ML19325F047
| ML19325F047 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/27/1989 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19325F046 | List: |
| References | |
| 50-348-89-23, 50-364-89-23, NUDOCS 8911130283 | |
| Download: ML19325F047 (9) | |
See also: IR 05000348/1989023
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NUCLEAR REGULATORY COMM!SSION
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REGION 11
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1;,1 MARIETTA STRE ET. N.W.
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AT LANTA, GEORGI A 30323
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- Report Nos.
- 50-348/82-23 and J64/89-23
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Licensee: Alabam. Power Company
600 North 18th Straet
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Birmingham, AL 35291-0400
Docket Nos.: 50-348 and 50-364
License Nos.:
NPF-2 Lnd
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Facility Name:
Farley 1 and 2
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Inspection Conducted: September 25-29, 1989
Inspector:-If
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M
/o/2.1// P
N. MerriwF her'
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Da'te SKgned
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Approved by. g b / !.
M,M
va/21/19
T. E. Con 1gn, chief
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Plant Systems Section
' Engineering' Branch
Division of Reactor Safety
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SUMMARY
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. ape:
This routine, announced inspection was conducted to review the licensee's
corrective actions in response to previous inspection findings involving
environmental qualification (EQ) of electrical equipment.
'Results:
The inspection concentrated on the corrective actions taken by the licensee to
resolve those EQ violations and Unresolved Items identified in NRC Inspection
Rept.rts 50-348, 364/87-25 and 87-30.
Although Alabama Power Company (t.PC0)
does not agree with the findings, the licensee took the necessary corrective
actions to resolve all NRC concerns.
Based on the results of this inspection the licensee is now considered to be in
full compliance on previous NRC EQ concerns. One exception, is the failure by
the licensee to replace the Raychem/ Chico A cable entrance seal on the
Victoreen High' Range Radiation Monitor which is a Regulatory Guide 1.97 item.
The inspector noted that substantial improvements have been made in Farley's EQ
Program (e.g., training, procedures, documentation and hardware). The level of
knowledge regarding EQ at the site has greatly improved.
One new unresolved
item was identified involving the qualification of the Victoreen High Range
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Radiation Monitor.
This problem may be generic to the nuclear industry. The
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8911130283 891031
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qualified configuratian of the detector consisted of the power and signal
cables installed in a sealed conduit arrangement. The detector at Farley uses
a "NAMC0/ Chico A" Seal at the detector junction box.
The problem with this
configuration is that APC0 has not adequately demonstrated to NRC satisfaction
that the "NANC0/ Chic A" Seal design is qualified. Additionally Victoreen tried
testing similar type seal designs with numerous failures because moisture
passed thru the seal via the cable jacket.
it a,npears that this seal design is
also subject to the same failure mode of loss of cable jscket integrity. The
licensee understands the concern and indicated that it is on their schedule to be
reworked.
However, there is not an acceptable fix available, other than to
seal the cable back to the penetration.
The longest run of cable from the
penetration is approximately 240 feet. The licensee indicated that they intend
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to replace the seal with a qualified seal design. This issue remains open and
is discussed in Paragraph 2.1.
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
- R. Berryh111. Systems Performance and Planning Manager
- S. Fullmer, Supervisor Safety Audit and Engineering Review
- R. Hill, Assistant General Manager -Operations
- D. Morey, General Manager-Nuclear Plant
- C. Nesbitt, Technical Manager
- J. Richardson, QC Engineer
- R. Stewart, Nuclear Engineering Licensing Representative
- W. Ware, QC Engineer
Other licensee employees contacted during this inspection included
craftsmen, engineers, security force members, technicians, and administro-
tive personnel.
Other Organizations
- E. Reeves. Senior Project Manager, NRR
NRC Resident Inspectors
G. Maxwell. Senior Resident Inspector
- W. H. Miller, Resident Inspector
- Attended exit interview
2.
Action on Previous Inspection Findings (92701) (92702)
a.
(Closed ) Unresolved Item 50-343, 364/87-25-03, Inadequate Peer
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Inspection Program
During the subject inspection it was identified that Peer inspactions
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of electrical splice configurations in general had been ineffective
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allowing unqualified
"V" type tape splices to be installed and
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accepted in EQ applications.
The unqualified tape splices have been
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replaced with Raycham heat shrink splices. To prevent recurrence the
licensee has developed detailed installation and inspection
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procedures for Raychem kit.c and ir line splice materia'Is. To verif/
the adequacy and effectiveness of QC inspections Farley's Administra-
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tive Procedure FNP-0-AP-3?
't the QC Engineer observe
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inspections are performed,
selected independent insr.
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.th procedures.
In 1988, at
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evaluated and documented tr
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least four obserm ions n ^.
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to witness independent
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inspections of Raychem splices.
On a sampling basis these observa-
tions confirmed that activities were being performed in accordance-
with procedures.
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b.
(Closed)
Violations 50-348, 364/07-30-01, Use of Unqualified
Commercially Procured Equipment in EQ Applications
The NRC identified a violation for failure to establish measures to
assure that applicable regulatory requirements and design bases were
preserved during the procurement and use of QA review Code "C" and
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Code "D" non-safety related items in EQ applications.
The licensee
respondeo to the violation in a letter to the NRC dated May 5,1988.
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In this letter APC0 describes the corrective action taken to resolve
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the concerns.
The licensee revised Administrative Procedure
FNP-0-AP-21 to require an engineerir.g review of QA Review Code "C" or
"D" non-safety related items prior to installation in safety-related
applications.
The licensee revised procedure ' FNP-0-AP-9 to
incorporate a parts dedication program for procurement'and dedication
of commercial grade items for use in safety-related applications. EQ
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- Program procedure FNP-0-ETP-4108 requires that Commercial grade parts
and materials . serving a safety-related function in EQ components be
purchased and dedicated for safety-related use per procedure
FNP-0-AP-9.
Based on the above actions taken by the licensee this
item is considered closed.
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c.
(Closed) Violation 50-348, 364/87-30-02, Failure to Procure
ReplacementEquipmentinConformancewith10CFR50.40(L).
The violation occurred because APC0 did not include the upgrading
requirements of 10 CFR 50.49 (L) for replacement equipment into their
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EQ program.
This was identified as another example of a previous
violation cited in inspection reports 50-348,364/87-11 and 87-14.
The licensee responded to the violation in a letter dated May 5,
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1988.
The action taken by the licensee was to review all EQ
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components replaced since February 1983.
All items were determined
to be either qualified to 10 CFR 50.49 or " sound reasons to the
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contrary "were docunented as recommended by Regulatory Guide 1.89.
The licensee performed a review of store-roor. inventories and removed
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from the EQ inventory those components that were not qualified to
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The licensee has also revised EQ program implementa-
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tion procedures to require replacement equipment to be upgraded to
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10 CFR 50.49 or " Sound reasons to the contrary" must be documented on
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a component by component basis to justify not replacing the component
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with a component qualified in accordance with 10 CFR 50.49.
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licensee is now considered to be in full compliance.
This item is
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considered closed.
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d.
(Closed) Violation 50-348, 364/87-30-03, Failure to Take Frompt and
Timely Corrective Action For EQ Programmatic Deficiency Identified By
SAER In 1983.
Action Reports (CARS) pection the inspector examined two Corrective
During the subject ins
identified as 830 and 1251 that described
significant conditions adverse to quality.
Corrective Action Report
(CAR) 830 identified a deficiency involving failure of. the design
change program to identify sendor technical manuals and vendor
drawings as requiring update prior to implementation of a plant
modification.
The second CAR 1251 describes a deficiency found in
November 1986, where the preventive maintenance of EQ motor operated
valves was found to be inadequate due to a lack of detail in
procedure FNP-0-MP-28,137 and personnel error. A violation was cited
'because the licensee failed to correct these CARS in a reasonable
time period. The licensee denied the alleged violation in a response
dated November 14, 1988.
The evaluation of this response will be
addressed by NRC later.
The inspector verified that corrective
action for both CARS have been completed.
The licensee has updated
vendor drawings and vendor technical manuals for EQ equipment.
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design organizations responsible for design control drawings have
revised their procedures to provide for updating of vendor documents
and vendor manuals.
The preventive maintenance procedure for motor
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operated valves FNP-0-MP-28.137 has been revised.
The licensee was
in full compliance on the above items on March 31, 1988.' Based on
the above this item is considered closed.
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e.
(Closed) Unresolved Item 50-348, 364/87-30-05, Thermal and Radiation
Effects hot Evaluated for Lead Wire Insulation, Terminal Blocks and
Resistors for the Gems Level Transmitter
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During the review of the GEMS icvel transmitter qualification file,
Model XM-36495, it was noted that thermal and radiation aging effects
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were not evaluated for all susceptible materials. Specifically, the
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1ead wires, termiral block and resistors were not evaluated.
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file stated that it was not necessary to evaluate the effects for
these materials since the materials were immersed in silicone oil
which would protect them from age related affects.
The walkdown of
the wide range sump level transmitters in Unit 2 revealed that there
was no silcone oil in the junction box as required.
The assumption
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that the materials won't experience these affects was considered
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invalid based on the walkdown inspection.
This item is essenn ally
part of the violation discussed in paragraph 2.f. below and the
licensee has replaced the wide range Unit 2 transmitters. This item
is now considered closed.
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(Closed) Violation 50-348,364/87-30-06, The Licensee Found Wide Range
and Harrow Range Containment Sump Level Transmitters on Both Units in
a Configuration Thut Was Not Considered Qualified By Existing Test
Data.
This item is also discussed in the paragraph above. A violation was
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cited because the GEMS level transmitters were not found in the
tested configuration with the instrument junction boxes filled with
silicone fluid and the Unit I narrow range transmitter had
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unqualified V-type tape splices.
The licensee's response to the
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violation is still being evaluated by NRC.
As stated earlier, the
Unit 2 wide range transmitters were replaced and the Unit I narrow
range transmitter splices were removed and replaced with Raychem.
All transmitters.were refilled with silicone oil.
The inspector
examined the approved work requests that replaced the splices on the
Unit i narrow range transmitters, replaced the Unit 2 wide range
transmitters and refilled all junction boxes with silicone fluid.
This item is now considered closed.
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Limitorgue Motor Operator V4olations:
(Closed) 50-348, 364/87-30-07, Limitorgue Motor Operated Valves
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(M0Vs) Inside Containmant Without Functional T-drains Installed.
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(Closed) 50-346, 364/87-30-08, Unqualified Lin.it Switch Installed In
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A L:mitorque Valve Inside Unit 1 Containment
(Closed) 50-348, 364/87-30-09, EQ File Did Not Include Qualification
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For Terminal Blocks Used In Motor Operated Valves In That Various
Terminal Blocks Were Identified During Walkdowns.
All of the above violations relate to deficiencies identified between
the tested and the installed configuration of limitorque motor
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operated valves. The corrective action taken by the licensee on each
concern was reviewed and found acceptable.
The licensee installed
T-drains on. EQ Limitorque MOVs having provision for such drair.s
inside containment.
Five operators in Unit 1 and three operators in
Unit 2 did not have T-drsins installed.
For those operators without
T-drains installed an acceptable analysis exists to justify the
deviations from the tested configuration.
The Unqualified limit
switch on valve M0V 3441D was replaced with a qualified limit switch
on November 24, 1987.
The licensee discovered nine f:0Vs with
unqualified terminal blocks.
The terminal blocks have since been
replaced with qualified splices.
The licensee has inspected all the
EQ limitorque motor operated valves and documented the as-built
configurations on Drawings (DWG) D-204900 and D-181900 " Installation
Details for Environmentally Qualified Limitorque MOVs".
Considering
the above, the violations are now considered closed.
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h.
(Closed) Violation 50-348, 364/87-30-11, I.icensee EQ Files Did Not
Support Qualification. For Use Of Statec And General Electric Terminal
Blocks In Instrumentation Circuits.
During the subject inspection the licensee took the position that
States terminal blocks were qualified for use inside containment at
Farley based on similarity to Connectron N553 terminal blocks.
The
NkC inspectors did not agree that the similarity analysis was
sufficient in that the quoted irs were totally unrealistic.
In
addition. APCO provided the inspection team a copy of a GE test
report dated November 27, 1983 which further indicated that the
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insulation resistance (IR) values demonstrated by States and GE
terminal blocks during design basis testing were not acceptable for
use in instrumentation circuits. However, to resolve this issue, the
licensee replaced the terminal blocks with qualified Raychem splices.
The licensee stated in their response to the viniation dated
November 14, 1988 that the terminal blocks were replaced on both
units by December 17, 1987.
The inspector toured Unit 1 containment
and selectively examined splices in 3 containment penetrations. Toe
Cable numbers were recorded and later verified by review o. EQ
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drawings to be EQ circuits. This item is now considered closed.
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(Closed) Unresolved Item 50-348, 364/87-30-12, Certain Solenoid
Velves (SOVs) May Not Be Qualified Due To A Lack Of Cable Entrance
Seals.
In a letter to the NRC dated October 17, 1988, APC0 committed to
en certain Automatic Switch Comp 6ny (ASCO) qualified to 10 CFR 50.4
install Conax ECSA cable entrance seals,
valves located both inside
containment and the main steam valve room in each unit. This work is
being accomplished to resolve an EQ concern regarding moisture
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intrusion on long term ASCO S0Vs.
The work on Unit 1 is now in
progress and should be con:pleted during the current Unit I refueling
outage.
The work on Unit 2 was completed during the last refueling
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outage. This item is now considered closed,
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(Closed) Unresolved Item 50-348, 364/87-30-13, Automatic Switch
Company Solenoid Valves Installed In Unit 1 Containment Exceeded
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Their qualified Life
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The licensee reanalyzed the aging calculations using Arrhenius
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methodology and taking cred?t for additional aging effects resulting
from self heating and aging during the WCA test and assuming an
average containment temperature of 97.96 t.
The calculations used
what is considered to be a conservative 104*F.
The method of using
the average temperature is not considered acceptable. However, this
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point is moot because the valves are beginning refurbished based on
the design qualified life temperature of 120 F or on actual
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temperature measurements.
The licensee is currently monitoring
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temperatures inside containment to substantiate the assumptions made
in ' the design.
Data shows that some areas of the containment may
exceed 130*F.
This item will be pursued by the licensee as part of
their ongoing EQ program. This item is closed,
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(flosed)
Violation
50-348,364/87-30-14
Qualification
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Demonstrated for Raychem Seal Installed on Target Rock Sdenoid Yalve
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Cable Entrance
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The corrective action taken by the licene.ee was to issue and
implement Production Change Requests (i.e., PCRs 86-1-3873 and
87-2-4108) that replaced the cable entrance seals on the Target Rock
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SOVs with qualified Conax Seal assemblies.
The work was performed
and documented by approved maintenance work requests.
This item is
now considered closed.
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(Closed) Violation 50-348, 364/87-30-15
Raychem/ Chico A Seal
Qualification Not Demonstrated Because Bonding of Raychem Material
Has Not Been Addressed.
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The licensee has taken corrective action to replace all Raychem/ Chico
A ' Seals on NAMCO Q-180 limit switches inside Units 1 and 2
containment and the Main Steam Valve Room (MSR) cn Units 1 and E.
The licensee hss also committed to have NAMC0 EC-210 Connectors
invalled on certain Unit 1 MSR NAMCO limit switches identified in
their October 17, 1988 letter to the NRC, . As stated earlier the
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licensee still maintains that the Raychem/Chio A seal is qualified.
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Thus, the licensee had these seals installed on the Victoreen High
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Range Radiation Monitors. These seals have not been replaced and arc
not considered qualified since' moisture could possibly enter the
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detector via the cable jacket if loss of cable jacket integrity
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occurs.
This was experienced during qualification testing of tne
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Victween detector.
This lead to the cable being installed in a
seahd conduit arrangement.
The licensee acknowledged the concern
and agreed that 'he seal would bc replaced when sa acceptable desigi;
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change is available and will be implemented during a future refueling
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outage on each unit.
The previous open item will be closed and this
item will be tracked and identified as Unresolved Item 50-348,
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364/89-23 01, Unqualified Raychem/ Chico A Seal On Victorcen High
Range Radiation Monitor.
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(Closed) Violation 50-348, 364/P M 0-16, Unqualified Splice on
Hydrogen Recombiners
lhe licensee replued the questionable 5-to-1 tape splices on all four
hydrogen recombiners with Raychem Splice Kits. The design change was
approved by PCRs 87-1-4553 and f..-2-4554 and implemented via approved
maintenance work requests.
This item is now considered cloi,ed.
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(closed) violation 50-348, 364/87-30-17,.Use of Unqualified Grease on
Motor Operated Valves
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The licensee has undertaken a program to replace the grease in all EO
Limitorque MOVs with Exxon hebula EPO grease.
The valves on Unit I
should be completed prior to startup from the current refueling
outoge.
The remaining valve operators on Unit 2 should be. completed
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by the end of the next refueling outage. Based on the above, this
item is considered closed,
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(Closed) Violation 50-348, 364/87-30-18, Unqualified Lutricants
Since the initial finding the licensee has' put together a
qualification file for lubricants used on EQ motors.
The greases
have been subsequently tested by the licensee to establish
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qualification to 10 CFR 50.49. This item is now considered closed.
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(Closed) Violation 50-343, 364/87-30-19, Use of Unqualified V-Type
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Electrical Tepe Splices on S0Vs, MOVs and Inside Containment Fans
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The corrective actions taken by the . licensee were replace the
questionable "V-type" electrical tape splices with Raychem heat
shrink and revise the EQ Master List to include ge <eral notes
regarding cable splices.
A check of all completed mainte.1ance work
requests compared to the latest EQ Mas'.er List confirmed that eli
"V-typ e " electrical splices have been repleced.
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recurrence the licensee has developed detailed insth11ation and
inspection procedures for use of Raychem heat shrink kits and in-line
splice materials.
This item is now considered closed.
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Exit interview
The inspection sccpe and results were summarized on Septeraber 29, 1989,
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with those persons indicated in paragraph 1.
The inspector described the
areas' inspected and discussed in detail the inspection results listed
below. Although reviewed during this inspection, proprietary information
is not contained in this report.
Dissenting comments were not received
from the licensee.
One new Utresolved Iten was identified as follows.
Unresolved Item 50-348, 364/89-23-01, Unqualified Raychem/ Chico A Seal on
Victoreen High Range Radiation Monitor, Paragraph 2.e.
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