ML18101A484

Responds to NRC 890421 Ltr Re Violations Noted in Insp Repts 50-272/86-23 & 50-311/86-23.Corrective Actions:Required Conax Connectors Installed Prior to Restart from Unit 1 Refueling Outage Which Commenced in Mar 1986

ML18101A484
Person / Time
Site:	Salem
Issue date:	05/22/1989
From:	Miltenberger S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89093, NUDOCS 8905310106
Download: ML18101A484 (24)

Text

Public Service Electric and Gas Company Steven E. Miltenberger Public Service t::!ectric and Gas Company P 0. Box 236. HancocKs Bridge. NJ 08038 609-339-.1., 99 MAY 2 2 1989 NLR-N89093 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC COMBINED INSPECTION REPORT NO. 50-272/86-23 AND 50-311/86-23 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas company (PSE&G) has received the subject Notice of Violation dated April 21, 1989 which included two violations related to the Salem Generating Station Environmental Qualification (EQ) program. Pursuant to 10CFR2.201, our response to these violations is provided in Attachment 1 to this letter.

Associated with one of the violations was a Proposed Imposition of Civil Penalty in the amount of $50,000 assessed pursuant to NRC Generic Letter 88-07, the "Modified Enforcement Policy Relating to 10CFR50.49." PSE&G has agreed to pay the civil penalty which will be submitted separately.

It should be noted that all of the concerns discussed in the Notice of Violation, with the exception of the Limitorque Gear case Grease Relief issue, were self-identified as discussed at an enforcement conference at NRC Region I on September 29, 1988. At the enforcement conference, in addition to discussing the root cause and corrective actions noted in our attached response to the violations, PSE&G also discussed the qualifiability and limited safety significance of the installed configurations in question prior to corrective actions being taken.

• Document Control Desk NLR-N89093 2 MAY 2 2 PSE&G responded to the Limitorque Gear case Grease Relief issue

~

immediately following the August, 1986 Salem EQ Inspection (this issue was not a subject of the September, 1988 EQ Enforcement Conference). PSE&G further clarified its position on this issue in a February 3, 1987 meeting at NRC Region I. NRC Region I acknowledged in a letter of March 11, 1987 that PSE&G's presentation with regard to this issue had "technical merit."

PSE&G's position on this issue was at that time, and remains, that a decision not to use the grease reliefs was made from all known and available, information and that the Limitorque EQ file contained sufficient information to support qualification of the Limitorque operators without the grease relief valves.

PSE&G believes that our actions taken in response to regulatory and other EQ-related issues and concerns have demonstrated a substantial commitment to improve and establish a high level of confidence in our EQ program. We also believe that our current EQ program is progressive and proactive and that ongoing compliance with 10CFR50.49 is assured.

Should you have any questions with regard to this response, please do not hesitate to contact us.

Sincerely, Attachments c Mr. J. c. Stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. W. T. Russell, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

• SALEM GENERATING STATION UNIT NOS. 1 AND 2 ATTACHMENT 1 PUBLIC SERVICE ELECTRI.C AND GAS COMPANY RESPONSE TO NOTICE OF VIOLATION Your letter of April 21, 1989 transmitted a Notice of Violation related to the Salem Generating Station Environmental Qualification Program. The violations and our related responses are presented below.

VIOLATION NO. 1 10CFR50.49(f), and (j), respectively, require that (1) each item of electric equipment important to safety shall be qualified by testing identical or similar equipment under environmental conditions identical or similar to those postulated for an accident, and the qualification based on similarity shall include a supporting analysis to show that the equipment to be qualified is acceptable; and (2) a record of the qualification shall be maintained in an auditable form to permit verification that each item of electrical equipment important to safety is qualified and that the equipment meets the specified performance requirements under postulated environmental conditions.

Contrary to the above, from November 30, 1985 until April 8, 1986, eight solenoid *operated valves in the Unit 1 Post Accident Sampling System were not qualified in that the valves did not have the required Conax connectors installed and qualification of the valves without the Conax connectors was not demonstrated.

This violation constitutes an EQ Category C violation (in accordance with the "Modified Enforcement Policy-Relating to 10CFR50.49" attached to NRC Generic Letter 88-07).

This violation was assessed a Civil Penalty of $50,000 since it existed in excess of 100 days of plant operation.

RESPONSE

1. PSE&G DOES NOT DISPUTE THE VIOLATION As described in LER 86-007, dated May 8, 1986, PSE&G identified, during a self-initiated walkdown of Salem Unit 1 in April, 1986, instances in which Conax connectors had not been installed in solenoid operated valves on the Post Accident Sampling System, contrary to PSE&G EQ program requirements. The eight (8) PASS solenoid operated valves were determined to be the only SOVs out of a total of 248 for both Salem Uriits which were installed without the required seal connectors.

NLR-N89093

• 2. THE ROOT CAUSE OF THIS VIOLATION WAS AN ISOLATED OCCURRENCE NON-ADHERENCE TO INSTALLATION INSTRUCTIONS The design change packages (DCPs) for the ASCO PASS solenoid valves (1EC-0540A and 2EC-0541A) specifically directed that Conax connectors be installed on both Salem Units. The required connectors for the PASS valves involved are located within a single panel (801-lA) in Salem Unit 1. Other ASCO solenoid valve installations in Salem Unit 1 and Salem Unit 2 properly addressed similar seal requirement instructions, included in the DCP. Accordingly, this appears to be an isolated instance of overlooking explicit directions, as these are the only eight, out of 754 Conax connectors (total for both Salem Units), that were not installed as required.

3. IMMEDIATE CORRECTIVE ACTIONS AND RESULTS ACHIEVED PSE&G promptly corrected the identified deficiencies by installing the required Conax connectors prior to restart from the Unit 1 refueling outage which commenced in March, 1986.

4. LONG TERM CORRECTIVE ACTIONS TO AVOID FURTHER VIOLATIONS PSE&G had taken corrective actions prior to the discovery of the deficiency 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 performed prior to design change package closeout (Engineering Procedure GM8-EMP-009, Revision O, December 1985). The procedure also ensures that all DCPs affecting safety-related equipment receive a review by the EQ section to ensure EQ compliance. Therefore, any EQ-related drawings or installation procedures which are contained within the DCP are required to be reviewed by EQ engineers.

Since that time, the PSE&G Engineering and Plant Betterment Department has been reorganized. A new Engineering Manual and new procedures have been issued. Nuclear Department Procedure No. NA-AP.ZZ-0008(Q) provides for the administrative control of design and configuration changes while Engineering Procedure No. DE-AP.ZZ-0007(Q) includes a specialty review checklist where specific EQ attributes must be addressed as part of the design change process.

5. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved with the installation of Conax connectors on the PASS solenoid operated valves in question on May 6, 1986 .

• NLR-N89093

6. CIVIL PENALTY PSE&G has agreed to pay the proposed civil penalty. This payment will be submitted in a separate transmittal.

VIOLATION NO. 2 10CFR50.49(f), and (j), respectively, require, that (1) each item of electric equipment important to safety shall be qualified by testing and/or analysis of identical or similar equipment under environmental conditions identical or similar to those postulated for an accident, and the qualification based on similarity shall include a supporting analysis to show that the equipment to be qualified is acceptable; and (2) a record of the qualification shall be maintained in an auditable form to permit verification that each item of electrical equipment important to safety is qualified and that the equipment meets the specified performance requirements under postulated environmental conditions.

Contrary to the above, at various amounts of time beginning November 30, 1985, components important to safety were not qualified including the following examples:

1. As of May 3, 1986, the qualification of terminal blocks used to terminate eight auxiliary feedwater transmitters was not demonstrated in that the qualified configuration of the associated junction boxes specified Raychem splices.

2. As of April 8, 1986, nineteen (eleven in Unit 1 and eight in Unit 2) Limitorque motor operated valves inside containment, affecting, among others, the safety injection system, residual heat removal system and Reactor Coolant System, did not have T-Drains installed in the operator housings to prevent moisture accumulation in a harsh environment and qualification of the valve operators without the T-Drains was not demonstrated;

3. As of April 8, 1986, sixteen junction boxes (seven in Unit 1 and 9 in Unit 2) affecting, among others, the Main Steam System and the Main Steam Isolation Valve indication limit switches for both units did not have properly sealed conduit connectors and qualification of the junction boxes without properly sealed conduit connectors was not demonstrated; and

4. As of August 15, 1986, various Limitorque motor operated valves inside containment did not have gear case grease relief valves and qualification of the valve operators without grease reliefs was not demonstrated.

This is a severity Level IV violation *

• NLR-N89093

RESPONSE TO VIOLATION NO. 2, ITEM 1. - TERMINAL BLOCKS ASSOCIATED WITH AUXILIARY FEEDWATER TRANSMITTERS

1. PSE&G DOES NOT DISPUTE THIS PORTION OF THE VIOLATION As described in LER 86-007, dated May 8, 1986, PSE&G identified, during a self-initiated walkdown, four (4)

Auxiliary Feedwater Flow Transmitters in Salem 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. The qualifiability and limited safety significance of the installed configurations prior to corrective actions taken were discussed at the Salem EQ Enforcement Conference at NRC Region I on September 29, 1988.

2. THE ROOT CAUSE OF THIS PORTION OF THE VIOLATION WAS A PERSONNEL ERROR IN THAT THIS WAS AN ISOLATED OVERSIGHT IN THE REVIEW PROCESS IN RESPONSE TO NRC INFORMATION NOTICE 84-47.

During an effort by PSE&G to upgrade safety-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 in response to IE Information Notice 84-47, "Environmental Qualification Tests of Electrical Terminal Blocks," these connections were not discovered. The revised configuration was identical for each of the circuits and represents an isolated oversight in the review process.

3. IMMEDIATE CORRECTIVE ACTIONS AND RESULTS ACHIEVED PSE&G promptly corrected this condition, prior to restart from the Salem Unit 1 March, 1986 refueling outage and entered a voluntary shutdown for Salem Unit 2 in May 1986 to assure a complete review and to implement corrective actions.

4. LONG TERM CORRECTIVE ACTIONS TO AVOID FURTHER VIOLATIONS PSE&G had taken corrective actions prior to the discovery of the deficiency 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 performed prior to design change package closeout (Engineering Procedure GM8-EMP-009, Revision o, December, 1985). The procedure also ensures that all DCPs affecting safety-related equipment receive a review by the EQ section to ensure EQ compliance. Therefore, any EQ-related drawings or installation procedures which are contained within the DCP are required to be reviewed by EQ engineers.

NLR-N89093

Since that time, the PSE&G Engineering and Plant Betterment Department has been reorganized. A new Engineering Manual and new procedures have been issued. Nuclear Department Procedure No. NA-AP.ZZ-0008(Q) provides for the administrative control of design and configuration changes while Engineering Procedure No. DE-AP.ZZ-0007(Q) includes a specialty review checklist where specific EQ attributes must be addressed as part of the design change process.

5. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved with the installation of qualified Raychem Splices in place of the terminal blocks on May 5, 1986 (Salem Unit 1) and May 6, 1986 (Salem Unit 2) prior to the restart of both units.

RESPONSE TO VIOLATION NO. 2, ITEM NO. 2 - LIMITORQUE T-DRAINS

1. PSE&G ;)()ES NOT DISPUTE THIS PORTION OF THE VIOLATION As described in LER 86-007, dated May 8, 1986, PSE&G identified, during a self-initiated walkdown, eleven (11)

Salem Unit 1 and eight (8) Salem 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 system and the chemical and volume control system. The qualifiability and limited safety significance of the installed configurations prior to corrective actions taken were discussed at the Salem EQ Enforcement Conference at NRC Region I on September 29, 1988.

2. THE ROOT CAUSE OF THIS PORTION OF THE VIOLATION WAS A LACK OF EXPLICIT INSTRUCTIONS DETAILING THE T-DRAIN REQUIREMENT

3. IMMEDIATE CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED PSE&G took prompt corrective actions to address the installation deficiency. Specifically, PSE&G installed T-drains in Salem Unit 1 prior to restart from March, 1986 refueling outage. T-drains were also installed in Salem Unit 2 prior to restart from a voluntary shutdown in May, 1986.

4. LONG TERM CORRECTIVE ACTIONS TO PREVENT RECURRENCE To address the root cause of this item, PSE&G established a new field directive (S-C-A910-MFD-0342, dated December 2, 1985) to provide added assurance 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, GMS-EMP-009 dated December 1985, to close-out DCPs with a field walkdown performed by the NLR-N89093

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.

since that time, the PSE&G Engineering and Plant Betterment Department has been reorganized. A new Engineering Manual and new procedures have been issued. Nuclear Department Procedure No. NA-AP.ZZ-0008(Q) provides for the administrative control of design and configuration changes while Engineering Procedure No. DE-AP.ZZ-0007(Q) includes a specialty review checklist where specific EQ attributes must be addressed as part of the design change process.

5. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved with the installation of the Limitorque T-Drains by April 30, 1986 for Salem Unit 1 and May 3, 1986 for Salem Unit 2.

RESPONSE TO VIOLATION NO. 2, ITEM NO. 3 - IMPROPERLY SEALED JUNCTION BOXES

1. PSE&G DOES NOT DISPUTE THIS PORTION OF THE VIOLATION As described in LER 86-007, dated May 6, 1986, PSE&G identified, during a self-initiated walkdown, seven (7) junction boxes in Salem Unit 1 and nine (9) in Salem Unit 2 (out of a total of 138 EQ junction boxes) that were not sealed in accordance with the instructions provided in original installation and design change packages (DCPs)

• systems and components affected by this deficiency include the Main Steam System; Main Steam Isolation Valve indication limit switches for Salem Units 1 and 2; Containment Pressure Vacuum Relief Isolation system solenoid valves for Units 1 and 2; and Liquid Radwaste Management System Containment isolation valve limit switches for Salem Unit 2. The qualifiability and limited safety significance of the installed configurations prior to corrective actions taken were discussed at the Salem EQ Enforcement Conference at NRC Region I on September 29, 1988.

2. THE ROOT CAUSE OF THIS PORTION OF THE VIOLATION WAS A MISINTERPRETATION OF GENERIC INSTALLAT~ON REQUIREMENTS Generic installation requirements were misinterpreted by insta1lation personnel due to confusion over sealing requirements specified for junction box entrance locations.

Also contributing to this portion of the violation was an oversight by the responsible EQ sponsor in not including all EQ identified junction boxes in the updated (most current issue in 1985) Equipment Qualification Master List (EQML) *

. The four junction boxes which were not included on the EQML were on the original master list.

NLR-N89093

3. IMMEDIATE CORRECTIVE ACTIONS AND RESULTS ACHIEVED The junction boxes in question were either properly sealed or evaluated and found acceptable prior to restart following and Salem Unit 1 March, 1986 refueling outage and a voluntary shutdown of Salem Unit 2 in May, 1986.

4. LONG TERM CORRECTIVE ACTIONS TO PREVENT RECURRENCE PSE&G had taken corrective actions prior to the discovery of the deficiency 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 performed prior to DCP closeout (Engineering Procedure GMS-EMP-009, Revision o, Dece:riiber, 1985).

The procedure also ensures that all DCPs affecting safety-related equipment receive a review by the EQ section to ensure EQ compliance. Therefore, any EQ-related drawings or installation procedures which are contained 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 misinterpretation. A field directive was also issued (FD No. S-C-A910-NFD-0405) on August 1, 1986 concerning EQ requirements for junction box installation and maintenance.

since that time, the PSE&G Engineering and Plant Betterment Department has been reorganized. A new Engineering Manual and new procedures have been issued. Nuclear Department Procedure No. NA-AP.ZZ-0008(Q) provides for the administrative control of design and configuration changes while Engineering Procedure No. DE-AP.ZZ-0007(Q) includes a specialty review checklist where specific EQ attributes must be addressed as part of the design change process.

5. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance with regard to the sealing or appropriate disposition of the EQ junction boxes in question was achieved on April 30, 1986 (Salem Unit 1) and May 3, 1986 (Salem Unit

2)

• NLR-N89093

RESPONSE TO VIOLATION NO. 2, ITEM NO. 4 - LIMITORQUE GEAR CASE GREASE RELIEF VALVES

1. PSE&G DOES NOT AGREE WITH THIS PORTION OF THE VIOLATION PSE&G initially responded to this portion of the violation in letters to NRC dated November 7, 1986, December 15, 1986, and February 13, 1987. PSE&G's position since that time has been that the grease reliefs are not required for the operability of the Limitorque operators in containment under Salem plant-specific post-accident conditions. PSE&G also made a presentation to NRC Region I on February 3, 1987 to discuss this (and other) Salem EQ inspection findings subject to the EQ Enforcement Criteria (which at that time were contained in NRC Generic Letter 86-15). NRC Region I acknowledged this presentation in a letter dated March 11, 1987 by stating that PSE&G's arguments had "technical merit" but that "PSE&G should have documented these arguments in the Limitorque EQ file prior to the time of the inspection."*

PSE&G continues to believe that a decision not to use the grease reliefs was made from all known and available information and that the Limitorque EQ file contained sufficient information to support qualification of the Limitorque opera~ors without the grease relief valves. A reprint of PSE&G's position on this issue presented at the February 3, 1987 meeting with NRC Region I is included as Attachment 2 of this letter.

The grease reliefs were installed in the Limitorque actuators in question in September 1986 as a matter of engineering practice, not to establish qualification of the act~ators.

Although PSE&G does not agree with this portion of the violation, its exclusion will not affect the applied severity level. As such, PSE&G requests that this concern be closed out in a similar manner to the other portions of the violation.

NLR-N89093

ATTACHMENT 2 TECHNICAL ARGUMENT IN SUPPORT OF QUALIFICATION OF SALEM IN-CONTAINMENT LIMITORQUE OPERATORS WITHOUT GEAR CASE RELIEF VALVES A potential enforcement item was identified by the NRC related to the absence of gear box grease reliefs on Limitorque actuators located in containment. The contention is that gear box grease reliefs must be provided in the plant installation since they were installed in the Limitorque actuators subjected to the LOCA/MSLB test simulation. It is verbally stated by Limitorque that the relief valve provides for relief of grease and the pressure build-up which occurs due to thermal expansion at prolonged elevated temperatures.

However, Limitorque also states in Report B0058, pages 14 and 15, that "Limitorque actuators for Nuclear Plant applications are designed to operate in normal and accident conditions without depending on absolute sealing. In fact, the ambient is not absolutely restricted from entering the actuator. The seals are of no importance for qualification and therefore, require no consideration for the qualification".

Mr. J. Drab of Limitorque stated in a telephone conversation with Ms. B. Horst of PSE&G on April 9, 1986, as documented in the Record of Verbal Discussions, "they are not an EQ requirement and their absence does not adversely affect the_qualification status of Limitorques." Mr. Drab and Limitorque have subsequently refused to issue this statement in a signed letter.

In FIRL test report F-C3441 prepared for Limitorque (used in their BWR Containment Report-60376A), it was identified that flooding of the test chamber occurred from a build up of steam condensate when the test chamber condensate trap became clogged.

This was attributed to a grease build up in the trap caused by grease that had evidently come out of the relief valve during the test. The test was stopped during the fifth day. Prior to the test discontinuation, the spegimen had been subjscted to two, three-hour t ansients at +340 F, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at +320 F and 4 1/2 days at +250 0F.

The Salem plant temperature profile fo 0 a Main Steamline Break (MSLB) shows a peak semperature of 347 F for 72 seconds, dropping to approximately 260 F ~n less than 5 minutes. For a LOCA, a peak temperature of 268 F is reached and maintained for 12 1/2 mingtes. Within 30 minutes the temperature will fall below 250 F. Each of these accidents produces a peak pressure of 43.2 psig for 170 minutes. Therefore, an external positive pressure is maintained for the duration of the temperature transient minimizing the pressure differential due to possible internal pressure buildup.

NLR-N89093

he superheat Temperature Test Report #B0027 was performed to

• aetermine the internal temperatures of components in the Limitorque valve actuators due to superheat ambient temperatures.

It illustrates that exposure of the actuator to high environmental temperatures for short durations of time will not raise internal unit temperatures to an equal state. It was demonstrated by analysis that an ambient temperature of 492°F in excess of 17 minutss would only result in a maximum internal temperature of 315 F for the electrical switch compartment components and motor windiggs. Actual testing indicates that an ambient temperature of 385 F was reached at 186 minutes and at this time the temperature inside the motor was only 282°F.

It can therefore be concluded that the effects of high ambient temperatures over a short time period will not result in excessively high internal temperatures. As such, excessive internal pressure will not result.

The grease utilized for lubrication of the intermittent gear box in the Limitorques at Salem is Mobil Grease 28. This is a synthetic lubricant exhibiting high pressure characteristics at temperatures in excess of 650 F. This grease has a dropping point of approximately 500 F, which precludes its changing to a liquid state even under superheat conditions.

• The main gearbox utilizes a calcium complex base grease anufactured by Exxon and known as Nebula EPl (or EPO). This rease can be used for applications up to 400°F, it contains an Extreme Pressure (EP) additive to help increase the film ~trength of the oil, and has a dropping point of approximately 500 F. The EPl grease exhibits similar characteristics to the Mobil 28 grease and both types of grease are approved by Limitorque for in-containment applications in the operators.

In Test Report BOOOJ, an actuator containing Nebula ~Pl gearbox grease was exposed to a sustained temperature of 250 F for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Grease relief valves were not installed on this actuator as Limitorque evidently determined that exposure to 250°F and 25 psig during an accident test was not sufficient to justify their usage. The test unit actuator was an SMB-0 type, which is rather small, containing approximately 9.5 pounds of gearbox grease.

Large actuators contain up to 75 pounds of grease (SMB-4 or 5 type). Given the small size of the tess unit, it can be deduced that maintaining the temperature of 250 F for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will bring the entire unit to thermal equilibrium, including the gearbox grease. It can Sherefore be determined that EPl type grease can be heated to 250 F and will not expand to any degree that would require the use of a grease relief on the actuator.

By utilizing the Salem accident profile for temperature and pressure for worst case Main Steam Line Break (MSLB) and Loss-of-Coolant Accident (LOCA), it can be determined by analysis hat exposure to either condition insige containment will not

• ause the gearbox grease to exceed 250 F. This is due to the NLR-N89093

Revised Attachment B - 2

• A potential enforcement item was identified by the NRC related to the absence of gear box grease reliefs on Limitorque actuators located in containment. The con~ention is that the gear box grease reliefs must be provided in the plant installation since they were installed in the Limitorque actuators subjected to the LOCA/MSLB test simulation. It is verbally stated by Limitorque that the relief valve provides for relief of grease and the pressure build-up which occurs due to thermal expansion at prolonged elevated temperatures.

However, Limitorque also states in Report B0058, pages 14 and 15, that "Limitorque actuators for Nuclear Plant applications are

.designed to operate in normal and accident conditions without depending on absolute sealing. In fact, the ambient is not absolutely restricted from entering the actuator. The seals, are of no importance for qualification and, therefore, require no consideration for the qualification".

Mr. J. Drab of Limitorque stated in a telephone conversation with Ms. B. Horst of PS~&G on April 9, 1986, as documented in the Record of Verbal Discussions, fiThey are not an EQ requirement and their absence does not adversely affect the qualification status of Limitorques", Mr. Drab and Limitorque have subsequently efused to issue this statement in a signe~ letter.

In FIRL test report F-C3441 prepared for _L'imitorque (used in .. *. .~'.:

their BWR Containment Report-60376A), it was identified that.

flooding of the test chamber occurred from a build up of* steam . . **

condensate when the test chamber condensate trap became,clogged *.

This was attributed to a grease build up in the trap caused by .

grease that had evidently come out of the rel~ef valve during _the (

test. The test was stopped during the fifth-day. Prior.to-the_ .:.

• test discontinuation, the speGinien had be.en subjected to\2~';J:.hree*':.

hour transients at +340°F, 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at +320°F and 4 1/2 dayi(a~Yi .

+250° F. . .. _ . *">~.(-. :,-_:.",:--;i,;\~;i~}f.:'**::~--;j: .

The Salem plant* temperature profile for a Main Steamline :*areak .: :, ;. *

( MSLB) ~hows a peak temperature of 34 7°F for

• 7 2 secongs, droppinq :* ,

• to approximately 260°F in *less than 5 minutes. For.*a:.'LOCA;* a . _ -'. ._..

peak teinperature of. 268°F is reached and maintained. for. 12,.1/2 :'. _ *.

minutes*.. Within 30 minutes the temperature .. :will ~*fall below *":* ,::-.

• 250°F. <-Each of these accidents produces**:a*:peak pressure*of ,43~2 psig for. 170 *minutes;~.. Therefore,* an exter'nal.positive pressure*:.:

is maintained for *the' duration- of the temperature transient- * * ;,-

minimizing the pressure. differential due t.o *possible internal * **.**.

• pressure buildup *. *_ ., .. ';*

.:.1

. da8/l

.* ' -.... r*. *1 *

• ~*. . *.~

i ..

.I

The Superheat Temperature Test Report #B0027 was performed to determine the internal temperatures of components in the

• Limitorque valve actuators due to superheat ambient temperatures. It illustrates that exposure of the actuator to high environmental temperatures for short durations of time will not raise internal unit.temperatures to an equal state. It was demonstrated by analysis that an ambient temperature of 492°F in excess of 17 minutes. ~fou.ld only result in a maximum internal temperature of 315°F fo'i;* the electrical switch compartment

• components and motor windings. Actual testing indicates that an ambient temperature of 385°F was reached at 186 minutes and at this time the temperature inside the_~otor was only 282°F.

• It can therefore be concluded that the effects of high ambient temperatures over a short time period will not result in excessively high internal temperatures. As such, excessive internal pressure will not result. *

• . *,.- The grease utilized for lubrica~ion of the ini~rmittent gear box in the Limitorques at Salem is Mobil Grease 28. This is a synthetic lubricant exhibiting high pressure characteristics at temperatures in-excess of 350°F. *Th.is grease has a dropping point of approximately 500°F, which.~recludes its changing to a liquid state even under superheat*condit~ons.

• The main gearbox utilizies a calciuln"complex base grease ...

manufactured by Exxon and known as Nebula,EPl (or EPO). This grease can be used for applications u~to 400°F, it contains an Extreme Pressure ( EP) additive to help.-:'increase the film strength

• Of the oil, and has a dropping point:*-~of:<:*approx,imately 500°F. The EPl grease exhibits similar characterlst'ics to the Mobil 28

• grease and both types of grease ar~)ap~r9ved_by Limito~que for in-containment applications in the:.!?,*pera.tor~. -:

• In* Test Repor*t 80003, an actuator. cpnt~lni.n_g:_ Nebula EPl gearbox grease was exposed to a sustained.: temperature of 25 0°F for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> *. Grease relief valves were~~not'*i;1ilstalled on this actuator

• *.as Limitorque evidently determined*:;_diat/.exposure to 250°F**and 25*.' .

. : * *.psig during an acciderit test was~~6t!~u~fl~ierit to*justify their

• J .** . usage **. ,The test unit actuator wa's'.>a)S~a+o. type, ;:which is rather *

~<i;\,r ** : small,: ~containing* approximately>9 ~~$?pounds :*of,;_ge.artiox grease~**.*.- :" .

. *** *.* * *Larger.. actuator*~,.*:c~:mt,ain up __to.*'::75.~'pou-#asK9f *)1r_ea~.~:*,;< SMB-:~. or*. 5 *

-i}.~:;~'.:( type t~ . Given:::: the* *$mall *.s ize'**of*,~:~he\.test,?:uni t;f:~f.~;'.:'can be****deduced.

%>_-,:_:.*: that ma:intaini_l'1_g*:.~*t.t1p

• temper*atur.e',:*.ae*:*_2*~o~_F/for **~24~'h(>urs. wil_l bring ,...

., ., the entire unH: **to?thermaL*equilibr.iiun;. including *the gearbox * :;-'r: .-.*

.>.-.> . grease. It: can:: ther~for.e :be determined, that* EPl type grease~ can::~* *: *

• . ,; :.~~ ,- be heated .fo.::250°F *and'.:'will not'-*exp'.ancf.;to: any. degree;, t.~~:t~*;*:WO\Jld_

'.';;~;*:;-./'. .:require the -use of-'*a';~grease relief -ori *the '"actuator.** . .. -'i'-1'!:~,.if!/~1;~~;{:<**::*.: *

~':_~t,\:~~~,'*

_ .r .* ~: . *. , '. ;*,:rc~ v ' " ' , ........ , : 'c!\( , . .. . . . , . ~J~*s:'\. *.--'J

.. . ,. .. . 'l~.~: .:

' ~- ~ ..

'.'.;:,;,,;** d 8/

2 .: .;

... '.*.**"' ' '~ .'

_~. -, ~for.;_i_~.w~ ;*g~if'."(,~\ ;:* ***;'.* * .* *;.**~:1H~*~ x*, y!.J* * *;* *

-~ ..

.. . /;_:~ .....:;:.. ..

. - ' :* ....:.-:. .. *::. *~. ", .~-* *,

By utilizing the Salem accident profile for temperature and ressure for worst case Main Stearn Line Break (MSLB) and Loss-of

• Coolant Accident (LOCA), it can be determined by analysis that exposure to either condition inside containment will not cause the gearbox grease to exceed 250°F. This is due to the fact that the maximum LOCA temperature of 268°F is reached in approximately 4 minutes following the start of the accident, after which the temperature slowly begins to decrease. Thirty minutes following the start of the event the temperature has fallen below 2S0°F.

As is evident, the time duration is not sufficient to heat the grease above 250°F.

During the MSLB event, a maximum temperature of 34 7° F. is *reach.~d in apprqximately 100 seconds. This temperature is maintained for 7 2 seconds, after which the temperature rapidly begins to . .

decrease. Thirty minutes following the start of the event the temperature falls below 250°F. Again the time duration at the temperature above 250° is not sufficient to heat the grease above 250°F.  :**, ::*

• • . ::*:. ~:... .

The character is tics of the grease would be a factor in*.* "o: ..:,.": .;* .. .- **.

determining the necessity of grease reliefs on the gear: case";,;'.}:,**' .. : .

housing.*. Since the greases utilized during the qualification<>'/.~'*:.*

tests were not identified, a correlation of actual parameters>>*

• cannot be made. However, a temperature. resistant grease such.'..as'..

the Nebula EPl appears to have been used. * ;* *. * **/_:,:.:...

proven by* test, the internal temperatur.e of the operator, even .

. ** der superheated ambient conditions, would nc;>t. cause th7.\ ,.-'

. internal temperature to exceed saturated condi t1ons. This ; ,,: , .

• _temperature is well within tJ:le design limits of the specif.ied '/' ,,

grease and would not be cause for it to exhibit appreciable:.-:'* .. *.....

expansion. A pressure buildup sufficient to breach the switch* *** * * * **.f*

compartment* is not possible under the Salem Station postulated* *;.'° \;*_."'..*-~.~_.~,*.*'*: *<::f accident conditions and therefore grease relief plugs are not,_').,: ...... . 1 .~ ::,./.!

requ i~_e?:~::T.o*.. ~:ti~~!*~~\ ~~~-r~~ i ~it y ** o_f .t~e val:~'.e * .* -~ .. ;:_,: .* : ... f/*>  :*.*:_:_\.:}'.~)~!'.f~{LiiFPt\: *;::(*.

It should**be note:d,,.tha.~ *p~E&G's position .was~ and .. still .ii:f, that~'.~:~~;;;~:,~;*~:~*'.\*~,\;;~i}~

a* determination to not~*use .grease reliefs was. made from** all known_'.()~J'.<fF.*'li:*.;i. ~-~z

• . . . a , '* * --~ :* ,* ', . *: *. ****~,r.:.~- **f,...., .... ,:rr*,,~-~~ ..,;;

and avaiiable,~.~information.*~:;;:, __Based on: the verbal< information from'!:'.;.t$;. :£'.{;Y,.'ll. ,'ft~}*_)};:':.;.~

• • Limitorqtie~:~~th'e:\S~lem:;~R;~:specific accident;'*profiles and,:~~~~-;~ -.;=:* '* 11 " 0°"~:.:f:.(f

,:-.

• knowledge./ofTiil'e.,/dat:a*:f;.ln~~the ..test report i 'it . was::aetermii\*e*d, that .

. . the *-grease' . . r~'ffef/valv'e's't.~were"::not necessary:. would .not* pr.event ..

the :valve s*:.;f ronaJ:per f_q~mrn:*9* 'their safety:,' function* 1.\ and *.[,their . ' ";- :.

,* ,* absence _wo_uld~{n§.~'.~\~~:~'.}~'.~x~o,!.~~ion_ of .the.::,q~~l} f;i,~~'~io~,'.: 'sta~us :a~

'*.*~.-'

-~ ' ..

. ~-. '  :

~ :* . ~. . '

For information purposes at the time of the .inspection, there were 7 in-containment class lE actuators£ in. Salem Unit 1 that re identified by Station QA personnel as *n.ot having grease

• lief valves. Salem Unit 2 had grease relief valves installed on all in-containment actuators. In accordance with the recommendation to utilize grease reliefs as good engineering practice, grease reliefs are now installed on all in-containment actuators at Salem.

da8/4

. ~. ~ ~:-.

... .*: /"-~:_*

-~

. :.._"r.'

'. .*. : ... ~*1_

.* .". ~*

~ :

- 'r:

.: . .;", ~ :

• • • ~---"'---**------ *-- -*

• • LIMITORQUE

4. Motor Orientation/T-Drains:

All tested motors were horizontal, motor Page 5 T-drains were utilized in certain tests as tabulated below. The principal purposes for use of the T-drains were, 1) to provide drainage of internal actuator condensation; and 2) to serve as the primary vehicle for internal-to-external actuator pressure equalization.

The T-drains were the principal pathways for steam and moisture intrusion into the actuator. In order to function as drainage pathways, the motor T-drains should be installed at the motor low point ports.

For motors covered by tests utilizing two T-drains, their location should be as follows:

( 1) motor principal axis horizontal one (1) T-drain on each motor-end bell at the lo.~est available point. If the motor iead wireway to limit switch compartment occupies one of these positions (e.g., for a horizontally mounted motors with 1 imi t switch compartment facing down) it will function as a motor drain . In this case the associated T-drain may be

. omitted or placed at the next available point to facilitate motor drainage.

q, J LIMITORQUE Page 6 09 (2) motor principal axis vertical two (2) T-drains on 0 lowest motor-end *bell.

typically provided in each (Four end plugged ports are bell which can be used u to locate the T-drains).

For actuator motors tested with one motor T-drain, it should

!) be placed at the lowest available end bell port. Multiple ports u are not typically provided in installed in unused end-bell ports.

these motors. Plugs should be I For actuator motqrs tested without T-drains (Reliance Rad H and Class B) motor T-drains are not required nor are they recom-I mended by Limitorque.

I Limitorque notes that all equivalent with electrical tested actuators were essentially component differences limited to I motors, terminal blocks, torque and limit switch materials.

Terminal blocks are generically addressed BOil9. For all I in-containment tested actuators the torque and limit switch I materials are equivalent.

utilizing replacement RH motors It is, therefore, possible when to "upgrade" a 600198 actuator's or motor's qualification to more recent reports.. In these cases, installed motors should be equipped with T-drains per the I

I I

I I

I

. I M I TORQUE -Page 7 referenced motor report. Limitorque recommends that the installed motors be provided with T-drains to represent the referenced motor's tested configuration.3 3/The NUGEQ notes that in locations which do not experience temperature and humidity increases due to steam line breaks (e.g., mild environments or radiation only harsh environments}

the pressure equalization and drainage provided by the T-drains would not be necessary. In these cases, the NUGEQ believes the absence of T-drains is justified. The omission of T-drains in other situations will not necessarily prevent proper actuator operation or violate environmental qualification. Examples of situations which, based on utility-specific analysis, may be considered acceptable include:

. 1) Operability only required for a short duration immediately post-accident, or

2) Motor orientations which would preclude moisture collection in the motor (e.g., drainage into the limit-switch compartment would occur), or

3) The required environmental parameters are bounded by other reports (e.g., 600198, B0003 or F-C3271) which did not utilize T-drains. Since the RH and LR class insulating systems which were tested with T-drains are considered superior to the Rad H and B Class systems, this extrapolation of the 600198, B0003 and F-C3271 reports can be made.

zmzrwn 1** I Page 8 LIMITORQUE I

Motor T-Drain Data:

( 1)

(2) 600198:

600376A:

None 2

I (3 600476: 2 (4) B0009: 1 I (5) B0003: None

( 6) F-C3271: None I (7) B0027: 2 I ( 8) B0212: 2

( 9) B0119: 2 I

I I

I I

11 I

I I _.

I I

I l LIMITORQUE Page 23 I 17. Limit Switch Compartment Drains/Seals/Conduit Connections:

I For tests utilizing environment entered the motor limit-switch T-drains, the external test compartment from the motor I housing via the motor lead wireway. For actuators tested without motor T-drains, the external steam environment entered the I actuator via the gas permiable Anchorite gaskets and via the conduit fittings which were not installed to provide pressure-I tight seals. Limitorque noted that in all the actuator tests I without T-drains, moisture and steam intrusion was evident from the small pool of condensate* that collected in the LSC. For I tests without T-drains, pressure recordings document actuator pressure equalization at test-chamber pressure and demonstrate I that leakage occurred in all referenced tests. It was also noted I that in the 600198 test (which tested units without motor T-drains) a 9-hour preliminary steam test was performed by piping live steam into the LSC via upper conduit taps and draining condensate with an open lower conduit tap. That report indicates I that the test was successful with no noticeable effect on the I function of any parts in the LSC. In all the Limitorque tests, the existence of moisture inside the unit did not prevent I adequate actuator performance.

During the testing, test leads (both power and control)

I exited the LSC via two conduit openings (one for power and one I for control). The configurations of these openings are tabulated below. Unused openings were closed with threaded pipe plugs. No I --

I I

1** '*

...- . LIMITORQUE external Limit Switch Compartment (LSC} drains Page 24 were provided I during any of the referenced EQ tests. As previously discussed, for the tested configurations, excess condensation during testing I drained from this compartment via the internal wireway into the motor housing. The exact location of the wireway varies with I actuator model number (SMB-0, SMB-00, etc.), but is located I roughly at 3/4 of the compartment horizontally.

height when the LSC is mounted (See Figure 1 attached.)

I For installations that reference tests utilizing motor T-drains, Limitorque indicated that the use of LSC drains I although not r~quired does not affect qualification since, during I the tests, the external environment T-drains.

enter the LCS via the motor I LSC Conduit Interface Data:

Three conduit wiring configurations were used in the various I tests as follows:

I TYPE A Non-nuclear grade Conax seals at both the limit switch *compartment conduit opening and test at chamber wall.

I TYPE B Non-nuclear grade Conax seals at test chamber wall. High pressure teflon hose threaded to both I the Conax seal and the LSC conduit openings. The tef lon hose was used to minimize abrasion to the internal~ test wiring during the qualification testing.

I TYPE C Non-nuclear grade Conax seals at test chamber wall. Steel tubing with threaded fittings I connected to both the Conax seal and the limit switch compartment conduit opening. The purpose of the tubing was to .minimize wire abrasion I during testing.

I I

(b) When the inspectors initially reviewed file E0-32 for coaxial cable the file contain~d Rockbestos Qualification Report, dated March 15, 1979, which is also subject to the concerns of IN 84-44. Again the licensee was unable to provide the inspectors with documented evidence that any of

• the corrective actions of the IN were taken. Prior to the

.. end of the inspection, the licensee added Rockbestos Qualification Report QR 6802 for "LE" coaxial cable and a similarity analysis to demonstrate the similarity of the tested "LE" cable to the installed "LO" (foam dielectric) cable to the .file. This report and the similarity analysis demonstrated qualification of the installed "LO" coaxial cable for its application at Salem.

~~e~ though the licensee* was able to establish qualification of the EPR and coaxial cables prior to the end of the inspection, the qualification files as presented to the inspectors did not support qualification of the cables, since the licensee was not able to provide documented evidence that adequate corrective action had been taken with regard to IN 84-44. The reports upon which oualification was initially based were not adeouate to establish qualification. Failure to establish qualification of the Rockbestos EPR and coaxial cables is identified as a Potential Enforcement/Unresolved Item (50-272/86-23-03; 50-311/

86-23-03).

(3) Limitorque Motor Valve Oper~tors, File EQ-51:

The inspectors' review of file EQ-51 for Limitorque motor valve v

\ . ..;

operators determined that operators were installed in inside containment applications without gear case grease relief valves.

This is contrary to the information provided in paragraph 6.0 "Design Life" of the basic Limitorque Qualification Report, 80058, dated January 11, 1980. Paragraph 6.0 states that greas' relief valves are used to accotrm0date the extreme temperatures and pressures of containment OBA environments. The inspectors questfoned the licensee concerning his justification for not using the grease relief valves and th*e licensee did not have ar~

documented analysis for not using the valve when questioned.

Based on the concerns raised by the inspectors and prior to the en~. of the inspection, the licensee docuuiented his position as

• to why the inside containment operators were considered qualifi~d

(\J v

without the relief valves~* The inspectors' review of this just'-

fication determined that it was adeouate to establish qualific~!;cn of the installed configuration of the operators.

Since there was no documented justification in the file for installing the inside containment operators in a configuratiori different than the qualified configuration when the file was initially reviewed,-this is identified as a Potential Enforcement.

Unresolved Item (50-272/86-23-04; 50-311/86-23-04).

11