ML18005A695

maintenance

program.

The

problem

involved

degradation

of the

environmental

qualification

boundaries

of

equipment

caused

by

maintenance

activities.

The

root

cause

was

determined

to

be

inadequate

training of both the maintenance

planners

and maintenance

craft personnel

in requirements

of Harris

EQ program.

Corrective

actions

taken, to

resolve

this

deficiency

are

described

in

paragraph

"b" above.

Additional corrective action,

implemented the week of August 8,

1988,

=to correct

the

above

deficiency

included

restructuring

the

Technical

Support organization.

An additional staff positions

have

been

added with responsibilities for administrative control of the

maintenance

program.

The objective of the

reorganization

is to

provide centralized

control for implementation of the

EQ maintenance

program.

Functional responsibilities,

levels of authority,

and lines

of internal

and

external

interface

communications

will also

be

specified to better coordinate

and assess

the effectiveness

of the

program.

Pursuant

to discussions

with licensee

management

the inspector

was

informed

that

procedure

PLP-108,

"Environmental

Qualification

Program," wi 11

be revised to reflect the above organizational

change.

A commitment date of October 1,

1988,

was

given for completion of

this

revision.

The

inspector

also

reviewed

section

4.4.2

of

procedure

PLP-108,

and verified that

inadequacies

in the

program

description identified during the first round

EQ inspection

had

been

corrected.

The corrective

action

was

completed

in accordance

with

the licensee prior commitment.

Within this area,

no violations or deviations

were identified.

Eg Documentation Files

and Walkdown Items

The

NRC inspectors

examined files for 28 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 conditions.

The inspector selectively reviewed areas

such

as

(1) required post-accident

operating time compared to the duration of

time

the

equipment

has

been

demonstrated

to

be qualified,

(2) similarity of tested

equipment

to that installed in the plant,

(3) adequacy

of test

conditions

enveloping, calculated

accident

profile conditions,

(4) aging

calculations

for qualified life

determination,

(5) temperature

related effects

on instrument accuracy

due to decreases

in insulation resistance,

(6) evaluation of test

anomalies,

and (7) applicability of Eg problems reported in IEBs/IENs

and their resolution.

The results of the file reviews

and walkdown

items will be

discussed

in detai

1 in the paragraphs

that follow;

however,

in general,

the files were considered

adequate.

(I)

General Electric Vulkene

Supreme

Mire (E(DP 6.10)

The inspector

reviewed

the- file for General

Electric Vulkene

Supreme

SIS wire used outside

containment for control applica-

tions.

The qualification basis

was

Category I.

The

worse

case

steam

environment is in the steam

tunnel

where the

peak

temperature

reaches

437'F for about ten minutes,

followed

by a fairly rapid return to much lower temperatures.

A thermal

lag analysis

(File

No. 2202.006,

not reviewed) yielded

a peak

temperature of'28'F.

The radiation dose is 43 Hrad normal

and

I Mrad,accident.

The

cable

was qualified to

nominal

IEEE 323-1974

conditions

and is reported tin

FRC report

F-C4497-2.

All plant

parameters

were

enveloped.

The tested

cable

was

identical

to the

cable

purchased

for the plant.

Good

IR

performance

was indicated

by the

steam test.

No findings were

identified.

(2)

Rockbestos

Coaxial

Cable

(E(DP 6.7)

The inspector

reviewed

the file for Rockbestos

coaxial

cable

used for instrumentation circuits, including the General

Atomics

radiation

monitor inside

containment.

Cables

used

include

RSS-6-104/LD,

RSS-6-105/LD,

and RSS-6-108/LD.

The qualification

basis

was

Category I.

The plant parameters

were

enveloped

by the test

and the

LD/LE similarity analysis

was

included

in the file.

Performance

(IR) of the

cable

is

addressed

elsewhere '(in General

Atomics radiation monitor file,

not reviewed).

No findings were identified.

(3)

Instrument

Loop Accuracy Calculations

(EgDP 90. 1)

10

(4)

The inspector briefly reviewed

the

instrument

loop accuracy

calculations

of

EgDP 90.1.

This file contains

the basis

and

justification for data

supplied

to Westinghouse

for input to

loop accuracy

calculations.

The reviewed calculation

does

not

include

any, degraded

IR calculations.

Cable lengths

and

IRs

used

for cables,

connectors,

penetrations,

and

splices

are

determined

in the

package

and justified based

on

peak expected

containment

temperature.

No findings were identified.

Rockbestos

Instrumentation

and Control Wire (E(DP 6.8)

The inspector

reviewed the file for Rockbestos

chemically

XLPE

(Type XXL-760D) insulated

600V control

and thermocouple

cable.

The control

cable

is used

in Limitorques

and the thermocouple

cable is

used

in Westinghouse

penetrations.

The qualification

basis

was

Category I.

The plant parameters

were

enveloped

by

the

test

conditions.

Insulation

resistance

performance

was satisfactory

during the test.

No findings were

identified.

(5)

Rockbestos

Instrument

and Control Wire (EgDP 6.9)

The inspector

reviewed

the file for Rockbestos

radiation

XLPE

insulated

cable.

All information for this cable is the

same

as

for the chemically

XLPE cable

in

4 above.

No findings were

identified.

Okonite Okozel

Cable

(EgDP 6. 13)

The inspector

reviewed the. file for okonite cable insulated with

Okozel,

an

ETFE flouropolymer (Tefzel).

The qualification basis

was

Category I.

The cable

is

used for internal

jumpers

and for field cable terminators for Target

Rock Solenoid

valves.

This cable

was purchased

and installed

as

a result of

IEN 84-68.

The cable is rated at 150'C in dry locations with a

qualified life of ten years.

The cable

type designation

are

Z

and

ZW.

The only area

questioned

was that of documentation

required to support

Category

I qualification.

Specifically,

the

items of Section

8.3 of

IEEE 323-1974

were

not fully

13

(I7)

addressed.

However, this item was previously accepted

by

NRR in

NUREG-1038,

Supplement

4, Section 3.11.4.

Target

Rock Solenoid Valves

(E(DP 3. I)

The

inspector

reviewed

the file for Target

Rock

799 series

solenoid

valves.

The qua'lification

basis

was

NUREG-0588/

Category I.

The valves

are primarily sampling

system contain-

ment isolation

valves.

Some of the

valves

are continuously

energized

and/or

subject to process

heat rise during

normal

operation.

Typically, the valves all closed at the beginning of

an accident,

but there still may

be process

heat rise.

The

licensee

performed

calculations

which

showed

very

short

'ualified

lives for

some of the valves

(on the order of one

month),

based

on the artificial aging performed.

An analysis,

based

on testing

done

on

a valve

removed

from Sequoyah

after'ive

years of continuously energized

service,

was

used to extend

th'e

minimum qualified life to one cycle.

Two questions

wer e

posed

to the licensee.

First, the valve

removed

from Sequoyah

did not appear

to be

one which would be subject to process

heat

rise,

resulting

in

a question

of the applicability of the

Sequoyah

valve.

Second, .it was, not clear what process fluid

temperature

was

used

in the Target

Rock test,

resulting in

a

question

of whether

the

plant valves

cou'Id

be

exposed

to

temperatures

above their qualification when accident conditions

are combined with process

heat rise.

The licensee

is addressing

the first question

through

on-going

evaluation

and

a test

program using naturally-aged

valves being removed from the plant

during the current outage.

The second

question

was adequately

addressed

by considering

the accidents

where the valves would be

needed,

their required

state

during these

accidents,

and the

actual

accident profile.

The question of qualified life and the

results

of additional

testing will be

reviewed at

a future

inspection.

Therefore,

this

item is

considered

unresolved

pending

the results of the testing to be performed

on the coils

removed

during this outage

and documentation

of the results

by

NED in the

E(DP (Unresolved

Item (URI) 50-400/88-27-02).

(18) Limitorque Actuators

(Dual Voltage),

Equipment

Tag Nos.

1CC-249

and,lCS-470

(Inspection Plan TI 2500/17)

The

Phase

1

Eg inspection

held

March 7-11,

1988, identified

URI

50-400/88-04-01,

Nylon

type

Crimp

Connectors

on

Dual

Voltage

Limitorque Actuators.

At the

close

of that

inspection,

the

licensee

committed

to obtain qualification

documentation

for the

nylon crimp connectors

or

remove

the

connectors

and replace

them with qualified splices.

The purpose

of the

Phase

2 equipment

walkdown was to physically inspect the

dual voltage limitorque actuators

inside containment,

determine

if the

nylon

connectors

were

being

used,

and

evaluate

the

licensee's

basis for qualification of these

connectors.

14

There

are

two dual

voltage Limitorque actuators

(1CC-,249

and

1CS-470)

inside

containment.

The

walkdown of these

valves'erified

that the mounting configuration was consistent

with the

tested

configuration.

The T-drains

and

grease

reliefs

were

found to be properly installed.

The equipment

was identified by

the manufacturer's

nameplate

as

a

dual

voltage

model.

The

licensee. stated that the nylon connectors for both were replaced

with Raychem splices.

The inspection of

1CS-470 verified that

Raychem splices

were

installed

on the motor lead connections.

When questioned,

the

~ licensee

could not identify the type of connectors

since

the

connectors

were not saved.

The licensee

stated that there

was

documentation

available

from Limitorque which indicated that

only Thomas

and Betts connectors

were supplied in the actuators.

Aging qualification could

be

demonstrated

by

a separate

test

report

on

the

motor.

Although,

these

documents

were

not

reviewed, it appeared

that

the

connectors

were qualifiable.

This finding was identified

as

a potential violation,

on the

basis

that

at

the

time of the

inspection

the

Eg file was

deficient in showing the qualification of the nylon connectors,

however, it is not clear that the licensee

should

have

been

aware

of this

problem

considering

the

location of these

connectors.

Therefore,

a violation will not be cited.

(I9)

Component

1CC-249

was

not

inspected

internally

since

the

licensee

stated that the

same

Raychem splices

were installed to

replace the nylon connectors.

Limitorque Actuators

Equipment

Tag Nos.

1RH-40,

1RH-2,

IED-94,

and 1SI-246 (TI 2500/17)

The

above

Limitorque actuators

were

inspected

for mounting

configuration, T-drains,

grease reliefs,

nameplate

information,

and internal wiring.

The installed configuration

was

found to

be consistent

with the

tested

configuration.

All walkdown

concerns

were addressed

prior to the close of the inspection.

The inspection of 1RH-40 discovered

a small

leak of red grease

inside

the

housing for the limit switches.

The

licensee

identified the grease

as Mobil 28 and stated that orientation of

the

actuator

prevented

the

grease

from reaching

the

switch

contacts.

Work ticket

WR5A 88AUJSI

was

issued

to clean

the

housing.

Valves

1RH-2

and

1CS-470

were

found to

have

terminal

boards

wired at adjacent

points, while 1SI-246

was wired at alternate

points.

When questioned,

the licensee

explained

that either

wiring configuration

was

acceptable,

since

Limitorque report

80119 supported

the

use

the

GE, marathon,

and

Buchanon terminal

blocks

in their worst

case

wiring configuration

(adjacent

points).

15

There were several

Raychem splices

where the shim protruded

from

the sleeve

and other

c'ases

where the sl'eeve

overlapped

the shim.

When questioned

the licensee

stated that the

Raychem installa-

tion Guide was used

as the basis for the plant 'procedures

-WP-210

and

EMP-3.

The installation

guide indicates that

an accident

location

requires

a 2-inch

seal

length.

In

a single

shim

installation

the

shim may

be overlapped

or protrude

from the

insulation

sleeve.

The seal

lengths

of several

splices

were

measured

and found acceptable.

Barton Transmitter

Models

763

and

765,

Equipment

Nos.

LT-474,

LT-477, 1RC-455,

and

1RC-456

The above transmitters

were inspected for mounting configuration

'and wiring and found acceptable.

Raychem splices

were used for

all connections.

Single

shims

were

used

and

appeared

to

be

properly installed.

There

were

no concerns

identified during

the walkdown.

(21)

(22)

Minco RVLIS RTD, Equipment

Tag Nos.

TE-1313

and TE-1314

The

above

RTDs

were

inspected for mounting configuration

and

wiring and found acceptable.

Raychem splices

were used for all

connections.

Single shims were used

and appeared

to be properly

installed.

The locations of all Minco RTDs were identified and

found to

be

above

flood level.

There

were

no

concerns

identified during the walkdown.

Reliance

Motors,

Equipment

Tag

Nos.

1CV-E002:004

and

ICV-E002:005

As a result of the

Phase

1

Eg inspection,

the licensee

committed

to inspect

the

Re'liance

motors

and

remove

the grease

lines to

the sealed

bearings.

However,

subsequent

to that commitment the

licensee

determined that the motor had double shielded

bearings

for which the use of grease

lines

was specified.

The licensee

surveyed

knowledgeable

personnel

at

Shearon

Harris

and other

plants for advice

on lubrication of the motor bearings,

but the

results

were inconclusive.

The licensee

took the conservative

approach

and committed to install the grease

lines

on the motors

during the outage.

The work tickets were identified and found

acceptable.

The licensee will void the original work tickets to

remove the grease

lines.

This explanation

was acceptable.

The

motors

were not inspected

during the walkdowns

due to limited

time.

(23) Hydrogen Recombiner

Equipment

Tag No.

1SP-E003

The

equipment

was

inspected

for mounting configuration

and

wiring and

found acceptable.

The

5

and

I

Raychem

splice

=

16

(2~)

configuration appeared

to be properly 'installed.

There were no

concerns

identified during the walkdown.

Electrical

Penetration

Assembly,

Equipment

Tag

Nos.

1AB-S1206

and

1AB-1225

(25)

These

assemblies

were

inspected

for mounting

configuration

and wiring and

found acceptable.

Penetra4ion

1AB-S1206

(and

other

EPAs

in

the vicinity) could

not

be

identified from the back panel,

which required

someone

to crawl

around

the

assemblies

in order

to

locate

the

equipment

tags.

There

was

a concern

that personnel,

exposure

would be incr eased

anytime

someone

needed

to identify a specific

assembly.

The licensee

issued

WRSA 88-AUNG1

and

committed to lable the penetrations

on the

back side of each

enclosure.

This was acceptable.

The inspection of Penetration

1AB-1255 discovered

several

black

wires with the

bare, conductor

showing where the insulation

was

stripped back.

When questioned,

the licensee

explained that the

Raychem splices

associated

with these

cables

were supplied

by

Westinghouse

as part of the electrical

assembly.

Installation was done in accordance

with the

Raychem guidelines.

The shield

on all cables

spliced

by Westinghouse

are covered for

isolation purposes

only.

This explanation

was acceptable.

GEMS

Transmi tter,

Equipment

Tag

Nos.

LE-01CT-7160ASA

and

LE-01CT-7160ASB

(26)

The

equipment

was

inspected

for mounting configuration

and

wiring and

found acceptable.

Raychem

splices

were

used

and

appeared

to be properly installed.

The junction box was filled

with silicon oil as

required

to seal

the terminations for the

sensors.

No concerns

were identified during the walkdown.

Eg Cable Identification

During the

walkdown portion of the inspection,

the inspector

obtained

cable identification

numbers

from the cable

connected

to selected

Eg equipment.

The licensee

was then

asked

to show

that

the

installed

cable

was .qualified

by their existing

'qualification

documentation.

With the 'cable

identification

number,

the licensee

referenced

the applicable pull card which

showed

the

cable routing,

reel

number

and termination

points

along with

a receipt

inspecti'on report which shows the bill of

materials

number for the installed cable.

The bill of materials

number

was

shown

on the

Eg Master List which identified the

Eg

file which established

the qualification for that cable.

.With

this

sampling,

the

inspector

determined

that

adequate

traceability

existed

for the

cables

requiring

environmental

qualification.

17

(27)

Samples of Target

Rock Solenoid Valves,

ASCO Solenoid Valves and

Namco Limit Switch installations

were

examined

in various

locations inside containment for manufacturer

and model

number,

orientation,

installation,

and interfaces (i.e.,

cable splice

and

entrance

seals).

No concerns

were identified during the

walkdown.

Since

the

inspection

the

licensee

has

reported

several

concerns

regarding

the

qualified

status

of their

installed Target

Rock valves

as

a result of cracked insulation

on

Reed Switch lead wires, cracked terminal blocks

and lack of

~

similarity between

tested

configuration

versus

vendor supplied

components

(i.e.,

terminal

blocks

and wiring).

All these

components

are

internal

to the

device.

Licensee

plans

to

replace all questionable

parts prior to restart.

f.

Followup of Licensee's

Commitments

Resulting

From the

Phase I

" Inspection

At the conclusion of the

Phase I

EQ inspection,

there

were

numerous

action

items which the licensee

committed to perform.

During the

Phase

2

EQ inspection

the

INEL inspectors

examined

the

EQ files,

PCR

change

requests,

and

work requests

to verify that

the

licensee

fulfilled its

commitment to resolve

these

items.

These

documents

were reviewed

and discussed

with the licensee

to verify that the

concerns

were adequately

addressed.

The Phase

2 inspection verified that the basis for corrective action,

qualification analyses,

s'afety analyses,

revisions to the

EQ files,

and

internal

reviews

were

performed

and

accepted

by the licensee

before

the

Phase

1 action

items

were considered

closed.

Discussion

with the

licensee

and

a brief walkdown of the 'central

files

determined

that

the

document

control

was

acceptable.

All work

requests

resulting

from the initial inspection

were

found to

be

completed or scheduled for completion during the outage.

Other

NRC

Inspectors

verified the licensee's

commitments for

EQ training and

replacement

equipment.

The following documents

were reviewed with respect

to updating the