

No.

3-N21-E21.5.

Thi s i tern i s cl osed.

2. 11

Closed

0 en item 50-220/85-13-11

pertaining to

a deformed

gasket

in

a conduit coupling for a related

switch and the seismic acceptability

of the valve (No. 50V-201.2-23) installation with respect

to

a steel

clamp.

The deformed gasket

has

been

replaced

and operator training provided

for replacement

and positioning of gasket

seals.

For the valve installation,

the licensee

has provided

an engineering

evaluation with supporting calculations

(No. S22.4-201.2-H24)

for the

installed configuration-( support

No. 201.2-H-24)

minus the steel

clamp.

The support

was analyzed

and designed for East/West

and Vertical loads.

The analysis

does not reflect

a north/south restraint of the valves

that would occur with the

use of a clamp.

The licensee

could not explain why the steel

clamp was installed.

The

clamp was

removed

and

a second

evaluation

and calculation

was performed

by the licensee

to determine if there

had been

any damage

as the result

of using the steel

clamp which would have prevented

thermal

expansion

in the north/south direction of the valve support.

The analysis

shows

that while the clamp was in place, it did not cause

overstress

in either

the piping or pipe support.

This item is closed.

3.0

Licensee

Post-Ins ection Reevaluation

of

E ui ment

uglification

Following the

NRC inspection of the licensee's

Equipment gualification

Program conducted

August 19-23,

1985,

the licensee

took steps

to correct the

identified deficiencies.

The licensee

corrective

actions

are described

in

three letters to the

NRC dated

September

30,

1985,

November

15,

1985 and

December

2,

1985.

Corrective actions related to specific file deficiencies

are evaluated

in section

2 of this report.

N '"

(4

k

With regard to programmatic deficiencies identified during the inspection,

the licensee

described their general

corrective actions during

an enforce-

ment conference

at the

NRC Region I office on February

5,

1986.

These

actions

included the following programmatic activities:

Reassessment

of EQ test Reports

Revision of

EQ test Reports

Addition of Page/Paragraph

References

Qualification File Review Checklist

Traceabi lity Matrix (Summary Table)

Functional

Performance

Reassessment

During the current inspection

each of these

programmatic activities were

reviewed both programmatically

and

as they related to specific equipment

qualification files reviewed during the inspection.

No programmatic defi-

ciencies

were identified.

The licensee

discussed

the results of their post-inspection

reevaluation

during the February

5,

1986 conference call with the

NRC and in their letter

dated

March 4,

1986 to the

NRC.

The licensee's

re-inspection

of accessible

qualified equipment

was initiated in April 1985.

This re-inspection

did not

identify any substantial

deficiencies.

The licensee

conducted

a re-evalua-

tion of all the equipmert qualification files in light of the deficiencies

identified during the August 19-23,

1985 inspection

and the programmatic

activities listed above.

As

a result of this re-evaluation

three-hundred

five (305) changes

were

made to the files as of February

17,

1986.

Of

this number,

17 affected the qualification status of qualified equipment.

The licensee

stated that

none of these

changes

required testing or additional

analyses

to establish qualification.

Furthermore,

no unqualified equipment

or required

hardware

changes

were identified.

the inspector

reviewed the

details associated

with a sample of the

17 file changes

affecting qualified

status.

Specifically, the inspector

reviews

changes

associated

with the

D.G. O'rien electrical penetrations.

The licensee

increased

the specified

operating

time from 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> to 100 days.

the inspector

confirmed that these

changes

in the specified operating

time were enveloped

by the qualification

of the equipment.

A summary review of several

other file changes

affecting

qualified status

by the inspector

confirmed the licensees

conclusion that

equipment specifications

were enveloped

by the equipment qualification.

No significant deficiencies

were identified by the inspector

in the licen-

see's

post-inspection

reevaluation

of Equipment Qualification.

4.0

Review of Additional

E

Files

4. 1

The inspectors

reviewed the

EQ files and

SCEW sheets

for three selected

equipment-types

to verify the qualification status

of the equipment

within the

scope of 10 CFR 50.49.

In addition to comparing plant

service conditions with qualification test conditions

and verifying

the bases for these conditions,

the inspectors

selectively reviewed

areas

such

as required post-accident

operating

time compared to the

duration of time the equipment

has

been

demonstrated

to be qualified;

12

similarity of tested

equipment to that installed in the plant (e

~ g.,

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;

evaluation of test anomalies;

and applicability of EQ problems reported

in IE INs/Bulletins and

their resolution.

4.2

The following equipment-types

were selected

for review:

a)

Rosemount

Model

1153D transmitters.

(SCEW sheets

062,

063,

064,

343 and 344).

b)

Limitorque Model

SMB-3 valve actuations

(SCEW sheets

078,

079,

080

and 185).

c)

Fenwal

Model

17002-40 temperature

switches

(SCEW sheets

20 through

35).

4.3

~Findin

Within the

scope of this review,

no unacceptable

conditions were iden-

tified.

.0

n ii

i

.

i

E

The inspector

reviewed the licensee's

method of verifying that generic equip-

ment installed in the plant is included in the Equipment (}ualification master

list and backed

by Equipment gualification files supporting

the qualification

of the equipment.

Examples of generic

equipment

are cables,

terminal blocks,

switch gear

and splices.

The methods

used

by the licensee

to verify installed generic

equipment vary.

For several

of the generic

items

on the master list such

as switch gear

and

power supplies,

the licensee

conducted

a walkdown of the items.

For the

cable splices,

the licensee

recently replaced

most of the cable splices with

qualified splices.

The verification methods

used for other items are not as

definitive as the above methods

and the verification methods

are not clearly

documented.

An example of an item in the latter category is cable.

Verifi-

cation of installed cable is accomplished

through

a combination of licensee

and vendor records relating to site cable procurement

and applications.

In

some,

but not all cases,

cable

can

be identified by walkdowns through cable

jacket markings,

SIS wire marking or samples

of unmarked cable

are returned

to the vendor for positive identification.

Additional information relating

to installed cable is available in the plant archives.

However, this infor-

mation is not computerized

or readily available for this purpose.

As

a

result of discussions

with the licensee,

they plan to document the various

methods

they used to verify installed generic

equipment at Nine Mile l.

No significant deficiencies

were identified by the inspector in this review.

0

Ef

'4l

'I

13

6.0

Plant

Ph sical

Ins ection

6.1

The inspectors

selected

a sample of four Limitorque valve actuators

(Model

Nos.

SMB-O,

SMB-1 and SMB-2), four Rosemount

11530 transmitters,

and four cables for physical

inspection.

All these

items were located

outside the drywell and were accessible

at the time of the inspection.

One Limitorque valve actuator

(Model

No.

SMB-1) is

a

new actuator

not

yet installed.

The inspectors

examined

the characteristics

such

as

mounting configuration, orientation,

interfaces,

model

number,

ambient

environment,

and physical conditions.

For the Limitorque valve actua-

tors,

the inspector also

examined

the identity of the internal wiring.

6.2

~Findin

s

a)

For Limitorque valve actuators,

the

NRC inspectors

did not identify

any unacceptable

conditions other than those already identified

by the licensee.

The licensee

had established

a program in 1984

to identify and replace,

as necessary,

all jumper cables

from the

limit switches to the torque switches if the cables

were not

either

Raychem "Flamtrol" or'ockbestos

"Firewall III."

They

developed

Procedure

Nl-EMP-45.96,

"Equipment gualification of

Limitorque Yalve Actuators

and Associated

Motor Type

SMB and

SB"

in 1984 to implement this program.

According to the licensee,

there

are

39 Limitorque valve actuators

requiring environmental qualification.

They conducted

a reinspec-

tion during the week of April 7,

1986, of 35 of these

actuators

and found that

20 of the

35 contained

jumper cables

(from the limit

switches to the torque switches)

whose identify was

unknown

and

qualification status

could not be established.

Subsequently,

work requests

had

been

issued

to replace

the jumper cables of

these

20 actuators

with qualified cables.

As of April 14,

1986,

four had

been

completed.

The rest will be completed during the

current outage.

The other four actuators will be reinspected

for their jumper

cables.

The licensee

plans to replace

the cables

where necessary

with qualified cables prior to startup

from the current outage.

The licensee

stated that the cases

where identification of the wire

was not immediately possible is not necessarily

a condition of

non-qualification but rather

a case

where the qualification could

not be established

without additional

research

or additional

test/analysis.

Since the qualification status of the affected valve actuators

cannot

be determined for the period from November 30,

1985 to

the time when the jumper cables

are or were replaced, this is

considered

an unresolved

item pending further.NRC evaluation of

the issue

(50-220/86-05-01).

~'

i

b)

The inspector identified that two Kerite cables

(one Model

HTK

power cable wired to Limitorque valve actuator.

IV-31-07, one

Model

FR II FR control cable wired to Limitorque valve actuator

FCV-80-118) were not included

on the master list, nor were any

SCEW sheets

prepared for this type of cable.

The licensee indi-

cated that the cables

were previously covered in a Kerite splice

qualification file.

However,

the qualification file had

been

deleted

from the master list when all the splices

were replaced

by other qualified splices.

This item is unresolved

pending

NRC review of the licensee's

corrective action

on the qualification of these

types of Kerite

cables

(50-220/86-05-02).

7.0

Unresolved

Items

Unresolved

items are matters

which require

more information in order to

ascertain

whether they are acceptable

items, or violations.

Unresolved

items identified during this inspection

are discussed

in Details, in para-

graph 6.2.

8. 0

Exit Me~et i e

The inspector

met with licensee

and licensee

representatives

(denoted

in

paragraph

1.0) at the conclusion of the inspection

on April 18,

1986 at

the corporate office.

The inspector

summarized

the

scope of the inspection,

the inspection findings

and confirmed with the licensee

that the documents

reviewed

by the team did

not contain

any proprietary information.

The licensee

agreed that the inspec-

tion report

may be placed in the Public Document

Room with prior licensee

review for proprietary information ( 10 CFR 2.790).

At no time during this inspection

was written material

provided to the

licensee.

t

ML17055B747

Text

Navigation menu

Search