ML17278A952
| ML17278A952 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/25/1986 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17278A951 | List: |
| References | |
| 50-397-86-12, NUDOCS 8608070366 | |
| Download: ML17278A952 (31) | |
See also: IR 05000397/1986012
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report No.:
Docket No.:
Licensee:
Facility Name:
Inspection At:
'50-397/86-12
50-397
Washington Public Power Supply System
Post Office Box 968
Richland, Washington
99352
WNP-2
WNP-2, Benton County, Washington
Inspection
Conducted:
April 28 to May 2, 1986
Inspector:
R.
C. Wilson, Equipment gualification
" and Test Engineer
7/ZS /FC
Date
0
Also participating in the inspection
and contributing to the report were:
U. Potapovs,
Chief, Equipment gualification Inspection Section,
I&E
R.
N. Moist, Equipment gualification and Test Engineer,
I&E
T. Young, Chief Engineering Section,
Region
V
J.
F. Burdoin, Reactor Inspector,
Region
V
D. J. Willett, Reactor
Inspector,
Region
V
D.
E. Jackson,
Consultant
Engineer,
Idaho National Engineering Laboratory
M. Trojovsky, Consultant
Engineer,
Idaho National Engineering Laboratory
J.
Grossman,
Member of Technical Staff, Sandia
National Laboratories
Approved By:
gag~ 2~ U/o
U. Potapovs,
C ief, Equipmen
gualifica-
tion Inspection Section,
Vendor Program
Branch
v/zs-/is
Date
t
8b080703bb
Bb0730
- DOCK 050003'V7
G
I
'L
INSPECTION
SUMMARY
!ns ection
on
A ril 28 to
Ma
2
1986
Ins ection
Re ort No. 50-397/86-12
Areas
Ins ected:
Special,
announced
inspect~on
to review the licensee's
imple-
mentation
o
a program per the requirements
of 10 CFR 50.49 for establishing
and maintaining
the qualification of electric equipment within the scope of
Results:
The inspection determined
that the licensee
has
implemented
a program
to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed
below.
Kame
Potential
Enforcement/Unresolved
Items:
~R
"P
h
I
N
b
1.
2.
3.
5.
Rosemount
1151 transmitters
4.D. {1)
Limitorque operators
4.D.(2)
Rockbestos
cable
4.D.{3)
low voltage contain-
4.D.(4)
ment penetrations
Procedural
deficiencies
4.D.(5)
a.
Victoreen'igh range radiation monitor
b.
Conax connector for HRRM
c.
Barber Coleman motor
d.
Rosemount
1151 transmitters
50-397/86-12-1
50-397/86-12-2
50-397/86-12-3
50-397/86-12-4
50-397/86-12-5
1.
2.
3.
Comp 1 etion of tra ini ng
Master List updating
Completion of Act~on on Noncon-
formance
Reports
a.
b.
Radiation rack preamplifiers
c.
Target
Rock solenoid valve
4.A
4.C
4.D.(6)
50-397/86-12-6
50-397/86-12-7
50-397/86-12-8
DETAILS
1.
Persons
Contacted
Washin ton Public Power
Su
1
S stem
WPPSS:
- C
- J
- J
- K
J.
- L
M. Powers,
Plant Manager,
WNP-2
W. Baker, Assistant Plant Manager
E. Rhoads,
Manager Equipment
equal.
Engrg.
R. Wise, Technical
Program Leader,
Eg
P. Burn, Director of Engineering
T. Harrold, Asst. Director, Generation
Engrg.
1.2
- N. S. Porter,
Manager, Electrical
and
I&C Systems
Engrg.
- G. W. Brastad,
Technical Specialist,
E'lec/I&C Engrg.
- K. D. Cowan, Plant Technical
Manager
- R. J.
Barbee,
Plant Technical
Supervisor
- R. L. Koenigs, Plant Technical
Supervisor
- M. R. Wuestefeld,
Plant Technical
Supervisor
- D. A. Armstrong, Tech.
Program Leader,
Mechanical
Eg
J.
D. Harmon, Manager,
Maintenance
J.
W. Hedges,
Maintenance
Engineer
- E. R. Ray,
I&C Maintenance
Supervisor
S.
Goodwin, Electrical Maintenance
"D. S.
Feldman,
Plant
gA Manager
- M. Bartlett, Plant
gA Supervisor
- C. H. McGilton, Assurance
Programs
Manager
- P. L. Powell, Manager, Licensing
'W.
S. Davison, Plant Compliance
Engineer
,J.
L. McDonald, Materials Mgt. Specialist,
Procurement
- J.
D. Martin, Asst.
Manager Director, Operations
- R. E. Partrick, Adm'inistration
- D. W. Porter,
Manaoer,
Engineering
Systems
Support
- S. S. Mabley, Secretary,
Eg Engineering
M. S. Robinson,
Sr. Engineer,
Eg Engineering
W.
E. Faraone,
Sr. Engineer,
E(} Engineering
R. Call, Engineer,
Eg Engineering
M. Widmeyer,
I&C Engineering,
Plant Technical
R. Abbot, Principal Engineer
R. Mathews, Engineer
- B. Fitch, Executive Secretary,
Energy Facility Site Evaluation
Council
- W. E. Eillbrot, Nuclear Engineer,
Bonneville Power Administration
A. J.
Papacz,
Plant Representative,
Bonneville Power Administration
D.
L
Williams, Engineer,
Bonneville Power Administration
WPPSS Consultants:
1.3
- S. H. Peck, Plant Tech.
Spare
Parts - Impell
- J. V. Costello,
E(} Engineer - Impell
M..White,
Eg Engineer - Impell
Observer
- D
D. Malone, Sr.
I&C Supervisor, Pacific
Gas
and Electric, Diablo
Canyon
- R. C. Barr, Resident
Inspector
- R. T. Dodds, Senior Resident
Inspector
- Denotes
those
present at exit meeting at WNP-2 on Nay 2, 1986.
PURPOSE:
The purpose of this inspection
was to review the licensee's
implementation
of a program meeting the requirements
of 10 CFR 50.49.
BACKGROUND:
WNP-2 is an
NTOL plant and the
NRR Eg review is documented in the Operating-
License
SER NUREG-0892 dated
March 1982, together with Supplemerit
3 dated
May 1983
and Supplement
4 dated
December
1983.
Original plant equipment is
qualified to NUREG-0588 Category II.
Significant WPPSS submittals
addressed
in the
SER supplements
are dated January
14,
1982;
September
15, 1982; Jan-
uary 31,
1983; June 30,
1983;
and September
16,
1983.
FSAR Amendments
32
dated
September
1983 and 33 dated
November
1983 extensively
address
the
Eg
program.
The staff also performed
an on-site audit of ten files and
a
plant walkdown from February
15 to 17, 1983.
Certain license
condi tions
and amendments
provided extended
deadlines for completing qualification of
certain equipment.
At the time of inspection prior to startup
from the
plant's first refueling outage, all equipment within the scope of 10 CFR 50.49
was required to be qualified except
the following items, addressed
in license
Amendment
No. 25, which was issued
on May 23,
1986:
(a)
Flux monitoring and suppression
pool level instrumentation
under
R.
G.
1.97 need not be qualified until startup
from the second refueling
outage.
(b)
Other
R.
G. 1.97 instrumentation
requiring qualification must
be
qualified prior to startup following the first refueling outage.
FINDINGS:
The
NRC inspectors
examined
the licensee's
program for establishing
the
qualification of electric equipment within the scope of 10 CFR 50.49.
The
program
was evaluated
by exam~nation of the licensee's
qualification docu-
mentation files, review of procedures
for controlling the licensee's
Eg
efforts, verification of adequacy
and accuracy of the licensee's
10 CFR 50.49 equipment list, and examination of the licensee's
program for main-
taining the qualified status of the covered electrical
equipment.
W
Based
on the inspection findings, which are discussed
in more detail
below,
the inspection
team determined
that the licensee
has
implemented
a program
to meet the requirements
of 10 CFR 50.49, although
some deficiencies
were
identified.
A.
E
Pro
ram Procedures
The
NRC inspectors,
to evaluate
the implementation of the Licensee's
"Environmental
Equipment gualification Program"
as required
reviewed the following listed instructions
and procedures:
En ineerin
Instructions
(EIs
EI 2.1,
Rev. 6, dated
February
14, 1986, "Preparation of WNP-2 Design
Change
Packages."
EI 2.35,
Rev. 3, dated October 2, 1985, "Master Equipment List (MEL)
. Update."
EI 2.40,
Rev. 4, dated August. 29,
1985, "Instructions for Special
Design
Review."
Technolo
Instructions
TIs
TI 2. 11,
Rev.
1, dated January
14,
1985, "Evaluation Procedure
and
Acceptance Criteria for WNP-2 Safety Related
Equipment gualification."
TI 2.12,
Rev. 0, dated
September
13, 1984,
"Type Testing of Class
1E/
SRM Equipment."
TI 2. 13,
Rev. 0, dated July 17, 1984,
"Procedure for Incorporating
Equipment gualification Requirements
for Equipment Important to Safety."
TI 2. 15,
Rev. 2, dated
December 5, 1984, "Preparation,- Verification, and
Approval of Calculations."
TI 2.56,
Rev. 0, dated
November 20,
1984,
"Use and Control of Radiation
Analysis Standards."
Plant Procedures
Manual'PM
PPM 1. 15,
Rev. 9, dated
May 14,
1985, "Organization
and Responsibilities,
Plant Operations
Committee."
PPM 1.3.7,
Rev. 6, dated April 22,
1985,
"Conduct of Operations;
Main-
tenance
Work Request."
PPM 1.3. 13,
Rev.
13, dated
February 7, 1985,
"Conduct of Operations;
Material, Equipment, Parts,
and Supplies
Procurement."
PPM 1.3.25,
Rev. 4, dated
March 25,
1986 "Conduct of Operations,
Master
Equipment List."
PPM 1.3.39,
Rev. 0, Preliminary,
"Conduct of Operations,
Plant Technical
Procurement
Review."
PPM 1.4. 1, Rev. 4, dated
March 3, 1986, "Plant Modifications."
PgA-03,
Rev. 6, dated October 1, -1985, "guali ty Assurance/guality
Control
Instruc4ions."
Mainhmance
1
PPM 10.1.5,
Rev. 8, dated April 4, 1986,
"Maintenance Administrative
Procedures,
Scheduled
Maintenance
System."
PPM 10.1.21,
Rev. 0, dated April. 28, 1986,
"Maintenance
Procedures,.
Maintenance of Environmentally gualified Equipment."
l
Areas of the Licensee's
program reviewed to verify that adequate
pro-
cedures
and controls
had been established
included methods
and their
effectiveness
for:
a ~
b.
C ~
d.
Requiring all equipment that is located in harsh
environments
and
is within the scope of 10 CFR 50.49 to be included
on the list
of equipment requiring qualification
(EQ Master List),
Controlling the generation,
maintenance,
and distribution of the
EQ Master List.
Defining and differentiating between mild and harsh environments.
Establishing
harsh environmental
conditions at the location of
equipment
through engineering
analysis
and evaluation.
e.
Establishing
and maintaining
a file of plant conditions.
f,
Establishing,
evaluating,
and maintaining
EQ documentation.
go
Training personnel
in the environmental qualification of equipment.
h.
Controlling plant modifications such
as installation of new and
replacement
equipment,
and providing for updating replacement
equipment to 10 CFR 50.49 criteria.
Establishing Quality Assurance
and Quality Control of the various
aspects
of equipment qualification.
j.
Establishing controls for the procurement of qualified equipment.
As part of the program review, the inspectors
examined
records
and met
with personnel
of the following groups:
a.
Generation
engineering
b.
Quality Assurance
c.
Electrical
and
ISC Systems
d.
EQ engineering
e.
Maintenance
The inspectors
examined in detail
the degree
and effectiveness
of QA
invo~ment to verify the Licensee's
compliance with 10 CFR 50.49
and
QA program requirements.
During this year the
QA organization
has
conducted
a comprehensive
surveillance of the site
EQ program.
This
surveillance
delved into the following activities:
procurement, in-
stallation
and maintenance,
C1E qualification methodology
and the
applicable
procedures,
EQ records retention,
and
EQ engineering,'s
train-
ing and experience
records.,
Review of Surveillance
Report 2-85-169
and
interviews with QA staff show a significant
QA involvement in the
EQ Program.
Deficiency reports
were issued
to the responsible
organ-
izations
and corrective actions
were followed-up.
Response
to
findings has resulted in improvements
to the
EQ Program.
Review of training records
revealed
a weakness
in this area.
The program
procedures
did not specifically identify formal training of the
Program
and requirements for qualification of equipment in the various
activities.
The
EQ engineering
had developed
a ten minute'film on
some aspects of EQ requirements
which was
shown to the various groups.
A sampling of these
groups
(QA/QC, maintenance,
and generation
engin-
eering) revealed
that none of the
QC inspectors
had seen
the film.
A
future
NRC inspection will verify that all personnel
involved in the
EQ program have received training and that appropriate
procedural
changes
are
made.
Completion of training constitutes
open item 50-
397/86-12-6.
8ased
on this review, it is concluded that, with the exception of the
open item identified above
and the deficiencies
discussed
in section
4.D(5), the licensee's
procedures
and their implementation
are ade-
quate to assure
that Licensee's
EQ program will function as designed.
E
Maintenance
Pro ram
The inspector held discussions
with managers
and staff responsible for
directing and implementing programs
to maintain the required environ-
mental qualification of equipment,
and the maintenance-related
proce-
dures listed above were reviewed.
The Scheduled
Maintenance
System
(SNS) identifies environmentally qualified equipment
by a green
SMS
card.
The
SMS is
a computer-based
maintenance
and surveillance
manage-
ment system which contains
component data;
maintenance
schedules;
records
of maintenance;
seismic, fire protection
and
EQ status;
and similar
information.
SNS is used
as
an on-line maintenance/surveillance
order
initiation, planning,
and tracking system.
The basis
for the
EQ-
required maintenance activi ties is the Qualification Related Mainten-
ance
Summary sections
of the Qualification Information and Documentation
files.
When equipment requires
scheduled
or unscheduled
maintenance
the work
is initiated by a work request.
The Maintenance
Programs
group reviews
the equipment
number against
the master
equipment list to determine
if it is environmentally qualified and identifies it as
such
on the
work request.
Planning/Scheduling
reviews the Engineering
Drawings
N397
5 %44 (these
are really not drawings but data)
to determine if
any special
instructions exist related
to maintenance
of the specific
equipl1lhnt ID, and if so incorporates
these
special
instructions into
the work request.
"Drawing M937" identifies ageable
component replace-
ments required
through 1989; "drawing M944" identifies special
main-
tenance practices.
Appropriate Quality Control inspection
and Quality
Assurance
reviews are accomplished,
as appropriate,
by work request
processing.
The inspector reviewed records of completed
and in-progress
maintenance
packages.
Among the selected
maintenance
packages
were those
from
components
previously chosen for AID file review and physical walk-
down inspection.
As previously identified, the inspector talked with:
Technicians
who performed the work, responsible
system engineers
and
supervisors
and
gC inspectors
who witnessed
required tasks.
No defi-
ciencies
were identified.
E
Master List
The licensee is required to maintain
an up-to-date list of the equip-
ment that must
be qualified under
This list is entitled
"Master Equipment List."
Considered
in the preparation of the list
are the environmental effects resulting from all of the postulated
design-basis
accidents
documented
in the Final Safety Analysis Report,
Technical Specification limiting conditions of operations,
emergency
operating
procedures,
piping and instrumentation
diagrams,
and elec-
trical distribution diagrams.
The Licensee's first Master Equipment List (MEL) was submitted
under
the Licensee's letter of January
14, 1982, in the WNP-2 NUREG-0588
Environmental
Equipment gualification Report, in response
to NRR's
letter of February 21,
1980, "gualification of Safety-Related
Electrical
Equipment."
Subsequent
and revised
MELs were submitted
to
NRR for
review
( the last dated
September
21,
1983)
as part of the licensing
process., This review is detailed in the Safety Evaluation Report,
NUREG-
0892,
Supplement
4, Section 3. 11, dated
December
1983.
Engineering,
Instructions (EI) 2.35, "Master Equipment List (MEL) Update"
and EI
2.1, "Preparation of WNP-2 Design
Change
Packages"
are used to maintain
the Master Equipment List in an updated condition.
As developed for WNP-2,
MEL is a component-level
computer data
base
containing data fields for ClE (Class
1E electrical
equipment),
(Nuclear Plant Reliability Data System),
and SRM,'(Safety Related
Mechanical
equipment).
Specific fields'n the
MEL identify which
equipment is qualified to 10 CFR 50.49,
and for what functions.
in turn is part of the Power Plant Information and Control System
(PPICS), which includes interactive terminals
and printers
used in
day-to-day operation
and maintenance
of WNP-2.
An "In-Process
MEL"
stores
data for pending
changes
to the
MEL.
The Engineering Instructions identified above were reviewed
and deter-
mined to be generally adequate
for their intended purpose.
However,
it was found that the EIs did not stipulate
any time requirement for
the updating of MEL following the completion/acceptance
of a Design
Change
Package
(DCP) which added
new qualified components
to
a Safety
System.
This could result in an out-of-date Master Equipment List,
and Af'act, the inspectors
noted equipment still listed
on the
as long as
19 months after removal of the requirement for qualifica-
tion.
A future
NRC inspection will review licensee
actions
to ensure
that
MEL is updated in a timely manner.
Master List updating consti-
tutes
open item 50-397/86-12-7.
Twenty-seven
items from four Safety Systems identified below were used
as
an audit sample
to verify the completeness
of the current Master
.
Equipment List.
In order to compile and cross-check
this audit sample,
the following Piping and Instrumentation
Drawings
(PSIDs)
and
vendor's
master parts lists were reviewed:
9
P&IDs/Audit Items
P&ID M-520, Hi
h Pressure
Core
S ra
S stem
Valve/Pum
Motors
V/1-MO-F001
V/4-MO-F004
HP CS-MO-P/1
Instrument/Transmitters
4-PT-N004
12-PS-N012
5-FT-N005
(2)
P&ID M-520, Low Pressure
Core
S ra
S stem
(LPCS
Valve/Pum
Motors
LPCS-MO-P/1
LPCS-MO-P/2
V/1-MO-F001
V/5-MO-F005
Instrument/Transmitters
9-PS-N009
(3)
P&ID M-521
Residual
Heat
Removal
S stem
(4)
(5)
Valve/Pum
Motors
RHR-MO-P/2A
RHR-MO-P/28
RHR-MO-P/2C
V/4A-MO-F004A
V/42A-MO-F042A
V/48A-MO-F048A
P&ID M-529, Automatic
02-MS-SPV-3DA
02-MS-SPV-4AA
02-MS-SPV-4BA
G.E. Master Parts List
Ins trument/Transmi tters
16-PS-N016A
37-PT-N037A
15-FT-N015A
De ressuri za tion
S stem
Valve
Pos ition
Aceous tie)
Moni tors
MS-POE-3D
MS-POE-4A
MS-POE-4B
ADS Parts List 238
X 178
-
RHR Parts List 238
X 184
HPCS Parts List 238
X 185
LPCS Parts List 239
X 287
The audit sample
was selected
to verify that those
items required to
be
on the list are included in the Master Equipment List.
All sample
items'equired
to be
on the
MEL were identified on the list.
Based
on this review, the Licensee's
Master Equipment List is considered
satisfactory
except for the Open Item cited above.
10
MEL identifies components
by Equipment Part
Numbers
(EPNs).
Since
electrical
cable is not assigned
an
EPN, it is not listed in MEL.
Accordingly, the inspectors
extensively questioned
personnel
concerning
the adequacy of cable identificat~on and qualification at
WNP-2.
The licensee
was able to satisfy the inspectors
that cable
used in safety applications
in WNP-2 was obtained
from only three
suppliers;
that such cable obtained
from those suppliers is qualified
for worst-case
environmental
conditions in the plant for any electrical,
or instrumentation applications
allowed for each particular type of
cable
by the specifications controlling WNP-2 installation procedures
or design
change
packages;
and that future procurements
of cable will
be similarly controlled.
Control of cable in WNP-2 includes
the
following important elements:
(a) cable is procured
by reel,
and
gA tracks it by type and reel; {b) each
Design
Change
Package specifies
cable
by type, including manufacturer;
and {c) a tracking system
individually identifies cables
used in the plant.
D.
Environmental
uglification Files
MEL is maintained
as described
above.
Generic information such
as
environmental
zone profiles and radiation analysis
standards
is separately
filed.
Component-specific qualification information is contained in
gualification Information and Documentation ((ID) files which reference
the generic information as appropriat'e.
Each /ID contains
the following:
Requalification Certificate
System
Component Evaluation Worksheets
(SCEW Sheets)
Analysis
Category
1 Checklist
gualification Related
Maintenance
Summary
(gRMS)
Calculations
References
The
NRC inspectors
examined files for 22 equipment items,
where
an
item is defined
as
a specific type of electrical
equipment,
designated
by manufacturer
and model, which is representative
of all identical
equipment in a plant area
exposed
to the
same environmental
service
conditigps.
The i tems were selected
in advance
by the inspection
team and identified to the licensee
during the entrance
meeting, except
that mme of the selected
items
had been
removed
from the Master List
and replacements
were identified for them during the inspection.
The files were examined to verify the qualified status of equipment
within the scope of 10 CFR 50.49.
In addition to comparing plant
service conditions with qualification test condi tions and verifying
the bases for these conditions,
the inspectors
selectively reviewed
areas
such
as required post-accident operating'ime
compared
to the
11
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
'onfiguration
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
decreases
in .insulation resistance
on equipment
performance;
adequacy
of demonstrated
accuracy;
evaluation of test anomalies;
and applicability
of Eg problems reported in IE INs/Bulletins and. their resolution.
, The files adequately
documented qual~fication of the equipment except
as described
below.
The files were readily auditable
and with the
exceptions
described
below were complete
and accurate.
Because
the
(ID file hardcopies
contained pencil, whiteout, correction tape,
and
erasures
the inspectors
examined control of these
documents.
The
following procedures,
instructions,
and criteria were considered:
Engineering Instructions 3.6,
Rev.
3 and 3.41,
Rev. 0; Corporate Policy
Procedure
CCP 1.1.52,
Rev. 1; Plant Procedures
1.3.4,
Rev.
6 and 1.6.7,
Rev.
1; ANSI/ASME N45.2.9-1979;
and ANSI N45.2.11.
The inspectors
concluded that the licensee is maintaining acceptable
control over
the gIDs, particularly because
each revision is adequately
side-
barred
and signed off when issued,
and readily retrievable microfilm
copies of all revisions
are maintained.
(1)
Rosemount
pressure
transmitter
model
1151,
AID file 209007 - In
the /ID file test report
RTM 57820,
page ll, section 4.2.1 states
that the user
has
the responsibility to provide nuclear qualified
seals at conduit connections
to prevent the entrance of conductive
fluid or vapor, which could cause
abnormal
operation
due to leak-
age currents.
Like other plant walkdown specimens,
transmitter
CMS-LT-1 was identified during the entrance
meeting
on April 28.
During the plant physical
inspection
on April 30 the
NRC inspector
observed
that thread sealant
on
a stainless
steel
plug in a spare
cable entrance
hub on the transmitter's
electronics
housing
was
tacky and volatile.
The
IKC supervisor
accompanying
the inspector
stated that on April 29 the transmitter 0-rings were replaced
and
the cover
torqued
under
MWR PAU5159.
The inspecto'r determined
that the completed
MWR did not address
the housing plug, although
it did identify the transmitter
as environmentally qualified.
The inspector also observed that the
EPN was merely written on
the housing in red felt tip pen, with no other tagging or iden-
tification in the area.
The completed
MWR did not address
the
lack of proper tagging.
The two technicians
who worked on the transmi tter on April 29
Mated that they installed the plug because
the hub was com-
pletely open.
An 18C engineer
who accompanied
the technicians
identified the transmitter for them based
on his experience with
it during the preoperational
test program.
Neither the technicians
nor engineer replied when asked
why they did not document
the
missing plug or tag.
The
gC inspector
who witnessed
the work
stated that when
he first saw the transmitter it had
a red shipping
. 12
cap
on the hub,
and that he did not document
the missing plug or
tag because
his inspection
was limited to ver~fying the special
maintenance
instructions of drawing M944.
All four licensee
personnel
stated that they had completed their documentation
on
this matter.
NOTE:
The inspectors
also noted that the licensee
NCR 5'286069
dated
March 14,
1986 identified need for
additional sealant in the conduit for CM-S-LT-1 and
other transmitters.
DCP 86-0101-OA dated April 4,
1986
covers resolution of the resultant
FCR-86-047
by docu-
menting the introduction of sealant into the conduits
under vital (expedited)
work request
PAY 0570.
The
inspectors
concluded that,
even if the concern raised
in NCR 5286069 were regarded
as
a violation,
a notice
of violation would not be issued
under the self-iden-
tification and correction provisions of 10 CFR 2,
Appendix C,Section IV.
This item is noted
because
of its apparent similarity to the concern raised during
this inspection.
In fact, the
two are completely
different because
AV 0570 deals with connected
conduit,.
whereas
the inspection
concern
addresses
the unused
(spare)
conduit connection.
At the request of the inspectors
the licensee
examined additional
transmitters
for possible
open spare
cable entrance
hubs.
The
l.icensee
reported prior to the exit meeting that of 90 additional
transmi tters examined,
nine had either
a plastic
cap or no closure
in the unused conduit entry.
Two of these,
EPNs CIA-PT-21A and
MS-PT-51B, required plugs for environmental qualification.
Paragraph
3. 11.4.2(4) of Supplement
3 to the MNP-2 SER NUREG-0892,
dated
May 1983,
documented
that during the February
1983
NRC
plant walkdown,
a transmi tter housing
was observed
to have only
a plastic insert instead of a threaded
metal plug.
The
SER supple-
ment states
that the insert
does not provide leaktight integrity
and could permit steam from a high-energy line break to enter the
housing.
The licensee's
awareness
of this concern is documented
on page
67 of 67 in the /ID file, which is part of an July 9,
1983
"Appendix A" response
to
NRC comments
as follows:
Comment
"There are
two threaded
connections
on the Rose-
mount transmitter's electronic housing.
In several
cases,
we noted that
a plastic plug was used to
"seal" the unused connection.
However, this plug
was loose
and would permit steam to enter the
electronic housing.
Other transmitters utilized
a threaded
metal plug which appeared
to provide
adequate
sealing.
These
concerns relate to all instruments
or equip-,
ment which are connected
to Anaconda
Flex conduit.
Also, since all Rosemounts
are of similar mechanical
design, all models
should
be inspected for plastic
plugs."
13
P
A
'I
'
Response
"The Supply System will investigate
these
items
following the audit.
Corrective action will be
taken
as required."
'he
procedural
aspects
of the Rosemount
1151 transmitter installa-
tion deficiencies
are included in Potential
Enforcement/Unresolved
Item 50-397/86-12-5 in section 4.O(5) below.
The direct
Eg defi-
ciencies resulting, from the installation of unqualified equipment-
consitute Potential
Enforcement/Unresolved
Item 50-397/86-12-1.
(2)
Limitorque operators,
BIO file 221001 - IE Information Notices
83-72
and 86-03 called attention
to numerous qualification prob-
lems involving parts
and materials
used in Limitorque operators.
Late in 1985
began planning walkdown inspection of Limitorque
operators
as part of their Integrated
Limitorque gualification
Program'IL(P).
A comprehensive listing was
made of all known or
suspected
concerns,
and binders
were assembled
to collect walkdown
findings and records of cor rective actions.
The first inspection
in the
ILgP took place
on March 28,
1986 during the first
refueling outage of WNP-2.
An April 15,
1986
NCR documented
deficiencies
found in the first operator inspected,
RHR-N0-9.
The deficiencies listed include incorrect lubricant type, motor
orientation,
absence
of T drains, unidentified/unqualified splices
on power and control wiring, and
a grease relief valve shipping
cap left in place.
The "Not Reportable"
block on the
NCR was
.
marked.
The licensee
stated that the nonreportable
determination
was
based
on the availability of alternate
equipment.
Upon quest-
ioning, the licensee
also stated that no further
NCRs would be
issued until the ILgP walkdowns
and evaluation
were completed.
Thus,
any consideration of reportability involving more than
just one operator
was deferred until
a complete evaluation
was
performed.
At the time of the
NRC inspection
the licensee
stated that the
outside containment operators
in the ILgP had been walked down,
and about
30 percent of those in the reactor building.
Although
the licensee
declined to provide
a commitmen't date for completing
the walkdown, agreement
was reached
that the hardware
would be
in a qualified configuration prior to restart.
NRC review of'alkdown sheets for the first eight Limitorque
opm'ators
examined
by WPPSS in the ILgP showed the following
deficiencies:
a ~
T drains not installed in several units.
b.
Gear grease
not sampled in two or more units.
c,
Gear
grease
sampled,
but not identified, in four units.
d.
Limit switch cover gasket material not identified in two
or more units.
(3)
(4)
e.
Limit switch gear housing material
not determined
in one
uni t.
f.
Improper orientation of drain plugs in one or more units
would not permit drainage of motor housing.
The
NRC inspection
team's
walkdown of six Limitorque operators
identified the following deficiencies:
a.
The motor nameplate for RWCU-MO-1 shows
40 ft.-lb. starting
torque, vs.
25 ft.-lb. on the
ILQP walkdown sheet.
b.
Several
wires on the limit switch finger board
oF RCIC-MO-
76 had stripped, stretched,
and/or
frayed insulation in
close proximity to the switch compartment
cover.
c.
A thin film of oil on the bottom of the
RCIC-MO-8 switch
compartment, cover indicated grease
leakage
around the switch
seals.
d.
Unidentified tape splices with no qualification documentation
were typically found on the motor leads inside the limit
switch compartment.
Additionally, the review of the QID file showed that it did not
contain sufficient information to establish similarity between
the plant equipment
and test
specimens
for each
model reviewed.
Limitorque operators
constitute Potential
Enforcement/Unresolved
Item 50-397/86-12-2.
Rockbestos
cable,
QID file 036003 - The qualification criterion
for this file was
NUREG -0588 Category II.
The file did not con-
tain any performance/acceptance
criteria or,functional analysis,
nor was there
any indication that current-produced
heating of the
cable
had been considered
in the determination of service
tempera-
ture.
A revision to the file incorporating discussions
of these
two items was in progress
at the close of the inspection..
personnel
had determined
that cable in primary containment
con-
sisted of second
generation
Series
100 coax,
power and control
cable formulated with 760D and 760G,
and
two conductors
formulated
with 780.
Qualification was established
for the coax
and 760
formulations with vendor supplied test r'eports.
The test report
referenced for the 780 formulation was one identified in IN 84-
44 and therefore did not support qualification.
MPPSS
was attempting
to~btain
a report from TVA which they feel will qualify the 780
formulation.
Rockbestos
cable constitutes
Potential
Enforcement/
'%resolved
Item 50-397/86-12-3.
low voltage containment penetrations,
QID file 383003
- The qualification criterion for this file was
NUREG-0588 Category
II.
Separate
test reports covering the low voltage penetration,
the medium voltage
and
a materials
.study were i~eluded
in the file.
The total integrated radiation
dose of 3.3
X 10
rads in the low voltage penetration
test report was not sufficient
to envelope
the stated
requirement of 7
X 10
rads.
A test
15
I
1I
I
i
report on the low voltage penetration
from WNP Units
1 5 3 did
envelop the Unit 2 TID and will be added
to the file.
Westing-
house
low voltage containment penetrations
constitute Potential
Enforcement/Unresolved
Item 50-397/86-12-4.
(5)
Procedural
Deficiencies
The Victoreen high range radiat~on monitor, its Conax connectors,
and the Barber Coleman motor are all R.G. 1.97 items not required
to be qualified until the end of the first refueling outage.
However, all three files were complete
and s'igned off, and the
equipment
shown
on the Master List as qualified.
These
three
component
types are
combined with the procedural
aspects
of the
Rosemount
1151 transmitters
discussed
in section 4.D.(1) above
to form an Appendix
B violation constituting Potential
Enforce-
ment/Unresolved
Item 50-397/86-12-5.
(a)
Victoreen high range radiation monitor, /ID file 27707-
The qualification criterion for this file was
gualification was established
with a vendor supplied test
report for Victoreen Model 875 which includes
the detector
Part No. 877-1 listed on the
SCEW sheet.
Two file deficien-
cies were identified.
First, the test report gave the accuracy
established
by the
LOCA test;
however,
the file did not
contain
a statement of performance/acceptance
criteria or
functional analysis.
Secondly,
Section
6. 1 and
gRMS Section
2.0 of the file indicated that the vendor-supplied
sealed
conduit system
was not used.
Photographs
from the
walkdown,
comments
by WPPS5 personnel,
and the inspection
walkdown all established
that the system
was used.
The file
was revised during the inspection to remove these discre-
pancies.
(b)
Conax connectors for HRRM, (ID file 049008 - The qualification
criterion for this file was
The test report
used in the file had aging data for 3 years.
An aging
analysis
was performed
on the test profile to determine
an
equivalent life at 150'C.
Then equivalent
time for the
accident
and margin was subtracted
from the total
and
a life
of 23 years
was claimed.
This analysis is unacceptable
for
10 CFR 50.49, which requires in paragraph
(e)(5) that equip-
ment qualified by test must
be preconditioned
by aging;
that is, the aging must precede
the
LOCA test, rather
than
= in effect follow it.
To address
the concern,
the licensee
planned
to change
the qualification criterion to Category
II of NUREG-0588 and
a revised aging analys~s
was being
prepared at the close of the inspection.
(c)
Barber
Coleman motor, (ID file 221002-E,-
The file did not
contain evidence of radiation qualification for the lubri-
cant;
the motor is filled with ATS-DOMET 6 oil.
The licensee
contacted
the vendor fot fluid properties,
and also plans
to qualify a separate oil suppl~er prior to restart.
The
16
file was also difficult to audit because it did not clarify
that the motor would be exposed
to either high temperatures
or high radiation,
depending
on the initiating pipe break,
but not both.
(d)
Rosemount
1151 transmitter
CNS-LT-1 - The procedural defici-
encies for the Rosemount
1151 transmitter discussed
in section
4.D.(1) above are included in Potential
Enforcement/Unresolved
Item 50-397/86-12-5.
They include failure to tag the
com-
ponent; modification without written procedure; failure to
document
the modification; failure to document or report
discovery of the unqualified component installation;
and
failure to consider
the possibility that other equipment
could be similarly def~cient.
(6)
Nonconformance
reports - During the entrance
meeting the licensee
identified several
nonconformance
reports involving environment-
ally qualified equipment.
The inspectors
reviewed
these matters
in detail
and concluded that the concerns
had
been adequately
dealt with by the licensee,
except that actions
were not complete
for three
NCRs; in each
case
WPPSS plans to complete resolution
before restart.
The three uncompleted
items are
ASCO solenoid
pilot valves
ROA-SPV-10, -11, -12, -13, -14, -15,
and -17
(NCR'86-153);
PSR-V-X73/2 and X80/2; and
qualif~cation of the radiation rack preamplifier without a
thermionic cooler.
In each
case resolution prior to restart
from
the first refueling outage is satisfactory,
and
a future
NRC
inspection will verify timely resolution.
Completion of:action
on nonconformance
reports constitutes
Open !tern 50-397/86-12-8.
(7)
IE Information Notices (IN) and Bulletins - The
NRC inspectors
reviewed
and evaluated
the licensee's
activities concerning
the
review of Eg-related
IE INs and Bulletins.
'The inspector's
review included examination of procedures
and
Eg documentation
packages
relative to Information Notices
and Bulletins.
The
procedures
review determined
that the licensee
does
have
a system
for distributing, reviewing,
and evaluating
INs and Bulletins
relative to equipment
within the scope of 10 CFR 50.49,
and that
the INs and Bulletins are addressed
in appropriate
component
Eg
files as described
above.
During the review of individual com-
ponent qualification files the
NRC inspectors
evaluated
the
licensee's
actions with respect
to Information Notices/Bulletins.
Except
as described
above in section 4.D.(2) for Limitorque
operators
no concerns
were identified.
E.
Plant"-Ph sical
Ins ection
The
NRC inspectors,
with component accessibility
input from licensee
personnel,
established
a list of 19 component
types for physical
inspection.
All were accessible
at the time of inspection.
The
inspectors
examined characteristics
such
as mounting configuration,
orientation, interfaces,
model
number,
ambient environment,
and physical
condition.
Several
concerns
were noted during the walkdown inspection;
they are addressed
in sections 4.D.(l), (2), and (4)(a) above.
17
I
Washington Public Power
Supply System
-3-
July 30,
1986
D
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July 30,
1986
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INEL
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