Text

Insp Rept 50-410/88-08 on 880418-22.Violations Noted.Major Areas Inspected:Program Implementation for Establishing & Maintaining Qualification of Electrical Equipment within 10CFR50.49 Scope
	ML17055E006
Person / Time
Site:	Nine Mile Point
Issue date:	06/27/1988
From:	Anderson C, Cheung L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML17055E004	List: ML17055E003; ML17055E005; ML17055E006;
References
	50-410-88-08, 50-410-88-8, IEB-79-01, IEB-79-1, IEIN-86-002, IEIN-86-003, IEIN-86-053, IEIN-86-071, IEIN-86-104, IEIN-86-2, IEIN-86-3, IEIN-86-53, IEIN-86-71, IEIN-87-008, IEIN-87-052, IEIN-87-52, IEIN-87-8, NUDOCS 8807200150
	Download: ML17055E006 (42)
	v • d • e

U. S.

-NUCLEAR REGULATORY COMMISSION

REGION I

Report

No.

50-410/88-08

Docket No.

50-410

License

No.

NPF-69

Licensee:

Nia ara

Mohawk Power

Cor oration

301 Plainfield Road

S racuse

New York

13212

Facility Name:

Nine Mile Point Nuclear Station

Unit 2

Inspection At:

S racuse

New York

Inspection

Conducted:

A ril 18-22

1988

da

e

S. Alexander,

EQ Test Engineer,

NRC-NRR/DRIS-VIB

E. Claiborne,

Senior Engineer,

Sandia National

Lab

M.

R. Carpenter,

Senior Engineer,

Idaho National Engineering

Lab

Q. Decker,

Senior

Engineer,

Idaho National Engineering

Lab

.Inspector:

Leonard

Cheung,

Senior

a tor

ngineer

Other participants

and contributors to this report include:

Approved by:

C. J.

nderson,

Chief, Plant

Systems

Section,

EB/DRS

date

Ins ection Summar:

Ins ection of A ril 18-22

1988

Ins ection

Re ort

>>/

Areas Ins ected:

Special,

announced

inspection to review the licensee's

implementation of a program for establishing

and maintaining the qualification

of electrical

equipment within the

scope of 10 -CFR 50.49.

Results:

Based

on the review covered

by this inspection,

the inspectors

determined that the licensee

has

implemented

a program to meet the requirements

of 10 CFR 50.49 except for certain deficiencies listed below:

8807200150

380706

PDR

ADOCK 05000410

PDC

a)

The qualification of the

Raychem cable splices associated

with three

Rosemount transmitters

in the reactor building was not established

at the

time of the inspection

in tha't the splices did not have the required

seal

length.

This is

a violation of 10 CFR 50.49 paragraph'(f)

(50-410/88-08-01,

report paragraph

13. 1).

b)

The licensee's

activities in response

to Information Notice 86-53

concerning potential

problems

in Raychem splice installation

was incomplete

in that

NMPC did not specifically select

Raychem splice

samples for verifi-

cation after receipt of Information Notice 86-53.

They relied

on

SWEC's

gC inspection during construction.

The NRC's walkdown samples

indicated

that deficiencies

existed in the

Raychem splice installation.

Following

.

the inspection,

NMPC conducted

a

100'< walkdown

on

Eg Raychem splices

and

identified several

deficiencies.

These deficiencies

were evaluated

and

documented

by the licensee.

This is an unresolved

item (50-410/88-08-03,

report paragraph

15.0).

c)

Three of the six Limitorque operators

(outside the primary containment)

inspected

by

NRC contained

unremoved plastic

caps

(used for shipping)

on

the grease relief valves.

The inspectors

were concerned that

a similar

situation might exist for the Limitorque operators

inside the drywell.

Following the inspection,

the licensee called the inspector

on

May 12,

1988, stating that they had found

6 Limitorque operators

inside the

drywell that contained

unremoved plastic

caps

on the relief valves.

These

plastic caps

were subsequently

removed

and the activities documented

in

the

Eg files.

An engineering

evaluation

was performed for the qualifica-

tion of the affected Limitorque operators.

This is an unresolved

item

(50-410/88-08-02,

report paragraph

13.2).

DETAILS

1.0

Persons

Contacted

Nia ara

Mohawk Power Cor oration

(NMPC)

A.

G

~

M

G.

J.

J

L.

R.

"M.

J.

L.

V.

AJ

K.

D

A.

Athelii, Senior

EQ Engineer

Dean, Assistant Unit Superintendent,

I&C

Eldrige,

EQ Engineer

Eron, Assistant

Engineer,

Electrical Maintenance

Geier,

Lead Material Engineer

Gresock,

Manager,

Nuclear Engineering

Jirousek,

EQ Program

Manager

Kroehler,

Manager, Quality and Reliability Engineering

Lagoe, Site

I&C Supervisor

Main, Training

Hosier,

Lead Engineer,

Safety Analysis

Pace,

Manager,

Material Engineering

Plank, Training

Price,

EQ Engineer

Roy,

I&C Training

Savoca,

Associate

Engineer,

Mechanical

Maintenance

Sweet, Electrical

Maintenance

Superintendent

Weaver,

Lead Material Engineer

Zallnick, Manager,

Nuclear Licensing

1.2

Stone

& Webster

En ineerin

Cor oration

(SWEC)

A.

D.

L.

P.

C.

Dellagreca,

Senior

EQ Engineer

Hobman,

EQ Engineer

Illy, EQ Engineer

Si lverberg,

EQ Engineer

Zehrer,

EQ Engineer

1.3

Other Contractors

J.

R.

J.

J

~

N.

R.

C.

E.

W.

Anderson,

Engineering

Program Manager,, Wyle Lab

Demark,

EQ Consultant,

Gasser

Assoc.

Gleason,

Director, Nuclear Engineering,

Wyle Lab

Konu,

EQ Consultant,

Gasser

Assoc.

Luria, Manager, Quality Engineering,

GE

McClelland, Senior Program Manager,

GE

Nieh, Design Engineer,

GE

Schum,

Senior

EQ Engineer,

Wyle Lab

Shaffer,

EQ Engineer,

PATSCO

Lon

Island Li htin

Com

an

LILCO

M.

J.

Gannattasio,

EQ Section

Head

Kaczor, Senior

EQ Engineer

1.5

United States, Nuclear

Re viator

Commission

C. Anderson,

Chief, Plant

System Section,

EB,

DRS

W. Cook, Senior Resident

Inspector

"Denotes

those

not present at the exit meeting at the

NMPC Corporate

Office on April 22,

1988.

2.0

~Pur oae

The purpose of this inspection

was:

( 1) to review the licensee's

implementation of a program to meet the requirements

of 10 CFR 50.49 for

the Nine Mile Point Nuclear Station, Unit 2 (NMP2); (2) to evaluate

the

licensee's

actions

on the Limitorque valve operator

jumper wires

'esulting

from IE Information Notice 86-03 "Potential Deficiencies 'in

Environmental gualification of Limitorque Motor Valve Operator Miring",

and, (3) to evaluate

the licensee's

actions

on the installation of

Raychem cable splices resulting

from IE Information Notice 86-53

"Improper Installation of Heat Shrinkable Tubing."

3.0

~Back round

In February

1980,

the

NRC asked certain near-term operating

license

(OL)

applicants

to review and evaluate

the environmental

quali,fication

documentation

for each

item of safety-related

electrical

equipment

and to

identify the degree

to which their qualification programs

were in

compliance with the staff positions discussed

in NUREG-0588.

A final rule

on environmental qualification of electrical

equipment

important to safety for nuclear

power plants

became effective

on February

22,

1983.

This rule,

10 CFR 50.49, specifies

the requirements

to be met

for demonstrating

the environmental qualification of electrical

equipment

important to safety located in a harsh environment.

In conformance with

10 CFR 50.49, electrical

equipment. for NMP2 may be qualified according

to the criteria specified in Category II of NUREG-0588.

To document

the degree

to which the environmental qualification program

complies with the

NRC environmental qualification requirements

and criteria,

the licensee

provided equipment qualification information by letters

dated January

3, April 22, October

17,

and

November

20,

1985, to supplement

the information in

FSAR Section

3. 11.

Additional information was provided

in letters dated

February 4, April 9, August 18,

and August 21,

1986.

The

NRC staff reviewed the above information for, the adequacy

of the

NMP2 environmental qualification program for electrical

equipment important

to safety

as defined in

10 CFR 50.49..

In addition, the

NRC staff

conducted

an audit of the licensee's

qualification documentation

and the

installed electrical

equipment

on December

16-19,

1985.

Based

on the

results of the review and audit, the

NRC staff concl'uded that the

licensee

had demonstrated

conformance with the requirements

for

environmental qualification as detailed

in 10 CFR 50.49,

and relevant

parts of GDC 1 and 4,

and Sections II, XI, and XVII of Appendix

B to

10 CFR 50,

and with the criteria in NUREG-0588.

By lette'r's dated August

18

and August 21,

1986,

the licensee

informed the staff that all equipment

within the

scope of 10 CFR 50.49

was fully qualified..

4.0

Nine Mile Point

2

E

Pro

ram

The

NRC inspectors

examined

the implementation

and adequacy

of the

licensee's

EQ program for establishing

and maintaining the qualification

of electrical

equipment in compliance with the requirements

of 10 CFR 50.49.

The current Nine Mile 2

EQ program

was developed

by Stone

8

Webster

in accordance

with SWEC procedure

J.O.

No. 15600.09,

"Envir'on-

mental Qualification Document

(EQD)," dated April 9,

1987.

This program

is being transfered

from SWEC to

NMPC.

NMPC has developed

procedure

NEL-052 entitled "Nine Mile Point

2

EQ Program" dated

March 25,

1988 to

supplement

the Stone

5 Webster

EQD.

The Stone

5 Webster

EQD describes

how the

NMP2

EQ program was developed.

Section

2 identifies the plant zones

subject to harsh

environment.

Section

3 defines

the "functional performance

requirements".

This section

also identifies the systems

required for accident mitigation and the

systems

whose

components

require

EQ.

Paragraph

3.3 defines

the post

accident operability period requirements.

Table 3-2 identifies the

systems

subject to various type of accidents,

including

LOCA, HELB, and

MSLB.

Section

4 establishes

the methodology of equipment qualification,

including qualification basis,

aging, margins, radiation

dose rate

and

synergistic effect.

Section

5 establishes

the requirements

of qualifica-

tion documents

including the environmental qualification list (EQL) and

System

Component Evaluation

Work (SCEW) sheets.

NMPC procedure

NEL-052 supplements

the

SWEC

EQD to provide guidance

and

control of the

NMP2

EQ program.

Section

6 of this procedure

establishes

the

EQ requirements

as follows:

6.1

6.2

6.3

6.4

6.5

6.6'.7

6.8

6.9

6.10-

For

EQ

the

EQ

in the

EQ Design Criteria, Preparation

and

Use

Review of Plant Modifications

Determination of

EQ Procurement

Requirements

Review/acceptance

of

EQ Reports/Documentation

Qualification Alternatives

Installation Requirements

Maintenance

Requirements

Equipment Qualification File Requirements

Reevaluation

of Equipment Qualification Criteria

Non-Qualified Equipment.

i

documentation,

the

EQ program manager is responsible

to maintain

file in an auditable

form.

The following documents

are included

EQ file:

i

EQ Master List

EQ Environmental

Design Criteria

(EQEDC)

Equi pment Quali fi cat ion Document

(EQD)

System

Component Evaluation Worksheets

(SCEW)

Qualification Reports,

Suppliers

Document Data

Form (SDDF) file,

Vendor Qualification Reports,

Test Laboratory Reports

Post Accident Operating

Period

(PAOP) data

sheets

Mechanical

Equipment Qualification

(MEQ) Reports

Environmental

Calculations

Equipment Qualification Required Maintenance

(EQRM) and/or

EQ

Maintenance

Program

Data Sheet

(EQMPDS)

Vendor Technical

Information

EQ Correspondence

Materials/Parts

Evaluations

Equipment Qualification Studies/Analyses

EQ Field Verification Data

Equipment Qualification Review Checklist

Equipment Qualification Job Books.

Of these

documents,

items

a through i are controlled documents.

These

controlled documents

are subject to change with plant modification or

reevaluation

of

EQ parameters.

The inspectors

reviewed these

procedures

and.did not identify any

deficiencies.

5.0

Environmental

ualification List

E

L

The

NMP2 EQL is

a subset of the

NMP2 Master Equipment List (MEL) database

which is

a functional

module of NMPC's comprehensive

computerized

plant

information management

system for

NMP2.

The

MEL includes all plant

equipment,

including safety-related

and non-safety-related

equipment.

Its

many data fields include coding for numerous

equipment attributes,

some of

which are associated

with

EQ

There are three principal sets of fields on which the

MEL data

base is

indexed to generate

the

EQL.

These

are: (1) the Environmental

Zone

( location code);

(2) the Environment (harsh or mild); and,

(3) the

operability

Code

(OP Code).

NMP2

OP Codes

A, B, and

C correspond

to the

EQ functional operability categories

in Regulatory

Guide 1.89 or

categories

2.a,

2.b,

and 2.c, of Appendix

E of NUREG-0588.

Each

MEL

equipment

item with environment

code "harsh" is assigned

OP Codes

associated

with each

DBE that exposes it to

a harsh environment in which

it must function.

The

EQL consists of all

OP Code A,

B or

C equipment in a harsh

environment.

This breakdown

covers all equipment within the

scope of

10 CFR 50 '9 in that safety-related

equipment

under

10 CFR 50.49(b)(1)

and

post accident monitoring equipment

under

10 CFR 50.49(b)(3)

would be

OP

Code

A for harsh

environments

in which it must function.

Non-safety-related

equipment,

the failure of which would be detrimental

to safety,

under

10 CFR 50.49(b)(2),

would be

OP

Code

B for DBE harsh

environments

to which

it is exposed.

Non-safety

equipment

in

a harsh environment;

not supplied

with lE power or automatically i solable

from 1E power,

the failure of

which is not detrimental

to safety (including misleading the operator) is

listed in the

MEL with OP Code

C.

Equipment outside

the

scope of 10 CFR 50.49 due to its being in a mild environment is listed as,OP

Code

0 also

requiring qualification only for extremes of its normal service

conditions.

The assignment

of OP Codes

and the required operability times for plant

equipment to determine

EQL inclusion

and

EQ requirements

were based

on:

(1) the Final Safety Analysis Report; (2) Safety Evaluation Reports

(SERs)

and Supplemental

SERs;

(3) the

NMP2 NUREG-0588 submittal; (4) technical

specifications;

(5) emergency

operating

procedures

(EOPs);

and, (6) plant

equipment verification walkdowns.

The walkdowns

had not been

completed

(NMPC estimated 80'.'omplete)

at the time of this inspection

due to equip-

ment accessibility

problems

and

some

equipment with missing

nameplates

~

NMPC was scheduled

to complete the walkdowns

and verify all equipment

not

positively identified by nameplate

during the outage

scheduled

to start

on

May 6,

1988.

EQ engineering

work for NMPC on

NMP2 including development

and

maintenance

of the

MEL (including the

EQL) is done

under the supervision

of the

NMPC

EQ Coordinator.

The

EQ Coordinator supervises

the efforts of

NMPC

EQ engineering

personnel

and

NMPC's

EQ contractors/consultants.

Procedure

NEL-052 "NMP2 Equipment Qualification Program" Revision 0,

dated

March 1988,

governs the development

and maintenance

of the

EQL.

The development

and maintenance

of the

MEL are detailed in procedures

SSG-112

"Component Identification" and

SSG-104

"NMP2 Master Equipment

List," Revision 0, dated

Oecember

8,

1987.

Review of these

procedures

indicated that control of the

EQL is adequate.

Records pertaining to

deletion of

EQL items were also reviewed with no unjustified deletions

noted.

As a further validation check

on NMP2's

EQL, the Emergency Operating

Procedures

(EOPs)

were reviewed with NMP2 operations

personnel.

The

inspectors

selected

27 items of equipment required to be used with the

EOPs.

Of these

27 items,

18 were listed in the

EQL as qualified under

OP

Code

A or B, eight were non-safety-related

and

powered

from non-Class

lE

power supplies,

and

one was listed as safety-related,

but,OP

Code

C,

i.e., not required to function in the harsh environment.

The inspector

determined this classification to be acceptable.

6.0

NRC Information Notice

INs

and Bulletins 'EB

NRC INs and bulletins are handled administratively

as part of a program

called the

Commitment Tracking System.

The program is

a module of NMPC's

comprehensive

computerized plant information management

system

(which

includes the

EQL) and provides for distribution, tracking,

and assignment

of responsibility for correspondence

requiring action and/or response

Specific instructions for handling of NRC correspondence

including INs,

IEBs, inspection reports, etc.,

are contained

in

NMPC Procedure

NT-30,

"Control of Licensing Correspondence."

The inspectors

reviewed Procedure

NT-30, Revision

3 dated July 1,

1987.

It specified that all such

incoming material is routed according to

a

standard distribution list.

The inspector verified that the appropriate

EQ personnel

are

on the list.

The

NMPC,EQ Coordinator,

who was included

on the distribution list had established

a special file several

years

ago

of EQ-related

NRC INs and Bulletins.

The file contained all

NRC INs and

Bulletins considered

to be EQ-related

from Bulletin 79-01 through

IN 87-52

and reflected that they had

been dispositioned for NMP1 and

reviewed for NMP2 applicability.

They had

been dispositioned

for

NMP2

with the exception of a few that were under review.

Most of this file

had been transfered

to the

Commitment Tracking System.

The inspectors

did not identify any EQ-related

NRC initiatives for which

NMPC

disposition

was not adequate

and timely with the exception of IN 86-53

discussed

in Section

15.0.

The inspectors

reviewed in detail. the status of actions

on selected

EQ-related

INs and bulletins

and examples

are discussed

below:

IN 86-02 concerns

corrosion of magnesium rotors in Reliance

AC

motors for Limitorque valve actuators.

NMPC had determined that

testing of Limitorque actuators

with magnesium

motor rotors for GE

at Wyle Laboratories,

as reported in GE

EQ Report

NEOC-31049,

was

adequate

to qualify them for NMP2 applications.

All of the

18 such

MOVs at

NMP2 have

a required post,-accident operability time of one

day and are required to operate

only once during the accident/post-

accident

phase.

IN 86-71 deals with problems in Limitorque MOVs associated

with

energized

switch compartment

space

heaters.

NMPC's response

to this

issue

was to add this concern to the Limitorque walkdown checklist

and inspect all

EQL Limitorques for heaters

and wire burn damage.

Review of records

and discussion with NMPC personnel

indicated that

all heater

elements

found were de-energized

and removed,

and all

wiring which showed

any evidence of burn damage 'was replaced.

IN 86-104 concerns

Nylon insulated

crimp type wire joints in dual

voltage

AC Limitorque motors.

NMP2 has

no dual voltage

Limitorques.

IN 87-08 alerted

licensees

to degraded

insulation

on Peerless

DC

motor leads in Limitorque actuators.

A comprehensive

audit

performed

by

NMPC in cooperation with the Velan Valve Company,

NMP2's supplier of DC Limitorque motors, disclosed that two MOVs at

NMP2 had the subject

Nomex-Kapton insulated

motor leads.

Review of

maintenance

records

confirmed that both of these

MOVs had qualified

Raychem sleeving applied to each

motor

lead

as

recommended

by

Limitorque.

IN 87-52 concerns

insulation

breakdown of silicone rubber insulated

single-conductor

cables

during high-potential testing.

NMPC's

disposition of this issue

was documented

in

a Peter

Si lverberg

memo

to the

IE Notice file dated April 8,

1988.

,NMPC had reviewed

specifications

and procurement

documentation

and determined that

no

silicone rubber cable

had

been

ordered for NMP2 and that the

manufacturer

noted in the IN, American Insulated Wire Corporation,

was not

a supplier to NMP2.

NMPC had identified silicone rubber

insulated wire only as short lead wires in qualified components

such

as

ASCO solenoid operated

valves,

Reliance

fan and

MOV motors

and in

the Comsip hydrogen analyzers.

IN 86-03,

concerning potential deficiencies

in the

EQ of Limitorque

motor wiring, was reviewed

and discussed

in Section'4.0.

The licensee's

QA audit group conducted

an audit of the

NMP2

EQ program

(Audit No. SY-RG-IN-86-021), at the Stone

& Webster Corporate'ffice

in

Cherry Hill, New Jersey

and

NMP2 plant site

on December

3-10,

1986 'he

audit team consisted

of 3 auditors

and

a technical

specialist.

The

activities audited included:

1.

Stone

& Webster Engineering

processing

of vendor

EQ reports,

GE

SILs, Nonconformance

Reports

and

NRC IE bulletins and INs.

2.

Stone

& Webster Engineering effort related to equipment life

extensions

based

on

EQ requirements.

3.

Stone

& Webster Engineering extraction of maintenance

and

surveillance

requirements

from

EQ documentation.

10

4.

NMPC incorporation of maintenance

and surveillance

requirements

into

the appropriate

procedures.

5.

NMPC performance of EQ related

maintenance

and sur'veillance.

The audit was performed in accordance

with NMPC QA procedure

18. 10

"Quality Assurance

Department Audits" dated July 3,

1986.

The following

audit checklists

were

used

by the auditors during the audit:

1.

SY-RG-IN-8602-1

Identification and Performance

of Maintenance

and

Surveillance

Required to Maintain Equipment Qualification

2.

SY-RG-IN-86021-2 - Equipment Life Extension

Program

3

~

SY-RG-IN-86021-3 - Review of Modifications, Nonconformance

Reports,

Design

Changes

for Impact on Equipment Qualification

The results of this audit w'ere documented

in audit report SY-RG-IN-86021

dated January

26,

1987.

The report indicates that four findings were

identified.

Three of these findings required revisions of maintenance

procedures

and were resolved before June

18,

1987.

The fourth one

involved numerous

design-changes

and nonconformance

documents

which were

not reviewed

by the

EQ group or were reviewed incorrectly.

The resolution

of this deficiency was verified to be complete

by the

NMPC auditors

on

February

19,

1987.

The inspector

reviewed the audit documents

provided by the licensee.

No

unacceptable

conditions were identified.

8.0

E

Maintenance

Pro

ram

EQ maintenance

at

NMP2 is generally covered

under the

same procedures

described

in Section 5.0 for the discussion

of the

EQL.

Requirements

from the

EQ files relating to installation,

maintenance

and replacement

of qualification equipment

to establish

and maintain qualification status

are transmitted to the

NMP2 site via

EQRMs.

The site

EQ coordinator

and

the Electrical

and

ICC maintenance

engineers

translate

these

maintenance

requirements

into detailed installation,

maintenance

and surveillance

instructions.

They also

schedule

the maintenance

and surveillance acti-

vities to assure

that qualified lives are not exceeded.

They are then

incorporated

in the

NMP2's planned

maintenance

management

system.

NMP2's

computerized

system covers all aspects

of plant maintenance

including

EQ.

In addition to the

EQ program procedures

mentioned

above that include

EQ

maintenance

requirements,

the inspector

reviewed the following site

maintenance

procedures

that pertain in particular- to

EQ:

.

NMP2 Procedure

S-IDP-X-GEN-001, "Instruction for Writing, reviewing,

and Revising Instrumentatioa

and Control Procedures"

Revision 4,

dated

March 18,

1988.

NMNPS Maintenance

instruction S-MI-GEN-002, "Maintenance Instruction

for writing Procedures"

Revision 2, dated April, 1988

'dministrative

AP-8. 1, "Preventive Maintenance"

Revision

3 dated

July 27,

1987

NMPNS Electrical Maintenance

Procedure

S-ENP-GEN-003,

"Splice

Installation Procedure",

Revision

1, dated

March 11,

1988.

NMPNS Procedure

S-MI-GEN-004, "Maintenance Instruction for Review

and Implementation of Technical

Requirements

in Maintenance

Procedures"

~

NMNPS Procedure

AP-5.2, "Unit 2 Procedure for Repair," Revision 9,

dated

December 8,

1987

At the plant site,

the inspectors

examined

the computerized

maintenance

management

system.

Maintenance

supervisory

and planning personnel

demon-

strated

how

EQ related

maintenance

and replacement

requirements

from the

EQ files are incorporated

into maintenance

instructions

and schedules.

The inspectors

reviewed selected

samples

of surveillance

and maintenance

instructions for qualified components,

and the records of completed

work

orders.

The inspectors

also interviewed

NMP2 maintenance

superv'isors,

planners

and technicians.

The inspectors

concluded that

NMPC has satis-

factorily implemented their program at

NMP2 for preservation

of the

qualified status of

EQ equipment.

9.

E

Trainin

Pro

ram

During the course of this inspection,

the

EQ training program for

personnel

at

NMP2 was reviewed.

The engineering

department training

procedure

"NEL Procedures

Mod-80-EQ", dated

March 1987 delineates

the

licensee's

training program to provide, maintain

and upgrade

the training

and qualification status of the personnel

performing safety-related

design, modification, review,

and approval,

including

EQ related

activities.

The

EQ training program provides

personnel

training in the

following EQ areas:

NEL-028, Equipment Qualification (EQ Rule,

10 CFR 50.49)

NEL2-028,

Equipment Qualification Program (Unit 2)

NEL2-028.A,, EQ Design Criteria

NEL2-028.B,

EQ Procurement Activities

NEL2-028.C,

EQ Qualification Alternatives

'EL2-028.D,

EQ Vendor Document

Reviews

12

NEL2-028

~ E,

EQ Installation Requirements

NEL2-028.F,

EQ Maintenance

Requirements

NEL2-028.G,

EQ Documentation

and Files

NEL2-028.H,

EQ Change

Control

In addition,

the training department

has developed .training'procedures

for the Electrical

and

IKC Departments

at the plant site.

For the

Electrical

Maintenance

Department,

procedure

EM 225 dated August 1985,

provides

the

means of ensuring

the proper training for their job acti-

vities.

Also, monthly meetings

are held with the electrical

personnel

to

discuss

any

new issues e.g.,

IE Information Notices

and

IE Bulletins,

industry notifications etc., for EQ equipment.

The electrical

department

also

has

"hands-on" training for their maintenance

personnel.

Procedure

NTP-7 dated October

1986, establishes

training requirements for the

IKC

craftsmen

at the plant site.

This procedure

provides the means of ensur-

ing the proper

and continuing training of the

IKC personnel.

There are

other training courses

to supplement this procedure,

e.g.,

Lesson

plan

IC-201.8 entitled "Equipment Qualification" dated

March 1988.

Also

Instrument Maintenance

Procedures

were incorporated

into the training of

the

I&C personnel

at

NMP2.

The instrumentation

personnel

were included in

the monthly information me'etings with the electrical

department

to keep

informed on current issues

and changes

to

EQ procedures.

The training instructor

attended

outside training courses for Raychem

Splices

and Limitorque MOV's.

From these

courses

a required training

session

was developed

and administered

to all electrical

and

IKC

personnel.

Review of the training records

and discussions

with selected

personnel

administering

the training courses

indicated that quality

control

and design

personnel

performing

EQ related activities are included

in the train.'ng sessions

along with the technicians.

Based

on the above,

the inspector determined that the licensee

has

established

and implemented

an acceptable

EQ training program.

10.

E

Procurement

Pro

ram

The procurement

program for the

NMP2 plant has

been

in'

state of

transition for the past year.

During the construction

phase

ending in

July 1987,

Stone

and Webster

handled all procurement at

NMP2.

From July

1987 through

December

1987 procurement at

NMP2 was conducted

according to

NMPC Nuclear Engineering

and Licensing Procedures.

Procedure

NEL-015.G,

"Commercial

Grade

Procurement

and Dedication" formalized the process

through which NMP2 could purchase

commercial

grade

items

and dedicate

their

use in safety-related

functions at

NMP2;

Starting January

1,

1988,

all procurement at

NMP2 was conducted

according to Niagara

Mohawk

Procedure

Number NEL-015.M, "Procurement

Requirements

Evaluation

and

Dedication Planning

Procedures

"

This procedure'rovides

instruction for

the procurement

of all safety-related

equipment including

EQ equipment at

e

13

NMP2.

This

new procedure

encompasses

NEL-015.G (Commerical

Grade)

and

expands

the

scope

to include the procurement of all safety related

and

quality-related

equipment.

Procedure

NEL-015.M applies to the procurement of items for Nine Mile

Point

1 and

2 categorized

as Safety Related,

Quality Related,

and Non-Safety

or Modification related

items.

This procedure

may also

be applied to the

procurement of services.

The emphasis

of this evaluation is placed

on

items procured for use in Environmental Qualification applications.

The implementation of NEL-015.M is accomplished

by the included

"Procurement

Requirements

Evaluation

Form."

On the first page,

the item,

is identified as safety related,

whether or not it will be procured

as

commercial

grade,

and whether the item is subject to

EQ,

If it is subject

to

EQ, it is reviewed

by a member of the

EQ group that is assigned

to the

procurement

group

and serves

as liaison between

the two groups.

This

EQ

trained person

reviews the items according to Procedure

NEL-028, "Equip-

ment Qualification," then determines

the requirements

the item must

satisfy to meet the desired

EQ Level.

These

requirements

are listed in

detail

on the procurement

evaluation

form.

In general, if the item can

be procured

from the original supplier

who is

a qualified supplier of

nuclear grade parts,

and who will certify the part is the

same

as original-

ly purchased

and tested, it will be.

If not,

an attempt will be

made to

purchase

"Nuclear Grade"

from another (preferably) qualified supplier.

If

it becomes

the case that "Commercial

Grade"

must be purchased,

a "dedica-

tion program" must be undertaken

to qualify the item for use in

a safety-

related function.

Procedure

NEL-015.M details

the steps

which must be

followed to dedicatea

commercial

grade

item,

and includes

a Critical

Characteristic

Worksheet.

This worksheet details the attributes

the item

must possess

including:

configuration description,

materials/physical

properties

and appearance,

dimensions,

markings

and identification,

mechanical

and electrical functional requirements

and whatever test infor-

mation and certification is available.

The actual

means

by which

EQ is

established (i.e., type-test,

partial test plus analysis,

etc.) is

determined

by the

EQ group.

Within the

scope of this review,

no deficiencies

or anomalies

in the

NMP2

procurement

program were identified.

11.0 Control of

E

Related Modifications

NMPC uses

SWEC Project Procedure

(PP)'94 to establish

the responsibilities

and methods to control the identification, coordination,

implementation,

and documentation

of all plant modifications that have

an impact on

environmentally qualified equipment.

This procedure is applicable to all

changes

which affect environmental,

mechanical,

and/or seismic/hydrody-

namic qualification of equipment which falls within the following areas:

14

Equipment modifications

Changes

to environmental. parameters

Changes

in the seismic

and dynamic loads

Changes

in the location of equipment

Changes

in design details which affect the structure,

materials,

and

mounting configuration or orientation of the

equipment'hanges

made to the equipment interfaces

Changes

in process

design conditions

Changes

involving safety-related

non-metallic material

Changes

in post accident operability period data.

The

SWEC lead

EQ engineer

and the site engineering

group are responsible

,for initiating a change within the

scope of this procedure.

The lead

EQ

engineer is responsible

to ensure that the completed

check list (Reviewer

Checklist to Determine Effects of Change

on Category

1 Electrical

and

Mechanical

Equipment Qualification) is technically correct

and consistent

with licensing requirements.

He is also responsible

to provide the Equip-

ment Qualification Action Item (EQAI) forms for concurrence

as applicable;

and when requested,

provide assistance

in completing the checklist 'and

providing technical justification for NO IMPACT statements.

The assistant

to the project Engineer

(ATPE-EQ) is responsible

for

monitoring the review changes

which affect the qualification of equipment

and ensure that all open

and action items identified on the

EQAI are

logged, filed, and properly dispositioned.

In addition, the ATPE-EQ is

responsible

to ensure that the

EQ lists are reviewed

and that

a sequential-

ly numbered

log identifying and tracking the

EQAI has

been established.

The inspectors

reviewed three modification packages.

Each of these

packages

contained

the necessary

documentation

to show that the

EQ

modification program is being

implemented.

The three modification

packages

reviewed were

as follows:

~

Modification No.

PN2Y87MX133 (EQAI No, 226) - Elapsed

Time Meters

Added to Control Circuit of 2HVC*FN2A and. 2B Fans

~

Modification No.

PN2Y86MX031 (EQAI No.

233

Rev.

1) - Relocation of

Temperature

Switches

2HVR*TIS31A and

B

~

Modification No.

87MX229 (EQAI No. 246) - Relocation of Transmitters

No.

ZGTS*PDTSA and

B

'll EQ requirements

are addressed

in these modification packages,

such

as

the

EQ master list,

EQ files,

and qualification documentation.

Within the

scope of review of the plant

EQ modification activities,

no

deficiencies

were identified.

A

15

12.0 Detail

Review of

E

Files

The licensee's

EQ files were examined to verify the qualification status

of equipment within the

scope of 10 CFR 50.49.

In addition to comparing

plant service conditions with qualification test conditions

and verifying

the basis 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 (insulation class,

component materials,

test configuration versus installed configuration

and documentation for 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

equipment accuracy;

evaluation of

test anomalies;

and applicability of

EQ problems reported

in IE Bulletins

and Information Notices

and their resolutions.

The inspectors

reviewed fifteen

EQ files,

The types of equipment

covered

by these files included areas

such

as electrical

cables,

terminal blocks,

Limitorque valve operator s, limit switches,

solenoid operated

valves,

electrical

penetrations,

triaxial connectors,

cable splices,

and

radiation detectors.

An equipment

type is defined

as

a specific type of

electrical

equipment,

designated

by manufacturer

and model, which is

representative

of all identical

equipment in the plant area

exposed

to

the

same or less

severe

environmental

service conditions.

The following

were noted during the inspection:

12.1 Limitor ue Valve 0 erators

Job Book PP304R

EQ Job book No.

P304R is the master file containing the environmental

qualification documentation

for all

149 Limitorque MOVs'on the

EQ

master list at

NMP2.

Placement of these

MOVs include

23 in the

drywell,

5 in the main

steam tunnel,

and the remainder at various

locations

in the Reactor Building.

During the course of the file review, three

concerns

arose that were

successfully

resolved prior to the exit meeting.

They are discussed

briefly as follows:

a.

Similarit

Anal sis for the Buchanan

0222 Terminal Blocks

Some Limitorques in the drywell and

steam tunnel at

NMP2 utilize

Buchanan

0222 terminal blocks.

NEDC-31049, which documents

a

test performed

by Wyle for General Electric (GE),

was

used

as

the basis for the qualification of these

Buchanan

terminal

blocks in the

NMP2 Limitorques.

The document

does

not spe-

cifically identify the terminal blocks used in the type test

as

0

16

Buchanan

Model 0222.

During the course of the inspection,

GE

personnel

retrieved the terminal block used in the

NEDC-31049

test, definitely identified as

a Buchanan,

then,-via matching

physical characteristics

with the Buchanan

G'-100 catalog,

identified it as either

a Model 0212 or a Model 0222.

The only

difference is that Model 0212 has

a plain marking area while

Model

0222

has

a painted marking

arear'he

inspector

had

no

further questions.

b.

Terminal Blocks

T

e Tested at 460

Y versus

E ui ment

A

lications at

575 V.

NEOC-31049 type tested

Marathon

300 and

Buchanan

0222 Terminal blocks at 460

V whereas

the

NMP2

Limitorques are operated

at 575 V.

This issue

was successfully

addressed

during the inspection

by the license presenting

evidence

showing the only increase

in failure mechanism

due to

higher voltage is tracking to ground under

100% moisture

conditions.

Both the subject terminal blocks are rated at 600

V and were

UL tested

wetted with a

1% Ammonium Chloride

Solution, which is more conductive

than water, at 600 V. .Both

of these

terminal blocks are

UL rated

PLX ¹1 (400

599.9

V)

indicating that

a material

in this class will perform

identically within the entire

range which includes

both 460

V

and

575

Y.

The inspector

concurred with this analysis

and

concluded

the

575

Y application for the Limitorque terminal

blocks at

NMP2 is acceptable.

Reliance

AC Motors Used

on Limitor ue

MOVs T

e Tested at

460

V and

Used at

NMP2 at 575 V.

The licensee

demonstrated

the

Reliance

AC motors

used at

NMP2 are the

same

as those

type

tested

in NEDC-31049 except the

number of turns in the

NMP2

primary motor windings were increased

in order to maintain the

standard volts per turn in the coil.

Since the horsepower is

the

same,

the normal operating

and locked rotor amperage

is

less for the

575

V motor and the type test results

from

NEDC-31049 for the

460

Y motor conservatively

bound the

575

V

motor application at

NMP2.

The inspector concurred with this

analysis

and considered this issue closed.

12.2 Litton Veam Connector

(Job Book ¹E061A)

The test report

used to qualify the Litton Yearn connectors

was

an

Isomedix document entitled "Test conducted

by Isom'edix Inc. for

Litton Products International," dated

February

1978.

The model

numbers tested

were CIR030-28-51

and CIR06RK-22-23.

Only one Litton

Yearn connector is used at

NMP2. It was installed

on

a bulkhead

inside the primary containment,. connecting

the cable for a

NAMCO

limit switch which sends

a signal to the control

panel

indicating ihe

position of air operated

valve 21CS"AOV157.

This position indication

is required to satisfy the requirements

of Regulatory

Guide

1

~ 97.

17

gualification deficiencies of Litton Veam connectors

had

been

identified at other plant sites

because

of low insulation resistance

issue.

The connector -at

NMP2 is for control application only.

Low

insulation resistance

is not

a serious

concern.

The licensee's

Field Verification Photo erroneously

showed the Litton

Yearn connector

as

an in-line junction box number 21CS*JB1995.

Because of this error, the licensee

has

committed to walking down the

connector during the next power outage to verify the installed con-

nectors

are the

same

as described

in the test report supplied

by

Isomedix.

13.0 Plant

Ph sical

Ins ection

The

NRC inspectors

conducted

a physical

inspection

on April 20,

1988, of

EQ components

in the Reactor Building at various elevations.

No items

were selected

in the primary containment

because

of its inaccessibility

during plant operations.

Items selected for examinations

included

Limitorque valve operators,

limit switches,

solenoids

operated

valves,

cables

and cable splices.

The inspectors

examined characteristics

such

as mounting configuration,

orientation,

connection interface,

model

and instrument type, cleanliness

and physical condition.

The. following deficiencies

were identified:

, 13. 1

Ra

chem Cable

S lices

During the plant walkdown on April 20,

1988, while in the Reactor

building, the inspectors

identified that the

Raychem cable splices

associa.ed

with the following transmitters

had seal

length less than

1 inch:

~

Flow transmitters

CSL*FT126 (GEPE21-N003)

in environmental

zone

SC175102

~

Pressure

transmitter

CSL*PT109(GEP21-N052)

in environmental

zone

SC175102

~

Level transmitter

SFC*LT32A in environmental

zone

SC328197

The qualification documents

in the

Raychem Splice

E(} file indicate

that the minimum seal

length for the

Raychem splices

in these

areas

must be

1 inch to meet <he qualification requirements.

The

inspectors

concluded -that-~he qualification of these

Raychem splices

was not established

at the time of the inspection.

. This is in

violation .of 10 CFR 50.49 paragraph (f) which requires

each

item of

electrical

equipment important to safety

be qualified

(50-410/88-08-01).

18

13.2

During the week of the inspection,

the licensee

was able to show

that the splices

in question

were qualifiable for'heir applications

in their relatively less

severe

environments.

NMPC was able to

obtain Wyle Laboratories

Nuclear Environmental Qualification (NEQ)

Report

No.

17859-02P which documents

a test

ML17055E006

Text

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