ML19329E395

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Forwards IE Circular 78-08, Environ Qualification of Safety-Related Electrical Equipment at Nuclear Power Plants. Action Not Required
ML19329E395
Person / Time
Site: Midland
Issue date: 06/02/1978
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Howell S
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8006120715
Download: ML19329E395 (1)


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. CMTRAL FILE 3 JUN 02 '078 Docket No Docket No.'50-330 Consumers Power Company ATTN:

Mr. Stephen H. Howell Vice President 1945 West Parnall Road Jackson, MI 49201 Centlemen:

The enclosed IE Circular No. 78-08, is forwarded to you for infor-mation. If there are any questions related to your understanding of the suggested actions, please contact this office.

Sincerely, James G. Keppler Director

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Enclosures:

1.

IE Cinular No. 78-08 2.

List of II circulars J

Issued in 1978 cc w/enels:

6T,entral Files Director, NRR/DPM Director, NRR/ DOR PDR Local PDE NSIC TIC Ronald Callen, Michigan Public Service Cocnission Dr. Wayne E. North

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Myron M. Cherry, Chicago gy 80061e0

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NRC Form 318A (R2K) (5-76) NRCM 02040

  • L. S. GOVERNMENT PRINTING OFFICE: 1978-253-818

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III June 2, 1978 IE Circular No. 78-08 l

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ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT AT NUCLEAR POWER PLANTS The NRC staff initiated a series of actions to confirm the environmental qualification of electrical equipment required to perform a safety func-tion under postulated accident conditions. These actions are summarized in the Commission's April 13, 1978 order in response to a petition from the Union of Concerned Scientists. Information obtained from recent licensee equipment tests and evalsations have indicated potential problems in qualification of int alled equipment. As a result, the NRC expanded these actions to inciv e an environmental review of safety-related electrical equipment at se3 acted older plants.1 This review did not identify generic qualification deficiercies.

However, as a result of IE Bulletins and the aforementioned testing to confira qualification, specific deficiencies were identified. Poor installation practices.

l inadequate consideration of subcomponents and omission of certain i

environmental parameters in the design are examples of such deficiences.

In addition, the documentation of qualification was found to be inadequate in many cases and the initial response to some licensees indicated a lack of detailed knowledge of the quality of installed equipment.

1 The purpose of this Circular is to bring to your attention such deficiencias and to highlight the important lessons learned. In its i

April 13, 1978 Order, the Commission indicated that "In order to fulfill its regulatory obligations, NRC is dependent upon all of its licensees for accurate and timely information.

Since licensees are directly in control of plant design, construc-tion, operation and maintenance, they are the first line of defense to ensure the safety of the public. NRC's role is one primarily of review and audit of licensee activities, recognizing that limited resources preclude 100 percent inspection.

Furthermore, the Commission notes that some of the licensee's initial responses indicate a lack on their part of detailed know-

g. 0 ledge of the quality of installed plant equipment. Licensees t

gaust have this detailed understanding of their own plants in kgb order to meet their obligations for public safety by ensuring a 00

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. s IE Circular No. 78-08 June 2, 1978 sound basis for making assessments of plant safety. The NRC establishes general safety criteria, sets specific requirements for many aspects of reactor design and operation, and ensures compliance with these criteria and requirements by independent audit. While, in the Commission's view, these activities play a vital role in ensuring safe plant operation, they are not a substitute for licensee safety reviews. The licensees must be knowledgeable and vigilent and must take more initiative in ferreting out details of potential plant weaknesses."

As part of this obligation, you should examine installed safety-related electrical equipment, and ensure appropriate documentation of its qualification to function under postulated accident conditions. Specific guidance on the subject of environmental qualification can be found in IEEE 323-1971 and 1974, as augmented by Regulatory Guide 1.89.

Examples of specific deficiencies identified in information provided by licensees are as follows:

1.

Connectors: Responses to IE Bulletins 77-05 and 77-05A revealed t

in certain instances a lack of qualification data for environmental parameters and inadequate design of connectors for postulated accident conditions. 2

.2.

Penetrations: A failed penetration prompted issuance of IE Bulletin 77-06. Responses to this bulletin showed adequate documentation for j

the qualification of the penetration assembly was not readily available in some cases.2 In one instance, the electrical connections of the penetrations were not qualified in conjunction with the l

penetration assembly,3 which demonstrates a lack of consideration for qualification of interfacing components.

3.

Terminal blocks: Because of unprotected terminal blocks in penetration areas inside containment of Haddam Neck, Bulletin

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78-02 was issued. These unprotected blocks were replaced with blocks designed to function in the LOCA and main steam line break environments.4 Responses to the Bulletin revealed two other facilities, Yankee Rowe and Ginna, with such unprotected blocks.5,6 Other terminal blocks were found to be inadequately qualified due to poor design or installation practices, even though they were in enclosures.7,8,9 and 10

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s IE Circular No. 78-08 June 2, 1978 4.

Limit switches: While examining the documentation for the qualification of all safety-related equipment installed inside containment, a vendor identified limit switches mounted on other-wise qualified valves at certain facilities. Preliminary review by the staff of responses to IE Bulletin 78-04 indicates such switches are installed in similar applications at other facilities. Corrective action is presently in progress.

5.

Cable splices: Electrical cable splices associated with electrical penetration assemblies were determined to be unqualified by licensees during their search for qualification documentation.11 6.

Other potential problems for specific componaats currently under staff review include:

-radiation and temperature effects on electrical cables 10

-adequacy of qualification testing of components by separate effects versus sequential testing of environmental parameter 10

-temperature limitations on nylon components cf dolenoid valves 12

-qualification.of electrical transmitters 13, 14 The review of these issues may result in the need for other fo11ovup or corrective actions.

No written response to this Circular itself is required. Each licenses should determine the applicability of the qualification items identified above for its f acility. Appropriate corrective action should be taken for any problem identified by the licensee as a result of its review.

NRC inspectors will review these matters with licensees in future inspections.

If further information is required, contact the Director of the appropriate Regional Office.

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3 IE Circular No. 78-08 June 2, 1978 LISTING OF IE CIRCULARS ISSUED IN 1978 Circular Subject Date Issued To No.

of Issua 78-01 Loss of Well Logging 4/5/78 All Holders of Source Well Logging Source Licenses 78-02 Proper Lubricating 011 4/20/78 All Holders of for Terry Turbines Reactor OLs or cps 78-03 Packaging Greater Than 5/12/78 All Holders of Type A Quantities of Reactor OLs, cps, Few Specific Activity Tual Cycle, Radioactive Material Priority I Material for Transport and Waste Disposal Licenses l

7844 Installation Errors that 5/15/78 All Holders of Could Prevent Closing of Reactor OLs or Fire Doors cps 78-05 Inadvertent Safety 5/23/78 All Holders of Injection During Reactor OLs or Cooldown cps 78-06 Potential Common Mode 5/25/78 All Holders of A

Flooding of ECCS Equip-Reactor OLs or ment Rooms at BWR cps Facilities 78-07 Damaged components 5/31/78 All Holders of On a Bergen-Paterson Reactor OLs or Series 25000 Hydraulic cps l

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.5 REFERENCES 1.

"Short Term Safety Assessment on the Environmental Qualifications of Safety-Related Electrical Equipment of SEP Operating Reactors,"

May 1978, enclosure to staff memorandum to Commission, dated May 12, 1978 and issued as NUREG Report 0458.

2.

"NRC Staff Report on Union of Concerned Scientists' Petition for Emergency and Remedial Action," December 15, 1977, enclosure to staff memorandum to Commission, dated December 15, 1977.

3.

Letter from Consumers Power Company to NRC dated April 6,1978, including, " Summary of Qualifications of Electrical Penetration Assembly Connectors for the Palisades Plant," Docket No. 50-255.

1 4.

NRC Sum =ary of January 29, 1978 meeting on " Environmental Qualifica-tien of Terminal Biccks and Replacement of Terminal Blocks, Hsddam Neck ?lant," Dockr.t No. 50-213, dated January 30, 1978.

5.

NRC Summary of Tebruary 1,1978 meeting, Yankee Rows Nuclear Power Station (terminal blocks), Docket No. 50-29, dated February 3,1978.

6.

NRC Summary of February 1,1978 meeting on " Environmental Qualifica-tion of Terminal Blocks and Replacement of Terminal Blocks," R. E.

Ginna Nuclear Plant, Docket No. 50-244 dated February 2,1978.

7.

Letter from Connecticut Yankee Atomic Power Company to NRC, dated March 29, 1978, including "Haddam Neck Plant Summary of Environ-mental Qualification Test Program, Terminal Block / Box Combinations,"

Docket No. 50-213.

8.

Letter from Consumers Power Company to NRC, dated April 12, 1978, including information on terminal blocks at Palisades, Docket No.

50-255.

9.

Letter from Indiana & Michigan Power Company to NRC, dated March 22, 1978 regarding terminal blocks at D. C. Cook Unit No. 2, Docket No.

50-316.

10. Letter from Indiana & Michigan Power Company to NRC, dated April 21, 1978, regarding terminations at D. C. Cook Unit Nos. I and 2, Docket Nos. 50-315 and 50-316.
11. Staff memorandum, " Status of Monticello Electrical Splice Upgrade "

dated May 10, 1978, Docket No. 50-263.

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12. Letter from Consumers Power Company to NRC, " Environmental Qualifica-tion for Big Rock Point," dated February 24, 1978, Docket No. 50-155.

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13. Letter from Consumers Power Company to NRC, " Environmental Qualifica-tion for Palisades," dated February 24, 1978 Docket No. 50-255.

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14. Letter from Westinghouse to E. G. Case, dated April 26, 1978, regarding environmental qualification status for D. C. Cook Unit 2. Docket No. 50-316.

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