ML18093B238
| ML18093B238 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/14/1988 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093B237 | List: |
| References | |
| 50-272-86-23-EC, 50-311-86-23, NUDOCS 8810250417 | |
| Download: ML18093B238 (69) | |
See also: IR 05000272/1986023
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-272/86-23, 50-311/86-23
Docket Nos.
50-272 and 50-311
License Nos.
Licensee:
Public Service Electric and Gas Company
Facility Name:
Salem Units 1 and 2
Conference At:
NRC Region I, King of Prussia, Pennsylvania
Inspection Conducted:
September 29, 1988
Approved by:
//?;A_~~
J. Durr, Chief, Engineering Branch
'date
Conference Summary:
Environmental Qualification (EQ) enforcement conference
held to discuss the significance of concerns about the environmental
qualification of Limitorque Valve operators without required T-drains, Solenoi¢
operated valves without Conax seals, Electric junction boxes not properly
sealed, Limitorque valve operators with brakes electrically disconnected but
not physically removed, Terminal blocks associated with auxiliary feedwater
transmitters.
DETAILS
1.
Public Service Electric and Gas Company
S. Miltenberger, Vice President and Chief Nuclear Officer
R. Burricelli, General Manager of Engineering and Plant Betterment
J. Zupko, General Manager of Quality Assurance
B. Preston, Manager of Licensing and Regulations
C. Lambert, Nuclear Engineering Sciences Manager
A. Blum, Program Analysis Group Supervisor
R. Blum, Engineering Sciences Group
J. Bailey, Engineering Sciences Group
F. Thompson, Nuclear Sciences Supervisor
.
D. Perkins, Manager at Station Quality Assurance
Atlantic Electric
M. Cavalier
NRC
T. Martin, Director of Division of Reactor Safety
N. Dudley, Project Engineer
C. Miller, Reactor Engineer
J. Stone, Sr. Project Manager, NRR
P. Swetland, Project Section Chief
R. Borchardt, Senior Resident Inspector
G. Hubbard, Reactor Engineer, Office of Special Projects
C. Anderson, Chief of Plant Systems Section
2.
Conference Scope
The enforcement conference considered the following potential EQ
violations:
Limitorque Valve operators without required T-drains
Solenoid operated valves without Conax seals
Electric junction boxes not properly sealed
Limitorque valve operators with brakes electrically
disconnected but not physically removed
Terminal blocks associated with auxiliary feedwater transmitters.
The scope of the discussions included:
Safety significance of each violation, number of deficiencies and
number of systems and components affected
3
Specific and underlying cause of each violation *
Actions taken or planned to correct the individual violations to
ensure overall compliance
A discussion of each violation in light of the Modified Enforcement
Policy for EQ Requirements, GL88-07
3.
Licensee Presentation
The licensee presented their position on the EQ issues of concern.
The
licensee presentation is outlined in their handout which is provided ~s
Attachment A to this document.
4.
Conclusion
The NRC staff stated that the licensee input will be considered in
assessing NRC handling of the potential enforcement items.
The licensee
will be notified of appropriate enforcement actions in the future.
~
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PUBLIC SERVICE ELECTRIC AND GAS
J
SALEM UNITS 1 AND 2 GENERATING STATIONS
ENVIRONMENTAL QUALIFICATION PROGRAM
ENFORCEMENT CONFERENCE
SEPTEMBER 29~ 1988
-INTRODUCTION - s. E. MILTENBERGER
BACKGROUND - c. w. LAMBERT
EQ ISSUES - c. w. LAMBERT/B. A. PRESTON
STATUS OF THE ENVIRONMENTAL QUALIFICATION PROGRAM - C. W. LAMBERT
SUMMARY - s. E. MILTENBERGER
. .
"
'
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PUBLIC SERVICE ELECTRIC AND GAS
SALEM UNITS 1 AND 2 GENERATING STATIONS
ENVIRONMENTAL QUALIFICATION PROGRAM
ENFORCEMENT CONFERENCE
SEPTEMBER 29, 1988
PRESENTATION MATERIAL
.
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BACKGROUND
ENVIRONMENTAL QUALIFICATION PROGRAM
- PRIOR TO NOVEMBER 30, 1985
1-
INITIAL EQ REQUIREMENT 1970-1979
0
BOP - EQ REQUIREMENT INCLUDED WITHIN EQUIPMENT
PROCUREMENT SPECIFICATION
NSSS - VENDOR <WESTINGHOUSE> ESTABLISHED EQ TESTING
PROGRAM FOR SAFETY RELATED EQUIPMENT DOCUMENTED IN
WCAP'S
2-
l&E BULLETIN 79-0lB, 1980-1983
0
0
0
REVIEW OF ALL ELECTRICAL EQUIPMENT LOCATED IN HARSH
ENVI RO NM ENT
SPECIFY REQUIREMENTS FOR AGI~G
SUBMITTAL OF SALEM UNITS 1 AND 2 *ENVIRONMENTAL
QUALIFICATION REVIEW REPORT* - 1980
1980 NRC AUDIT OF SALEM UNIT 2 EQ PROGRAM - ALL OPEN
ITEMS HAVE BEEN RESOLVED
3.
NUREG 0588 ENDORSED BY NRC ON JUNE 25, 1980.
0
PSE&G PROMPTLY RESPONDED AND INITIATED ACTION FOR
UNITS 1&2
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BACKGROUND
-
UNIT 1 - DOR GUIDELINES
UNIT 2 - CATEGORY II REQUIREMENTS
4.
1981 THROUGH 1983 COMPREHENSIVE CHANGEOUT OF PLANT
EQUIPMENT
Cl
200 TRANSMITTERS
Cl
180 SOLENOID VALVES
Cl
250 LIMIT SWITCHES
Cl
UPGRADE OF LIMITORQUE ACTUATORS
5.
QUALITY ASSURANCE INVOLVEMENT IN DCP REVIEW AND FIELD
VERIFICATION ACTIVITIES
6.
JANUARY 61 1983 lOCFRS0.49 ISSUED AS FINAL RULE
7.
JANUARY 191 1983 NRC SERS AND TER ISSUED
Cl
PSE&G 30 AND 90 DAY RESPONSES TO QUESTIONS
0
ASSESSMENT OF COMPLIANCE TO lOCFRS0.49
0
DEVELOPMENT OF MAINTENANCE/REPLACEMENT PROGRAMS
8.
NRC SER'S FOR FINAL RESOLUTION OF EQ PROGRAM ISSUED
0
DECEMBER1 1984 FOR SALEM UNIT 1
.,__.,:_**.
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BACKGROUND
JANUARY, 1985 FOR SALEM UNIT 2
NRC CONCLUDED PSE&G'S EQ PROGRAM WAS IN COMPLIANCE
WITH THE REQUIREMENTS OF 10CFR50.49
9.
EQ TASK FORCE EFFORTS REFOCUSED TOWARD PROGRAM
ENHANCEMENT - 1985
0
.
0
0
0
MAINTENANCE REQUIREMENTS
ASSURANCE OF COMPLIANCE WITH lOCFRS0.49
QA AUDIT OF PROGRAMMATIC CONTROLS DURING JUNE, 1985
ISSUANCE OF CONSOLIDATED EQ PROCEDURE GM8-EMP-022 IN
OCTOBER~ 1985
- ,
.4
ISSUE 1
LIMITORQUE T-DRAINS
DESCRIPTION OF CONDITION
19 OF 24 LIMITORQUE ACTUATORS Cll IN SALEM 11 8 IN SALEM 2>
INSIDE CONTAINMENT WITHOUT I-DRAINS DISCOVERED DURING
WALKDOWN.
SYSTEMS AND COMPONENTS AFFECTED
-
ACCUMULATOR OUTLET VALVES - SAFETY INJECTION SYSTEM
-
RHR PUMP INLET VALVES FROM RCS HOT LEG - RHR SYSTEM
-
PORV BLOCK VALVES - REACTOR COOLANT SYSTEM
-
RHR PUMP DISCHARGE VALVES TO HOT LEGS ~ RHR SYSTEM
-
CO.NTAINMENT ISOLATION VALVES - COMPONENT COOLING WATER
CCCW> RETURN FROM RCP MOTOR
COOLERS
BARRIER COOLERS
- RCP SEAL WATER RETURN VALVE
CCVCS>
CAUSE
LACK OF SPECIFIC DETAIL IN DCP/VENDOR MANUAL INSTALLATION
I NSTl{UCTIONS
. .
...
ISSUE 1
- LIMITORQUE T-DRAINS
CORRECTIVE ACTIONS TAKEN
T-DRAINS INSTALLED IN SALEM UNIT 1 PRIOR TO RESTART FROM
MARCH 1986 REFUELING OUTAGE.
T-DRAINS INSTALLED IN SALEM
UNIT 2 PRIOR TO RESTART FROM VOLUNTARY SHUTDOWN IN MAY 1986.
NEW PROCEDURE ESTABLISHED TO CLARIFY INSTRUCTIONS WITH REGARD
TO INSTALLATION OF T-DRAINS <FIELD DIRECTIVE
S-C-A910-MFD-342).
PROCEDURE ESTABLISHED CGM8-EMP-009 ISSUED 12/85) REQUIRING
FIELD WALKDOWN BY PROJECT TEAM MEMBER IN ORDER TO CLOSE OUT A
DCP.
SAFETY SIGNIFICANCE
-
DEFICIENCIES NOT SAFETY SIGNIFICANT DUE TO QUALIFIABILITY
OF EXISTING CONFIGURATION.
- ORIGINAL LIMITORQUE ACTUATORS CERTIFIED TO TEST REPORT.
600198 ESTABLISHED QUALIFICATION OF RELIANCE RAD-H TYPE
"OTOR WITHOUT T-DRAINS.
UPGRADED VALVE ACTUATOR MOTORS TO CLASS H1 TYPE RH IN
1984.
NEW RELIANCE MOTORS CERTIFIED TO TEST REPORT
600456.
SIMILARITY ANALYSIS DEMONSTRATES THAT UPGRADED RELIANCE
TYPE RH MOTOR WAS QUALIFIABLE WITHOUT T-DRAIN.
- ,
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ISSUE 2
CONAX CONNECTORS FOR SOLENOID VALVES
DESCRIPTION OF CONDITION
8 OF 248 SOLENOID OPERATED VALVES WITHOUT REQUIRED CONAX
CONNECTORS DISCOVERED DURING WALKDOWN.
SYSTEMS AFFECTED
-
POST ACCIDENT SAMPLING SYSTEM - SALEM UNIT 1-
-
REACTOR VESSEL HEAD VENT VALVES - CONAX SEALS ARE NOT
REQUIRED FOR THE QUALIFICATION OF THESE VALVES.
CAUSE
ISOLATED OCCURRENCE OF NON-ADHERENCE TO INSTALLATION
INSTRUCTIONS.
ONLY 8 OUT OF 754 CONAX CONNECTORS NOT INSTALLED AS REQUIRED.
CORRECTIVE ACTIONS TAKEN
CONAX CONNECTORS INSTALLED PRIOR TO RESTART FROM SALEM 1
"ARCH 1986 REFUELING OUTAGE.
PROCEDURES ADOPTED REGARDING EQ REVIEW OF DCPS.
FIELD WALKDOWN PROCEDURE ALREADY IMPLEMENTED <DECEMBER 1985).
.I
ISSUE 2
CONAX CONNECTORS FOR SOLENOID VALVES
SAFETY SIGNIFICANCE
NOT SAFETY SIGNIFICANT.
-
PASS NOT REQUIRED FOR ACCIDENT MITIGATION.
-
QUALIFIABLE BY TEST FOR AT LEAST 12 DAYS*
-
REACTOR VESSEL HEAD VENTS DO NOT REQUIRE THE CONAX
SEALS, AND ARE NOT REQUIRED FOR MITIGATION OF DESIGN
BASIS ACCIDENTS.
-
NORMALLY DE-ENERGIZED, KEY LOCKED CLOSED DURING
OPERATION.
-
REDUNDANT MEANS OF NON-CONDENSIBLE GAS REMOVAL
DURING RECOVERY AS IDENTIFIED IN EOP'S.
-
VALVES ARE FAIL-CLOSED.
..
ISSUE 3
ELECTRIC JUNCTfON BOX SEALS
DESCRIPTION OF CONDITION
16 OUT 'OF 138 JUNCTION BOXES C7 IN SALEM l AND 9 IN SALEM 2)
WERE NOT PROPERLY SEALED IN ACCORDANCE WITH DCP INSTRUCTIONS.
SYSTEMS AND COMPONENTS AFFECTED
-
MSIV INDICATION LIMIT SWITCHES
-
CONTAINMENT PRESSURE VACUUM RELIEF -ISOLATION SYSTEM SOVs
-
UNIT 2 LIQUID RADWASTE SYSTEM CONTAINMENT ISOLATION VALVE
LIMIT SWITCHES.
CAUSE
CONFUSION OVER 'GENERIC INSTALLATION REQUIREMENTS, WHICH LED
-TO MISINTERPRETATION.
OVERSfGHT BY EQ SPONSOR IN NOT INCLUDING ALL JUNCTION BOXES
IN EQML.
CORRECTIVE ACTIONS TAKEN
0
JUNCTION BOXES WERE EITHER PROPERLY SEALED OR EVALUATED
AND FOUND ACCEPTABLE BASED ON THEIR CONFfGURATION PRIOR TO
RESTART FROM SALEM l MARCH, 1986 REFUELING OUT~GE AND MAY
1986 VOLUNTARY SHUTDOWN OF SALEM UNIT 2.
ISSUE 3
ELECTRICAL JUNCTION BOX SEALS
0
EQML AND DESfGN DOCUMENTS WERE UPDATED.
ADMINISTRATIVE CHANGES WERE MADE <PROCEDURE 'GMB-EMP-009
ISSUED 12/BS>*To ENSURE EQ SECTION REVIEW OF DCPs AND
EQ-RELATED DRAWINGS1 AND VERIFICATION OF FIELD WALKDOWN
PERFORMED BY PROJECT TEAM MEMBERS TO CLOSE OUT DCP.
FIELD DIRECTIVE <NO. S-C-A910-NFD-0405) FOR INSTALLATION
SEALING REQUIREMENTS WAS ISSUED IN AUGUST 1986.
SAFETY SfGNIFICANCE
-
DEFICIENCY NOT SAFETY SfGNIFICANT:
INDIVIDUAL CONFfGURATIONS WERE QUALIFIABLE.
AFFECTED COMPONENTS WOULD COMPLETE THEIR INTENDED
FUNCTION.
- MSIV LIMIT SWITCHES PROVIDE POSITION INDICATION FOR
WHICH ALTERNATE POSITION INDICATION WAS AVAILABLE.
~ CPVRIV AND LIQUID RADWASTE VALVES '60 TO FAIL-SAFE
. POSITIQN.
- .
- ***, ..
ISSUE 4
REMOVAL OF LIMITORQUE OPERATOR MOTOR BRAKES
7 C4 IN SALEM 11 3 IN SALEM 2> OF 136 CONLY 51 ORfGINALLY
SUPPLIED WITH MOTOR BRAKES> LIMITORQUE MOTOR OPERATORS WITH
MOTOR BRAKES FOUND OUTSIDE OF CONTAINMENT WITH BRAKES
ELECTRICALLY DISCONNECTED. BUT NOT PHYSICALLY REMOVED.
SYSTEMS AND COMPONENTS AFFECTED
-
COMPONENT COOLING WATER OUTLET OF RHR HEAT EXCHANGERS
-
SALEM 1 SAFETY INJECTION PUMP SUCTION
-
SALEM 2 RHR PUMP SUCTION.
CAUSE
MISUNDERSTANDING AS TO WHAT CONSTITUTED COMPLETE REMOVAL OF
THE BRAKES.
SPONSOR ENGINEER STATES THAT HE OBTAINED CONCURRENCE FROM
LIMITORQUE REPRESENTATIVE THAT ELECTRICAL.DISCONNECTION OF
BRAKES WAS SATISFACTORY.
CORRECTIVE ACTIONS TAKEN
MOTOR BRAKES WERE PHYSICALLY REMOVED PRIOR TO RESTART FROM
SALEM UNIT 1 MARCH1 1986 REFUELING OUT<<GE AND MAY 1986
VOLUNTARY SHUTDOWN OF SALEM UNIT 2.
WALKDOWN VERIFIED NO
OTHER EXAMPLES OF THIS DEFICIENCY.
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ISSUE 4
REMOVAL OF LIMITORQUE OPERATOR MOTOR BRAKES
REEMPHASIS OF ADHERENCE TO INSTRUCTIONS AS PART OF EQ
TRAINING PROGKAM OF STATION PERSONNEL.
SAFETY SIGNIFICANCE
-
DEFICIENCIES NOT SAFETY-SIGNIFICANT DUE TO QUALIFIABILITY .
OF EXISTING CONFIGURATION.
LIMITORQUE TEST REPORTS 600198 AND FC2485-l QUALIFY THE
OPERATORS WITH BRAKES <REPORT WAS FILED IN BACKUP
FI LES>.
MAXIMUM RADIATION EXPOSURE WOULD NOT DEGRADE BRAKE OR
COIL MATERIAL TO THE POINT OF IMPAIRING OPERABILITY.
INSERVICE STROKE TESTS HAVE CONFIRMED THAT THE PRESENCE
OF THE DEENERGIZED BRAKES DID NOT IMPAIR SAFETY
FUNCTION.
AFFECTED VALVES WOULD BE POSITIONED IN THEIR REQUIRED
RECIRC LINEUP BEFORE THEY WOULD BE EXPOSED TO
SIGNIFICANT RADIATION DOSES.
- SIMILARITY ANALYSIS DEMONSTRATES THAT AS-FOUND
CONFIGURATION WAS QUALIFIABLE WITH MOTOR BRAKES.
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ISSUE 5
AUXILIARY FEEDWATER FLOW TRANSMITTER CONNECTIONS
DESCRIPTION OF CONDITION
MARCH, 1986 WALKDOWN IDENTIFIED 8 C4 IN EACH UNIT> AUXILIARY
FEEDWATER FLOW TRANSMITTERS COUT OF 200 QUALIFIED
TRANSMITTERS> THAT WERE TERMINATED WITHIN JUNCTION BOXES ON
TERMINAL BLOCKS RATHER THAN QUALIFIED SPLICES.
SYSTEMS AND COMPONENTS AFFECTED
-
AUXILIARY FEEDWATER SYSTEM FLOW TRANSMITTERS
CAUSE
ISOLATED CASE OF USE OF TERMINAL BLOCKS IN A TRANSMITTER
CIRCUIT WHICH WAS NOT DISCOVERED BY THE REVIEWERS DURING
REVIEW OF IN 84-47.
CORRECTIVE ACTIONS TAKEN
THE TRANSMITTER TERMINATIONS WERE MODIFIED TO USE QUALIFIED
RAYCHEM SPLICES..
SPLICES WERE INSTALLED_ PRIOR TO RESTART
FROM SALEM 1 MARCH, 1986 REFUELING OUTAGE AND MAY, 1986
VOLUNTARY SHUTDOWN OF SALEM 2.
- .. *- . . ";
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ISSUE 5
AUXILIARY FEEDWATER FLOW TRANSMITTER CONNECTIONS
ADMINISTRATIVE CHANGES MADE <PROCEDURE GM8-EMP-009 ISSUED
12/85) TO ENSURE EQ SECTION REVIEW OF DCPs AND EQ-RELATED
DRAWINGS1 AND VERIFICATION OF FIELD WALKDOWN PERFORMED BY
PROJECT TEAM MEMBER TO CLOSE-OUT DCP.
SAFETY SIGNIFICANCE
-
DEFICIENCY WAS NOT SAFETY SIGNIFICANT:
- CONFIGURATION WAS QUALIFIABLE
- - TRANSMITTERS HAVE NO ACCIDENT MITIGATION FUNCTION.
AFW FLOW VERIFICATION WILL OCC*UR LESS THAN TWO MINUTES
INTO ACCIDENT1 BEFORE ADVERSE CONDITIONS COULD AFFECT
THE TERMINATIONS.
- . AFW FLOWRATE IS GOVERNED BY STEAM GENERATOR LEVEL, NOT
THE INDICATED FLOW.
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GENERIC LETTER 88-07 APPLICATION
EVALUATE EACH ISSUE AGAINST GENERIC LETTER 88-07 CRITERIA FOR
APPLICATION OF THE MODIFIED ENFORCEMENT POLICY:
1.
PRIOR TO NOVEMBER 30J 1985 DEADLINE
2'.
"CLEARLY KNEW OR CLEARLY SHOULD HAVE*KNOWN" TEST
-
AVAILABILITY OF VENDOR-SUPPLIED QUALIFICATION DOCUMENTATION
-
EQUIPMENT CONFIGURATION VERIFICATION MEASURES
-
PRIOR KNOWLEDGE OF POTENTIAL EQ DEFICIENCY.
-
IDENTIFICATION AND CORRECTION OF SIMILAR PROBLEMS BY OTHER-
LICENSEES PRIOR TO DEADLINE
GENERIC LETTER 88-07 ENFORCEMENT POLICY ASSESSMENT
IF APPLICATION OF ENFORCEMENT POLICY IS CONSIDERED, DETERMINE
"SIGNIFICANCE" OF EACH ISSUE?
1.
IS THE EQUIPMENT "QUALIFIABLE"?
2.
IF NOT SINGULARLY "SIGNIFICANT", ARE THE PROBLEMS, IN THE
- AGGREGATE, PROGRAMMATIC?
3.
IF "SIGNIFICANT", CLASSIFY PROBLEM AS "ISOLATED", "MODERATE",
OR "EXTENSIVE" PURSUANT TO THE EXPLANATION PROVIDED IN GENERIC
LETTER 88-07.
.
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MODIFIED POLICY vs 5 DEFICIENCIES
- 1.
LIMITORQUE T-DRAINS
2.
CONAX CONNECTORS FOR SOLENOID VALVES
3.
ELECTRIC JUNCTION BOX SEALS
4.
REMOVAL OF LIMITORQUE OPERATOR MOTOR BRAKES
5.
AUXILIARY FEEDWATER FLOW TRANSMITTER CONNECTIONS
° CLEARLY SHOULD HAVE KNOWN ?
0
QUALIFIABILITY
- GENERAL ENFORCEMENT POLICY SHOULD APPLY -
MITIGATION/ESCALATION FACTOR ASSESSMENT
IF A CIVIL PENALTY IS PROPOSED UNDER GENERIC LETTER 88-07 FULL
MITIGATION IS WARRANTED:
-
ALL DEFICIENCIES WERE IDENTIFIED BY PSE&G AS A RESULT OF SELF-
INITIATED WALKDOWNS AND PROMPTLY REPORTED TO NRC
-
PROMPT AND EXTENSIVE CORRECTIVE ACTIONS TAKEN~ INCLUDING EXTENSION
OF SALEM l OUTAGE~ VOLUNTARY SHUTDOWN OF SALEM 2~ PHYSICAL
MODIFICATIONS AND ADMINISTRATIVE IMPROVEMENTS
-
LIMITED NUMBER OF COMPONENTS AND SYSTEMS AFFECTED
-
PSE&G APPLIED BEST EFFORTS TO COMPLETE EQ PROGRAM WITHIN DEADLINE
0
MAJOR REPLACEMENT EFFORT UNDER NUREG-0588~ CAT. II (1981-83)
0
QA INVOLVEMENT (1981+)
0
EQ TASK FORCE EFFORTS (1984-1985)
° FINAL SERS AND APPROVED PROGRAM (1984-1985)
0
PROGRAM ENHANCEMENTS Cl985)
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ASSESSMENT UNDER GENERAL ENFORCEMENT POLICY
ClOCFR PART 2~ APPENDIX C>
THE FOLLOWING POINTS SHOULD BE CONSIDERED IN APPLYING lOCFR
PART 2~ APPENDIX C
1.
THE EQ DEFICIENCIES IN QUESTION WERE IDENTIFIED BY PSE&G
2.
THE DEFICIENCIES WERE REPORTED IN LER 86-007
3.
EACH DEFICIENCY IS NO MORE THAN SEVERITY LEVEL V .
4.
APPROPRIATE CORRECTIVE ACTIONS HAVE BEEN TAKEN TO RESOLVE
THE DEFICIENCIES AND PRECLUDE RECURRENCE
..
5.
THE FINDINGS COULD NOT HAVE BEEN PREVENTED BY CORRECTIVE ACTIONS
RESULTING FROM A PREVIOUS VIOLATION
6.
THE EQ DEFICIENCIES IN QUESTION ARE NOT SAFETY SIGNIFICANT
- EXERCISE OF DISCRETION IS WARRANTED -
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PROGRAM STATUS
ENVIRONMENTAL QUALIFICATION PROGRAM AFTER NOVEMBER 30, 1985
1.
MILESTONE EVENTS
0
0
0
EQ WALKDOWN FOR MAINTENANCE BASELINE OF SALEM UNIT I
- MARCH 22, 1986 *
0
PLAN INITIATED IN EARLY 1985
0
VERIFY EQUIPMENT SERIAL NO. AND INSTALLATION DATE
TO ESTABLISH START OF QUALIFIED LIFE
.
0
J)ETERMINE SPECIFIC EQUIPMENT LOCATION <ELEVATION
AND COLUMN LINE>
0
VERIFY MOUNTING ORIENTATION, MOISTURE SEAL, SPLICE
OR TERMINAL BLOCKS
SHUTDOWN OF SALEM UNIT 2 TO PERFORM COMPREHENSIVE
WALKDOWN - MAY l, 1986
0
SAME ACTIVITIES AS SALEM UNIT 1
0
ISSUE LER #86-007 - MAY 8, 1986
SHUTDOWN OF SALEM UNITS 1&2 - AUGUST 6, 1986
0
REPLACE QUESTIONABLE WIRE IN LIMITORQUE ACTUATORS
- IN RESPONSE TO INFORMATION NOTICE #86-03
0
PROGRAM STATUS
0
100% WALKDOWN OF LIMITORQUE ACTUATORS IN EQ
PROGRAM
-
0
100% REPLACEMENT OF SUSPECT WIRE WITH QUALIFIED
ROCK8ESTOS FIREWALL III WIRE
NRC EQ INSPECTION - AUGUST 11-15, 1986
0
ALL ISSUES ADEQUATELY RESOLVED
2-
ORGANIZATION ENHANCEMENTS
0
(l
ENGINEERING & PLANT BETTERMENT CE&PB> REORGANIZATION
TO MATRIX ORGANIZATION - OCTOBER, 1987
FORMED THE PROGRAM ANALYSIS GROUP CPAG> - OCTOBER,
1987
0
PROGRAMMATIC SPONSOR FOR EQ
° CENTRALIZED DEDICATED GROUP TO SUPPORT SALEM AND
HOPE CREEK STATIONS
0
ESTABLISH COMMONALITY, CONSISTENCY BETWEEN SALEM
AND HOPE CREEK STATIONS
3.
PROGRAMMATIC ENHANCEMENT
0
DEVELOPMENT OF PROGRAMMATIC STANDARDS
.o
RESTRUCTURE OF SALEM EQ FILES
0
PROGRAM STATUS
CONVERSION OF HOPE CREEK EQ FILES FROM PURCHASE ORDER
BASIS TO EQUif'lENT TYPE BASIS
4.
INDUSTRY ENVOLVEMENT
0
0
-
Cl
0
MEMBER OF NUCLEAR UTILITY GROUP ON EQUIPMENT
QUALIFICATION CNUGEQ)
MEMBER OF EPRI
MEMBER OF SEISMIC QUALIFICATION UTILITY GROUP CSQUGl
MEMBER OF SEISMIC OWNERS GROUP
\\.
PUBLIC SERVICE ELECTRIC AND GAS
SALEM UNITS 1 AND 2 GENERATING STATIONS
ENVIRONMENTAL QUALIFICATION PROGRAM
ENFORCEMENT CONFERENCE
SEPTEMBER 29, 1988
DETAIL HANDOUT MATERIAL
- t
INTRODUCTION
PUBLIC SERVICE ELECTRIC AND GAS
SALEM GENERATING STATION UNITS 1&2
NRC EQ ENFORCEMENT CONFERENCE
SEPTEMBER 29, 1988
The material provided in this package supplements PSE&G's verbal
presentation in response to the NRC letter of August 19, 1988
with regard to PSE&G's identified deficiencies in the Salem Units
l and 2 concerning the Environmental Qualification of Electrical
Equipment as addressed in LER No.86-007, dated May 8, 1986.
BACKGROUND
The following is a discussion which chronlogically presents the
various milestones encountered during the development of the
Salem Units 1 and 2 Environmental Qualification Program.
The environmental qualification of electric equipment has been an
item of primary importance throughout the licensing and
operational stages of both Salem Unit 1 and Salem Unit 2.
At
Salem Unit 1, guidance for the design and installation of
safety-related electrical equipment was initially {i.e., in the
early 1970s) based on existing engineering codes and standards
and was indicated within the specific design and procurement
specifications for the individual components.
For the NSSS
equipment, qualification assessments were made by the vendor
(Westinghouse) to assure the operation of appropriate
safety~related equipment in a post-accident environment.
At the
site, all of this equipm-ent was installed under the purview of an
effective Quality Assurance program established under the
requirements of 10CFR50, Appendix B.
While initial environmental qualif ic~tion efforts were similar
for Salem Unit 1 and Unit 2, the actions taken to comply with EQ
guidelines were magnified by Salem Unit 2's status as a post-TM!
near OL plant.
In 1978 and 1979, PSE&G responded to a number of
Salem Unit 2 SER Open Items with regard to the qualification of
terminal blocks, limit switches, solenoid valves, pressure
transmitters, instrument panels, motor operated valves and
cables *.
On January 14, 1980, the N.RC Office of Inspection and Enforcement
issued the DOR guidelines and I&E Bulletin 79-0lB.
In response*
to Bulletin 79-018 and its associated supplements, PSE&G
conducted an EQ review of electrical and control equipment
located in a {post-accident) harsh environment.
Equipment
Al 88/ba
"
Background (Cont.)
2
qualification was based on IEEE 323-1971 with the additional
requirements for aging noted in Bulletin 79~01B.
This review
effort resulted in the submittal of the original Salem Units 1
and 2 Environmental Qualification Review Report to NRC on
December 1, 1980.
On June 25, 1980, the NRC issued a Generic Letter endorsing the
EQ guidelines provided in NUREG-0588.
PSE&G promptly responded
and initiatea action to review the Salem Units ) and 2 EQ program
based on the Category II requirement~ of NUREG-0588 (Salem Unit 1
is a DOR plant).
On September 8-9, 1980, and December 9-10, 1980, NRC conducted a
pre-license audits of Salem Unit 2 EQ Program at the corporate
headquarters in Newark~ NJ.* Issues raised by the NRC during the
Septemb~r audit-were adequately addressed prior to the December
audit.
In 1981, PSE&G initiated utilization of the EPRI ~Q Data Bank
(EQDB) in order to obtain additional information concerning
equipment qualification.
This data base provided support to the
Salem EQ program and also allowed PSE&G access to a data base of
other utility EQ-related activities.
From 1981 through 1983 PSE&G initiated and completed whole. scale
-changeout of plant equipment with new environmentally qualified
equipment.
This effort included replacement of approximately 200
transmitters, 180 solenoid valves, and 250 limit switches in
Units 1 and 2.
During 1984 and early 1985, 24 Limitorque
actuator's motors were upgraded from class B to class RH
insulation in Salem Units 1 and 2.-
QA's involvement in the EQ program, in particular verification of
design changes Covering replacement of the above noted equipment
was significant.
In 1981, prior to the start of the EQ equipment
changeouts, surveillance plans were executed to provide
verification of pre-assembly operations as well as field
installation surveillances covering component model verification,
installation of splices and seal assemblies torquing
requirements, and various other attributes.
Review of the design
change packages content was also done by QA for procedural
compliance, specific details and appropriate engineering
instructions.
The reviews by QA resulted in favorable results in
each of the above areas.
The Salem Units 1 and 2 Environmental Qualification Review Report
was reviewed for the NRC by the Franklin Research Center.
The
NRC Safety-Evaluation Reports (SERs) for Salem Units 1 and 2
along with the associated Franklin Technical Evaluation Reports
Al88/ba
Background (Cont.)
3
(TERs) were issued in January, 1983, shortly after the issuance
of the final EQ rule, lOCFRS0.49 on January 6, 1983.
Following
the required 30-day and 90-day responses to the SERs, the
development of the Salem EQ program was defined by four (4)
distinct efforts:
1.
The resolution of any remaining concerns ~ith regard to the
NRC SERs and the ~ranklin TERs,
2.
The assessment of compliance with lOCFRS0.49, particularly
with regard to the 3ppl:cation of the more stringnt
requirements of IEEE 323-1974 to replacements and spare
parts,
3.
The development of a maintenance/replacement program for
equipment with less than a 40-year qualified life, and
4.
The categorizing and disposition of all safety-related
electrical components into functional maintenance,
surveillance and test plans.
These efforts resulted in the formation of a task force in early
1984 to keep track on the progress of responses to NRC open items
as well as the overall development of the EQ program.
This task
force was headed by Engineering and Plant Betterment (E&PB),
Systems Analysis Group (SAG) who, with plant engineering, were
primarily responsible for the development of the program and its
related documentation.
On April 24, 1984, a meeting was held in Bethesda, MD to discuss
NRC's remaining EQ concerns and PSE&G compliance with
lOCFRS0.49.
NRC's primary concerns were:
1.
The finalization of the EQ Master List,
2.
The response to the two generic deficiencies noted in the
Franklin TER with regard to submergence and chemical spray,
and
3.
The confirmation that all design basis events which could
result in a potentially harsh environment (including flooding
outside containment) were addressed in the identification of
safety-related electrical equipment which was to be
environmentally qualified.
PSE&G's responses to these concerns were documented in a letter
dated June 8, 1984.
The NRC SERs for Final Resolution of the EQ
Program were issued in December 1984 for Salem Unit 1 and January
19~5 for Salem Unit 2.
?\\188/ba
- '
.... -*** .. _;_ *.
-~** **- -
.* ... -*
- ~ .. *-***--***. ~*-***""'-"""""'****---.... ~.-*-**-*- - --***-**
Background (Cont.)
4
The NRC concluded that Public Service Electrical and Gas
Company's Equipment Qualification Program was in compliance with
the requirements of 10CFR50.49.
QA verification continued during this period on EQ related design
changes.
In line surveillances were supplemented in 1984 with
follow-up desiqn change package and EQ report reviews as
committed to the NRC during the April, 1984 meeting.
EQ Task Force efforts were refocused at this time toward program
enhancement regarding maintenance and control and assurance of
continued compliance with 10CFR50.49.
Several QA walkdowns of
randomly selected components were initiated at the direction of
the task force.
In conjunction with the task force, SAG
initiated an effort to review-all qualification documents and to
assure establishment of the programmatic controls necessary to
maintain appropriately qualified electrical equipment.
A QA
audit of the programmatic control of EQ at Salem Units l and 2
was performed, at the recommendation of the EQ Task Force, from
June 17-25, 1985.
The QA audit did not reveal any obvious
programmatic flaws but did result in the initiation of several
recommendations with regard to procedures, documentation and
training which were incorporated accordingly.
On October 16, 1985, PSE&G procedure GM8-EMP-022 was issued to
consolidate and provide a more comprehensive description and
guide to the EQ requirement& established for Salem.
This
procedure centralized all phases of the EQ program so that its
implementation could proceed more effectively.
Further enhancement of the program by SAG in 1985 included
reviewing all of the EQ file binders to assure compliance with
the above noted procedure.
In addition, new field directives
regarding installation and maintenance requirements were issued
providing more explicit information for Station personnel usage.
The above summary represents those actions taken by PSE&G prior
to the November 30, 1985 mandatory EQ deadline to establish and
maintain the qualification of safety-related electrical equipment
at Salem Units 1 and 2.
PSE&G feels that the results of these
efforts represent a firmly established EQ program and that the
efforts themselves represent a substantial commitment on our-part
to comply with the EQ deadline.
Al88/ba
PUBLIC SERVICE ELECTRIC AND GAS
TECHNICAL ASSESSMENT
ISSUE 1
LIMITORQUE T-DRAINS
I.
STATEMENT OF CONDITION
As described in LER 86-007, PSE&G identified (during a
self-initiated walkdown) eleven (11) Unit 1 and eight
(8) Unit 2 Limitorque actuators inside containment for
which T-drains had not been installed in the motor bell
- housings.
These actuators were located inside
containment and involve the safety injection system,
residual heat removal system, reactor coolant system,
component cooling water system and the chemical and
- volume control system.
II *. ROOT CAUSE
These omissions were isolated instances.
PSE&G
nevertheless considers the underlying cause of the
omission to be a lack of explicit instructions
that detailed the T-drain requirement.
III. CORRECTIVE ACTIONS TAKEN
PSE&G took prompt corrective actions to address fully
the deficiency as well as the root cause.
Specifically,
PSE&G installed T-drains in Salem Unit 1 prior to
-
restart from the March, 1986 ~efueling outage.
T-drains
w~re aiso installed in Salem Unit 2 prior to restart
from a voluntary shutdown in May, 1986.
PSE&G further
established a new procedure (S-C-A910-MFD-0342, dated
December 2, 1985) to provide added as~rnrance that future
DCPs include sufficient instructions with respect to
T-drains and other EQ requirements.
In addition, PSE&G
had previously implemented a new engineering procedure,
GM8-EMP-009 dated December, 1985, to close-out DCPs with
a field walkdown performed by the project team members.
These actions provided assurance that PSE&G was in full
compliance prior to restart and that this type of
condition should not recur.
IV.
SAFETY SIGNIFICANCE
1.
There was no safety significance regarding the
installed configuration in that:
Al88/l
..
Issue 1 (Cont.)
2
(a)
On a case specific basis, PSE&G analysis
con~luded that Salem Station containment
Lirritorque actuators do not require T-drains to
assure qualification.
The actuators were
qualifiable without T-drains based on
Limitorque Test Report 600198, which was the
original basis for qualification of Limitorque
actuators inside containment.
(b)
Report 600198 tested a size SMB-0-15 actuator
without T-drains to a maximum temperature of
328°F, 105 psig, and 100% saturated steam
environment.
Radiation qualification was
achieved by utilizing Report 600376A plus
analyses.
(c)
Qualification upgrading program consisted of
installing superior quality components (DCR's
1788 and 1789).
New class H, type RH motors
were ordered to replace existing RAD H
containment motors.
(d)
Motor similarity analysis demonstrates
qualif iability of class H, type RH motor to
original motor qualification report, 600198.
(See Appendix A for qualifiability bases)
V.
STATUS
Al88/l
Full compliance with respect to the T-drain.
condition was achieved by April 30, 1986 for Unit 1,
and May 3, 1986 for Unit 2.
-:... ..... *.:*:. .. ~, : .. ~,;;_,,, .. *-- .* .:. --
. .* ... ~ . '* . -
'
- ...
~ .. -' * ~-. , ** , - * ,..:-.~ ... ,, *. -* ** *.:. * .* .:.. .. ,.. .,, ;. .. :-_,* ,; ... * *.*:-. ...:, ;: * *;..,. ;;~ *. :... .. *-~;.::. .-:.. , .:* .*. _ *. .- :-J.-.!>.! *. . "" ,..,_ . _ ........ * ;.,,_ .. __ .. ,. ~-
- .L*
- _.~. "-'-****** ***- .__;.:,. *-:-..
,.
LIMITORQUE T-DRAINS
APPENDIX A
BASES FOR QUALIFIABILITY
Limitorque designed the actuator with the philosophy th~t the
environmental ambient conditions be permitted to enter the
actuator with minimal restrictions, while ensuring the
capability of the actuator to perform their safety function
during the accident scenario.
The Ankorite gaskets, used between the actuator housing and
.the limit switch compartment cover, will seal against the
entry of fluids sprayed on the actuator, but are not designed
to seal against vapor entry as would be experienced during an
accident (as a result of differential pressure).
Qualif icatio~ testing was performed at extremely high
pressure and temperature conditions.
This philosophy was
designed to incorporate a significant safety margin.
Motor
T-drains were installed on the test units to drain away
potential acctirnulation of fluids that could result from the
extremely high test pressure, combined with the saturated
steam environment.
In order to serve their principal purpose, which is to
function as drainage pathways, the T-drains should be
installed at actuator low points.
Limitorque recommends that whe~ T-drains are requir~d, that
they be installed on the motor bell, regardless of the
orientation of the as-fnstalled actuator, to represent the
tested configuration.
Motor orientation, which would preclude moisture accumulation
in the motor bell, does not necessitate the use of T-drains
as drainage ports, as the function of the T-drain, to
eliminate moisture from the low point of the unit, would not
be performed.*
Due to the un~ealed actuator design, internal to external
actuator pressure equalization will be achieved without the
need of T-drains.
Salem Station Limitorque actuators inside containment are*
oriented *such that the motor and limit switch compartment are
horizontal.
The limit switch compartment cover is mounted in
Al88/l
.,
- . -* .... _. ~-.,, .
.
'
Appendix A (Cont.)
2
a vertical position, thus the bottom of the limit switch
compartment is the low point of the ~ctuator.
In this
orientation, it is unlikely that moisture will accumulate in
the moto~ bell housing.
The original Reliance RAD H motors were certified to
Limitorque Qualification Report 600198, which was the basis
for qualif ic3tion of Limito~que actuators for use inside
containment at Salem Station.
Testing and qualification to
this report was done without the uie of T-drains.
This
report is currently maintained in the Salem EQ backup files.
For actuators tested without T-drains, as is the case of
Report 600198, T-drains are not required to support the
qualification of the actuators.
The replacement Reliance*
type RH motors, are supplied with certification to more
recent qualification testing (Report 600456), that had
T-drains installed on the motor bell.
When upgrading the
actuators inside containment, qualification changed from
Report 600198 to 600456.
Since the .RH type of motor
insulating system is considered superior to the RAD H system,
an analysis has been generated that supports the gualif ied
configuration of the original installation without the. use of
motor T-drains.
In this case, the absence of T-drains is
readily justified and will not.prevent proper motor operation
or violate environmental qualification.
To support the issue of operability of the installed
. configuration without T-drains, motor orientation, which
would preclude moisture accumulation in the motor bell,
should not necessitate the use of T-drains (as drainage
ports}.
Salem Station Limitorque actuators inside
containment are oriented such that the motor and limit switch
compartment are horizontal.
In this configuration, it is
unlikely that moisture will accumulate in the motor bell
housing, as the motor bell is not at the low point of the
actuator unit.
Since the actuators installed at Salem Station are not in the
worst possible~test orientation position, the functionality
of the T-drains on the motor bell is not essential for
moisture elimination.
Also, due to the results of Limitorque
test 600198, and the unsealed actuator design, internal to
external pressure equalization will be achieved without the
need *of T-drains.
Thus, Salem Station Limitorque actuators
inside containment are qualif iable in their installed
Al88/l
._ .... : . .- . *--- :.
..
. -* . . . --*
~*
. - - *..* : *..
~ .*. *-*:
.~ .,.. ..... * ~*. -** *:~* .. --~---.: *.. _;:;_.: *. _:*.~.:c.:.::...J - ""-'"-""-*-'** ;_ ---* ._ .*. ; ____ .... -4.. : .. ..... ' ~; * '* **.*** *,. -.-**** -'*-* .,,
PUBLIC SERVICE ELECTRIC AND GAS
TECHNICAL ASSESSMENT
ISSUE 2
. SOLENOID OPERATED VALVES -
CONAX SEALS
I.
STATEMENT OF CONDITION
As.described in LER 86-007, PSE&G identified during
self-initiated walkdowns of Salem Units 1 and 2
instances in which Conax connectors had not been
installed in solenoid operated valves, contrary to the
requirements of PSE&G's EQ requirements.
The solenoid operated ~alves involved were on the Unit.!
Post Accident Sampling System and the Unit 1 and Unit 2
Reactor Head Vent valves.
A total of 16 valves were
identified in the LER as not utilizing seal connectors.
Subsequent evaluation has shown that the Reactor Head
Vent valves do not require seal connectors, therefore,
only 8 of 248 solenoid operated valves were installed
without the required seal connectors.
I I.
ROOT CAUSE
The DCP's for the ASCO PASS solenoid valves specifically
directed that Conax connectors be installed.
The
required connectors for the PASS valves involved are
located within a single panel (801-lA) in Unit 1.
Other
ASCO solenoid valve installations.in Unit 1 pnd Unit 2
- properly addressed s.imilar DCP seal requirement
instructions.
Accordingly, this appears to be an
isolated instance of overlooking explicit directions, as
these are the only eight, out of 754 Conax connectors,
that were not installed as required.
With respect to the Target Rock Reactor Head Vent
solenoid valves, no DCP requirement was necessary as the
seals are not required.
III. CORRECTIVE ACTIONS TAKEN
PSE&G promptly corrected the identified deficiencies by
installing the required Conax connectors prior t6
restart from the Unit 1 refueling outage which commenced
in March, 1986, and instituting corrective measures to
address the root cause of the deficiency.
Specifically,
in response to the findings discussed in LER 86-007,
PSE&G instituted a procedure to require a formal review
Al88/2
- .
Appendix A (Cont.)
3
- configuration by the original basis supplied in Report
600198.
Detailed analysis have been performed by Engineering
and are on file at PSE&G.
Al88/l
..
,'--,
.. *.: ...... --..-.. .: .~. : .. : __ , ___ ~ __ ._,;*_,._,_,. ... : ... :.*: ... ~* ...... -~. * .. -.. * .... *~-~-- -*---: _*.: .. :_ .. :.* .. -......... *,_ . -*-~--~ ..... __ ,,_, __ _.*, .. *
Issue 2 (Cont.)
2
In addition, another
procedure had previously been implemented (December,
1985) to require a post-installation walkdown by the
IV.
SAFETY SIGNIFICANCE
The identified deficiencies were not safety significant.
Al88/2
Unit 1 Post Accident Sampling System Valves -
Post
Accident Monitoring System
Evaluation of these solenoid valves has shown that
they are qualifiable, by vendor testing perf0rmed,
for a minimum of 12 days.
Inoperability of the valve solenoids could preclude
the ability to sample the containment atmosphere and
the Reactor Coolant System to assess cor& damage.
(NUREG 0737,Section II.B.3.)
Although this
sampling is not required for mitigation of an
accident, it is employed for emergency planning
purposes such as providing protective action
recommendations.
There is no condition which would
re$ult in inadvertent opening of the valves.
A
short due to moisture would result in the valves
failing closed.
In addition, in series with each
valve in question is-a second valvE (located outside
containment) in a mild envir_onment.
The switches.located in the control room for the
PASS valves provide control power only.
The valves
are operated from the PASS sampling panel.
This
panel contains adequate inform2tion to ascertain
valve position and flow.
Once the operator
energizes the control power he has no further
interface with the operation of these valves.
Therefore there is no potential for the operator to
be misled or confused by conflicting information
from valve position.
Unit l and Unit 2 Reactor Head Vent Valves
Evaluation of these solenoid valves has shown that
seal connectors are not required to ensure proper
operation of the valves.
._._. .... ,.
<'
"
Issue 2 (Cont.)
3
These valves are normally key-locked closed during
operation, and are used only as a last resort to
remove a non-condensible gas bubble from the reac_tor
head in the event that no other means is available
(EOP-FRCI-3).
However, these valves are not
required to mitigate accidents analyzed in the
FSAR.
Additionally, there is no condition which
would result in inadvertent opening of the valves;
i.e., a short due to moisture would result in the
valves failing closed.
If moisture intrusion were to occur, the resultant
short circuit would trip the 125VDC breaker
supplying power to the valves.
This breaker also
provides power for the limit switches which provide
position indication.
Therefore position indication
would be lost the same time the valves
failed-closed, eliminating the possibility for
conflicting information being presented to the
operator regarding actual position of the valves.
In summary, the affected valves do not perform functions
necessary for the prevention or mitigation of design
basis accidents.
Thus, there is no safety significance
to the stated deficiency.
V.
STATUS
Al88/2
Full compliance with respect to the PASS valves and
Reactor Head Vent valves was completed on May 6,
198 6.
Regarding corrective actions to address the
root cause, the DCP process was supplemented by
procedure GM8-EMP-009, issued December, 1985.
The
post-installation walkdown procedure had already
been issued and implemented.
SOLENOID OPERATED VALVES -
CONAX SEALS
APPENDIX A
BASIS FOR QUALIFIABILITY
ASCO solenoid valves a~e mounted inside of Panel 801-lA,
which will shield the SOV's from direct impingement of water
spray and steam.
Because.of the installed configuration, the only way moisture
can enter into Panel 801-lA is through the pressure
equalization vent in the lower left corner of the enclostire
door.
Qualification testing of the ASCO SOV's was performed at
extremely high temperatures and pressures-.
The 30 day LOCA
test performed more than encompasses the Salem LOCA profile,
where the severe accident pressure condition decays (to 5
psig) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
One anomaly occurred during the LOCA test when the SOV coil
shorted due to moisture intrusion.
This occurred on the 12th
day of the LOCA exposure, when the test pressure was at 68
psig.
(Note:
pressure is the parameter that will force
moisture into the SOV housing, which could then possibly
cause the coil to short.)
After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the Salem accident
pressure has decayed to 5 psig, and remains there throughout
the completion of the accident scenario.
The tested SOV coil
shorted only_ after exposure to two transients, 10 days of
exposure to extreme pressure conditions (i.e., above 30
psig)*, and one full day of exposure at 68 psig.
Therefore,
the SOV's are shown to be qualifiable for a minimum of 12
days.
It is postulated that the PASS SOV's would operate well
beyond the 12th day failure point experienced in the ASCO
test report.
At Salem, the accident pressure rapidly decays
to a low value, rather than fluctuating between extreme
values.
This "equilibrium" effect provides a less severe
environment, and therefore, will have less ability to drive
moisture into the SOV hou~ing.
As a result of the anomaly, ASCO recommended that the SOV
installation utilize a sealed vented conduit/junction box
GOnfiguration to prevent moisture intrusion.
Essentially,
the as-installed configuration meets this criteria.
ASCO did
not specifically recommend the use of seal connectors.
Al88/2
..
Appendix A (Cont.)
2
ASCO's recommendation of using a sealed vented conduit/
junction box configuration was not subsequently tested.
Therefore, no firm evidence exists that utilization of this
configuration will prevent coil-related failure of the SOV
from moisture intrusion at extreme pressure conditions.
To date, there is no known methodology to extrapolate
p1:essure/humidity test results pcist the actuc.l t.:steC: time
period.
To prove that ASCO's "sealed" system is qualified
for 100 days post-accident, it would have been necessary to
test the unit for 100 days.
Since this testing was not
performed, there is no evidence that the sovrs will survive
for 100 days, anymore than there is evidence that they will
fail after 12 days.
Al88/l
..
- -:. *** **** *'Y<>-\\; *** : ...... ,_,-;..-...... ~---**~
- .
- '~*,
--*~-: ....
o,.:. .***. *_*_ ** '.-~---~*:_.;.*.:...:-~->-*";....__.,~:,:*: .* :,.* ........ *.--**** ***--... --~__,__;_._"_,.__,
PUBLIC SERVICE ELECTRIC AND GAS
TECHNICAL ASSESSMENT
ISS.UE 3
ELECTRIC JUNCTION BOX SEALS
I.
STATEMENT OF CONDITION
As described in LER 86-007, PSE&G identified seven (7)
junction boxes in Unit 1 and nine (9) in Unit 2 that
were not sealed out of a total of 138 EQ junction boxes,
in accordance with the instructions provided in original
installation and design change packages (DCP's).
Systems and *components affected by this deficiency
include the Main Steam System; Main Steam Isolation
Valve (MSIV) indication limit switches for Units 1 and
2; Containment Pressure Vacuum Relief (CPVR) Isolation
System solenoid valves for Units 1 and 2; and Liquid
Radwaste Management (LRM) System Containment isolation
valve limit switches for Unit 2.
I I.
ROOT CAUSE
The root cause of the above deficiencies is (1)
confusion generic installation requirements which led to
misiriterpretation, and (2) an oversight by the
responsible EQ sponsor in not including all EQ
identified junction boxes in the updated (most current
issue in 1985) EQML.
The four junction boxes which were
not included on the EQML were on the original master
1 is t~.
III. CORRECTIVE ACTIONS TAKEN
The junction boxes were either proper iy sealed or
evaluated and found acceptable prior to restart
following the Salem Unit 1 March, 1986 refueling outage
and a volunta~y shutdown of Salem Unit 2 in May, 1986.
PSE&G had taken corrective actions prior to the
discovery of the deficiencies that would likely have
precluded its occurrence in that procedures had 'been
modified io reqtiire that a field walkdown by the project
team members be performed.prior to DCP closeout
(Engineering Procedure GM8-EMP-009, Revision 0,
December, 1985).
The procedure also ensures that all DCPs receive a
review by the EQ section to ensure EQ compliance.
Therefore, any EQ-related drawings which are contained
Al88/3
...... -. .:. *~-* : .. ,* ..
- !
- ** *
'*.
.
-
- *
- -~* * , ....
Issue 3 (Cont.)
2
within the DCP are required to be reviewed by the
responsible EQ engineer to ensure that all EQ junction
boxes are designated as such to avoid misinter-
pretation.
A field directive was also issued (FD No.
s-C-A910-NFD-0.405) on August 1, 1986 concerning EQ
requiremerits for junction box iristallation and
maintenance.
IV.
SAFETY SIGNIFICANCE
1.
The deficiencies were not safety significant in that
affected components (a).were qualifiable *in their
individual configuration, (b) provided valve
position indication, for which alternate position
verification was available, (c) would fail such that
associated valves would go to a fail-safe position,
and (d) components would operate prior to failure of
the junction box/terminal block.
Al88/3
Specifically, for each item listed above:
(a) QualifiabLlity of the existing configuration is
addressed in Appendix A.
(b) Limit switches for 12MS167 and 14MS167 for Unit
1 and, 22MS167 and
24MS167 for Unit 2, in the
Main Steam System MSIVs only provide indication
for verification of containment isolation.
Alternate indication, (which is required by EOPs
to be checked when MSIV position indication is
lost) is available from steam flow
instrumentation.
The CPVR Isolation Valves (lVCS and 2VC5) are in
series with a second normally closed valve (1VC6
- and 2VC6) which also receives a containment
isolation Phase A signal to provide redundant
isolat..i.on.
The ~RM system containment isolation valve
limit switches, 2WL13, 2WL17, 2WL97, 2WL99 and
2WL108 only provide position indication and a
seal-in function from the open limit switch to
maintain the valves open.
These valves are
closed upon initiation of the accident and are
verified early in the EOP.
........ :*-* .... ~*:-: .... *. -
..
-*-
- .*
- *** * *
- ,,._.._ .. * * ** -*, *
- .:. : .*,. ,:. ,;~ ....... :. ' ****' .C.* .' *
- -~** **. *,
- .:.** .;_ ** *._ *. ;
-
Issue 3 (Cont. )
3
(c) The*CPVR Isolation Valves (lVCS and 2VC5), are
normally closed, fail closed valves and would
not be opened during an accident.
In addition,
should associated solenoid valves SV928 and
SV1025 fail, lVCS and 2VC5 will fail-closed.
The LRM system containment isolation valves are
all fail closed valves.
Failure of the
associated limit switch will only result in a
spurious indication signal on the control room
panel.
All valves will be closed at the
~
initiation of the accident and are verified
early in the EOP, before the loss of position
indication would occur.
V.
STATUS
Al88/3
Full compliance regarding junction box seal
deficiencies was achieved on April 30, 1986 (Unit 1)
and May 3, 1986 (Unit 2).
Corrective actions regarding the DCP process have
been previously noted as being completed by
December, 198 5.
.
......, .. ~~ :. :-.. : .. -*. : ..*
UNSEALED JUNCTION BOXES
APPENDIX A
BASES FOR QUALIFIABILITY
The basis for sealing the conduit entrances to junction boxes
is to prevent the possibility of a
~tream of water from
flowing through tne rigid conduit into the top of the box
resulting in the terminal block being flooded and shorting
out.
Plant walkdown inspections demonstrate that the installed
configuration eliminates the possibility of the junction box
being flooded.
This is accomplished through (1) sealed rigid
conduit, (2) horizontal or bottom conduit entrances where
sealing is not required, (3) physical barries protecting open
conduit and (4) the actual location of the open conduit not
being closed enough to a HELB/MELC area where the steam/spray
mixture could enter the conduit opening.
The junction boxes installed in Salem Units 1 and 2 are
designed and tested in, accordance with PSE&G specifications.
Junction box cover plates are installed on all junction boxes
to protect the. terminal blocks from direct spray
impingement.
However, there are no cover gaskets provided.
Therefore, if high pressure spray or moisture enters into the
box through the gaps created by the'metal-to-metal interface
between the junction box cover plate and junction box edges,
or through condensation it will drip out through these same
gaps.
The test report used to establish qualifiability tested a
junction box/terminal block configuration similar to the
configuration installed in Salem.
Additionally, the plant
installed configuration is considered to be superior in
design due to the utilization of Raychem splices or Conax
connectors installed at the specific component which provides
a water-tight seal.
The junction boxes are located in the Mechanical Penetration
Area and the Outboard Penetration Area where they could be
exposed to a HELB or MELC.
The pressure and spray conditions
during the HELB tests were more severe in magnitude and
duration than the expected plant conditions.
Temperature, in
this case, is not an environmental parameter of any concern
with respect.to leakage current associated with the terminal
block circuit.
Al88/3
.** .~ .. :; , ..
"
-****'* *. , *. *********'*'"***-** **
.r~* *--*-* ** _...,._.r ... *:.*- -****-**** * ., * .._.~ ... ***-----**--*~--* *****--**.--*****,.**-* * **-*****- -**-******
Appendix A (Cont.)
2
Leakage current was monitored during the HELB tests as a
basis for acceptance criteria.
The worst case leakage
current recorded is not sufficient enough to energize any of
the affected components.
A more detailed engineering analysis has been performed by
engineering and is on file at PSE&G.
Al88/3
... J' . *.-* __ -. ...:. *. ~,:_,_ - - .:.:_., _ _.. -~ . , - . ~
. -...
. .. *, ... -.
. - --- *- . . . . . *. ~.-: :. . .".*.-= -*-- ... , __ :~ .... :. :... ,* *. ::._. .:.~ __ : -.-:_.;.,...:..:...: .. _._,_ . __ ... ; ___ _, -~*"-'"'-**~*---* .* ~--- ........ -...... __ ..
- -:.~:..',_, ... ~- , .*.. -... -. - .. --* . -.. -
PUBLIC SERVICE ELECTRIC AND GAS
TECHNICAL ASSESSMENT
ISSUE 4
FAILURE TO REMOVE LIMITORQUE MOTOR BRAKES
I.
STATEMENT OF CONDITION
As described in LER 86-007, PSE&G identified four (4)
Limitorque motor-operated valves (MOVs)
outsid~ of Unit
1 containment in which brake assemblies had been
electrically disconnected but had not been physically
removed from the valve operators.
A subsequent
inspection of Unit 2 discov~red three (3) Limitorque
actuators outside containment also contained brake
assemblies that were electronically disconnected but not
physically removed.
The affected Limitorque operators
were found in the component cooling water outlet of the
residual heat removal heat exchanger, the Unit 1 safety
injection pump suction, and the Unit 2 residual heat
removal pump.
I I.
ROOT CAUSE
The ~oot cause of the motor brakes, not being removed
was an apparent misunderstanding of what.constituted
complete removal of the motor brake assembly.
Also, the
EQ sponsor engineer had been given verbal information
from Limitorque which indicated that physical removal of
the brakes was not necessary.
A Limitorque motor brake removal drawing was
unavailable, and instructions by the EQ sponsor engineer
in response to a Field Questionnaire ~nly stated the
brake is to be removed in a manner that the minimum
. number of parts are removed and the associated wiring is
disconnected so the brake is render~d inoperable.
The
Field Questionnaire answer did not correctly clarify the
issue.
III. CORRECTIVE ACTIONS
PSE&G took prompt corrective actions to address fully
the deficiency as well as the root cause.
PSE&G promptly conducted a total walkdown of all
safety-related electrical equipment .and confirmed that
there were no additional examples of the deficiency.
Al88/4
.. ~_. ...... *.; ..
Issue 4 (Cont.)
2
The brakes were removed from Salem Unit 1 prior to
restart from the March, 1986 refueling outage, and from
Unit 2 during the voluntary shutdown during May, 1986.
Corrective actions are ongoing.
Salem Station personnel
are instructed during EQ training that procedural
adherence is a must.
PSE&G further established a new procedure
(S-C-A910-MFD-0342, dated December 2, 1985) to provide
added assurance that future DCPs include sufficient
instructions with respect to motor brakes and other EQ
requirements.
In addition, PSE&G had previously
implemented a new engineering procedure, GM8-EMP-009
dated December, 1985, to close-out DCPs with a field
walkdown performed by the project team members.
These
actions provide assurance that PSE&G was in full
compliance prior to restart and that this type of
condition should not recur.
IV.
SAFETY SIGNIFICANCE
i.
There was no safety significance regarding the
presence of the motor brakes in that:
A188/4
(a) The motor operators had been qualified by
Limitorque test report F-C2485-l, which was the
original basis for Limitorque operator
qualification outside containment (See Appendix
A for qualifiability bases).
(b) The maximum exposure of the brake assemb1y and
brake coil to the outside containment radiation
environment is 106R, which would not degrade the
brake or coil component material to a degree
that would cause binding of the motor.
This is
supported by WCAP-7410-L.
{c) Post maintenance in-service valve stroke test
times confirmed that the presence of
de-energized brakes did not prevent the
actuators from performing their intended safety
function.
This is supported by 4.0.5-V tests.
. * *
' :., ** * .* "*.' : '
_.. * .._ *.*. *. ::l',.'. : *_..._ ...... _.,_,; .,;,.._ *** ** "... .* .--1 '~*** I .:.":,. *. J_,; ** * ** *, 'i...< *- .:_
'~ ..._ .* _.._-.._ ,.:; * .. , *I~---**'* .I._,_.._, ~ - ~ ** * *
~'. ,_ * '- ** *~ .". *'
Issue 4 (Cont.)
3
(d) All affected valves would be positioned in their
required recirculation lineup before they would
be exposed to any significant radiation doses.
VI.
STATUS
The Limitorque actuator motor brakes were removed and
the work W3S completed by April 30, 1986 for Unit 1, and
M~y 3, 1986 for Unit 2.
Al88/4
..
FAILURE TO REMOVE
LIMITORQUE MOTOR BRAKES
APPENDIX A
BASES FOR QUALIFIABILITY
The use of motor brakes is a qualifiable configuration.
The
original basis for ~ualificrition cf Limitorque operators with
class B motors outside contaJnment at Salem Station (File
EQ-29), used Limitorque test report F-C2485-0l to qualify the
operator with brakes installed.
This report is titled,
- "Tests of a Limi torque Valve Operator and Motor-Brake
Assembly, Both With Class B Insulation
Under Simulated
Reactor Containment Post-Accident Steam and Chemical
Environments."
Other reports were used to support specific
para~eters, of which 600198, F-C2232-01 and WCAP-7410-L were
referenced~ These reports are currently maintained in the
Salem EQ backup files.
In conjunction with upgrading Limitorque actuators outside
and inside of containment at Salem Station to DCP's 1788 arid
1789 (in 1984 and 1985), the EQ files were also upgraded to
more recent qualification test reports (B0058 and 600461).
These new reports did not support motor brake assembly
qualification.
However, the original class B motors
qualified to report F-C2485-01 outside containment were not
replaced.
Since the brake~ were originally qualified by testing, the
disconnection of the brakes at Salem could be deemed a
conservative step, which need not have been made if the
original reports had been used, and a ~aterial composition
~nalysis had been performed.
The existence of the brake~,
whether connected or disconnected, did not substantially
differ from the mechanical configuration that was qualified
in the original Limitorque test reports.
The primary
difference .is that de-energized brakes may create surface
drag between the discs, whereas energized brakes maintain a
preset gap between the stationary and rotating frictiori
discs.
Since the disconnected brakes are no longer
functional, qualification is no longer appropriate, but motor
operability is necessary.
Qualification tests, along with
radiation analysis of brake disc materials, show that class B
or RH brake materials do not change after being exposed-up to
2 x 108 rads gamma radiation.
Also, since the valves were
stroked within their specified time period following brake
disablement in a normal in-service stroke test and
Al88/4
.::. .... - : ... ; ...... :. ..: ~-
- _,, -*~",. -. . .. ~** -.-* *- *. - * - -: .. -:... '* .. ** --.:* **. ~ .,.,; .: *'.~.*- *.* , .* :. :, *. ,_,::., .. *:_, *,.:-... ~._ .... : ... :.:.-..;.;;.:..o:..*:~:~ ....... .:..:..""'*:-..:. .... .: .* - *-* _. ** - -
Appendix A (Cont.)
2
periodically thereafter, it is a reasonable conclusion that
they would stroke under the accident condition of 1 x 106
rads of gamma radiation.
Post-maintenance inservice stroke-time tests SP(0)4.0.5-V-CC
3nd SP(O) 4.0.5-V-SJ, confirmed th~t t~e pre~ence of
de-energized motor brakes did not adversely affect valve or
a.:tuator operability.
Since the presence of dG**snergized
motor brakes did not adversely affect MOV operability, as
confirmed by the post-maintenance stroke-time tests, there
was no safety significance regarding the presence of the
de-energized brakes.
LER 86-007 discusses the possi~ility that the brakes could
bind the valve as a result of radiation exposure.
Subsequent
evaluation of this claim concludes that radiation induc~d
binding of the valve stem, as a result of brake exposure to 1
x 106. rads gamma radiatl.on; is highly unlikely.
The capability of the motor brake assembly and brake coil to
withstand radiation was supported by WCAP-7410-L, "Topical
Report Environmental Testing of Engineered Safety Features
.Related Equipment," December 1970.
The purpose of this
program was to determine the effects of steam, pressure,
temperature and radiation on valve operators with both class
H and class B insulation on .the motor and motor-brake
assembly.
Page 5-4 documents that class B insulation was
irradiated to.a level of 2 x 108 rads with no apparent
degradation of the insulation.
Although failure of. the coil
portion of the assembly did occur during the testing, this
.was attributed to steam and chemistry solution entering into
the assembly through the cutouts for the leads, causing coil
failure.
Since the motor brakes in our analyses were
electrically disconnected from the coil, and the brake disc
assemblies are only subjected to a radiation harsh
environment of 1 x 106 rads, this failure mechanis~ will n~t
be present.
It is therefore concluded that there was no safety
significance regarding the presence of the electrically
disconnected motor brake assemblies.
PSE&G had test reports
to support the qualification of the brakes for their location
specific environment.
Thus, Salem Station Limitorque
actuators outside containment are qualifiable in their
installed configuration by the original basis supplied in
Report F-C2485-01.
A more detailed analysis has been
performed by Engineering and is on file at PSE&G.
Al88/4
PUBLIC SERVICE ELECTRIC AND GAS
TECHNICAL ASSESSMENT
ISSUE 5
AUXILIARY FEE.rMATER FLOW TRANSMITTER CONNECTORS
. I.
STATEMENT OF CONDITION
As described in LER 86-007, PSE&G identified during a
self-initiated walkdown four (4) Auxiliary Feedwater
Flow Transmitters in both Units 1 and 2 that were
terminated in junction boxes with terminal blocks.
PSE&G determined that these connections should have been
made with qualified splices.
I I.
ROOT CAUSE
During an effort by PSE&G to upgrade saf~ty-related
transmitters and associated equipment, the AFW flow
transmitter square root extractors were relocated.
The
AFW transmitters were also replaced by design change
packages.
These design change packages were later.
modified to include terminal blocks inside a junction*
box to facilitate the relocation of the square root
extractors.
In review of terminal block use for
response to_ IE Information Notice 84-47, these
connections were not discovered.
The revised
configuration was identical for each of the circuits and
represents an isolated oversight in the review process.
III. CORRECTIVE ACTIONS TAKEN
PSE&G promptly corrected this condition, prior to
restart from the Unit 1 March, 1986 refueling outage
and ~ntered an unscheduled outage for Unit 2 in May 1986
to assure a complete review and to implement corrective
actions.
PSE&G had taken corrective actions prior to the
. discovery of the deficiencies that would likely have
precluded its occurrence in that procedures had been
modified to require that a field walkdown by the project
. team members be perf_ormed prior to DCP closeout
(Engineering Procedure GM8-EMP-009, Revision O,
December, *1985).
The procedure also ensures that all DCPs receive a
review by the EQ section to ensure EQ compliance.
Al88/5
i":.:: ... :-..
-.;'..:*~**~J-*_, ... --~~: *. :. - *.:
'*
- ~ .. : .
..
Is s u e 5 ( Cont * )
2
Therefore, any EQ-related drawings which are contained
within the DCP are required to be reviewed by the EQ
section.
IV.
SAFETY SIGNIFICANCE
The condition was not safety significant.
Configuration is qualif iable as discussed in
Appendix A.
These transmitters are not essential to the
mitigation of an accident.
The EOP in place at the time (EOP-TRIP-1) directed
the operator to verify total AFW flow to be greater
than 44,000 lbs/hr as the second step of the
immediate actions, immediately after the
verification of turbine trip.
This flow
verification will occur in less than two minutes
following the initiation of the accident.
Because
the connections were inside a closed EQ junction
box, the adverse conditions which could have
affected the AFW flow indications in the penetration
area (2/4 loops) would not have developed before the
flow verification was completed.
Subsequent usage
of the AFW flow indication is as a reference
indication for maintaining the established flow
until steam generator level is within the narrow
range.
The AFW flowrate is then governed by steam
generator level, and not the indicated flow.
Since
the AFW flow indication has no control function, the
flow would remain at an adequate level regardless of
whether the flow indication failed and steam
generator level would still be attained.
V.
STATUS
Al88/5
Full compliance with respect to these connections
was achieved by May 5 (Unit 1) and May 6 {Unit 2),
1986.
AUXILIARY FEEDWATER FLOW TRANSMITTER CONNECTORS
APPENDIX A
BASES FOR QUALIF!ABILITY
The following synopsis highlights the evaluation of .the
terminal blocks installed in AFW flow transmitter circuits:
The primary concern for inadequacy of terminal blocks in
instrument circuits, as delineated in NUREG/CR-3691, is the
formation of surface moisture film which can induce
unacceptable leakage currents during steam line break
conditions.
Although much testing has indicated that
terminal blocks are not normally acceptable for use in
transmitter cir~uits, consideration must be given to the
following factors:
(1)
Applicability of test reports
(2)
A~equacy of performance mea~ures
(3)
Performance requirements *
(4)
Safety function
Because the majority 6f industry testing did not monitor low
level leakage. currents, only one test report is used in this
evaluation.
This test report contained the same manufacturer
and type terminal block, the same installation configuration,
was monitored for functionability to the same transmitter
type~ was exposed to steam line break conditions and
monitored leakage currents in the micro-amp range.
The
results of this test showed that the tested terminal block in
tested configuration showed no leakage current above 50
micro-amps and permitted the.proper functioning of the
attached Rosemount transmitter.
This test provides
documentation of acceptability of the.terminal blocks
installed inside EQ junction boxes in the AFW flow
transmitter circuits.
As -an additional measure of assurance of the acceptability of
the subject terminal block/junction box configuration,
evaluation of the actual safety function of the flow
transmitters was reviewed.
The functional use of the flow
transmitters for steam line break accident resolution is as
an indication of AFW flow for steam generator level
recovery.
This reading from the flow indicators will occur
in one to two minutes from accident initiation as it is the
second step in emergency operating procedures.
The following
Al88/5
-~--~-~~--------.. -... - ..
~;:-::-=-=-----~~-
.*~-. .
.:~ .** ~ ... ;-,.*-~-*-*- .:_ ...... ,_,. __ ,.... .. __ 1_ .. ~.*.;z;-;--_..,._._,,.-:--.._-;-___ *.~-*-
--~ ~, ....... c
Appendix A (Cont.)
2
points summarize the evaluation of acceptability in regard to
the safety function and safety impact of the flow transmitter
signals:
( 1)
Significant ~igna.l ert*or induced by steam ~nter ing the
closed junction box and moisture film forming across the
block would be unlikely to affect the indication before
the control room had verified flow.
(2)
If an error were induced at initial flow verification,
subsequent operator action would, by procedure, preclude
any safety impact due to the error.
(3)
At most only two transmitters can be affected by any one
accident which leaves two steam generators unaffected.
Only two steam generators are required for safe
mitigation of the accident.
Al88/5
- .
"
PUBLIC SERVICE ELECTRIC AND GAS
ASSESSMENT OF THE MODIFIED EQ ENFORCEMENT POLICY
(GE-NERIC LETTER 88-07) AND ITS APPLICATION TO
THE DEFICIENCIES IDENTIFIED IN LER 86-007
BACKGROUND
On April 7, 1988, NRC issued Generic Letter 88-07, the most
recent in a series of Generic Letters (including GL *85-15 and
GL 86-lS) intended to establish a separate enforcement policy
for the environmental qualification of safety-related
electrical equipment.
PSE&G recognizes NRC's desire to
.convey to the industry the need for concerted action to
comply with the requirements of 10CFR50.49.
PSE&G has
interpreted this guidance as a pronounced effort by the NRC
to ensure that a utility is not in gross violation of and/or
negligent with regard to the requirements of 10CFR50.49.
The
following assessment of the application of the Modified EQ
Enforcement Policy (Generic Letter 88-07) as it relates to
the EQ deficiencies in LER 86-007 will show that PSE&G was
not ~egligent with regard to 10CFR50.49, and that the
deficiencies represented isolated failures to properly
implement established Salem EQ program guidelines.
PSE&G recognizes that the LER 86-007 deficiencies existed
prior to the November 30, 1985 mandatory EQ deadline.
However, the following discussions of each deficienc~ provide
information to support PSE&G's contention that enforcement
action under Generic Letter 88-07 is not appropriate.
al88/asm
J~ ** :
~ * ~ '*
- ,
. -~--
- . ,~~*. c --...:.* ,_._ *** *-* -~- __ .,_ ** ,._ ** _; ** *
- - -
.. _. ,._r-.,_ --* '-.4-~'4***"">.ol'~d-- - ... -:c:::-.............. __ -~ ..* _ ......... _ .... '-.*--.!... --
---'* ..... .
ISSUE 1
LIMITORQUE T-DRAINS
PSE&G believes that the as-installed configuration (i.e. the
Limitorque operator motor bell housings without the T-drains)
does not warrant escalated enforcement action.
The motor operators were qualifiable in the as-installed
configuration.
PSE&G believes that the "qualifiability"
argument should be admitted in this case as well as other
issues noted in LER 86-007 since PSE&G was not given the
opportunity to db so during the NRC EQ inspection of Salem on
August 11-15, 1986.
The NRC inspection team stated at that
time that the deficiencies identified in LER 86-007 would be
considered under the then existing EQ Enforcement Policy (GL 86-15) but that they would not be looked at during the
inspection.
PSE&G had no need at that time to perform a
qualif iability determination because T-drains had
conservatively been installed on all the inside containment
Limitorque operators prior to startup fro~ the Salem 1
refueling outage which commenced in March, 1986, and the
subsequent voluntary shutdown of Salem 2 in May, 1986.
Had
this concern been formally raised during the inspection, a
qualif iability .evaluation could have been generated at that
time by PSE&G.
A summary of the qualifiability determination
is presented in Appendix A to the technical discussion of the
Limitorque T-drain issue.
This deficiency should not be classified as a "clearly should
have known" condition under the Modified EQ Enforcement
Policy because:
Prior to November 30, 1985, PSE&G's EQ personnel were
aware that T-drains were required as evidenced by sev.eral
PSE&G memoranda referencing the installation requirement.
DCPs lEC-1788 and 2EC-1789 were issued in 1984 and 1985
to upgrade existing operators.
Included in the DCPs for
installation purposes were excerpts from Section 6 of
Limitorque Test Report B0058 which noted that
in-containment actuators use T-drains to accommodate the
extreme temperatures and pressures of Design Basis Event
environments.
The vendor instructions attached to the new actuator
motors included direction regarding installation of the
T-drains.
,
al88/asm
...
- "'
. _,. '_':. *- .. --**~--~*-**" - . -. . .. -;" . *~ .. :.* *,. "*
Issue 1 (Cont.)
2
Reasonable post-installation verification measures had
been taken in the form of QA field verification walkdowns
on a ~ampling basis.
Although more detail concerning T-drain installation
could have been included in the DCP, PSE&G believes this
deficiency should be categorized as an isolated oversight
and not a "clearly should have known" case.
Based on the qualifibility of the configuration and the
"clearly should have known" evaluation, this deficiency
should be evaluated against the General Enforcement Policy
and classified as a Severity Level V.
The Modified Policy is
not applicable.
al88/asm
- '
"
ISSUE 2
CONAX.CONNECTORS FOR PASS SOLENOID OPERATED VALVES
PSE&G believes that this self-identified deficiency does not
_ warrant escalated enforcement action and should be classified
as no more than a Severity Level V violation.
PSE&G has performed an evaluation which demonstrates that
these solenoid operated valves were qualif iable in their
as-installed configuration.
A summary of the qualifiability
evaluation is presented in Appendix A to the technical
discussion of this issue.
PSE&G does not believe that enforcement action should be
taken under the Modified EQ Enforcement Policy for the
followin~ reasons:
1.
The PSE&G EQ program clearly directed that Conax
connectors be installed on the solenoid valves in both
Salem Units prior to November 30, 1985.
The PASS DCPs ( 1EC-0540A and 2EC-0541A) for the ASCO
solenoid val~es for both units contained the same
reqtiiremeni.
(The connectors were only missing from
the Unit 1 PASS System, Panel 801....:lA).
A large amount of evidence exists which demonstrates
that Conax connectors have been installed in EQ
applications as required.
Nearly 750 Conax connectors
had been properly installed within both Salem Units in
accordance with similar directions.
The deficiencies were at most isolated* occurrences of
non-adherence to applicable program requirements~
2.
This condition ~hould not be classified as a "clearly
should have known" condition under the Modified EQ
PSE&G identified .the need to install qualified
connectors.
The DCPs (1EC-0540A and 2EC-0541A) for the PASS valves
specifically called for Conax connectors for both
Units 1 and 2.
The total number of appropriately installed Conax
connectors in EQ applications is indicative of
effective equipment installation and verification
programs.
Based on qualifibility and the "clearly should have known"
evaluation, the General Enforcement Policy should apply.
. . - .... , , ........... .
.
~ . ,,.
. -* : ... _
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ISSUE 3
ELECTRIC JUNCTION BOX SEALS
PSE&G believes that this self-identified deficiency has no
safety significance, does not warrant escalated enforcement
action and should not be classified as more than a Severity
Level V violation.
The junction boxes have been determined by PSE&G to be
qualif iable in their as-installed configuration.
A summary
of the qualifiability evaluation is presenteq in Appendix A
to the technical discussion of this issue.
PSE&G does not believe that enforcement action should be
taken under the Modified EQ Enforcement Policy for the
following reasons:
1.
Design change documentation incorporated EQ requirements
by providing a drawing with instructions.
These Generic
installation instructions for the proper sealing of EQ
junction boxes were confusing and led to misinter-
pretation in some cases.
The EQ engineer failed to properly transfer a limited
number of junction boxes from the original EQ list to an
updated EQ Master List.
2.
PSE&G should not have clearly known the above
deficiencies existed because:
The engineering oversight and the confusion over the
installation instructions were isolated events not
indicative of a breakdown in the EQ requirements for
junction boxes.
Verification was based on a sample and could not
reasonably have been expected to identify every
possible error.
Based on qualifibility and the "clearly should have known"
evaluation, the General Enforcement Policy should apply.
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ISSUE 4
LIMITORQUE MOTOR BRAKES
PSE&G believes that escalated enforcement action is not
warranted for this self-identified condition and should be
classified no more than a Severity Level V violation.
~he Limitorque motor operetors with tha motor bra~e~
installed are qualifiable.
A summary of the qualifiability
eval~ation is prdsented in Appendix A to the technical
discussion of this issue.
Enforcement action under the Modified EQ Enforcement Policy
is not warranted because the deficiency does not represent a
"clearly should have known" condition.
Only a limited number
of the Limitorque motor operators were installed without the
motor brakes physically removed.
In the vast majority of
cases, the DCP instructions were understood.
In some cases,
however, the DCP instructions were not fully understood, and
a field questionnaire was written to seek clarification as to
whether the brakes were to be physically removed or
disconnected.
For purposes of responding to the field
questionnaire, the EQ sponsor engineer states that he was
given information verbally by Limitorque that physical.
-removal of the motor brakes was not necessary.
This
vendor-supplied information provided a basis to cionclude that
the configuration was adequate.
_,
Based on qualifiability and the "clearly should have known"
evaluation, the General Enforcement Policy should apply.
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., . * .
ISSUE 5
AUXILIARY FEE~ATER FLOW TRANSMITTER TERMINATIONS
PSE&G believes that the self-identified deficiency does not
warrant escalated enforcement and should be classified as no
more than a Severity Level V violation.
A qualif iable configuration existed in the terminal block~
located inside a qualified junction box.
A summary of the
qualif iability evaluation is provided in Appendix A *to the
technical discussion of this issue.
PSE&G does not believe that enforcement action should be
taken under Generic Letter 88-07.
The deficiency should not
be cl~s~ified as a "clearly should have known" condition
because:
In responding to Information Notice 84-47, PSE&G
evaluated these configurations for qualification and
determined that no additional action was required
because, among other components, transmitters were to
be installed with qualified Raychem splices.
In fact,
at Salem Station, over 200 transmitters had been
replaced in 1982 and 1983 and Raychem splices were
used in accordance with Engineering directions for all
transmitter terminations.
All terminal blocks were
replaced with Raychem splices for transmitter
terminations in this effort.
Although the IN 84-47
was fully addressed the verification effort failed to
identify the auxiliary feedwater terminations.
This
was an isolated over~ight and not a
"cl~arly should
have known" case.
Based on qualifibility and the "clearly should have known"
evaluation; the General Enforcement Policy should apply.
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PSE&G ASSESSMENT OF THE GENERIC LETTER 88~07
MITIGATION/ESCAIATION FACTORS
While PSE&G does not believe that escalated enforcement
action is warranted for any of the EQ deficiencies identi~ied
in LER 86-007, the civil penalty mitigation/escalation
factors noted in Generic Letter 88-07 have been evaluated as
requested in the NRC Region I letter of August 19, 1988,
which scheduled this enforcement conference.
If a civil
penalty is proposed for any or all of the self-identified
defici~ncies, full mitigation is warranted for the following
reasons:
- PSE&G identified the conditions during self-initiated
walkdowns in March, 1986 (Unit 1 and May 1986 (Unit 2).
The conditions were timely reported to the staff in LER 86-007.
In each case, PSE&G promptly corrected the Salem
conditions by physical modification prior to restart.
PSE&G voluntaiily e~tended the Salem Unit 1 1985 outage
and entered an unscheduled shutdown of Unit 2 to
implement corrective actions in May, 1986.
PSE&G took prompt corrective measures to address the root
causes. through procedural and administrative changes.
These actions assured PSE&G was in full compliance prior
to restart and provided assurance that these conditions
should not occur~
The deficiencies re~resented isolated failures to
appropriately implement established Salem EQW program
guidelines.
A limited number of system and components were affected.
PSE&G employed its best efforts to compete implementation
of an EQ program prior to the November 30, 1985 deadline.
The five criteria, at the bottom of page 4, of the Generic
Letter denotes those factors which must be met in order for
full mitigation of any proposed civil penalty to be
considered.
PSE&G believes that consideration of its action
to discover, report and resolve the deficiencies of LER 86-007 along with the significance and overall etfect of
these deficiencies leads to the conclusion that full
mitigation is warranted.
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PSE&G ASSESSMENT OF THE POTENTIAL FOR ENFORCEMENT
ACTION UNDER THE GENERAL ENFORCEMENT POLICY
- ( 1 OCFR PART 2, . APPENDIX C)
NRC Generic Letter 88-07 presents two (2) conditions where
enforcement action related to EQ deficiencies which occurred
prior to the November 30, 1985 deadline is to be assessed
under the General Enforcement Policy (lOCFR Part 2, Appendix
C).
These are (1) when the equipment in questions
determined to be aqualifiable," as-installed, rendering the
deficiency not sufficiently significant for assessment of
civil penalties under the Modified EQ Enforcement Policy and
- (2) when noted EQ deficiencies are not singularly significant
but, in the aggregate, are indicative of a programmatic
problem.
In the case of the EQ deficiencies noted in LER 86-007 the
following statements are relevant:
1.
The EQ deficiencies identified in LER 86-007 represent
configurations which were qualifiable in the as-installed
condition.
2.
The EQ deficiencies were identified by PSE&G during the
Salem Unit 1 1986 refueling outage and the voluntary
shutdown of Salem Unit 2 in May, 1986.
1.
The deficiencies were reported to the NRC in a timely
fashion -via the LER.
4.
After review of lOCFR Part 2, Appendix C,Section IX,
Supplement I, PSE&G believes that none of the
deficiencies individually should be categorized as more
than a Severity Level V violation.
5.
Appropriate corrective actions were taken promptly to
resolve the deficiencies and adminstrative changes were
made to preclude recurrence.
6.
There had been no previous inspection findings similar to
those deficiencies self-identified by PSE&G in LER 86-007.
Therefore, the deficiencies could not have been
prevented by corrective actions resulting from a previous
enforcement action~
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Assessment (Cont.)
2
7~
The EQ deficiencies noted in LER 86-007 are not safety
significant as noted in previous discussions.
For *these reasons, PSE&G believes that NRC should consider
exercising discretion under lOCFR Part 2, Appendix C, Section
V.G. and not issue a violation for any deficiency assessed
under the General Enforcement Policy.
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SALEM GENERATING STATION UNIT 1&2
PROGRAM STATUS
The following identifies actiotis taken by PSE&G after the
November 30, 1985 deadline to maintain and control the Salem EQ
program in accordance with the requirements of 10CFR50.49.
On March 22, 1986 PSE&G initiated an EQ walkdown for Maintenance
baseline during the Salem Unit 1 ref.ueling outage.
Planning for
this walkdown was started by the EQ task force during the first
quarter of 1985.
The objective of the walkdown was two fold:
1)
Verify the serial number of each component to establish the
exact installation date for start of qualified life and
follow-up maintenance considerations.
2)
Determine specif~c equipment location information (elevation
and column line identification) for use by the Station
Maintenance personnel.
At the same time an as-installed photograph was taken and several
other checks were made for program control.
These included
mounting orientation, installation of moisture seals (where
applicable) and splice or terminal block verifications.
Ag a result of the findings of the Salem Unit 1 walkdown, Salem
Unit 2 was shut down on May 1, 1986 so that a similar walkdown
could be performed.
The deficiencies identified by PSE&G during
these walkdowns were documented and submitted to the NRC in LER
- 86-007, dated May 8, 1986.
These are the deficiencies which
have been identified as the primary subject of this enforcement
conference.
These items are discussed in much greater detail in
the issues package enclosed with this handout.
In response to NRC Information Notice 86-53, "Improper
Installation of Heat Sh~inkable Turbine," PSE&G evaluated the
installation of Raychem splices i~ Salem Units 1 and 2 and found
that the splices in Salem Unit 1 had not been installed in
accordance with Raychem instructions.
PSE&G performed an
engineering analysis and determined that the "as-found"
installation was acceptable and posed no operability concerns.
Qualification data was obtained from Wyle Laboratories to support
this conclusion.
This investigation was documented in LER
- 86-015, dated August 7, 1986.
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Program Status (Cont.)
2
On August 6, 1986, PSE&G shutdown both Salem Units to replace
questionable wiring on Limitorque motor operators.
Although
initial review in response to NRC Information Notice 86-03 of
vendor documentation and purchase order information related to
subsequent field installed wiring in Limitorque motor operators
did not indicate a problem with the qualification of the wiring,
inspections of selected motor operators revealed questionable
internal jumper wiring.
Both units were shutdown so that a 100%
walkdown could be performed and documentation of the field
installed wiring in each Limitorque motor operator could be
established.
The questionable wires were replaced with qualified
Rockbestos Firewall III SIS wire.
The results of these
inspections were documented in LER #86...,018, dated September 5,
1986.
On August 11-15, 1986, the NRC conducted an inspection 6f the
Salem EQ program.
PSE&G has adequately responded to all the
issues raised by the NRC Inspection Team.
It is PSE&G's
understanding that the issues raised during the above referenced
inspection are not subjected to escalated enforcement action
under Generic Letter 88-07.
I
During the August, 1986 inspection, the NRC recommended to PSE&G
that certain file improvements should be made to generally
improve and clarify the contents of the material and to correct
the minor documentation inconsistencies that were identified
during the review.
In October, 1987, the Engineering and Plant Betterment (E&PB)
department underwent a major reorganization.
As a result the
Program Analysis Group (PAG), which is part of the Nuclear
Engineering Sciences Section, was formed.
Experienced EQ
engineers from SAG were transferred to PAG as part of the
reorganization in order to ensure continuity of the program.
In
.recognition of the importance of this program additional staff
was also allocated to the maintenance of the program at this
time.
PAG assumed the responsibility for the Equipment Qualification
Programs for both Salem and Hope Creek Generating Stations.
A
centralized group has the advantage of consistency in program
implementation and development and establishing commonality
between Salem and Hope Creek with respect to the Environmental
Qualification of equipment.
The current major objectives of PAG in support of the Artificial
Island Environmental Qualification Programs are:
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Program Status (Cont.)
3
1.
Restructure of Salem EQ files.
2.
Conversion of Hope Creek EQ files from a Purchase Order basis
to a Equipment type basis.
3.
Development of Programmatic Standards.
4.
Represent PSE&G in NUGEQ meetings and task forces.
The following is a short description of the above major
objectives:
1.
Restructure of Salem EQ Program
An extensive effort is nearing completion to implement a
comprehensive restructure of the Salem EQ file, in accordance
with E&PG procedure NO. DE-PS.ZZ-0002(Q)-A8.
This effort
included the review of all EQ related documents to assure
completeness of the EQ files, upgrade the System Component
Evaluation Worksheet (SCEW) and Equipment Qualification
Maintenance Instructions, organize the EQ binders in
accordance with a standard index contained in the procedure,
and review and approve each binder.
The primary emphasize
for this effort is to -establish a common file structure for
both Salem and Hope Creek.
2.
Conver~ion bf Hope Creek EQ Program
As committed to the NRC subsequent to the NRC EQ inspection
at Hope Creek, the Hope Creek EQ file binders will be
converted from a Purchase Order based file system to an
Equipment Type based file system.
This effort is scheduled
for implementation during 1989.
3.
Development of Programmatic Standards
An extensive effort is underway to develop Programmatic
Standards for the Environmental Qualification Program.
The
Programmatic Standard will serve as an Engineering Ma~ual for
consolidating the criteria, methods, and control of the
Environment~l Qualification Programs at PSE&G.
The issue of the Programmatic Standard is scheduled for
December 31, 1988.
Nuclear Department indoctrination on the ProgrammQtic
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Program Status (Cont.)
4
Standard will be initiated following. formal issue in 1989.
4.
NUGEQ Participation
PSE&G is a member of the Nuclear Utility Group on Equipment
Qualification (NUGEQ) and participates in its meetings and
task forces on various issues.
Group participation provides
PSE&G with current information on EQ issues in the industry
and accessibility to a large data base of information and
documents to support our EQ program.
The information presented above is indicative of PSE&G's
commitment to continuous support of its Equipment Qualification
Program and assurance that the EQ program meets the requirement
of lOCFRS0.49.
PSE&G is confident that both the administrative and technical
aspects of the Salem EQ Program are well established and that
ongoing compliance with the requirements of lOCFRS0.49 will be
maintained.
The Salem EQ p~ogram is a dynamic one and will be enhanced, as
needed to reflect the latest information and tools available to
PSE&G.
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