ML17199F914
| ML17199F914 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/08/1986 |
| From: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17199F915 | List: |
| References | |
| NUDOCS 8609120295 | |
| Download: ML17199F914 (7) | |
See also: IR 05000237/1986013
Text
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September 8, 1986
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. Docket Nos.:
50-237 and 50-249
License Nos.:
Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
Vice *President . *
Post Office Box 767
Chicago, Illinois 60690
Gentlemen:
SUBJECT:
INSPECTION NOS_.([0-237f86W; 50-249/86015
Enclosed is the report bf the team inspection conducted by Mr. A.
R~- Johnson
and other NRC representatives on May.19 to 23, 1986, at the Dresden Nuclear
Power Station, Units 2 and 3, of activities authorized by License Nos. DPR-19
and OPR-25.
The team's findings were discussed with members of your staff at
the conclusion of the inspection.
The inspection reviewed your implementation
of a program for establishing and maintaining the qualification of electric
equipment within the scope of 10 CFR 50.49.
The inspection also included evalu-
. ations of the implementation of equipment qua,ification (EQ) corrective action
commitments made as a result of identified defici~ncies of (1) the February 12,
1986 Safety Eva-luation Reports (SERs) for Units 2 and 3; (2) the December 29,
1982 SER and June 22, 1982 Franklin Research Center (FRC) Technical Evaluation
Report (TER) enclosed with it for Unit 2; (3) the December 29, 1962 SER and
July 21, 1982 FRC TER enclosed with it for Unit 3; *and (4) your proposed method
of resolution for each of these EQ deficiencies documented in responses from you
(June 3, 6, and 11, 1983, October 5, 1983, March 30, 1984, May_.21, 1984, July 2,
1984, February 14, 1985, and January*3, 1986)~. Within these areas, the inspection
consisted of the examination of selected procedures and records, interviews with*
personnel, and observations by the inspectors.
The inspecti~n determined that you have implemented a program to meet the require-
ments of.*10.CFR 50.49 .*
Six deficiencies**with respect to your program implemen-
tation, involv.ing EQ documentation files and physically installed configurations
- of equlpment-**in both plants, are summarized in Appendix A and are classified as
Potential * Enforceinent/Unresol ved Items and wi 11 be. referred to the NRC Region I I I
office for further action. All six Potential Enforcement/Unresolved Items
represent failures to *fully establish the qualification of the followirig
equipment:
Amp nylon insulated butt splices, BIW cable, GE type SI Vulkene
cable, Raychem splices, Limitorque motor operators, AVCO solenoid valves, and
Dresser solenoid valves. Twelve concerns are classified as Open Items and a
future NRC inspection will review your actions concerning them .
Details 6f all deficiencies and concerns are discussed in the ~nclosed inspection
report ..
8609120295 860908
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- Conmonwea 1th Edi son Report
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September 8, 1986
Your letter of *June 12, 1986 (Commonwealth Edison to USNRC, Office of Inspection
and Enforcemek:t~}!.~cprovid*ing additional. information subsequent to the NRC inspec-
tion, addres'sfn~*'the* inspection findings and proposing methods of resolution, has
.been reviewed.* With regard to.your comments conc.erning the conditions of
Limitorque motor operated valves, the NRC inspection team identified significant.
degradation of cables and cable terminations within the valve operator limit
switch housing assemblies. This condition was apparently caused by improper
or inadequate installation or maintenance.
We acknowledge your effort to upgrade
your station's maintenance and surveillance program for equipment required to
.be environmentally qualified. Specifically, we recoimnend that increased
attention should be given to the Dresden Station Limitorque maintenance and
surveillance inspection checklist criteria, in monitoring installed cables with
respect to deterioration during your maintenance and.surveillance activities.
Al~o, the apparent cable cuts, cracks, discoloration, etc., observea by the NRC
inspection team should be evaluated to confirm that these defects affect only
the outer cable jacket and do not degrade the cable insulation. Outer cable .
degradation would be acceptable only where qualification testing clearly
demonstrates that the c6nductor jacket or ov~rall cable jacket is not
significant with respect to qualification. Further, continuing your program
involving your checklist criteria should preclude cases of loose termination*
studs on torque/limit*switches, broken wires to limit switch contacts, and
. *
broken jumper wires to torque switch contacts, as found by the NRC inspection
team.
- *
We also acknowledge your corrective action commitments concerning the qualification
of Amp nylon insulated butt splices. *These wi.ll be reviewed during a future
_inspection.
Your corrective actions regarding other identified deficiencies in the enclosed
inspection report should not be delayed pending either a future NRC inspection
-0r further action by the NRC Regiori III office.
We are availabl~ to discuss any questions you have concerni~g th~s inspection~
Enclosures:
Sincerely,
F. Heishman, Chief
- Vendor Program Branch
- Division of Quality Assurance, Vendor
~nd Tech~ical Training Center Prog~ams
Office of Inspection and Enforcement
1.
Appendix A-Po ten ti al Enforcement Unresolved Items
2.
Appendix B-Inspection Report Nos. 50-237/86013,
and 50-249/86015
cc w/enclosures:
See next page
Commonwealth Edison Company
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Route 1
Morris, IL
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D. L Farrar, .JU rector
of Nuclear"tfcensing
Commonwealth Edison Company
Post Office Box 767
Chicago, Illinois 60690
D. J. Sc6tt, Plant Manager
Dresden Nuclear Power Station
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.Rural Route #1
Morris, Illinois 60450
Phyllis Dunton, Attorney General's Office
Environmental Control Division
-160 North LaSalle, Suite 900
Chicago, 111.inois 60601
September 8, 1986
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- APPENDIX A
- Potential Enfcf~e~fflent/Unresolved Items
~~ ....
As a result of the special equipm,E!nt_ *qualification inspectiOn of May 19 to 23,
1986, the following items have been referred to NRC Region* III as .. eotential ..
Enforcement/Unresolved Items (paragraph references are to the detailed portions
of the inspection report) .
.. 1.
Contrary to. paragraphs '(f) and (k) of 10 CFR 50.49 and Section 5.2.2. of
the DOR Guidelines, for approximately 400 AMP nylon insulated butt splices
installed with GE electrical penetrations in Unit 3, the files did not
adequately establish qualification because of failure to demonstrate
similarity between the tested and installed components~
No anplysis.
linking the .GE splice test results and test materials with tho~e supplied
with the FOi electrical penetrations were available in the Equipment
Qualification File (EQF) *. (Paragraph 4.F(l), 50-249/86015-01). *
2.
Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.5 of
the DOR Gujdelines, the EQFs for BIW cable, GE SI Vulkene cable, and Raychem
splices did not adequately demonstrate qualification because of failure
to show that plant functional performance requi.remerits were satisfied.
No *
analyses contained in the documentation files address how parameters
- measured during type tests (leakage currents, !R's, would affect Dresden
plant circuits (Paragraph 4.F(2), 50-237/86013-02; 50-249/86015-_02).
3.
Contrary to paragraphs (f) and (1) of 10 CFR 50.49, the documentation files
- for AVCD ~olenciid valves, model C5450-4 did not adequately establish qual-
ification for replacement solenoid valve model C6948 because of failure to
demonstrate similarity between the type tested and the installed replace-
ment solenoid valve. Also, no analysis was cqntained in the qualification
file to support maintenance intervals of 10 to 12 years, contrary to the
manufacturers recommended 12 to 18 months for the replacement part. (Para-
graph 4.F(9), 50~249/860~5-03). *.
-
4.
Contrary to paragraph (f) *and (k) of 10 CFR 50.49 and Section 5.2.2 of the
- DOR Guidelines, EQFs for Dresser solenoid valves model
15~5VX, us~d on the
main steam lines. for Unit 2, did not adequately establish qualification
because of failure to demonstrate similarity between the tested and installed
components.
No.evidence was contained in the documentation files which
could demonstrate that the PVC jacketed shunt wiring to the solenoid
(supplied by the manufacturer) had been replaced with EQ qualified wiring~
in accordance with the manufacture~'s statement of qualification contained
in the file.
(Paragraph 4.F(lO), 50-249/86015-:-04) ~
5.
Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.6 of
the DOR Guidelines, the installed condition of six Limitorque motor
operators, located inside and outside the drywell, was not the same as
qualified by type test due to improper installation and/or inadequate
maintenance, in that the condition of cable and cable terminations showed
significant-deterioration.
(Paragraph 4.H(l), Item 50-237/86013-05;
50~249/86015-05).
- ~ '
- 2 -
6.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and paragraph
B.3.f of Dresden Administrat*ive Procedure OAP 11-14, Revision 1, the
responsible maintenance group at Dresden failed to follow procedures
in not performing semi-annual reviews and preparing an EQ Equipment
. Maintenance Annual Summary Repo*rt .to identify EQ related exp.eriences
to the Dresden plant management (Paragraph 4.C(l), 50-237/86013~06;
50-249/86015-06).
.