ML18149A425

issues.

Notice No.

24

contained

in

IN 83-72 deals with potential

qualification

problems with Limitorque motorized valve actuators (MOV).

had evaluated the problems identified in the IN and had taken

corrective actions which they considered necessary at that time.

determined that no further actions on

the issue of

potentially unidentified (and unqualified) degradable materials

5

such as w1r1ng

insulation mentioned in

Notice 24 was

necessary for qualified Limitorques at SURRY until the problem

was again identified in IN 86-03.

IN 86-03, dealing directly with i denti fi ed L imitorque wiring

deficiencies, precipitated a comprehensive MOV inspection and

upgrade program at SURRY per Engineering Work Request (EWR) No.86-191,

11Controlling Procedure for

MOV

Corrective Action.

11

EWR-86-191

covered

wiring. and

other

issues

including

lubrication, totque and limit switches, grease reiiefs and caps,

111"-.dr_ains, terminal blocks and heaters.

All internal control

wiring was being replaced with qua l if i ed Brand Rex NGA-34 wire.

The NRC inspectors reviewed completed SURRY inspection forms and

examined internally two MOVs in Unit 1 in containment and two

MOVs

outside containment.

Two

MOVs outside containment in

Unit 2 were also examined. (See paragraphs 4.E(5) through (8).)

SURRY inspection_ sheets indicated that four of the five Unit 1

MOVs inspected thus far of the eight total in containment and

74% of those in the MSVH and the AB had had some uni dent i fi ed

wires. VEPCO had examined two Unit 2 MOVs outside containment

finding both with at least some unidentified wire.

The results of these inspections by SURRY together with the

walkdown of this NRC inspection established that some MOVs

inside containments, outside containments, and in the MSVHs

would have been in an ~nqualified condition due to unidentified

and potentially unqualified wiring as of November 30, 1985 and

presumably remained so until the outage in progress on Unit 1

and the June 17 unscheduled outage of Unit 2.

VEPCO's failure

to identify

MOV wiring and establish its quali-fication or

replace it with qualified wire by the qualification deadline of

March 31, 1985 or (with NRC Staff approved extensions) of

November 30, 1985 and continuing to operate until the above

outages, constitute Potential Enforcement/Unresolved Item

50-280,281/86-12-0l.

At the time of the NRC inspection, 54 of 5_7 Unit 1 MOVs had been

upgraded.

The remaining three MOVs were to be upgraded prior to

startup from the outage in progress. The NRC inspectors verified

rewiring according to EWR-86-191 in the MOVs they examined

which had been upgraded.

Unit 2 was scheduled to operate until.

the October 1986, outage with all 50 of the outside containment

MOVs potentially unqualified.

This issue was addressed in Surry

Power Station Technical Report EQ-6,

11Justification to Operate.

11

During the inspection; on June 17, Unit 2 was shut down to make

other repairs.

During this short outage, VEPCO comitted extra

resources and inspected the remainder of Unit 2 MOVs, reporting

completion of required rewiring on June 24, 1986.

IN 84-44 identifies problems with Rockbestos cable qualification

testing.

VEPCO's actions regarding this are addressed in con-

junction with the discussion of Rockbestos cable in paragraph

4.D(3) below.

6

IN 84-90 Concerns *qualification Problems resulting from the

superheated steam environment which is created when, during a

large MSLB, steam generator tubes are uncovered by the resulting

blowdown producing superheated steam.

Nuclear Engineering (NE)

Technical Report No. 508 documented the VEPCO review of IN 84-90

and evaluation of a MSLB in SURRY's main steam valve houses

(MSVH) which are confined spaces outside containment in which

these conditions can be extremely severe.

This report replaced

NE Technical Report 442 which considered the impact of super-

heated steam on the break mass and energy release, but failed

adequately to. account for -the elevated steam temperatures.

NE Technical Report 508 concluded that SURRY had the minimum

required equipment ~vailable to detect, isolate and recover from

a postulated 1.0 ft MSLB with superheated steam.

.

However, an internal engineering memorandum dated June 4, 1986

in the IN 84-90 file summarized the results of the NE technical

reports, but pointed out that while this conclusion was based on

conservative assumptions with respect to break location and

equipment failure, permanent flow openings exist between the

upper and lower-elevations of Unit l's MSVH i._e., between areas

MSVH-27 and MSVH-11 which provide vent paths into containment

spray pump houses CSPH-11 and CSPH-27 via area MSVH-11.

This

invalidated credit taken

in* generating environmental

zone

descriptions (EZD) for no significant vent paths between areas

MSVH-27 and MSVH-11 in Unit 1.

Per design, Unit 2 has no floor

openings between these zones.

At the time of the NRC inspection, VEPCO was* evaluating this

issue further based on. recomendations in the above memorandu2

to generate plant specific environmental profiles for the 1 ft

MSLB and investigating taking credit for MSVH upper elevation

doors acting as blowout panels to the atmosphere.

Of particular

significance were recommendations in the engineering memorandum

to revise Emergency Operating Procedures (EOP) to deal with

potentially erroneous or lost main steam pressure indication and

to insulate the affected transmitters or relocate them to a less

harsh environment.

VEPCO had planned to resolve the issue for

Unit 1 prior to startup from the outage in progress, but planned

to complete any required corrective actions for Unit 2 during

its scheduled outage in October, 1986.

However, on June 17,

during the NRC inspection, Unit 2 shut down for an unscheduled

outage for other reasons.

By the end of the inspection, VEPCO

had_ decided to divert resources from the Unit 1 outage and take

necessary EQ corrective actions on Unit 2 while it was down.

This office was informed on June 24 after the inspection. that

all affected transmitters in both units had been relocated and

that structural modifications had been made where required to

limit the steam communication between the affected spaces. The

unqualified condition of transmitters PT-1474, 1475, 1476, 1484,

1485, 1486, 1494, 1495 and 1496 in Unit 1 and PT-2474, 2475,

2476, 2484, 2485, 2486, 2494, 2495 and 2496 in Unit 2, while

located in the superheated MSLB zones, constitutes Potential

Enforcement/Unresolved Item 50-280,281/86-12-02.

7

t

B.

(2)

EQ Personnel Training

VEPCO has provided EQ awareness training to plant personnel in

the departments of Engineering, Maintenance, QA/QC, Procurement

and Training as described in Power Training Services Instruction

Guide,

11 Environmental Qualification (EQ)

Awareness Program.

11

The training covered a* brief history of EQ and its regulatory

requirements.

It* covered types of equipment to be qualified,

EQ criteria and the implementing procedures.at SURRY, including

the. documentation

used

to

develop

the

pro*gram,

and

the

responsibilities of individuals at the station.

The inspectors

reviewed records of attendance and test results and verified

that representatives from the above organizations were provided

basic EQ training.

'

EQ Maintenance Program

The station is responsible for maintaining qualified equipment in a

qualified condition by incorporating EQ maintenance practices into

station maintenance programs. * Review of the procedures listed in

paragraph 4.A above indicated that these requirements have been, in

general, properly incorporated into site and department procedures.

Failure of the site to develop adequate procedures for analyzing and

replacing oil in the High Head Safety Injection pump motors every

2040 hours0.0236 days 0.567 hours 0.00337 weeks 7.7622e-4 months as required by the qualification data package maintenance

section (as discussed in detail in paragraph 4.D(l) below) was

identified as a maintenance concern and Potential Enforcement/Unre-

solved Item 50-280,281/86-12-03.

Two concerns were identified with respect to Raychem heat-shrink

sleeving procedures.

The installation procedure for Raychem splices

used at SURRY had no restriction on maximum bending of the splice nor

did it prohibit the installation of splices over braided material.

Analysis to justify these deviations from current recommended Raychem

practice was not provided.

VEPCO committed to review the procedures

and make required changes.

A computer program had been developed by VEPCO to help monitor EQ

related maintenance and to avoid overdue mai~tenance problems.

This

system was demonstrated to the inspectors and appeared to be a sig-

nificant enhancement to EQ and general plant maintenance management.

The EQ maintenance review also included the following procedures:

a.

Periodic Test Procedure l-PT-18.7,

11Charging Pump Operability

and Performance Test

11

, dated February 25, 1986

b.

Electrical

Maintenance

Procedure

Electrical Maintenance Procedure

Motor

11

, dated July 25, 1985

EMP-C-EPC-138,

11Corrective

for Repairs to

LHSI

Pump

c.

Surveillance Instruction SI-P-E/RI,

11Electrical Preventive

Maintenance

Procedure

for

Low

Head

Safety Injection

Pump

. Motors

11

, dated February 28, 1985

8

1*

I

C.

D.

d.

Electrical Maintenance Procedure EMP-C-EPH-139,

11Corrective

Maintenance Procedure For Repair to 4160 V Charging Pump Motors

11

The inspector concluded that except as noted above, these procedures

were adequate to properly control EQ-related maintenance activities.

Environmental Qualification Master List (EQML)

The NRC inspection team reviewed the SURRY Unit 1 EQML, Revision 11,

dated 6/10/86 and Unit 2 EQML

Revision 10, * dated 6/10/86 and

associated documents discussed below to verify the adequacy of the

implementation of SURRY

1s EQML development and maintenance procedures.

The EQML was based on a review of Technical Specifications, Emergency

Operating Procedures (EOP), Flow Diagrams, Electrical Diagrams and

Regulatory Guide 1.97, Revision 3, Categories 1 and 2 .confirmed by

field verification walkdowns.

-

The procedures listed in paragraph 4.A above and the Nuclear Design

Control Interface Manual-3 establish procedures and responsibilities

of company organizations for maintenance and control of the EQML.

Review of these documents indicated that all types of equipment

required to be qualified under 10 CFR 50.49 would have been covered.

As a validation check on SURRY

1s EQML, Emergency Procedure EP-2.00,

Loss of Reactor Coolant, Rev. 00.05 and EP-1.00, Reactor Trip/Safety

Injection, Rev. 00.06 were reviewed with SURRY representatives.

The

inspectors verified that selected equipment

identified in

the

procedures as required during the accident were on the EQML.

Records

pertaining to

EQML

deletions were reviewed with no unjustified

remoyals identified.

Environmental Qualification Documentation Files

VEPC0

1s EQ documentation files are established within the corporate

office engineering data

and

configuration control

system with

duplicate files to be maintained at SURRY.

The files are called

11Qualification Documentation Reviewsll

(QDR)

and consist of

Summary

Sections,

Worksheets

( simi 1 ar

to

system-component

evaluation worksheets (SCEW)), Environmental Zone Description (EZD)

sheets, reference lists, parameter evaluations, accident profiles,

installation and maintenance requirements, NRC IE IN and IEB recon-

ciliations, and references including EQ test reports and supporting

analyses, and related correspondence.

A QDR is prepared for each specific type of qualified component

designated by manufacturer and model, in a plant area exposed to the

same environmental service conditions.

The NRC inspectors examined QDR

I s for 21 selected equipment types .

In addition to comparing plant service conditions with qualification

test conditions and verifying the bases for these conditions, the

inspectors selectively reviewed areas such as required post-accident

operating time compared to the duration of time the equipment has

been demonstrated to be qualified, *similarity of tested equipment to

9

that installed in the plant (e.g., insulation class, materials of

components

of the

equipment,

tested configuration compared

to

installed configuration, and documentation of both), evaluation of

adequacy of test conditions, aging calculations for qualified life

and replacement interval determination, effects of decreases in

insulation

resistance

on

equipment

performance,

adequacy

of

demonstrated

accuracy,

evaluation

of

test

anomalies,

and

applicability of EQ problems reported in NRC IE Information Notices

and Bulletins and their resolutions.

Specific QDR findings were as

fo 11 ows-:

.

(1)

QDR S-4.1,

11 High Head Safety Injection (HHSI)Pump Motor

11

,

(TAG

Nos. 1-and 2-CH-P-lA, B, and C) review resulted in two concerns

being identified.

(a) Aging calculation NE-030, Rev 0, dated

11/20/85, demonstrated a qualified life of 36 years whereas the

maintenance/replacement

section

of

the

contained

no

requirement to replace the motors before the end of the 40 year

plant life.

In response to* this concern, VEPCO committed to

revise the aging calculation, relaxing some over-conservative

parameters (such as service temperature) to demonstrate a 40 yr

qualified* life.

Pending future NRC review, this is identified

as Open Item 280,281/86-12-07.

(b) The QDR indicated that the oil used in the "HHS! pump motor

must be analyzed or changed before 2040 hours0.0236 days 0.567 hours 0.00337 weeks 7.7622e-4 months of operating time

has

expired.

Contrary to. this

requirement, maintenance

procedure CH-P-E/SA only required that maintenance be done on

the motor semiannually.

In response to this item,

committed

to verify installation of hour meters

on motor

breakers and to begin logging operating hours, to change oil at

appropriate intervals in the future and to change oil before

plant restart.

Meanwhile,

would

be performing oil

analysis and conducting tests to attempt to extend the qualified

life of the oil.

VEPCO's failure to implement EQ maintenance

requirements to preserve the qualified status of the HHSI

motors

constitutes

Potential

Enforcement/Unresolved

Item

50-280,281/86-12-03.

(2)

QDR S-4.3, Low Head Safety Injection (LHSI) Pump Motor, Rev 5,

dated 3/27/86, Westinghouse Motor Model ABDP, indicated that the

LHSI pump motors (TAG Numbers 1- and 2.;. SI-P-lA and lB) were

qualified by Westinghouse in Test Report WCAP-8754, Rev 1, to

NUREG 0588, Category II requirements.

However, FRC had reviewed

this same information on these motors (FRC TER Item No. 51) and

concluded that there was insufficient information to establish

qualifitation based on similarity to .the tested motors and

SURRY's rewound motors.

VEPCO had on file Westinghouse letter

dated April 9, 1981 [VPU(RRK) -

120] which stated that an

investigation of all available information regarding the rewind

of the SURRY LHSI pump motors revealed that only specification

LIT-Spec. 711306 was in use at the time of the rewind and for

several years before and after. The possibility that other

materials or specifications were used is minimal.

Westinghouse

.indicated that an insulation system similar to that specified in

Spec. 711306 was tested for thermal performance demonstrating

10

that this insulation performs as well as the latest thermalastic

epoxy system in Class B service with regard to thermal aging.

A

review of the insulation materials called for in Spec. 711306

shows

that s i mi 1 a r

ma teria 1 s

ca~,

in

genera 1 , withstand

radiation levels between 10

and 10

RADS without degradation.

Based on this information, similarity was considered established

which presumably resolved the TER deficiency.

However, review of the Westinghouse letter .revealed that while

Westinghouse considered this information suffident to justify

continued operation, they concluded that there was insufficient

documentation to* satisfy the long-term qu9lification require-

ments set forth in IEB 79-0lB (DOR Guidelines).

In response to

NRC

concerns,

committed

to obtain clarification of

Westinghouse's position and to obtain additional information to

demonstrate similarity between SURRY's LHSI

pump motors and

those listed in WCAP 8754.

VEPCO's failure to show similarity

between rewound LHSI motors and the tested motors upon which

qualification was based in light of the manufacturer's position

is

identified

as

Potential

Enforcement/Unresolved

Item

50-280,281/86-12-04.

(3)

QDRs 6.1, 6.2 and 6.12., Rockbestos (Cerro) cable.

Reasonable

bases under the DOR Guidelines for qualification of formulations

KXL 760-5, KXL 780, and KXL 760-D of chemically cross-1 inked

polyethylene (XLPE) insulation wer:e included in the file.

The

concerns in IE IN 84-44 were addressed by two of the methods

outlined in IN 84-44:

(1) demonstration of significant margin

between specific accident parameters for the installed cables'

locations and the values in suspect Rockbestos reports cited.in

IN 84-44 and (2) supplementing Rockbestos data with generic qata

from other manufacturers and from Sandia National Laboratories

testing. Just prior to this inspection, VEPCO had obtained from

Rockbestos the specific formulations supplied for each SURRY

purchase order.

Previously* unknown to VEPCO,

KXL-760 (also

known as 760-A) and KXL-510 (

11Pyrotrol III") formulations were

also identified by Rockbestos as having been supplied for SURRY.

Review of documentation relating to IN 84-44 indicated that

VEPCO had been reasonably thorough in establishing qualification

for Rockbestos cable they believed was installed at SURRY and

that this recent revelation was the result of trying to obtain

final confirmation on specific formulations as a culmination to

the ongoing process of following the Rockbestos requalificatibn

program and upgrading their files accordingly, and in light of

recent discoveries at other plants.

Qualification of the KXL-760 would have been supported by the

existing file, but this formulation was not specifically listed.

VEPCO committed to (and was already in the process of) updating

the QDR to include KXL-760.

Pending future NRC review, this is

identified as Open Item 50-280,281/86-12-08.

KXL-510 (

11 Pyrotrol III

11

) qualification was being added to the

file.

The planned action was to qualify these cables based on

five Franklin Research Center reports with additional supporting

11

I

J

analysis similar to the other formulations.

VEPCO's failure to

establish qualification for

the

KXL-510

is identified as

Potential Enforcement/Unresolved Item 50-280,281/86-12-06.

(4)

QDR S-6.13 Brand Rex XLPE insulated, Hypalon jacketed, 600V

power and control cable qualification basis was 10 CFR 50.49.

The

adequately supported qualification, but similarity

between tested and installed cable was not clearly established.

Certificates from Brand

Rex related purchased to installed

cable, but did not specify if the tested cable was identical or

simjlar to installed cable.

demonstrated that the

installed cable is the same material and construction type as

the tested cable and is similar in configuration within the

guidelines of IEEE Standard 383-1974.

VEPCO committed to update

the QDR to support similarity on this basis.

Pending future NRC

review, this is identified as Open Item 50-280,281/86-12-09.

(5)

QDR S-3.2, Inside Containment Limitorque Motor Operators, Model

SMB-00, Maintenance Section (Tab E) requires cycling valves

twice a year.

However, MOV-1869A, 2869A, MOV-1869B, 2869B,

MOV-1842, and 2842 cannot be exercised during power operation.

During

cold

shutdown,

the

charging

flow

could

cause

an

ove:r-pressuriza tion of the reactor cool ant system and could

force a safety system to function.

Opening MOV-1867C, 2867C, MOV-1967D, and 2867D, during power

operation would allow concentrated boric acid to flow into the

piping systems that are not heat traced and a boron buildup

could crystallize and block system flow.

These ten valve operators are therefore cycled every rerueling

outage (approximately every 18 months).

SURRY provided the

following justification for extending the cycling periodicity:

These MOVs have met the stroke time requirement in the past.

Also, Limitorque had indicated in a telephone conversation,

(a record of which was in the file) that the requirement for

cycling the operators twice a year can be relaxed if operating

experience indicates they can be cycled less frequently.

Since

the MOVs listed above have been successfully cycled every

refueling outage, extending the cycle time is reasonable.

Tab E of QDR- S-3.2 was to be revised to reflect this.

The NRC

inspectors reviewed the Engineering Change Request (ECR) to

accomplish this revision which provided for cycling these valves

every

18 months.

Since deviation from

standard cycling

periodicity

was

justified

in

this

case,

incorporation

of the ECR will resolve the discrepancy in the documentation.

(6) It was not clear from review of Limitorque QDR's S-3.1 and 3.2

that the Marathon terminal blocks used in the associated MOVs

were covered by the QDR's although qualification reports were on

file that established qualification when these TB's are used in

L imitorque motor opera tors.

VEPCO committed to upgrade QDR' s

to clarify this.

Pending future NRC review, correction of

this item is identified as Open Item 50-280,281/86-12-10.

12

.

E.

Plant Physical Inspection

The NRC inspection team, physically inspected 25 qualified components

and selected field run cables inside and outside containment in SURRY

Unit 1 which was in a refueling outage at the time of the NRC EQ

inspection and outside containment in Unit 2 which had been operating

until it shut down for an unscheduled outage the second day of the

inspection on June 17. Unit 2's containment was not accessible to the

NRC team at the time for radiological reasons.

The :inspection team

examined-

characteristics

such

as

mounting

configurations,

orientation,

interfaces,

nameplate

data,

ambient

environment,

moisture seals, internal wiring and physical condition.

Results of

the walkdown inspection are discussed below:

(1)

Unit 2 LHSI Pump Motor A connection boxes for both motor leads

and heater leads were loose and not tight against the motor

frame, and the room HVAC vent duct cover was clogged and filled

with dirt.

SURRY generated work requests to correct these

problems.

(2)

The field control cable to the Limitorque on valve MOV-FW-1510

was found to be Rockbes tos Pyrotro 1 I II ( 1969) and the power

cable was found to be Rockbestos Pyrotrol III (1970).

produced documentation that showed the cable to be purchased

under PO #246 and PO #1246 both issued to Cerro Wire and Cable

Co. (Rockbestos).

The cable to level transmitter LT-1474 could

not be identified in the field but documentation showed the

cable to be Continental Cable -Purchased under PO #285.

Both

Cerro (Rockbestos) and Continental cables were on the EQML.

(3)

The Raychem splices to level transmitter LT-1474 were examined

and appeared to be properly installed, but the Raychem splices

to solenoid valve TV-GW-1128 were bent 180° with zero bend

radius when they were compacted into the condulet.

The exces-

sive bending does not comply with the "as tested" configuration

of the splice nor with Raychem installation specifications which

give a minimum bend radius of five times the outside diameter of

the splice sleeve.

This specification was given in the Raychem

In-Line Splice Application Guide, Revision 1, issued 8/83.

The

previous edition of the Application Gufde, (included in the QDR)

did not specify any bending restrictions.

VEPCO's procedure for

Raychem installations had no bend radius restrictions nor was

there any information which prohibited installation over braided

material.

Both versions of the Raychem procedure clearly

require all braid material be removed from the seal area prior

to sleeving installation.

Procedural corrections are discussed

in paragraph 4.B above.

VEPCO's failure to maintain Raychem

sleeves in a qualified configuration is identified as Potential

Enforcement/Unresolved Item 50-280,281/86-12-05.

(4) There are eight Limitorque motorized operated valve actuators

(MOV) inside containment in Unit 1, including the four whose