ML17285A903

Responds to Questions Raised at 891120 Enforcement Conference Re Timeliness of Util Limitorque Walkdowns & Lack of Cement in Com Ed Testing of Okonite Splices,Per Insp Rept 50-397/89-28

ML17285A903
Person / Time
Site:	Columbia
Issue date:	11/30/1989
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Faulkenberry B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO2-89-218, NUDOCS 8912210062
Download: ML17285A903 (13)

Text

ACC3KZRATEK) DISHUBUTION DEMONSTIRATION SYSTEM p

REGULATORY INFORMATION DISTRIBUTXON SYSTEM (RIDS)

SSION NBR:8912210062 DOC.DATE: 89/11/30 NOTARIZED: NO DOCKET CIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION BOUCHEY,G.D. Washington Public Power Supply System RECIPIENT AFFXLXATION RECIP.NAME FAULKENBERRY,B. Region 5, Ofc of the Director gq-2$

Responds to questions raised at 891120 enforcement 'UBJECT:

conference re applicability of test rept to configuration.

DXSTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response

'NOTES RECIPIENT COPIES RECXPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 '1 SAMWORTH,R 1 1 INTERNAL: ACRS ~ 2 2 AEOD, 1 ~

1 AEOD/DEXIB 1' AEOD/TPAD ,1 '1 DEDRO 1 1 NRR SHANKMAN',S '1 1.

NRR/DET/DIR 8H3 1 1 NRR/DLPQ/LPEB10 1 1' NRR/DOEA DIR 11 1 1. NRR/DREP/PEPB9 D 1 ~

NRR/DREP/PRPB11 2 2 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 ' 1

, NUDOCS-ABSTRACT 1 1 0 ,J 1 OGC/HDS2 1 1 02 1 .1 RES MORISSEAU,D 1 1 RGN5 FILE 01 1 1 RNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS"

~ RECIPIENIS'LEASE US 70 REDUCE WASFEl CONTACI'HE.DOCUME&G'ONIROLDESK, ROOM Pl-37 (EXT. 20N9) TO ELIMNATEYOUR NAME FROM DISIRIBUTION AL NUMBER OF COPIES REQUXRED: LTTR, ~ 27 ~

ENCL 27

ii WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 November 30, 1989 Docket No. 50-397 G02-89"218 Mr. B. H. Faulkenberry Deputy Regional Administrator U.S. Nuclear Regulatory Commission Region Y 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF"21 ENFORCEMENT CONFERENCE - NOVEMBER 20, 1989 ADDITIONAL INFORMATION

Reference:

1) Letter, R. P. Zimmerman (NRC) to G. C. Sorensen (Supply System), NRC Inspection at WNP-2 (Report No. 50-397/89-28),

dated October 12. 1989.

2) Letter R. P. Zimmerman (NRC) to G. C. Sorensen (Supply System), Request for Information on Environmental qualification'f Taped Electrical Splices, dated October ll, 1989.

At the enforcement conference of November 20, 1989, the Supply System committed to provide further information with r espect to the timeliness of the Supply System's Limitorque walkdowns compared with other licensees. In addition, . NRC staff members questioned the applicability of the Commonwealth test report to the Supply System configuration. Responses to these issues are provided in the attached Appendix A..

. 89i22l0062, 89i130 ADOCK..05000397 (P

PDR' -"-- 'DC

Mr. B. H. Faulkenberry Page 2 November 30, 1989 NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 ENFORCEMENT CONFERENCE " NOVEMBER 20, 1989 ADDITIONAL INFORMATION Regarding the E() issues. the Supply System's position continues to be that:

1) the as-found splices were qualifiable, and 2) documentation deficiencies were not safety-significant and, therefore, do not warrant escalated enforcement. In addition, should the staff determine that escalated enforcement is appropriate, the Supply System urges the staff to exercise enforcement discretion and not propose a civil penalty. Because corrective actions were taken almost four years ago and similar deficiencies have not recurred, escalated enforcement and a civil penalty are not necessary to satisfy the regulatory purpose "of the Commission's enforcement policy (10CFR Part 2, Appendix C). Pr ecedent for such discretion is provided by staff enforcement actions in 1986 regarding 10CFR Part 50, Appendix R.l/

Very truly yours, G. D. Bouchey, Direc or Licensing & Assurance Attachments cc: Nr. C. J. Bosted, Resident NRC Inspector (901A)

Nr . J. B. Martin, Region V NRC Nr. N. S. Reynolds, Bishop, Cook, Pur cell & Reynolds Nr. R. B. Samworth, NRC Nr. D. L. Williams, BPA (399)

Nr. R. C. Wilson, NRC NRC Document Control Desk 1/ See Enforcement Actions (EA): EA 85-112, Susquehanna; EA 84-36, Salem; ZA 85-101, Summer; EA 83-124, Davis Besse, EA 85-048, Sequoyah; and EA 84-007, Vermont Yankee.,

APPENDIX A Discussion of E ui ment Oualification Issues During the November 20, 1989, enforcement conference, the staff expressed two specific concerns regarding the equipment qualification (Eg) area. The first concern involved the timeliness of the Supply System's Limitorque walkdowns. The second concern involved the lack of a "cement" in the Commonwealth Edison testing of Okonite splices as a basis for questioning the Supply System position on qualifiability. Hith regard to the "cement" issue, the Supply System notes that Okonite tape splices were also successfully tested in a potentially more exposed "V-type" configuration without the "cement" by Alabama Power Company. The staff is very familiar with these tests which further support the Supply System's position of qualifiability and, therefore, further discussion of this issue is unnecessary.

Hith regard to the timeliness of the Supply System's response to Limitorque concerns raised by the staff, Information Notice 83-72 (Environmental

(}ualification Testing Experience, dated October 28, 1983) expressed specific environmental qualification concerns on Limitorque MOVs and/or associated testing. IN 83-72 was based on construction deficiency reports filed by Bechtel concerning the Midland Plant, Units 1 and 2. In response to the IN, Limitorque sent a form-type letter to many licensees. During the November 20 enforcement conference, the staff incorrectly stated that this Limitorque letter requested that licensees take subsequent action to address the issues identified. Instructive on this point is the conclusion of Limitorque voiced in the letter as quoted below:

In summary, the underrated terminal block incident which occurred at Midland was an isolated field problem. The Buchanan 0824 terminal blocks are qualified by analysis but due to the stigma associated with nylon in the nuclear power industry, these terminal blocks are not considered acceptable. These terminal blocks were supplied exclusively for one valve manufacturer who has undertaken a project to replace all the Buchanan 0824 terminal blocks. The balance of the items identified as a concern were a matter of educating the Midland personnel on Limitorque actuator construction as it relates to the qualification reports as there were no incidents of units found that were not suitable for the service for which they were provided.

Limitor ue does not recommend that an corrective action be taken as a result of this Information Notice. emphasis added Letter of Daniel . Hersing, Technical Manager, Limitorque Corporation to, among others, Cliff Reynolds of Babcock and Hilcox dated July 19, 1984 at 3-4. See Enclosure 1.3 It is noteworthy that the IN did not reference any concern regarding MOV splices. Accordingly, licensee speculation regarding the scope of. the IN would not likely have included a walkdown of Limitorque-related splices. in any event.

Additional specific concerns regarding Limitorque MOVs were not expressed generically by the staff until it issued IN 86-03, "Potential Deficiencies in Environmental gualification of Limitorque Motor Valve Operator Wiring,"

dated January 14, 1986. This IN was published several months after a 10CFR Part 21 report was filed concerning Limitorque wiring at Commonwealth Edison's Zion Plant. The staff was awar e of this Limitorque issue prior to the November 30, 1985, deadline. However, it did not notify the nuclear industry of its concerns until after the deadline had passed.

In response to increasing staff and industry concerns regarding Limitorque MOVs as discussed above, the Supply System planned and implemented a comprehensive review of all Limitorques during the WNP-2 first refueling outage beginning in March 1986. The staff commented favorably on the review during its 1986 inspection. The Supply System believes that its review was timely given the information available at the time and was conducted ahead of the majority of other licensees who had the same information.

Supporting this belief, the Nuclear Utility Group on Equipment gualification (composed of 43 nuclear utilities) informs us that based on informal surveys conducted during meetings and informal telephone contacts, the clear majority of the members responding conducted detailed Limitorque reviews (such as conducted by the Supply System) after the Supply System's review began. This is further supported by inferences drawn from a cursory review of E() inspection reports which reflects that staff inspections with adverse Limitorque findings of over 60 plants were conducted after the Supply System's review. This suggests that either no Limitorque reviews were conducted prior to the staff's i nspections or the reviews were inadequate.

Finally, a review of E(} inspection reports reflects that only 17 specifically note the'pproximate timing of the Limitorque reviews conducted by the licensee. Of those 17 reports, only 6 were conducted prior to the WNP-2 review. ( It should be noted that even those with Limitorque deficiencies whose review was conducted after the Supply System's generally did not result in escalated enforcement action.) In short, it is clear that contrary to the staff's impression noted at the enforcement conference, the WNP-2 Limitorque review began before the vast majority of other licensee's reviews.

In view of the above discussion and as discussed during the November 20, 1989, enforcement conference, supported with appropriate bases, the Supply System submits that escalated enforcement action is .not warranted.

Further, if the staff disagrees, . the Supply System maintains that upon consideration of the factors noted in the Enforcement Policy, full mitigation of any civil penalty is appropriate. In addition, the Supply System does not believe that escalated enforcement action at this time will result in any further regulatory purpose being served. As noted in 10CFR Part 2, Appendix C, Paragraph I, the purpose of the NRC enforcement program is to promote and protect the radiological health and safety of the public, including employees'ealth and safety, the common defense and security, and the environment. This purpose is satisfied by: 1) ensuring compliance with NRC regulations and license conditions; 2) obtaining prompt correction of violations and adverse quali.ty conditions which may affect safety; 3) deterring future violations and occurrences of conditions adv'erse to

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quality; and 4) encouraging improvement of licensee and vendor performance, and by example that of industry, including the prompt identification and reporting of potential safety problems. Moreover, the Enforcement Policy states that:

Each enforcement action is dependent on the circumstances of the case and requires the exercise of discretion after consideration of these policies and procedures. 10CFR Part 2, Appendix C, Paragraph I In regard to the above, the Supply System has already taken extensive actions to ensure compliance with NRC regulations and license conditions.

Second, prompt actions were taken to ensure that a qualified configuration was installed once the deficiency was identified. Third, considering the continuing amount of attention given to the tape splice issue over a three year period, additional NRC actions are not necessary to deter future violations or conditions adverse to quality. Further, considering the history of E(} enforcement, enough examples have already been provided for industry which have resulted in significant improvements in Eg programs at other nuclear facilities.

Finally, the Supply System has had an excellent enforcement history as evidenced by only one escalated violation and never being cited for a civil penalty in six years of operation. This record would not have withstood the test of time if the Supply System was not a proactive licensee that promptly responds to deficiencies and pr events recurr ence of similar violations. The subject EO deficiencies are clearly another example of the Supply System promptly responding to discovered deficiencies. It is noteworthy that subsequent to the April 1986 Eg inspection and walkdowns, no additional examples of similar violations have occurred. Accordingly, the exercise of discretion is appropriate in this case similar to actions taken bg the staff in several 10CFR Part 50, Appendix R enforcement actions.

1/ See ~e, Enforcement Actions (EA):

Vower and Light Company's Susquehanna EA 85-112 against the Pennsylvania Plant; EA 84-36 against Public Service Electric & Gas Company's Salem Plant; EA 85-101 against South Carolina Electric 8 Gas Company's Summer Plant; EA 83-124 against Toledo Edison Company's Davis Besse Plant; EA 85-048 against TVA's Sequoyah Plant; and EA 84-007 against Vermont Yankee Company's Vermont Yankee Plant.

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t Attention c,': Mr.",C'luff. Reynolds Gentlenen: '.;.'::I>,t~ ',; '. ~

Subfect . HRC .Infor'aaron, Notice~ 83-72 Equipment'.Env<roen'en@@1. equal'iffcat<on Hotice No. 24 contained $ n the rH'erenced Infoimition. Notice'identifies several concerns on the qualfffeatice of L<mitorque'ctua'to'r components. The information contained $ n .the potence

<qdicates that'ft was basaf "on an interim report fran the NMland Planrt, which bss Mitten in June, $ 983,'"priQr to the architect/engineer completiiig &e a

revim of thi doeumenta't3on piov$ ded by L<mitorque. On the completion of the engtnGP1 in/ anilysis, 'these'issues were resolve and Midland provided the NRC

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with'their "fina), rep'0'rt." ..

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The'mafority of,the'con'cerns raised in Ndland's intenai report to the .

NRC were. items which the architect/engineering fina was in the proces~ of

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evaluating.:. Hast of thii'e,issues were a matter of educating the engineering personnel on the con'str0cHon and quai)ffcation of Umitarque actuators. Thi~.

. educationaT.'process took, place oYer a period of tm to threa years during NMch

'ime'.Urlitorque providedapproximately PS letters responding ta engineering questions as we11 as transmitt$ nj qua1ifioation report information. En addition to tlat correspondence fnyolved', several meetings were held between Limftorqua and Bechtel to discuss the var)ous educationa1 items..

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In lS79. Bechtel .requ'ested that. Umitorque rep>ace'.%he terminal %locks-dn.--

a group, of actuators'for"'the purpose of providing additional termina1 points.

The only field 'serve'ice 'reepresentatfve available was a trainee that had been with Liaitorjue for less'han two wleeks. Hex terminal blocks. were provicfed fram the factory~ however; befour'e the f>e]d work, was completed, the field service repre-sentative ran out of facltory supplied blocks. In his enthusiasm to complete his a"sijnment, he obtain'ed additional terminal blocks locally. These terminal

'.blocks i'ere not r'ated for'60'olt service.'ollowing identification of the Problem~ Uraitorque inspected all of the actuators listed in our field. report ~

and rep)aced the'underrated termlna'l blocks. As a further confirmation that

><<e te~'anal b'locks. had not been installed elsewhere. Lie%torque found'o inspected a random-samp1e of a/1;, actu'atdrs ht the Nidland facility

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and other It

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instances of underrated. terminal.41ocks.

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fs our conclusion that this is a un'u' a-'Ir.tdc:nt. nnta;ld. llcta ttyt bCen @Mph ts-a4cd ries:ofhce-re ~ ~

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The Buchanan 0824 termina$ blocks identified a.t the Mf@and Jab sita were qua1,$ fied by".analysks't. the tirae the actuators were furnished. The terminal block .$ s a'issive device and'not. a structura't component. howevers the terminal black material $ s nylon,.:.. EC is.L<mitorque's opinion that the terminal block

<ftca4$ en test.,

h0wevet', b~iisy'of.thi'.stigaia associated 4th ny1on Q the nuc1ear power induszr we have chosen'..not to'pur siii any further qualification ~rk on the cccnpanent.

Thes'e terminal blocks w'ere"used exclusive1y on actuators provided to Mes~inghouse Electric Cor d'or'ation's, Ele'c$ po Hechanica) 0]vision. Mestinghouse has been np4$ f$

of ihe"problem a'nd.they ar'e"curr'ently in the process of replacing all oj'the Buch>nan 0824 termina1 61ocks ut$ 1$ zed

~l in Mestinghouse 4supplied equipment.

(N1and site personnel,conducted a random inspection of safety related Lictor'qua actuitors r'esultiiig in a list oV questions coecernin9 t56 con-struction.of t'ai.'equipnent. '.'he. following numbered <terms correspond to those, 1isted 'a"s Add)fiona) qualification Concerns in the !nformation Hot<ca.

1) 'lass, 8 insulated'motors on Limitorque actuators are rated for

~ 40oC ambient't.tEnp'erasure and are qua1ified in accordance <tg

. IEEE Standar'0 382-72 for outside containment environments Limitorque.nisei glass RH insu1ated motors for inside conta 'in merit applications, 'prior to adoption of the Class 1$ nomen-clature the'ar]y motors oP this design wesi nameplated as Cla'ss H,..These motors ai.e qualified for inside containment app'1 ications'n accordance with IEEE-382-72. Lictor que re feted al.l, of the records on the Midland Onside containmeng operators'..and.'c'onf5rmed that motors nameplated as Glass H C

sere coostrvctid'with a Class RH $ nsu'latioa systerrr prior to

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The motor leaden on quality'fed Litaitorque motors are en integral t

par of thi .motor and qual iAed as such. Mesc motor leads do oot, have any w'ire manufacturer identification uerkings. The 841-fng used fn the 11mit switch compartment by Limitorqua can be Identified,'by'he wire manufacturer's naca printed on the insulation with the'exception of the'shorte pieces'of cable which'p'~~."not show the Hire manufacturer's name as this infor motion is'printed on the'nsulation in one M Wo feet intervals.

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t Lim<torque's gualification Repot 8-0058 expl icitly states the I

I reco~ii endedmunting positions for the actuators. Me recommend agai'nst moun'ting the operator in a position where either the motor or the limit switch compartment are Airect1y beneath the gear case;-'here is a remote possibility Chat a random seal failure cou1d occur resulting in lubricant )caking into the electr<ca) enclosures and possibly impairing the actuator's operability..

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".7"..:. dr'sins".3ii'.the'two q ue RH motor s r equ ire the insta'liat on of motor

~ -:- lowest drain plug locations. The fnqtal-

"'latfoii, p'ositio'n of the Yalve(actuator asMnbly ik not known a<

thii time the'actuator $ s shipped from Umitorqtte. Consequently,

" the in%or'..."T" dra$ pq are placed $ n the limit mftch eompaMent Mth Cns&llaHon instructions at the tkme eF actuator shipment.

Lieitorj6e's Clasi B insulated motors do not utilize motor "7<<

drains 4n 'safet'y related applications.

8) . Tw types. of:limit switch assemblies ara us@et in l.im'ftorque "acMators'.'.'nits qualified for outside containment applications use'an'aluminum, gear frame construct<on and those units f'r inswe containment. apji$ cat$ ons utilize a bronze gear'ry'. '

S):, Thi 'Midlarid Pr'object 'personnel Found that there Was equipnent

'fnstal3 ed. $ ni5d~'containment which was nut rnmufaczured apjl ication 'e f'r this rivieved our records on alk units located @side containment for"Hjd1and and found that all the ac>ators'rovided .

by Limitorque,vere manufactured 5n accordance with the require-ments of the purchase order. Limitorque was not ad$ vsed of Hidland's'inal dete'rmihation of the cause of'nqualH'i'ctuators being 1 ocated. inside'. of .containment.

'T) The Limitorque'7ia1 <fication program included space heaters as a pu't.'of': the actuator construction. however. these heaters vere not energized during the envirorunental testing- .

.that the heaters are to be used to prevent coadensation damage It >s our intentfon during site storage and they do not neecf to be energized during

. p>ant o pe~ation..

~ t 8)'.: Toe types 'o'f O.-ring materials are used in LTantorq'ue actuators, Lt de p eridin 0 u po n the uri b e$ ng E ocated e 4th er $ ns5de or outs lde containment.".-::The architect engineer on'he Ndland Prospect ws amr e.that 'e use4 two different seal'materia1s but Ms unsure of ho%

L t.hey are'applied., ~ M

) Yhe unide'n.iifiable 'ter>annal b]ocks are low vo'Itage control circuit Cern~nal. blocks; '-'During L<mitorque's inspection of randomly selectecf actuators at the Headland site, all control terminal blocks were'ide'n'tHied and found to be, suitab'fe for their y,...

appl ication.:,:,'.,"

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In 'sumnar theu'iiderrated te pn ina1 block incid en t'Mich occurred't, Hidland was an,'isolated Beld 'pr'ob'i,eii. Thi Buchanan 0824 terminal b'locks are qualifiecf by analysjs bbut due.to. the s6gma associated with nylon in the nuclear Power industry, ~

hese te inal blocks .are, not con s x"dered a cce ptable. These te inane blocks were

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Hr.,Cliff Reynolds July ]9> 1984 supplied exct.usfveTy fo'r on'e vaTve manufacturer who has undertaken a prospect to repiace ill tpe Suchalnan 0824 terminal blocks. The balance of the items identified as a coricern'iere"a 11itter'of'educating the Headland personnel on Umitorque actuagor construction ai $ t re1ates to the qua'lificaQon reports as there Mere no incidents "of units fouiid that were not suitable for the service for'Mch they were ' provided. . Lie)torque .does not recommend that any correct4ve actÃan beta ken as a. result of thjs,Information HotÃt'.a.

Pleasi contact'this'office shou1d you have any further questions.

'o ' ~,'~fr,f ~ ' ~: Very truly yours, LIMITORQUE CORPORATION

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D~J" S., Parsing D~'aniel R/ Technical Manager ~ ~

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