ML20100R400
| ML20100R400 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/21/1992 |
| From: | NUCLEAR UTILITY GROUP ON EQUIPMENT QUALIFICATION |
| To: | |
| References | |
| CIVP-A-081, CIVP-A-81, NUDOCS 9204080341 | |
| Download: ML20100R400 (78) | |
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RELATED TO QUALIFICATION l ENVIRON MENTAL MOTORIZED " ' ' i OF LIMITOROUE VALVE OPER ATORS i b PRF. PARED BY: NIUCLEAR UTILITY GROUP ON f,20UIPMENT QUALIFICATION AUGUST 1989 i l
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O oos4947 t CLARIFICATION OF INFORMATION RELATED TO THE ENVIRONMENTAL QUALIFICATION OF LIMITOR00E MOTORIZED VALVE OPERATORS AUGUST 1989 PREPARED BY: NUCLEAR UTILITY GROUP ON EQUIPMENT QUALIFICATION lD ' (Preparedby/datbforNUGEQ)' [ /. APPROVED BY: LIMITORQUE COPRORATION hd &s A>No 95Y (Approvedby/date[forLimitorque)
TABLE OF CONTENTS 0064948 SECTION Illd f) fag Introduction..........................................i
- 1. Actuator Size.........................................!
- 2. Orientation ......................................... 2
- 3. Motor Size / Manufacturer.............................. 4
- 4. Motor Orientation /T Drains........................... 6
- 5. Motor Rotors......................................... 9
- 6. Motor Brakes........................................ 10
- 7. Motor Leads, Connections and Terminations........................................ 12 7a. Motor Leads......................................... 12 7b. Connections and Terminations........................ .
13
- 8. Motor Internal Overloads (Thermogards) . . . . . . . . . . . . . . 17
- 9. Motor Heaters....................................... 18
- 10. Lubricants.......................................... 20
- 11. Ge ar Box Rel i e f Va1 ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 ;
- 12. Se al s and Ga s ket s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4
- 13. Handwhee1s.......................................... 26
- 14. Local Position Indicator (LPI) . . . . . . . . . . . . . . . . . . . . . . 27
- 15. Limit Switch Compartment Orientation................ 28
- 16. Limit Switch Compartment Cover Materials............ 30 S
TABLEOFCONTENTS(continesd) 0064949 SECTION llILE PJGE (O,/ 17. Limit Switch Compartment Drains / Seals / Conduit Connections........................... 3*
- 18. Terminal Blocks (Power and Control) . . . . . . . . . . . . . . . . 35
- 19. Wiring Connections.................................. 39
- 20. Actuator Wiring...............'...................... 41
- 21. Limi t Swi tch Materi al s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
- 22. Torque Switch Materials............................. 46
- 23. Limit Switch Compartment Heaters.................... 48
- 24. Remote Position Indicators Sildewire Potentiometers............................ 50
- 25. Miscellaneous Control Components.................... 51
- 26. Submergence......................................... 52
- 27. Replacement Parts................................... 53
- 28. Recommended Periodic Maintenance
( and Re pl a c eme n t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 5
- 29. Aging Analysis...................................... 57
- 30. Motor and Control Circuit Voltage Ratings. . . . . . . . . . . 58
- 31. Motor Voltage ,and Actuator Thrust................... 59 APPENDIX A LIMITOROVE TEST CONFIGURATION DATA
SUMMARY
.......................................A-la APPENDIX B NUGEQ Letters Requesting Limitorque Review........B-1 APPENDIX C Limitorque letters Confirming Review. . . . . . . . . . . . . .C-1 TABLE I............................................ 111 TABLE 11.................................... ....... 38 FIGURE 1............................................ 34 m
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I, 0061950 Introduction Limitorque motorized valve actuators are used extensively throughout the nuclear industry in applications requiring environmental qualification to 10 CFR 50.49. Clarification of the limitorque's test experience was sought by the Nuclear Utility Group on Equipment Qualification (NUGEQ) in light of recent industry attention to the environmental qualification of Limitorque actuator control wiring, the various actuator configurations which can exist, and the spectrum of generic onvironmental qualific,ation tests performed by Limitorque. Theattached'informationwasdivelopedbytheNUGEQ,basedonmeetings and discussions held with limitorque during 1986 and 1988 together with information contained in a series of limitorque reports. The topics which have been addressed were suggested by NUGEQ. members as items for discussion. Their inclusion in this report does not imply , that they are issues which are of major importance fn' the-environmental qualification of Limitorque actuators. lhe objective O was rather to provide a set of consistent clarifications for each of these topics. Finally, the Group notes that Limitorque's test reports and experience provide only one of a variety of input data-sources used by licensees to environmentally qualify valve actuators to the requirements of 10 CFR 50.49. A broad spectrum of case-by-case considerations and additional information are used by utilities to formulate their final analysis of environmental qualification. The information contained in this report should not be viewed as restricting the use of these Limitorque reports or limiting the case-by-case considerations which are necessary to adequately address equipment qualification.
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0064951 O The 1989 revision of this report addresses new information,
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clarifications, and additional topics not contained in the original 1986 version of the report. Appendicies B & C contain the 1986 correspondance confirmir,g the accuracy of the original report information. The accuracy of the 1989 revision is confirmed by NUGEQ and Limitorque signatures contained on the title page. The attached table identifies the 1.imitorque qualification test reports which form the basis for the NUGEQ discussions with Limitorque. Relevant data associated with each of these Limitorque reports is provided, where appropriate, in each section of this report. During a review of these sections, please note that Reports B0003 and F C3271 may be generically referenced as the "out of-containment" test reports. The NUGEQ recognizes that a number of
. other Limitorque actuator tests have been performed by others or by Limitorque under proprietary agreements. Information associated with these additional reports has not been incorporated into this document, but should be referenced where appropriate to extend or modify this report's information.
i The NUGEQ recognizes that all actuators are essentially equivalent, with differences limited to cover material changes, electrical component differences (including motors, terminal blocks, torque switch and limit switch materials), and the use of motor T-drains and actuator grease relief valves. It is, therefore, possible for utilities to modify, extend or upgrade an actuator's qualification through the selective combination of applicable reports or through the use of alternate replacement parts. ii
0064952 O '*att t (1) Project 600198 Report F C2232 01 January 2, 1969 Test of limitorque Valve Operator To Heat General Requirements Of An Electric Valve Actuator In Nuclear Reactor Containment Environment (including Addendum #1, April 29, 1969) (2) Project 600376A Report F C3441 May 13, 1976 Nuclear Power Station Qualification Type Test Report Limitorque Actuators For BWR-ServiceV (3) Project 600456 Report 600456 December 9, 1975 Nuclear Power Station Qualification Type Test Report Limitorque Actuators-For PWR ServiceV (4). Project 600426 Report B0009 April 30, 1976 Qualification Type Test Report limitorque D.C. Valve Actuators For Nuclear Power Station Service Conditionsl/ 1/These reports are also provided as appendices to Limitorque Report
-B0058, limitoroue Valve Actuator Qualification For Nuclear Power Station Service, January-11, 1980, iii 4
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0064953 (5) Project 600461 Report B0003 June 2, 1976 Qualification Type Test Report Limitorque Valve Actuators For Class IE Service Outside Primary Containment In Nuclear Power Station Servicel/ (6) Project 360160 Report F C3271 February 1972 Qualification Test Of A Limitorque Valve Actuator In A Steam Environment (7) Project 600508 Report B0027 August 31, 1978 Limitorque Valve Actuator Temperature Related To High Superheat Ambient Temperatures 1/ (8) Project Report 80212 April 10, 1985 Nuclear Power Station Qualification Type Test Report limitorque Valve Actuators with Type LR Motor for Westinghouse PWR (9) Project 681041 Report B0119, Rev. -1 -November 10, 1982 Qualification Type Test Report of Multi-Point Terminal Strips For Use In Limitorque Valve Actuators For PWR Service 1/ These reports are also provided as appendices to Limitorque Report B0058, Limitoraue Valve Actuator aualification For Nuclear Power Station Service, January 11, 1980. iv O- . a f
LIMITORQUE 0064954 O 1. Actuator Size Limitorque philosophy is that a full range of actuators are qualified by the mid size actuators (SMB 0) which have been used in all EQ testing. This range includes the full spectrum of SMB and SB units. In Section 2.1 of Report 80058, limitorque states:
"The qualifications were conducted to encompass the entire family of Limitorque actuators SMB, SB, SBD, and SMB/HBC in all available unit sizes (SMB 000 thru SMB-5). This was accomplished by_ conducting the qualification testing on a mid-size unit (SMB-0) subjecting the actuator to simulated seating loads equivalent to the actuators published unit rating during the , test procedure."
Additionally, Section 4.5 of Report B0058 stater "The SMC 04 actuator, although of different housing material,'would be qualified for outside containment service by-the SMB outside containment qualification Report B0003." Actuator Size Data: , (1) 600198: SMB 0-15 (2) 600376A: SMB 0 25 -- (3) 600456: SMB 0-40 (4) B0009: SMB 0 25 (5) B0003: SMB-0-25 (6) F-C3271: SMB-0 10
-(7) B002'/: SMB 00-15 (8) B0212- SMB 00-15 (9) B0119: N/A (used as a fixture only) e i
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NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 2
- 2. Orientation: ,
All actuators tested by Limitorque were oriented with the limit switch compartment vertically up, the motor horizontal, and actuator stem horizontal. Based on experience, historical data, and screening tests, this position was selected by Limitorque to represent the worst case position. The basis for this selection was to expose the motor (as the lowest electrical component) to the highest levels of moisture collection and steam intrusion. In Section 4.1.3 of Report B0058 Limitorque states:
"The mounting position of the actuator was chosen with the limit switch compartment up and the motor horizontal. This is considered the worst possible position because it allows any condensate that collects in the unit to flow through the motor to provide the most damaging effect on its insulation system." 1/
Limitorque, based on its testing and analysis, considers actuators - qualified for all orientations. Although considered environmentally O auaiifiee, instaiiatiens wit 8 the motor or iimit switch cemoartment aligned vertically down should be minimized. In these orientations, unanticipated failure of the limit switch, torque switch,-and motor shaft seals during normal or accident conditions could permit grease to accumulate in or on electrical components. However. Limitorque has not experienced actuator failures during qualification tests resulting. from grease / oil on electrical components. When the motor or limit-switch compartment are oriented vertically downward,- the potential exists for minor seepage of-grease / oil past these seals, particularly when the units are not operated. 1/ RH type DC motor wireways are potted-thus preventing. condensate-from draining from the limit switch compartment into the motor. tonsequently, DC motors are not subject to the same potential for moisture drainage through the motor. , .c - ,..-_.,.,-..,.,w.,,-e,.,w.. . - - , . , - ,,em-, - ---m,+,-n. ,-wa.~, +,, ,ew c,- + - . ,v - . . .. ,-v. + , - , - . . . ,..a,n,-
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 0/89 PAGE 3 00G4956 Increased normal operational surveillance with examination for grease !' O e,aratten or see,aes 8a, eeee identified as ene et8 d < aeeaunteix address this potential occurrence when actuators are installed in this i configuration, , 1 i i t O l
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y l. NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 4 0064957
- 3. Motor Size / Manufacturer:
O i il teats, with the excePsicn f these inveivin9 Ci ss B ^C meters. the limitorque tested motor was the same manufacturer / design using identical or approved alternate materials as those supplied w'ith the i units certified to the applicable test report. However, other types i of motors may have been supplied for actuators not originally l certified to a particular qualification report. For these units, motor qualification may be established by determining that the motors are identical or similar in construction and materials to those tested 4 in the various Limitorque tests. For the Class B units tested in B0003 and F-C3271, the purpose of _ the test was to demonstrate the inherent capability which exists ia generic commercial grade UL standard Class B systems to function during the tested conditions. During the 80003 test three motors of different manufacturers were tested. Limitorque considers that these tests demonstrate the inherent capsbility of other Class B systems . they have supplied to perform under similar conditions. Peerless O Class B AC motors were not tested. However, limitorque has supported a similarity analysis originally developed by others for the LILCO Shoreham unit to qualify by similarity these units. The similarity analysis was reviewed by the NRC during a Limitorque vendor inspection. The applicability of the analysis .to a particular Class B motor should be established on a case by case basis. Limitorque noted that Peerless Class B AC motors have not been supplied since approximately 1973 2/ 2/Although not formally incorporated into this summary, please note that a Peerless Class B AC motor with Dings brake was successfully tested in WCAP 7310-L, Appendix 0 (F C 2485 01)..
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i NUGEQ REPORT ON LlHITORQUE EQ CLARIFICATIONS - 8/89 PAGE 5 0064958 Motor Datat (1) 600198: Reliance Rad H (nameplate "H"), (connected to , unit), dual voltage, AC 2/ Relianca Rad H (nameplate "H") with Dings brake (operated in chamber), dual voltage, AC (2) 600376A: Reliance RH, 1800 rpm, dual voltage AC (3)600456: Reliance RH, 1800 rpm, single voltage, AC (4) B0009: Peerless RH (nameplate "H"). DC (5) B0003: Reliance B (connected to actuator), dual voltage, AC Electric Apparatus B (operated in chamber), AC Paramount B (operated in chamber), AC (6) F-C3271: Reliance B with Reliance brake, dual voltage, AC (7) B0027: Reliance RH, AC (8) B0212: Reliance LR, single voltage, AC (9) B0119: N/A . O 2/Limitorque no longer supplies Reliance Rad H motors certified to 600198. The replacement Reliance RH motors are supplied with certificrtion to 600376A,600456,(or600198 ifrequested). The brakes in RH replacement motors will ILg1 be certified to these reports (See discussion of motor brakes).
, 4
NUGEQ REPORT ON ',IMITORQUE EQ CLARIFICATIONS - S/89 PAGE 6 4 ligipt Qrigntation/T-Drains 0064959 All tested ri.otors were horizontal, motor T-drains were utilized in certain ter,ts as tabulated below. The principal purpatas for us' of the T-vrains were, !) to provide drainage of internal actuator condensstion; and 2) to serve as the primary veh;.h for internal-to- , external actuator presscre equalization. Ti:e '.-drains were the principal p u hwsys for steam and rooisture intrusion into the
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i actuator, in ordeE to function as drainage pathways, the motor T-drains should be installed at the motor low point ports. Fcr motors ccvered by tss*s ut nizing two T-drains, their location ) should be as follows: (1) motor principal axis horizontal - one (1) T dra'n 6n eaco motor-end bell at the lowest available point. If the motor lead wireway to limit switch compartment occupies one of these positions (e.g., for a horizontally mounted motors with limit switch cupartment facin.g down) it will function as a motor drain. In this case the associated T-drain may be omitted or ) O aiaced at the next ava4,a81e peint te fac4iitate meter drainage. Since 'RH" type DC motor wireways are potted, drainage between tne motor and Limit Switch Compartment (LSC) does not occur. Con nquently, the motor T-drain cannot be eliminated by assumhig drainage into the limit switch compartment for these DC actuators. (2) motor principal axis vertical - two (2) T-drains on lowest motor-end bell . (Four plugged ports are typically provided in each end bell which can be used to locate the T-drains). O V
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NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 7 0064960 The motor T drains prevent submergence of the AC motor stator windings in accumulated cendensate. Consequently, miaor variations in the O location of the T drain, provided they are installed below the stator winding coils, are acceptable. A single T drain, due to internal drainage between the motor end balls, may prov'.de adequate drainage for AC motors if moisture accumulation in the motor is minimized. Examples of such situations may include lower paak accident temperatures and actuator configurations pre 41uding drainage of limit switch compartunt accumulated moisture into the motor (e.g., motor and switch compartment principal axes both horizontal). However, the use of tw: T drains in AC motors is preferred. For DC actuator mt. ors 'etteri with one motor T-drain, it should be placed at the lowest available m brli port. Multiple ports are not typically provided in these motors. Plugs should be installed in unused end bell ports. For actuator motors tested without T drains (Reitance Rad H and Class B motors), T drains are not required nor are they recommended by O 1.imitorque. Limitorque notes that all tested actuators were essentially equivalent with electrical. component differencer, limited to motors, terminal blocks, torque and limft switch materials. Termir.a1 blocka are i generically addressed in B0119. For all in-containment ts:ted 2ctuators the torque and limit switch materials are equivalent. It ie, therefore, possible when utilizing replacement RH motors 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 referenced motor report. Limitorque recommends that the installed motore be provided with T-drains to represent the referenced motor's tested configuration.
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NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 8 0064961 In locations which do not experience temperature and humidity g increases due to steam lino breaks (e.g., mild environments or radiation only harsh environments) the pressure equalization and drainage provided by the T-drains is not necessary. In these' cases, the absence of T-drains is readily justified. The omission of motor T-drains in other situations will not necessarily prevent proper actuator operation or violate environmental qualification. Examples of situations, based on utility-specific analysis, which may be considered acceptable on a case-by-case basis include: (1) Operability only required for a short duration immediately post-accident, or (2) Motor orientations which woult' preclude noisture 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 f-~ T drains. Since the RH and LR class insulating systems which vere 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. flotoe T Drain Data: (1) 600198: None j (2) 600376A: 2 j , (3) 600456: 2 (4)S0009: 1 (5) B0003: None (6) F C3271: None (7) B0027: 2 (8) B0212: 2 (9) B0119: 2 n () i
NUGEQ REPORT ON LIMITORQUE EQ CLARIFEATIONS - 8/89 PAGE 9
- 5. Motor Rotoru 0064962 Magnesium rotors only exist on certain Reliance AC motors. Both aluminum and magnesium rotor motors have been tested as tabulated below. Since magnesium rotor motors acceptably passed the 600456 and 80212 steam test conditions, limitorque has concluded that rotor materials do not affect the level of motor qualification.3/
Limitorque certifies the performance of magnesium rotor motors to all referenced tests. If requested, limito,rque will, for a fee, provide utilities with information on rotor materials for installed motors. Limitorque requires the motor ID number (serial number). Reliance may also be contacted to provide this information. As general guidance, magnesium rotors should exist on 180 FRAME size and larger AC motors, aluminum rotors should exist on 48 and 56 FRAME sizes. Limitorque is not completoly aware of details associated with the GE/Wyle testing which formed the basis for issuing IEN 86-02. Limitorque had previously initiated efforts, with utility funding, to develop replacement aluminum rotors for magnesium rotors. However, this effort has been terminated. Limitorque is presently evaluating additinnal information developed by the utility industry re: degradation of magnesium rotors during normal service. Maanesium Rotor Motor Data: (1) 600456: magnesium (2) B0212: aluminum (connected to actuator) magnesium (operated in chamber) (3) all others: aluminum 4/ A magnesium rotor motor as part of the B0212 test program was successfully tested to the transient portion of the same profile reported in the B0212 test report. The results are not published in. the B0212 test report, however, this information is on file 'and available for audit at limitorque. __o
l! NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATICNS - 8/89 PAGE 10
- 6. Motor Brakes: 0061963 Reliance motors with brakes were tested in 600198 (Dings brake) and F-C3271 (Reliance brake). In both tests, the units successfully functioned during the test conditions and are considered by Limitorque as qualified to these reports. It was noted that radiation was not ,
included as a test parameter and, based on the particular appilcation, 4 should be analyzed. Due to design improvements, Limitorque recomends replacing / modifying SMB actuators requiring motor brakes with the SB design. Full functionality of brakes in SMB units may not be achievable and limitorque recommends modifications or replacement with SB/SBD type unit 2. Limitorque noted that many units originally supplied with brakes can be satisfactorily configured to function without brakes using specialized settings and performance tests. Other units can be modified to use self-locking gear sets (stem or actuator) prec1'uding the need for motor brakes. Limi*orque will support such utility efforts if serial and shop order numbers and "as found data" are I provided. - Although actuator modifications, to the SB/SBD design, may be performed in the field, Limitorque recommends factory modification. Limitorque's factory will support refueling outage schedules. It was noted that replacement SB/SBD units are slightly heavier than the equivalent SMB unit. Limitorque stated that while it is possible to modify the actuator to render the brakes inoperative, it requires careful readjustments, introduces other potential problems, and is not recomended. Simple de-termination of the brake leads does not render the brakes 0 0
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 11 inoperative and in fact will make the brake drag. Limitorque 08Q/3 p64 a case by case basis cartify, as qualified, motors supplied with [} brakes but will specifically exclude qualification of the brake assembly from the certification. However, limitorque prefers'that such configurations are modified to preclude the use of motor brakes. Motor Brake Datat (1) 600198: ReliancewithDingsbrake(operctedinchamber) (2) F C3271: Reliance with Reliance brake (3) all others: no brakes (2:) O
NUGEQ REPORT ON LlHITORQUE EQ CLARIFICATIONS 8/89 PAGE 12
- 7. yotor leads. Connections 3nd Terminations:
0064965 7a. Motor leads To avoid motor lead abrasion Reliance RH motor leads are covered with a heat shrinkable polyolofin which was included in the tested configuration. Limitorque indicated that, depending on the Reliance facility fabricating e e motors, the heat shrinkable polyolofin may be installed inside or outside the braided lead sleeving. Limitorque stated that both sleeves wero used to provide physical protection. F Limitorque has reanalyzed all previous changes to their "RH" AC & DC motor specifications and has determined that these material and design changes, including motor lead materials, do not affect the motor's qualification basis. Similar reviews were not deemed necessary for Rad H and Class B motors. In response to questions regarding the qualification of various generations of DC motor leads, limitorque has completed an evaluation of a proprietary test report which su.bjected the Nomex and Kapton (2nd generation) and Nomex and impregnated fiberglass (3rd generation) leads to the test levels of B0009 excluding seismic testing. The test also included an undamaged 2nd generation lead with a 3M Insultite Witon) sleeve used to provide physical protection. To insure that the 2nd generation lead wire is not damaged-(i.e., cracked) during routine maintenance, Limitorque recommends the individual wires be sleeved with the "Insultite" sleeving or other qualified sleeves. The. proprietary report is available for review at Limitorque. 1/ Limitorque noted that reolacement motors are supplied with a single plastic sleeve over the motor leads to protnct them during shipping and installation. These sleeves are designed to be removed during installation.
7 l NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 13 0004966 7b. Connections and Terminatie n All actuator motors, with the exception of the B0212 test motor, had their power leads terminated with crimp-type lugs to the power terminal blocks loc!.ted within the limit switch compartment. A Raychem splice kit splice was used in the B0212 tests tv demonstrate the acceptability of this termination method. Limitorque indicated that the Raychem splice was placed over the motor lead braid. A Harathon 300 terminal block electrically connected to a motor periodically operated outside the test chamber was also qualified in the B0212 test. Terminal blocks acceptably qualified as motor terminations are acceptable for.use at control circuit voltages. Alternate terminal blocks (other than those supplied by Limitorque) or splices, if suitably qualified by the user, may be used for power or control lead terminations. Limitorque noted that the first generation Peerless RH motor leads are g considered impregnated; the *econd generation non-impregnated; and the V third slightly impregnated. The Reliance RH motor leads are considered by Limitorque as impregnated. The Group notes that Commonwealth Edison test reports (Reports No. 17859-02P and 17859-028) previously distributed by the Group support using Raychem motor splices for both impregnated and non-impregnated leads. Since dual voltage motors were tested at the higher voltage rating (460 volts), splicing of certain 1 cads was necessary. Limitorque fabricated the motor test splices in accordance with its factory standards which utilize insulated T&B RB-4 and RC 6 blind barrel crimp splices in the same product families as the crimp-type lugs used for control and power circuit terminations. Unless otherwise requested in the applicable purchase documents, limitorque provides motor leads terminated per the referenced test , report. Limitorque indicated that motor terminations ut.ilizing* nuclear grade splices, qualified by others, are also considered an d acceptable termination method. (See Section 18. Terminal Blocks, and Section 19, wiring Connections, for further clarification). 4
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 14 0064967 O With respect to the dual voltage motor splices, Limitorque has conducted a number of tests of actuators with dual voltage motors (600198,F-C-3271,B0003,and600376A). Dual voltage motor connectors existed in all testing of a fully assembled actuator with a dual voltage motor. This would include tests sponsored by others, such as the actuator tests documented in Section 5 of WCAP 7410 l, if Limitorque configured the motor and actuater assembly. Given the vintage of the applicable Limitorque' tests and the relative insignificance of the dual voltage motor connectors, Limitorque did not develop extensive documentation on either tested or production configurations. However, Limitorque (based on a review of material purchase documents) has confirmed that only the T&B RB-4 and RC-6 lugs were ever purchased for this use in SMB actuators. The NRC has reviewed relevant Limitorque' information and does not disagreed with this conclusion. Based en a review of the photographs contained in the test reports and their recollection of the actual tests, Limitorque indicates that they did not take any special precautions with the connector configurations. Consequently, the tested configuration are reasonably representative of typical field installations. The T&B connectors were exposed to all test conditions that involved a fully configured actuator. For example, if a mctor was separately aged and irradiated, and then assembled into a.1 actuater for LOCA testing, the connector was likely exposed to only the LOCA test. Test report 600198 did not identify any actuator exposed to radiation or thermal aging conditions that was subsequently exposed to the LOCA steam environment test. The report does, however, contain two pictures which indicate that dual voltage motor connectors were exposed to the LOCA test conditions. Test report 600376A indicates O 4
- l
NUGEQ REPORT ON LIhlTORQUE EQ CLARIFICATIONS - 8/89 PAGE 15 0064 968 that the LOCA tested actuator motor (601962P) was thermally t.ged and exposed to 204 Megarads radiation orior to tssembly into the f") actuator. One can conclude that the connectors were only exposed to the BWR LOCA steam environment. The F-C3271 test was a outside v 0 containment 212 F steam test without aging or radiation. The B0003 test is an outside containment test, however, the fully assembled - actuator was subjected to all test con m ions, including thermal aging at 135"F,100% M, for 200 hours, radiation exposure to 20 Megarads, \ ' 0 and steam testing to 250 F maximum temperatures. In all these limitorque tests the motors performed adequately with no indications of T&B connector problems. Illinois Power has performed MOV testing which included T&B RB-4 and RC-6 connector specimens aged to the equivalent of 8 years at 1250F, 40 years at 125'F, and 8 years at 150"F. Althougn the 8 year 125 0F samples passed the test, the remaining sanples failed by shorting to } ground during the steam exposure. The failures appeared to result from arcing to ground due to cracks in the nylon insulation resulting from the thermal aging combined with tne high HELB inoisture conditions. The samples aged to 8 years at 125"F did not experience this cracking and successfully passed the test. The Illinois testing is discussed in Information Notice 88-81, FAILURE OF AMP WINDOW INDEhY KYNAR SPLICES AND THOMAS AND BETTS NYLON WIRE CAPS DURING ENVIRONMENTAL QUALIFICATION TESTING. The results of the Illinois Power testing are consister.t with the previous Limitorque tests, since Limitorque, except for the B0003 test, did not age or irradiate the T&B connectors during their qualification testing. During the B0003 test, the full actuator assembly was aged at 165 F for 200 hours (equivalent to approximately 121 days at 125 F cr 4.8 years at 90 F assuming a Nylon eV of 1.17). The successful performance of the connectors in both this and the e f% y
- NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89- PAGE 16 0064969 Illinois 8 year 125 F testing appears to indicate that when thermal aging causes cracking of the nylon insulation the potential- for
[) shorting exists. This cracking when combined with sufficient moisture at high temperatures can cause shorting of the connectors if-they are in intimate contact with either other connectors or a ground plane, This failure mechanism would not exist in a radiation only harsh environment. The Illinois test results combined with the B0003 testing suggest that acceptable thermal aging of the nylon lugs can be analytically extrapolated beyond the B0003 test conditions. However, this extrapolation should not extend beyond the aging of the successful Illinois test samples and may require periodic replacement due to the limited thermal aging capability of the nylon material,
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NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - ?/89 PAGE 17 0064970 O i. aeter 1 1 r , Ov r,e 8. <18 r ee re > Limitorque indicated that to the best of their knowledge-integral
-motor overloads have not:been supplied on-any nuclear grade motors cartified_to the various Limitorque test reports.__
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l NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 9/89 PAGE 18
- 9. Motor Heate s: 0064971 O
V The motor heaters are small flat discs which are attached within the motor-end bell with leads extending into the limit-switch compartment. Motor heaters were not included in any environmental or seismic testing conducted by Limitorqc. If requested in purchase documents, they have been provided in_ nuclear-qualified units but should not be considered as qualified by Limitorque. Limitorque recomends that the heaters only be energized during storage. Limitorque has not analyzed the effect that the heaters may have on environmental or seismic qualification, but offers the following perspectives: (1) If energized, the heaters could increase the motor ambient temperature. Limitorque indicated that their practice was to size the heaters for approximately a-1000 temperature rise, however, no Limitorque data exists on the. actual temperature rise experienced by the motor when the heaters are energized.5/ (2) Un-energized heaters should not affect environmental-qualification due to their location and materials of construction.- (3) Seismic qualification should not be affected by the presence of-the heaters due to their low mass and location. I s/ A review of B0058 suggests that for most applications an acceptable qualified life (40 years) with substantial margin should still be available for units with minor temperature increases above typical plant ambient conditions. See B0058, Section 3.2, Thermal Acina.
~
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS.- 8/89 PAGE 19.- The wiring of certain DC motor starter results in continuous. 0064972 ' energizing of the DC motor shunt windings. This practiceLwas. O evidently designed to permit the-shunt' winding to function .as a motor - heater. Limitorque has determined that continuous energizing.of this winding may cause premature motor failure resulting from thermal degradation of the winding innlation, Limitorque does not recommend the use of this practice. Limitorque also recommends the use of a. , discharge resistor or-varistor to absorb the energy when the shunt field circuit is opened quickly. O I i l . O m-- -, -e<- , , r..,. , m. r - ~ .2.., _.. .-....%. .,,.,,..,,-,-.,,...,,-.,..c. .-r.,.--4, , .m .
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 20
- 10. Lubricants: 0064973 Lubricants that can be used in the Limitorque actuators are identified in the appropriate instruction manual and Lubrication Data Form LC8.
The actual greases utilized during Limitorque testing are tabulated below. Other lubricants with the appropriate properties may be substituted for those tested or certified by Limitorque. The properties are identified in several Limitorque publications including LUBRICATION DATA FORM LC8 provided under Tab B of Report B0058. However, testing, analysis and qualification of these substitute lubricants should be established by the user. The motor bearing lubricant used on the tested Reliance units is Chevron SRI-2. The main gearboxes were originally tested and supplied for in-containment applications with Exxon Nebula EP1 grease. Nebula EPO is now supplied for in-containment applications, although Nebula EP1 can be mixed with or used in place of the EPO. Limitorque does not recommend mixing the Nebula EPO and EPl with any other type lubricant. This lubricant is light tan in color and appears to have a g) C smooth texture. Mixing of certain lubricants may be justified based on a compatibility analysis or tests. However, limitorque does not have information on such compatibility. For SMB-000, SMB-00 and SMB-5 actuators certified to the out-of-containment tests, the inain gear box can also be 5bricated with Sun Oil Company 50 EP (XC-421-39) instead of the Exxon Nebulas identified above. Limitorque originally supplied the Sun Oil for the out-of-containment certified SMB-00 and SMB-000 units with serial numbers below 295810. This lubricant shall not be mixed with the Exxon Nebulas and it is recommended that utilities use Exxon Nebula EPO for all SMB applications. Commencing with S/N 392194 all SMB-000, SMB-00 and SMB-5 units were supplied with Nebula EP-0. O
=
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 -PAGE 21 In support of accepting the Sun lubricant for SMB-5 applications 0064 974 Limitorque has subjected tne Sun Oil EP to 225 megarads and performed an independent analysis on the grease's-lubricity. The analysis indicated acceptable performance of the Sun Oil grease. The Sun Oil lubricant is black in color with a stringy texture. Limitorque has tested and supplied Beacon 325 and Mobil 28 greases for the limit switch gear housing and cartridge assembly. The Mobil 28 is reddish-brown'in color. The Beacon 325 is a light grey / beige. Limitorque noted that the Beacon and Mobil greases should not be mixed. Finally, Limitorque suggests that the. Mobil'28 be used in 0 application when normal operating temperatures are greater than 150 F. Lubricant Data (main aearbox/ limit switch cearbox and cartridae): (1) 600198: Humble Nebula EPl/ Beacon 325 I/ (2) 600376A: Exxon Nebula EP1/ Beacon 325 (3) 600456: , Exxon Nebula EPl/ Beacon 325 (4) B0009: Exxon Nebula EP1/ Beacon 325 (5) B0003: Exxon Nebula EP1/ Beacon 325
~
(6) F-C3271: Humble Nebula EP1/ Beacon 325 (7) B0027: N/A (8) B0212: Exxon Nebula EP0/ Mobil 28 (9) 80119: N/A Z/The original Humble Nebula is equivalent to Exxon Nebula since Humble was acquired by Exxon.
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.I NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 22 0064975
- 11. = Gear Box Relief Valves During early LOCA testing Limitorque experienced blowout of a handwheel or declutch shaft seal due to grease pressure build-up.
Consequently, gear Box relief valves were installed in all tested actuators with the exception of those tested in B0003 and F-C3271. The relief valve provides for relief of grease and the pressure build-up which occurs due to thermal expansi2n of grease'and air inside the actuator at prolonged elevated temperatures. Without the grease relief, due to the pressure build-up resulting from thermal expansion there is a possibility that grease could extrude into the motor or-limit-switch compartment. Althcugh the impact of such grease extrusion is not known, Limiturque recommends that the installed actuators be provided with grease reliefs to represent the referenced tested configuration. In locations which do not experience prolonged _ elevated external temperaturea sufficient te cause thermal expansion and pressurization 3 of the grease, the absence of a grease relief _can be justified. The omission of grease reliefs in other situations may also be justifiable. Examples of situations, based on utility-specific analysis, which may be considered acceptable on a case-by-case basis, include: (1) operability required for only a short-term post-accident; (2) required environmental temperature bounded by the maximum SMB operating temperature rating or the test temperatures contained in reports which did not utilize grease reliefs.3/ S/ The maximum published operating temperature for standard non-nuclear Limitorque SM8 actuators is 1800F. In marginal cases a thermal analysis could be performed to demonstrate that bulk actuator temperatures are bounded by this. rating or the temperatures contained 4 in reports (e.g., B0003, F-C3271) which did not utilize grease reliefs. O J . 3
PAGE 23. NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89. 0064975 The grease relief valtas are shipped with plastic. caps which should be-removed during installation.. However, failure to remove;the cap does not prevent the valve from performing its. function for several reasons. The caps are relatively loose and there is a significant margin between the less than 5 psig relief valve set-point pressure a.1d the pressure causing 0-ring failure or grease weepage. Furthermore, softening of the caps during high temperature conditions decreases the possibility of their interference with relief valve operation.9/ Gear Box Ralief Valve bata:
-(1) 6001911: Installed (2) 600376A: Installed (3) 60L U a ; Installed (4)3000$ Installed (5) BOUO3: Not Mstalled (6) F-C3271: Not Installed O ]f)B0027: Installed (8) B0212: -Installed (9) B0119: Installed 9/ The Group notes that in LOCA testini; perfont.ed by Duke Power (Test ~
Report TR-076) a cap was installed on the re1{0f vr've. Since the cap softened during the steam exposure and felliff the valve during the test, this test apparently demonstrates that- the plastic cap will not prevent proper operation of the grease relief.during accident conditions. O l
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l NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 24 0065977
- 12. Seals and Gaskets:
- Per Limitorque, the actuator seals and gaskets which function to exclude the external environment from entering the actuator components are not critical to qualification since the actuator does not depend on absolute sealing to survive DBE conditions.19/
In B0058 Section 3.2.3 Seals, Limitorque states:
"Limitorque actuators for Nuclear Plant application are designed to permit them to survive 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."
All inside-containment qualification testing was performed with Viton seals whereas Buna-N was used during outside containment testing. Viton was selected for in-containment applications due to additional
. material margins to failure. Viton seals can be used in all actuator d applications. The gaskets for all tested actuators were fabricated of Anchorite Part #425 by Anchor Packing Company. Klinger X-61 is also supplied as a gasket material. Limitorque indicated that both materials are bonded asbestos, are equivalent in form, fit, and function, and are made of identical materials to the same ASTM and MIL specifications. Limitorque noted that these gasket materials are permeable to gases, possibly including steam.
19/ Limitorque in their Critical Component Evaluation has classified the actuator gaskets and seals as non-critical except for the limit switch and torque switch 0-ring seals which are considered as critical to safety and qualification. O
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 25 006493 O limitorque suggests that the same type seals and gaskets used in the-referenced test configuration, be used during plant operations. However, limitorque, when requested,- will also supply Anchorite #443A, a non-asbestos gasket material.11/ Seals / Gaskets Data (Seal / Gasket): (1)600198: Viton/ Anchorite #425 (2) 600376A: Viton/ Anchorite #425 (3).600456: Viton/ Anchorite #425 (4) B0009: _Viton/Aachorite #425 (5) B0003: Buna-N/ Anchorite #425 , (6) F-C3271: Buna-N/ Anchorite #425 (7) B0027: N/A (8) B0212: Viton/ Anchorite #425 (9) B0119: N/A O 11/ Limitorque does not certify the non-critical Anchorite #443A as qualified but maintains that actuators remain qualified when this substitute material is used since the gaskets do not prevent moisture from entering the actuator, S v i w
9 e NUGEQ REPORT ON.LIMITORQUE EQ CLARIFICATIONS _- 8/89_ PAGE 26-
- 13. Handwheels: 'IS ?g The use,-location, and configuration of handwheels do not appear to have an effect on the units' environmental qualification _. Limitorque has been . unable- to develop- any handwheel.- failure mechanisms that'would preclude the actuator from performing its function. ~ Consequently, handweels are not an equipment-qualification concern.
j x O O
l .,.. NUGEQ REPORT ON'LIMITORQUE EQ CLARIFICATIONS - 8/89- PAGE-27
- 14. Local Position Indicator (LPI): 06 4980 Unless required by procurement documents, LRIs are not normally supplied on environmentally qualified-units.- However, an LPI was installed en actuators tested in 600198 and 600376A. Installation of the LPI does not affect the qualification of actuators certified to other test reports. The LPI is a gear-driven mechanical device which-is attached to the-limit switch compartment. It has no safety function, nor should its performance affect other actuator components. Limitorque notes that since actuators were qualified with moisture intrusion into the limit switch-compartment, physical integrity of-the LPI window is not critical to-actuator performance.
LPI DATA: (1) 600198: LPI (2) 600376A: LPI
~
(3) 600456: NO LPI (4) B0009: 'NO LPI (5) B0003: NO LPI (6) F-C3271: NO LPI (7) B0027: NO LPI (8) B0212: NO LPI ; (9) B0119: NO LPI O 1
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 28 88j
- 15. Limit Switch Comoartment Orientation:
As previously discussed, the orisntation of _ all tested actuators was with the limit Switch Compartment (LSC) vertical- at the top of the actuator. In this configuration, excess condensation drained from the limit switch compartment into the motor housing via the actuator's internal motor lead wireway.12/ Limitorque stated that this configuration qualifies the unit for all LSC orientations. See Section 17 for additional information on the tested configurations. Based on its testing experience, Limitorque indicated that in-configurations not promoting LSC drainage into the motor insufficient moisture will condense within the LSC.or within a motor draining into the LSC to affect operability of the unit. Small pools of water in the LSC will not affect performance. Condensate accumulation in the LSC would only potentially affect operability when terminal blocks, switches, uninsulated wiring, or other electrical devices became submerged. O Limitorque' indicated that when external sources of significant amounts of water may enter the LSC (e.g. . via drainage through long vertically oriented conduit runs) it may be-advantageous to provide LSC drains or minimize the potential for accumulation of water in the LSC. Alternatively conduit drip legs or connection seals could be used. In those cases where LSC drains are used, motor T-drains or suitable substitutes (i.e., designs preventing-spray and water entrance yet 12/ Note that all RH ~ type DC motor wireways are potted thus preventing condensate from draining from the limit switch compartment into the motor. O 1
-_ _ _ _ _ _ _ - _ _ ____A
L . NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS'- 8/89 PAGE 29-- 00<19g', ' li- with holes large enough to promote drainage) may be used without affecting.the qualification of the units. These drains may be ~ installed-on the existing LSC low point conduit connections or by drilling and taping:a hole in the LSC cover below the level of the l active electrical devices, i 1 1 I i a O
M NUGEQ REPORT ON LIMITORQUE EQ' CLARIFICATIONS - 8/89 PAGE 30
- 16. . Limit Switch Comoartment Cover Materials: 006 9 Boththealeminumandcast-ironLimitSwitchCompartment(LSC) cove [s83
- supplied by Limitorque have'been tested. Since-Limitorque has not
- tested aluminum covers' for PWR chemical spray conditions, it 'is i recommended that the actuators for PWRiin-containment applications-.use
- cast iron covers.13/
i LSC Cover Data:
-(1) 600198: . NO DATA (2) 600376A: CAST IRON (3) 600456: CAST IRON' (4) B0009: CAST IRON ; (5) B0003: ALUMINUM
- (6) F-C3271
- ALUMINUM (7) B0027: CAST IRON
, (8)B0212: CAST IRON (9).B0119: . CAST IRON l 13/ The NUGEQ notes that the concern with aluminum in this application
-is the effect of the long-term caustic spray on the cover material's integrity. If adequately analyzed by utilities for external corrosive effects, aluminum covers may be acceptable for PWR in-containment applications.
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i 4 PAGE 31 NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 00
- 17. Limit Switch Comoartment Orains/ Seals / Conduit Connections: 4984 Far tests utilizing motor T-drains, Limitorque indicated-that the external test environment entered the limit-switch compartment from the motor housing via the motor lead wireway. For actuators tested without motor T-drains, the external steam environment entered the actuator via the gas' permeable Anchorite gaskets and via the conduit-l fittings which were not installed to provide pressure-tight seals.
f Since the external environment entered the actuator in all the l referenced tests, limitorque does not require configuring the conduit i- openings to represent the tested configurations. ? i ~ Limitorque noted that in all the actuator tests without T-drains, ! moisture and steam intrusion was evident from the small pool of I condensate that collected in the LSC. For tests without T drains, i pressure recordings document actuator pressure equalization at test- ' chamber pressure-and demonstrate that leakage occurred in all ! referenced tests, it was also noted that in the 600198 test,(which i tested units wit.hout motor T-drains) a 9-hour preliminary steam test i was performed by piping live steam into the LSC via upper conduit taps 3 and draining condensate with an open lower conduit tap. That report indicates that the test was successful with no noticeable effect on the function of any parts in the LSC. In all the Limitorque . tests, f the existence of moisture inside the unit did not prevent adequate actuator performance. j-During the various tests, test leads (both power and control) exited ~ the LSC via two conduit openings (one for power and one for control). The configurations of these openings are tabulated below. Unused i openings were closed with threaded pipe plugs. 1
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PAGE-32 NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 0064385 No external Limit Switch Compartment (LSC) drains were provided during any of the r1ferenced EQ tests. As previously discussed, for the L tested configurations, excess condensation during testing drained from this compartment via the internal wireway into the motor hous'ing. The-exact location of the wireway varies with actuator model number (SMB-l 0, SMB-00, etc.), but is located ~ roughly at 3/4 of the compartment height when the LSC is mounted horizontally. (See Figure 1 attached.) i For installations that reference tests utilizing motor T-drains, J Limitorque indicated that the use of LSC drains, although not required, does not affect qualification since, during the tests, the external environment enter the LSC via the motor T-drains. (See Section 15. Limit Switch Comoartment Orientation for further discussion of LSC drains.) LSC Conduit interface Data: l Three conduit wiring configurations were used in the various tests as () follows: TYPE A Non-nuclear grade Conax seals at both the limit switch l' compartment conduit opening and test chamber wall. TYPE B Non nuclear grade Conax seals at test chamber wall. High pressure teflon-hose threaded to both the Conax seal and the LSC. conduit op'enings. The teflon hose was used to minimize abrasion to the internal test wiring during the qualification - testing. lO i
NVGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS --8/89- PAGE 33- 006 4986 TYPE C- Non-nuclear grade Conax seals at test chamber wall.- Steel-O tubing with threaded fittings connected-to both the Conax seal and the limit switch compartment conduit- opening. .The -. purpose of the tubing was to minimize wire abrasion during s, testing. (1)600198: TYPE C (2)600376A:- TYPE A (3) 600456:. TYPE B (4) B0009: -TYPE B (5) B0003: TYPE B (6)-F-C3271: TYPE C (7) B0027: TYPE B (8) B0212: '!PE B (9) B0119: TYPE B O = i O
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1 NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 350064 988 ! 18. Terminal Blocks (Power and Control): Terminal Blocks were used in all- Limitorque tests to interface the j motor power leads .with' the test chamber wires. . Terminal' Blocks were-4 not used in any limitoroue tests foie controt circuit wirino.- The wire l termination points, which are' integral parts 'of l_imit' and Ltorque - switches,- were qualified as part of these' assemblies. Limitorque terminated the test chamber control wires directly to.both the limit ! switches and torque switches, and developed the necessary circuit interconnections (jumpers) external to the test chamber. : Testing in. l this manner facilitated monitoring of- individual switch performance, i- - l In addition to testing power terminal blocks during the standard ! - Limitorque= tests, ~ a special- test B0119 was' performed to specifically j test the range of terminal blocks and crimp-type terminations used.by
.Limitorque. Only the Marathon 300 block with adjacent-wiring was
) j energized at motor voltages during the LOCA simulation. -The-'selectica-of the Marathon-300 adjacent configuration was based'on.the assumption j that this block had the lowest performance capability due to its- !O P8xs4ca, censtructien veitaee ratine. and t8e enereiz4ne ef aeaacent terminations. All blocks were periodically-meggared 'at various ! voltages based on the capability of the instrument used. Many of the ! readings were taken at DC voltages substantially below 500 volts. I i Acceptability for- the various terminal blocks was based on measured IR I ! values greater than the values measured for the Marathon 300 terminal ! blocks. During an audit of the -test data, transcriptions errors werr { fourd for two Curtis "L" IR values. The " Event:5". values were.200, j 700, and IX ohms rather than the 800K, 700K, and IX published values. e 4 4
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NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 36 0064989 In 1987 it was noted that testing by others of the Marathon 1600 f series block in NEMA enclosures at similar. voltages (e.g., 480 Vac) resulted in a number of test failures but the Marathon 1600 blocks were acceptably qualified at voltages up to 240 Vac. Althoug'h the test configurations, block orientations, and the potential for condensate buildup on the blocks differed from the Limitorque B0119 test, these test failures brought into question the acceptability of using IR measurements at voltages significantly lower than normally energized voltages as the sole acceptance criteria. Additional support for the qualification of the blocks tested in 4 B0119, other than the Marathon 300 series, can be provided by referencing qualification tests performed by Limitorque and others. Table II tabulates some of these alternate test reports. Limitorque tests provide direct qualification support for the Buchanan 0524 series and the Marathon 300 series blodks at motor terminal-voltages. Support can be provided for the other blocks by reference to terminal fm block qualification tests performed by others using the same or U sufficiently similar terminal blocks at motor terminal voltages. While a number of other terminal block tests exist for these blocks at control voltage levels (i.e., 125 - 250 Vac); these reports have not been listed here. Limitorque maintains that the B0119 methodology is valid and does not recommend replacement of terminal blocks. However, to promote standardization the Marathon 300 block will be provided on all new safety related actuators. Limitorque encourages utilities to utilize the Marathon 300 block when ordering spare or replacement terminal blocks. Limitorque stated that it will certify the performance of Marathon 300 terminal block to the applicable test reports including B0119. p V. .
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 -PAGE 37-0064990 It was noted that the Marathon 300 series blocks were de-rated by UL q from 600V to 300V. This resulted in Limitorque's decision to use every other terminal point, e.g., alternate vs. adjacent, for power wiring in subseouent Limitorque tests. Both limitorque and the NUGEQ agree that the use of alternate vs. adjacent. wiring does not affect the performance or level of qualification provided for the Marathon 300 blocks based on the 80119 testing. Limitorque stated that the use of environmentally qualified splices in lieu of terminal blocks, in both power and control circuits, was an acceptable configuration. Limitorque indicated that it will-standardize on the Marathon 300 terminal block for future actuator and replacement parts orders. Terminal Block Data: (1) 600198: Buchanan 0524 (adjacent) (2) 600376A: Buchanan 0524 (adjacent) (3) 600456: Marathon 300 (alternate) (4) B0009: Marathon 300 (alternate) (5) B0003: Marathon 300 (alternate) (6) F-C3271: Buchanan 0524 (adjacent) (7) B0027: N/A (8) B0212: Marathon 300 (alternate) (9) B0119: Marathon 300 (adjacent) Marathon 300 (alternate) Buchanan 0524 (alternate). ; Buchanan 0222 (adjacent) GE EB-5 (adjacent) Marathon 1600 (adjacent) Curtis Type L (adjacent)
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O O E o E TABLE II h ALTERNATE TEST REPORTS FOR TERMINAL BLOCKS TESTED IN B0119 S. TEST SPONSOR OR SOURCE TEST REPORT fpfBER/ REFERENCE = TERMINAL 810CE,11tf r. 600198 g BUCHANAN 0524 Listtorque 600376A g
.Limitorque g Limitorque F-03271
_E m GE NEDC'31049 BUCHANAN 0222 13 A-686-85 n GENERAL ELECTRIC CP&L (E8-5.& EB-25) g EB-5, E8-25 System Energy Resources (Grand Gulf) 11/6/73 Letter RM Schuster (Westinghouse) 5
~
O: (test of CR1518) System Energy Resources PEN-TR-79-48 g d
-(test of CR1518) g: .
=: q System. Energy Resources PEN-TR-77-83
- HAR!.IliON 1600 .
H (test of .1500 series) - ?,. A-686 g.
'CURTIS TYPE "L"' CPALE PEN-TR-80-86 System Energy Resources A' number of other-terminal: block test reports, not identified'here, have been developed ' .. [
Note: m. for;-these blocks at control. voltage levels.. Otheritest reports may also be available.to j I support the acctptability of these terminal block'at. motor- voltages. . o
- o C3 .
CD (D b.
NUGEQ REPORT ON-LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 39 0064992
- 19. Wirina Connections:
Limitorque stated that only three types of terminal lugs have been O used in the fabrication of Limitorque actuators (including the tested units). These are: Thomas and Betts: RB873 Burndy: YAE-14N53 Hollingsworth: XSS-20826 Crimp-type lugs were used to terminate motor leads during all Limitorque testing. The exact type of lugs ustd in each test was not formally documented. The insulation on the barrel o the crimp-type terminal lugs is not required due to their use on terminal blocks.14f The terminal spacing and construction of these termination devices provides the necessary insulation capability. Limitorque, however, has included the 3 - terminal-lug types in its 30119 testing. Although not stated in the 3 report, each lug was attached to a short length of stranded wire. At the conclusion of the test, the terminal lugs were evaluated and the following observations made: (1) The resistance across the crimp joint was measured with an ohm-meter as "0" ohms. . (2) The integrity of the wire joint crimping was retained. (3) Surface cracks were noted on the terminal lug insulation; however, all insulation remained intact. L4/ The cotistruction of limit switches and torque switches does not preclude the touching of terminal lugs barrels at different potentials, however, normal instPlation and inspection practices typically preclude the intimate contact of such logs.
~
, e O
I
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 40 006,199'7 On the basis of these observations, Limitorque concludes that the .A terminal lugs utilized by Limitorque :re qualified to all test report O service conditions based on the performance demonstrated during the B0119 testing. Crimo luo Data: (1) B0119: Thomas and Betts: RB873 Burndy: YAE-14N53 Hollingsworth: XSS-20826 (2) All others: One of the above 3 types was utilized but not documented. O G Ns L)
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 -PAGE 41
-0064994- ,
- 20. Actuator Wirina:
Limitorque confirmed previous Group information regarding power and { control wiring as follows: (1) No power wiring, other than integral motor leads were' tested or are used by Limitorque. (2) Control wiring was not qualified by Limitorque as part of its actuator testing. Limitorque has supplied different types of internal control wire based on various factors including procurement documentation requirements. Table 2 provides a general categorization of the wiring types used by Limitorque unless specified otherwise by the purchaser. Limitorque has used Raychem Flamtrol, Rockbestos Firewall SIS and wire specified as Canadian Standards Association (CSA) Type TEW wire for the limit switch compartment jumper and control circuit wiring. Limitorque's selection and use of the Raychem and Rockbestos wiring was based on-the availability of separate vendor qualification test reports. The CSA type TEW wire and its various' equivalents (e.g., TW and TFF), , which are PVC insulated, have historically been used by Limitorque for , all commercial-grade Limitorque actuators. Limitorque likely used the TEW for all actuators fabricated prior to 1970 and for all pre-1978 safety-related, outside-containment actuators. Limitorque stated that it was not the purpose of the Limitorque test reports to qualify control wiring, and that the wires must be qualified separately based on other test reports or analysis. For procurement of a new actuator Limitorque-indicated, if requested, it-would identify the specific wiring used and the-test report which Limitorque believes is applicable. O
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 42 0064995 Utilities may substitute wiring qualified by othes for the wiring ,Q originally r.upplied by Limitorque. It was noted thdt certain wire insulations (e.g., EPR compounds) experience some dete.*ioration when exposed to petroleum based products (e.g., greases). TABLE 2 TYPE PRE 1970 1970 -1978 1978 - PRESENT Standard TEW TEW TEW Actuators In-Containment TEW Raychem or Rockbestos Actuators ~Rockbestos Outside TEW TEW Rockbestos Containment Actuators Notes: (1) TEW denotes CSA wire designation TEW which is 105 C PVC insulated wiring. Recent plant inspections and Limitorque research have indicated that types TW and TFF, among others, which are PVC insulated 60 C wiring, have also been used. Equivalent wire and insulation design permit substitution of these various PVC insulated types. (2) Raychem denotes Flamtrol wiring. (3) Rockbestos denotes Firewall SIS chemically or radiation cross-linked wiring. (4) Prior to 1973-1974, Limitorque records will likely not identify the type of wiring which was used. Limitorque believes that it is highly likely that PVC wiring was used for all actuators except safety-related in-containment units. It was Limitorque's colicy after 1970 to use Raychem wire for units clearly identified as safetv-related in-containment units. Limitorque records after 1974 will document the type of wiring utilized. 3 (O
i NUGEQ REPORT ON LIMITORQUE EQ CLARIFsCATIONS . 8/89 PAGE 43 ,, 0064990 ;
- 21. Limit Switch Materials:
Limitorque stated that all in containment tests were conducted with a l bronze intermittent gear limit swit-h busing..ll/ All outside l containment tests utilized an alumim housing. The limit switch i aluminum housings which :.i anodized appear as a smooth bronze colored i I surface. The bronze housings are sand cast and appear as a pebbly-bronze surfa:e. . Limitorque recommends that utilities maintain field actuator ' configurations which are consistent with the referenced test report. However, bronze limit switch intermittent gear housings are acceptable for all applications. . l The limit switch non metallic _ tested in all in containment reports. l except B0212, was a whitish-grey. Melamine. The 80212 test utilized a , brown Fibrite proprietary material. Helamine is no longer available. All replacement parts, now supplied 'oy Limitorque utilize the Fibrite material. Limitorque will certify the Fibrite to B0212 or any report which originally utilized Melamine. Outside containment tests utilized a red or black Durer phenolic. The phenolic material continues to be used for replacement part- The l Fibrite or Melamine material may also be used on um :s certified to ; the outside containment reports. i ll/The original 600198 test was unsuccessful when an aluminum housing - was utilized. The subsequent Addendum #1-testing utilized the~ bronze ; housing, j i
- i
, a 4
i O : i
. - - - . . , - . . ~ . . . ~ , . . _ . - , _ ~ - - . - . _ - . _ . . ~ . _ . . . _ _ _ . . _ - - . - . _ . . . _ _ . - . .. ,-.
NUGEQ REPORT ON LlHITORQUE EQ CLARIFICATIONS - 8/89 PAGE 44 00S4997 Limitorque indicated that during 1973 the supplier of its SMB 00 and Sk8 000 four train gear cartridge bearings replaced the metal bearing O cage with one fabricated of nylon. Subsequent four train gear cartridge bearings were supplied with this nylon component. 'According to Limitorque a nylon cage four traan cartridge was tested 'n the actuator qualified in the 80212 test. Based on this performance Limitorque certifies the these assemblies to other Limitorque test reports. Limitorque contia'Jes to recommend that cracked melamine rotors or finger plates be replaced. Virtually all such cracks are likely mold
.Arinkage cracks and will not affect performance or qualification.
More than 50Y. of the melamine parts have such mold shrinkage cracks. However, other types of cracks have been observed in a few installations which may have the potential to affect performance during accident conditions. The potential for these more significant cracks forms the basis for Limitorque's recommendation. It was noted that acceptable operation during normal conditions provides some assurance that these cracks may not adversely affect performance during accident environments. Limitorque noted that although the Fibrite material was only tested in 80212, the material exhibits superior performanue to the melamine and phenolic materials and is considered qualified to any of the other Limitorque test reports. Limitorque will certify the Fibrite to any of these test conditions. Limitorque in a 1988 maintenance update indicated that SMB 000 actuators manufactured in the late 1960s' used a four train limit assembly other than those subsequently qualified. If any of these assemblies are identified they should be replaced with qualified units. The unqualified switch is visibly different for the qualified units permitting its rapid identification. O
NUGEQ REPORT ON LIMITOROUE EQ Cl.ARIFICATIONS 8/89 PAGE 45 0064998 Limit Switch Material Data (1) 600198: Brsnze/ Melamine (2) 600376A: Bninze/ Melamine (3)600456: Bronze / Melamine (4)B0009: B/onze/ Melamine (5) B0003: Aluminum / phenolic (6) F-C3271: Aluminum / phenolic (7)B0027: Bronze / Melamine (8) B0212: Bronze /fibrite (9)B0119: N/A O O m -. r,- e - ,- - - v,., ,- - , .. e , - - - - - - - - . . . - , , ,m,.,-- -~.-r.--..--,+,- g -
ll t NUGEQ REPORT ON LlH1 TORQUE EQ CLARIFICATIONS - 8/89 PAGE 46 :
- 22. Toraue Switch Materials:
US Torque switch non metallic materials for both test and field units are ; identical to those utilized in the limit switches (e.g., Melamine, , Fibrite,andDurezphenolic). Limitorque in a 1988 maintenance update indicated that SMB-00 and SMB 000 actuators manufactured in the late 1960s may have been supplied with SMA type torque switches. The SMA torque switches, constructed of a brown laminated phenolic, were ; discontinued prior to the first Limitorqee qualification tests. The switch designs are visibly different making it possible .to di ting Ished between the qualified and unqualified switches.. If any of these assemblies are identified they should be replaced with qualified units. Some physical differences exist between the tested and certain supplied switches. Limitorque provides two style torque switches, referred to here as a " cam type" and a "non cam type". The cam type switch was provided on all SMB 000 units and on SMB 00 units manufactured with serial numbers lower than 233218 (approximately 1976). The non cam . type has been used on all..SMB 0 and larger actuators and the newer SMB-00 units. Since Limitorque generally tested a mid-sized actuator (i.e., SMB-0) only the non cam type unit. has been tested. The 80212 test included a SMB-00 unit, however, this unit was n.anufactured after the 1976 design change. ~ Limitorque maintains, based on the use of identical materials and similarities in
, design and performance, that all the SMB types are qualified based on the existing tests.
Limitorque has utilized and provided aluminum, aluminum with bronze bushings and all-bronze construction for limit switch un'its certified to the various-tests. All 3 types of construction can be utilized for in-containment applications although the aluminum with bronze bushing and all bronze units are preferred. Limitorque.noted that replacement torque switches are now only provided in the all-bronze construction-for in-containment units. Limitorque also stated that the commercial-O
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 47 grade torque switches used in the outside containment tests are 000 fabricated of sluminum and do not contain the bronze bushing. The in-containment typk torque switches can be utilized for all applications. In November 1988 Limitorque issued a Part 21 notification recommending ; r 11acement of all SMB 000 and SMB 00 c*m type Melamine torque switches with priority given to older switches and those installed in 0 actuators in high temperature (i.e., 2120 F) ambient environments. The notification indicates that two potential failure modes, cam lug breaking and cam to torque switch shaft binding, have been identified i for Melamine type switches. The replacement switches should be , fabricated of the Fibrite material. Limitorque noted that although the Fibrite material was only tested in 80212, the material exhibits superior performance to the melamine and phenolic materials and is considered-qualifted to any of the other Limitorque test reports, limitorque will certify the Fibrite to any of these test conditions. Toraue Switch Material and Style Datat-i (1) 600198: Aluminum / Melamine /Non cam type (2) 600376A: Aluminum with bronze bushings /Helamine/Non-cam type (3) 600456: Aluminum with bronze bushings / Melamine /Non-cam type (4) B0009: Aluminun with bronze bushings / Melamine /Non-cam type (5) B003: Aluminum / Phenolic /Non-cam type (6) F C3271: Aluminum / Phenolic /Non-cam type (7)B0027: N/A (8) 80212: Bronze /Fibrite/Non-cam type (9) B0119: N/A 9 O l
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 48 0065001
- 23. Limit Switch Comoartment Heaters:
Limitorque did not intend to test or qualify LSC heaters, but based on a customer request a LSC heater was included in the full B0119 test sequence. Its performance is documented in test report B0121, however, the heater was only energized during the last phasa of the LOCA sequence. Limitorque has, also conducted screening tests and evaluations of the heaters. The heaters provided by Limitorque are principally of a wire-wound / ceramic construction, although some are of a carbon-film / ceramic construction. The heaters are stud mounted with wiring bolted to two contact ears located at the opposite ends of the resistor. Limitorque noted that the heaters are typically sized to provide a 100 0 temperature rise in the LSC. However, the actual temporature rise will vary base on the LSC configuration, orientation, and installed components.lf/ In November 1978, a limitorque test was conducted by applying proper voltage to a Ward Leonard space heater allowing the surface p temperature to stabilize (measured at 250 degrees F), and a glass of V tap water was poured over the heater (temperature measured at 68 degrees F). This was repeated a second time, once again without ill effect. When inspected at the conclusion of the test, no damage was noted. JJ/A review of B0058 suggests that for most applications an acceptable qualified life (40 years) with substantial margin should still be available for units with minor temoerature increases above typical plant ambient conditions. See B0058, Section 3.2 Thermal Aging. 3 (V
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 49 0065002 Limitorque indicated that the qualification test, combined with the screening test and the non organic materials of construction, suggests that the heaters would likely tolerate EQ-type test conditions although no certification of this capability is provided by Limitorque. Limitorque stated that the heaters need not be energized after actuators are installed since the units are fully qualified without the use of heaters. Limitorque has provided heaters in actuators if they were specified' in the purchase documents. EQ certification of these actuators does not include heaters so suppliad, although the heaters need not be physically removed when the actuators are placed in service.12/ NRC Information Notice 86 71 Indicated that energized heaters have the potential to caus'e damage to wiring in close proximity to energized heaters. Limitorque recommends the use of heat shields, seismically qualified and available from Limitorque, to protect wiring should utilities wish to energize heaters. 12/ Limitorque recognizes some utility interest in utilizing energized heaters to minimize the effects of moisture related degradation and corrosion. However, no additional Limitorque test information supporting the qualification and use of heaters is available. The use of heaters should address 1) the heat rise and associated impact on qualified life of LSC components, 2) subfusing of unqualified heaters to prevent propagation of electrical failures to safety related LSC components and other circuits, and 3) failure modes and effects analysis of unqualified heaters to demonstrate that hypothesized environmental failures will not affect actuator performance. O
- . . - - . - . - _ - - - - - . - - . . . . - . . = - . . . _ _ - . _ - . . - _ . - . _ _ - _ - _
4 i NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 50 0065003
- 24. Remote Position Indicators Slidewire Potentiometers:
l No Remote Position Indicators-(RPIs) were included in any Limitorque EQ testing although RPIs ware tested as part of certain seismic tests. Limitorque would have provided RPIs in actuators, if they were specified in the purchase documents. The EQ certification, however, did not include the RPIs so supplied. Limitorque believes that RPIs do not affect actuator environmental qualification due to the low voltages used in the indicator circuit (10 volts) nor the RPI short circuit condition'(-0 ohms) which is used to indicate one extreme of valve position. A Limitorque review of likely mechanical failure modes indicates that such failure modes will not aff act actuator performance during accident conditions. O . r
- O L
L __ ~ _ . _ , _ . _ _ . _ _ . _ _ . _ _ _ _ _ _ . _ _ _ _ . . _ _ . _ . . . . _ _ . _ . _ - . _ . . _ _ _ _ .
NUGEQ REPORT ON LIMITOROVE EQ CLARIFICATIONS - 8/89 PAGE 51
- 25. Miscellaneous Control comoonents:
0065004 ) No other control components, i.e. integral starters, indicating lights, push buttons, etc., were included in the Limitorque EQ tests. Limitorque is also unaware of any "EQ-qualified" Limitorque actuators supplied with such components. e O e 4
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 52
- 26. Submeroencei 0065005 Limitorque stated that the actuators have not been tested for operation in a submarced condition. in test 600376A, the actuator was accidently submerged when grease plugged the test chamber drain.
During that test, the limit switch compartment filled with sufficient water to submerge the switch rotors. At that time, the control circuits failed (i.e., the control circuit fuses blew).la/ Control circuit operation resumed after the chamber was drained and water removed from the limit switch compartment by air purging through a transducer tubing connection. The 600376A test demonstrates that operation subsequent to submergence is possible if the motor and limit switch compartments are drained of water. This test giso supports the perspective that small amounts of water in the LSC do not affect performance, however, submergence of the electrier.1 devices may cause failure of the control circuits. la/ The 600376A test report does not indicate that the control circuits failed. This information is based on the recollection of the Limitorque personnel involved in the qualification test. O
NUGEQ REPORT ON LlHITORQUE EQ CLARIFICATIONS 8/89 PAGE 53
- 27. Reolacement Parts: 0065006 Limitorque is upgradirg its QA Program to meet the current requirements for dedication of commercial grade components. In September 1988 a critical components document was distributed identifying the rationale and the parts categorized as critical to
, safety. In conjunction with implementing the QA Program improvements, l Limitorque has found it necessary to make some changes in replacement l parts policies. Certain previously certified components are no longer provided as critical components or certified to the applicable test repnrts. The most significant are as follows: (1) Only Fibrite limit and torque switches will be supplied as critical components and certified to the applicable test reports. Red / black phenolic insulation / aluminum body switches will be supplied as commercial grade items. (2) All gaskets and seals are considered non critical except for the 0-rings on the limit and torque switches. (3) Only RH and t.R insulated motors will be supplied as critical components. Class B motors will be supplied as commercial grade items. Other general replacement parts information is as follows: j (1) Seals: Replacement seals are provided, as requested, in either Viton or Buna-N (red dot on Viton seal). (2) Gaskets: Replacement gaskets for nuclear grade service are provided as Anchorite 425 or Klinger K 61. l l l t
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 54 D ! (3) Limit Switches: Limit switch replacements for reports using M500 7 whitish gray Helamine insulation / bronze bodies are now supplied O as Fibrite insulation / bronze bodies. Limitorque will certify these replacements to any report utilizing the Melamine or phenolic switches. (4) Torque Switches: Torque switch replacement criteria is similar to that discussed under L Sit Switches above, with Fibrite now ; used to replace Melamine and phenolic. I (5) Motor Replacements: AC replacement motors are only supplied as Reliance RH class, LR class or B class. The Rad H class used in Report 600198 is no longer provided. RH class motors are used as the replacement motors for the Rad H class and will be , certified to the applicable test report including 600198, if requested. All DC replacement motors are supplied as Peerless RH class. (6) Terminal Blocks: Marathon 300 for all new actuators. O O
NUGEQ REPORT ON LlHITORQUE EQ CLARIFICATIONS 8/89 PAGE 55 006500g
- 28. Recommended Periodic Maintenance and Reolacement:
Limitorque does not reauire any equipment qualification maintenance O activities or periodic parts replacements. All actuators were designed and tested to provide, without component replacement, a 40-year qualified life.19/ Limitorque has identified in its maintenance manuals, Form LC8 and LC9, guidance on suaaested maintenance pract ces and intervals. Limitorque stressed that these recomendations can and should be varied based on actual field experience and historical data. Appropriately varying suggested maintenance does not render the actuator units unqualified. In particular, the Limitorque recommendation for maintenance at 18 month intervals is suggested as the initial inspection interval. In cases where utilities have successful experience with less frequent inspections for actuators under similar operating and environmental conditions this experience can be used to establish the initial inspection intervals. Subsequent inspections can and should be varied based on the results of the initial inspections and operating experience. Test report B0058 (Section 10.0 MAINTENANCE) recommends periodically operating the actuator to facilitate grease mixing and the coating of internal parts. In cases where operational requirements prevent the actuator from being periodically cycled, Limitorque indicated that inspections for proper grease composition can be used in lieu of the operational recommendation. The periodic actuator operation recommendation can and should be varied based on experience and inspections. 19/ Although thermal aging of the Fiberite material in test B0212 may not envelope a qualified life of 40 years at high ambient temperatures, (e.g., 150"F), Limitorque maintains that the material is superior to the older switch materials and consequently is qualified for 40 years at typical ambient temperatures. , O i
\
l NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 56 g06500g Limitorque further stated that all motors were designed to obviate the need for any maintenance. The bearings are sealed-continuous duty units which do not require replacement. DC motors are designed for 500 hours of maintenance free service which should envelope 40 year applications. Limitorque stated that all motors are manufactured for Limitorque, to Limitorque standards, by various vendors. Repairs, or rewinds, on these "Limitorque" motors should only be performed through Limitorque, by the applicable motor manufacturer. Limitorque will only assure qualification for motors repaired in this fashion. Although repairs or rewinding of motors conducted by others when properly controlled and conducted may provide an acceptable level of quality, limitorque will not certify those motors to its test reports.1Q/ O 10/For example, since the outside containment Class 8 tests (see Section 3) were performed to demonstrate generic capability, it may be possible for utilities to perform an analysis which combined with these reports, would. demonstrate the capability of motor rewinds performed by others. I l
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS - 8/89 PAGE 57 0065010
- 29. Aoina Analysis!
The following activation energy information was provided: (1) Motors:
- Reliance Class B 0.93eV (generic to all Class 8 motors)
- Reliance Class RH 1.02eV Reliance Class LR 1,53eV (2) Switehts:
Durez Phenolic 1.02eV
- Fibrite 1.78eV
- Melamine unknown W (3) Terminal Blocks:
- Marathon 300 1.63eV O
1 W The thermal aging analysis contained in B0058, Section 3.2.2, Switch Materials, also applies to Melamine ~except that the temperature 0 index of Melamine is 130 F, with its 50% property point reached in 6 7.68 X 10 hours. Forty years, therefore, represents less than 5% of-its available life. s
+
F O 5 Tw-,,rc y ~i-.,re,-.rev. .----,+--v--+-+ =w-,~rv5 ,5vym,%. , - ,, v w e er s' e -+ & ~- +- -- f- wo,%+= -+,-w,%?"*-r-e*<=~*=- -'
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/80 PAGE 58
- 30. Motor and Control Circuit Voltaae Ratinas: 06501; The testing performed by Limitorque is directly applicable to AC systems with 480 Vac motor <oltages and 120 Vac control circuit voltages and to DC systems with 125 Vdc motor and control circuit voltages. Limitorque considers these tests to be apolicable to other system voltage ratings. For motors and motor terminations, the test voltages are used to demonstrate similar performance for 575 Vac and 250 Vdc systems based on the motor insulating system design and performance capabilities of the motor materials and components.
Limitorque also noted that the AC motor insulating system has been tested for 600 VAC service based on the IEEE Standard 117-1974 motorette test secuence which includes higher test voltages under high humidity conditions. For control circuits, the 120 VAC and 125 VDC test voltages are used to demonstrate performance for 240 Vac and 250 Vdc based on the 600 volt rating of the control circuit components. Accroximate Ranae of Motor and Control Circuit Voltaae Data:22/ (motor volts / control circuit volts) Q (1) 600198: 496 520 VAC/120 VAC (2) 600376A: 473 -484 VAC/120 VAC (3) 600456: 480 - 495 VAC/120 VAC (4) B0009: 121 - 126 VDC/121 - 126 VDC (5) B0003: 490 - 500 VAC/120 VAC (6) F-C3271: 470 - 474 VAC/120 VAC (7) B0027: N/A (8) B0212: 414 - 506 VAC/120 VAC (9) B0119: 480 VAC/N/A 22/ The motur voltages are based on the published report data. The control circuit voltages are based on Limitorque information on the typical test specimen control circuit design. O l
NUGEQ REPORT ON LlHITORQUE EQ CLARIFICATIONS 8/89 PAGE 59 l
- 31. Motor Voltaoes and Actuator Thrust: 5012 Most of the Limitorque qualification tests were not performed at supply voltage and frequency extremes. However, the 80212 test included operation at voltages from 414 - 506 VAC and frequencies from 57 to 63 Hz. Actuator performance in this test confirmed that reduced voltage and variations in frequency do not affect AC actuator performance when actuators are adequate sizing in accordance with the design requirements.
For most Limitorque tests the octuators' ability to produce rated thrust / torque was verified by instrumented load cells. The required thrust / torque was developed and. recorded as seating loads with the actuator essentially unloaded, except for stuffing box loads, through the majority of its stroke range. This testing demonstrates both the actuators thrust / torque capability and simulates the load cycle
~
typically encountered during valve travel. In November 1988 Limitorque issued a Part 21 notification regarding temperature effects on DC motor actuator starting torque. Limitorque found that at ambient temperatures between 1200 F and 3400 F (the peak temperature in the B0009 test) certain size DC motors cannot produce full rated torque. For actuators required to operate at these or higher temperatures the applications should be reviewed with Limitorque to determine if adequate torque will be available. The following table is a complete list of those RH insulated DC motors used in SMB actuators that do not produce rated starting torque at ambient temperature up to 3400F. The motors will produce rated torque at any temperatures up to an including the listed temperatures. 4 0
NUGEQ REPORT ON LIMITORQUE EQ CLARIFICATIONS 8/89 PAGE 60 0 Motor Startina Toraue E ged DC Voltaae 40 foot-pounds 250 volts Ambient 250 F Temocrature 0650/*l O 60 foot-pounds-80 foot pounds 250 volts 250 volts 200 F 200 F 100 foot-pounds 250 volts 150 F 40 foot. pounds 125 volts 300 F 60 foot-pounds 125 volts 250 F 80 foot-pounds 125 volts 300 F 100 foot pounds 125 volts 120 F Acutator Thrust Measurements: (1)600198: Thrust measured before and after environmental test (2)600376A: Thrust measured during environmental test _(3)600456: Thrust measured during environmental test- > (4) B0009: Thrust measured during environmental test (5) B0003: Thrust measured during environmental test - (6) F-C3271: Thrust measured before and after environmental test (7) B0027: N/A (8) B0212: Thrust measured during environmental test (9) B0119: N/A O P f l O
.f
,.-,---,,,----,,,,.,,,.,,o ..n.,---,~ ,,i-n,-, ....,,..,-.,,,-.,+...n.....,.,.,,..-.e. , , , - - - , ,-.a,w.n-,., ,,n. I- m -
~
d O APPEN0lM A LIMITORQUE TEST C0ssflG AAI10W DATA SlDetART TESi REPORI 600196 600376A M56 90009 M3
- 1. Actua10R SI2E Sas-0-15 Sus-0-25 Sns-0-40 Sus-9-25 sme-0-25
- 2. ORIEuTATIon o LSC - VERilCAttY o tSc - VERTICALLY e tsC - WEtitCALLY o LSC - WRTICALLY o LSC - WRTICALLY (SEE mofE 1) (UP) (UP) (UP) (UP) (UP) o MOTOR - NORI20WiAt o MOTOR - NORI20siAt o M010R - NORIZONTAL o fe0 TOR - 100RIZOuiAL o MOTOR - Is0RIZONTAL
- 3. M010R/ SIZE o RELIA 4CE RAD E o REll ANCE RN o RELIANCE RW e PEERLESS R4 o RELIANC2 3 4
MAaRAFACTURER (WAfeEPL ATE *n*) 1800 RPn, DUAL 1800 RPM, Simstt (mAmtPL A1E *N"), DC (CommECTED 10 i (CONNECTED TO VOLTAGE, AC VOLTAGE AC ACTUAVOR), 00AL , ACTUATOR), cuAL VOLTAM , AC VOLTAGE,AC o ELECTRIC o ret lANCE RAD M AFfARATUS S (hAME?tAIE *N*) (OFERATED IN CmA#esER), AC ; W/DihGS SRARE (OPERAILD le o PARAmramt a CmameER) DUAL (OPERATED IN 4 VOLTAGE AC ChasenER), AC 4 se0 TOR /I-DRAlus moue 2 2 1 es0ME
! t l,. 5. se010R 3010R$ Attmlastm attmluun seacnESItm Altmlutel AttseleRm
- 6. MOIOR 3RARES RELIAhCE WiiN WO RAAKES Is0 SRARES Iso SEARES #0 BRARES DlhGS DRAKE (OPERATED IN CHAMSER) i !
4 T. se0 TOR READS, REFER TO SECTIos T REf ER TO SECitoes T REFER TO SECil0N T REFER TO SECTIOef T REFER TO SECTION T CommECitons, TEXT (ALSO SEE TEsi (ALSO SEE TEmi (ALSO SEE TENT (ALSO SEE TEXT (ALSO SEE *
! & TEtatthal10mS ITEMS 18. & 19.) ITEMS 18. & 19.) ITEstS 15. & 19.) !! EMS 18. & 19.) ITEMS 18. & 19.)
i
- 8. MOTOR INTERmAL ss0NE INSTALLED OR WONE INSTALLED OR teossE INSTAttED OR seossE INSTAttED OR It0ME INSTAttED OR OVERl0 ADS .
IESTED TESTED TEsitD TESit0 TESit0 (IhtRMOGARDS) O PAGE A-la D CII
<::5
APPEM0llt A LIMITORGUE IEST ' DuflG.JRAll0W DATA St#99ARY 1ESI REPORT F-C3271 8002T s0212 30119
- 1. ACluAlost SIZE Snt-0-10 Sas-0-15 SMs-0-15 m/A steste AS A flRiuRE ONLV) ,
4
- 2. ORIE NT All0N o LSC - WRitCALLY e LSC - W RilCALLY o LSC - WRitCALLY o LSC - W RilCALLT ;
, I (SEE moiE 1) (UP) (UP) (UP) (UP) e pe0 TOR - te0Rl20ediAL o 9e010E - NORl200sTAL e 18010R - leORIZONTAL e MOTOR - NORIZONTAL i 3. MOTOR / SIZE RELIANCE a WliR RELI ANCE RN, AC RELIANCE LR, AC N/A i leassufACTURER RELI AmCE MAstE, l DUAL WOLTAGE, AC ,
; 4. m0 TOR /I-DRAlus most 2 2 2 4
- 5. MOTOR ROTORS o Attselwun AttMINUM ALLMlWUM AltsellRJpl (COsamECTED TO l ACTUATOR)
- o MAGaeESitM ,
(OPERATED 15 CMAMBER) l . 1 l
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APPEND *.' 5 NUCLEAR UTILITY GROUP 0065020 ON EQUIPMENT OUALIMCATION switt foo 8200 StvtNittNTM St#ECT N *- aalaimotCN. C C 20C35 T E LE PMON C 18 04) 8 5? 9 81F May 7, 1986 P004 EL3506-017 Mr. Joseph B. Drab Special Projects Engineer Limitorque Corporation 5114 Woodall Road . Lynchburg, VA 24506
Dear Joe:
Enclosed please find a Nuclear Utility Group on Eo:ipment Qualification (NUGEO) document on Limitorque actuator environmental qualification. The . document has been prepared by the Group based on our discussions with Limitorque and the contents of the refe.enced Limitorque reports. The Group requests Limitor, 's review and comment on this material. The objective of our efforts has been to clarify various topics W ich have been raised by Group members related to the actual testing performed by Limitorque. In addition, the Group has an interest in Limitorque's design, testing and manufacturing experience, and any feedback on field experience vnicn vould aid utilities in the application of your reports and other qualification data to installed actuators requiring environmental qualificatien to 10 CFR 50.49. ( The Group would appreciate your prompt attention and response. On behalf of the Group, 1 vant to thank you and Limitorque for the time and effort associated with providing this information. Very truly your , ! 46 ^ s <- l Phi.ip M. Ho). man PHR/ak , Enclosure (1)
0065021 APPENDIX C
'o Limitorc ue Corporation a ~ - ---
. : :;.: *: .. ac.cion ono ecc., e: e : .w , -
y $114 Woocoil Rocc PO. Box 11316 Lynchburg VA 24506 1316 Teiephone-604 $26 4400
- Telex-82 9448 O ,
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J May 9, 1986 Nuclear Utility Group on Equipment Qualification Suite 700 1200 Seventeenth Street, N.W. Washington, DC 20036 Attention: Mr. Philip H. Holzman Gentlemen:
Subject:
" Clarification of Information Related to the Environmental Qualification of Limitorque Motorized Valve Ooerators" P004 EL3586-017 Referring to your letter of May 7, 1986, we have reviewed the subject document and believe it accurately reflects our discussions with you and the utility group related to Limitorque actuator qualification.
Very truly yours, LIMITOROUE CORPORATION d .3 Dr n\.,, J. B 3 rab Special Projects Engineer J0:mlb
'I .
0065022 4 I i i i i 1 1 l W 1 1 h f 9 ( l
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/ N I r, 4 835 UNITED STATES NUCLEAR REGULATORY com!$5!0N g g j3 M2 09 OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 ornc5 m MCM M
,Ncm: *m *4MMi June 15, 1984 IE INFORMATION NOTICE NO 84 47: ENVIRONMENTAL QUALIFICATION TESTS OF ELECTRICAL TERMINAL BLOCKS Addressees:
All nuclear _ power reactor facilities holding af, aperating license (0L) or construction permit (CP). Purposes: This information notice is being issued to provide licensees and construction permit holders with information pertaining to the results_of a recent NRC spon-sored environmental qualification methodology research test conducted on electrical terminal blocks. This information notice also serves as an u rly notification regarding the reduction of insulation resistance values sustained by certain terminal blocks used in a Conax Electrical Penetration Assembly curing c design rasis event simulation test.
- It is expected that recvients will review the information for applicability to their facilities. Nr /pecific action or response notice is required.
Description of Circumstances:
- 1. Additional information on NRC-sponsored test on terminal blocks In 1981, the NRC spons. red a research test on terminal blocks to ,
investigate the insulator deterioration of the terminal blocks under - accident conditions. This test was conducted at the Sandia National Laboratories (SNL) in Albuquerque, New Mexico. The test results of this earlier test program were published in IE _!nformation Notice No. 82 03. The results then indicated that the performance of the terminal blocks was questionable, however, the results were inconclusive because there were several areas where test conditions deviated from the.actually installed conditions. Recently, in order to quantify the performance of realistically installed and protected terminal blocks in a LOCA environment, $NL tested 24 more terminal blocks of different models-from four selected manufacturers.- Previous testing data on the terminal blocks indicated that neither the accelerated aging process nor the seismic testing will significantly af feet terminal block performance; therefore aging and seismic simula-tion was not. incorporated in the later SNL test. Terminal blocks were tested in the "as received" condition to simulate normal handling during installation. Additionally, no special care was taken during test prepa-I ration to prevent the deposit of fingerprints _or other contaminants on the terminal block surfaces. *' --
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IN 84-47 . June 15, 1984 ! Page 2 of 4 Test terminal blocks were installed inside NEMA-4 electrical enclosures with 1/4" diameter weep holes in the bottom. Cables entered the boxes from the side through " liquid tight" conduit. To simulate cables entering through conduit from a cable tray system, the conduit was terminated inside the test c5 amber and the conduit end was not sealed. The test was divided into two phases; each phase was tested under temperature profiles closely following the PWR temperature profile as described in Appendix A of IEEE 323-1974. Phase I consisted of an 11-day exposure to a steam-only environment, and Phase IJ consisted of approximately one day of simultaneous steam / chemical spray followed by a 5-day exposure to a steam environment. Saturated steam conditions were maintained throughout both test phases. Details of the test and test connections are being documented in NUREG/CR-3418 which will soon be published by the NRC. The terminal blocks were power-ed at voltages typical of in plant applications: 4 V de typical of RTD circuits, 45 V de typi W of instrumentation circuits, and 125 V de typical of control circuits. The terminal-to-terminal leakage currents were monitored during both Phase I and Phase II tests, and the terminal-to ground leakage currents were monitored during the Phase 11 tests only. The SNL test provides the following significant results: (1) the surface moisture film formed during the test reduced insulation resistance to 102 to 105 ohms from initial values of 10s to goto ohms; the reduction in insulation resistance ccurred during the steam exposure portion of the LOCA simulation,
- ) e. 45 V c , leakage currents were on the order of 0.1 to 10 mA, i3: r 4 V de, insulation resistance was at 5 x 103 to 7 x 10*
mms, and (4) one open failure was observed when leakage currents continued to increase for a 90-minute period to values which caused a 12-AWG wire to separate from the terminal point of the terminal block. The separation occurred at the terminal block - wire junction of a 125 V de circuit.
- 2. Low insulation resistance resulted durino qualification testino of terminal blocks used in low voltage instrumentation / control (1/C) elec*rical penetration assembly (EPA)
In a Part 50.55(e) Potential Reportable Deficiency Report, the Arizona Public Service Company (APS) has recently reported to the NRC that during the review of a qualification test report on terminal blocks used in lov voltage (I/C) EPA supplied by CONAX Corporation, APS has observed that insulation resistance (IR) values between terminal points of the terminal blocks were substantially reduced during simulation of design basis events. APS concluded that the low-level signals (up to a maximum 48 Y de and 4-20 mA range) cannot tolerate this low IR condition. This
' IN C4-47 June 15, 1984 Page 3 of 4 condition could result in erroneous response in the sensing and control functions, which in turn might jeopardize reliable plant operation during accident conditions. APS reported that the test terminal blocks were made by Kulka Electric Corporation and that during an investigative test, the terminal mitter andblocks :.lso failed the "as-installed conditions" test in trans-RTD circuits. APS further indicated that Raychem splices are under consideration as replacement for the terminal blocks for trans-mitter and RTD circuit applications at the Palo Verde units.
Discus sio_n: This information notice highlights a potential concern that may exist when terminal blocks are exposed to a steam environment. The results of the SNL test show that a moisture film will form on the surface of the terminal block during the simulation of the LOCA/MSLB events, and will result in the reduction of insulation resistance between terminal points and ground, and thus will allow some leakage currents to flow to ground. Based on the review of the SNL test and the review of other qualification test reports on terminal blocks, the NRC staff recognizes that leakage currents do exist during LOCA/MSLB simulations and that the leakage currents may be of significance in some applications. Although no written response to this notice is required, it is suggested that licensees and construction permit holders
- 1) review their facilities to determine if terminal blocks are used in -
low-voltage applications, such as in transmitter and RTD circuits, and
- 2) review terminal block qualification documents to ensure that the functional requirements and associated loop accuracy of circuits utilizing terminal block will not degrade to an unacceptable level due to the flow of leakage currents that might occur during design basis eve'ts. Instances where fuses were used ;
to monitor leakage currents, and where failure criteria were based on the ' failure of these fuses (1 ampere er less) do not provide information about leakage currents of magnitude that are less than the fuse rating. Data pro-vided under these instances are not considered to be acceptable data. The NRC staff considers this review to be part of the on going activities that the licensees are currently undertaking to resolve other environmental qualification deficiencies to meet the deadline and requirements set forth in the EQ final rule, 10 CFR 50.49. When supporting data for leakage currents are not substantiated during this review, one of the following possible corrective actions should be ennsidered:
- 1) Perform a valid qualification test of the installed terminal blocks with provision for the continuous monitoring of leakage currents throughout the test, and perform analysis to demonstrate that acceptable loop accuracy and asscciated response time for instrument circuit utilizing terminal block are being maintained throughout various operating conditions.
1
4
$ IN 84o47 June 15, 1984 Page 4 of 4 e 2) Obtain documentation from valid qualification tests already performed with substantiated data for leakage currents, and perfors appropriate analysis as stated in 1) above.
- 3) Replace the installed terminal blocks with qualified splices.
In addition to the concern of leakage currents being addressed in this notice, licensees and construction permit holders are reminded that otter information concerning on going preventive maintenance activities that involve periodic inspection of terminations and terminal blocks for cleanliness as described in the previously published information notice No. 82-03 remains in effect. If you have any questions regarding this matter, please contact the Re Administrator of the appropriate NRC Regional office, or this office. gional l [E ard L. Jo dan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enfor::ement I l Technical
Contact:
R. G. LaGrange, NRR (301) 492-8208 N. B. Le, IE (301) 492-9673
Attachment:
List of Recently Issued Informatien Notices l l l
. l l I
. . _ - - _ . . ._ - -= __ . . . _ . . _ _ - . . _ _ _. _ -_ _
r .,
, s. . APR 131988 Staff Exh.13 00CKElE0
&~dyg'l3(pf~8,Ilf l 4'
UbHHC Docket Nus. 50 348, 50-364 f M '92 MAR 13 P12 :02 4 License Nos. NPF-? and NPF-8 k
,4rr !c! Lt RCM,iAC . Alabarea Power Company Mcm imG s. Si WCl i' W "
i' ATTN: Mr. R. P. Mcdonald Senior Vice President P. O. Bn 2641 Birmingham, At 35?91-0400 . Gentlemen: l Ll@ JECT: ENFORCEMENT CONFERENCE
SUMMARY
l (NRC IN!.PECTION REPORT N05. 50-348/87-30 AND 50-364/07-30)
- This refers to the Enforcement Conference held at our request on March 15,
- 1988. This meeting concerned attivities authorized for your Farley facility.
The issues discussed at this conference related to environmental qualification . of electrical equipment. A list of ottendees, a summary, and a copy of your hencout are enclosed. We are continuing our review of these issues to l determine the appropriate enforcement action. i in accordances with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosures
- will be placed in the NRC Public Document Room.
l l Should you have any rivestions concerninq this matter, please contact us. l . ' - Sincerely, 4 i < l i J. Nelson Grace Regional fdministrator f I inclosures i 1. Enforcement Conference Sumiary
- 2. List of Attendees
- 3. Handout l x i cc w/encis: \
i D. P. Guthrie, EMutive Viu: President J. D. Woodard, General Manager - l Nuclear Plant i W. G. Hairston, !!!, Vice President -
. Nuclear Support l J. W. McGnwan, Manager-Safety Audit l and Engineering Review i 5. Tulmer, Superv%nt-Safety ;
Audit ent! Ent}ineertrig Review I bcc w/encls: (See page 2) i A m';m n #o4 : 3 s l F DFr ADOrF O!,Oon34g
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- Nf . _ _ . IDChT!ilEDM / 1 4;Vid _ RECElvfD '/h$D (C'w t t ._ REJECTfD C -arg Oft't Cer<t:s t:n DATE N Ciner witness I
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9
r , i . I E,NCLOSURE 1 Enforcement Conference Summary On March 15, 1988, representatives of the Alabama Power Company (APCO) met with NRC Region 11 personnel and Headquarters representatives in Atlanta, Georgia, to discuss the issues of environmental qualification of electrical. equipment (EQ) that derived from the NRC inspection at plant Farley during November 2-6 and 16-20, 1987 The meeting was opened with remarks given by M.L . Ernst, Region !!, Deputy Regional Administrator. He expressed a desire that the meeting focus on the issues relating to the prograrismatic beookdown of the EQ Program at Farley and not co'.centrate on one specific violation. The licensee acknowledged his request and stated that their presentation would address his concerns, however, they w~11 also address each violation. Mr. R. P. Mcdonald, Senior Vice President, APCO, began the meeting with opening renarks on the APC0 EQ program. He provided a chronology of how Farley EQ program was formulated. He went on to say that the basic EQ program was equipment oriented. The walkdowns performed of plant equipment were done to specifically identify name plant data and model numbers. The walkdowns did not evaluate the interconnecting of components within each system (i.e splices, terminal boards, seals and etc). Althouch, the EQ Program did address special EQ maintenance requirements, it did not address the mechanical aspects, instrument loop accuracies, grease, oils and etc. APC0 admitted that a breakdown did occur in the EQ Program at Farley. They
'. ' believe the breakdown occurred due to a " mind.',et" that developed somewhere in the 19E'd time frame. APC0 believed they had a program in compliance with the rule at that time. Hnwever, as a result of this " mind set", APC0 chose not to join the Nuclear titil ty Group on Equipment Ouolification and did not revise their pr wram as a function of time in spite of emerging NRC 10 Notices and Generic s etters. Symptoms emerged in late 1986, that indicated there may be problems with the 10 Program. However, due to the " mind-set" established, it wn not until mid 1987 that t wa'. clear ' hat significant deficiencies existed in the EC program. The licensee went on to sdy that a six person EQ Task icam
*is forrvd in mid IW to review certain arcai of the EQ program and at that t ime an APC0 Ingineet identified the V-type t.i ,plice concern. Subsequently, the t.isk team was espanded tre approximately " per*.iinnel from APC0 and Bechtel.
In summary, the licensee indicattoi that the root cause for the prngrarandtic breakdown was irincipolly duo to a "tri rii.e- that their IQ program was in cornpliance with hhe rule. Later during t he rnecting, the licensee provided informat ion on the violations and unresolved items disruued in the inspection report. in most tases, the licensee did not anree with the position taken by NRC. The basis for the-licen'.ee's positions is outlined in their handout (int losure 3). The meeting was closed with f inal comment s from M. I. Ernst, _, ; *. , . . ; 9. j , e
f a ENCLOSURE 2 Lis.T OF ATTENDEES Alabama Dower Company (APCO) J. E. Garlington, Maracer, Engince ing and Licensing, ADC0 W G. Hairston, 111, Vice Pr..sident Nuclear Support, APCO D. H. Jones, Manager, Design Engineering, APC0 R. P. Mcdonald, Senior V ce President, APC0 J W. M:Gnwan, Manager, Safety A,dit and Engineering Review, APC0 W. B. Shipman, Assistant Plant Fanager, Farley Nucles- Plant (FNP) ( APCO) R. W. Stewart, Project Engineer, APCO J. D. W'.odard, Manager, FNP, APCO Other Orgrati::ation P. A. Disenedetto. EO Consultant, DBA, Incorporated F. . Gandni, Prejar Enqir-cer, Eetht 1 Engineerinc. J. Luve, Assistant Proj~ct Engineer, Bechtel Enginnering J. E 5,ncergill, r0 Group Supervi:ar, B-chtel Engineering US N;C
- 1. E. :anlon, Ch'ef, Pl nt System' Section, Divistnn of Reactor Safety (045), Rll i
H. C . Dance, Chief , r( Jec t Sec t ir.n l A. Di vision of Reettor Projects 1 M. Ere,1, Deputy Reg ic.na i Admi s. i s t ra te.e , R11 4 F G bson, D i r .f c t u ' , Divipon nt kedctor $af ety (ORS) Rll 4 J b>Cda*d, kelionel Counsel, Rl1 A. R %rdt, Chie', 1 .,; i n a o r i n e, Rrantt, DRS, F11 6 !aicas, A ,s i st ant
- rec
- pr . bil Reactor,, NWR W. Lev's, Geactor i n ,;,or, t o r , Ril N
- rei--ather, meactor inspector, Rll i F rAhoff, Deputy Dire 4 tor, DE5, h))
W. H Miller, Jr., k a s i tia n t it,1.e. tor - farley llont, 41] (. Paull, Reactor i n *,0**: t u r , kil 11 . Pa t a nov 'i , kor.t cn C' ief , Sp%ial F oin-ts ' t",pne t t on Section ($F15), NRR
- f. A. k e e v e ', ,, S e n i e Frt. ject Manaq"r, Nkk l 51 u . , , I ti f o r.<. o+ n t A :. s t
- t.i n t , klI C. 5c'.n, R"atti In.."ctor, k!'
O. 'Irg., Spriinr i !or(om"nt Ceio* 'ina t ur , Rll D. M Je rell t , Chief I'roje.c t *. br. inch 1, Divi ,lon of Runt inr Projet.t s , Rll R . C Wi l ,on , i n'a i n"e' , SI'15 Nk R l' Wong, 5"ntur intor."m..nt Spo. : i l i .t , O f i i t. e o f Inio, oment, NRC O
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- PRESDRATION OF TEONICAL ISSUES AGDCA r >
l
- DXNMDEATION ISSUES i
KTIOR OPERA'IE VALVE ISSUES l SOLDCID OPERA'IE VALVE ISSUES SPLICE ISSUES DTOANCE SEAL ISSUES TERMINAL BCARD IN INS'IEUMDTP CIRCUIT ISSUE j GREASE ISSUE ,
- PROGRAM ISSUES
- GD'.S LEVEL TRANSMITIIRS ISSUES
- STILAN CABLE ISSUE l
i i I l l l i , t l l l _, . ... , - ,_..,-...__..m -. .
t . Page-0'of 50
-Enclosure 3 4 4 i
5 PCIOR OPDATEJ VALVE ISSUES
- T DRMNS
- 7TRMIfRL BOARDS
- ALUMINUM LIMIT Sh'I701 CCNIR
- MIXED GREASE l'
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Enciosure 3 Page 3 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-07
- 1. Restatement of NRC's description of finding
- The NRC has designated this as a violation. See Paragraph 3, page 20:
Some Limitorque Motor Operated Yalves (MOVs) inside Unit 1 containment do not have T-drains installed. This condition is not in accordance with the tested configuration documented in the files, paragraph 6.1.(3). II. Sequence of Event
- Limitorque test reports 600456 and 600190 were in the central file prior to November 5,1985 documenting qualification of Limitorque actuators in FNP.
- APCo identified that the MOV's in TNP did not have T-drains.
- APCo determined that T-de: ins are not required for qualification.
- Limitorque was contacted and confirmed the APCo position thet T-drains are not needed for qualification.
- NRC insp0ckbr concluded that the T-drains were required for long term horizontally rounted operators for valve position indication and repositioning due to the potential for flooding of the limit switch compa rtment.
III. Immediate Corrective Action
- APCo has determined that (for both Units) all MOV's inside Containment without T-drains are qualified.
- T-drains were installed (for both Units) on all long term operating H0V's inside containment which had provisions allocated for T-drains.
- Limitorque supports APCo's determination and conclusion.
l l l l l
2 , - - . i l- Enclosure 3 Page;4 of 50-i. i NRC EQ Audit Findings j Status .
' 50/348,364/87-30-07 Page Two 4
4 IV. Analysis of Event
- This is another example of an emerging issue. .
- 1 A. Use of' Test Report E00196 in combination with Test Report 600456 is l' acceptable for qualification of Limitorque actuators without T-drains
- 1 for the following reasons:
- 1) Test parameters of 600198 enveloped FNP accident conditions through extrapolation' of the seven day test _ to encompass APCo's:long term j (thirty day). operating requirement.
i 2) FNP motors have' class RH insulation
- 3) The limit switch' compartment is not water tight. Any water collecting in the limit switch compartment would drain Oct through i the gasket.
- 4) Where bottom entrv conduits into limit switch compartment exist at FWP, any water .. . teted will drain out through the flex conduit, j
i
- 5) Conduit is sufficiently shielded from spray to prevent spr4y entry via conduit.
I B. Limitorque stated in a letter to APCo dated November 20,1987 that: 1 Limitorque Qualification report 600198 is' the worst mounting position. t if moisture were to enter the limit switch compartment, it would-
- collect in the motor which does not have a T-drain. For vertical stem mounted valves moisture would drain through the fibrous limit switch-gasket material.
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- -a. ~ . _ , - , . . , , - , . , , ,.,.m,. ,m,. -m a -y v.,m, , , - .
Enclosure 3 Page 5 of 50 NRC EQ Audit findings Status 50/348, 364/87-30-07 Page Three V. Long Term Corrective Action
- None VI. Date of Full Compliance N/A Yll. Conclusions
- This was identi'ied by APCo and evaluated prior to the NRC EQ Audit
- There is no safety significance of this finding. T-drains are not required to establish qualification.
- APCo concludes that the M3Y configurations that did not have T-drains i'nstalled are Qualified and do not impact the safe operation or the ability of the units to mitigate the consequences of a design basis accident.
4
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Page 6'of 50
-Enclosure 3- -
~
NRC EQ Audit Findings Status-50/348,364/87-30-09 ,
- 1. Restatement of:NRC's description of finding
- The NRC has designated this as unresolved. .See Paragraph 3, page 21:
EQ file did not include qualification for terminal blocks used in notor-operated valves in that various terminal- blocks were identified during- > walkdowns of limitorque operators, paragraph 6.1.(3).
- 11. Sequence of Events-
- APCo walked down Unit 2 EQ scope MVs during the Unit 2 fif th refueling outage to determine if qualified terminal blocks were installed by Limitorque.
- Asmyq.{
- The Unit 2 MOVs mere found to have terminal blockssbe covered by Limitorque Report Number B0119 3 qualified Raychem splices were installed.
All Unit 1 MOVs that have a'long tenn post-accident function were inspected and either found to contain terminal blocks covered by Limitorque Report Number 80119 or- qualified-Raychem splices were installed.
Since it is assumed that Units 1 and 2 are similar APCo will conduct a walkdown of all Unit 1-EQ scope NVs during the upcoming Unit 1 eighth refueling outage to verify the terminal blocks.are covered by Limitorque Report Number B0119.
' FND EQ Package 23C was placed in the; Central File on November 24, 1987-which documents qualifications of Limitorque; installed terminal blocks covered by Limitorque Report Number 80119.
I 111. lunediate Corrective Action
- Qualified Raychem splices were installed in Unit 2~ MOVs that contained terminal blocks which may not be qualified by Limitorque Report Number B0119'
'a ' Page 7 of 50 l
. Enclosure 3 1 NRC EQ Audit Findings ;
Status ! 50/348, 364/87-30-09 (Page 7wo) IV. Analysis of Events
- This is another example of an EQ emerging issue.
- All Unit 2 MOVs have been verified by inspection to contain terminal blocks qualified by Limitorque test report 80119 or qualified Raychem splices have been installed. .
- Imnediate corrective actions were taken on Unit 1 where found to be applicable. .
Y. Long Term Corrective Actior.
- N/A VI. Date of F ill Compliance
- November 25, 1987.
VII. Conclusions
- Raychem splices have been installed in all Unit 2 MOVs that could not be positively identified by inspection to contain terminal blocks qualified by Limitorque test report B0119.
Enclosure 3 Page 8 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-08 1 Restatement of NRC's' description of finding
- The NRC has designated this as a violation. See Paragraph 3, page 21:.
Unqualified limit switch housing installed in a limitorque valve inside Unit 1 containment, paragraph 6.1.(3). [ NRC report identifies MDYBB11A as the valve in question. This should be MOV34410. ]
- 11. Sequence of Events
- APCo identified this item as part of the lOV walkdown associated with the response to IEN 86-03 (Limitorque internal wiring).
- An Administrative LCO was established in November 1987.
- The limit switch was replaced on November 24, 1987 clearing the Administrative LCO.
111. Indiate Corrective Action w . tr
- Administrative LCO established. The limit switch was replaced on #
November 24, 1987 clearing the Administrative LCO. 1Y. Analysis of Event
- This item is resolved.
- The NRC identified MOV8811 as being exposed to the Containment atmosphere. It is not exposed to Containment atmosphere. The correct number is MOV34410.
- There is no safety sigr.;icance associated with the failure of MOV34410.
The normal and accident p.sition of his valve is open. Only one of four containment coolers is required to provide adequate containment cooling.
- Corrosion of the Limit switch on PDV34410 is a long term event.
The only' impact of long term loss of this limit switch would be lack of indication on the main control board. The operator does not rely on this indication to perform any subsequent safety function.
$ 1
. Enclosure 3 Page 9 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-08 (Page Two)
V. Long Term Corrective Action N/A VI. Oate of Full Compliance N/A Yll. Conclusions
- This was identified by APCo as part of the field inspection conducted in 1985 to identify internal wiring for IEN B6-03. A review by the.EQ Task Force in November 1987 discovered' this configuration and established an Administrative LCO.
- The limit switch housing for this HOV has been replaced
- The as-found configuration at this M3V did not create a safety concern or inpact safety.
The postulated f ailure nmchanism is a long term event l
- Only one of four containment coolers is required to provide adequate containment cooling during a design basis accident
- The normal and accident position of this valve is open.
- Based on subsequent review, this item could be removed from the EQ l
Master List. i
Page 10 of 50 Enclosare 3 NRC EQ Audit Findings Status 50/348, 364/87 30-17
- 1. Restatement of HRC's description of finding See Paragraph 3.e, page 4.
- The NRC has designated this as a violation.
Mixed grease used in P0Ys and qualification documentation not in file for Texaco MRF AK-AP prior to 11/87. [ The NRC has not reviewed qualification package on Texaco MRFAX-AP. ]
- 11. Sequence of Events
- FHP standardized on the procurement of Texaco greases for use in all FNP applications. .
- It was discovered that KV's were supplied with a grease using a dif ferent base material than Texaco Marf ak AP.
- APCo's evaluation of the mixed grease issue determined that mixed greases was not a safety concern as documented by the JC0 dated September 23, 1987.
24,1987 and
' Texaco Marf ak AP qualification package completed September was available for NRC review during the November 1987 NRC audit.
111. Imediate Corrective Action
' A JC0 was written September 17, 1987.
IV. Analysis of Event
- This is another example of an emerging issue.
- Texaco Marf ak AP was qualified by APCo.
- Mixing of greases was determined.to be an issue in September 1987, whereupon a JC0 was initiated.
l Y. Long Term Corrective Action
- FNP plans to change.out grease in EQ Limitorques over the next two outages per unit. Currently operating under JCO's which Any extensions to the have been schedule I
written to cover mixed grease concern.This effort mquires disassembly of the ' will be discussed with the NRC. MOV and therefore being coordinated with other MOV work (e.g., MOYATS). VI. Date of Full Compliance-
- The current schedule for replacement is by the end of Unit 1 ninth refueling outage and the end of the seventh refueling outage for Unit 2.
- Vll. Conclusions I
' There is no safety significance in this finding.
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. Enclosure 3 : Page 11:of 50:
,=. . SOLDOID OFDA'II:D VALVE ISSUES SOLDCID OPERATED VALVE CONDUIT SEALS
- QUALITIED L!rE CALCULATIONS-
.- l l
e 4
. - - . - -~ . - -. .
Enclosure 3 Page 12 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-12
- 1. *- Restatement of HRC's description of finding
- The NRC has designated this as unresolved. See Paragraph 29, page 35.
Certain SOVs may not be qualified due to a lack of cable entrance seal s. This is contrary to the qualification basis, paragraph 6.i.(29) i (a), (b) and (c). II. Sequence of Events
- NRC concern on S0Y seals was identified during the audit i !!!. Innediate Corrective Action
- There are no corrective steps required.
ly. Analysis of Event
' IEN & -90 has been addressed by evaluating the peak surf ace temperature caused by the revised MSt.B scenario and determini'ig that they are still envelop!d by the existing FNP qualification profiles.
- The NRC position that all long term acting SUVs should be equipped with conduit seals is not supported by ASCO. In a lette. from ASCO to Bechtel dated November 10,1987,-it was stated that seals were not required. (This letter is contained in packages 2A and 28 in the APCo-Central File). No time interval was stated as a bounding condition on the ASCO position. Therefore, seals are not' required on long term acting SOVs since the ASCO testing envelopes FNP conditions.
- Additionally, the valves in the main steam room are equipped with liquid tight flexible conduit connecied to rigid conduit which is routed (with no openings) out of the main steam valve room.
l 4 . _ _ _ _ . . _ . - , . , .
Enclosure 3 Page 13 of 50 NRC EQ Audit Findings 5 Status i ,
' 50/548, 364/87-30-12
/ (Page Two) IV. Analysis of Event (Continued)
- SOVs in Unit 2 containment have moisture loops or conduit runs which slope away from the SOV which is in accordance with the ASCO installation bulletin.
- The PORY pilot solenoid valves are shown on the EQ Master List as a result of NUREG 0737 requirements to ensure PORY closure. No credit for operation of the PORVs is taken in the FNP sccident analysis.
V. Long Term Corrective Action *
- Unit 150V's will be walked down during the upcoming Unit 1 eighth refueling outage as follows:
- For insidt Containment, moisture loops or conduit runs which slope essy from the S0Y will be verified.
- For MSVR, use of liquid tight flexible conduit connected to rigid conduit running out of the KSVR (with no openings) will be verified.
Y1. Date of Full Compliance
- N/A - since no corrective steps are required Yll. Conclusions
' Evaluation of IEN84-93 has been completed.
- There is no safety significance of this finding.
- SOV's are configured to prevent moisture intrusion.
- v. <
Enclosure 3 Page 14 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-13
- 1. Restatement of NRC's description of finding
- The NRC has designated this as unresolved. See Paragraph 29, page 35.
Automatic Switch Company Solenoid Valves installed in Unit 1 Containnent exceeded their qualified life, paragraph 6.1.(29) (d). [ NRC requested copy of calculations for review to resolve this issue. ]
- 11. Sequence of Events
- The EQ component, maintenance and replacement schedule for these SOVs documented an eight year qualified life based on APCo's evaluation of the test report. Based on vendor information received in 1987, it was determined that for a normal design temperature of 120'F inside cor.tainment the minimum qualified life of normally energized solenoid valves was 5.6 years.
- Subsequently, actual operating temperature data was received showing that the average annual containment temperature was epproximately 98'F
- A revised qualified life calculation was performed using a conservative
.emperature value of 104*F. The msuit of this calculation shows that for norm:11y energized solenoid valves the minimum qualified life based on actual data is 11.2 years.
The eight year replacement schedule documented in the EQ component maintenance and replacement schedule for these solenoid valves was therefore conservative.
- As a unre conservative measure, an administrative qualified life based on 120'F inside containment is presently documented in the EQ component maintenance and replacement schedule.
111. Imediate Corrective Action i Cefjleted qualified life calculation based on actual containment temperature neasurements.. A copy of this calculation is available for NRC review. i i I i . l i e _ _ _ _ _ _ . _ _ _ _ _ _ _
Enclosure 3 Page 15 of 50 NRC EQ Audit Findings Status ' 50/348,364/87-30-13 (Page Two) IV. Analysis of Event
- Celculations have been completed showing a qualified life of a minimum s
of 11.2 years for normally energized solenoid valves.
'
- Even though some Unit 1 SOVs exceeded the conservatively calculated 5.6 year qualified life, they have not exceeded the eight year qualified life . hat was documented in the EQ component, maintenance and replacement schedule as supported by the revised calculation using actual containment temperature data.
- The solenoid valves which were replaced had been installed for eight years or less. Therefore the replaced valves were qualified at the time of replacement.
' There is no safety significance of this finding since the replaced valves were still capable of functioning during a DBA if it had occurred at the time of replacement.
Y. Long Term Corrective Action
- There are no corrective steps required V1. Date of Full Compliance
- The calculations demonstrate that APCo has always been in compliance in this area.
Yll. Conclusions The qualified life of these SOVs has not been exceeded.
- Calculations have been completed.
- There is no safety significance of this finding.
Enclosure 3 Page 16 of 50 SPLICE ISSUES g PICtreIriER SPLICE
- V-;YPE ELECTRICAL TAPE SPLICES
Page 17 of 50 Enclosure 3 NRC EQ Audit Findings f Status i 50/348,364/87-30-16 l
- 1. Restatement of NRC's description of finding l ,
See Paragraph 3.a. page 4.
- The NRC has designated this as a violation.
The licensee operated Units 1 and 2 of the Farley Plant30,1985 at various power without l levels for some unknown period of time after November adequate documentation in their EQ files to demonstrate that the in-line 5-to-1 field to pigtail tape splice configurations used on the Hydrogen < Recombiners would perform its intended function during a design basis accident. II. Sequence of Events .
- Westinghouse used a five to one taped splice as part of the Hydrogen Recombiner package.
- The FNP original installation was a five to one taped splice.
- There were no details for installing the five to one taped splice qualified by Westinghouse, at the time of installation.
' NRC questioned APCo's five to one taped splice configuration.
l
- APCo wrote JC0 for the Hydrogen Recombiner splice.
- The taped splice was replaced with a Raychem splice in accordance with Raychem guidelines.
- Westinghouse documented in a letter to APCo that the configuration tested was constructed with Scotch 70 tape.
l 111. Immediate Corrective Action
- A JC0 was written by APCo upon questioning by HRC.
- Taped splices were replaced with Raychem splices.
I l e
Enciosure 3 Page 18 of 50 NRC EQ Audit Findings Status 50/348,364/87-30-16 (Page Two)
!Y. Analysis of Event
- In-line taped splices (one to one) was an approved detail as documented by the electrical notes and details. While similarity of the five to one and one to one taped splice was not documented and located in, the Central File, the five to one taped hydrogen recombiner splice is a similar configuration to the one to one taped splice.
* - A five to one taped splice was the Westinghouse tested configurati_on.
The installed five to one taped splice was superior to the tested -* configuration.
- APCo took prompt and effective corrective action specifically, a JC0 was written and the splices were replaced.
- There is no: safety significance in this finding.
Y. Long Term Corrective Action None 4 VI. Date of Full Compliance Replacement with Raychem of the Unit 1 Hydrogen Recombiner splice was completed on October 15, 1987. I Replacement with Raychem of tne Unit 2 Hydrogen Recombiner splice was completed on November 5,1987. Y11. Conclusions
- This finding has no safety significance since the installed installation was superior to the configuration tested by Westinghouse in the qualification test.
l l 1
~ - - - - . . . - -. .. . . . Page 19 of 50 Enclosure 3 NRC EQ Audit Findings Status 50/348,364/87-30-19
- 1. Restatement of NRC's description of finding
- The NRC has designated this as a violation. See Paragraph 3.g. page 5.
Unqualified V-type electrical tapa splices on SOVs, mVs and Inside Containment Fans. II. Sequence of Events
- APCo determined that a potential deficiency might exist with regard to EQ solenoid valves' pigtail to field wire connection.
- A JC0 was prepared for EQ sole'noid valve Y-splices which was submitted to the NRC until verification of qualification could be performed. .
- In conjunction with the above. a test program was developed for verifying qualification of taped splices.
- A systematic program was developed to replace all such EQ solenoid valve spitees with Raychem splices in accordance with design.
- It was determined that certain EQ MOV motor lead spidees potentially t t:lized the V-splice configuration
- A JC0 was developed for EQ mV motor lead V-splices
- A systematic program was developed to replace all such EQ KV motor lead splices with Raychem splices in accordance with design
- EQ fan motors inside containment were inspected and all y-splices were replaced with Raychem splices as necessary.
- All EQ 4160V motor splices were inspected and replaced as necessary with Raychem splices in accordance with design.
- The test program was developed by assembling a taped splice test specimen for each configuration found during the efforts to replace taped splices with Raychem splices, or similarity to other test reports was documented. Therefore envelopment of FNP configurations was ensured in the test program.
.Enclos6re 3 * - - - - ~ -~ - Tyr 20 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30-19 (Page Two) 111. lunediate Corrective Action All EQ equipment in both units required that has a long-terr, post accident function have been replaced.
As a conservative measure, all Unit 2 EQ V-taped splices have been replaced with Raychem splices. For any taped splices that have not been replaced on Unit 1, a JC0 exists in addition to the WDe qualification report. V-splices have been qualified by Wyle testing. IV. Analysis of Event / APCo does not agree as written. The Y-splices referenced have been proven to be qualified by Wyle Test Report or similarity to other test reports has been documented. Testing was completed and documented prior to the November 16,1987 audit. The current field status is resolved based upon the Wyle Test Report. Additionally all the V-spices on EQ equipment have been replaced in Unit 2 and are being replaced in Unit 1 with qualified Raychem splices. There is no safety significance in this finding since the V-splices have been qualified by testing. Y. Long Term Corrective Action The FNP Electrical Notes and Details will be revised to document the types of splices that are acceptable for each type of EQ component. VI. Date of Full Compliance W/A VII. Conclusions There is no safety significance in this finding. In addition, V-splices were qualified by testing. Documentation supporting the qualification of the. V-tape splices
%ss completed prior to November 16, 1987 audit.
Enclosure 3 Page 21 of 50 l DUTRCE SEAL ISSVLS
- DUTRCE CTM Of TAPG.7 PCG SOLDO!D \71VE PAYODVQi!CO SFJ104 LIMIT mil 7CE.S O
6
"" ** Page 22 of 50 HRC EQ Audit findings Status 50/348. 364/87-30 14
- 1. Restatement of HRC's description of finding
- The NRC has designated this as a violation. See Paragraph 31, page 37.
Qualification not demonstrated for Raychem seal installed on Target Rock 3olenoid valve cable entrance seal, paragraph 6.1.(31).
- 11. Sequence of Events
- These valves are installed to meet the NUREG 0737 requirements an'd >
schedule. Installation was completed on Unit 2 prior to initial plant startup in July 1981 and on Unit 1 on May 8,1981 with power removed pending NRC approval of the Head Vent System. Design for these modifications was issued on PCN 79 463 and 2BE833 in 1980. These va)ves were shipped for Unit 2 on July 17,1980 and for Unit 1 on April 29, 9 0.
- At the time of installation, sealing was not a requirement identified by the vendor. APCo added a Raychem seal as an additional conservative measure.
- Subsequent to APCo installation. Westinghouse qualified to 10CFR50.49 requirements the Target Rock Solenoid Valve with a Conax seal. The Westinghouse test report was rev12wed, the seal deviation was identified, and concluded that replacing the seals was not required since FNP was a NUREG 0588, Category !! plant.
./
111. / ! mediate Corrective Action
' PCNs 8613873 and 87 2 4108 replaced these seals with 50.49 qualified Conax seals.
IV. Analysis of Event
' At the time of installation, there was not a design requirement for entrance seals identified by the vendor.
- FHP sccident analyses do not take credit for the head vent valves and this equipment is therefore not essential to achieve a safe shutdown condition. This conclusion is documented in Alabama Power Company's submittal of May 20, 1983.
~ - - - - - - - - , ,- . . _ - . .,_ __ ,_
~
A.* . ,
. . .. i .. ._. . _ _. .
Eni:10sure3 Page 23 of 50 WRC EQ Audit Findings ' Status s 50/348, 364/87-30 14 (PageTwo) Y. Long Term Corrective Action
' None.
Y!. Date of Full Compliance
- The Reychem/ CHICO seals were. replaced with Conax connectors qualified-by the Westinghouse test report on eccember-HT-1987-en6 0ecember 15, ;
1987 for UMmnd12. respecttvelyr k I'
*b' ''# '/ ' * '
s'f /'4 8 * * '
# Tkt t , .4. , . ., / s ..vM de ** h* 'I *'N!'
s ' ' ' " ' ' [k ' 4***fl, l., It s..e 4. s l n. *l <*.. I. .. . ., Y11. Conclusions
- These valves were installed to meet the NUREG.0737 requirements and schedule.
- NUREG.05BB, Category 11 requirements applied to FNP at the time of installation. .
- PCWs 8613873 and 874.9 4108 replaced these' seals with Conax connectors qualified by the Westinghouse test report.
- This equipment has no safety function during or following a DBA.
f l l l l g
- . ~ , . -
,,,.--m_--,,-,,,,-,-re w a , ,- - - --- --<--,.4---------,--**~---~~--w------- - - - + - , - - - - . - - - - = r-+E-- .-- * - -
.u, . Enclosure 3 Page 24 of 50 NRC EQ Audit Findingt Status 50/348, 364/87-30 15
- 1. Restatement of HRC's description of finding
- The NRC has designated this as a violation. See Paragraph 32, page 38.
Raychem/ Chico A Seal (Package 29G) - NUREG 0500 Category 11 qualification not demonstrated because bonding of the Raychem matertJ'. to the retal pipe nipple under LOCA conditions (including chemical spray) has not been addressed, paragraph 6.1.(32).
- 11. Sequence of Events
- IEC 79-05 was issued to address a concern reg 6rding moisture intrusion into limit switches.
- APCo developed and tested the Raychem/ CHICO seal because no qualified conduit seal could be identified et that time.
- Raychem material was used because it w*s qualified for the FNP environment.
Chico was t.*1 as a backup noterial for the Raychem to provide support to withstant the pressurc spike. Subsequent to the installation of the Raychem/ CHICO seals, the present generation of conduit seals became available.
- Questions concerning these seals were raised, during the NRC inspection.
On January 8,1988 a letter was issued to the NRC addres"e 1 their concerns.
- The current fleid status is awaiting completion of HRC evaluation.
111. Inmediate Corrective Action
- Since APCo believes the existing seal configuration to be qualified, no corrective action is required.
t e
f. Encl 0sure 3 Page 25 of 50 NRC EQ Audit Findings y Status 50/348,364/87-30-15 (Page Two) IV. Analysis of Event
- APCo selected Raychem material because testing by Raychem in other configurations was done to parameter levels in excess of those at FNP.
- Documentation supporting APCo's position was in the Central File prior to November 16, 1987.
The January'8,1988 letter provides additional information needed to25, 1987 address NRC s concerns raised during the audit and the November meeting. V. l.ong Terni Corrective Action N/A - based on the response in section 111 above. VI. Date of full Compliance N/A - based on the response in section 111 above. s V11. Conclusions
- APCo's position is that this configuration is qualtfled based upon the qualification package in the EQ Central File prior to the November 16, 1987 audit and additional clarification in the January 8,1988 letter to the NRC.
- l. '
.Enclo'sure 3 Page 26 of 50 O,
e min BCAPD Iti IllSTRUMDC CIRLVIT 185VC O h f : - > f 4 9
Entlosure 3 - Page 27 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30 11
- 1. ., Restatement of NRC's description of finding
- The NRC has designated this as a violation. See Paragraph 15, page 25.
Licensee EQ flies did not support qualification for use of States (type HT/ZWM) and G. E. (type (CR1518) terminal blocks in instrumentation circuits, paragraph 6.1.(15). II. Sequence of Events j States terminal blocks were qualified by Wyle Test Report. The tent report did not document leakage current values during the test. l Westinghouse was contracted in 1984 to consider the error associated I with the use of terminal block's and their impact on instrument loop accuracy.
- Further discussion with Westinghouse in 1987 indicated that these errors were assumed to be negligible.
Westinghouse was provided a 1.R.value based upon similarity to the Connectron block for evaluation of instrument accuracy. The NRC auditors indicated the acceptability of the instrument accuracy analysis methodology documented by WCAP 11658 but questioned the applicability and acceptability of the Connectron blocks test report number to the FNP installed configuration. APCo developed a JC0 for use of the teminal blocks based on test data presented in a Sandia Report. The G. E. terminal block qualification report was placed in the central file before the November 24, 1987 meeting. Meeting held with the NRC Region !! November 24,1987. NRC concluded from meeting presentation that the terminal blocks may be qualifiable. For Unit 1. APCo agreed to increase shif t supervisors and STA awareness and replacement of the terminal blocks with qualified splices. Such Unit 2 teminal blocks in EQ instrumentation circuits were replaced prior to startup. Unit 1 terstnal blocks were replaced in December 1987. Additional qualification test evidence was provided by APCo letter to the NRC dated January 8,1988.
Ericlosure 3 Page 28 of 50 NRC EQ Audit findings Status 50/348. 364/87 30-11 (Pege Two) 111. 1 mediate Corrective Action
- Replaced terminal blocks in EQ instrumentation circuits with Raychem splices.
IV. Analysis of Event ,
- This is another example of an EQ emerging issue.
Qualification central file prior documentation to the audit; however of the States this testterminal blocks report did not was in the document leakage current valves during the test. .
' Additional documentation supporting qualification was developed by APCo demonstrating that the instruments muld have performed their intended function.
- The HRC auditors accepted the instrument accuracy analysis methodology documented by VCAP but questioned the similarity analysis.
- To expedite resolution of this issue, the terminal blocks have been replaced with qualified Raychem splice on instrument loops in the scope of EQ.
- The HRC did not question the basic qualification of terminal blocks - ,
only the IR values as they pertained to use in instrumentation circuits. V. Long Term Corrective Action i
- Restrict the use of terminal blocks, in instrument circuits in potentially harsh environments, by design control.
Y1. Date of Full Compliance
- Replacement of terminal blocks with qualified Raychem splices on EQ instrument loops was completed on Decenter 5,1987 and December 17,1987 on Unit 2 and Unit 1, respectively.
VII. Conclusions
- The current field status is resolved. Terminal blocks have been replaced with qualified Raychem splice on instrument loops in the' scope of EQ.
- This was identified by APCo and additional qualification information was developed to demonstrate that the instruments wuld perform their intended function.
I. S
Enclosure 3 Page 29 of 50 GREASE ISSUE
- GREASE USED Q1 COTIAllMDfr FAN MCHORS N'
a ,
- Enc 1dsure 3
- Page 30 of 50 l .
NRC EQ Audit Findings Status 50/348,364/87-30-18
- 1. Restatement of NRC's description of finding
- The NRC has designated this as a violation. See Paragraph 3.f. page 5.
No documentation in EQ Central File to support the use of Texaco Premium RB grease on f an motors inside containment. The licensee is currently operating under JCO.
- 11. Sequence of Events
- Grease qualification in trotors is an EQ issue identified by APCo through review of audit reports. .
- Joy test did not documc.it the type of grease tested.
- APCo wrote a JCO.
- Texaco is performing qualification testing.
111. Irnediate Corrective Action
- A JC0 has been written. Grease is being qualified.
IV. Analysis of Event
- Tnis is another example of an emerging EQ issue.
- While qualification documentation was not in the file justifying the use of this grease, there is no safety significance in this finding as determined by grease JC0 dated September 17,1987.
1 .. . . . .
64 .
. Enclosure 3 Prge 31 of 50 l
NRC EQ Audit Findings Status 50/343,364/87-30-18 (Page Two) V. Long Term Corrective Action
- Qualify Texaco Premium RB grease.
Y1. Date of Full Compliance
- December 31,1988.
V11. Conclusions
- There is no safety significance in this finding as determined hy the applicable JCO.
4 4 1
Page 33 of 50 Enc,1 sure 3 NRC NRC EQ tudit findings Status 50/348, 36a/87-30 01 Restatement of HRC's description of finding ll 1.
- NRC designated this as 50-348, an additional example of a finding documented in 364/87-11 and 50 348, 364/87-14. See WRC Inspect %n Report Nos.
Paragraph 6.e. page 9:Use of unqualified commercially procured equipment i
!!. Sequence of Event 5
- In August 19B', APCo performed a storeroom inventory evaluation us revised procurement procedures.
a data base that uniquely identified parts in the storeroom as saf ety related and nonsafety-related.
- NRC conducted a vendor audit inspection on May 11 - 22, June 1 - 5, and June 11 - July 10,1987.
- On June 4,1987 APCo developed an interim procedure requiring written review and approval of comercial grade parts prior to use in safety related applications.
' In June 1987, a historical review of work packages that may have impact on EQ equipment was initiated.
l ' On November 13,1987 APC0 revised procedures to require engineering review of comercial grade parts prior to installation in safety related appifcations. In addition, APCo implemented a Comercial Grade Parts j Dedication procedure," requiring a detailed dedication plan based on
" critical to function characteristics for each item.
- The week of November 16, 1987 NRC EQ inspection team raised concerns regarding adequacy of the existing comercial part dedications program for equipment installed in EQ applications.
- APCo received a Wotice of Violation (NOV) for vendor inspection audit dated November 3,1987 and APCo responded to the HOV by letter dated December 17,1987.
1
- NRC issued EQ inspection report dated February 4,1988 citing additional examples of a violation identified during the NRC vendor aud't inspection.
Enclosure 3 ,, Page 34 of 50 WRC EQ Audit Findings Status ) 50/348, 364/87-30-01 * \ Page Two
. i l
111.1 mediate Corrective Action
' Prior to completion of the vendor inspection audit, on June 4,1987, plant procedures were revised to require written evaluation and approval of comercial grade parts prior to their use in safety related applications. This action was an interim reasure until a dedication ;
program was approved. 1 13,1987 requiring engineering l
- Procedures were revised on November review of comercial grade parts prior to installation in scfety related applications. In addition procedures were revised to incorporate a The dedication plan which is comercial grade parts dedication program.
a part of this program includes acceptance criteria when tests or measurements are required for dedication. IV. Analysis of Event
- The current procurencin process now requires an up4tront engineering evaluation of procurement documents for all safety-related applications which includes EQ equipment applications.
- Based upon a review of approximately 11,000 historical packages (NWR, HIF, P.O.'s) to date and physical inspections conducted by AFCo, no degradation of safety functions have been identified based on the use of comercial grade parts in EQ applications. ,
' The two examples referenced in the NRC report (States type IkH teminal blocks and Okonit- T-95 insulating tape and No. 35 overlay tape) have been evaluated by .. Co and found to be acceptable for use in IQ applications.
- In discussions with many of the original equipment manufacturers during the 1970's and 1980's it was a conmon practice to buy replacement parts through the OEM as comercial grade since many of these parts were supr11ed comercial grade. The significance of the dedication program for comercial grade parts has recently become an industry issue. The WRC and industry have comittees that are currently developing postions; therefore, this is an emerging issue.
9- , - - - ~ - , - , ~ . , . - ~ c , n..
'., Eni:Josure3 Page 35 of 50 NRC EQ Audit Findings Status 50/348, 364/87 30-01
- Page Three V. Long Term Corrective Action
- APCo will work with the NRC and industry comittees in an ef fort to finalize guidelines for dedication of comercial grade items for use in safety-related applications.
VI. Date of Full Compliance .
- June 4,1987 V11. Conclusions
- Since regulatory guidance has not been provided relative to this new, emerging area APCo does not believe that it is appropriate to require the industry through enforcement proceedings to inplement programs for dedication of comercial grade items.
- This is not a new violation upon which additional enforcement action should be based (NRC Inspection Report Nos. 50-348, 364/87-11 and 50-348, 364/87-14). Corrective actions _ have been taken to prevent future occurrences.
l (
Page 36 of 50
,"CI?8 83 NRC EQ Audit Findings '
Status 50/348,364/87-30-02 . t
- 1. Restatement of NRC's description of finding
,i
- NRC designated this as an additional example of a finding documented in ,
NRC inspection Report Hos. 50 348, 364/87-11 and 50-348, 364/87-14. See Paragraph 6.e.2, page 13: Failure to procure replacement equipment in co 10CFR50.49(L).
- 11. Sequence of Events
- On January 11,1984, a meeting with NRC staff in Bethesda, Maryland was held to discuss APCo position on maintaining equipment qualification.
- On February 29, 1984, APCo documented, via letter to the NRC, minutes of 1984 meeting where APCo's position on procurement of
- the Januaryequ replacement 11,ipment was described. Specifically, APCo will procure
" identical components" as replacements unless identical components cannot be obtained.
- On December 13, 1984, NRC issued an SER specifically referencing the February 29, 1984 APCo letter and concluding that APCo's EQ program is in accordance with the requirements of 10CFR50.49.
- During EQ inspection conducted during the period of September 14 - 18, 1997, a concern was identified that the requirements of 10CFR50.49(L) were not dxumented.
- On November 16,1987, APCo revised FNP-0-ETP-4108 requiring replacement equipment be upgraded to 100FR50.49 or " sound reasons to the contrary" be documented.
Ib Page 37 of 50 Enclosure 3 NRC EQ Audit Findings Status 50/348. 364/87-30-02 Page Two
!!!. Imediate Corrective Action
- On November 16,1987, APCo revised procedures requiring replacement equipment to be upgraded to 10CFR50.49 or sound reasons to the contrary be documented.
- A review of store-room inventory was conducted prior to issuance of the revised procedures to determine the level of qualification of all. items in inventory. This review resulted in a detemination that all replacement components in inventory designated for E0 applications were:
- procured to the requirements of 10CFR50.49; or " sound reasons to the contrary" exists.
1Y. Analysis of Event
' APCo informed the NRC through a meeting and by letter of its intended actions on maintaining qualification of equipment; specifically replacement equipment.
- The NRC SCR documented that APCo's EQ program including APCo's definition of replacment equipment, was in compliance with 10CFR50.49 requirements. ,
i
- APCo procured equipment in accordance with its documented and NRC approved EQ program.
- HRC, Region !!, did not interpret the requirements of 10CFR50.49(L) as they were approved by NRC in 1984.
- APCo revised the procedures on November 16,1987 to resolve the NRC concerns.
- The replacement of EQ components since February 1983 has been reviewed and determined that all items were qualified to.10CFR50.49 requirements or " sound reasons to the contrary" exists.
- Replacement components qualified as a minimum to NUREG 0588 were installed. Equipment qualified to NUREG 0588 will function properly in a design basis accident. .
8,' Enclosure 3 . Page 38 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30 02 Page Three 1 V. Long Tenn Corrective Action l l l
- N/A Y1. Date of Full Compliance .
- Procedures were revised November 16,1987 ,
VII. Conclusions
- Historically, APCo's position was that the NRC provided a SER which r.i epted the APCo EQ program definition of an upgrade.
- To resolve ongoing NRC concerns, plant procedures were modified November 16,1987 to requi 1 the procurement of replacement equipment qualified to 10C*R50.49 requirements or " sound reasons to the contrary" be documented.
- There is no safety significance in this finding.
, -y,
,.,,.~7. , , , , ~ . . , , - - , . . , ~ . .. ,.,,,._,.........Lt..._,,,,,--.--,, r.,,. ... , ,,, * - . ,4., J., . - - ~ 4 +,,,..
- - ~ ~ " - " Enclosure 3 fage 39 of M NRC EQ Audit Findings Status 50/348, 364/87-30 03
- 1. Restatement of NRC's description of finding
- NRC designated this as a Violation. See Paragraph 6.f. page 13:
Failure to take prompt and timely corrective action for EQ programatic deficiency identified by SAER staff in 1983.
!!. Sequence of Events
- On December 2,1983, noncompliance FNP NC 48 83/19(8) issued.
Failure to indicate instruction books and vendor drawings for EQ equipment, which require revision as a result of design changes. '
- On December 29,1983, CAR 830 written with estimated completion by April 1,19B4 -
- In March 1984, VETIP was finalized by RJTAC addressing G.t. 83 28 pointing out that all vendor manuals ar.s 'rawings would not require retrofit.
' On April 9,1984, CAR 830 was expanded to address all vendor unuals and drawings by memo from W. G. Hairston, !!! to 0. D. Kingsley, Jr.
- On June 25,1984 APCo submitted fine) response to G. L. 83 28 section 2.2.2 to NRC.
- On August 8,1984, CAR 830. Rev. I was issued stating the following:
- 1) Vendor unuals and drawing will not be updated
- 2) List will be developed for equipment which has EQ limit switches or solenoid valycs attached.
- 3) Planners will be instructed on the EQ requirements to appropriately stamp MdRs.
' On August 27,1984, as a result of G.L.83 28 CAR 830, Rev.2 was issued by FNP to state that appropriate vendor manuals and drawiny. will be revised henceforth. In addition, to prevent recurrence,
- 1) For EQ equipment, the design organization will develop a cross index of appropriate drawings and manuals for each item on the EQ master Itst.
- 2) Non - EQ equipment retrofit changes to vendor drawings and manuals identified during routine activities will be made on an as required basi *..
Estimated completion date for Rev. 2 was July 1,1985. 1 -__
a * * ~
'Pagol0of50
{nclosure 3 NRC EQ Audit findings Status 50/348, 364/87-30 03 Page Two
. i lI. Sequence of Events (continued)
- On December 18, 1984 NS advised FNP that Design Organizations had completed review and update of procedures to ensure that manuals are updated.
- On March 11,1985 NRC letter to APCo stated that G.t. 83 28 concerns were incomplete.
' On April 4,1985, a meting between NRC staff and APCo (R. P. Mcdonald) to discuss the APCo position and NRC concerns.
' On April 22,1985 APCo letter to NRC stating that a response to the March 11,1985 NRC request for additional information-on Section 2.2.2 of Generic Letter 83 28 was not required based on the April 4,1985 meeting between the NRC and APCo.
- On July 5,1985, estimated completion date for CAR 830 revised from July 1,1985 to January 1,1986. Reason stated in CAR is that the solution requires revision of vendor manuals. NETS was requested to coordinate.
' On January 3,1986, esti.nated completion for CAR 830 revised from January 1,1986 to July 1,1986. Reason given was that FNP, NS and designer are developing reconnendations to improve the update process for vendor manuals. Rctomendation will be presented to management. -
- On February 13,1986, ES 86 575 issued to Bechtel and SCS for pilot program to revise vendor manuals and drawings to. their current status.
Pilot program enveloped 25 or 250 such documents.
- On June 30, 1986, estimated completion date for CAR 830 revised from July 1,1986 to December 15,1986. Reason stated that cross index had j
not been satisfactorily resolved, j
- On August 20,1986. ES 86 696 issued to Bechtel with an authorization of 3800 manhours to:
Phase 1) Develop cross reference between each EQ item on the Master 1.ist and all applicable domestic drawings, vender manuals -
' and vendor drawings. Completed January 30,1987.
t l Phase 2) Research all PCNs with WCWs to. determine those which could impact the EQ Master 1.ist and revise documents to reflect
! the WCN. Scheduled for completion March 31,-1988.
4 I !
; l 1
'8 ' ,, _ Page 41 of 50
. Enc 91 sure 3 NRC EQ Audit Findings Status 50/348, 364/87 30-03 Page Three
- 11. Sequence of Events (continued)
- On September 18, 1986, completion date for CAR 830 revised from December 15,1986 to October 1,1987 based on requested dates given in ES 86-696.
- On December 15, 1986, NRC SER on Section 2.2.2 of Generic Letter 83-28 issued accepting the APCo program with exception. The exception consists of a requirement for APCo to expand the formal vendor contact -
progran with vendors.
- On January 30,1987 Phase 1 (cross reference) completed by Bechtel and transmitted to APCo.
- On March 17,1987 APCo letter to NRC stating objection to the SER on Section 2.2.2 of Generic Letter 83 28. The objection was to the requirement imposed by the SER for APCo to expand the APCo fonnal vendor contact program.
- On October 1,1987, estimated completion date for CARB30. Revision 2, revised from October 1,1987 to March 31,1988 due to ongoing work by Bechtel on Phase 11 of ES Bb696.
111. Imediate Corrective Action
- Designers were required to review procedures to ensure that adequate controls exist and are applied to guarantee vendor drawings and manuals are revised to reflect design changes henceforth. (Ref.: letter NT-84 1274 f rom W. G. Hairston,111 to J. D. Woodard, dated 12/18/84).
i G 4
't, ,
. . . . - . . . . . ,. . . .. .s -
3 NRC EQ Audit findings Status 50/3< 364/87 G 03
- ge Four IV. Analysis of Events i
- APCo has been actively involved with the NRC and NUTAC on the issues ,
identified by G. L. 83 28. This is an emerging area and APCo does not believe that it is appropriate to identify a violation for untimely corrective action in EQ audit for an issue that is of broader scope than l EQ and remains in negotiations between the NRC and industry.
- APCo did not close-the CAR when original was satisfied; however the scope of the CAR was expanded at each revision. NRC acce sted the NUTAC posttion on 2.2.2 as documented by NRC letter dated Decem)er 15, 1986.
The only issue remaining open'(per NRC letter referenced above) was by vender contact program. Review by Region 11 inspectors found no violation as documented in inspection report dated April 23,1985. Y. Long Term Corrective Action
- None.
l VI. Date of full Compliance ,
' The CARB30 should be completed by March 31, 1988.
VII. Conclusions
- APCo does not agree that this finding is~4 violation.
- CAR 830 addresses G. t. 83 28 issues which are outside the scope of EQ.
A violation for untimely corrective action in an EQ audit inspection to a CAA that addresses issues outside CQ is not valid.
- Additionally, based on a review of work history anJ physical inspections conducted by APCo, no safety issues resulted from the use of these vendor manuals or documents while performing maintenance on EQ equipment.
- As items were closed, new issues were identified tnit' related to the issue. To f acilitate tracking, APCo decided to revite the existing CAR ~
as additional items were identified, rather than close the CAR and initiate. others. I
- Notwithstanding all of the above,. APCo decided within one year to revise all manuals-on design change work henceforth. This completed the root cause corrective action. Enhancements, such as the cross reft >ence ,
index, were completed subsequent to this date-and the retrofit work of ' l updating technical manuals from pre 1984: design changes was initiated I (to be completed March 1988). It should be noted that-this exceeds the - commitments made for G. l. 83-28 Section 2.2.2.
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. ,,~.-w ,,.& --, , + -,,4%~ .m.
.W. Enclosure 3 Page 43 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30 04 1 Restatement of HRC's description of finding
- HRC designated this as unresolved. See Paragraph 6.h, page 17.
Failure to train personnel involved in EQ activities in the requirements of the EQ program.
!!. Sequence of Events
- Craf t personnel were trained en EQ prior to the audit. ,
- NRC EQ audit identified a concern related to failure to train Technical Staff and Management personnel in EQ activities.
l 111. Imediate Corrective Action
' Plant training plan has been revised and requires training for Technical Staf f and Managers.
- The FNP QC engineer and his staff, and the Plant Modifications group have been trained since the EQ audit.
- Appropriate G. O. staff personnel have also been trainst since the EQ audit.
- Licensed operators will be trained as part of upcoming requalification training.
IV. Analysis of Event
- N/A Y. Long Term Corrective Action
- N/A VI. Date of Full Compilance
- Training plan, " Technical Staff and Manager Curriculum Guide" was revised on February 8,1988 to address EQ training for the Technical Staff and Managers.
Y!!. Conclusions
- There is no safety significance in this finding. This is an enhancement to the EQ program.
' It is APCo's position that this item can be closed based upon corrective action listed in Section !!!.
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Enclosure 3 - Page'44 of 50 A , i 1 1 GEMS 12VI2, SANSMITITRS 355UE3
- O!L, SEALS MD SPLICES
- AGING EFFICTS t
t 0 l I s 9 ( i 1 i l- } 4 8 9 r
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W' - Enclosure 3 Page 45 of 50 NRC EQ Audit Findings Status 50/348, 364/87 30-05 and
*. 50/348, 364/87 30-06
- 1. Restatement of NRC's description of finding
- 50/348, 364/87-30 05 NRC designated this as unresolved. See Paragraph 6.1.(1), page 19:
Thermal and radiation effects not evaluated for lead wire insulation, " terminal blocks and resistors for the GEM's level transmitter (XH 36495 Wide Range). 4
' 50/348, 364/87-30-06 NRC designated this as a violation. See Paragraph 6.i.(1) page 19:
The licensee found wide range and narrow rangc containment sump level . transmitters on both units, in a configuration that was not con;idered qualified by existing test data.
- 11. Sequence of Events GEMS Wide Range transmitters documented qualification configuration was based on a test report which used a junction box with a terminal block and RTV 60 to seal the conduit entrance to the junction box. G. E. type
. F-50 silicon fluid was used in the junction box and transmitter housing. (If the RTV 60 had failed, the silicon fluid wauld have still covered all age sensitive parts (by approximately 1/8").)
- The Harrow Range transmitter's configuration was based on the GEMS test report which used a junction Mx with a Raychem splice rather than a
; terminal block. The junctira Dox had a ninaty degree elbow at the conduit entrance rather than kTV-60 to conta'n the Dow Corning 710 i silicon fluid which covered the age sensitive parts.
I i
- Walkdor Unit 2 Wide Range transmitters on October 10, 1987 discove..e that the only deviation from the tested configuration was l that there was no fluid in the junction box or transmitter housing.
l 4
- Walkdown for Unit 2 Narrow Range transmitters discovered low fluid levels; however, sufficient fluid levels were found to exist in the
; junction boxes to cover all age sensitive parts.
I I l
Enciosure 3 Page 46 of 50 0 NRC EQ Audit Findings Status 50/348, 364/87-30-05 and 50/348, 364/87-30 06 Par Two
!!. Sequence of Events (continued)
' Walkdown for Unit 1 Wide Range and Harrw Range transmitters on October 10,1987 discovered the following deviations from the tested configuration:
- For the Harrow Range transmitters, V-taped splices were found in lieu of the Raychem splice.
For both tk Narrow Range and Wide Range transmitters, fluid levels l were found to be low; however, suf ficient fluid levels were found to l exist in the Harrow Range. transmitter junction bnxes to cover all ! age sensitive parts.
- For the Wide Range transmitter junction boxes, approximately one ,
inch of the lead wire and terminal block was exposed. 111. Immediate Corrective Action
- Unit 2 Wide Range transmitters were replaced with identical transmitters prior to startup from the Unit 2 fif th refueling outage.
- Fluid was added to the Unit 1 Wide Range transmitter junction box on October 13,1987 and October 14,1987.
- Additionally, the Wide Range transmitters on both units were upgraded by PCWs 87 2-4583 (November 19,1987) and 87-1-4587 (December 10, 1987) to provide the same Cable elbow entrance into the transmitter junction box that was used on the Harrw Range transmitter junction boxes and all transmitters have Dow Corning 710 silicon fluid.
- Fluid was added to the Unit.1 Harrow Range transmitter junction box and Y-tape splices were replaced with Raychem splices on December 10, 1987 and December 12,1987.
- Note: Unit 2 Wide Range transmitters were replaced under APCo WR's 138990 and 138991.
IV. Analysis of Event
- This item was identified prior to the NRC 7udit by APCo an(
corrective actions were initiated and escribed in III. ,
nc o ure 3 Page 47 r # 50 NRC EQ Audit Findings Status 50/348,364/87-30-05 and 50/348, 36a/87-30 06 Page Three IV. Analysis of Event (Continued)
- Emergency procedures wert reviewed to identify usages for the wide and narrow range containment sump level indications during accident conditions. Evaluation of the usages concluded that they were either limited to accident scenarios which were beyonc design basis e:cidents l or their usage was redundant to other indications listed in the procedure which would be available to the operator.
i V. l.ong Tem Corrective Action -
- Maintenance procedures have been revised to require fluid level inspections at each refueling outage for each unit. The app 1tcable
- procedures are STD 206.1, 206.2, 224.2 and 224.3.
VI. Date of Full Compliance November 14,1987 VII. Conclusions
- The as-found condition of these instruments did not impact safe operation or create a condition adverse to safety.
- The wide range instruments may be used by the operator as an additional source of information to terminate safety injection. The primary source is RWST level indication.
- The narrow range instrument's function is leak det.ection. They have no active safety function to perfonn during or following a design basis .
accident. e
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E$ closure 3 Page 48 of 50 STILAN CAB!2 ISSUE 9
- STIIR1 CABiz APPLICAT!at (R.G.1.97 - coPI alt 'ntr.PMXWPLE) h 0
1 5 4 4 I
... .. .__U-___-.____.___________ .___m_ ____._ _ _ . ..
A _.A _ Enclosure 3 Page 49 of 50 NRC EQ Audit Findings Status 50/348, 364/87-30 10
- 1. . Restatement of NRC's description of findi19
- The NRC has designated this as unresolved. See Paragraph 14, page 24:
Raychem Stilon (sic) cable test data does not support qualification for the use of this c'a'Sle in instrument circuits, paragraph 6.1.(14).
!!. Sequence of Events
- NRC had questions on the Stilan cable qualification report and questioned where it is used. The test report identified a *1ess than' insulation resistance value which has no meaning.
- This was identified late in the audit and did not allcw sufficient time for APCo to pursue the question.
- Af ter further investigation with Raychem, additional documentation to address the question was not available due to the age of the report.
111. Imediate Corrective Action
' N/A 1.' . Analysis of Event
' The only E0 system which utilizes stilan cable at FNP is the core exit thermoccui;le system
' The core exit thermocouple system is required to be environmentally qualified by Reg. Guide 1.97. APCo comitted t: ensure compliance with Reg. Guide 1.9 ' by the end of the Unit 1 eighth and the Unit 2 fif th refueling outages, respectively as documented by APCo response to Reg.
Guide 1.97, dattd March 30, 1984 for Unit 2 and June 29, 1984 for Unit 1.
- The NRC issued an order dated June 12,1984 requiring implementation (installation or upgrade) of Reg. Guide 1.97 parameters by March 1988 (eighth refueling outage) for Unit 1 and by October 1987 for Unit 2.
- The NRC issued an SER on "% Guide 1.97 dated January 7,1987 that enclosed the EG&G Idaho . . Toe conclusion was that APCo conforms to or is justified in des sing from Reg. Guide 1.97.
- The Stilan cable has been peplaced as part of the Reg. Guide 1.97 upgrade for Unit 2 and will be for Unit 1 during the eighth refueling outage. ,
' Stilan is on the EQ Master List in error.
- The core exit thermocouple system will be added to the EQ program documents af ter the Unit 2 fif th and the Unit 1 eighth refueling outages respectively.
l
. , , . . . , ~ . _ _ . . .
'Edcidsu're3 Page 50 of 50-o
-NRC EQ Audit Findings Status 50/348,364/87-30-10
- _( Page Two)
V. Long Term Corrective Action
' The Stilan cable package will be removed from the EQ central file af ter replacement of the cables.
C VI. Date of Full Compliance , i i
- N/A VI; . Conclusions
- There is no safety significance of this finding. This is an enhancement _
to EQ program required by RG.1.97. 1
nas b O hb E ,, 4 ' . e [*g UNITED STATES 4 ,,< +, ) l [ 3e g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 205
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'92 mR 13 N Marr F2h. 4 TO ALL POWER REACTOR LICENSEES AND APPLICANTS
SUBJECT:
an ( Tr8mM MODIFIED ENFORCEMENT POLICY RELATING >TO 10 V t 50.49, "EN W NTAL QUALIFICATION OF ELECTRICAL EQUIPMENT IMPORTANT 'M. TO SAFETY i.0 CLEAR l POWER PLANTS" (GENERIC LETTER 88-07) Bachround: Generic Letters, Bulletins, and Information Notices have been issued to provide guidance regarding the application and enforcement of 10 CFR 50.49, "Euvironmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants." Generic Letter 85-15, issued August 6,1985, and Generic Letter 86-15 issued s i' September 22, 1986, provided information related to the deadlines for, compliance with 10 CFR 50.49 and possible civil penalties applicable to licensee:. who were not in compliance with the rule as of the November 30, 1985 deadline. Upon review, i the Comission found that the EQ Enforcement Policy promulgated in Generic Letter i 86-15, could result in imposition of civil penalties that did not properly reflect the in thesafety past.significance of EQ violations with respect to civil penalties imposed the Commission determined that the EQ Enforcement Policy The should purpose of this letter is to provide a modification to the NRC's enforcement . po\ icy, as approved by the Comission, for environmental qualification (EQ) violations. and 86-15. This letter v laces the guidance provided in Generic Letters 85-15 Modified EQ Enforcement Policy _ 4 The details of the modified EQ enforcement policy are provided in the enclosure. Generally, the changes made to the policy are to: (1)aggregatesignificant EQ violations together, rather than consider each separate item of unqualified electrical equipment, for assessment of a civil- penalty, (2) assess a base civil penalty according to the number of systems or components which are affected , by the unqualified equipment in a graded approach by assignment of the aggregate EQ$750,000 of problem into one of three categories, (3) establish-a maximum EQ civil penalty for most cases, (4) maintain a minimum civil penalty of $50,000 for a significant EQ violation in most cases, and (5) consider mitigation or escalation of the base civil penalty based on the factors of identification and reporting, best efforts to com , and duration of the violation.plete EQ within the deadline, corrective actions, This modified policy should not be interpreted as a lessening of the NRC's intention to assure that all plants comply with EQ requirements. The modified
" policy is intended to give a significant civil penalty to those licensees with significant EQ violations. The NRC's view is that the modified policy more closely reflects the relative safety importance of EQ violations with other enforcement issues.
Safety Issues When a potential deficiency has been identified by the NRC or licensee in the environmental qualification of equipment (i.e., a licensee does not-have aa
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Generic Letter 88-07 April 7, 1988
'1 adequate basis to establish qualification), the licensee is expected to make a prompt determination of operability (i.e., the system or component is capable of performing its intended design function), take imediate steps to establish a plan with a reasonable schedule to correct the deficiency, and have written justification for continued operation, which will be available for NRC review.
The licensee may be able to make a finding of operability using analysis and partial test data to-provide reasonable assurance that the equipment will perform its safety function when called upon. In this connection, it must also be shown that subsequent failure of the equipment, if likely under accident conditions, will not result in significant degradation of any safety function or provide misleading information to the operator. The following actions are to be taken if a licensee is unable to demonstrate equipment operability:
- a. For inoperable equipment which is in a system covered by plant technical specifications, the licensee shall follow the appropriate a: tion statements. This could require the plant to shut down or remain shut down.
- b. For inoperable equipment not covered by the plant technical s' pecifications, the licensee may continue reactor operation:
- 1. If the safety function can be accomplished by other designated equipment.that is qualified, or
- 2. If limited administrative controls can be used to ensure the safety function is performed.
The licensee must also evaluate whether the findings are reportable under 10 CFR 50.72 and 50.73, 10 CFR Part 21, the Technical Specifications or any other pertinent reporting requirements, including 10 CFR 50.9(b), particularly if equipment is determined to be inoperable. This letter does not require any response and therefore does not need approval of the Office of Management and Budget. Coments on burden and duplication may be directed to the Office of Management and Budget, Reports Management Room 3208, New Executive Office Building, Washington, DC 20503. Should you have questions on this letter, the staff contact is Howard Wong, Office of= Enforcement. He can be reach on (301) 492-3281.
%dd 3 .
Frank J. MWaglia Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated w
4 o ENCLLURE MODIFIED ENFORCEMENT POLICY FOR EQ REQUIREMENTS This enclosure provides the details of the modified enforcement policy for EQ requirements for those licensees who were not in compliance with 10 CFR 50.49 as of the November 30, 1985 deadline. I. Scope of the Enforcement Policy for EQ Reouirements If violations of the EQ rule identified at plants operating after November 30, 1985 existed before the deadline and the licensee " clearly knew or should have known" of the lack of proper environmental qualifi-cation, then enforcement action may be taken as described in Sections III and IV. If the licensee does not meet the " clearly knew or should have known" test, no enfor tement action will be taken. This enforcement policy applies to violations of the EQ rule identified after November 30, 1985 which relate back to action or lack of action before the deadline. Violations which occurred after Neve@er 30, 1985 (either as a result of plant modifications or because the p Lnt was-licensed after November 30, 1985) will be considered for enforcement action under the normal Enforcement Policy of 10 CFR Part 2. Appendix C. In addition,-EQ violations which are identified after the NRC's last-- first-round inspection, J/ approximately mid-1988, will also be considered under the normal Enforcement Policy. II. Application of the " Clearly Knew, or Should Have Known" Test Licensees who " clearly knew" they had equipment for which qualification ' could not be established may have comitted a deliberate violation of NRC requirements. This situation will be evaluated on a case-by-case basis. The NRC will examine the circumstances in each case to determine whether the licensee " clearly should have known* that its equipment was not quali-fled. The factors the NRC will examine include:
- 1. Did the licensee have vendor-supplied documentation that demonstrated that the equipment was qualified?
- 2. Did the licensee perform adequate receiving and/or field verification inspection to determine that the configuration of the installed equi) ment matched the configuration of the equipment that was qualified by tie vendor?
- 3. Did the licensee have prior notice that equipment qualification deficiencies might exist?
- 4. Did other licensees identify similar problems and correct them before the deadline?
J/ First-round inspections are special team inspections to review licensees' compliance with 10 CFR 50.49. i -
4 Enclosure In assessing whether the licensee clearly should have kn'own of a deficiency, the information provided to the licensees by the NRC and the industry on specific deficiencies will be taken into consideration. This information, and the timeliness of it being provided to licensees prior to the EQ deadline are relevant factors. If one licensee determined that a s)ecific EQ deficiency existed, it would not be assumed that all Itcensees siould have also come to the same conclusion unless information about the specific deficiency had been widely disseminated within the industry or by the NRC. The staff will carefully consider these criteria when evaluating whether a licensee cleely should have known of a deficiency prior to the deadline. III. EO Violations not Sufficiently Sionificant to Merit a Civil Penalty Under the Modifieo Policy Any failure to adequately list and demonstrate qualification of equimnent required by 10 CFR 50.49 may constitute a violation of the rule. This does not require, however, that all violations of the rule be considered for escalated enforcement or be assessed a civil penalty. For example, if the qualification file presented to the inspector during an inspection did not demenstrate or support Qualification of equipment, the' equipment would be considered unqualified 2/ and 10 CFR 50.49 requirements would be violated. However, although not G the qualification file, if sufficient data exists or is developed during the inspection to demonstrate qualification of the equipment cr. based on other 1-formation available to the inspector, the specific equipment is qualifia.le for the application in question, the qualification deficiency is not considered sufficiently significant for assessment of civil penalties. These violations would be considered to be Severity Level IV or Severity Level V violations based on a violation of 10 CFR 50.49 requirements at the time of the inspection. Programatic violations or problems that are identified as a result of the EQ inspections that involve several EQ violations which themselves would no* be considered sufficiently significant to merit a civil penalty under the modified EQ enforcement policy nonetheless may be aggregated and evaluated for escalated enforcement action (generally Severity Level III) for the failure to satisfy applicable requirements of 10 CFR 50.49 and/or 10 CFR Part 50, Appendix B. The civil penalties for these violations would be assessed under the normal Enforcement Policy of 10 CFR Part 2. Appendix C (Supplement I). IV. Basis for Determining Civil Penalties A. Base Civil Penalty Significant EQ violations, for which the licensee clearly should have known that they had equipment for which qualification had not been established. 2/ For purposes of enforcement " unqualified equipment" means equipment for which there is not adequate documentation to establish that this equipment will prform its intended functions ir the relevant environment.
4 S Enclosure are to be considered together, in the aggregate, and the base civil penalty assessed in a graded approach based on the riumber of systems or components affected. 3/ The base civil penalty would be determined as described below. EQ Violation Category Base Civil Penalty A. Extensive; EQ violations affecting many $300,000 systems and many components. B. Moderate; EQ violations affecting some $150,000 systems and some components. C. Isclated; EQ violations affecting a $ 75,000 limited number of systems and components. The three EQ violation categories reflect the overall pervasiveness and the general safety significance of significant EQ violations. The NRC considers violations of EQ requirements to be safety significant because the electrical equipment required to be qualified were those which have , importance to safety. The violation categories do not include those EQ violations which have been determined to be not sufficiently significant i standing alone to be considered for escalated enforcement and which will be norna11y considered as Severity Level IV or V violaticos, as described in Section III. As stated in Section III, however, programatic problems may be the subject of escalated enforcement action under the NRC's normal Enforcement Policy. The significance of the EQ violations is considered when the NRC evaluates the number of systems affected by the EQ violations and determines the EQ violation category. The NRC will assume, for escalated enforcement cases, that the unqualified equipment could affect operability of the associated s l system. The NRC will not consider refinements on the operability arguments such as the actual time the equipment is required to be operable, admini- Q, strative measures or controls available to ensure the safety function is g accomplished, the degree to whi;h the operability of a system is affected, or, that through additional analyses or testing, the equipment may be demonstrated to be qualified or qualifiable. This assumption is made for l enforcement purposes in order to reduce the resources anticipated to be I spent by licensees and the NRC to evaluate in detail whether system ope.rability was in question.
~~
l .
~
3/ The EQ violation categories (A-C) will be used rather than the severity levels in the normal Enforcement Policy of 10 CFR Part 2. Appendix C. The base civil penalty for the violations will be applied consistent with the statutory limits on civil penalties under Section 234 of the Atomic Energy Act.
Enclosure Because the NRC is considering enforcement action rather than a justifica-tion for continued operation and the EQ deficiencies have been corrected in most instances, the NRC will make a conservative judgment'as to the overall safety significance of the EQ violations based on the number of safety systems affected. This approach has the benefits of a relatively quick, though conservative, view on the safety consequences of unqualified equipment and will focus on the underlying cause of the E0 violations. Cases involving deliberate violations or very serious EQ violations (more safety significant than considered in this modified enforcement policy such as widespread breakdowns or clearly inoperable systems) will be evaluated on a case-by-case basis and may be subject to more severe sanctions than those described in this policy. B. Mitioation/ Escalation Factors Mitigation and escalation of the base civil penalty determined in Section IV.A will be considered in the determination of the civil >enalty amount. The NRC will consider the EQ violations in aggregate, not )ased on individual violations. Adjustment of the base civil penalty will be considered as described below: Mitication/ Escalation Factors Maximum Hitiption/ Escalation Amount (from L base civil penalty)
- 1. Identification and prompt reporting, if required, 50%
of the EQ violations (including opportunities to identify and correct the deficiencies).
- 2. Best efforts to complete EQ within the deadline, t 50%
- 3. Corrective actions to result in full compliance t 50%
(including the time taken to make an operability or qualification determination, the quality of any supporting analysis, and the nature and extent of the licensee's efforts to come into compliance).
- 4. Duration of violation which is significantly below - 50%
100 days. In order to be fair and equitable to those licensees who took appropriate actions prior to November 30, 1985 or shut down prior to this date to be in compliance, civil penalties generally should not be less than $50,000 to emphasize that a significant environmental qualification failure is unacceptable., The NRC will, however, konsiderifull mitigation (no civil penalty) for W f I those EQ violations which satisf alt of the Tive following criteria: f, *A (1) violations which are isolate n affect a limited number of systems and components, (2) violations _hkl.clLArt identined.bylhe_ licensee, 4 (3) violations which are promptly reported to the NRC, if required, (4) violations which are corrected and-ections taken will result in full compliancewithinareasonabletime,Qnd.(5)violationsforwhichthe
~
licensee har iiemenstrated best efforEs ~to complete EQ within the deadline. l _
~
Enclosure - \ The intent of full mitigation of the civil penalty for EQ violations which meet all five criteria is to increase the incentive for self-identificatTon of EQ deficiencies which might not otherwise be found by NRC. The NRC will generally issue only a Notice of Violation for violations which meet all these criteria. If the licensee is able to convincingly demonstrate at the time of the inspection, or shortly thereafter. that an item is not required to be on the EQ list, then the item would not be considered for enforcement action. The NRC does not intend to consider for enforcement pur>oses the results of a licensee's after-the-fact testing for mitigation w1ere the licensee clearly should have known that its documentation was not sufficient. O
. --- - --- - - - - - - - ' ' - - - ~ - - - - - - - " ' ' " - - - - - - ' - ~ - - ~ ~ ~ - - - - ' - - ' ~ - ~ ~
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c . _ - - - - _ - - _ _ _ o LIST OF RECENTLY ISSUED GENERIC LETTERS I "'noric Date of ter No. Subject Issuance Issued To GL 68-06 REMOVAL OF ORGANIZATION CHARTS 03/22/BB ALL POWER FROM TECHNICAL SPECIFICATION REACTOR ADMINISTRATIVE CONTROL LICENSEES AND REQUIREMENTS APPLICANTS GL 88-05 BORIC ACID CORROSION OF CARBON 03/17/88 ALL LICENSEES STEEL REACTOR PRESSURE OF OPERATING BOUNDARY COMPONENTS IN PWRS AND PWR PLANTS HOLDERS OF CONSTRUCTION PERMITS FOR PWRS GL 88-04 DISTRIBUTION OF GEMS O2/23/08 ALL NON-POWER IRRADIATED IN RESEARCH REACTOR REACTORS LICENSEES GL 80-03 RESOLUTION OF GENERIC SAFETY O2/17/88 ALL LICENSEES. ISSUE 93, " STEAM BINDING OF APPLICANTS FOR AUX 1LIARY FEEDWATER PUMPS" OPERATING LICENSES, AND HOLDERS OF CONSTRUCTION PERMITS FOR PRESSURIZED WATER REACTORS GL B8-02 " INTEGRATED SEFETY ASSESSMENT 01/20/88 -ALL POWER PROGRAM !! (15AP II)" REACTOR LICENSEES GL B8-01 "NRC POSITION ON IGSCC IN BWR 01/25/98 ALL LICENSEES AUSTEN1 TIC STAINLESS STEEL OF OPERATING PIPING" BOILING WATER REA* TORS AND HOLDERS OF CONSTRUCTION PERMITS FOR BWRS GL B7-16 NUREG-1262, " ANSWERS TO 11/12/87 ALL POWER AND OUESTIONS AT PUBLIC MEETI 4GS NONPOWER RE IMPLEMENTATION OF 10 f.FR55 REACTOR DN OPERATORS LICENSEES AND LICENSES APPLICANTS FOR LICENSES P B7-15 POLICY STATEMENT ON DEFERRED 11/04/87 ALL HOLDERS OF PLANTS CONSTRUCTION PERMITS FOR A NUCLEAR POWER PLANT GL B7-14 REQUEST FOR OPERATOR LICENSE 0B/04/B7 ALL POWER SCHEDULES REACTOR
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(, N/ - 92 m o n2 m2 March 2, 1988 POLICY ISSUE sem p Fer: The ComisdNfnGATIVE CONSENT) Frem: Victor Stello, Jr. Executive Director for Operations
Subject:
PROPOSED GENERIC LETTEP ON MODIFIED ENFORCEMENT POLICY RELATED TO 10 CFR 50.49 (ENVIRONMENTAL QUALIFICATION OFELECTRICALEQUIPMENT) P0recse: To request Ccmission approval of the staff's proposed generic letter advising the industry of the changes to the enforcement policy related to the environmental qualification of electrical equipment (10 CFR 50.49). Discussion: Generic Letters 85-15 and 85-15, sent to NRC licensees on August 6, 1985 and September 22, 1986, respectively, set forth the NRC enforcement criteria, which were approved by the Commission, applicable to those licensees whc were not in compliance with 10 CFR 50.49 as of the November 30, 1985 deadline. In SECY 87-255, the staff prcposed to the Ccmmissicr. modificatiun of the enforcement policy for such EQ violations, The Comission approved the staff's proposec modification, with changes, as described in the staff requirements retorancum dated January 12, 1988. The staff recuirerents menoranoum also reeuested that the staf' sttrit to the Commissien for its cer.sent the prcposed gereric letter. The proposed geretic~1etter (enclosed) is intended to replace Generic Letters 85-15 and 85-1E and incorperates the charges to the EQ enforcement policy as approved by the Commission. Recorre Na tinn: Th'e staff intends to issue the propcsed generic letter which cerrmunicates the changes made to the FO enforcement policy two weeks trom the date of this paper unless the Commission directs otherwise. Coordinatior: OGC ha*, no legal objection to this paper. , y 3[
~ ff ' kd5[
cto'rGleUh,JO ' Executive Director for Operations , ,o
- c. .
Enclosure:
Preposed Generic Letter ' CONTACT:
- p. g .gg741) bb3Mo357
~
2-SECY !?OTE: In the absence of instructions to the contrary, SECY will notify the staff on_ Friday', March 19, 1988, that the Commission, by negative consent, assents to the action proposed in this paper. DISTRIBUTION: Commissioners OGC (H Street) OI OIA
'J .' A REGIOMAL OFFICES EDO OGC (NF)
- ACRS ASLBP ASLAP SECY e
e 9-
. l
TO ALL LICENSEES AND HOLDERS OF AN APPLICATICk FOR AN OPERATING LICENSE GENTLEMEN:
SUBJECT:
MODIFIED ENFORCEMENT PCLTCY RELATING TO 10 CFR 50.49, " ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANTS" (GENERIC LETTER 88-XX)
Background:
Generic Letters Bulletins, and Infomation Notices have been issued.to provide guidance regarding the application and enforcement of 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants." Generic Letter 85-15, issued August 6,1985, and Generic Letter 86-15, issued September 22, 1986, provided irfomation related to the deadlines for compliarce with 10 CFR 50.49 and possible civil penalties should licensees operate in noncompliance with the rule. The purpose of this letter is to provide a modifi-cation to the NRC's enforcement policy, as approved 'by the Comission, for environmental qualificatien (EQ) violations. This letter replaces the guidance provided in Generic Letters S5-15 and 80-15. Modifieo EO Enforcement Policy The details of the modified E0 enforcement policy are provided in the erciosure. Generally, the changes made to the policy are to: (1) aggregate significant EQ violations together, rather than consider each separate item of unqualified electrical equipment, for assessment of a civil penalty, (2) assess a base - civil penalty according to the number of systems or corpenents which are af#ected by the unqualified equiprent in a graded approach by assignment of the aggregate E0 problem into one of three categories. (3) establish a maximum EQ civil penalty of $'50,000 for most cases (4) maintain a ninimum civil penalty of 550,000 for a significant EQ violation in rest cases, ano (5) consider nitigation or escalation of the base civil penalty based on the factors of ioentification and reportitig, best efforts to corplete EQ within the deadline, corrective actions, and duration of the violation. While the rodified EQ enforcement policy may in seme cases reduce the amourt of a civil penalty for significant E0 violations, this modifiec policy should not be interpreted as a lessening of the NRC's intention to assure that all plants comply with EQ receirements. The modified policy is intended to give a significant civil penalty to those licensees with sienificant EQ violations. The NRC's view is that the modified policy more closely reflects the relative ir:portance of EO violations with other enforcenent issues. Safety Issues _ When a potential deficiency has been identified by the NRC or litersee in the environmental cualification of equipment (i.e., a licensee does not have an adequate basis to establish qualification), the licensee is expected .to make a
i.- I-Generic Letter 88- : proirpt determination of operability (i.e., the system or component is carable of performing its intended design function), take imediate steps to establish a plan with a reasonable schedule to correct the deficiercy, and have written justification for continued eperation, which will be available for NRC review. The licensee may be able to make a finding of operability using analysis and 2 pertial test data to provide reasonable assurance that the equipment will perform its safety function when called upon to function. In this connection, it rust also be shown that subsequent failure of the equipment, if likely under accident conditions, will not result in significant degradation of any safety function or provide misleading inforination to the operator, i The following actions are to be taken if a licensee is unable to demonstrate equipment operability. i i a. For inoperable equipment which is in a system covered by plant technical specifications, the licensee shall fcilow the appropriate action statements. This could require the plant to shut down or remain shut down. ] I b. For inoperable equipment not covered by the plant technical
- specifications, the licensee may continue reactor operation:
- 1. If the safety function can be accomplished by other decignated.
equipment that is cualified, or
- 2. If Timited administrative controls can be used to ensure the sa'ety function is performed.
The licensee r",st also evaluate whether the findings are reportable under
- .10 CFR 50.72 and 50.73, 10 CFR Part 21, the Technical Specifications or any '
i other pertinent reporting requirements, including 10 CFR 50.9(b), particularly if ecuipment is determined to be ineperable. This letter does not require any response and therefore dces not need approval ef the Office of Management and Budget. Comments on burden ancl duplicatier, r ay be directec to the Office of Management and Budpet, Repcrts Managenert Room 3008, New Executive Office Building Washington, CC 20503. Should you have cuestions on this letter, the staf# rentact is Howard Wong, Office of Enforcement. Pe can be reach en (301) 492-3281. Frank J. Miraalia Associate Director Office of Nuclear, Reactor Reculation
Enclosure:
As stated l
., . ~ . _ _ , _. . ,
ENCLOSURE PODIFIED ENFORCEMENT POLICY FOR EQ REQUIREMENTS ! This enclosure provides the details of the modified enforcement policy for EQ - requirements for those licensees who were not in compliance with 10 CFR 50.49 as of the November 30, 1985 deadline. l I. Scope of the Enforcement Policy for EO Recuirerents t l If violations of the EQ rule identified at plants operating after November 30, 1985 existed before the deadline and the licensee " clearly l knew or should have known" of the lack of proper environmental qualifi-
- cation, then enforcement action may be taken as described in Sections III J and IV. _If the licensee uoes not meet the " clearly knew or should have i known" test, no enforcement action will be taken.
This enforcement policy applies to violations of the EQ rule identified after November 30.-1985 which relate back to action or lack of actier, before the deadline. Violations which occurred after November 30, 1985 (either as a result of plant modificatiens or because the plant was licensed after November 30,1965) will be censidered for enforcement i action under the nomal Enforcement Policy of 10 CFR Part 2 Appendix C. In addition EQ violations which are identified after the NRC's last first-round inspection, 1/ approximately mid-1988, will also be considered under the nomal Enforcement Policy. II. Application of the " Clearly Knew, or Should Have Known" Test Liewnsees who "cleerly knew" they had equipment for which qualification could not be established may have comitted a deliberate violation of NRC requirements. This situation will be evaluated on a case-by-case basi,s. The NPC will examine the circumstances in each case to detemine whether the licensee " clearly should have known" that its equipment was not quali- - fjed. The factors the NRC will examine include:
- 1. Did the licensee have vendor-supplied docunentatier that demonstrated that the equipment was cualified?
- 2. Dio the licensee perfom adequate receiving and/or field verification inspection to detemine that the configuration of the installed equipment matched the configuration of the eouipment that was qualified by the vendor?
- 3. Did the licensee have prior notice from any source that equipment qualification deficiencies might er.ist?
- 4. Did some licensees identify similar problems and correct them before the ceadline?
1/ First-round inspections are special team inspections to review licensees' compliance with 10 CFR 50.49. .
t Enclosure . In assessing whether the licensee clearly knew or clearly should have known of a deficiency, the information provided to the licensees by the NRC and the industry on specific deficiencies will be taken into corsideration. This information, and the tireliness of it being provided to licensees prior to the EQ deadline are relevant factnrs. If one licersee determined that a specific EQ deficiency existed, it would not be assumed that all licensees should have also come to the same conclusion unless information about the specific deficiency had been widely disseminated within the industry or by the NRC. The staff will carefully consider these criteria when evaluating whether a licensee clearly should have known of a deficiency prior to the deadline. III. EO Violations not Sufficiently Significant to Merit a Civil Penalty Under the Moo 1fied Policy Any failure to adequately list and demonstrate qualification of equipment required by 10 CFR 50.49 may constitute a violation of the rule. This does not require, however, that all violations of the rule be considered for escalated enforcement or be assessed a civil penalty. For example, if the qualification file presented to the inspector during an inspection did not demonstrate or support qualification of equipment, the equipment would. be considered unqualified 2/ and 10 CFR 50.49 requirements would be violated. However, although not fii the qualification file, if sufficient data exists or is documented during the inspection to demonstrate qualification of the equipment or, based on other information available to the inspector, the l specific equipment is qualifiable for the application in question, the qualificatien deficiency is not considered sufficiently significant for assessment of civil penalties. These violations would be considered to be Severity Level IV or Severity Level V violations based on a violation of 10 CFP, 50.49 requirements at the time of the inspectier. Pregrammatic violations or problems that are identified as a result of the EQ inspections that involve several EQ violations which themselves would ont be considered sufficiently significant to merit a civil penalty under the modified E0 enforcement policy renetheless may be aggregated and eveluated for escalated enforcement action (gererally Severity Level III) for the failure to satisfy applicable requirements of 10 CFR E0.a9 ana/or 10 CFR Part 50 Appendix B. The civil peralties for these violations would be assessed under the norral Enforcement Policy cf 10 CFR Part 2, Apperdix C (Supplement I). l l IV. Easis for Determining Civil Penalties A. Base Civil Penalty Significant EQ violations, for which the licensee clearly knew or clearly should have known that they had equipment for whicF cualification had not
?_/ For purpcses of enforcement, "unoualified equipment" means eouipment for which there is not adecutte documentation to establish that this equipment will perform its intended functions in the relevant environment.
V e P
, Enclosu're .
been established, a're to be considered together, in the a9gregate, and the base civil penalty assessed in a graded approach based.on the number of systems or components affected. 3/ The base civil penalty would be determined as described below. EQ Violation Category Base Civil Penalty A. Extensive; EQ violations affecting many $300,000 syster.s and many components. 1 B. Poderate; EQ violations affecting some $150,000 t systems and some components. C. Isolated; EQ violations affecting a $ 75,000 limited number of systems and components. The three EQ violation categories reflect the overall pervasiveness and the ger.eral safety significance of significant E0 violations. The NRC considers violations of EQ requirements to be safety sienificant because ; the. electrical equipment required to be qualified were those which have importance to safety. The violation categories do not include those EQ r violations which have been determined to be not sufficiently significant standing alone to be considered for escalated enforcement and which will I be norra11y considered as Severity Level IV or V violations, as described in Section II. As stated in Section II, however, progratmatic problems i may be the subject of escalated enforcement action urder the' NRC's normal Enforcement Policy. The significance of the EO violations is considered when the NRC evaluates the number of systens affected by the EQ violatinns and determines the EQ violation' category. The NRC will assure,'for escalated enforcement ce.ses, that the uncualified eouipment eculd affect operability of _the associated , system. The-HPC will not consider refinements on the operability arguments such as the actual tire the equipment is recuired to be operable, admini-strative measures or controls available to ensure the safety function is acccmplished, the degree to which the operability of a system is affected, or, that through additional analyses or testing, the equipment may be derenstrated tc be cualified or qualifiable. This assumption is made for enforcement purposes in order to reduce the resources anticipated to be spent by licensees and the NRC to evaluate in detail whether system operability was in question. 1 3/ The EQ violation cateoories (A-C) will be used rather than the severity levels in the normal Enforcement Folicy of 10 CFR Part 2, Appendix C. The base civil penalty for the violations will be applied consistent with l the statutory linits on civil penalties under Section 234 of the Atomic Energy Act. {!
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S-/2 Nw do-MT/% Y -W "% z/ & m0 4 W noe0 t MC Staff Exh.12
'92 tim 13 P12:02 Docket Nos. 50-348, 50-364 License Nos. NPF-2 and NPF-8 g y, auCMiiNG '. 4 iW I Bh Ath '
Alabama Power Company v ATTN: Mr. R. P. Mcdonald Senior Vice President P. O. Box 2641 Birmingham, AL 35291-0400 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-348/87-30 AND 50-364/87-30 - This refers to the Nuclear Regulatory Commission (NRC) ins.pection conducted ty N. Merriweather and other NRC representatives during the per_ icds -of November 2-6, 1987 and November 16-20, 1987, at your Farley plant, of activities authorized by NRC License Nos. NPF-2 and NPF-8. At the conclusion of the inspection, the findings were discussed with you and those members of your staff identified in the enclosed inspection report. A Confirmation of Action Letter was also sent to you on December 2,1987, for Unit 1. The inspectors reviewed your implementation of a required program for establishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with ) personnel, and observation of activities in progress, The inspection findings indicate that certain activities appeared to violate NRC requirements. The violations described in the enclosed Inspection Report are under consideration for escalated enforcement action. Accordingly, no Notice of Violation is being issued at this time and no response to this letter is recuired. However, please be advised that the number and charac-terization of violations described in the enclosed Inspection Report may change as a result of further NRC review. An Enforcement Conference to discuss these violations will be scheduled for a future date. You will be advised by separate correspondence of the results of our deliberations on this matter. Ycur attention is invited to the unresolved items identified in the inspection report. These matters will be pursued during future inspections. The violations identified as 50-348, 364/87-30-01 and -02 on page 2 of the-enclosed inspection report are additional examples of a violation identified during an inspection conducted on May 11-22, June 1-5 and June 11 - July 10, 1987 (NRC Inspection Report Nos. 50-348, 364/87-11 and 50-348, 364/87-14). Please provide your corrective actions for these additional examples in a supplemental response to the NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES forwarded to you under separate letter dated November 3,1987.
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In accordance with Section 2.790 of the NRC's " Rules of Practice." Part 2, Title 10, code of Federal Regulations, a copy of this-letter and.its enclosures will be placed in the NRC Public Document Room.- Should you have any questions concerning this letter, please contact us. , Sincerely, m . L, Gnd b # J. Nelson Grace Regional Administrator .
Enclosure:
NRC Inspection. Report cc w/ enc 1:
# 0. Whitt, Executive Vice President '
# D..Woodard, General Manager -
Nuclear Plant . dr. G. Hairston, III, General Ptanager - Nuclear. Support f.W.McGowan, Manager-SafetyAudit and Engineering Review F K. Osterholtz, Supervisor-Safety Audit and Engineering Review bec w/encls: PCResidentInspector DRS Technical Assistant g Reeves, Project Manager, NRR Document Control Desk State of Alabama erw ther:es TC 1 [ed y , RII RII I RIIg RI4 12,17
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.,,,,- c. um. cr e scia ::::3 Report Nos.: 50-348/87-30 and 50-364/87-30 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291-0400 Docket Nos.: 50-348 and 50-364 License Nos.: HPF-2 and NPF-8 Facility Name: Farley Nuclear Plant, Units 1 and 2 Inspection Conducted: November 2-6, 1987 and 7 November 16-20, 1987 Inspector: ., m..w
/ l- 2 ? ~ Yi N. Merriweather, Team Leader Date Signed Also participating in the inspection and/or contributing to the report were:
S. Alexander, Equipment Qualification and Test Engineer T. E. Cenlon, Chief, Plant Systems Section, Region II H. C. Dance, Chief, Project Section 18. DRP J. F. Hanek, t'onsultant Engineer, Idaho National Engineering Laboratory M. Jacobus, Consultant Engineer, Sandia National Laboratories W. Levis, Reactor Inspector, RII E. W. Merschof f, Deputy Director DRS C. Miller, Consultant Engineer, Idaho Material Engineering Laboratory C. Paulk, Reactor Inspector, RII U. Potapovs, Chief, Special Projects Inspection Section, NRR C. Smith, Reactor Inspector, RII i D. M. Verrelli, Chief. Projects Branch 1, DRP H. Walker, Reactor Engineer, NRR R. C. Wilson, Equipment, Qualification and Test Engineer Approved b T. Q ~T. Conlon, Chief
// / .2 b k Date Signed Plant Systems Section Division of Reactor Safety
SUMMARY
Scope: This special, announced inspection was in the area of Environmental Qua'ification (EQ) of Electrical Equipment and included a review of Alabama-Company's (APCO) implementation of the requirements of 10 CFR 50.49; walkdown inspections of electrical equipment within the scope of 10 CFR' a review of the licensee's corrective actions for previously identified
- iencies; and a review of their evaluations of these findings on how ict restart of Unit 2 and continued operation of Unit 1. 1 484r6 poz.t
'!7 348
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. 2 Results: Eleven violations were identified and are discussed in paragraphs 2 and 3.
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e , TAPJ.EY NUCLEAR PIRTI i DNIPOcdL*:AL Ct:ALITICAtlCt1 PROGPM CPGANI; ATIC2{ l l w l 1 E Q TASE TEAM pregrese Meattoring a Manpever Ceerdanation Lob Berrybill Audattaalsty tguay walkdevas Correlatten of Precurement. Tratatag of CTMT. Aus tid. PC's, Master Dedlestaan, g a rtles Marv Ra Laat. !asta14ed storage Equay. Actsvattee David Jones Cliff Buck Lee Williacs/ Larry Enfinger Lee Willian Gene llegi 1 Matatenance Progran pest Maant. Revtew SR Actsvities Document Actavnty Revtew spares To
, Proventatsve 3evolepnent rer !! feet on Assure Precured Correctsve tg Cert. :AW St. 43L Lewis Ward Shipman /Derrybill William Vare Lee Williams e M9 E
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s( l 4 q i REPORT DETAILS i , l 4 / 1. Persons Contacted ! Licensee Employees L . *T. M. Broad, Design Engineer
*C. L. Buck, Discipline Engineer n *L. W. Enfinger, Manager Plant Administration .
! 'J. E. Garlington, Manager Engineering and Licensing-
*W. G. Hairston,: III, Vice President Nuclear Support
} ! *D. H. Jones, Supervisor, Design Support ) *R. P. Mcdonald,-Senior Vice President ! *J. W. McGowan, Manager Safety Audit and Engineering Review j- *B. L. Moore, Training Representative i- *D N. Morey, Assistant General Manager - Operations l C. D. Nesbitt, Technical Manager i *J. K. Osterholtz, Supervisor - Safety Audit and Engineering Review I- *W. B. Shipman, Assistant Plant Manager l *R. W. Stewart, Project Engineer _ l *L. M. Stinson, Plant Modification and Maintenance Support Manager j *W. G. Ware, QC Engineer
*L. S. Williams, Training Manager i . _
- *J. D. Woodard, General Manager, Nuclear Plant ,
*L. A. Word, Maintenance Manager
( l Other licensee employees contacted included ' craftsmen engineers, . technicians, operators, securit" force members, and. office = personnel. l-s Other Organizations ( [ *P. A. D. Benedetto, EQ-Consultant, DBA. Inc.
*J. Love, Project E;;ineer, Bechtel Engineering NRC Resident Inspector i
l
*W. H. Bradford, Senior Resident Inspector t
j
- Attended exit interview
- 2. Exit Interview -
The inspection scope and findings were sumarized on November '20.1987, with those- persons -indicated in paragraph _1. The inspector-_ described'the areas inspected and discussed in detail the inspection ~findingsL listed below. The licensee subsequently presented their' position on each of the findings. In most cases, 'the licensee did- not agree _with the position L taken by NRC. Subsequent to the inspection, one new violation was
- identified because the wide range and narrow range containment sump level 4
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' transmitters were found not to be installed in accordante with the tested I configuration (Item No. 50-348. 364/87-30-06), one previously identified
~
1 unresolved item has -been determined to'be a violation-(Item No. 50-348, 364/87-30-07) for lack of T-drai.ns-.on limitorque motor operated valves, and one new unresolved item was identified as Item No. 50-348, _ 364/87-30-12, for lack of cable entrance seals on certain solenoid valves. In addition, six previously identified unresolved items have been upgraded to violations and are discussed in Paragraph 3 below. The following is a list of new items identified during this inspection. Item Number Descriotion/ Reference Paragraph 50-348, 364/87-30-11 Violatun, Licensee EQ files did not support qualification-for use.of' 5tates (type NT/ZWM) and G.E. (type CRISIB) terminal blocks in instrumentation circuits, paragraph 6.1 (15) 50-348, 364/87-30-08 Violation, Unqualified limit switch installed in a--limitorque valve inside Unit I containment, parsgraph 6.1.(3) - 50-348, 364/87-30-15 Violation, Raycham/ Chico A Seal- - (Package 29G) - NUREG 0588" Category II qualification -not demonstrated because bonding of the Raychem material -to the metal pipe nipple under LOCA conditions
'(including chemical spray) has not been addressed, paragraph 6.1.(32) 50-348, 364/87-30-14 Violation - Qualification not. demon-1 strated for Raychem: seal ~ installed on Target Rock = Solenoid : valve cable entrance seal,; paragraph 6 i~.(31)-
*50-348, 364/87-30-01 . Violation, Use _ of ' unqualified com-mercially _ procured equipment - in : EQ
-applications,-paragraph 6.e.(1)
*50-348, 364/87-30-02 Violation,- Failure to procure replacement - equipment in confomance with.10CFR50.49(L), paragraph 6.e.(2) 50-348, 364/87-30-04 Unresolved --Item, Failure to train-personnel involved in EQ activities in the requirements of the EQ - program, parsgraph 6.h '
- Listed :for record purposes only and not included in the total of 11- !
violations identifed in the sumary section. l 1 , - ...,_ u,__._____ .-_ . _ _ ._._-_a__._..._.-
-3 50-348, 364/87-30-03 Violation, Failure to take prompt and-timely- corrective action for EQ programmatic deficiency identified by SAER staff in 1983, paragraph 6.f-50-348, 364/87-30-09 -Unresolved Item,' EQ file- did L not include _ qualification -for teminal ,
5 blocks used in motor operated valves in that various teminal blocks were identified during walkdowns of limitorque operators, paragraph 6.1.(3)' 50-348, 364/87-30-07 Violation, Some Limitorque Motor-Operated Valves- (MOVs) -inside Unit I containment do not have T-drains - installed. This. condition is not in
- accordance with 'the tested config- '
uration- documented in the files, paragraph 6.1.(3) 50-348, 364/87-30-12 - Unresolved Item, Certain SOVs may not be qualified due to a_-lack of cable entrance seals. This is contrary to the qualification basis. - paragraph ' 6.i.(29)(a),_(b)-and(c) 50-348,364/87-30-06 Violation, The licensee found wide range and narrow range containment sump-i ~1evel transmitters on -both units, in a - configuration that was not considered L -1
.paragraph qualified'6.1. by (existing
- 1) test data, 50-348, 364/87-30-13 Unresolved Item, Automatic . Switch-Company Solenoid. Valves installed in-Unit 1 Containment exceeded ~ their qualifid life, paragraph. 6.i.(29)(d) 50-348, 364/87-30-10. Unresolved Item Raychem Stilon = cable test data .does not support quali-fication for .the use of this cable in instrument circuits, paragraph 6.1.(14)_
50-348, 364/87-30-05 Unresolved Item, Thermal and radiation effects not evaluated Efor lead wire insulation, terminal blocks and' resistors .for the GEMS level trans-- mitter, paragraph 6.1.(1) Although proprietary material was_ reviewed during the inspection, proprietary information is not contained-in this report.
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- 3. Licensee Action on Previous Enforcement Matters
- a. (Closed) Unresolved Items 50-348, 364/87-25-01: Unqualified Splice on Hydrogen Recombiners.
This item is being upgraded to violation 50-348, 364/87-30-16. The licensee operated Units 1 and 2 of the Farley Plant at various power levels for some unknown period of time after November 30, 1985 without adequate documentation in their EQ files to demonstrate that the in-line 5-to-1 field to pigtail tape splice configuration used on the Hydrogen Recombiners would perform its intended function during a design basis accident.
- b. (Closed) Unresolved Items 50-348, 364/87-25-02. A: Procurement of Commercial Grade Components for EQ Applications.
This item is being upgraded to a violation and is discussed in Paragraph 6.e. in this report. -
. (Closed) Unresolved Items 50-348, 364/87-25-02.B: Inadequate Upgrade Program for EQ Components.
This item is being upgraded to a violation and is discussed in paragraph 6.e. in this report.
- d. (0 pen) Unresolved Items 50-348, 364/87-25-03: Inadequate Peer Review Program.
Peer inspections of splice configurations on the containment Pcst-Loca mixing fan motors were inadequate and did not reflect drawing requirements. Recent walkdown inspections of the fan motors showed only the use of T95 tape in V-configuration which are not in accordance with design. Maintenance Work Requests used to deter-minate and reterminate splices during the previous outages on each t unit indicated that the splices were documented as being in accordance with design by an inspection performed by the foreman. Specifically, MWR 147889, completed November 13, 1986, on Unit 1 documented that the splices on containment Post-Loca Mixing Fan l Motors IB and 1C were in accordance with design. However, during the ! recent walkdowns on Unit 1, it was found that these fan motor splices i only had T95 tape in a V-configuration which is not in accordance with design (reference MWRs 159078 and 159079), indicating an inadequate peer review. This item is still considered unresolved,
- e. (Closed) Unresolved Itsns 50-348, 364/87-25-04: Use of Unqualified Grease On Motor Operated Valves.
V-The Limitorque Motor Operated Valves (MOVs) used by FNP inside containment were supplied by the vendor with Exxon Nebula EPO or EPl_ stease Jn 4he main gear-kxes.Mhe potential oT havi?Rr1Trc~ompatible
~-
greases inside the main gear box exists as a' resilt'6f ~ Main'tenance performed with Texaco MARFAK AP_ grease, which is a lithium soap base, ,_
Le , , versus Nebula which is a calcium soap bate,. The lubrication checks is7pecTfwd ty'~fhe FNP Lubr%atson MaTual (P12) are performed every 548 days and MARFAK AP is a *,ed as necessary to ensure sufficient grease level. Limitorque specifically states that greases of different soap bases should not be mixed. In addition, this problem was detailed further in INPO SOER 7-84. The team noted that the plant response to this SOER was to be included in that of IEB 85-03 which is not yet completed. Another item of concern to the team was the fact that no documentation was presented to the team on Septuber 18, 1987, to establish the environmental qualification of the MARFAK AP grease for inside containment applications or SUN SOEP grease for outside - containment applications. The licantee stated that they had J nformatien_.addressingJiAREALAP but it was itill Under review ~~6d a s not yet E M Subsequent to'the inspection, the licensee provided the team a copy of a JC0 for mixed grease used in MOVs. This item is being upgraded to Violation 50-248, 364/87-30-17.
- f. (Closed) Unresolved Items 50-348, 364/87-25-O'5: Unqualified Lubricants.
No documentation was presented to the inspection team on September 18, 1987, which supported the tts.e_qf_Eremium.RB_ grease on fan fnotus inside containment and room coolers outside containment. n** Jacluded on the E0 Master The tootcause .is 4hatJuhricants wara Subsequenl list o f EQ equipment and components. 'tf We'TMsfeW iB'n' Welicensee documented a JC0 to allow centinued operation with this deficiency. This item is being upgraded to violation 50-348, 364/L7-30-18.
- g. (Closed) Unresolved Items 50-348, 364/87-17-01, 02 and 03: Use of Unqualified V-type Electrical Tape Splices on SOVs, MOVs and Inside Containment Fans.
These items are being upgraded to violation 50-348, 364/87-30-19. These items are discussed in detail in inspection report 50-348, 364/87-25. 4 Unresolved Items , Unresolved items are matters about which more information is required to detennine whether they are acceptable or nay involve violations or ! deviations. Five unresolved items identified during this inspection are , I discussed in paragraph 6.
- 5. Background On January 11,1984,-the NRC4 eld a seeting .with APC0_to. discuss proposed l methods 4 -resolse t he__de.f.frienc ie s irlantifi ed in the Equipment- l l
l
4 6 l i Quauf444*on-Seht /-Eta 49at4cn Report-4at+d January-31r4983r-aed3 the FrankW 4esear.ch Lanier, (FRC) Teghrdejt__Jvaluation 1 Reports dated January 14 anc 17, 1983 for Units 1 and 2, respectively. Discussions also inchdeLgeneral methodology for complitnce _ with 10_CJA._5Lf 9_ and-justificatiort.for._ con.ti.nued aper _a._tinD_IJIO) for those equipment items for which environmental qualification was not completed. The minutes of the meeting and proposed method of resolution for each of the EQ deficiencies were documented in a submittal dated February 29, 1984. The final SER was transmitted to ApC0 in a letter dated December 13, 1984 In the licensee's submittel dated February 29 1984, the licensee sined .that 3
"all equipment'r'equire~d ~to' achieve a safe shutdown-condition 4t. FNP is envircnmentaily qual.ff ted__tnd Justif 3 cations .f u Continued Operation (JCO) -
are not necessary." _ Prior to this inspection, there was a reactive inspection conducted by Region 11 during the period of September 14-18, 1987, to followup on licensee identified deficiencies regarding unqualified tape splices on ASCO solenoid valves, limitorque motor operated valves and containment fan - motors. The results 6f this inspection were documented in inspection report 50 348, 364/87-25. On September 24, 1987 at tiie NRC offices in Bethesda, Maryland, a meeting was held with APC0 to discuss the deviation from design of certain cable j splices used at Farley Nuclear Plant on environmentally qualified equipmer' and the potential safety significance associated with the use of
- these t tes. The results of this meeting were summarized in a letter dated 5 mber 30, 1987 from APC0 and in a meeting surrnary documented by NRC dat6 November 5, 1987. In this meeting, the licensee made certain commitments to the NRC relative to v-splices which were later documented in a Confirmation of Action letter (CAL) from NRC to APC0 dated October 6 1987.
This inspection reviewed the licensee's implementation of a program to meet the recuirements of 10 CFR 50.49 and corrective actions on previously idantified EQ issues.
- 6. Finding-The NRC inspectors examined the licensee's program for establishing the environmental qualification of electric equipment within the scope of 10 CFR [*.49. The program was avaluated by physical inspection of EQ equipment, examination of the EQ files, interviews of personnel involved in EQ activities, review of procedures for controlling the EQ Master List, and examination of the licensee's maintenance program for maintaining the qualified status of the covered electrical equipment. The procedures and documents reviewed are discussed in other sections of this report. This inspection took place over a two week period of time due to the licensee's planned cutage tasks.
During the entrance meeting on November 16,1987. APC0 provided an overview of the Farley EQ Program, organization, procedures, and EQ
.g
7 documentation. The licensee indicated that changes had been made in the EQ program to be more consistent with NRC positions. The Ifcensee also discussed their commitments which were documented in their letter to NRC cated September 30, 1987 and the Confirmation of Action letter from NRC to AFC0 dated October 6, 1987. A copy tf the licensee's handout is included in this report as Attachment A. Tht inspection leam no.ted_ that si.gqlf.icant_improv2ments had been ipa 4e-4otha Armt's E0 PrqgE
<ompted to.J2r2v.icus-.dnip.tttions m)'Specificaily, the licensee has made improvefeTts_in_the EQ central f1Tes making them auditable or in some cases more auditable. In addition, the licensee has corrected significant omissions from the El] mas.itt li),t _and has revised the EQ program
~ ,/
;T -
A number ofTTnificant deficiencieswere identified, and the inspection
's team concluded that the licensee implemented a very marginal program in gttempt to meet the requirements of 10 CFR SON.
A more detail review of maintenance; IE Notices and Bulletins; procure-rent; EQ master list; EQ filer and walkdown results are discussed in the paragraphs that follow. ,
- a. EQ Maintenance Program The licensee has undertaken a thorough review of the EQ Maintenance Program at Farley due to deficiencies identified by a NRC inspection team and other problems identified in the industry relating to EQ.
The licensee reviewed plant maintenance records and procedures, and performed walkdowns of EQ equipment to detemine if the maintenance program at Farley was adequate to maintain the qualified status of EQ equipment. The results of these reviews identified that !Leveral deficiencies existed. in..the implementation of the EQ maintenaiic~e' _ program.at the Far, ley Plant .and that not,all, required EQ maintenance hAd beeftperforned. For example, the review of plant records (i.e., maintenance work requests (MWRs) and purchase orders) identified apgrg.gimatalv 10.000 ~
. items -R,000 for Hnu 1-44 %. 000_ for Unit 2) for which'EQ qualjucation_nay_no_t hay.t_been maintaine.d. At the time of the inspection, approximately 60% of the items had been reviewed and 22 discrepancies had been noted. Most of the discrepancies that have been identified involved the puchasa and use. nia.cggMnrade (Code _C) ccmponents in 10 aoplicationj (for more discussion on the use of Code C items in EQ app 1Ea'tlons see paragraph 6.e.).
Also found during the review was that luhr1 Cation _.ttqu.irements_wara for _alkaquipment and an evaluation had not been n(bein3Jnet_llow a different lubrication schedule than that which
~
perfo'rmlid to a was specified by the vendor. Subsequently, the licensee perfomed an evaluation to show that qualificatioli was not jeopardized by the deficiency. To prevent recurrence, the licensee has included preventive maintenance on EQ equipment into the Technical Speci-fications Surveillance Program. Procedures have been writter, but
i 8 all have not been approved and issued. These chang'es will require future Preventative Maintenance (PM) on EQ equipment to be scheduled and performed as required by their surveillance test program. Some of the_def.icienciasJdentified dur_ing walkdowns which were al.so' considired caused ,Jy inadequate _,ma_iatf_n3Et_ are: (1) use of unqualified V-type tipCsilTc_tL on numerous EQ componentsi (2) Raychem~ipfices,.not_insta11eL per_.yendor instructions; (3) use of unqualified fu~mper wires; (4) use of unquonied lubrhants; (5) use of ungualified limit _ switch on_13mitor.quet (6) exceeding replacement sche'5ules for ASCO solenoid valves; (7) failure to install T-drains on certain limitorque motor operated valvest and (8) failure to install ASCO -solenoid .-. valves in accordance with vendor recommendations. The licensee is currently taking steps to correct all maintenance-concerns prior to restart of S it 2 in accordance with commitments made to NRC. ,
- b. Inspection and Enforcement Notices (IENs) and Bulletins (IEBs)
The NRC inspectors reviewed and evaluated the licensee's activities concerning the review of EQ related IENs and IEBs. The inspectors , review included examination of procedures and E0 documenta* 'on packages relative to Infonnation Notices and Bulletins'. .ne inspectors concluded that the_ licenlee_ Apes have aLJystem for
, distr.ibuting.. nviaging, and evalua_1.1.ngJEAs and_ IEBs_ r? ATWir to
~
equhment_.withia the sr.cp ;f 1MER 50.49. A weakness observed in the licensee's program is that the IENs - anc IEBs are not aMrtssed in~ khe componeD_t EQ_fil.es. The specific IENs and IEBs examined are IENs: 84-47, 86-53, 86-03, 84-90, 84-68, 84-78, 83-72, 80-08, 82-03, 84-57, and 85-47.
- c. Environmental Qualification Master Equipment List The licensee is required to maintain an up to-date list of equipment that must be qualified under 10 CFR 50.49. The list for FNP was prepared as described in their SER dateo December 13, 1984. The list was based on a review of the design and as-built documentation, the Final Safety Analysis Report (FSAR). Technical Specifications, Emergency Operating ~ Procedures and flow / electrical diagrams to .
determine the systems and components required to perform the functions of reactor trip, containment isolation or accident mitigation and exposed to harsh environmental conditions. Other i equipment evaluated included nonsafety-related electrical equipment whose failure under postulated harsh environmental' conditions could prevent satisfactory accomplishment of safety functions. Thi, list is a controlled document at FNP and is updated in accordance with FNP-0-AP-8.
9 To assess the completeness of the Master List, a spot check of several syste% snd components was performed. Specifically, flow diagrams 0 l' Ani D 175038 and D-175041 for the Low Head Safety injection a, ' ; W Head Safety injection System were reviewed to determine tk s,9 tem components, such as Motor Operated Valves (MOVs), Solenoid Valves (SOVs), motors, and instrumentation that are required to bring the plant to a safe shutdown condition. In addition, required auxiliary support system components such as HVAC and CCW were reviewed to verify necessary components were included on One the Master List. NjL#e fi ci en ci e sJer2.J.oted .dur.itg th1Lrivd ew. item of concern to the taam during the course of the review, however, involved the accumulator discharge valves, MOVs E21MOV8808A, B, and C. The team noted that these valves were located below the submergence level and had brakes installed on the motor operatFS. The team was concerned that the MOVs were not qualified to operate ursder these conditions. Th? licensee reported, bewever, that although the valves were .ncluded on the Master List - the valves were not required to operate under all postulated accident conditions and in fact were locked open with power removed during normal plant operation.
- d. Cable identification During the plant walkdown inspection the inspectors identified cable ID numbers to the licensee so that traceability could be established to the cables identified in the EQ Master List. In all but one case the cable was able to be traced back from the installation records to The ene case where traceability the material receiving reports.
could not be traced back to the receiving report was i to lack of reel number identification on the pull card. The litusee could, however, establish how the cable was procured by reviewing the receiving records for all of that type of cable. No further questions were asked in this area,
- e. EQ Equipment Replacement and Spare Parts Procurement Procedure FNP-0-M-060, " Environmental Qualification Program Description," describes the environmental qualification program for safety related electrical equipment installed in potentially harsh environments, and establishes requirements for procurement of equipment and components within the scope of 10 CFR 50.49. Imple-mentation of the procurement requirements for EQ assemblies and components is delineated in procedure FNP-0-ETP-4108, "FNP Environmental Qualification Program Implementation." Paragraph 7.0 of this procedure delineates procurement controls necessary to assure that applicable regulatory requirements are included in procurement documents. Requirements for up-grading EQ equipment in accordance with 10 CFR 50.49(1) have been delineated in writing. Additionally, comercial grade parts and materials procured for EQ applications will be dedicated for safety-related use in accordance with the requirements of 10 CFR 21.3(c-1).
i
- - _ _ _ _ _ _ _ - _ _ . _ f
10 Administrative process for the procurement of EQ equipment, and control of the associated procurements, is described in procedure FNP-0 Ap.9, " Procurement and Procurement Document Control." The procurement process ensures that the EQ requirements of procured equipment are included as part of the QA Program requirenents. As such 0A documentation is required to include either a certificate of compliance to the specified test report from the vendor or a reference to the appropriate documents which indicate that the Manager of Nuclear Engineering and Licensing approves the use of another qualification method for the wmponent. In addition, the test report number and revision date m required to be st.ated on the certificate of confomance. . 0A Review Codes are assigned to all procured equipment. These codes are based on the importance to nuclear safety or system operation of the equiptrent; the complexity of design or manufacture; cost, reliability, or design; or availability as a stock or special purpose item. QA Review Codes are documented on the Purchase Order. Definition of 'the QA Review Codes includes Code A (Safety-Related); Code A (Non-safety-Related); code C (Non-safetyRelated); Code D (Nonsafety- Related); and Code E (Non-safety Related). Responsi-bilities for assigning QA Review Codes have been delegated to the Supervisor of the group requisitioning the material, with review and concurrence by the Manager, Perfomance and Planning, or his designee. Pursuant to the review of the QA Review Codes it was detemined that the application of these codes for the procurement of 10 CFR 50.49 categcries (b)(1),(b)(2) and (b)(3) equipment was not addressed. Discussions with licensee management revealed that all EQ equipment are procured as Code A (Safety-Related). Spare parts for _ EQ assemblies may be procured as Code A (Safety-Related) or Code E i (Non-safety Related). The procurement of spare parts as Code E (Non-safety Related) is a comercial grade procurement with the potential for degradation of the EQ status of equipment in the
- absence of a comercial grade dedication process. The inspectors l were informed that procedure FNP-0-AP-9 will be revised to more clearly define the application of QA Review Codes for the procurement of EQ equipment.
The following purchase orders (P.O.s) were reviewed to verify inclusion of EQ requirements in the procurement documents: P.O. - No. QP-1481 dated February 26, 1987, P.O. No. QP-1132 dated September 8,1986, P.O. No. QP-2106 dated November 3,1987, P.O. No. QP-1576 dated April 7,1987, P.O.- No. QP-1544 dated March 26, 1987, P.O. No. QP-1393 dated January 15, 1987, and P.O.- No. QP-1164 dated September 18, 1986. Deficiencies identified in the procurement documents reviewed and root cause of the identified deficiencies are discussed below. (1) Procurement of Comercial Grade-Components for EQ Applications
11 The licensee's accepted QA program FNP-FSAR-17. Secticn 17.2.3, states that design changes and/or modifications during plant operations will be handled in a manner which will comply with the requirements of ANSI N45.2.11-1974. Additionally Section 17.2.4 states that procuremen't documents will delineate the quality program requirements to be met by the contractor and will provide for the control of procured items in compliance with the requirements of ANSI N45.2.13-1974
.Rjtyi.ew__of___the__guality _jmple.menting._pr_ocedure_ FNP 2 0 Ap.9, Revision 12, te_vealed_that_ measures hadMtibien.establGEhd_to assure that applicable regulatory requirements are met, and ~ ~
'5fTTgn~ bases"are preservedJudng The prdeurement innd tise of QA ret 4es Code ClNoiG~sa,fety-Relate ~aTTnd 'OA Review Code D (Non-safety-Related) items in EQ applications. Ecuipment and spare parts classified as QA Review Code'C~are commercial grade items that require dedication prior to use in EQ application, pursuant to 10 CFR 21.3 (C-1). Additionally, this application is a design change which is required to be controlled in accordance with the requirements of ANSI N45.2.11-1974. This standard requires that design changes shall be subjected to design control measures comensurate with those applied to the original design, and be approved by the organization that performed the original design, unless the licensee designate another responsible organization.
ANSI N45.2.13 1974 delineate requirements for control of procured items. Paragraph 10.2.1, requires the procurement dccument to specify the method of acceptance of an item; and where a Certificate of Conformance is used the certificate should identify the specific procurement requirements met, such as codes and standards. Paragraph 9.2.1.5 of procedure FNP-0-Ap-9, Revision 12, establishes requirements for imposing 10 CFR 21.3 (C-1) on safety-related procurements. Measures had not in fact been established to impose the requirements of 10 CFR 21.3 (C-1) on material procured as QA Review Code D (Non-safety-Related). Materials procured to this QA Code level are therefore comercial grade and require dedication prior to use in EQ applications. A dedication process involving the performance of an up-front engineering evaluation of the items critical attributes; its ability to functien in the intended safety-related application; and a determination of the acceptance parameters required for verification of those critical attributes had not been established by the licensee. Procedure FNP-0-AP-9, Revision 12 was subsequently revised to establish requirements for a Dedication Program. However, the root cause of the deficiencies _ identified with the following P0s is programatic_artd they are examples of the deticienctrinat existed in the EQ procurement Failure to assure that applicable reguTRory-
.-R . . . .
12 requirements, design bases, and other requirements necessary to assure adequate quality are correctly translated into specifications, drawings, and instructions is identified as a violation (50-348, 364/87-30-01). This is considered to be another example of a previously identified violation (50-348, 364/87-11 03). P.O. No. QP-148J4A Review Code D) was issued for the procurement of statavTvneEM teminal blockp The controlling procedure for this procurement was rd-0-EP-9, revision 12 (Issue Date September 2,1986). This procedure defined Code D as a non-safety-related procurement of an item where current license requirements are applicable to the part, or special - vender documentation and verification of vendor's QA program is deemed necessary. The requirements of 10 CFR 21 were not imposed on this purchase order. Acceptance of the items by the licensee was by receipt inspection with a Certificate of Conformance that noted the teminal blocks had been manufactured using vendor's standard QA/QC procedures for Class 1E terminal blocks. However, specific supplemental documentation, such as material certificates or reports of tests, was not requested in the purchase crder nor were they provided by the vendor. The reactive inspection the week of September 14-18, 1987, for - followup of licensee identified unqualified taped splices revealed the use of commercially procured tapes for EQ applications. Purchase Order No. 84541 (QA Review Code C) was issued on September 30, 1985 for procurement of miscellaneous electrical supplies including Okonite T-95 insulating tape and No. 35 overlay tape. An engineering detemination of the items critical attributes, ability to function in the intended safety-related application, and the acceptance parameters for verification of those critical attributes were never performed by the licensee. An assessment of the impact on EQ status pursuant to receipt of Okonite's letter to Mr. Robert Culp, dated November 11, 1986, was never performed. This letter gave a qualified shelf life for T-95 tape as 18 months, and for No. 35 tape as 24 months. The controlling procedure for this procurement FNP-0-AP-9, revision 12, did not establish requirements for dedication of commercially procured items prior to use in EQ applications. Licensee management has created a task force that is presently reviewing old maintenance work orders to assess the impact of past maintenance activities on equipment EQ status. The following are examples of licensee identified deficiencies discovered during this -ongoing effort. Installation of unqualified limit switch and torque switches in motor operated valves discovered during walkdown in response to IEN 86-03. (ProcuredCodeC)
13 Installation of Raychem Breakout kits in NAMCO Limit Switches for Chico Seal (Procured Code D without supporting documentation). Installation of G.E. O rings in penetrations (' Procured Code C, not upgraded for EQ applicable). Installation of metal 0 rings in Conax Penetration (ProcuredCodeC). The above deficiencies are symptomatic of a programmatic breakdown of procurement activities in addition to weaknesses in - the maintenance area.. Other maintenance activities are addressed in paragraph 6.a. of the report. (2) Failure to Upgrade Equipment During Procurement Activity An example of failure to upgrade during procurement is the purchase of Snap-Lock limit switches. P.O. No. QP-1164 (QA Review Code A) was issued for the procurement of environmentally qualified Snap-Lock limit switches on September 8,1986. The switches were procured as safety-related equipment, and the previsions of 10 CFR 21 were imposed on the purchase order. However, the P.O. specified that the Certificate of Compliance should certify compliance with ACME-Cleveland Development Report No. QTR/105 Revision 4, dated January 8,1984 This report establishes envircnmental qualification (EQ) to NUREG 0588 Category 11. Contrary to the requirements of 10 CFR 50.49(1) the equipment was not upgraded to 10 CFR 50.49 and reasons to the contrary for not doing so were never documented. The controlling procedure for procurement activities. FNP-0-AP-9, revision 12 did not establish requirements for procurement of upgraded items. This failure of the licensee procurement program to establish measures that ensure upgrade of equipment in accordance with requirements of 10 CFR 50.49(1) is identified as a violation (50-348, 364/87-30-02). This is considered to be another example of a previously identified violation (50-348, 364/87-11-03).
- f. QA/QC Interface The supervisor, Safety Audit and Engineering (SAER), and his staff conducts an audit program of safety-related activities for Farley to verify that such activities are in compliance with the Operational Quality Assurance Program (0QAP). The objectives of the audits are to detemine that the OQAP has been developed in accordance with applicable requirements; to verify by evaluation that the program has been implemented; to assess the effectiveness of the 00AP; to identify program noncompliances; and to verify resolution of deficiencies and noncompliance.
14 The SAER group onsite has conducted audits of var'ious performance areas of the EQ program. Review of five audit reports covering a time span from August 8, 1986 to July 7, 1987, revealed the following deficiencies:
- Inadequate specification of EQ requirements on purchase orders.
' Inadequate delineation of EQ requirements in preventive maintenance procedures.
' Improper maintenance activities perfonned on EQ equipment.
- Failure to perfonn vendor recomended maintenance for EQ equipment in storage.
The scope of the deficiencies related to maintenance practices were documented as being generic to the electrical and mechanical, and the Instrumentation and Control (!&C) shops. Corrective action has not been completed for some deficiencies. However, developed corrective action plans for the other identified deficiencies appeared to be adequate. The SAER staff conducted an audit of the Farley EQ program during October 20 - November 15, 1983 and identified three non-compliances. The audit findings are documented in the report dated November 15, 1983. The first non-compliance described on Corrective Action Report (CAR) No. 829, identified a deficiency in the EQ Program documen-tation as required by 10 CFR 50.49(f) and (j). The CAR dated December 22,1983, for this identified deficiency stated that all required documentation, i.e. those required to make auditable files, will be on site by January 1984 Objective evidence for completion of this corrective action by January 1984 was not presented. The third non-compliance described on CAR-831, identified a deficiency concerning containment cooler fan motors and whether or not they were approved models based on the Acceptable Test Report List. The developed corrective action plan for this deficiency appeared to have been adequate. , Nonconformance FNP-NC-48-83/19(8)-CAR-830, identified a deficiency that involved failure of the design change program to identify vender technical manuals- and vendor drawings as requiring ' update- upon implementation of a plant modification. The licensee s Preventative Maintenance (PM) program for EQ equipment requires that appropriate vendor service manuals be referenced for the performance of PM activities. Failure of the design program to identify vendor technical manuals and shop drawings that should have been updated resulted in the PM program referencing incorrect vendor documents. The scope of. the problem was defined as generic to all Production Change Notice (PCN) work involving both EQ and Non-EQ components. Estimated completion of corrective action for this deficiency was documented on the Corrective Action Report (CAR) fonn as April 1, 1984 Further evaluation of the problem by licensee management
15 resulted in CAR-830 being revised on July 7, 1984, and an estimated completion date of January 5, 1985 was given for CAR 830. Revision 1. Administrative controls were also implemented to assure that environmentally qualified components would not be degraded by PM activities. These controls are delineated in administrative procedure FNP 0-AP-52. The effectiveness of these controls are in doubt, however, because the SAER staff in audit report dated October 10, 1986, identified a deficiency wherein the controls delineated in this procedure were not being followed. CAR 1222 was prepared to address this deficiency. Pursuant to further evaluation of the problem by licensee management, CAR 830, Revision 1 was revised on August 27, 1984, and an estimated - completion date of July 1, 1985 was given for CAR-830 Revision 2. The inspector determined that CAR-830, Revision 2, with an initial estimated completion date of July 1,1985, was subsequently given approved estimated completion dates of January 1,1986; July 1,1986; December 15, 1986; and January 1, 1987. A more recently requested estimated completion date of March 3, 1988 was approved on October 10, 1987 by the Plant Manager. The apparent lack of timeliness in correcting a significant dificiency identified in 1983 and its potential for degrading EQ eauipment because of incorrect guidance contained in the PM program was discussed with licensee management. In response, licensee management referred to generic letter 83-28, and their actions taken to meet the requirements delineated in this letter. Previous correspondence from the licensee was reviewed regarding generic letter 83-28 Item 2.2, Equipment Classification and Vendor Interface (Programs for all Safet and the Safety Evaluation Report (SER)transmitted y-Related to Components), Mr. R. P. Mcdonald, Senior Vice President, in NRC letter dated December 12, 1986, from Edward A. Reeves, Project Manager. The SER stated for generic letter 83-28, Item 2.2.2, that the lack of a formal vendor interface with each vendor of safety-related equipment, or a program to periodically contact vendors of safety-related equipment, does not relieve the licensee of his responsibility to obtain appropriate vendor instructions and information where necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service, and to ensure adequate QA in accordance with 10 CFR 50 Appendix 8. - Another example of untimely corrective action and failure of the SAER staff to effectively implement the QA program is provided by CAR 1251. This CAR describes a deficiency found in November 1986, where the preventive maintenance of EQ motor operated valves was found to be inadequate. The root cause was determined to be lack of detail in procedure FNP-0-MP-28,137. The corrective action, which involves revising the procedure, has been given an estimated completion date of March 31, 1988.
- 16 The licensae's accepted QA Program requires that conditions adverse to cuality be promptly identified and corrected. In the case of signifir'at conditions adverse to quality, measures shall assure that the catae of the condition is determined and corrective action taken to preclude repetition. Examples of non-compliances identified by SAER and addressed in this section of the report have not been corrected in a timely manner. Specifically, failure to promptly correct the deficiency identified in November 1983, wherein vendor technical information and shop drawings were not upgraded for implemented PCNs, and which created conditions adverse to quality such that the PM program contained incorrect guidance for maintenance of EQ equipment, is identified as violation 50-348, 364/87-30-03. .
- g. EQ Modification Program
- Pro:edure FNP-0-ETP-4108, "FNP Environmental Qualification Program,"
establishes requirements for ' design changes that add, delete, or alter environmentally qualified equipment. Responsibilities have been assigned to off-site engineering organizations to ensure that Production Change Notices (PCNs) impacting EQ equipment address Farley specific environmental conditions, maintenance, installation configuration, submergence level, and interfaces with other components. PCNs prepared for design changes to EQ equipment are required to be completed in accordance with the requirements of ANSI N45.2.11-1974, OA Requirements for the Design of Nuclear Power Plants." The controlling procedures for design changes are FNP-0-AP-8, " Design Modification Control," revision 12, and GO-NG-11 " Design Change and Design Control," revision 5. These procedures were reviewed to assess the adequacy of licensee control of EQ requirements in the modification program. The documents indicate that the General Office Nuclear Support Group is responsible for administration of the offsite design development program and for processing production change requests (PCRs) in accordance with applicable portions of procedure GO-NG-11. This procedure establishes requirements that ensure EQ program considerations are included in the design effort from initial identification of a station problem that resulted in the preparation of a PCR. Additionally, responsibilities have been assigned to ensure that completed design change packages have incorporated EQ program requirements. The Production Change Notice (PCN) Review Checklist is used to verify the adequacy with which EQ requirements have been included in the design process, Procedure FNP-0-AP-8, paragraph 9.1 and 9.2, assigns engineering evaluation and review responsibilities to the Plant Modification Manager and his staff. It was determined, however, that training in the requirements of the Farley EQ program had not been given to members of this group. This deficiency is addressed in paragraph 6.h. of this report where it is identified as a violation.
.. o . ,
17 Production Change Packages No. B84-2-2624, and B84-2-2618 which involved the change-out and installation of EQ electronic differ-ential pressure transmitters to meet the requirements of Regulatory Guide 1.97 were reviewed. Associated engineering requisition for procurement of the instruments and completed maintenance work request for their installation was also reviewed. No EQ related deficiencies were identified.
- h. EQ Personnel Training Procedure No. FNP-0-M-060. Environmental Qualification Program Description, Revision 0, assigns responsibility to the Farley Nuclear Plant Training Center for providing EQ and special training to craf t '
and maintenance personnel working on EQ equipment or components. Discussions with the Training Manager and review of procedure FNP-0-M-015. "FNP Master Training Plan," revealed that EQ training was not specifically addressed within the training program. The e inspector was informed that EQ training is an integral part of the overall training provided to plant personnel. Pursuant to an INPO audit in June 1986 which identified deficiencies in the EQ training of craft personnel, licensee management has enhanced the EQ training provided to this group. INPO accreditation of the Electrical and Instrumentation and Contr;o1 (IEC) training programs was received by Farley in late 1986. The inspector reviewed Attendance Sheets, Lesson Plans, and Exami-nation Grade Sheets of four persons in both the Electrical and I&C groups to verify incorporation of environmental qualification requirements within the training program. No deficiencies were , identified in the licensee's program to provide EQ training to Electrical and I&C craft personnel. Responsibilities for implementation of various activities associated with the EQ program has been assigned to the QC Engineer. Paragraphs 3.2.3 and 9.0 of procedure FNP-0-ETP-4108 delineate these responsibilities. Discussions with the QC Engineer and other members of this group revealed that training in the requirements of the EQ program had not been provided. Additionally, review of objective evidence in the form of training attendance sheets corroborated this finding. Licensee management's response to this identified deficiency was that the Technical Staff and Management Training Frogram will be revised to include requirements of the Farley EQ program. Subsequent discussions with the on-site Plant Modification group identified similar deficiencies in EQ program training. Licensee accepted QA program. FNP-FSAR-17. Section 17.2.2, states that the objective of the Operational QA Program is to provide adequate assurance of quality during operation of FNP by complying with the provisions described in the OQAPM and procedures listed in the OQAPIL which satisfy the criteria of 10 CFR 50 Appendix B.
18 Criterion II of 10 CFR 50 Appendix B states that the QA program shall provide control over activities affecting quality to an extent consistent with their importance to safety. The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained. However,-at the time of the inspection licensee management had not provided training in the requirements of the EQ Program to the QC Engineer and his staff, nor to members of the plant modification group. This failure to prc, vide indoctrination and training of personnel assigned responsibilities for implementation of various activities of the EQ Program is identified as an unresolved item 50-348, 364/87-30-04. .
- i. EQ Documentation Files and Walkdown Items The required-qualification level for-the Farley 1 and 2- original 10 CFR 50.49 scope equipment is the DOR Guidelines or NUREG .0588, Category II. Replacement equipment purchased after February 23, 1983 is required to meet the requirements of 10 CFR 50.49. T_he EQ
, Doc _uggLnlatinn_Jti._Earley _ isAposed _of. Master . Equipment-_Mit4 sEnvir.om. ental Profiles and the Central File. The, Central File cont'ains the EQ7sTRiipirti;~EQ EvaluaOon checklists, system
~
component,eF ult' ion'worksheet jSCEW) and support documentation. The licensee's generic EQ files were reviewed in detail against the requirements to determine if qualification. had adequately been established and that records were maintained in an auditable fashion. As discussed previously the_licens'ee_had_ revamped their EQ files to make them auditable and in some cases more auditable. The NRC inspectors examined files for approximately 32 equipment items, where an item is defined as a specific type of- electrical equipment, designated by manuf acturer - and .model, which is representative of all identical equipment in a plant area exposed to the same environmental service conditions. The items were selected in advance by the inspection team and _ identified to the licensee during the entrance meeting. The files were examined to verify the qualified status of equipment within the scope of 10 CFR 50.49. - 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- (1) required post-accident operating time compared to the duration of time the equipment -has been demonstrated to be - qualified, (2) similarity of tested . equipment-to that installed in the plant (e.g., insulation class, materials of components of the equipment. - test configuration compared- to -installed configuration. - and documentation of both), -(3) evaluation of adequacy of test conditions, (4) aging calculations for qualified life and replacement
-interval determination, (5) effects of decreases in insulation resistance- on equipment performance, (6) adequacy of- demonstrated
- 19 accuracy, (7) evaluation of test anomalies, and (8) applicability of EQ problems reported in IEBs/IENs and their resolution.
The aging calculations were not reviewed because they were not available at the site and the team was told that they would have to be reviewed at Bechtel, Gaithersburg, Maryland. In addition, the performance characteristics or accuracies were not specified in the l files. The files would reference a Westinghouse WCAP-11658 dated November 13, 1987, which was the basis for instrument accuracy calculations. To evaluate the Westinghouse WCAP on instrument accuracy the licensee had to have representatives from Westinghouse ! come to the site on November 18, 1987. l This meeting resolved all ' concerns the team had regarding the calculations performed to develop Emergency Procedures and Instrument Setroints. It identified another ccncern about the values provided to Westinghouse for terminal block (10 E7 ohms) error contributions in the loop accuracy calculations. Roview of the files for GE Penetrations, and States Terminal Blocls did not identify IR values which were measured during the LOCA iest. These concerns are discussed further under the file rev'ews for Penetrations and Terminal Blocks. Excluding the fact that no aging calculations 'were reviewed and performance data was not included on the SCEW sheets, the files were auditable and documented qualification of the equipment, except as described in the findings below. These ccmments on both EQ records and walkdown items are considered the most significant findings. (1) G S Delavel Level Transmitters During the review of the GEMS level transmitters tual.ification - file, model XM-36495, it was note.d__that_ thermal and radiation agTng effects were not evaluated for all susceptible materials. terminal block and resis. tans were 5pW1TI'c'a11y, the lead wires, Tters. The file stated that it not evaluated for these tYansm __as w not necessary to evaluate the e cts.for._those ma12 rial'L-since~ the mkt} dais _ were 1mfrierse in silicone oil which would _protelt_.1bem._from ace related T ects. It was noted during the walkdown of the wide range sump level transmitters in Unit 2 that there w35 no ci'icona nil in the .iunction box as required. The assumption that the materials won't experience Inese affects is invalid based on our physical inspection. This item was left as unresolved and is listed as Unresolved Item 50-348, 364/87-30-05, Inadequate Materials Evaluation for GEMS Level Transmitters. The licensee found wide rage and narrow range containment sump level transmitters, on both units, in a configuration that was - not considered qualified by existing test data. Specifically, one or more of.the GEMS type level transmitters did not contain
- 20
,_the_nguirad_silirone _ oil i!.L_the_b.ousing, the' conduit opening was not sealed and/or wires were terminated using an unquallfied
,Y.typa -tep+--.$pl34e_A;Ln,f {ggAtlon. Inis is considered a
' violation of 10 CFR 50.49 and it is identified as Violation 50-348,364/87-30-06.
(2) Joy Manufacturing Containment Fan Motors During the walkdown of Unit 2 equipment inside containment the team noted that plastic shipping caps were still installed in the unused conduit port of the auxiliary conduit box for the- , Post-Loca Mixing fans and the Hydrogen Dilution fans. There was a concern that the p.lastic caps would melt during the temperature extremes experienced during a Design Basis Accident and allow a direct path for moisture to enter the motor. However, during the course of the inspection the. li.censee was_. able .to. produce addi.tional _ i nformation from the vendor that
' verified that the fan motors would perform their function during 4 the Design Basis Accident due to the specific FNP configuration and location.
(3) Limitorque Motor Operators During the course of the inspection PCN 86-1-3760_was revieweA This 2CfLwas_ generated to ressive._cIncerns_ detailed lnTIEN J5.AL._u.ecifieally~the use of.unguali fied Intetna LJu-@6t_wifTs. in limitorque moYor operated valveLU10ys'7. Coincident with the internal wiring inspection / replacement requi. red by the PCN other items of MOVs were checked per ,an approved check sheet. Some items of concern noted by the team during the review of the completea walkdown sheets which were performed for Unit 1 during October 1986 include the following: T-drainLnot installed at low point f.or.15 MOVs .
- Presence of one MOV inside containment with limit switch frame ho,using constructed ___of aluminum
- Use of unidatillad_teminal bloch for power leads in limitorque MOVs The absence .of. .T-drains was a o_noted dur.ing._the._walkdown
- inspection conducted ~the wee of' November 2. 1987. Speci-fica 11y, MOY 3046 d660, 3441A,_3_441B and 3872A were configured for T-drains _bu
~
id stlaf~e~them7nstalle3.f In addition the MOV was~1nsta11'el with the limit switcti compartment on the.same horizontal plane as the motor with top entry conduit into the switch compartment for both the power and control cables. Dur_i,._g. n hour.se_of_the_j nspection _th.e_. team._ wits _ presented with - additional infomation bylhe__1_irensee to_. justify their. installejf_confRJration... The team was satisfied with the
4 21 information presented for these MOVs which had a short tem operating requirement. However, for those MOVs which have a long term operating requiPement,-be"1t" valve position indication or valve repositioning the team was not satisfied. The team was concerned that the long 16rm affects of moisture intrusion were not adequately addressed 'ai the tested ~versus lnitalled o configuration with respect to orientation and conduit system differed and the referenced test without T-drains had a total test duration of seven days. This item is considered to be a Violation of 10 CFR (50.49) and is identified as Violation 50-348, 364/87-30-07, Lack of T-Drains in Limitorque Motor Operated Valves. The walkdown check sheet for MOV Q1E11MOVBB11A Aated.0ctober 9, 1986, indicated that the limitiswitch frame housing was - constructed of aluminum. Aluminum is not qualifi_ed for applications where ~it can be subjected ~lo a caustic spray environment as evidenced in Limitorque report 600198 where a limit switch frame housing constructed of aluminum corroded and caused the limit switch to fail less than 24 hours into the trst. The licensee pointed out to the team that they became aware of this problem during a recent review of the walkdown data and had initiated Ka'R 167476, dated November 3, 1987, to
- replace the switch during the upcoming refuelir.g outage. In addition, an administrative LCO was written for this valve on November 19, 1987, to ensure that the valve remained in its required safety position. This unqualified component is in violation of 10 CFR 50.49 and is listed as Violation 50-348, 364/87-30-08, Use of Unqualified Limit Switch in Motor Operated Valve.
The walkdown check sheets also indicated the use M tarft,nal i blocks for some _of the power leads. Some were identified'by-just the manuf acturer's nTme,1.e. quchanan, with no model number or by just the color, i .e. , black. ' The equipment qualification file for the Limitorque MOV's file numbers 23A, 23B and 23C did not specify which terminal blocks were acceptable for use in Limitorque MOVs. During the inspection the licensee stated that terminal blocks qualified by report B0119 were acceptable for use. However,gthere was no evidence that Ticip.the JJcensee_had _ reviewed .this -reporMReFEii~ne 'itstabilit installed in their MOVs were one of the models tested in the B0119 report. This item is identified as Unresolved Item 50-348, 364/87-30-09, Use of Unidentified and/or Unqualified Teminal Blocks in Limitorque Motor Operated Valves. . (4) File Number 30A, B - Rosemount RTD, Model 176K and F. This item is required to be qualified to a temperature of 378'F for accident conditions at Farley. However, the test report l
22
. demonstrated qualification to only 366'F. The file referenced a Bechtel mechanical calculation no. 23.4 This calculation is suppose to show that there will be a thermal lag, and therefore this item will not reach 378'F. This calculation was not available at the site for review. The licensee was also requested to provide accuracy requirements for this item. The licensee provided the accuracy requirements of the test plan and the test results, and stated that the performance data is contained in the Westinghouse W-CAP and is used in the calculation of loop accuracy.
The file adequately demonstrated qualification for all other requirements. ' (5) File Number 10A - Conax Containment Air Temperature Sensors, Model 7D-37-10000-01. This file contained information that showed this item to-be-qualified for its application at Farley (i.e., qualified by similarity to a Conax RTD). (6) File - Westinghouse Hydrogen Recombiner Type A. No deficiencies were found in this file. (7) File Number 14C - Foxboro Junction Box ! This junction box was qualified in conjunction with a Foxboro transmitter. However, this file indicates that it is being used with a Barton transmitter, therefore the licensee was requested to show that the amount of leakage current measured during the qualification test was sufficiently low as not to affect the accuracy of the Barton transmitter. The licensee provided information that showed that the terminal block, as tested.
. displayed a leakage current of 1.9 x 10-6 amps and agreed to add this information to the file.
(8) Okonite Okozel Instrument Cable File 27 The qualification basis was 10 CFR 50.49. Qualification was based upon Okonite Report #NQRN-4A, Revision 1, dated March 31, 1987, " Qualification of 0kozel Insulation for Nuclear Plant Service." Test conditions adequately enveloped the required plant profile, with margin, though credit was taken for an analysis per Bechtel Mechanical Calculation No. 23.4 which provided a basis of 317'F peak cable surface temperature. Similarity was not addressed in the file. The licensee was able to show that the samples tested were identical to plant installed cables, though this discussion was not included in the file. The reviewer suggested that a summary explanation be provided. Supplement #1 to the EQREC provided a summary of a _m__ _ _ _ _ _ . _ _ _. . _ _ _ _ _ . _ _ _ _ - -
4 5 4 23 licensee trip report which included verification of raw data which was not available from Okonite. This fact, and the results, were not clearly addressed and cross-referenced in the file. The licensee stated that the files were currently being upgraded in a generic fashion to more completely document similarity. A number of questions regarding incomplete or missing file documentation were posed and resolved. Beta radiation was not specifically addressed; however, there was more than adequate gama dose margin to negate this issue. No findings were identified. (9) Okonite Low Voltage FMR Power and Control Cable File 26B. As with the instrument cable, test parameters enveloped the plant conditions with the provision for using 317'F peak cable temperature. Qualification was based upon Okonite_ Report No. NORN-2, Revision 6, dated February 27,1987, " Qualification of Okonite-FMR Insulated cables for Nuclear Plant Service." As with File #27, the raw data was not available in the file and is apparently proprietary. The licensee physically inspected (audited) and verified the data which is summarized in the test report. Similarity was not clearly addressed and the licensee provided a response to trace the cable identification and to show that the samples tested were identical to plant cables. Insulation resistance readings taken during the LOCA were only marginally acceptable. However, all stated test acceptance criteria were met. These low irs were used in Bechtel Calculation No. E-87 for instrument loop accuracy calculations and for input to a Westinghouse Setpoint Analyses (WCAP-11658). No findings were identified. (10) ITT Supernate type SIS 600 Volt Wire. The qualification basis was 10 CFR 50.49. This cable is exposed to a relatively mild environment (104'F,14.7 psia, 6.7 Mrad gama) in the auxiliary building. The Isomedix Report No. 1179-01 more than adequately exposed identical cable with good results and no anomalies. No findings were identified. , (11) Raychem Flamtrol-Insulated 1000 Volt Control Cable - File 28A. The qualification basis is NUREG 0588, Cat. II. Qualification was based on "Raychem Flamtrol Qualification to IEEE Std. 383." dated March 15, 1976,.and Appendix XI to that report: Franklin Report F-C4033-1, January 1975. Time did not allow a complete review of this package, though the documentation and technical basis appeared complete. No findings were identified. (12) Brand Rex SIS Switchboard Wire, Ultrol #T-61057, File 7C
F - - ' - - - ~ ~ - - - - ' - ' - - - - - - - - ~ - - - - - .. . . _ _
' 24 The qualification basis is 10 CFR 50.49. The plant environ-mental conditions were adequately enveloped by the stated test condi tions . The file referenced Franklin Test Reports F-C5120-1, -3, and 4. Report (F-C5120-1 was missing from the package. The licensee reported that the master EQ file includes it and a copy was provided for review. Performance (insulation resistance) was monitored during all phases of testing and found acceptable. A Bechtel letter was referenced to support the similarity analysis but was not in the EQ file. Insulation (XLPE) and jacketing (hypalon) for both tested and installed cable is identical but part numbers were different and thicknesses not clearly addressed. The Bechtel letters were provided for review and they adequately addressed that installed (30 mil XLPE) and tested (20 and 30 mil XLPE) had similar thickness insulation. Aging was based on a derived value for activation energy of 2.21 eV. When questioned, information was provided which gave a good discussion of the methods used and understanding of the use of this relatively high value. No findings were identified.
(13) Brand Rex 300 Volt Instrument Cable, File 7B. The qualification basis was 10 CFR 50.49. The plant profile was enveloped and acceptable performance during testing was verified. Qualification was based upon Franklin Report No. F-C5120-4 As in File 7C, an activation energy of 2.20 ev was used. The response discussed the highly conservative service temperature of 90'C and that acceptable qualified life could be shown for activation energies as low as 0.996 eV. The licensee committed to revising the file to include this discussion. Beta radiation was not discussed and a reference to Bechtel drawing No. A-506150, Rev. O, " Beta Radiation Reduction Methodology" was missing. A copy was provided and briefly reviewed, but not discussed in detail with the licensee. Qualification was based on sample SB of the test report, which was #16 AWG, 7 strand, 20 mil XLPE insulated cable. The referenced codes Y35 and Y36 cables given on the SCEW sheet were questioned as to similarity. A response was provided which documented the traceability and certification of the cables (per APC0 P.O. #QP 0417). No findings were identified. (14) Raychem Stilan Cable. File 28A. The qualification basis was the D0R Guidelines. The test profile easily enveloped the plant conditions, but a significant number of insulation resistances were reported only as "less than" some value (apparently the low end of the instrument range). These anomalies were discussed in the test report, but no additional " good" data was included in the file. The utility was questioned about Stilan cable usage and they responded that it is used in instrument circuits. Sufficient time was not
25
. available to discuss the issue further so it was left as an unresolved item at that time. At the follow-up meeting on November 25, 1987 in the Region 11 office, the licensee stated that they have replaced or will replace this cable. This item is still unresolved and will be tracked as Unresolved Item 50-348, 364/87-30-10.
(15) States and General Electric Teminal Blocks, File 34 and No File. The inspectors reviewed the file for States teminal blocks used inside containment in instrumentation and control circuits. The qualification basis was NUREG-0588, Category 11. Plant personnel indicated that the General Electric terminal blocks were included in the General Electric penetration file, but the reviewer could not find any evidence that terminal blocks were included in the steam testing of the penetrations, and the licensee later agreed with this position. The only reference to General Electric terminal blocks was in the licensee's response to E.Q. Action Items 018 and 067 pertaining to teminal blocks and loop accuracy requirements associated with IEN 84-47. The action items were identified by the licensee on October 27, 1987, and resolved to the licensee's satisfaction on 7 November 15, 1987. The._ license.e had perfomed a type test of the installed States blocks to qualify them for-vie in cohtFo-1 circiiits, but no insulation' resistance _(IRLinformation was
~~
ob~tained
.. -- in the_ test. -
To a T.Jualify_the blocAs-for-4nsttumertation. Q. Action items 018 and 067), the licenseecircuits (relative chose to cite a to Conax test report on Connectron NSS3 terminal ~ bloc 1cs and qua11Ty both-the States "and Tieneral Tlectric blocks-by' 51milarity. 'The similarity analysis was based on center-to-center spacing of terminal block poles, whether a barrier existed between poles, the height of the block with the barrier, and the width of the block with the barrier. The analysis stated that "all of the installed instrument loop terminal blocks have superior significant charact6ristics to the NSS3." A minimum IR of 3 x 107 ohms (L) was quoted from the Conax test as a basis for providing a value of .1 x 107L to Westinghouse for use in instrument loop accuracy calculations. The Jnspectors did not - agree _that the . similarity analysis _ was suffici'eht and-feit lhat
'thtquolgd ,JAs wm_ + 0 tally _.unrea.u stic. Consequertt]y%e NRC requested _that_.the_ licensee..pr_ovidg_ a Juf Mficat4o oL Continued _ Operation (JC0ffor the operatiig unit. On
~~
19W Tietino was held at the NRC of ctrr.in Novemb'er Atla ntaN~d25,Tscuss Farley EQ issues. The megjumary is included in~ a lettet.Lo..the .. license.hted January 22, M88. 'The
~
inspect 5i's reviewed the Conax report and found that'the' single data point for insulation resistance above 150*F (taken at 300*F) was very clearly stated in the test report as being
26 invalid due te instrumentation difficulties an'd the value was not plotted on the data plots provided by Conax. However, the licensee considered this to be acceptable test data to establish similarity. In ad tion, the licensee provided the intptttien team a enny of
% estnepWeted No"a-har 27. 1983.st4ch 4 "d %4e4-tha t
.t_he IR._vAlue.s_ demons 4 rated by_S.tattts. and AE. t_eminal blocks during design basis testing were not acceptable for use in instrumentation circuits.
Section 2.2(2) of NUREG-0588, Category II states in part that *
" test results should demonstrate that the equipment can perform its required function.. ." Irdormation Notice _8.4-47 c'early 5.tt.teddhe te_rminal__blocL hsyes_ a.LrLd suggested actions- by lleensees_Ani further stated that coHU deraV5nN- teltge currents _was.3.lready part of tFie TO~ final rule; 10 CFR 60.49.
Contrary to the above, the licensee did not have data to demonstrate that both States cnd General Electric terminal blocks would maintain acceptable instrument accuracy during design basis accidents. The cited _ test data for Connectron terminal blocks was considered inv.alId- 5f 3he'3es11nr-- or piriizaTion and sVnflarity betweef the Connectron and States teminal block was not established. It should also be noted that the only evidence of licensee response to IEN 84-47 was dated November 15, 1987. This is considered as Violation 348, 364/87-30-11. (16) File No. 1.0, Amphenol Coax Connector, Models "N" Plug 34500-1000 and Jack 18250-1000. The connectors qualified using this file are located inside and outside containment. Only the inside containment application of these connectors was considered during the file review. 1nese connectors are used to connect the plant's Victoreen Radiation Monitor to power and signal cables. The licensee considers these connectors qualified to the requirements of NUREG-0588, Category 1. Qualification is supported by the following test documents:
- Westinghouse Test Report, PEN-TR-84-08, dated June 1,1984
- Similarity Analysis perfomed by Bechtel (attachment 4 to EQREC No. 1, Rev. 1)
The Licensee has issued a maintenance w3rk request to seal the 1 1/2-inch opening in penetration B009-A, to provide additional protection from the effects of chemical spray, l 1
cd' m y . .\ W.3 gn b 27 The inspectors concluded these Amphenol Coax Connectors are qualified to the 10 CFR 50.49(k), NUREG-0588, Category 1, requirements for the conditions specified at the Farley Nuclear Plant. File No. 9A, Conax Medium Voltage Power Electrical Penetrations. (17) Model 7K69-10000. E The penetrations qualified using this file are located in the containment wall. They are used to supply power to the Reactor Coolant Pumps (Non-EQ Circuits). However, qualification is required to maintain the containment boundary. ' l The licensee considers these penetrations qualified to the requirements of NUREG-0588, Category 11. Qualification is supported by the following documents:
- Conax Test Report No. IPS-1286 Rev. A
- Conax Test Report No IPS-585.1 Rev. C
- Conax Test Report No. IPS-325 Rev. E The inspectors concluded these Conax Penetration Assemblies are qualified to the 10 CFR 50.49(k), NUREG-0588, Category II, requirements for the conditions specified at the Farley Nuclear Plant.
(18) File 9C, Conax Instrumentation Electric Penetration Assembly, Models 7D20-10001-01 and 02. The penetrations qualified using this file are located in the containment wall. They are f9r instrumentation circuits in the Inadequate Core Cooling System. The Licensee considers these penetrations qualified to the requirements of NUREG-0588, Category 11. Qualification is supported by the following test documents:
- Conax Test Report No IPS-1117 Rev. A
- Conax Test Report No. IPS-1054 Rev. 0
' Conax Test Report No IPS-325 Rev. E.
The inspectors concluded these Conax Penetration Assemblies are qualified to the 10 CFR 50.49(k). NUREG-0588, Category !!, requirements for the conditions specified at the Farley Nuclear Plant. (19) File 9D, Conax Electrical Penetration FTAs for ECT and ROSA, Models 7H59-10000-01 and 7H59-10001-01, 4
- 28 The penetrations qualified using this file are located in the containment wall. They are used in Non EQ instrument circuits.
However, qualification is required to maintain the Containment boundary. The Lic-9see considers these penetrations qualified to the requirements of NUREG-0528, Category 11. Qualification is supported by the following test documents.
- Conax Test Report No. IPS-1242 Rev. C
- Conax Test Report No. IPS-585.2 Rev. C
- Conax Test Report No. IPS-325 Rev. E
- Conax Test Report No. IPS-1054 Rev. 0 The inspectors concluded these Conax Penetration Assemblies are qualified to the 10 CFR 50.49(k). NUREG-0588, Category II, requirements for the conditions specified at the Farley Nuclear Plant.
(20) EQP No. 9E, Conax Feedthrough/ Adapter Module Assemblies for GE Penetrations, Models 7179-10000-01 and 02, 7F30-10000-01 through 06 and 08 through 17. The penetrations qualified using this file are located in the containment wall. They are used for EQ instrumentation and low voltage power circuits inside containment. The Licensee considers these penetrations qualified to the requirements of NUREG-0588, Category 11. Qualification is supported by the following test documents:
- Conax Test Report No. IPS-723 Rev. D
- Conax Test Report No. IPS-325 Rev. E The failure, in Farley Unit 1 of the originally installed General Electric Series 100 penetration modules, is discussed in Farley Licensee Event Report 016, dated October 9,1985. These failures necessitated the installation of the Conax Modules into the General Electric Penetrations.
The inspectors concluded these Conax Penetration Assemblies are qualified to the 10 CFR 50.49(k), NUREG-0588 Category !!, requirements for the conditions specified at the Farley Nuclear ' Plant. (21) File Number IB, General Electric Electrical Penetrations (Low Voltage) 100 Series, Models Y7156-1-15 and Y7156-455. 1
4 29 The penetrations qualified using this file are located in the containment wall. They are used for EQ instrum'entation and low voltage power circuits inside containment. The walkdown of containment electrical penetration assemblies identified terminal blocks that were not on the master list of qualified equipment. The GE penetrations were in the process of ; having the GE penetration modules replaced with Conax modules due to the unavailability of the GE modules. It was noted that many of the penetration junction boxes had top entry, unsealed conduits, and that at least one box had a hole with no conduit. Many of the boxes had holes in the bottom, some with cable - passing through and some empty. The Licensee considers these penetrations qualified to the requirements of NUREG-0588, Category II. Qualification is supported by the following test documents.
- GE Test Reports U-406155 Unit 2. U-400755 Unit 1 dated January 29, 1974 and Addendum No. 1 dated March 1974
- GE Test Report 941-V7110-3 Rev. O, dated May 16, 1973, U-406158 Unit 2.
' GE Test Report 941-V7110-5 Rev. O, dated May 16, 1973, U-406160 Unit 2.
- GE Test Report 941-SY008-1 Rev. O, dated May 31, 1973 U-406157 Unit 2.
' GE Test Report 941-SY008-2 Rev. O, dated May 31,'1973, U-400721 Unit 1.
i
- GE Test Report 941-SY008-5 Rev. O, dated May 31, 1973.
U-400723 Unit 1. GE Test Report 941-SY008-9 Rev. O, dated May 31, 1973, l U-400724 Unit 1.
- GE Test Report 941-SY008-13 Rev. O, dated May 31, 1973 U-406159 Unit 2.
i The licensee stated this file contained qualification data for l During l the GE CR151B terminal blocks used inside containment. l the course of the detailed file review it was noted that I qualification .of-these 4erminal Alocks -was .only addressod-4*-e se1smi~c.. qualification _ test.V The licensee stated.tht: tey wer?
~ - t I
attempting t6'obtain data to establish LOCA and poss-LOCA, qualification of the GE {R151B tenninarbT6 cts-for-mse on i instrument circuits inside containment. l 4
~ '-'
. , _ , _ -- - n, =- , a -- er , , -~--,-i r-e--, ri
30 The licensee stated IR values of 1.0 x 10E7 ohms were used as input to the loop accuracy calculations in Westinghouse WCAP-11658. Attachment 3 to EQREC 18 Rev.1 stated that IR values of -1.0 x 10E7 ohms shall be factored into the final setpoint calculation. This discrepancy was discussed with the Licensee and detertnined to be a typographical error. Additional test references supplied by the Licensee ,provided data to support a calculation input of 1.0 x 10E7 ohms. The inspectors concluded these General Electric Penetration Assemblies (excluding the GE CR151B terminal blocks) are qualified to the 10 CFR 50.49(k), NUREG-0588, Category II, requirements for the conditions specified at the Farley Nuclear - Plant. The lack of qualification documentation for the GE terminal blocks is considered a part of violation 50-348,364/87-30-11 and is discussed further in paragraph 6.i (15). (22) File humber 38, Veritrak (Westinghouse) Differential Pressure Transmitter, Model 59 Series. The Differential Pressure Transmitters qualified using this file are located outside containment. They are used to provide Service Water to Containment Cooler flow indication. The licensee considers these Differential Pressure Transmitters qualified to the requirements of NUREG-0588, Category II. Qualification is supported by the following test document:
- Franklin Institute Report F-C3715, dated October 1973 The inspectors concluded these Veritrak (Westinghouse)
Dif ferential Pressure Transmitters are qualifwd to the 10 CFR 50.49(k), NUREG-0588, Category II, requirements for the conditions specified at the Farley Nuclear Plant. (23) File Number 42, Westinghouse Low Voltage Control and Instru-mentation Electrical Penetrations, Models 328, 261 aM 246. The penetrations qualified using this file are located in the containment wall. They are used for EQ instrumentation and low voltage power circuits inside containment. The licensee considers these penetrations qualified to the requirements of NUREG-0588, Category II. Qualification .is supported by the following test document:
- PEN-TR-77-59, July 18, 1977 (Part of PEN-TR-79-07, January 25,1979) Qualification of Modular Type Electric
31 317-1976 and 1EEE Std. 323-1974 for use in PWR and BWR" (U-217092). The inspectors concluded these Westinghouse assemblies are qualified to the 10 CFR 50.49(k) penetration
. NUREG-0588, Category !!, requirements for the conditions specified at the Farley Nuclear Plant.
(24) File Number 4 - ITT Barton Remote Sensor, Models 352 and 353. Barton sensors are located both inside and outside containment and are used with different transmitters to provide level, pressure, and flow measurements. The Licensee considers these sensors qualified to the requirements of NUREG-0088, Category I. Qualification is supported by the following test document:
' ITT Barton Test Report No. R3-764-20, dated July, 19-84 The inspectors concluded that the Barton Models 352 and 353 sensors are qualified to 10 CFR 50.49(k), NUREG-0588, Category I, requirements for the conditions specified at the Farley Nuclear Plant.
(25) File Number 3A - ITT Barton Pressure Transmitter, Model 763. Barton Model 763 transmitters are located both inside and outside containment above the 115 ft, flood level. The licensee considers this transmitter to be qualified to the requirements of NUREG-0588, Category 1. Qualification is supported by the following test documents:
- ITT Barton Test Report No. R3-764-20, dated July 19, 1984.
- Addendum to Report No. R3-763-6, dated December 9, 1983.
The Barton Remote Sensors and the Model 763 (764) transmitters are considered an integral unit and Test Report R3-764-20 supports qualification of such a unit. The licensee specified environment for both the remote sensors and the transmitters (i.e., both 763 and 764) are enveloped by all the individual test reports. The required accuracies for the 763 (764) transmitters were not provided (i.e., the accuracies for both accident and post-accident conditions). The licensee acknowledged that the 20.5% accuracy specified SCEW sheet for the 763 transmitter was. an error. This number should have been c5.0, as was provided for the 764 transmitter. This accuracy issue is more generic in nature, however. The Licensee took the position that accuracy requirements need not be specified for individual instruments because the real issue was overall loop accuracy (i.e., the
7 s
- e <
32 overall accuracy when considering the accuracies and/or IR values for the individual components in the instrument loop). The licensee stated that instrument loop accuracies had been determined by Westinghouse and are provided in a report (WCAP-11685, dated November 13, 1987). The licensee did acknowledge that he failed to provide a reference to this report in some EQP files, however, (Note: Of the Barton, Foxboro, and . Rosemount files, only the Foxboro file referenced the WCAP report.) The overall issue of instrument accuracies is discussed further in paragraph 6.j. Demonstrated accuracias are proviced in the test reports for the - transmitters. These . demonstrated accuracies can thus be compared to the accuracy values inputed into the Westinghouse calculations. Specified accuracies in the Barton test reports are :5 and 210 for DBE-First 5 Minates and DBE-Post accident monitoring, respectively. A review of maintenance requirements for 763(764) transmitters resulted in a concern that 0-rings might be being reused when the transmitter covers were removed. The licensee verified, by providing a copy of the specific maintenance procedure, that 0-rings were not being reused. The licensee's response to IE Notice 83-72, as it related to Barton instruments, was reviewed and found to be adequate. The inspectors concluded that the Barton Model 763 transmitters are qualified to 10 CFR 50.49(k), NUREG-0588, Category I requirements for the conditions specified at the Farley Nuclear Plant. (26) EQP No. 3B - ITT Barton Differential Pressure Transmitter, Model 764 Barton Model 764 differential pressure transmitters are located both inside and outside containment above the 115 ft. flood level. The Licensee considers this transmitter to be qualified to the requirements of NUREG-0588, Category I. Qualification is supported by the following test reports:
- ITT Carton Test Report No. R3-764-9, dated October 5, 1982
- Addendum to IIT Barton Test Report N: R3-7 64-9.
The tests performed by Barton on the 763 and 764 transmitters were identical in terms of environmental and other conditions imposed on instruments. The discussions above involving accuracies, maintenance requirements, and IEN 83-72 are applicable to the Model 764 transmitters as well as the Model 763.
33 The inspectors concluded that the Earton Model 764 transmitters are qualified to 10 CFR 50.49(k). NUREG-0588. Category 1 -- requirements for the conditions specified at the Farley Nuclear Plant. (27) File Number 14A - Foxi,cro Transmitter, Model N-E11GM. Foxboro transmitters of this model are located inside containment above the flood level and - are used in the pressurizer and accumulator tank pressure instrument circuits. The licensee considers-this transmitter-to be qualified to the requirements of NUREG-0588, Category I. Qualification is supported by the following test report: -
- Wyle Test Report No.- 45592-4, dated May-18, 1983.
Actual test was performed on a Model No-E10 transmitter; the Model N-E11GM was qualified by similarity with supporting analysis to the Model N-E10. The loss-of-coolant (LOCA) temperature used in the test was 350'F. which is less than the composite LOCA/high energy-line-break (HELB) temperature of 378'F specified in the Farley FSAR. However, Bechtel calculations were performed and indicated that the peak surface temperature for the transmitters would be only 318'F. y Instrument accuracy was not specified (see discussion under K); however. -the Westinghouse WCAP-report -was--referenced in the file. A review of maintenance- requirements- ~ verified that-- the Licensee's procedures called for replacement of the instrument and the cover 0-ring at intervals that-would be conservative with respect to the qualified life of the transmitter. . The inspectors concluded that the Foxboro Model N-E11GM Transmitters are qualified to 10 CFR 50.49(k), NUREG-0588, Category I requirements for the conditions specified at the Farley Nuclear Plant. (28) File Number 31A/B, Rosemount Pressure-Transmitters, Models 1153D Code R and 1154. Rosemount pressure transmitters are used both inside and outside containment in pressure and flow measurement applications. . The transmitters are located above the flood level and-those inside containment are required to have a Rosemount Model 353C' conduit
34 seal. The Licensee considers these transmitters to be qualified to the requirements of NUREG-0588, Category I. ' Qualification is supported by the following documents:
- Rosemount Type Test Report No. D8300131, Rev. A, dated c December 13, 1983
- Roscrount Type Test Report No. 08300040, Rev. C, dated Map t i
'f?S, 4
Rosemount Report No. D8400102, Rev. B, dated June 14, 19P4 Note: Model 11530 Code R and 1154 transmitters are structurally - c identical. The only difference between the two models is the . value (not the physical dimensions) of certain sub-components (e.g., resistors). The test configuration for the transmitters utilized a 1/4-inch weep hole in the low point of the conduit run. This weep hole was not utilized in the as built configuration. When questioned aboet this concern, licensee stated that the conduit system inside containment is not air tight and will thus equalize .t pressure quickly. The concern of moisture intrusion is further diminished by the fact the Rosemount 353C seals are used inside containment aNf the conduit entry points were configured such that water would not stand on the end of the seal. This latter fact was determined through discussions with those Region II inspectors that had previously walked down this equipment. The tested LOCA temperature for the Model 11530 Code R transmitter (350'F) di? not envelope the composite LOCA/HELB temperature as specifica in the Farley FSAR (378'F). Sechtel calculations showed peak surface temperatures during LOCA to be 313'F (271'F for MSLB); therefore, the 350'F LOCA test temperature does enveicps the component's "as-seen" temperature. A review of maintenance documentation demonstrated that procedures were in place to replace these transmitters prior to the end of their qualified life. A review of the Licensee's response to IE Information Notice 85-100, concerning a zero point shift, indicated that the Licensee had revised six different calibration procedures and informed appropriate licensed personnel of the problem via a Training Change Notice, dated March 11, 1987. While jn
~
eting pressure transmitter 02B21pT407. it "e: noted
. that a V-type ap pire'ETTjFin the rondulst-adjacent trthe instrument,- Closer-ins)ection revealed that the insulation had been cut'all the way through on both instrument leads. This was confirmed when the licensee electrician removad the splices from
- 35 the condulet and the wire arched across to the condulet. Even though this splice was identified to be replaced during the licensee's walkdowns as per CAL October 6,1987. -the at
. instriation-was-not Marttified and is another example of poor peer _ review % See Unres51veThieC50 34Bi~354/87 25437 -
Paragraph 3.d. (29) A1CESolenohdalves Package 2A for NUREG 0588 Cat. II and Package 2B for 10 CFR 50.49, both SCEW sheets dated November 16, 1987. A_ major malific" inn coDcerJLrelated to the., absence _of cable _
,en,t trance seak4or the. harsh environment solenoid valies (SOVs) as determined in the previous plant walkdown inspection. The inspector reviewed and discussed in detail the licensee's "EQ Action Item Response No. B-001" which addressed this concern by dividing the SOVs into groups and jmtifying--Qence of c a b le--e nitance -s e ni s -for-ea ch-gr-ou p .
(a) Seventeen pilot SOVs (per unit) are located in the Main Steam Valve Room (MSVR). The licensee provided FSAR Figures E-1A and E-2 which show that the MSVR environment remains above 210'F for only 1.3 seconds, and the inspector agreed that a cable entrance seal would not be required for that environment. Howevet, a new WCAP report dated November 13, 1987 provided results of new calculations reflecting the steam generator tube superheat concerns of Information Notice 84-90; the newly calculated environment remains above 300'F for 5 minutes. The licensee was advised that if his continued evaluation of IN84-90 supported the newly calculated values apply to these SOVs, then cable entrance seals would be required. Simple confonnance to ASCO installation guideline permitting open conduit entrances with low point drain holes would not be acceptable because ASCO type testing did not demonstrate qualification for such a configuration. This item is ' unresolved pending completion of the licensee's action concerning IN 84-90 and is identified as part 1 of unresolved item 50-348, 364/87-30-12. (b) Four Pressurizer Power Operated Relief Valve (PORV) pilot
- SOVs (per unit) are located inside containment. The licensee demonstrated that the PORVs need not be actuated to provide any safety function; the pilot SOVs are shown on the EQ Master List only because the PORVs are reauired by c NUREG 0737. Just before the exit meeting tha licensee advised that a ten second required operating time would be shown in the EQ documentation for these SOVs, and the ;
inspector agreed that in that case no cable entrance seal is required. This item remains unresolved pending verification that the ten second operating time is
36 documented. This item is considered as part 2 of unresolved item 50-348, 364/87-30-12. 3 (c) One pilot 50V (per unit), P175V3184-B, is located inside containment. The associated isolation valve is normally open to provide component cooling water for the reactor coolant pump seals, a non-safety function. A Phase B containment isolation signal energizes the 50V to close the isolation valve; however the Phase B signal also isolates instrument air to co..tainment, which will close the isolation valve through loss of air pressure due to bleeding. Thus the SOY need not be qualified and a cable entrance seal is not required, provided that it is either - removed from the EQ Master List or it can be demonstrated by test data or analysis that the valve will operate within design requirements and still meet the single failure criteria. This item is considered as part 3 of unresolved item 50-348, 364/87-30-12. (d) The licensee stated that all other steam-environment SOVs on the Master List perform their function very early in the accident, are de-energized to perform their safety functions, and after actuation the current paths to the solenoid coils are interrupted by control equipment located in a mild environment. Questioning by the inspector further revealed that each coil is individually protected by a 3 amp fuse. It is concluded that these SOVs can perform their safety functions without cable entrance seals and after functioning there is no failure made that can adversely affect safety. Another 50V qualification concern involves'the failure of the licensee's original qualified life calculations to reflect higher nurmal operating temperature for normally-energized SOVs. This inspector determined that three Unit 1 SOVs and several Unit 2 SOVs had in fact operated beyond their qualified lives as determined by new licensee calculations. Unit I data are as follows: Date Qual. End of Date Tao No. Installed Life Qual Life Replace 3376 4/80 5.8 years 2/86 11/10/87 3443 4/80 5.8 years 2/86 11/10/87 8047 11/79 5.8 years 9/85 10/12/86
~
The licensee advised, near the end of the inspection, that the new qualified life calculations did not take credit for outages and that preliminary revised calculations show discrepancies of only about one month for SOVs 3376 and 3443. Another valve, 7126, was also reported as having a discrepancy of about three
_4 . l .
'37-
- months. Subsequent to theLinspection, the-licensee stated that for those. valves that appeared to have exceeded their qualified life, additional _ calculations were ~ performed to take into-account actual temperature and actual time. energized in order _ to extend _the qualified life-time. The licensee further stated in a management meeting held November 25, 1987, in Region:Il that the calculations extended the life to approximately eleven years. -The licensee, however, has not provided NRC- these calculations for review. This is considered Unresolved Item 50-348/87-30-13, ASCO Solenoid Valves Exceeding Qualified Life.
(30) Namco Limit Switches. ' Package 25A -for- NUREG' 0588 l Cat. II and 25C for _10 CFR 50.49 Namco limit switches. No concerns were. noted except that numerous limit switches covered by package 25A-are dependent on
- the Chico seals which are- covered separately. (Package 25C ,
limit switches use the Namco connector .to seal the cable ; entrance. r (31) Ca bl e_ E ntra nce._S t al.forla.tg et_ Roc k Sol eno i d Jalve s . This dasign was not addressed in -a qualification package. The reactor coolant system (RCS) head vent SOV are covered in package 35 documenting qualification to 10 CFR 50.49. -To - describe the design the licensee-provided. a drawing A-177541 (no sheet number) which shows a one inch' conduit nipple and a Y-fitting connected = to the SOV: ciBe entrance hub.: Each of=the two ports of the Y-fitting _ contains an unspecified length of one inch conduit nipple, and a Raychem CB-4 cable breakout-kit is. installed over each of:these two nipples and the lead wires entering the SOV. The drawing: calls for Greenfield adjustable type . compression fittings -and--_1-1/4 inch couplings to- be installed over . the Raychem boot, connected to 1_1/4 _ inch - Greenfield type flex - conduit. _ During the inspection ;the licensee did not provide a rationale for q6alification of this cable entrance design. . The inspector noted the following basic qualification deficiencies: (a) Raychem cable _ breakout kits are AOCA-qualif.ied-only aver cable jackets, et metaLpipe_nippl.as, and never with' metal conduit compress .ittings over. the plastic breakout. (b) This general design of device' entry seal was tested by both Raychem and Alabama Power Company. - and both _ experienced -
.catase;phic fdhm _during iLOCA testing because ther.e._u.
a vpij inside the Raychem boot adjacent = to the end of the f' pipe nipple. Tie 7omBntT1oh of external I,.QfJLpressuEand temperatura-iMuted_.jh'FTH10a'ge of; the heat-shr4nk-boot material.. lea __to._. ruptures of. the boot-wall . Possible softening of the Raychem adhesive could also aggravate seal
- 38 failure. Thus, the Farley design has been demonstrated by test to fail under LOCA conditions.
(c) No documentation was provided by the licensee to address these and other concerns, or to otherwise demonstrate qualification. Subsequent to the inspection the licensee indicated that the cable entrance design would be modified by introducing Chico cement. This modification has two unacceptable aspects. (1) The licensee has not demonstrated qualification for his Chico cable entrance, and - (2) Even if the Chico cable entrance were shown to be qualified for NUREG 0588 Category II, the qualification basis including test reports is inadequate for the 10 CFR 50.49 qualification level of the Target Rock SOVs. The deficiencies are addressed in the Chico cable entrance discussion. , The Target Rock cable entrance design constitutes a violation of 10 CFR 50.49 and is identified as Violation 50-348, 364/87-30-14. (32) Chico Seals Package 29G for NUREG 0588 Cat. II. W The licensee stated that his cable entrance design is used_only fnrJamcodimit switches qualified to NUREG 0588 Cat. II. The design is simlTrr-ttr-ttie cable entrance described above for the TargetNck RCS ~hearvenDalyes, in that a Raychem cable breakout seal kit is'Tipp'11ed over a Me inch pipe. nipple 2nd under ~1-1/4 inch -flex conduit ' fittings. Although not shown in the drawings, the~7icensee's contractor explained that a Raychem sleeve was installed over the breakout boot (and under the compression fitting) and the sleeve is clamped to the metal nipple. None of the drawings provided during,the_ inspect 4cn clearly shtnrth configurauon; in fact, the inspector drew the des'ign oirTwTTteb~oard to ensiFre understanding. In addition. Chico A inorganic cement mix is injected into the boot from the limit switch side to fill and seal internal voids. Tht_Jesign' was_dere_ loped _by Bechtel for Farley, and .is_not_2_Raychem
--designr Eo statemeiits7 rom:Jaychem _roncerning qualificat4cn of this design-were_proWed to the .inspe_cjors.
The file contained three qualification type--test r_gpor_ts. .Wy.le Report 58442-2 aiated April 3,1981 covers LOCA type-testing of a Raychem 403A112-52 cable breakout seal; it covers a cable breakout application (sealing individual insulated conduc* ors emerging from a translated cable jacket) but do'es not_addr_e_s5 a deMce_emtry- application Involving metal _ pipe _ nipples and j
39 conduit fittings. A Nnd reo3tJ covers a 1981 test of the Farley_ Chico _.seaLJesign, parform.gLfor the licensee; it is further described below. A tin'td_idt report describes testing of the Chico A material by@gthw u st Research Institute (Project No. 03-4974-001) for Grand Gulf Nuclear Station. Although the Grand Gulf design is very dIfferent from Farley's, the report does confirm that the Chico A materials are not damaged by the Farley total radiation dose. Fina.Qy., altbaugh not included in the- parlage-prov4ed _to the i.nspeypr for review, upoP
' questioning, the licensee did provide a four.=pagfL1981 BeIb.tel qualification xaport, drawings, and other documentation. The CEico :eal qualification was also discussed in some detail.
Additional information. provided during a November 25 meeting at - NRC Region II offices did not contribute any additional basis for qualification beyond the documentation and discussion at the plant site during the inspection. The 4481-Bechtelaualif.ication . report states that "since the breakout had be,en qualified previously, the Farley configuration needed only to be tested for pressure and temperstWewh time Epindent variations app 7oxlmaTing the p~os't01Tteo FirTey 1.0CA profile." The test actually performed exposed one sample of the Farley seal design to compressed air in an electrically heated chamber whose dimensions are not stated. Seal leakage was monitored by a pressure gage connected to the inside of the pipe nipple by an unspecified length of piping or tubing. In response to questioning, the licensee stated that "any increasing building of pressure inoicative of a pressure boundary breach would have been unacceptable;" however, an initial increase of uncalculated magnitude was expected due to expansion of trapped air in the leakoff volume". Since the sequence specified in the test procedure had resulted in catastrophic failure of specimens without Chico cement, the Chico test specimen was instead subjected to the following test sequence: The open chamber was electrically heated to 310*F. The chamber cover, with tf.st specimen attached, was installed and within about one minute, compressed air was admitted to bring the chamber to 60 psig. After seven minutes, the pressure was ramped down at about 0.5 psig per minute, and the temperature at roughly 1.0'F per minute. After li hours, the pressure was held at 15 psig and the temperature at 200*F for about 3 hours, then both were further reduced. The test was terminated after 24 hours, the last 151 hours of which were generally at or below 5 psig and 130*F. A_t no time was moisture or._rhemical - epray introduced into the test chamher. Further-core, no_ electrical perforianee measovernintL of any-type we6
~
made. / The gauge monitoring seal internal pressure initially read 0.4 psig on a 0 to 30 psig scale. It's reading steadily increased to 1.0 psig 51 minutes after installing the test
.s.:.._.L
l . .
. 40 ^ -
sample, at which time the chamber pressure had decreased to 35 psig and the temperature to 254*F. The leakage pressure then steadily dropped to 0.2 psig ovtr the next two hours, read from 0.4 to 0.6 psig for the next 4-3/4 hours (chamber down to 5 psig and 140 F), then generally read 0.2 psig thereafter. The test described above must bear the full burden of LOCA qualification for the Farley Chico seal design (other than for radiation). Raychem's qualification testing the sealing ability of its cable breakout kit is irrelevant because of the major differences in application of the Raychem seal, particularly the intimate involvement of Raychems plastic with metal in the e Farley design. In fact, the metal compression adapter bearing down on a Raychem sleeve surrounding a metal pipe nipple at elevated temperature must be regarded as a negative design feature until proven otherwise. The inspectors-conclude _that the type test of the Farity Chico _sealjesign 40es-not -adequately [ simulate Farley_LOCA conditjons for the following-reasons: (a) No steam __9r_moistute of any sort was present even though moisture leakage is a frequent cause of electrical equipment LOCA test failures. (b) NQ chemical spray _was-4 sed aven-though-the-effect-of-these chemicals..on_ bonding JLMie_R_aychem . seal to the metal pipe-nipple isDonsider.able-conceib7e licensee. addressed this concern only_ by stating tha't Raychem's type test , showed .that _the spray does not react with the" adhesive; p howeyvJr, e the Rashem-testdoes .not address __the_binB between / \ the adhesive and the m.etal__ pipe niqpl.e. and the licensee Tur r-cauttons_thatthe _tpray.my_ react with the mipple's ne coatino to formt.3_gr.Ay_pqwier-._that -could fur-ther_
- c. enje_the_ adhesive-bonds . The inspectors note in this regard that the Raychem NEIS conduit seal kit has been successfully qualification tested for high energy line breaks outside containment (no chemicals), but LOCA qualification is not claimed and a stainless steel pipe nipple is used.
(c) The ow initial temperature increaseYfailure to simulate th -themal shock of the LULA transient as it would ct rapid differential thermal expInsion of-the metal, plastic, and cement portions of the seal. Additionally, the nature of the test appears to avoid simultaneous application __of Dea lpItssure and temperature as is-tnus.of tie plant LOCA profile, so that7he most, severe combination is not simulated. The test in fact if nonconservative because softening of the Raychem plastic by temperature will occur after the pressure peak. i . .
41 (d) Although not mandatory for qualification to Category II _ of NUREG 0588, Rock solenoid Category)1 valves could not- qualification be based(as on for thisthe testTarget because of failure to age the test specimen, failure to perform the complete test sequence on a single specimen and numerous QA/QC-related deficiencies. The inspectors also concluded that the data taken during the test did not support qualification of the Farley Chico seal design for the following reasons: : (1) The dry chamber atmosphere and lack of electrical performance measurements of any type constitute a failure to monitor the performance of the seal design in its major function - keeping electrical circuits dry. (2) The O to 30 psig leakage gauge appears to be of dubious value for detection of small, short-terr leaks (and the o absence of moisture and chemicals greatly reduces the probability of small, long-term ' leaks). In fact, the increase in measured pressure for the_first 51 minutes of the test, while the chamber pressure and temperature decreased significantly, suggests that the seal did leak. The subsequent increase in measured pressure, maintained over an additional 4 J/4 hours, also suggests a leak. A conclusion that no leakage occurred appears to be unfounded. The inspectors also concluded that the licensee's procedures for installing the Chico seal did not adequately control the uniformity of the seals, for reasons including the following: (1) Drawing A-177541 sheet 235-1, Rev. O does not control the minimum quantity-of Chico mixture. It specifies injecting - li ounces into the pipe nipple, and cautions against using more than li ounces to ensure against forcing the mixture into the limit switch housing. Since the Chico mixture is injected through the side of the limit switch into the assembled Raychem boot and conduit, using a hypodermic syringe and tubing, the technician cannot easily see _ when the seal cavity is-filled. (2) Procedures provided to inspectors did not cover details known to be important in Raychem-designed applications of their seals, such as surface preparation, detailed use of a heat gun, and selection of _ properly dimensioned kits. , (3) Similarity of the test specimen to plant equipment was also not established. The test procedure references drawing A-177541 sheets 23K, 231., and 23P all Rev. O, whereas the inspectors were given sheets 23K Rev. 2, 23M Rev.1, and
t
~
. . 42 23U Rev. 1. The inspectors noted that the quantity and type of Chico cement are included in " clouds" on two of the drawings, and the Raychem cable breakout kit number on one.
No explanation of differences was provided. (4) Infomation provided by the licensee concerning the metal compression adapter applied over the Raychem sleeve contains conflicts. The 1981 test procedure material list calls out a "Greenfield compression fitting or equivalent." Drawings provided during the inspection show a "Greenfield adjustable type compression fitting" for both the Chico seal and the Target Rock SOV. At the Region II meeting, the drawing provided calls out an " adjustable type . compression fitting," and the test provided refers to an "appleton compression adapter." In no case is a model number specified. In summary, the-Chico seal package provided for review fails to 1 documenf qualification, and review of additional material provided during and after the inspection also fails to establish qualification. Chico seals constitute failure to adequately demonstrate qualification for violation 50-348,364/87-30-15.
- j. Instrument Accuracy.
The inspectors had difficulty detemining how the overall subject of instrument accuracy was addressed for Farley. Relevant equipment files do not contain plant perfomance requirements. These files cover transmitters, cable, terminal blocks, and containment penetrations. The category " Accuracy" had been deleted from System Component Evaluation Worksheet imediately before the inspection. File deficiencies further complicated the review; for example there was no file for GE terminal blocks because the licensee erroneously assumed that they were covered in the GE containment penetration package. A proprietary Westinghouse report, WCAP-11658 dated November 13, 1987 covered much .but not all of the -accuracy evaluation. For example, it included loop-by-loop cable leakage current valves transmitted to Westinghouse by an Alabama Power Company letter dated November 11, 1987, but the Bechtel calculations were not available for inspection; they were subsequently explained to the inspectors' satisfaction using sampler pages faxed from Bechtel's Gaithersburg office. Acceptance criteria values for transmitter loops were not provided in the WCAP, nor were the values of errors calculated for each loop; concerns _ in this area were resolved by Westinghouse personnel in a -meeting the evening before the exit meeting. The WCAP included as Appendix A.4. a short Bechtel letter dated November 5,1987 stating that a value of IE7 ohms should be used for each teminal block, but providing no basis for that number. 1
43 Farley is vulnerable to instrument accuracy concerns because of the widespread use of terminal- blocks in in-containment instrument circuits. The inspectors felt that the problem is , aggravated by the arrangement of relevant documentation, described in the following paragraphs. Transmitter files, although lacking plant acceptance criteria, do identify errors determined during LOCA testing, and those errors were provided to Westinghouse. Unfortunately, the licensee had to address.all test anomalies without knowledge of required performance. All anomalies were found acceptable by the licensee. The States terminal block file used the acceptance criteria that the block should n'ot experience completely open or short circuits during the LOCA test. No data pertaining to instrument circuit performance were present, and substantial physical distortion apparently caused by heat softening was considered. acceptable. There was no package for GE terminal blocks. On the second afternoon of the inspection, a- four page typed response to inspector questions stated that a value of IE7 ohms was supported by a test of Connectron teminal blocks and the licensee proposed to use that test as a basis for qualifying states and GE terminal blocks. Instrument cable packages documented the leakage currents measured during LOCA listing. The Bechtel calculation cited above then determined, for the cable type and length in each instrument loop, the minimum LOCA leakage current.- As for transmitters and terminal blocks, the acceptability of these valves was determined by Westinghouse. The Westinghouse methodology for combining instrument loop errors was described in IEEE Transactions on Nuclear Science vol. NS-33 number 1 February-1986, pages 684-7,- and was generically reviewed by the NRC as reported in Supplement 4-to NUREG 0717, the Summer Nuclear Station SER, dated August 1982. Subsequently, plant-specific WCAPs have been reviewed in the NTOL licensing process by ICSB. .For Farley, WCAP-11658 specifically addresses the " Evaluation of the Impact' of Cable and Teminal Block Leakage on RPS/ESFAS and ERP Setpoints." It-is Westinghouse Proprietary : Class II. WCAP-11658 does not include calculations or quantitative comparisons of calculated loop errors with setpoint values. Although most inputs defining EQ errors for loop components are included Barton and Rosemount transmitter errors are not specified. Accordingly, there was not sufficient information at hand to pemit verifying the overall consistency of the-instrument accuracy calculations. For example, if the IE7 ohm terminal block resistance could not be supported, available information did not permit estimating the impact on accuracy. The licensee offered to bring
44-Westinghouse personnel to the _ site for a mee ing, and the inspectors agreed. Westinghouse confirmed that EQ errors were combined for Farley in a conservative manner. Although sp?cific E0P setpoint values were in general not discussed, Westinghouse's approach to establishing setpoint values that do not infringe on normal operation was explained. The " Engineering Evaluation" basis for acceptability in WCAP-11658 was explained as including (1)'an error in a conservative direction, (2) a change considered insignificant with respect to imposing operator response, and (3) a change that was considered to have no impact on the events - scenario. Westinghouse confirmed that-two terminal blocks per loop were assumed- inside containment, one each at the transmitter and _ containment penetration. Westinghouse - also stated that the loop error contributed by terminal blocks is about 0.05% at IE7 ohms - increasing by one decade for each decade decrease in= resistance; these values are consistent with
- the inspectors' expectations.
- All questions relating to WCAP-11658 were resolved.
The inspectors concluded that, even though a separate violation may not-be warranted at this time, the licensee's documentation related to instrument accuracy should be placed in a. controlled, auditable format to meet the intent of 10 CFR 50.49.
Attachment:
Environmental Qualification Program Presentation j
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-----_--_____________________j
. .s ATTACHMENT ALABAMA POWER COMPANY FARLEY NUCLEAR PLANT ENVIRONMENTAL QUALIFICATION PROGRAM PRESENTATION NRC EQ AUDIT NOVEMBER 16 - 20, 1987 e
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, r FARLEY NUCLEAR PLANT NRC EQ AUDIT
- AGENDA INTRODUCTION J. D. Woodard-General Manager-Nuclear Plant HISTORY David Jones ORGANIZATION W. B. Shipman '
Assistant General Manager - Plant Support EQ DOCUMENTATION W. G. Ware MAINTENANCE AND SURVEILLANCE R. G. Berryhill Manager'-Performance & Planning-Nuclear ATTACHMENT . . . _ i . e 4 ,_ J* .. _ . _ . _ _ _ . _ _ . _ - . _ =
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E. Q. INSPECTION TRACKING SHEET FARLEY NUCLEAR PLANT NRC_ INSPECTOR: .DATE: EQ COMPONENT: EQ FILE NUMBER: . NRC OUESTION: ' ESPONSE A$$1GNED TO: DATE: _PCO RESPONSE: DATE: 5 m 4 E 4 ,_
#" . . A . . . .
E.Q. DOCUMENTATION e MASTER EQUIPMENT LT.ST
- e. ENVIRONMENTAL PROrILES. ,
e CENTRAL RILE
- Environmental Qualification Test Reports
- Environmental Qualification Report Ivaluation Checklist
- System-component Evaluation Worksheet Supporting Documentation O
9 f 7 4 .-
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%e MASTER EQUIPitENT LIST , ,
e Provided for each unit e Defines / identifies components relied on to function (or not fail) when exposed to a.potentially harsh environment resulting from a postolated Design Basis event e Component identified by system't plant identification number, generic name, manufacturer, model number, building location, and elevation e Controlled by TNP-0-AP-8
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a. e I (p. .- s 8 ,
f JOSEPH M. FARLEY WUCLEAR PLANT UNIT 1 _ , (Class 1E Electrical EquiFment Required to Tunction Under Postulated Accide'nt Conditions)
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SYSTEM: Teodwater Centrol System ,
/M CCMPCVEWTS
, _ LOCATION PLANT ID FC. CENERIC EAXE MAWFACTURER MODEL SLDC ELEV _
Q1C221SO478 ' Limit ', Mn Sta (FCve78) Switch g MAMCO EA-180 Room 131' Q1C22SV0478A Solenoid Mn Sta (FCV478) g Valve ASCO MV-206-381-2U Rome 131' Q1C22SV0478B Solenoid , Mn Sta > (FCV478) Valve ASCO WV-206-381-2U Reem ~131' Q1C222SO488 Limit - Mn Sta (FCV488) Switch g NAMCO EA-180 Reem 131' ' Q1C22SVC488A . Solenoid - Mn Sta > , (FCV488) Velve ASCO MV-206-381-2U Roem ~131' Q1C22SV04888 Solenoid Mn Sta (FCV488) Valve g ASCO MV-206-381-20 Room 131' Q1C22:SO498 Limit Mn Sta (FCV498) Svitch
, g WAMCO EA-180 Room 131' '
Q1C22SV0498A Solenoid Mn Sta > (FCV498) Valve ASCO - MV-206-381-2U Room ~ 131'
. Q1C22SV04983 Solenoid un Sta k (FCV498) Velve ASCO MV-206-381-2U Reem
~131'
( Q1C222SO479 (?CV479) Limit .
. Mn St.a Switch NAhCO EA-180 Reem 130' Q1C22SV0479A Solenoid Mn Sta (FCV479) Valve ASCO W- 206-381 -4U Reen 130' Q1C22SVC479B Solenoid Mn Sta IFCYa79) Valve ASCO- W-206-3 81-4U Q1C22:30489 Limit Room 130' _
, Mn Sta >
(FCV489) Switch EA-180 _NAMCO Room ~131' Q1C22SVC489A SolenciA Mn Sta > (FCV489) Valve ASCO MV-206-381-4U Reem ~131' Q1C22SVC489B Solenoid Mn Stc > (FCV489) Valve ASCO WV-206-381-4U Reem ~131' Q1C22:30499 Limit Mn Sta (FCV499) Switch WAMCO
, g EA-180 Reen 131' Q1C22SV0499A Solenoid 'Mn Sta (FCV499) Valve ASCO g
W-206 -381-4 U Roem 131' Q1C22SV04998 Solenoid Mn Stm (FCV499) Valve' ASCO g WV-206-381-4U Reem 131' Ter.ninal States Mn Sta N1C22SV0478A-A/J3 Bleek Cevany
, g Type t'Irt Room 131' Terv.inal States Mn Sta WIC22SV0488A-A/JB Bldek Cemeany Tvse I'.M Room ~131' Terminal States Mn Stn N1C22SV0498A-A/JB Block Cemoany _ Tve e tw Roem ~131'
( IVAL5060B
. Control Cable Mn Sta Meem
~131'
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e List cf Test Reports
- Typical information provided/r forence'd supporting qualification O
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IN7!RCSM""AL C" ALIT *CATICN REPORT I"7AI.UA!!CN C*EC?T !$T m uip=en: Dese:1ptic Ma:ufac:ure - a __ Model/ Serial No. /' qalifier (Test ub) Report No. *
?lant Ar.ta Ivalua:ed fc: Equiper. : I:s ta'14:i . ?:apared by *1:la _ Date Tas:
1eport Reecire=et: luit Co=pliance See:13: 10 CTR 50.'9 7.cle See:1:: Tes i No er Pare R e= arks 1.0 Te:: era:ure and ?ressure (e)(1) Does the :r.s: preftle acceptably e: vel p the : =perature a:d , pressure c= di:1::s resulting f := the =es: severe desig basis accide:: duri:s c felieving
- vhich the equip =e:: is required to re:41: fu ::ie:al?
2.0 - u=1dity . (e)(2) Was hr.=1di:7 c: sidered i= the qualift:a:1:: ;;:gra=?
- 3.0 Che:1:a1 Iffe::s (e)(3)
Was the che=1:al spray used i: qualifica:ic testi:3 the sa=a or =cre severe that testi:g resul:is; f::= the ==s: 11=1:1:3
- ode of p1A=: operatic ?
1.3 2.a d ia :Len . (e)(4) Vas the radia:1cn 1: :he quali-fica:10: :es: based c:: 1) :he 7pe of radia:10. 4.xpec:ed, 2) the :etal dese e.xpe :ediduring mor a1 opera:icn over the installed life of the equipses: - - plus the cos: severe 03A duri:s t-or fo11ov1:g whi:h :he equip:e:: T, is required :s reesi: fuse:10:al, 4 ._ a:d 3) rad'a:1:: resul:ing f:: .
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l . TABLE 7.0-1 LIST OF VENDORS - {})'AmphenolCoaxconnectors
- 2. Automatic Switch company solenoid valves - NP, 206 and HP-1 Series ,
- 3. Barton Transmitters - Models 763 and 764
(}) sarton Transmitter sensors - Models 352 and 353
- 5. Boston Insulated Wire and Cable >
- 6. Brand-Rex Cable
() Brown-Boveri - Could 5600 series MCC Telemecanique) (Supplier
~
. aussmann ruses and ruseholders -
~
Champlain cable Corporation 600 V Grade Wires and Cables
- 10. Chico A Sealing Compound .
(
- 11. Combustion Engineering Inadequate C5re Cooling System
- 12. Conax Electrical Penetrations and Thermocouples and Cable
- 13. Conax Penetration Modules
. Electroswitch Lockout Relays
. ERD whittaker MI Cable system with Connectors (suppliers (
combustion)
- 16. Fisher E/P Converter for RHR Hx Contrcl Valves
- 17. roxboro Transmitter - Models E11GM (MCA), E13DM, N-E11GM, N-E11GH, N-E13DM, N-E13DH
- 18. Camma-Metrics Neutron riux Monitor - RCS Series O19. GE'S Delaval Level Transmitter - Medel XM-36495: Level Tre.1smitte. - Model LS-36497: Level switch - Model XM-54852A Level sensor - Model XM-54854 Receiver - Model RE-36562A
- 20. General Electric 600 VAC Motors
- 21. General Electric Penetraticas - 100 Series ..
- 22. General Electric ruse Blocks - Model 8452-3
- 23. G& H Technologies (Suppliers Combustion)
- 24. ITT Gould (See Brown Boveri)
- 25. ITT Imperial (See Brown severi) 26, ITT Suprenant 600 V SIS Wire .
- 27. Joy Manufacturing Containment ren Mptors Limitorque Mo, tor Operators
~- .
r DEC ETP-137/2 17 Rev. 0 9 .~
/*- .. .
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1 1 < * . Table 7.0-1 (continuod) . L!s; or VENDORS, t antinued
- 29. Limito que Brakes for Limitorque Actuators (Dings Company)
- 30. NAMCo Limit switches - Model EA-180 and EA-170XI302 l 31. okonite Control and Power Cable
! 32. okonite Instrument cable (okuzel Insulated, I ([]}3) Raychem Cable - stilan, rlastrol and splice
- 34. Rosemount RTD - Models 176Kr and 176Ks ~
- 35. Rosemount Pressure Transmitters - Models 1153D and 1154
- 36. Rosemont Remote seals - Model 1159
- 37. Rosemount conduit seal Model 353C '
- 38. states Terminal slock - Type ZWM and NT
- 39. Target Rock solenoid valve - Model 79AB-001
- 40. Telemecanique Qualification of Motor control Centers (Mcc) 10, IV, 2U and 2V and their components. (see also Brown
'+ Boveri)
- 41. Texaco Grease
~~~
- 42. Veritrak Differential Transmitters e Model 59 series
- 43. Victoreen Radiation Monit'or - Model 877-1
- 44. Weidmuller Terminations Inc. Terminal slocks
- 45. Westinghouse Disconnect switches
- 46. Westinghouse tiectric Mydrogen Recombiner - Type A
- 47. Westinghouse Penetration
- 48. Westinghouse Pump Motors s
~ ~ - .
r DEC ETP-137/2. 18 Rev. 0-gy. .- J i-
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- 1. F .0GR m FRCC E; 3 E4 AG GCU.':E t;T.7 Am-! .-0:0 E a v i e on.iie n t a t Quaiiti:ation Frogran; *er:rirt i :. n FNF ET P-4 i OE FNF Environmental-Qualifac: tion Prograhi '
Imptementation thP-0-ETF-424? Guideline.r to Ma int a i n Enviromnent a lly Qualified Equipment HAINTENANCE PROCEDUhl; FCA EQ TERMINATIONS /SFLICES F.NP-C-nf-9i.0 Termina* ion of Environ.nentaL-Quatified Hotori Using Raycnem Motor Inspecti6h Kits FNP-0-MF -fi . i Termination of Environmental Qualified Limitortue hotors Using Raychem hotor Connect ion Kits (Electr ica l Ma intenance>
'N5 MF -? 1. 2 In-Line Environmental Qu.Liiivd Termineison Urin; Paycheo Heat Shrink (Etectrical naintenance.' .
EQ INIFECTION PROCELUPi! ' 3.s F - '-E T F - 4;i 's :ntrection Procecure for Ra chem Heat ihrint , In Line !p t ice; or Repa irs
~r- P-0-ET?-4 'r i Insp ec t ion Precedure for Raycne.u' Heat thring "onnectiont thP-0-ETP-d263 EQ Instrumentation Spiice/ Termination Inspection Ib?-0-ETP-4~.64 EQ Inspect ion of Electr ita L Ponetrat iont intide Centainment
??'? ET P-4 2 : 5 EQ Inspectson of itectricat F.'ene t t a t i on: OL<:.cf C On t i i n:ne n t
% k- - {T& .:2 ,.[ EQ ir.jpg; tic,, of ;,ny*puggnt . g g p ,. .
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~ts .-G-ETP-4;T'. . Eu Inspec t ion of Jo tenoid .'a tv+.
~NP-0-ETF-42Ti 20 Inspec t i on o f L i m i t-sequ'c Op e r a t err 4 .-.
. 19 i 3.. .
l _ _ _ _ _ _ - . . _ _ _ _ . _ _ _ e
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!-ET. .,*. E2 Progi am Eva luations and Review
.'3
.v?-0-Ei-e-hyJ Invir:amentst 2ua t iiica1 t on Jaspect i:n st
. : i sc e t .a neous !.av ! r sovie n t a . n Ca e t i t i 3:!
It4ipene M AMINISTRATIVE PROCEDURES APPLICAf:LE TO EQ
- !P-0-AP-1 Development, Review, and Approva l 6f Plant Protecure -
NF-0-AF-3 Plant Organi za t ion and Resp'ontib i li ty NP-0-AP-4 Control of Plant Decuments and Records WP-J-AF-! Jurve i llance Progr am Ad.ni ni sba t i ve Controi NP-0-AF-E - Design hedification Control W-0-AP-9 + Frecurement and Procurement Docunient Control
- -0-AP-l! 'As intenance Conduc t of Operations tr-C-M -13 Concuct o f "n e r a *. t ons - T ectin i c a l G r e ap 6*lk b 5 '
9.-t'-er v neceipt Inspection: t% s et AF - J1 - dentift:ation anc Centroi :t naterialt, P6 tty And C onip o ne n t f d-9 mF-2~ Nonconforn.ance Contro t / ?+ficiency hoori a no 9-s'- A F-OI Hand!ing, Storage, anc Snipping of nateria!I, Components, and Etuipment iP-0-AP-2C E*t u i p me n t Identification 4F-0-AP-27 Conduct of Operations - Training Group 4P-0-AF-Oi Plant Lubtication Program
~
I?-G- AF -I i uality Control Measurar , . 4?- -AP-22 Feview c- Operating 04 6
'P-i- AF -;T Generat Pieat Hottet:een i A9 sr. d '. . e i n 1 i a+ / /
ConTro s.*5*$F-5A . 0leaniiav!! Q' ?le.. .I'* i T e m! 'a n d t= E C 'J e i iTi Couponeri** , *
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FNP 0-AP-45 .Farley Nuclear Plant Training Plan
-N--0-AP-51 I.irtrumentation and Contrel Group Concuct of CPerttien enF-0-AF-52
- Iquipment Statur Contrat and naintenance Autnori:staco FNP-0-AP-f3 -
Preventive Maintenance Program FNF-0-AP-62 Evaluations of Defects and Noncompliances Potentially Reportable Under 10CFR21 FNP-0-AF-63 Cenduct of Operations - Systems Performance Group FNP AF -6 5 FNP Operating Experience Evituation Program FNP-0-AP-70 Concoct of Operation: - Plant Modifications and Maintenance Support - LIST OF OTHER FRCCEDURES APPLICABLE TO EQ COMPONENTI
'NP-0-hP-70.0 FNP-0-hP-82.0 9-nP-83.:. FNP-0-MP-34.0 The-0-hP-25.i?? FNP-0-MP-29.i67 FNP-0-MP-29.104 FNP-0-MP-28.iT2 FNP-0-hP-25.212 FNP-0-hP-45.0 FNP-0-MF wr.1 FNP-0-MP-45.2 INP-0-nP-4f.i inF Master List of Our.eillance Retuirements GENERAL hAINTENAtJCE PPOCEDURES APPLICABLE TO EQ:
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~hP-0-GMF-T TNP-0-GnP-12.0
'NP-0-GhF-13.0
~NP-0-GnP-iT.v
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;MF-0-GnF-Si INSTAUMEHT -!AINTENANCE PROCEDUEE .4PPLICABLE TO IQ
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V2 tiAR 13 P12:09 ,T Fafe M MPk, Wm 10CFR50.49 cr M :9 : t g i ;,,,, N chi W 3 <i. m r! rkt,NLu ,. r0 January 8,1983 E Docket Hos. 50-348 50-364 Mr. D. M. Verre111 U. S. Nuclear Regulatory Commission Region 11, Suite 3100 101 Marietta ' treet N. W. Atlanta, GA 30303
Dear Mr. Verre111:
Joseph M. Farley Huclear Plant - Units 1 and 2 Environnental Qualit1 cation of Raychem/ CHICO Sealant and Terminal Blocks Per discussiens between Alabama Power Company and the llRC Region 11 Staf f, attached is additional docunentation that supports the environnental qualification of Raychem/ CHICO Scalant and terminal blocks used in farley Huclear Plant. Attachnent 1 provides additional environrental qualification docurentation that should address the HRC concerns regarding the scaling integrity of the Attachment 2 provides an assessment of' Farley Raychem/ CHICO configuration. twenty eight (28) terminal blocks tested for use in nuclear power plants. The results of this review supports the qualification of the GE CR151B and States ZWM Terminal Blocks used in the Farley Nuclear Plant. It should be noted, however, that all terminal blocks in instrument circuits within the scope of environnental qualification inside containment have been replaced with cr.vironmentally qualified splices. It is the position of Alabama Power Company that terminal blocks and Raychem/ CHICO sealant used in Farley Hucicar Plant will perform their intended function when exposed to their relevant environrent and are therefore environmentally qualified.
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, .lg, r..., January 8, 1988 fir. D. H. Verre111 Page 2 U. S. Iluclear Regulatory Commission If there are any questions, please advise. Respectfully submitted, ALABAMA Porter COMPANY LO. . (bs .p~~~ R. P. ficDonald RPM /DHJ : ds t-T.S .
. Attachtnents cc: Mr. L. B. Long Mr. E. A. Reeves Dr. J.14. Grace Mr. H. C. Dance Mr. W. H. Pradford U. 5. Nuclear Regulatory Commission ATTH: Document Control Desk liashington, DC 205 %
ATTACHMENT 1 _. Bechtel Eastem Power Company Engineers - Constructors 15740 Shady Orwe Road - Galthersburg, Maryland 20877 1454 (301) 25&4000 > January 7, 1988 , In reply refer to AP-14075 Mr. W. G. Hairston, III Alabama Power Company 600 North 18th 8treet Post Office Box 2641 Birmingham, Alabama 35291-0400 Daar Mr. Hairstont Joseph M. Farley Nuclear Plant Units 1 and 2 Bechtel Job 7597-042 Raychem/ chico sealant Environmental Qualification (ES 87-890) Bechtel File A-88 and E-91 AP-14075 This letter is written to transmit the Raychem/ Chico Sealant Environmental Qualification avaluation and Attachments 1 thru 7 in response to the request from your Mr. D. H. Jones. The evaluation addresses the NRC concerns regarding the sealing integrity of the Farley Raychem/ Chico configuration. Environnenntal Qualification Package No. 29G, Rev. 2 provides the basic qualification of this Raychem/ Chico configuration for 40 years plus DBE at FNP. It will be revised to include this evaluation at a later date. If you have any v estions or comments, please contact us. You vary truly, , ('
- p. #. Candhi Project Engineer ECG/JES/SK sg Enclosures As stated above cc J. R. Crane, w/1 J. D. Woodard, w/1 L. B. IAng, w/1 J. E. Carlington, w/1 R. G. Woodfin, w/1 R. P. Mcdonald D. H. Jones, w/1 R. W. Stewart, w/1 A(N cfBeets' % orpyskr
s t Ravehen/ chico sealant Envirennental cualification I. Introduction At the NRC Environmental Qualification audit at Tarley 16, 1987, Nucisar Plant (THP) during the week of November the NRC inspection team concluded that the Raycham/ CHICO seal qualification package had not demonstrated that the Raychem/ CHICO configuration will seal the conduit nipple l entrance to NAMCO limit switches during LOCA/MSLB design basis events. This NRC conclusion was based upon the l l absence of chemical spray during the qualification testing The of the installed Raychem/ CHICO seal configuration. postulated failure mechanism discussed during the audit was corrosion of the sinc coating on the galvanized steel nipple I due to exposure ins chemical sprays. The result was . postulated to be a path for enough noisture to enter the limit switch between the Raychem seal components and the degraded conduit tinc coating to cause functional failure of the limit switch. , The following discussion evaluates the Raychem/ CHICO environmental seal configuration at FNP for the postulated 14CA/HELB conditions. This evaluation concludes that the Raychem/ CHICO seal will saintain its integrity and prevent noisture intrusion which could potentially lead to loss of function of the limit switch when subjected to its relevant 1 _ _ . _ _ _ . . ' --+w' er , , _ , , _ _ , _ _ , _
Havchan/ CHIC 0 Sealant Envirenrantal cualification environment. This conclusion is based upon a detailed review of literature and independent tests conducted by Sandia Labs and Raychst on similar configurations that l'neluded chemical spray. f II. PNP confleuration The following paragraphe describe in detail the Farley configuration relative to the postulated failure described above. In summary, it should be noted that CHICO A alone To provides a pressure seal inside the conduit nipple. provide additional assurance that noisture will not enter the limit switch, three additional barriers have been They are: applied to the FNP configuration.
- 1) Raychem breakout boot (Part Number 502A823-52/144)
- 2) Keeper sleeve (Raychem)
- 3) Compression adapter clamp The Raychem breakout kit used for the FNP application le' environmentally qualified including thermal aging, irradiation, and LOCA/MSLB testing with chemical sprays (Reference Wyle Test Report No. 58442-2, dated 4/03/81).
The Yarley configuration uses the Raychem breakout kit at the and of the conduit nipple. Since the breakout kit had been qualified previously, and there were no known 2
Ravehen/ CHICO Bealant Environmental Qualification deleterious affects of chemical sprays on CHICO A, Farley conducted a test on the Raychen/ CHICO environmental seal configuration shown in Attachment No. 1 for pressure and temperature conditions postulated during a LOCA without introducing chemical sprays (Reference Qualification Testing of Raychem Environmental seals for Alabama Power Company, Joseph M. Farley Nucisar Plant, dated 12/30/81). As shown in Attachment No. 1, each environmental seal is corposed of a Raychem breakout boot that has been shrunk onto a 1" conduit nipple attached to the NAMCO Limit switch. The individual conductors connected to the switch pass through the breakout boot which forms a seal to the conductor insulation / jacket. To provide techanical rigidity to the breakout boot, a portion of the nipple and the breakout boot are filled with Crouse-Hinds analing corpound (CHICO A) and allowed to cure. In addition to providing mechanical rigidity to the braakout boot crotch, the CHICO A compound provides an additional pressure barrier (seal) inside the conduit nipple. CHICO A is an inorganic expansive cement sixture developed and marketed by Crouse-Hinds Electrical Construction Materials a Division of Cooper Industries, Inc. CHICO A was developed for sealing explosive proof electric fittings and is used 3
---- _ _ ___ __11_ _ :_z
Raveher/ chico sealant Environtentai cum 11fication in National Electrical Code (NEC) Class I, Division 1 or Division 2, hazardous locations. CHICO A was qualified by , test conducted by Southwsst Research Institute (8WRI Project No. 03-4974-001) for use as BWR VI Mark III electrical drywell penetrations. In addition, a Raychen keeper sleeve is shrunk over the breakout boot and conduit nipple, and an Appleton compression adapter is clamped over the keeper sleeve which nochanically compresses the keeper sleeve to the conduit nipple. The Tarley configuration using tho qualified breakout kit and CHICO A sealing compound in conjunction with the additional barriers, ensures that the Raychem/ CHICO seal will naintain its integrity and prevent noisture intrusion which could lead to failure of the limit switch. However, to resolve the NRC concern regarding the absence of chemical spray, the following chenical spray evaluation is provided. III. chanical serav EvaluaticD Tests to determine the effect of chemical spray during a postulated accident on galvanized steel have been conducted by Sandia Labs and Raychem. Sandia Laba studied the effects of temperature, pH and boron (as Boric Acid) on the corrosion of galvanized steel to produce hydrogen gas 4
R avchericHIc0 Seelant EnvironneDial Qualification during accident conditions. Since hydrogsn is released as a result of the reaction between the spray and the sinc coating, the results of these tests are applicable to the review of the effecte of chemical spray on the galvanized , pipe. During the Sandia tests the torporature effects were evalutted at 48'C, 107'c and 168'C (NUREG-CR2412) and The pH effects were 132 ' c , 153 ' c and 175 ' c (NURZO-CR3 3 61) . studied using 4.0, 7 0 and 10.0 (NURIG-CR2812) end 8.5-9.0 (NUREG-CR3361). The effects of boron concentration were determined using 2000, 3000 and 4000 ppm boron. In Test Report No. 58730 dated, June 22, 1982, Raychem tested twelve N IS (Nuclear Environmental Interface 8eal) kit assemblies for environmental qualification including a The NEIS 30 day LOCA/MSLB exposure with chamical spray. kits were installed on 6" long 1/2" diameter galvanized steel conduit nipples. The simulated 'empercture and pressure accident profiles are shown in Attachment No.,2. The cha=ical spray solution during the Raychem test consisted of 3000 ppm boron with pH of 10.5. The NEIS kits were subjected to the chemical enray for 30 days at temperatures greater than 280*F for the first 7.5 dkys followed by 232'F for remainder of the 30 day &. As shown in Attachment No. 3 these temperatures are far in excess of 5
RaycherJcMico sealant Tnvirorrental cualification those at Yarley. Even at these nevere spray and temperatura conditions only three of the twelve test However, specimens evidenced leakage duriny the I4CA/MSLS. during the post test l~spection it was revetles that leakage occurred at the threaded test flanne connection which is outside the test specimen construction. In Raychen Test Report 58730 there is no documented evidence of Icakage in the test specimens due to corrosion of the tine galvanic layer. In addition, Wyle labs tested two Namco limit switches, an ASCO solenoid valve and a Weed RTD with galvanised steel nipple sealed with Raychon breakout boot and a keeper sleeve but no compression clamp. The breakout boot was filled with Scotchcast No. 9 epoxy. This Raychen/ Scotchcast / galvanize 6 steel test configuration is similar to the Tarley Raychem/ CHICO / galvanized eteel configuratien. The environmental qualification tests . including thermal aging, radiction, and accident simulation were conducted by Wyle Labs and documented in Test Report No. 48842-1, for southern Commany Se:Wices, Georgit Power Company's Plant Eatch. During the accident simulation the test specimens were subjected to damineralised water spray for 3 hours and 15 minutes. The Wyle Lab test uposed the r 6
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b b [ ' b ~l 16 O il fUb 4 Ravchen/ CHIC 0_ Sealant ?nvironnantal Qualification test specimens to 350'T for 25 minutes which anvelopes the rarley peak temperature of 313'T (See Attachment No. 3) . In Kyle Test Report No. 48842-1 thers is no evidence of corrosion of the galvaniaed steel nipple forming a path between the Raychem seal and the nipple or of moisture intrusion to the and device. There was no docunented evidence of degradation of the keeper sleeve or breakout boot for any of the test specimens except the Raychem boot on the conduit nipple of the solenoid valve. Even though the Raychen boot split no water was found in the solenoid valve. The Raychem boot split was caused due to a few nicks and cuts during removal of the test specimen from the Hatch site for environmental qualification L.st. During accicaat sirulation the Ptgh temperatures caused nicks and cuts tc propagate into a split. The chanical makeup of the spray is not a contributing,' factor at rarley because the spray solution is maintained within the low reactive pH range of 7 to 12.5 (see Attachment No. 4). The corrosion rate of aino'is high in strong acid (less than 6pH) and strong alkaline solutions (greater than 12.5pH). The lowest corrosion rates are in the weakly alkaline solutions in the pH range from 7 to 12.5 (Ref. Metals Handbook, 8th Edition, p 1163). Sandia 7 _ __ __o
5 5. v s / u t s0.sr 2vc Ravehme/ chico sealant Environmental cualification The Labs conducted tests at pH of 4.0, 7.0 and 10 0. resnits show that the rate constant is independent cf pH Since and boric acid concentration (See Attachment No. 5). Raychem tests on the NEIS kits were conducted with charical spray solution with pH of 10.5 (Test Report 58730, p. 9) the corrosion which resulted is attributed to factors other than pH cf the chemical solution. At Farley there are three remaining factors which could affect the extent of corrosion of the sine coating on the galvanized steel nipple. Thess ares (1) Terparature, (2) Presence of Moisture, and (3) Duration of chemical spray (Ref. Metals Handbook, 8th Edition, p. 1162, 1163;
)
s NURIG-CR2512, p. 13; NUREG-CR3361, Fig. 8). o
- a. Tanearature Test conducted by Sandia Labs indicate that the ,
corrosion reaction increases with increasing temperatura (See Attachment Nos. 5 & 6). At 168'c (334'F) the reaction rate is over 100 times faster than at 48'C (118'F) (See httachmant No. 5). As shown on Attachment 3, the Raychen test temperature profile was significantly higher than the Farley e i l
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f gavchen/ chico sealant _Environtental cualifIcation profile especially for the last 29 dhys of the DBA. As can be further swan, for the last 25 days of the DBA the Tarley conditions ace less than or equal to 50'C. Therefort, based on the Candia tests, there would be little or no corrosion expected for the last 25 days of the event.
- b. Prasance of Moisture Tests conducted by Raychem (Ref. Raychem meno dated, August 4,1982 from Mr. T. Tan to Mr. L A".derson, Attachment No. 7) and Sandia Labs (Ref.
NJREG-CR3361, p. 5) indicate that the sine layer does not react with the boric acid in the chemical solution. This lack of boric acid reaction is also supportad by Sandia Lab testr. which indicate the absence of sine borates in the powdery residue,left on the pipe at the conclusion of the test. The effect of boric acid in the chemical solution is to lower the rate of corrosion (Raf. NUREG-CR2812, p. 14). It is primarily the water in the spray which ' causes the corrosivo reaction (Ref. NUREG-CR3361,
- p. 1, 2, 5 and NUREG-CR2812, p. 2). The water reacts with the sine laysr to form sinc oxide and 9
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t i . . k'avcher/ CHICO Sealant Environmental cualificatiSD l hydrogengas,andthereactInnisaconieratedat higher temperature.
- c. Duration _of chemical seray Test conducted by sandia tabs show that at a temperature of 153.1'c (307'F) ths corrosion of galvanized steel by c.hanical spray dcas not start for at least 6 hours -- approximately two hours after the termination of spray at Farley (NtmIG- :,
CR3361, Fig. 8, Attachment No. 6). The Farley specified ICCA profile is completely envaleped by the sandia 14b test except for 10 seconds when the maximum specified temperature af 312'T exceeds the 307'r test temperature. The approximately twc-hours margin after the end of Farley spray duratic:- and initiation of corrosion is considered ' Ths sufficient to offast the 10 second duration. maximum surface temperature during MsLB for the Raychem/ CHICO environmental seal of 217'F (Raf. Mechanical Calculation 23.4, Table 3) is enveloped by the Sandia test. Since the postulated LOCA/MSLB temperatures drop below 190*F within two hours of accident, it is reasonable to conclude 10
6 6. U l i C 16'C: . i t. 4 Ra';ehen/ CHICO Bealant Environmental duelification that the onset of corrosion would be delayed even further. As further verification of corrosion being duration dependent, the spray duration in the Wyle test for Hatch was 3 hours and 15 minutes and no significant corrosion was observed at the galvanized nipples during post LOCA inspection. IV. cenelusion As discussed above, it has been documented that corrosion of the sine layer is negligible at the specified Farley chemical hpray pH. Bandia Lab tests indicate that at high temperatures (greater than 307'F) the corrosion is initiated only after approximately 6 hours and the corrosion rate drops significantly at lower tazparatures. The Hatch test for similar configuration as Farley (Raychem bonding on galvanized nipple) showed no , significant corrosion of the galvanized steel and the Raychem bond to the nippla stayed intact, no moisture intruwlon was observed, and no functional failure of the test) components resulted fue to the conduit osal configuration. Since the Farley spray duration is enveloped and the containment tamparature decreases steadily to a value which will result in little or no 11'
Raveher/Cf!ICO Baalar,t Environmental Oualification corrosion, it is concluded that the ispingement of chemical spray on the Raychem/ CHICO environanntal seal is not detricantal to the system. Therefore, the THP postulated design basis LOCA/MSLB events will not result in corrosion of the conduit nipple sufficient to allow moisture intrusion through the cor.bination of keeper sleeve / compression fitting, breakout boot / CHICO A seal resulting in loss of function of the qualified NAMCO limit switches. k 12
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0 0. U 1/ U f 10;UO t c. v ATTACHMinf 7 Wo. 7 I"TFEE!!MEMEEE" Raychem w- '%L h/ t., xc: K. Dahl s on August 4.1982 J. Greendorfer F. Kameda wmoio M. Anderson v. McCarty g MAD File 5,om T. Tan 8M ' i r= 40024. CTM 8208-001 sworm * -8205 01 NE!5 CORR 0510M EVALUATION One half the length
'We received tinc coated iron pipes. each 6" long.After LOCA proftle testing, corrosion of pipe is covered with WCSF sleeve. During the test a buffer solution was observed beneath the WCSF sleeve. The purpose containing Hg80 3 and Na,5l0 was sprayed on the pipes.
of our analy!is is to dit Mine if this buffer solution is the cause ofT corroston. borate and thiosulfate in the corroded region. We observed the following;
- 1. XRF of grey powder on the pipe shows the presence of In and Fe.
,s 2. XRF of grey powder on the WCSF sleeve (1. e., adjacent to the pipe) shows the nresence of Zn and Fe.
I( ./ 3. Gross infrared spectrum of grey powder from pipe shows the presence of In0. A pipe with grey powder deposits was washed with H3 0. The water solutie 4. portion of the grey powder was examined by x-ray fluortscence and infrared spectroscopy. (ap XRF shows the presence of $. C1. and low level of Zn. - (bj Infrared spectrum is a close match to Na24 50 . ' S. Beric acid spot test on the gross grey powder was negative.
- 6. XRD of the gross grey powder shows the pesence of In0. There w!s no evidence of Na 2450 or iron oxide.
CONCLUSION. The grey powder contains Na 2 50, which could be
- caused related 50 !u$. Therefore there is evidence of corrostonhowever, it is to Na2 by the c tic spray; absense of boron.
TT:y1 . AUG 121982
\ RAY. CHEM ,
" ~-- L - -a . F P.AMW.$ht,V r;j @mi.jeR:.
_ ATTACHMENT 2 ._
.. Y t k D!Benedetto Associates, Inc.
*""*'Y '
M O p m uy as/ 49end.La - .. MS S.m Suom 777 E tea ec.c re+wer om Bees.sa ceser SAe!! sae 316 4800 How tav t4o Arew. MA 016 s Ann Arw. uese, satos swee 610 fE17) 68190C9 pt3) 994 9400 Bet *.r.da. MD 20614 pot) 4?61433 b Hr. David H. Jones Supervisor, Design Support Huclear Engineering and Licensing Alaba:a Pcver Coepany 600 North 16th Street Birmingham, AL 35291-0430 .
Subject:
Qualification of GE and States Terminni Blocka
Dear Mr. Jones:
DiBenedetto Associates. Inc. has completed the assessmaet of an additional twenty eight (26) terminal blocks tested for use in nuclear power plants. m results of this review are presented in the attached report. The additions 1 information reviewed supports the qualification of the GE CR151B and States 2VM Terminal Blocks used in the Farley Nuclear Plant. The table attached to the report presents the data tabulated for each Terminal Block Report reviewed. I trust that the inforestion provided is satisfactory, however, if you have any questions or if I may be of any further assistance, plasse do not h$sitate to call as at (617)661-9009. i Sincerely.
, f * *4 h lip A. P enedetto e President PDB/spo
Attachment:
As Stated cc: J. Love e
ms ( QUALIFICATION Or GE AND STATES TERMINAT. BLOC FOR At.ABAMA PO4'ER COMPANY FARLEY h"JCLEAR PLANT. WITS 1 AND 2 BY DiBENEDETTO ASSOCIATES, INC. 0 APC01-08-02/REVIS gg$ . JANUARY 7,1987 ' sy b v , Q$$ B002000276 PDR 880100ADOCKOSOOg8 P
- APC01-05 02/REVIS10N 0 QUALIFICATION OF GE AND STATES TERMINA1,BIDCKS Alabama Power Company environmentally quellff ed the States !VH :
In 1979 , termins) blocks and the General Electric CR151B terminal blocks for use in the Tarley Nuclear Plant , Units 1 and 2. The States tvrminal block was qualified by type test conducted for Alabnma Power Coepany by Wyle Laboratories. The GE CR1513 block was qualified by General Electric Co:pany as part of the qustification of thn GE series 100 penetration assembly procured and installed in Farley Nuclear Plant Units 1 and 2. The NRC staff performed an audit of the Farley F.nvironmental Qualification Progra:e during the week of November 16 through November 20, 1987 and deteirmined that the qualification of the terminal blocks used in the Farley units did not demonstrate, by test, the performance required for usa in instrumentation circuits. Although failure of the terminal blocks to perform their intended function was not evident from the GE and Vyle tests performed, performance characteristics auch as insulation resistance or leakage current ware not monitored during theno tests. On this basis and on the basis that the s t af f's consultant, Sendia f,cboratories, conducted terminal block testing under simulated 14CA conditions, the staff concluded that terminal blocks should not be used in instrument circuits unless it could be demmstrated that the and devices (eg. transmitters) could perform their intended functions under test conditions monitoring the appropriate performance parameters. Since it was not practical nor reonized to retest the installed terminal blocks, Alabama Pever Company prforced a similarity analysis to demonstrate the capability of the installed configuration. The similarity analysis assumed that .he leakage conditions observed during the Sandia tests were a functicn of the physical dimensions, the LOCA surface conditions of block, and the height, thickness, and arrangement of the barriers between each ' terminal point. On this basis the matorisi properties of the terminal blocks were not considered. This assumption is supported by the information provided in the Sandla report, u n terminal block used in the similarity analysis was a Connectron block which exhibited similar physical and dimensional characteristics. he minimum insulation resistance recorded was on the order of 1F.07 Chms, no evaluation performed to demonstrate the acceptability of the al=11arity analysis was not accepted by the NRC staff during the EQ audit. ,- In previous reviews and audits of the Alabama Power Company Environmental Qualification Program, the staff approved and accepted the qualification infor=ation associated with the States and CE CR151B terminal blocks. On the basis of the recent audit finding and staf f conclusion that the infor=ation and additional analysis provided did not support qualification of the installed terminal blocks for their intended application, Alabama 2 Power Coepany provided a Justification For Continued Operation (JCO). The JC0 was based on additional review of the Sandia report and a review of all instrumentation required to perform a safety function during and following the course of a postulated design basis accident. The results of this analysis indicated that all active functions associated with safety-related instrumentation would be completed prior to exposure of the ' terminal blocks to adverse environmental conditions which could potentially craate unacceptable leakage current v,alues. Additionally, the MG' er i
APC01 081 02/REVIS10N 0 analysis evaluated the post accident monitoring required and the necessary instrumentation channels required to provide the information. _It was determined that :.o instruments would be required during the period when the potentia! to experience- low insulation resistance (high leakage current) veaues was probable. H e evaluation further indicated, as did the Sandia report, that insulation resistance as well_as leakage current values recoveted as the transient peak diminishnd. On this basis, Alabama g- Power Crepany concluded that no actions had to be taken by the operatora x based on information ebtained from instrumentation that could be affected-ty -the accident conditions during the peak period and until such time that the environmental conditions affecting instrumentation performance had subsided. Since no adveres actions would be taken and the performance of the instrumentation associated with ' the installed terminal blocks would not be coepromised. it was concluded that the installed terminal blocks were guslified for their -intended functions. During a meeting with the NRC in Atlanta, Georgia, on November 25, 1987, the staff-indicated that - the analysis and JC0 prepared by Alabama power Company addressing the use and acceptability of terminal blocks installed in instrumentation circuits at the Tarley Naclear plant'was not acceptable. In order to forther demonstrate that the terminal block configuration installed and used-in instrumentation circulta at the Tarity Nuclest Plant are qualified for their. intended use during postulated accidente, and that the JC0 presented during the November 25, 1937 meeting was conservative and supported the use of the terminal blocke in instrumentation circuits in the manner described -in the JC0, Alabama Power Company conducted an additional review of available industry test reports ~ which monitored the perfornance of various . terminst -blocks during simulated accident conditions. n o- attached tables ausenarise the data taken from test reports coepiled for various nuclear utilitian. % e data represente tests conducted on twenty eight (28) -terminal blocka. ~ % e terminal blocks tested represent blocks that.are identical, similar,- and dinnimilar to the terminal blocks installed at the Tarley Nuclear Plant.- Although the simulated accident profiles arn- not - totally representative of~-the postulated profile applicable to the- Tarley- Nuctent Plant postulated accident scenario, the results are applicable. , ne terminal tiocks used-in the Tarley Nucinar P_lant for instrumentation circuits era General Electric CR1515 and States ZVM terminal blocks. nese blocks are used as circuit interfaces to connect instrumentation to their power supplies and related circuitry. - no instrumentation is used te detect the onset of a postulated accident and to initiate the operation of protective and accident- sitigating equipment.- In addition. -the instrumenta are used during post . accident periods' to monitor- the parameters necessary to . permit the reactor. operators to take appropriate actions to maintain a safe shutdown condition.- he data presented is tabulated by test and numbered as modules for the purpose of this report. he numbering of data modules has no relevance to. the importance or ranking of -the test' reports reviewed, but is simply numbered in the order in which the reports were reviewed.
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- AFC01-08-02/ REVISION 0 .
Data module 17 presents the data obtained for a States NT snries terminsi ; block. De data collected demonstrates that for a terminal block exposed to a temperature range of up to 340*r at 100% humidity, with It no enclosure, that the minimum insulation demonstrates that as the resistance environmental recorded was 2.4E04 conditions Che returne further anbient (70'F), the insulation resistance of the terminal block noreal or This installation in not representative of the recovered (4.4E09 Ohms). ne termanni blocks insta!1ed in the Tarley Nuclear Plant instellation. Farley Nuclear Plant are enclosed. The data for a States ZWi terminal block identical to that which is installed in the Farley Nuclear Plent is presented transmitters were in data modulo
- 26. This terminal such as RTD.s and pressure I actual). End devices circuit to f acilitate monitoring of the terminal included in the tested f,eskage current was sonitored throughout the test an block performance, Although was recorded insulation resistance The test was a an IEEF. 323-1974 type *. cst.
test was coreple te d. during testing they do not affcet the use ano anocaties did occur Farley Nuclear Plant (sea comment section Data Hodule appliestion at the 28). During the LOCA portion of the test the leakage current values wer en The data the order of 50 to 790 microamps.with an acceptance criteria of The i 10% RTD.sestablished. was monitored recorded indicated that the transmitters operated During within the test i 5%.a the reference so were monitored against establish d. reference within 2 degrees of that the temperature varianco ranged from 0.1 to 0.6 was recorded data shows tests indicated a variance of up to 3.1 degrees. Post functions!acceptance critoria of the test was not eat, the degrees. Although the blocks were within acceptable demonstrated performance of the the terminal Farley Nuclent Plant. In ac:ordance ranges for the application at with the Vestinghouse setpoint and accuracy analysin performed for Alabama Power value of Coepany, previously presented and provided to the monitoring was considered acceptabis. in excess of the SE05 Ohms current during this test relate to values minicum acceptance criteria for insulation resistanceas i 5% inaccuracy ( SE05 defined Chks by resistance relates tn insulation Vestinghouse for their setpoint accuracy analysis, this was presented to On this basis. Alabama Power Company the staff during the EQ audit). terminal blocks. model ZWM, are concludes that the installed States in the Tarley Huclear Plant and gus11fied for their intended operation that the JC0 provided during the Novembar 25, 1987 APC/NRC ecating was conservativa and did not require consideration of a period during the postulated eccident where operator actions would have been restricted. no other terminal block used in the Farley Nuclear Plant are the Gen Electric CR1518 terminal blocks. the General Electric series 100 electrical penetration n e testand were originally for these qualified, by typt test, by GE in the early 70's. blocks did not acasure performance in terms of transient leakage% . current <-r
- - _____ -__m_ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _
a w _ -- _ 1 1 8 16 Ss a cp g ee m s e,, o AH- e-eO FR1 APC01-08-02/REVIS!0N 0 resistance, but insteadcurrent, tested the function of the or insulation voltsgo, and to naintain penetration and block to pass rated resistance in a go-no-go type test. Data that minimum insulation the qualification of the installed configuration is presented demonstrates In order to appropriately discuss the in data module. 8, 16, 19, and 24. performance and acceptability GE of the data it is first necessary EB S and the GE CR1518 blocks. Theto 1 ] establish similarity between the 19 relate to the EB 5 terminal blocks, data provided in modules 8 and modules 16 and 24 relata directly to the CR151B terminal blocks. Similerity between the EB-5 and CR1513 terminn) blocks is described below and is based on information provided by the terminal block man General cellulose filled, general purpose phenotic tereinal block was a ennufactured by CE and that of the CR151B terminal block was also The a cellulose filled, general purpose phenotic manufactured by CE. electrical properties of the phenolic material are shown below. CR1513 Phono 11c Electrical EB5 Phenolic MatitiAl Prererties Material __ Vater absorption, 24 hrs % 0.5 E CE Test, 1/81n x 4fn disc 0.4 Dielectric Strength ASDt D-149, 1/81n thick 300 r 60 horts, 25'C, s/t, vpm 325 130 60 hertz, 100'C, s/t, vpm 175 Power Factor, 60 hertz-dry 0.13 ASDi D-150,1/8 in thick 0.20 C.04 0.05 1 megahertz-dry Dielectric Constant 60 hertr.-dry 8.2 ASD! D-150, 1/6 in thick 8.0' 4.9 - 1 megahertz dry 5.0 l Volume Resistivity.chs es 6E11 ASDi D-257, 1/8 in thick 6E11 Based on a comparison of theand electrical pro, : Lies tabulated above, the the fact that the physical dimensions of use of identical material, blocks vary by only 1/64 of an inch in the height of the barrier, the two the two terminal blocks are similar and that the it is concluded that on the EB 5 terminal block is applicable to the CR151B testing performed terminal block. cu 3 4 l
*
- APC01008bO2/REVIS20N 0 Hodulo 8 presents data for an 15-5 terminal block tested'as part of a 11eitorque actuator, eithough not representativa of the actual use and installation at Farley Nuclear Plant,.'the performance durlag the first- -
transient demonstrated insulation resistance values on the order of 1-2005-Chas. A more representative test (module 19) demonstrated that the E8-3' torsinal block exhibited leakage currents ranging from 0.0 to C.06 sa during a simulated LOCA test that reached peak temperatures of 309'F, the test duration was three days =,;three hours, and-forty four minutes. The data presented additionally supports the conclusion that insulation resistance as well as leakage ' current values recover as the transient. parameters diminish, was tested to a 100% humidity, 340'T, for a total of he GE CR151 -block 202 hours withoutthis an enclosure. % e lowest insutstion resistance reading recorded during test was 1.9E04 Ohms (Data module 16). The starting insulation resistance .andand. Ohms- the'insutstion 3.5E09_~_0hms resistance recorded respectively, atfurther which the test were 10E10 and de=enstrates the terminal block ability to recovet as temperature and humidity conditions improve. % e termins) blocks installad at the Farley. Nuclear plant .are similst to the blocks testou,;but are provided with enclosures. Hodule 24 presents the GE CR1518 terminst block data from a simulated LOCA test of sixteen hours in duration. % e peak temperature reached was. 222'F. n e leakage current values recorded during'this test were minimal. was run with a pressure transmitter used as an end (0.0 sa). The test representative of en instrumentation device. De applied voltage was circuit (26.5 vdc at approximately 27 ma).- 4 ' Based on the data presented above, Alabama Power Company concludes that ' the GE CR151B terminal block is qualified for the intended function and use in the Farley Nuclear Plant. Additionally, based on the information provided, it is concluded that the JC0 provided reasonsble assurance.that the terminal blocks would have performed-their_ intended function-'vithout restricting or misleading the operators, ne additional data modules provided demonstrate ths :' capability of terminal blocks to perform their intended. functions - when s'aposetto - i postulated-_ accident environments and further-. confirm the recovery of the ~ blocks performance as-environmental conditions subside.- Issed on the review of the additional test reports and the data presented, Alabama Power- Company concludes that the terminal blocks (States'!WM and CEs CR1513) were qualifiede to' perform their- intended functions in the, Tarley Nuclear plant 11 nits' : 1 and 2,_ and= although Alabama Power Company: elected to repisce all terminal blocka with qualified . splices, the'- installed configuration comprised a gualifled installation :for--their-intended function and should not be considered a vioistion of 10CFR50.49 ' and therafere should- not be considered an item for potential enforcement action. I 5 j.
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Dr. J. H. Grace U. S. NJclear Regulatory Commission b, YCb .._.L._.1- L.] Region 11, Suite 3100 !_ J_ 101 Marietta Street N. W. ' L ---- M Atlanta, GA 30303 {.f".,1
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Dear Dr. Grace:
Joseph M. Farley Naclear Plant - Units 1 and 2 Environmental Qualification Meeting of September 24, 1987 A meeting was held on September 24, 1987 at the NRC Offices in Bethesda, tiaryland to discuss tne deviation from design of certain cable splices used at Farley Haclear Plant on environmentally qualified equipment and the potential safety significance associated with the use of these splices. This letter provices a discussion of the splice issues as presented at the meeting, including the basis for Alabama Power Company's decision to continue operating both units of Farley Nuclear Plant, future actions for ensuring that af fected splices are restored to full compliance with design, and the status of testing on the subject splices. When a significant issue occurs at Farley Naclear Plant, Alabama Power Company's first concern is to establish confidence in the safety of the plant, then to rapidly and methodically establish plans and rcccurces to resolve the issue, and then to implement the resolution on a schedule that is accelerated to the extent consistent with overall safety. With regard to the splice issue, Alabama Power Company has acted rapidly, conservatively and within what we believe to be the requirements of the regulations. Alabama Power Company plans to continue to vigorously pursue environmental qualification (EQ) issues. In concert with this approach, Alabama Power Company made the following commitments to the NRC at the
. September 24, 1987 meeting:
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Dr. J. N. Grace L,- h M7 U. S. Nuclear Regulatory Commission ! Region 11, Suite 3100 -
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Dear Dr. Grace:
7597-Joseph H. Farley Nuclear Plant - Units 1 and 2 Environmental Qualification Meeting of September 24, l'J87 A meeting was neld on September 24, 1987 at the.NRC Offices in Bethesda, Maryland to discuss the deviation- from design of certain. cable splices used at Farley Huclear Plant on environmentally qualified equipment and the potential safety significance associated with the use of these splices. Tnis letter provides a discussion of the splice issues es presented at the meeting, including the basis for Alabama Power Company's decision to l continue operating both units of Farley Nuclear Plant, future actions for i ensuring that af fetted splices are resterc4 to full compliance with design, and the status of testing on the subject splices.. 4
-When a significant issue occurs at Farley-Nuclear P1 ant. Alabama Power Company's first concern is to establish confidencez in the safety of the-plant, then to rapidly ad methodically establish plans-and resources to !
resolve the issue, and then to implement the resolution on a schedule that is accelerated to the extent consistent with overall safety.- With regard ' to the splice issue, Alabama Power Company has-acted rapidly, conservatively and within what we believe to be the requirements of'the _ j regulations. Alabama Power Company plans to continue to vigorously pursue environmental qualification (EQ) issues. In concert with this approach, Alabama Power Company made the following commitments te the NRC at the i
. September 24, 1987 meeting:
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Dr. J. N. Grace September 30, 1987 U. S. luclear Regulatory Commission Page 2
- 1. Alabama Power Company will not start-up Unit 2 from its projected 52-day ref ueling outase starting on October 3,1987 without assurance that Alabama Power Company has resolved all operating issues on EQ matters (i.e., EQ issues wnich affect operability) for Unit 2 with the NRC.
- 2. Alabama Power Company will keep the NRC advised of any energing operating EQ issues found in either Unit 1 or 2 not addressed in the September 24, 1987 meeti ng.
- 3. Alabama Power Company will not stait-up Unit 1 from the Spring 1988 ref ueling outage witnout reaffirming assurance that Alabama Power Company has resolved all operating EQ issues involving Unit 1.
4 Alabama Power Company will take appropriate action if an operating issue emerges at any tine on Unit 1 or Unit 2. In December 1984, a safety evaluation was issued by the NRC concluding that Alabana Power Company's EQ program for Farley Nuclear Plant was in conpliance with 10CFRSO.49. In 1986 and 1987, an INP0 evaluation and Alabama Power Company Quality Assurance audits respectively identified several findings related to the EQ program. These findings were expeditiously resolved. In Kay 1987, a Vendor Information and Procurement inspection was- conducted by the NRC with concerns identified on the EQ file documentation and the use of commercial grade parts in EQ systems. Tne above findings provided an indication that other issues potentially existed in the established EQ program at Farley Nuclear Plant. Ba ed on the indications discussed above, an extensive review of the Farley Nuclear Plant EQ program was initiated by Alabama Power Company in June 1987. This review included a re-review of test reports to ensure tnat the data to support qualification is available, a review of test reports and technical manuals to ensure that maintenance requirements for EQ equipment are specified in maintenance procedures and practices, a review of past corrective maintenance to ensure that the environmental qualification of equipment is being preserved, and a review of EQ problems experienced at other nuclear plants for relevance to Farley Nuclear Plant. Based on the review of an NRC EQ Audit Report on another nuclear facility and discussions with various maintenance and construction personnel, Alabama Power Company determined on July 16, 1987 that cable splices configured in a V formation (V-splices), which is a deviation from the design, potentially existed on ASCo solenoid valves as the cable connection mechanism rather than in-line taped splices or Raychem configurations. A JC0 was prepared and the V-splice on solenoid valr.?; which were accessible were replaced witn Raychem splices that were in accordance with the design. . In conjunction with establishing the plan associated with ASCo solenoid valves, it was determined that the V-splice issue might be applicable to otner categories of equipment. Concurrently, consideration
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- Dr. J. N. Grace September 30, 1987 U. S. Oclear he9ulatory Comnission Page 3 of the available information relating to V-splices led Alabama Power Company to conclude that the splices in question would perform their intended function. Upon review of the situation, Alabama Power Company determined the following two approaches could be taken with this potential issue:
- 1. A justification for continued operation (JCO) could be developed based on previous test data concerning V-splices, which could envelope V-splice configurations in the plant, or
- 2. Having evaluated the capability of the subject splices to
- perform their intended function, a more conservative methodology (i.e., a methodology involving the development of JCOs, the inspection of splices, and replacements as necessary to restore to the approved design) could be adopted and applied to problems discovered in each category of equipment.
Tne nore conservative JCU methodology was adopted as the general approach for the V-splice issue. The categories of equipment to which the V-splice issue would potentially be applicable were defined and prioritized to serve as a corrective action plan extending beyond the solenoid valve actions already initiated. The technical justifications for Alabama Power Company's decision that the taped V-splices in question would perform their intended function were based on (1) qualification test data. (2) protection afforded to preclude exposure of the splices to direct spray, (3) the use of materials which are qualified for in-line splice configurations, and (4) engineering judgement. With regard to the qualification test data, an evaluation was performed considering Wyle Report 17859-02P (Qualification Test Program for Couwnwealth Edison Com,)any's PWRs). This test report provides qualification information on V-shaped splices using T95 insulation tape and
#35 jacketing material that were subject to moisture incursion since the crotch of the V was not filled with any insulating material. The test specimens were subjected to an accelerated thermal aging equal to 40 years plant life, radiation exposure of 200 MRads gamma, and a design basis accident profile with a peak, of approximately 360*F and 58 psig.
Alabama Power Company believed that the splices would not be directly exposed to spray bece"w the splices are contained inside termination boxes, conduits, or rM+t enclosures. Since moisture incursion into the taped V-splice under c:.tulated accident environmients was a potential concern, Alabama Power Company considered the shielding of the splice from direct spray to be a significant f actor. Additionally, the materials used by Alabama Power Company for the V-splices were expected to be qualified materials.
Dr. J. N. Grace Septembe* 30, 1987 U. S. foclear Regulatory Conmission Page 4 i Small amounts of leakage currents could be postulated to occur as a result of the V-splice configuration. Since these splices were not expected to be installed on instrument circuits where leakage currents could sipificantly af fect the function of the circuit, it was concluded through engineering judgement that sns11 leakage currents were not significant with respect to equipment oper6bility. l Based upca these technical justifications and engineering judgement, , Alabama Power Company believed the V-splices would perfonn their intended function when exposed to the relevant environment. Accordingly, Alabama Power Company has never declared equipment inoperable due to the V-splice configuration. Tneref ore, Alabana Power Company believed, and continues to-believe, that the continued operation of_ Units 1 and 2 of Farley NJClear Plant is safe, is acceptaole, and does not represent a potential-risk to , tne health and saf ety of the public or Farley Nuclear Plant employees. On July 24, 1987, an evaluation was initiated on certain motor operated valve (MOV) motor-lead splices that were potentially installed in the V configuration. A JC0 was developed for these MOVs utilizing the following groupings: 1) MOVs outside containments or the main steam valve rooms; 2) MOVs inside containments or the main steam valve rooms, with no post accident operation; 3) MOVs inside containments or the main steam valve rooms, with short-term en,t accident operation; and 4) MOVs inside containments or the main steam valve rooms, with long-term post accident operation. For the fourth group of MOVs, Alabama Power Company decided the actual configuration of each of tnese valves had to De determined and either replaced with a' configuration in accordance with the design or a f urther JC0 developed based on past test reports. All of the valves in the fourth group were placed in a configuration in accordance with the design by July 31, 1987. In total, 40 of 60 M3V motor-lead splices have been replaced on Unit- 1, 26 of 74 MOV motor-lead' splices have been replaced on Unit 2, and replacements on accessible MJVs are continuing even though JCOs-may not require near-term replacements. On August 4, 1987, an evaluation was. initiated on ten fan motors inside , containment on each unit that potentially contained splices which were a deviation from the_ design. A JC0 was initiated and, at the sane time, action was initiated to inspect each- fan motor and correct any splice 3 configurations identified to be a deviation from the design. The decision - to inspect and make necessary replacements was considered a more conservative measure than waiting for the development of a JCO.-_ -Upon commencement of the inspection, Alabama Power Company decided-that the work could be completed prior to the completion of the.JC0 and ef forts on the JC0 development'were stopped. Multiple inspection / replacement teams were utilized on each shif t to expedite the schedule and to_ minimize personnel , radiation exposure and; heat stress. Additionally, only one component was taken out of service at a time to minimize the collective number of safety
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4 9 . 1 1 [ Dr. J. N. Grdce September 30, 1987 1 U. S. kJclear Regulatory Commission Page S ! systems out of service at .a time. All ten f an _ motors on each unit were j - placed in a configuration in accordance with the design during the period j from August 7,1987 to August 22, 1987. 3 j Un Septenber 15, 1987, an evaluation was initiated on 4160V motor. '
- - terminations that potentially contained splices which were a deviation from the design. The scope of this potential deviation from design involved the j l charging pumps, RHR pumps, and containment spray pumps on each unit.. l' 1 Subsequently, the V-splice configuration was approved by design for
] applications not in a post accident steam environment. These puys are not i in a post accident steam environment. Alabama Power Company decided to i destructively -inspect each of these splices- to determine if splice j materials and dimensions were correct. _ The charging pump splice a inspections on each unit are complete. i 1 l Oue to tt.a V-splice issue ~ identified on solenoid valves, Alabama Power j Company rccognized the potential for a splice problem on the electrical ! connection to the hydrogen recombiner heaters and scheduled an evaluation j of this potential problem. The NRC expressed concern about this potential ! problem during the Region 11 inspection _ performed the week of_ September 14, , i 1987. In response to the concern expressed by the NRC, Alabama Power _ l 4 Company elevated the priority of tnis potential problem and . developed a JC0 j for the expected splice configuration. .This JC0 was reviewed by the Plant j Operating Review Committee and approved on September 18, 1987. The 1A i recombiner was inspected on the afternoon of September 18, 1987 and i confirmed to be in the expected configuration (i.e., one field wire bolted , l to five heater leads and taped with Okonite T95 insulating tape with ! Okonite #35 jacketing tag over the T95 tape).- The-NRC questioned the September 18, 1937 JCO. A revised, more detailed, JC0 was subsequently l prepared and provided to the NRC, which is still under review by the NRC. j
- Additionally, Westinghouse provided by letter dated September 22, 1987 the 4
original splice test configuration for tne Farley Nuclear Plant hydrogen ! recombiners. The configuration used-during the test was a taped splice i similar to the as-found 1A configuration. Alabama Power Company is ! currently pursuing with Bechtel Eastern Power Company and Raychem Company a l- design that will resolve the concerns w1th this connection. ; i i Alabama Power Company plans to continue to' evaluate splices for EQ l equipment and components as follows: , }
- 1. 600V fan motors outside containment.
[ 2. Instrumentation inside and outside containment such as transmitters, level switches and-radiation nonitors. ! 3. Containment electrical penetration terminations, i-l 4 Any otner equipment or components that could' potentially oe , i' spliced or terminated as a deviation from- design.
Dr. J. N. Grace September 30, 1987 l U. S. Nuclear Regulatory Commission Pege 6 As determined necessary by these reviews, splices and terminations will be replaced consistent with the design. All known work, inspections aid walkdowns will be completed with evaluations performed by the end of the next refueling outage on each unit. In addition to'the JC0s prepared and corrective actions taken, Alabama Power Company initiated an expedited test program of V-splices. At the time of the Septeinber 24, 1987 meeting, the splices had successfully completed radiation exposure and thermal aging tests, and had successfully endured exposure to the peak temperature and pressure of the accident environnent. Also at the time of the meeting, the splices were being : exposed to a post-accident soak environment with the majority of the ) chemical spray exposure test completed. No failures had been reported. Alabama Power Company noted that testing was scheduled for completion on Septemoer 25, 1987. All qualification testing was successfully completed on September 25, 1987. Tne qualification test results were submitted to Alabama Power Company by letter from Wyle Corporation dated September 28, 1987. The results of the testing presented in t he letter states that all of the test specimens demonstrated the capability to conduct the specified currents at the specified voltages throughout the test. The letter concluded that the test specimens are qualified to the intent of IEEE Standard 323-1983, "!EEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations." At the September 24, 1987 meeting with the WRC, Alabama Power Company was requested to provide in this letter a discussion of walkdowns to be conducted. Walkdowns inside containment relative to the splice issue will be conducted during the next refueling outage on each unit at feriey Huclear P. ant. The walkdowns will include a sample of components in representative equipment categories which are subject to the splice issue. The scope of these walkdowns will include instrumentation, penetrations, and any other categories of equipment determined by review'; to be subject to the splice issue. The Unit 2 walkdown will begin during the first full week of the outage and will be completed as soon as possible (currently estinated to be within two weeks from initiation). Alabama Power Company is developing a subset of the walkdown plan which will identify a smaller sample of the equipment / components with field wiring connections in order to quickly identify significant issues. This subset of et ipment is anticipated to be inspected in three to four days from the veginning of the walkdown. Alabama Power Company w'.11 provide this detailed schedule of the Unit 2 walkdown to the NRC Region 11 Resident Inspectors. Additionally, Alabama Power Company will continue to ensure that the Resident inspectors are kept
- informed of our continuing EQ ef forts and any f urther EQ issues that are identified.
d Dr. J. N. Grace Sept et.ber 30, 1987 U. 5. fiJClear Regulatory Cornission Page 7 If there are any questions, please advise. Respectfully submitted. ALABAMA POWE , MPANY r Y R. P. Mcdonald RPM /LCT: dst-T.S.7 cc: Mr. L. B. Long Mr. E. A. Reeves Mr. W. H. Bradford O. 5. Itaclear Regulatory Cominission ATTft: Document Control Desk , Washington, DC 205b5 s
e bc: Mr. W. O. Whitt
- Mr. W. G. Hairston, III Mr. K. W. McCracken Mr. J. D. Woodard Mr. J. W. McGowan Mr. C. D. Nesbitt Mr. R. G. Berryhili Mr. D. E. Mansfield Mr. J. A. Ripple (3)
Mr. J. K. Osterholtz Mr. J. T. Brantley Mr. D. E. Dutton Mr. J. R. Crane Mr. K. C. Gandhi i 4 f 4 t s l i l f i 1 . I
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Q Pg f T tNroacturNT ACiset'%8or rOn runo#Rrtexst . 92 n2 w Exn.s POLICY ISSUEW" SECY-87-2ss et b'" 23 "87 (Notation Vote) For: The Commission i I From: Victor Stello, Jr. Executive Director for Operations
Subject:
PROPOSED MODIFICATION OF POLICY ON ENFORCEMENT OF ENVIRONMENTAL QUALIFICATION REQUIREMENTS FOR ELECTRICAL EQUIPMENT AND APPLICATION TO VIOLATIONS AT CALVERT CLIFFS (EA 87-77) AND ORESDEN UNIT 3 l (EA 87-81) l
Purpose:
To request Comission approval of the staff's proposal to modify the existing enforcement policy for environmental
- qualification (EQ) of electrical equipment and to apply this modified approach to issue a Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $300,000 to Baltimore Gas and Electric Company for its Calvert Cliffs facility and a Notice in the amount of $150,000 to Comonwealth Edison Company for Dresden Unit 3 for violations of environmental qualification requirements. The staff is seeking Comission approval because (1) the staff proposes to modify the daily civil penalty approach of the existing EQ enforcement policy set forth in Generic Letters 85-15 and 86-15 (Enclosures 1 and 2), and (2) these are the first cases involving the use of the EQ enforcement policy in the Generic Letters.
Discussion: Generic Letters 85-15 and 86-15, sent to NRC licensees on August 6, 1985 and Septe der 22, 1986, respectively, set forth the NRC enforcement criteria, which were approved by the Commission, concerning 'the handling of EQ violations.
- The criteria provide for the assessment of daily civil penalties of $5,000 per item of unqualified equipment for each day the plant operated and the item was unqualified after November 30, 1985, up to a maximum of $500,000 per item, provided the licensee as of that date clearly knew or clearly should have known that they had equipment for which qualification had not been established. Generic Letter 85-15 defines an item of electric equi > ment as a ' specific type of electric equipment <fesignated >y ennufacturer and
Contact:
James Lieberman, OE r x28214 ; g'#(#"Y>p, Howard Wong, OE x27851 ENrORCrMENT ACTION - NOT FOR PUBLIC R$ LEASE
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nn a.w . i . The Comisston andel, which is representative of all identical equipment in a plant area exposed to the same environmental service conditions' and also defines, for the purposes of enforce-ment, unqualified equipment as 'equipmaitt for which there is not adequate documentation to establish that this equip-ment will perform its intended functions in the relevant environment.' Also provided in Generic Letters 85-15 and 86-15 are mitigation factors to be applied to determine the amount of the proposed civil penalty. These mitigation factors are primarily related to (1) Itcensee identification and prompt reporting of the noncomsliance (2) the licensee's efforts , to conplete IQ within tie deadline, and (3) the licensee's corrective actions to come in full compliance within a-reasonable time. Other mitigation factors (i.e., signifi-cance of the deficiencies, opportunities to identify and correct them, time taken to make a determination, quality of the supporting analysis, and length of time the deft-ciencies existed before identification) were also to be c considered. Specific percentages for each factor were not developed. In recognition that some licensees did complete all actions prior to November 30, 1985 or shutdown to be in compliance, the guidance provided that civil penalties should not be lower than $50,000. Significant v'iolations of the EQ rule are being considered by the' staff for escalated enforcement. In most cases the , staff would expect-that if a significant EQ violation is involved that the licensee clearly should have knewn of the EQ deficiency because of the amount of information provided to licensees by.the NRC and industry. The staff intends to closely scrutinize arguments of licensees who take the position that they should not have clearly known of the deficiency prior to the deadline. A violation is not ' considered significant if sufficient data exists-or is developed before the inspection ends or shortly theresfter,
' to demonstrate qualification of the equipment or, based on-other information available to the inspector, the specific '
equipmenti is qualifiable for the application in question. These violations would be considered es Severity Level !Y ) or Y violations (See Enclosure 3. Enforcement Guidance Memorandum 87-02). Generic Letter 86-15 included a provision for expiration d the daily civil penalty approach. The guidance in the
' Ceneric Letter provided that the daily penalty approach would be applied until the completion of the NRC first-round inspections which is now scheduled to be completed in mid-1988.
Thereafter, the normal enforcement policy of 10 CFR Part 2 Appendix C; would be applied. .The Generic Letter also provided that, if EQ violations identified after the November 30, 1985 deadline do not relate back to action or lack of action before the deadline, the normal enforcement policy would apply,
1 , - The Comission - The staff has applied the existing EQ enforcement guidance of Generic Letters 85 15 and 86-15 to the Calvert Cliffs case, in which 13 items of unqualified equipment were identified, resulting in a pro mitigation in the range of $1, posed 100,000civil penalty after as described below (details are provided in Enclosure 4). Base civil penalty: $6,500,000 ($500,000 per item for 13 items) Mitigated civil penalty: $ 500,000 (for one licensee-identified item for which adequate corrective actions were not ' taken)
+$ 600,000 [$50,000 (the minimum civil penalty) times 12 (the number of other licensee-identified items))
51,100,000
. While recognizing the i g ortance of EQ compliance, the staff does not believe that a civil penalty of tiis magnitude scoperly reflects the relative importance of enforcement issues w11ch the staff has dealt with in the past, which includes more significant violations, such as the loss of feedwater' event at Davis-Besse (proposed penalty of $900,000) and the failure of.the reactor to shutdown on a low steam water level signal at Salem (proposed penalty of $ generator 850,000).
Further, for Fiscal Years 1982 tirough 1986, only 10 of 192 (55) of the enforcement actions with civil penalties for power reactors involved amounts of $250,000 orgreater.J/ Because a civil penalty of $1,100,000 seems out of line , with other enforcement actions, the staff considered other approaches to EQ enforcement. One apl: roach considered was to group similar type ' items" (such as splices, cables, wires, and terminal blocks) together and not consider the various models or manufacturers. The staff even considered broadly grouping ' items' functionally in one grouping, such as elecerical connectors. However, in using such approaches, the definition of an unqualified " item" would be contradictory to that given in Generic 1.etter 85-15 and would also seem to lessen the civil penalty for those licensees with numerous unqualified items. It also results in a different definition for ' items' depending on the circumstances of each case. 1/ It is noted that in the past the NRC has not routinely escalated sanctions based on duration. The sttff also frequently groups violations together in assessing penalties. If duration were considered and/or an aru ssment made for each violation similar to the EQ guidance for daily civil penalties for each unqualified ites, the amounts of civil penalties would be larger. 1 ____ _ _ _ ----- --- - -
, . ,9 The Coenission .
The staff believes that wide variation could occur with such interpretations and would not result in a consistent treatment of EQ deficiencies. The staff also considered assessing civil penalties. based on the safety significance of the f0 discrepancy by consi-dering the unqualified equipment involved and the system affected. tbwever, the staff determined that extensive resources, both the NRC's and the licensee's, would be . necessary to assess the actual safety significance of each discrepancy for the unqualified piece of equipment, both-individually and as a group. The evaluation for safety significance becomes even more complex-taking into account the actual period and duration for which the equipment must function during design basis events. The difficulties in : assassing the actua safety significance can be demonstrated . I from a review of the types of electrical equipment affected at Calvert Cliffs. Enclosure 5 provides a listing from the licensee of the EQ discrepancies. It is evident from this listing that multiple systems are affected, including ECCS, , secondary side components, component cooling systems, the plant parameter indication s components and penetrations,ystem, electrical and containment distribution cooling components. . i To fully consider the safety consequences of the EQ : discreplacies and their effects on the total plant would be a difficult if not ig ossible job involving substantial j-resources of EQ engineers and personnel knowledgeable of - plant and reactor systems. Such resource expenditures on the part of NRC and lichsees are difficult to justify in i
, light of the fact that in most cases the EQ discrepancies have been corrected after their identification. Also, the safety evaluations done to assess the potential impact of ,
the deficiencies would only be useful for enforcement purposes-and would tend to shift the focus of the EQ violations from the root cause of the EQ discrepancies to system operability analyses. As provided in Generic Letter 86-15, if a licensee decides to operate following _identificationiof a potential EQ deficiency, the safety aspects of the potential EQ 1 . i deficiency must be considered by the Itcensee, who must make a progt determination of operability, take imediate ~
- l steps to establish a plan-to correct the deficiency, and have a written justification for continued operation.- i Another approach considered for enforcement of significant EQ violations, which the staff recomends, would treat EQ violations-in the aggregate as a single problem and eliminate the necess'ty to consider each violation (or item ofunqualifiedequipment). Rather.than a daily civil penalty of $5,000 per day per item with a maximum civil penalty of
$500,000_ per ites as specified in the Generic Letters,. the staff's approach would: (1) aggregate significant EQ violations topether, rather i.han consider each separate item of unqua.ified equipment, (2) assess a base civil
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penalty according to the number of systems or subsystems which are affected by the unqualified equipment in a graded - approach by assignment of the aggre i one of three violation categories, gate EQ problem into,3) establish th; EQ civil penalty of $750,000 for the worse case, (4) maintain i in most cases the minimum civil penalty of $50,000 for a significant EQ violation, and (5) consider for mitigation-and escalation of the base civil penalty the factors of identification and reporting, best efforts to complete EQ within the deadline, corrective actions, and duration of ' the violation. . The specific application of this' proposed approach for two cases at Calvert Cliffs and Dresden Unit 3 is described in Enclosures 4 and 7. The civil penalties resulting from ' this approach are $300,000 for Calvert Cliffs and $150,000 for Dresden Unit 3 and are viewed by the staff to properly reflect the potential ispect and significance of the violations. The= staff recomends this new approach to EQ enforcement
- because: (1) it provides a more workable approach than i t was previously provided in the Generic Letters, (2) it puts into the proper perspective the relative importance of the EQ requirements in relation to other NRC requirements, (3) the safety significance of the EQ deficiencies are. ,
broadly categorized by their impact on plant systems, and (4) it maintains the mitigation factors of the Generic - Letters Jrhile also providing for escalation of the base I civil penalty for those cases in which licensees have not performed well in the EQ area. While this approach
. eliminates the daily civil penalty approach previously approved, the staff's proposed approach would generally ?-
still result in higher civil penalties than norselly imposed for other significant violations. Conclusion The use of the EQ enforcement guidance novided in Generic Letters 85-15 and 86-15 would lead-to civil penalties for Calvert Cliffs and Dresden Unit 3 which are considered by-the NRC staff to be inconsistent with civil penalties given in the past, including those for significant operational events (Davis-Besse and Sales), and do not properly reflect the significance of the EQ deficiencies at Calvert Cliffs and Dresden Unit 3 in relation to these and similar operational events. The staff has proposed an alternative approach to EQ enforcement which aggregates the significant EQ violations together, assesses a base civil penalty according to the nur6er of systeras and subsystems affected, and considers - for mitigation and escalation of the base civil penalty the factors in the Generic Letters. The staff considers this alternate approach appropriate-for EQ violations in which the-licensee clearly should
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. The Comission have known that to demnstrate there was insufficient information available qualification. In using this approach, Calvert Cliffs would be assessed a civil penalty of $300.000 and Dresden Unit 3 would be assessed a civil penaltv of $150,000.
If the Comission approves of this alternate approach, the staff intends to use this approach for subsequent cases , involving significant violations of EQ requirements. Cases involving deliberate violations or significantly more egregious EQ violations than considered herein will be handled on a case-by-case basis. In accordance with the Enforcement Policy of 10 CFR Part 2. Appendix C, the staff would consult with the Comission prior to taking enforcement action on si nificant EQ violations for other facilities inwhichaekvilpenaltyexceeding$300,000 is proposed. In addition, the staff proposes to issue a brief Generic E Letter on this issue in the interest of notifying licensees of the change in the EQ enforcement policy. Recomendation: That the Comission approve the staff's proposal to:
' , g
- 1. Modify the policy on enforcement of environmental !
qualification as set forth in Enclosure 6.
- 2. Apply the m:>dified policy and issue Notices of Violation and Proposed Imposition of Civil Penalties tc Calvert Cliffs and Dresden Unit 3 in the amounts .
of $300,000 and $150,000 respectively.
- 3. Issue an updated Generic Letter comunicating the
. changes m de to the existing EQ enforcement policy.
Coordination: OGC has no legal objections with this paper. ctor /te
, Jr
. Execut ye Dire or for Operations
Enclosures:
- 1. Generic Letter 83-15 ,
- 2. Generic Letter 86-15
- 3. Enforcement Guidance Memorandum 87-02
- 4. Proposed EQ Enforcement Approach for Calvert Cliffs .
- 5. EQ Discrepency Listing for.
Calvert Cliffs
- 6. Proposed Modification for Enforcement of EQ Requirements *
- 7. Proposed EQ Enforcement Approach
.for Dresden Unit 3
. .> .f.
.e 1 7-I 1 Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Friday, October 30, 1987. Commission Staff Office comu sts, if any, should be submitted to the Commissioners NLT Frir4ay, October 23, 1987, with an information copy to the Office of the Secretary. If the paper is of such a nature that it cequires additional time for analytical review and commenc, the Commissioners and the Secretariat should be apprised of when comments mya be expected. DISTRIBUTION: - Commissioners OGC (H Street) OI OIA GPA REGIONAL OFFICES
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Enclosure 4 PROPOSED EQ ENFORCEMENT APPROACH : FOR CALVERT CLIFFS On March 23-27, 1987, an NRC inspection was conducted at Calvert Cliffs Units 1 and 2 to review the status of the licensee's EQ program. During-the inspection, the NRC found that tape sp1fces on electrical leads of certain safety-related ' solenoid valves were not included on the list of electrical equipment important - to safety required to be maintained in accordance with 10 CFR 50.49, and there was no documentation in a qualification file to indicate that the splices were qualified to perform their intended function under postulated environmental conditions. A similar finding concerning the use of unqualified tape splices on other solenoid valves had previously.been ide,ntified by a licensee field engineer in late December 1986. Although the licensee corrected these specific
' tape splices by the end of December, the_ licensee did not perform an evaluation at that time to determine whether these unqualified tape splices were used on t any other components at Calvert Cliffs, as was subsequently identified by the i NRC to be the case.
In response to the NRC findings of March 1987,-the licensee conducted an imediate followup inspection of their EQ program at Unit 2, which was shutdown at the time. Based on their initial finding of additional unqualified tape splices in Unit 2, the licensee voluntarily consnenced a shutdown of Unit 1 on April 1, 1987 to perform an evaluation of the EQ program at both units so as to determine the magnitude of the problem. During this evaluation, the licensee identified several other tape splices, a,s well as several other items of-electrical equipment important to safety, which were either: (1)-not included on the list required to be maintained in accordance with 10 CFR 50.49 or (2) ! not environmentally qualified ,in that there was no documentation available in a file to support qualification, or both. L l ' As a result of the NRC's and licensee's-EQ review,13 unqualified items of i electrical equipment, as defined in Generic Letter 85-15, were identified (see Enclosure 5). 1/ These unqualified items include: tape splices, heat shrink tubing splices ~(Raychem and Ideal), terminal blocks-(Buchanan, GE, and unidentified phenolic-type), wee l and Telemecianique)pholes , a coil, motorin jun: tion boxes, operated valverelays T-drains ($quare and handswitches. D .Struthers Dunn. Regarding the criterion that the licensee clearly knew or c,learly should have-known the equipment was not qualified the staff believes that, for the case at ( Calvert Cliffs, the licensee clearly s,hould have known that this equipment was l 1/ ' ~ The 13 items are related to Unit.1.- While additional' items have been - identified in Unit 2. under the staff's proposed approach, this fact would not affect the amount of the civil penalty because the extensive EQ- ' deficiencies have.already been evaluated for Unit'l and determined to affect many systems and many components,-thereby resulting in the maximum base civil penalty. Four additional items were identifis,d by the licensee < which involved Single Insulated Switchboard ($15) wires manufactured by Rockbestos, Delco Link; Brand Rex, and Amer 11nk. These, however, are generally used in the internal wiring of valve motor operators for which, under SECY-87-32, approved by the Comission, no enforcement action would be taken. , 8
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Calvert Cliffs unqualified. Specifically, for tape splices, the licensee clearly should have known that these splices were unqualified because it was reasonable to expect that licensees would assure that electrical connections for equipment (such as tape splices) would be included in the master EQ list. Further, it was reasonable to expect licensees to perform field verification for electrical equipment which should have included connections. The unqualified tape splices should have been readily found. It was industry standard practice and knowledge that tape splices wire qualified only under specific installation procedures and for specific tape materials, whereas the tape splices at Calvert Cliffs in some cases were several wraps w standard electrical tape. The staff believes that, for the other licensee-identified violations (items), the nature of the items, the systems involved, and the previous NRC guidance provided (i.e., IE Bulletins, Circulars, and Information Notices) demonstrate that the licensee clearly should have known that, for these items of electrical equipment, qualification was incomplete. In additio'n, the corrective actions for other problems in the EQ program identified during NRC team inspections in 1984 and 1985 were not effective. The problems identified in 1984 and 1985 inspections included a lack of documentation in the qualification files to support qualification of certain items of electrical equipment. Thus, the staff believes that the licensee clearly should havc known that qualification had not been demonstrated for certain equipment. Had the licensee performed adequate field verifications and qualification file reviews, these EQ deficiencies would have been identified earlier. 1 In the case of Calvert Cliffs, Units 1 and.2 operated in excess of 100 days after the November 30, 1985 deadline with these unqualified items. Therefore,
, if a civil penalty is calculated in accordance with the Generic Letters, the l maximum of $500,000 per item is reached ($5,000 per day per item for 100 days).
l Applying a strict interpretation of the definition of an ' item' results in a I bese civil penalty of $6,500,000 ($500,000 per item for 13 items). l In considering the sitigation factors set forth in the Generic Letters, the l staff has determined it would be appropriate to mitigate the base civil penalty l amount based on the licensee's progt and aggressive corrective actions once the additional tape splice deficiencies were identified by the NRC, and the subsequent identification by the licensee and progt reporting to the NRC of the other EQ deficiencies. Mitigation of the civil penalty based on the licensee's. corrective actions is considered appropriate because (1) the licensee promptly shutdown tra Unit 1 reactor upon evaluation of the NRC inspection findings, and both Unit 1 and 2 remained shutdown for a> proximately two months to conduct en extensive r a iew of the EQ progran.; (2) tie licensee's review, which was perfctmed by design engineers (electrical, mechanical, and instrumentation), 1;eensed operators, and contractor consultants, appears to have resulted in a thorough assessment of the scope of the problem and the underlying deficiencies; and (3) the licensee has taken appropriate corrective measures to either qualify or replace most of the affected electric equipment or provided a justification for continued operation for certain remaining items of unqualified equipment associated with the ECCS Pump Room Cooler, and to estab11sh appropriate and complete files to support qualification. However, in applying *he Generic Letters the staff would not recorrnend full mitigation because (1) the licensee's review was not conducted until after the
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, Calvert Cliffs . .
NRC findings in March 1987, aven after the tape splice problem was identified by their staff in December 1986, and (2) the EQ history at Calvert Cliffs based on the 1984 and 1985 inspections and the present findings do not demonstrate best efforts by the licensee to meet the EQ requirements. In determining the appropriate amount of mitigation to be applied, one approach would 10 CFR bePart to use 2 Apthe percentages as used in the normal Enforcement Policy of splice violation.pendix C. This would result in the base penalty for the tape identified the tape splice violation balanced by the faThis is based on considerin additional examples of which the licensee was unaware. ct In that the NRC addition, identified while the licensee did initiate corr 4ctive actions for the tape splices after NRC identi-fication of the problem meriting mitigation, the 1.icensee failed to fully correct the issue when it was first identified in December 1986. Therefore, on balance no mitigation is considered appropriate for the licensee's corrective actions. The staff would consider it a>propriate to fully mitigate the other items (but not less than $50,000 for esci ites) based on;the corrective actions taken and the identification of the deficiencies by the licensee. The resulting civil penalty of $6,500,000 would be mitigated to $1.100,000 [$500,000 (for the one tape splice item) + $600,MD (the m' nimum civil penalty - $50,000 times the . numberoflicensee-ident'fieditems-12)). In the staff's view it is not the appropriate penalty for the subject violations. ; When applying the sta'f's proposed new guidance set forth in the Coenission paper rather than that in the Generic Letters, the staff. concludes that the EQ . violations were extensive and many systems and components were affected by the unqualifjed aquipment, including ECCS, secondary side components, component cooling syste.ns, plant parameter indication systems, electrical distribution c mponente bise and penetrations, civil penalty of $300,000and containment cooling components. Therefore, a is appropriate; -In consideration of the mitigation at.d eseslation factors, as described below, on balance neither mitigation nor esceMion of the base civil penalty was deemed appropriate by the staff. While the licensee did initially identify the first tape splice deficiencies, and other EQ deficiencies subsequently, these additional deficiencies were only identified after NRC inspection revealed that the tape splice issue had not been cow letely resolved. Had the NRC inspection not been done, the additional EQ deficiencies may not have been discovered. Therefore -in consideration of the factor for identification and reporting, on balance 25 percent mitigation was considered warranted. Because the licensee had not applied best efforts to cei.11ete EQ within the
- edline and the NRC had indicated problem areas in 'the lictnsee's EQ pW4i' considered appropriate to escalate the base civil p..previously, it is alty by 50 percent. Vnile the licenste's actions to shut down an operating unit after the NRC had identified EQ program problems in March 1987 were censidered to be extensive, the licensee failed to take gpropriate corrective actions when tape splice deficiencies 1986.
were first identified by the licensee's-personnel in December-It was only after the NRC performed a followup inspection of the EQ program did the extent of the tape splice probles as well as other EQ program problems became evident. Theretore, on balance, only 25 percent mitigation was deemed to be appropriate in considering the corrective actions taken by the licensee. In addition, these EQ violations existed in excess of 100 days-
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- 4-of plant operation. This results in a total civil penalty of $300,000 ($300,000
- 25 percent mitigation based on identification and reporting + 50 percent inscalation based on lack of best efforts - 25 percent mitigation based on corrective actions), which, in the staff's view, properly reflects the significance of the violations, e
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. o Enclosure 6 PROPOSED MODIFICATION FOR ENFORCEMENT OF EQ REQUIREMENTS The staff proposes a modified a)proach for the enforcement of EQ violations from that specified in Generic .etters 85-15 and 86-15. One of the principal changes made in the existing EQ Enforcement Policy is that, in the staff's new proposal, significant EQ violations for which the licensee clearly knew or clearly should have known that they had equipment for which qualification had not been established would be considered together, in the aggregate, and the base civil penalty would be assessed based on the number of systems or components affected in a graded approach. The base civil penalty would be determined as described below.
EQ Yiolation Cateoortes M Base Civil Penalty 4
- 1. Extensive; EQ violations affecting many $300,000 systems and many components.
- 2. Hoderate; EQ violations affecting some $150,000 systems and some components.
- 3. Isolated; EQ violations affecting a $ 75,000 limited nurser of systems and components.
While eliminating the item count basis of the Generic Letters, the staff's
- proposed approach would establish the amount of a civil penalty based on the number of systems which are affected by the unqualified component or piece of equipment and, in doing so in effect, would account for the number (items) of unqualified equipment. Th~e staff's a>proach also reme< ties a problem in the existing EQ enforcement guidance in w11ch one item of unqualified equipment, as defined in the Generic Letters, whether it affected only one or several hundred components, would be treated as a single item for enforcement purposes.
The staff's proposed approach would specifically account for the degree to which components or systems are affected by the unqualified item or equipment. , Safety significance is not considered a separate factor because all violations of EQ requirements.are considered to be safety significant in that the elactrical equipment which had to be environw*"y qualified were those that were important t'o safety, as specified u te (Fe 50.49. However, to reflect the overall pervasiveness in effect oi :tsnificant EQ violations, a graded approach is being proposed with three violation categories. These . categories do not include those EQ violations which have been determined to be not sufficiently significant to be considered for escalated enforcement and which will be normally considered as Severity Level IV or Y violations. The safety significance of the EQ violations are conddered only to a limited degree when the number of systems affected by the Ef v clations are evaluated ) 1/ As with the examples in the Supplements to the Enforcement Policy of 70 CFR Part 2. Appendix C, judgment will be needed to detennine which l category the particular violation should be placed. ' l l l \ t .
3
. end a determination of the EQ violation category is made. The staff proposes to assume for enforcement purposes that unqualified equipment could in some way affect the asscciated system and will not consider additional operability refinements such as the actual time the equipment is required to be operable, administrative measures or controls to ensure the safety function is accomplished.
.he degree to which the operability of a system is af 7ected, or that through "
- k. ; j W itional analyses or testing, the equipment may be monstrated to be qualified 4
> -lifiable. This assumption for enforcement purp;.ses was taken in order to 4 s a the resources anticipated to be spent by licensees and NRC to evaluate
"% w etail whether, system operability was in question.
a S Because we are considering
~
" cement action rather than a justification for continuf' <reration and that, instances the EQ deficiencies have been corrected,17.1 approach has the W its of a relatively quick, though conservative, view on the safety con-t'x :n:es of unqualified eouipment. e 3
m , In o nsideration of whether the licensee clearly knew or should have known, E in most cases the staff expects that the licensee clearly should have knocn of the EQ deficiency because of the amount of inforraation provided to licensees
- by the NRC and industry. The staff intends to closely scrutinize arguments of licensees who take the position that they should not have clearly known of the deficiency prior to the deadline. -
The concept of a daily civil penalty was included when the amounts for the base civil aenalties for the three vio?ation categories were established. The base civil penaitin reflect 100 days of plant operation after the November 20, 1985 deadline G 4 9 the licens,ee clearly knew or should have known that they had , eqe pment foi k nh qualification b d not been established. Mitigation of the " W e civil penalties would bc consicared for those cases in which the time ' period of pi nt operation was significantly below 100 deys. The staff believes ' that few cases exist in which mitigation would apply as the time between the first round E0 ir.spections and the November 1985 deadline steadily 1ncreeses. Other mitigation and escalation factors will also be considered in determinin;; the amount of the civil penalty for EQ violat%ns. The mitigation and escalation factors will consider the EQ violations in aggrugate and not based on individual violations, as described below: ' . Mitigation / Escalation Factors Maximum Mitigation /
- Escalation Amount (from base civil penalty)
- 1. Identification and prost reporting, if : required, t 50%
of the EQ violations (including opportunities to identify and correct the deficiencies).
- 2. Be:t efforts to complete EQ within the deadline. t 505
- 3. ' Corrective tctioni to' result in full cogliance 2 bM (including the time taken to make an operability or qualification determinathn, the quality of any supporting analysis, and the nature and extent of the licensee's efforts to come into cegliAnce).
- 4. Duration of violetion which is significantly below 100 - 50%
days.
. ,- l e
, )
1 3 Civil penalties should not be 16. than $50,000 in most cases to be fair and equitable to those licensees who took appropriate actionr, prior to November 30, 1985 or shut down prior to this date to be in compliance, as provided in the Generic Letters and to emphasize that a significant environmental qualification failure is unacceptable. However, the staff proposes to fully mitigate (no civil penalty) those EQ violations which: (1) fall into the category of EQ violations which are isolated and affect a limited number of systems and components, (2) are identified by the licensee, (3) are promptly reported to the NRC, if required. (4) corrective actions will result in full compliance within a reasonable time, and (5) the licensee has demonstrated best efforts to complete EQ within the deadline. The intent of full sitigation of the civil penalty for EQ violations which meet all five criteria is to increase the incentive for self-identification of EQ deficiencies which might not otherwise be found by NRC. The staff preposes to issue only a Notice of Violation for violations which meet all these criteria. If the licensee is able to convincingly demonstrate at the time of the inspection, or shortly thereafter, that the item is not required to be on the EQ list, then the item would not be considered for enforcement action. The staff does not intend to consider for enforcement >urposes the results of a ' licensee's after-the-fact testing for mitigation w1ere the licensee clearly 3 should have known that its. documentation was not sufficient. , , t . i
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a Enclosure 7 PROPOSED EQ ENFORCEMENT APPROACH FOR DRESDEN UNIT 3 On May 19-23, 1985, an NRC inspection was conducted at Dresden Station, Units 2 and 3, to assess the licensee's program to implement the EQ requirements of 10 CFR 50.49. The inspection revealed that adequate documentation was not avail-able to show that nylon-insulated butt splices (manufactured by AMP Corporation) in Unit 3 were qualified to perform their intended function under postulated environmental conditions. Tiese splices had been used for circuits in electrical penetrations important to safe operation and shutdown. The EQ files failed to demonstrate the similarity between the tested splices and the installed splices. Severe degradation of these splices had already been identified by the licensee in September 1985 in Dresden Unit 2 and was postulated to be due to aging and an event which caused a high temperature in the containment. T% Dresden Unit 2 splices had been replaced with another type of splice privr to < the November 30, 1985 deadline. The Unit 3 splice were inspected by the licensee at that time and found to be acceptable. Subsequent to the NRC findings, the licensee conductec qualification testing of these splices, during which all of the four samples tested failed in that each of the samples exhibited excessive leakage currents and three of the four shorted to ground. Based en these failures, the licensee shutdown Dresden Unit 3torepairthesesplicesinDecember1986,.,1f The staff believes that the license'e clearly should have known that these splices were not qualified because (1) severe degradation of these splices had been identified in January 1985 in Dresden Unit 2 due to aging and a high temperature event inside containment (the licensee replaced these splices with a differens type in Unit 2 but only initiated a monitoring program for Unit 3), (2) the DOR EQ guidelines mention nylon material as being suspect due to its inherent poor characteristics under postulated nuclear power plant environmental conditions, and (3) while some vendor EQ test re> orts used to qualify the penetration and splices existed in the qualification file, tiese reports were clearly inadequate in that the tests failed to demonstrate that the installed nylon AMP splices or a suitable similar material had been tested. The test report and subsequent correspendence described a nylon-type splice, but did not specify the manufacturer nor the formulation and material properties of the nylon which was tested. These factors are considered crucial to demonstrate the similarity of the tested and installed materials. Thus, Commonwealth Edison had not demonstrated that the AMP splices installed had similar properties to those tested. These nylon-insulated butt splices, while used in three penetrations in the same environmental service condition, are considered to represent one item of unqualified electrical equipment as defined in Generic Letter 85-15. Dresden Unit 3 operated in excess of 100 days after the November 30, 1985 deadline with these unqualified splices. Therefore, the maximum civil
$500,000 is reacheo ($5,000 per day for 100 days for one item) penalty
. In of U Quad Cities Unit 1 was also shut down because the AMP splices were used in similar applications. Quad Cities Unit 2 was in a refueling outage at the time.
Enforcement action for these units are beino addressed separately. The staff isalsopursuinganissueinvolvingthequalificationofcablesthatmayimpact Dresden and Quad Cities. I
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. Dresden Unit 3 l consideration of the mitigation factors, using strict application of the EQ enforcement policy with the normal Enforcement Policy mitigation percentages, 4
mitigation could be based on the licensee's good efforts in the EQ area generally. With regard to corrective actions. the licensee's actions to innediately shut down operating units upon learning that the tested splices failed EQ testing and repair these splices prio- to putting Dresden Unit 3 back into operation were balanced against the fa,'ure to promptly resolve the issue after identification by the NRC. While'the licensee did take action-to test the splices, it was done only after attempts were unsuccessful in convincing I the NRC staff that the splices were qualified. In addition, the NRC had identified the violation. Therefore, mitigation of- the civil penalty is not appropriate for identification and reporting nor for.the corrective actions tacen. Full mitipation of the civil penalty-could be considered based on the licensee's genera ly good efforts /past performance in the EQ area. As a result, under the normal Enforcement Policy mitigation percentages, the civil penalt could be fully mitigated and the resulting civil penalty (after mitigation) y-could be the minimum civil penalty for an EQ violation of $50,000. ::n the staff's view a larger civil penalty is appropriate given the potential impact of the violations. Ilsing the proposed new approach, the staff reconnends the AMP splice violatio'n be assessed a base civil penalty of $150,000 because the unqualified splices affected some important~ safety systems and components, including isolation. , . valves for systems (reactor building closed cooling water, isolation condensers, ~ high pressure coolant injection steam supply, reactor-water cleanup, shutdown cooling) and main steam line solenoid valves. This is indicative of a moderate EQ violation ($150,000 base civil pensity). Escalation of the base civil - . , penalty by 50 percent under the staff's proposal is considered appropriate when * ' considering the factor of identification because the NRC identified these-violations and the licensee failed to take advantage of the identification of
- the degrading splices in Dresden Unit 2 to resolve the quellfication issue of identical splices installed in Dresden Unit 3. The staff elso considers-it appropriate to mitigate-the base civil penalty by 50 percent for the licensee's best efforts-in EQ. While the licensee did shutdown operating units upon- ,
learning of the test failure and repair these splices prior to putting Dresden Unit 3 back into operation, these actions were not done in reasonable time in that the plant operated from May to December 1g86 with splices for which qualification could not be-demonstrated. Therefore, on balance neither siti-gation nor escalation is deemed appropriate considering the licensee's correc-tive actions. The plant did operate in excess of 100 days-after the November 30, 1985 deadline. Therefore, overall the staff propose neither mitigation nor escalation of the base civil penalty (50 percent esca'ation for'the NRC identification of the issue with 50 percent mitigation fer the licensee's best efforts):and results in a total civil penalty of $150,000 for the AMP splice violation at Dresden Unit 3. This penalty amount is consistent with the staff's view of the significance of the violations. 4
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i 5 / $ [A500LlR$k" oo4d PS :07 LICENSEE: Alabama Powe- Company (APCo) D JKO-FNPm_ FACILITY: m ._ ui So 4 1Ar ksest4$ Joseph h.'CFifle(N4dleaEPlant. Units 1 and 2 I hg(g.g,i svn Mwi
SUBJECT:
50HARY OF MEETING HELD ON SEPTEMBER 24, 1987 BETWEEN NRC 'b *8 STAFF AND APCo REPRESENTATIVES TO DISCUSS RECENT PROBLEMS RELATED TO QUALIFICATION OF Y-TYPE ELECTRICAL SPLICES AT FARLEY SITE b Introduction The NRC Project Manager (E. Reeves) reviewed the purpose of the meeting and asked all personnel in attendance to state their name and affiliation. A list , of attendees is enclosed. NRC (S. Varga) noted that the NRC staff has serious concerns about the quali-fication of V-t Administrator (ype electrical cable splices at Farley site. Region II N. Grace) reviewed briefly the recent history of V-splice problems and actions taken by Alabama Power Company (APCo. the licensee) at Farley site. He reiterated the NRC staff concerns. (' APCo (P. Mcdonald) spoke to the challenge being offered to discuss this matter. He stated he would speak to the safety of the plant in which he maintains a strong confidence of the continued safety. APCo (J. Woodard) discussed the i basis of actions taken to date, the actions already taken, actions now underway, and actions planned. The history of the EQ Y-splice Program at Farley site was reviewed. In June 1987. APCo set up a review program of 6000 work request packages completed at Farley. This action resulted from the Vendor June / Procurement team audit conducted by NRC for three-weeks concluding on 5, 1987. safety significance. APCo is reviewing each category of equipment considered of found not to be in accordance with design.They subsequently inspected and repaire which were found were not considered as inoperable.APCo st&ted that Ti.sy had replaced the the V-splices splices with RAYCHEM type splices known to be qualified in M steam environment. Other splices were destroyed during the inspection process and RAYCHEM type splices were used as replacements. i He noted that the Unit 2 l refueling shutdown is scheduled to start on October 3.1987. Unit I refueling ' shutdown is scheduled March 17, 1988. APCo plans walkdown inspections. including where inside containment, to be performed and corrective actions .taken. necessary. In sumary Mr. Woodard stated that APCo never declared a splice to be inoperable, always acted with safety as the overriding criterion, and always acted rapidly and conservatively. APCo (G. Hairston) stated that the hydrogen recombiner splices are to be left "as is" pending further study. A justification for continued operation was (' -
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h provided to Region II on September 23, 1987, by APCo. Test results at Wyle Laboratory are underway now for fourteen configurations of "as found" splices
'( at Farley. Results are expected in October 1987, with preliminary results in about a week.
APCo (R. Mcdonald) stated the following comitments to NRC:
- 1. APCo will not start up Unit 2 from its projected 52-day refueling outage starting on October 3,1987, without assurance that APCo has resolved all operating issues on EQ matters (i.e., EQ issues which affect operability) for Unit 2 with the NRC.
- 2. APCo will keep the NRC advised of any emerging operating EQ issues found in either Unit 1 or 2 not addressed in the September 24, 1987 meeting. '
- 3. APCo will not start up Unit I from the Spring 1988 refueling outage without reaffirming assurance that APCo has resolved all operating EQ issues involving Unit 1.
- 4. APCo will take appropriate action if an operating issue emerges at any time on Unit 1 or Unit 2.
APCo (W. Shipman) noted that the splice problem had occurred because of 'a field installation error in reading the design documents for "teminations" vice for " splices". Also, each splice had not been specifically identified on the EQ list of safety related components. { The NRC staff questioned various reasons why APCo took the actions to date. The APCo staff responded to each question which was asked with specific emphasis on the logic involved in each action taken. APCo (J. Woodard) sumarized that the Farley plants are considered to be safe to continue to operate as follows:
- 1. Pigtail splices are considered qualified.
2. Instrurents inside containment are not expected to have pigtail splices.
- 3. No known pigtail splices exist inside containment.
- 4. Hase not found a safety problem yet.
APCo (G. Hairston) stated that preliminary test results just received from Wyle Laboratory indicate that the V-type, pigtail splices being tested appear to be acceptable. This preliminary report gives APCo additional confidence. NRC (Reeves) asked if APCo would expedite the walkdown inspections on Unit 2. APCo responded that the walkdowns were scheduled for the entire outage period. This was of concern to the NRC staff since Unit I would continue operating exist there. for that length of time without knowing if other splice problems may APCo noted that they rould take imediate action on Unit 1 for similar problems found on Unit 2 during the Unit 2 walkdowns. ( _ _ _ _ - . _ - _ . _ - . - - - - - - - - - - - - - - - - - - - - - - ' - - - ~ ~ ~ ~ ~ ~~ ~
e $ Following an NRC staff caucus, NRC (J. Grace) presented the NRC staff concensus
, as:
{
- 1. Will accept the APCo judgement that splices are qualifiable at this time.
- 2. Requested APCo to submit, to NRC, APCo's judgment and a basis for continued operation.
- 3. APCo should accelerate the inspection inside Unit 2 containment to complete it in about two weeks.
- 4. APCo should document the Wyle Laboratory splice test results as soon as possible to the NRC (A. Gibson RII).
APCo agreed to provide a written sumary documenting their plan to resolve the entire issue. Region II will then provide a comfirmatory action letter to APCo. APCo (Mcdonald) thanked the NRC staff for the confidence shown. Edward A.. Reeves, Sr. Project Manager Project Directorate 11-1 Division of Reactor Projects - I/II
Enclosure:
As Stated { cc w/
Enclosure:
See next page b
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Mr. R. P. Mcdonald Alabama Power Company Joseph M. Farley Nuclear Plant cc: Mr. W. O. Whitt D. Biard MacGuineas. Esquire Executive Vice President Volpe, Boskey and Lyons Alabama Power Company 918 16th Street, N.W. Post Office Box 2641 Washington, DC 20006 Birmingham,-Alabama 35291-0400 Charles R. Lowman Mr. Louis B. Long, General Manager Alabara Electric Corporation Southern Company Services Inc. Post Office Box 550 Post Office Box 2625 Andalusia, Alabama 36420 Birmingham, Alabama 35202 Chairman Houston County Commission Regional Administrator, Region II Dothan, Alabama 36301 U.S. Nuclear Regulatory Commissier 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts and Trowbridge Claude Earl Fox, M.D. 2300 N Street, N.W. ( Washington, DC 20037 State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36130 Robert A. Buettner, Esquire Balch, Bingham, Baker, Hawthorne, Mr. J. D. Woodard Williams and Ward General Manager - Nuclear Plant Post Office Box 306 Post Office Box 470 Birmingham, Alabama 35201 Ashford, Alabama 36312 Resident Inspector U.S. Nucleur Regulatory Commission Post Office Box 24 - Route 2 Columbia, Alabama 36319 ( __o
* ,?
~
Enclosure EQ MEETING September 24, 1987 NRC APCo W. a ord f,. aforsab
" J. Woodard f
- y, D. Jones H. Dance W. Shipman L. Reyes A. Gibson J. Grace Bechtel L. Dewey R. Anand K. Gandhi H. Walker J. Love G. Lainas E. Adensam
~ koski Other Associates k go E. Merschoff V. Noonan - R. L. Cloug Assoc. R. Wilson ( N. Merriweather A. Thadani S. Varga J. Craig J. Sniezek R. Starostecki t h L
TES U* [Sa asc e NUCLE AR REGULATORY COMMisslON
-% Os' '*( , AEGlcN ll
; e 101 MARIETTA STREET.N.W, f
In ATL ANT A. GEORGI A 30323 0
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Docket Nos. 50-348, 50-364 '92 W D License Nos. NPF-2 and NPF-8
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- N((I b Alabama Power Company ATTN: Mr. R. P. Mcdonald Senior Vice President P. O. Box 2641 Birming.ea. AL 35291-0400 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-348/87-25 AND 50-364/87-25 This refers to the Nuclear Regulatory Comission (NRC) inspection conducted by N. Merriweather on September 14-18, 1987. The inspection included a review of activities authorized for your Farley facility. At the conclusion of the inspection, the findings were discussed with those members of _your staff identified in the enclosed inspection report. Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress. Within the scope of the inspection, no violations or deviatior were identified. Your attention is invited to unresolved items identified in the inspection report. These matters will be pursued during future inspections. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NPC Public Document Room. Should you have any questions concerning this letter, please contact us. Sincerely, t 40w n R. dt, Chief [ Engine ing Branch Division of Reactor Safety
Enclosure:
NRC Inspection Report cc w/ encl: (See page 2)
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- OCT 18 M67 l t . Alabama Power Company 2 l cc w/ encl:
W. O. Whitt, Executive Vice President J. D. Woodard, General Manager - Nuclear Plant W. G. Hairston, III, General Manager - Nuclear Support J. W. McGowan, Manager-Safety Audit and Engineering Review J. K. Osterholtz, Supervisor-Safety Audit and Engineering Review i
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Report Nos.: 50-348/87-25 and 50-364/87-25 Licensee: Alabama Power Company 600 Nurth 18th Street Birmingham, AL 35291-0400 Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8 Facility Name: Farley I and 2 Inspection Conducted: September 14-18, 1987 Inspection at Farley si ejiear Dothan, Alabama Inspectors: / 14..$ ~
,e M' /6- [7 Date Signed N. Merriweather j
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/A O~/6-W7 C . ' P a y,l k Date Signed
/ Pn,< w S h f h /C -/4 - 7 7 C. Smith Date Signed ke.o~1 - - &
/O - /6 - 7 7 Date Signed W. Levis Approved by: '/ M- / ' ' ' //
T. E. Conlon, Section Chief Date Signed-Division of Reactor Safety
SUMMARY
Scope: This special, announced inspection was perfomed to followup on the EQ deficiencies identiff ed by the licensee on solenoid valves, motor operated valves and inside containment fan motors. Results: No violations or deviations were identified. I
~~ "
REPORT DETAILS
- 1. Persons Contacted Licensee Employees
*J. D. Woodard, General Manager
*W. B. Shipman, Assistant General Manager - Technical Support
*D. N. Morey, Assistant General Manager - Operations
*C. D Nesbitt, Technical Manager
*D H. Jones, Supervisor, Design Support
*L. A. Ward, Maintenance Manager
*B. R. Yonce, Electrical Maintenance Supervisor
*W. G. Ware, QC Engineer R. G. Berryhill, Systems Performance (59) Hansger
*L. S. Williams, Training Manager
*L. M. Shinson, PMD Manager
*L. M. Enfinger, Administration Manager
*J. J. Thomas, SP Engineer
*E. W. Carmack, Unit Supervisor G. Dykes, Lead Electrical Engineer
, C. Buck, Discipline Engineering Supervisor Other licensee employees contacted included craftsmen, engineers, technicians, security force members, storekeepers, and office personnel in the warehouse.
Other Organizations
*J. E. Love, Bechtel Engineering
*C. R. Foltz, Bechtel Engineering
*C, J. Vaz, Bechtel Site
*E. A. Raves, Farley Project Manager, NRC NRC Resident Inspectors
*W. Bradford, Senior Resident Inspector
*W. Miller, Resident Inspector
- Attended exit interview
- 2. Exit Interview The inspection scope and findings were summarized on September 18, 1987, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings. The followin5 new items were identified during this inspection:
i
- a. Unresolved Items 50-348,364/87-25-01, Unqualified Splice on Hydrogen Recombiners, paragraph 5.a.
l
-_ \
2
- b. Unresolved Items 50-348, 364/87-25-02.a Procurement of Coteercial Grade Components for EQ Applications, paragraph 5.b.:
- c. Unresolved Items _ 50-348, 364/87-25-02.b. Inadequate Upgrade Program for EQ Components, paragraph 5.b.
- d. Unresolved Items 50-348, 364/87-25-03, Inadequate Peer Review Program, paragraph 5.c.
- e. Unresolved Items 50-348, 364/87-25-04, Use of Unqualified Grease on MOVs, paragraph 5.d.
- f. Unresolved Items 50-34 , 364/87-25-05, Unqualified Lubricants, Lara-graph _5.e.
The licensee did not identify as proprietary _ any of the materials provided to or reviewed by the inspectors during this inspection. Suosequent to the inspection, telephone conversations 6cd a meeting were held with licensee management to discuss the insper' ion findings- and corrective actions to be taken for resolution o' 5ne identified defi-ciencies.
- 3. Licensee Action on Previous Enforcement Matters f
See paragraph 5 for more inforination on previously identified enforcement matters.
- 4. Unresolved Items Unresolved items are matters about which more information is required to determine whether they_ are acceptable or may involve violations or deviations. Five unresolved items identified during this inspection are discussed in paragraph 5.
- 5. Followup On Licensee Identified EQ Splice Problems During the weeks of May 11-22, 1987, and June 1-5, 1987, a Procurement and Vendor Technical- Interface Program Inspection was performed- by NRC. In order to address concerns expressed by the NRC inspection team and recent EQ maintenance problems experienced by other utilities (such as Calvert Cliffs), Farley management formed an Environmentally Qualified Equipment Document Verification task team on June 15, 1987, to review maintenance records to verify that EQ equipment had been maintained in a qualified status.
On July 16, 1987, the licensee's task team noted a potential problem with the electrical connection between_ the solenoid pigtails and the -field wires. Plant inspection of a sample soienoid valve on July 20, 1987, confirmed that the con .e. tion was not in accordance with design and the
3 licensee subsequently notified NRC, A JC0 was prepared for the solenoid valves to allow for continued operation based on the operability require-ments of the solenoid valves. Further review by the licensee's task team indicated that the potential problem also existed with MOV motor lead splices and other 600V motor terminations. A JC0 was prepared for the MOVs on July 31, 1987 Three MOVs in each containment were not capable of justification for continued operation and required imediate configuration verification. These valves were inspected and subsequently repaired on July 31, 1987 and August 1, _ 1987. On August 4, 1987, the licensee's task team identified the same potential splice problem with containment fan motors. There were ten fans involved per unit, which affected several systems. Instead of preparing a JC0 for these fans as recommended by Generic letter 86-15 and as done previously with the SOVs and MOVs, the licensee chose to inspect the motor termina-tiets one trair at a time and correct deficiencies as they were found. In this manner, the train was declared inoperable during the inspection and repair and later declared operable upon completion of repaf rs. All splices / terminations for the containment f an motors were found to be deficient and required replacement. The work was accomplished for Unit 1 from Auga t 7-13, 1987, and for Unit 2 from August 13-19, 1987. During the week of September 14-18, 1987, NRC Region II performed a Reactive Inspection to followup on the EQ splice deficiencies identified by the licensee on solenoid valves, motor operated valves, and inside containment fan motors. Tb inspection concluded that there was not sufficient splices. documentation tc mtablish oualification of the installed The splices were determined to be unqualified as defined by Generic Letter 85-15. The unqualified configuration is a type V-stub connection splice using T95 tape for insulation and T35 tape for jacket material. This configuration is not covered by design drawings or engineering instructions and has not been environmentally tested for Design Basis Accidents (DBA) (e.g., Loss of Coolant Accidert (LOCA), High Energy Line Break (HELB)) by ApC0. This type of splice is not completely sealed. It can allow moisture to travel along the cables to the V-stub connection. The root cause of these unqualified configurations was determined to be due to incomplete design drawings / engineering work instructions and misinterpretation of electrical notes and details by craft. It should be noted that the drawing did not address the V-type stub connection but indicated that the Raychem splice kit for in-line splices should have been used in the above applications. The splice issue for SOVs, MOVs, and the conuinment fans were previously identified as Unresolved Items 50-348, 364/87-17-01, 02, and 03, respec-tively, and will remain open. Additionally, potentially unqualified splices may exist in electrical penetrations and instrumentation tircuits inside containment. The licensee did not perform adequate walkdowns prior to November 30, 1985, to ensure compliance with 10 CFR 50.49.
'O 4 Other specific concerns expressed by the inspection team and left as unresolved items at the exit meeting include:
- a. The licensee has not established qualification for the in-line splice configuration used on the hydrogen recombiner on both trains in both units. The assumed configuration as described in the licensee's JC0 dated September 17,1987 (letter No.13525), identified a one-to-five splica configuration. The team's concern is that this configuration will allow moisture egress into the unsealed splice region along the heater lead cables causing potential fault paths. The EQ central files only address a SKV in-line one-to-one splice configuration and do not provide adequate information to establish reasonable assurance that the five-to-one splice will perform its intended function. It should be noted that the licensee also took credit for operability of the hydrogen recombiners in their JC0 on motor operated valves dated July 30, 1987 (letter No. NS-87-0241). This item is identified as Unresolved Item 50-348, 364/87-25-01, Unquali#ied Sp!! c on Hydrogen Recombiners.
- b. The tapes procured for these splices (i.e., V-type or in-line) are procured as commercial grade (Code C), and have been since construction. No program existed to dedicate Code C components for safety-related and/or EQ applications. The current program allows i
for the foreman or above supervision to substitute commercial grade (Code C) parts or components into safety-related and/or EQ applica-tions (Code A). The licensee acknowledged a deficiency in their procurement program for Code C items and are undertaking corrective actions. In addition similar deficiencies concerning use of commercial grade items in EQ applications was identified by the Vendor Program Branch Inspection Report (50-348, 364/87-11). This item is identified as Unresolved Item 50-348, 364/87-25-02.a. Procurement of Commercial Grade Components for EQ Applications. Additionally, the licensee's EQ Administrative Program does not address upgrade requirements as specified in 10 CFR 50.49(l). The licensee does not agree with this finding. However, contrary to the requirements of 10 CFR 50.49(L) procedural controls have not been established to document reasons to the contrary for not upgrading replacement equipment. The licensee considers that their program meets their commitments as specified in their letter dated February 29, 1984, which states in part that "if identical components cannot be obtained", the exiting equipment is requirec to be replaced with new components procured to meet provisions of test reports that have been reviewed and accepted by APC0 to the requirements of 10 CFR 50.49. This item will be submitted to NRR for further review and is identified as Unresolved Item 50-348, 364/87-25-02.b, Inadequate Upgrade Program for EQ Components,
- c. Peer inspections of splice configurations on the containment mixing fan motors were inadequate and did not reflect drawing requirements.
Recent walkdown inspections of the fan motors showed only the use of i _____- - _ _ - - i
t 5 T95 tape in V-configuration which are not in accordance with design and are not environmentally qualified. Maintenance Work Requests used to determinate and reterminate splices during the previous outages on each unit indicated that tha splices were documented as being in accordance with design by an inspection performed by the foreman. Specifically, MWR 147889, completed November 13, 1986, on Unit I documented that the splices on containment Mixing Fan Motors 18 and 1C were in accordance with design. However, during the recent walkdowns on Unit 1, it was found that these fan motor splices only had T95 tape in a V-configuration which is not in accordance with design (reference MWRs 159078 and 159079), indicating an inadequate peer review. In addition, other deficiencies were identified by the Vendor Program Branch and are documented in Inspection Report No. 50-348, 364/87-11, which are indicative of generic problems in the area of " Peer Reviews." .This is Unresolved Item 50-348, 364/ 87-25-03, Inadequate Peer Review Program.
- d. The Limitorque Motor Operated Valves (MOVs) used by FNP incide containment were supplied by the vendor with Exxon Nebula EPO or EP1 grease in the main gear boxes. The potential of having ircompatible greases inside the rain gear box exists as a result of maintenance performed with Texaco MARFAK AP grease, which is a lithium soap base versus Nebula which is a calcium soap base. The lubrication checks as specified by the FNP Lubrication Manual (P12) are performed every 548 days and MARFAK AP is added as necessary to ensure sufficient grease level. There is no requirement to completely change the grease. Liaitorque specifically states that greases of different soap bases sc.ould not be mixed. In addition, this problem was detailed further in INP0 SOCR 7-84 The team noted that the plant response to this SOER was to be included in that of IEB 85-03 which is not yet completed.
Another iten of concern to the team was the fact that no documenta-tion was presented to the team to establish the environmental qualification of the MARFAX AP grease for inside containment applications or SUN SOEP grease for outside containment applications. The licensee stated that they had information addressing MARFAK ?.P but it was still under review and was not yet approved. Subseqaent to the inspection, the licensee provided the team a copy of a JC0 for mixed grease used in MOVs. This is identified as Unresolved Item 50-348, 364/87-25-04, Use of Unqualified Grease on MOVs.
- e. No documentation was presented to the inspection team whien supported the use of Premium RB grease on fan motors inside containment and room coolers outside containment. The root cause is that lubricants were not included on the EQ Master list of EQ equipment and components.
Subsequent to the inspection, the licensee documented a JC0 to allow continued operation with this deficiency. . This is identified as Unresolved Item 50-348, 364/87-25-05, Unqualified Lubricants, l
6 Additionally, the inspection team was concerned with the installation and qualification of other EQ equipment, such as electrical penetra-tions and instruments inside the containment. The licensee did not have adaquate justification or documentation to accurately verify the installation configuration in order to assure that the additional equipment was qualified. Such documentation should have been available had the licensee performed adequate walkdowns to ensure compliance with 10 CFR 50.49. L On September 22, 1987, a conference call was held between NRC staff and APC0 to discuss the inspection team findings and actions tal:en by APC0 to resolve deficiencies previously identified by themselves. Numerous questions were posed by the staff; however, the answers provided by APC0 were not sufficient to satisfy NRC concerns at that time. These issues will be examined further during the planned EQ inspection in November 1987.
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M iV , Smte nbe c 30,"1987 Docket Nos, dO-348 50-364 { Dr. J. N. Grace U. S. Nuclear Regulatory Commission Region 11 Suite 3100 101 Marietta Street N. W. Atlanta, GA 30303
Dear Dr. Grace:
Joseph M. Farley Nuclear Plant - Units 1 and 2 Environmental Qualification Meeting of September 24, 1987 A meeting was held on September 24,1987 at tt.e '4RC Of fices in Bethesda, Maryland to discuss the deviation from design of certain cable splices used at Farley Nuclear Plant on environmentally qual' tied equipment and the potential safety significance associated with the use of these splices. Inis letter provides a discussion of the splice issues as presented at the meeting, including the basis for Alabama Power Company's decision to continue operating both units of Farley Nuclear Plant, future actions for ensuring that af fected splicas are restored to full compilance with design, and the status of testing on thE subject splices. When a significant issue occurs at Farley Nuclear Plant, Alabama Power Company's first cv .ern is to establish confidence in the safety of the plant, then to r
- 11y and methodically establir plans and resources to resolve the iss . and then to implement the resolution on a schedule that is accelerated ta the extent consistent with overall safety. With regard to the splice issue, Alabama Power Company has acted rapidly, conservatively and within what we believe to be the requirements of the regulations. Alabama Power Company plans to continue to vigorously pursue environmental qualification (EQ) issues, in concert with this approach, Alabama Power Company made the fcl'.owing commitments to the NRC at the September 24, 1987 meeting:
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i ) t jv ! Dr. J. N. Grace September 30', 1987 U. S. Huclear Regulatory Commission Page 2 i
- 1. Alabama Power Company will not start-up Unit 2 from its
- projected 52 day refueling outage starting on October 3,1987
- without assurance that Alabama Power Company has resolved all 4 operating issues on EQ matters (i.e., EQ issues wnich af fect operability) for Unit 2 with the NRC.
L 2. Alabama Power Company will keep the NRC advised of any emerging operating EQ issues found in either Unit 1 or 2 not addressed j in the September 24, 1987 meeting.
- 3. Alabama Power Company will not start-up Unit 1 from the Spring 1988 ref ueling outage without reaf firming assurance that Alabama a
Power Company has resolved all ooerating EQ issues involving Unit 1. 4 Alabame Power Company will take appropriate ution if an , operating issue emerges at any time on Unit 1 or Un!t 2. I In December 19'i, d a safety evaluation was issued by the IRC concieding that , Alabama Power Company's EQ program for "arley Nuclear Plant was in compliance with 10CFRb0.49. In 1986 sc.d 1987, an INP0 evaluation and ! Alatama Power Company Quality Assurance iudits respectively identified , several tindings related to the EQ program. These findings were expeditiously resolved. In liay 1987, a Vendor Information and Procurement inspection was conducted by the NRC with concerns identified on the EQ file I documentation atid the use of commercial grade parts in EQ systems. Tne i above findings provided an indication that other issues potentially existed in the established EQ program at Farley Nuclear Plant. Based on the indication discussed above, an extensive review of the Farley No: lear Plant EQ program was ir.itiated by Alabama Power Company in June 1987 This review included a re-review of test reports to ensure that the data to support qualification is available, a review of test' reports and technical manuals to ensure that maintenance requirements for EQ equipment are specified in maintenance procedures and practices, a review of past corrective maintenance to ensere that the environmental qualification of equipment is being preserved, and a review of EQ probleirs experienced at other nuclear plants for relevance to Farley Nuclear Plant. Based on the review of an NRC EQ Audit Report on another nuclear facility and discussiors with various maintenance and construction personnel, Alabama , Power Company determined on July 16, 1987 that cable splices configured.in l a V f ormation (V-splices), which is a deviation f rom the design, . l potentially existed on ASCo solenoid valves as the cable connection mechanism rather than in-line taped splices or Raychem configurations.. - A JC0 was prepared and the V-splice on solenoid valves which were accessible were replaced with Raychem splices that were in accordance with the design. In conjunction with establishing the plan associated with ASCO solenoid valves, it was determined that the V-splice issue nignt be applicable *.o other categories of equipment. Concurrently, consideration
Dr. J. H. Grace September 30, 1987 U. 5. Nuclear Regulatory Conaission. Page 3 of the available information relating to V-splices led Alabama Power Company to ccnclude that the splices in question would perform their intended function. Upon review of the situation, Alabama Power Company determined the following two approaches could be taken with this potential issue:
- 1. A justification for continued operation (JCO) could be developed based on previous test data concerning V-splices, which could envelope V-splice configurations in the plant, or -
- 2. Itaving evaluated the capability of the subject splices to perform their intended function, a more conservative methodology
(' .e., a methodology involving the development of JCOs, the inspection of splices, and replacements as necessary to restore to the approved design) could be adopted and applied to problems discovered in each category of equipment. The more conservative JC0 methodology was adopted as the general approach for the V-splice issue. The categories of eqp_ipment to which the V-splice
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is. sue would. potentially_,be applicable were defined and prioritize~d to-serve as a corrective action plan extendinj beyond the solenoid valve actions already initiated. The technical justifications for Alabama Power Company's decision that the taped V-splices in question would perform their intended function were based on (1) qualification test data, (2) protection af forded to preclude exposure of the splices to direct spray, (3) the use of materials which are qualified for in-line splice configurations, and (4) engineering judgement. I With regard to the qualification test data, an evaluation was performed l considering Wyle Report 17859-02P (Qualification Test Program for Commonwealth Edison Company's PWRs). This test report provides qualification information on V-shaped splices using T95 insulation-tape and
#35 jacketing material that were subject to noisture incursion since the crotch of the V was not filled with any insulating material. The test specimens were subjected to an accelerated thermal aging equal to 40 years plant life, radiation exposure of 200 MRads gamma, and a design basis accident profile with a peak of approximately 360*F and 58 psig.
Alabama Power Company believed that the splices would not be directly exposed to spray because the splices are contained inside termination boxes, conduits, or other enclosures.. Since roisture incursior into the taped V-splice under postulated accident environments was a potential concern, Alabama Power Company considered the shielding of the. splice f rom direct spray to be a significant f actor. Additionally, the materials used by Alabama- Power Company for the V-splices were expected to be qualified materials.
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Dr. J. N. Grace September. 30, 1987 U. S. Nuclear Pegulatory Commission Page 4 u Small amounts of leakage currents could be postulated to occur as a result of the V-splice configuration. Since these splices were not expected to be installed on instrument circuits where leakage currents could significantly af fect the function of the circuit, it was concluded through engineering judgement that small leakage currents were not significant with respect to equipment operability. Based upon these technical justifications and engineering judgement, Alabama Power Company believed the V-splices would perfono their intended function when exposed to the relevant environment. Accordingly , Alabama Power Company has never declared equipment inoperable due to the V-splice configuration. Theref ore, Alabana Power Company believed, and continues to believe, that the continued operation of Units 1 and 2 of Farley Nuclear Plant is safe, is acceptable, and does not represent a potential risk to the health and saf ety of the public or f arley Nuclear Plant employees. I On July 24, 1987, an evaluation was initiated on certain motor operated 1 valve (MOV) notor-lead splices that were potenti?ily installed in the V configuration. A JC0 was developed for these MOVs utilizing the following groupings: 1) MOVs outside containments or the main steam valve rooms; 2) MOVs inside containments or the main steam valve rooms, with no post , accident operation: 3) MOVs inside containments or the main steam valve rooms, with short-term pnst accident operation; and 4) MOVs inside containments or the main steam valve rooms, with long-term post accident operation. For the fourth group of MOVs, Alabama Power Company decided the actual configuration of each of these valves had to De determined and either replaced with a configuration in accordance with the design or a f urther JC0 developed based on past test reports. All of the valves in the f ourth group were placed in a configuration in accordance with the design hy July 31, 1987. In total, 40 of 60 MOV notor-lead splices have been replaced on Unit l', 26 of 74 MOV motor-lead splices have been replaced on Unit 2, and replacements on accessible MOVs are continuing even though JCOs may not require near-term replacements. On August 4, 1987, an evaluation was initiated on ten fan motors inside-containment on each unit that potentially contained splices which were a deviation from the design. A JC0 was initiated and, at the sane time, action was initiated to inspect each fan motor and correct any splice configurations identified to be a deviation from the design. The decision to inspect and make necessary replacements was considered a more
. conservative measure than waiting for the develo; ment of a JCO. Upon commencement of the inspection, Alabama Power Company decided that the work could be completed prior to the completion of the JC0 and ef forts on the JC0 development were stopped. Multiple inspection /replacenent teams were utilized on each shif t to expedite the schedule and to minimize personnel radiation exposure and heat stress. Additionally, only one component was taken out of service at a time to minimize the collective number of safety
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e Dr. J. N. Grace September 30, 1987 k U. S. Muclear Regulatory Commission Page 5 systems out of service at a time. All ten fan motors on each unit were placed in a configuration in accordance with the design during the period f rom August 7,1987 to August 22, 1987. On September 15, 1987, an evaluation was initiated on 4160V motor terminations that potentially contain(d splices which were a deviation from the design. The scope of this potential deviation from design involved the c h a rM nc n"-*', RHR numps, and containment spray pumps on each unit. Subsequently, the V-splice configuration was approved by design for applications not in a post accident steam environment. These pumps are not in a post accident steam environment. Alabama Power Company decided to destructively inspect each of these splices to determine if splice materials and dimensions were correct. The charging pump splice inspections on each unit are complete. Due to the V-splice issue identified on solenoid valves, Alabama power Company recognized the potential for a splice problem on the electrical 3 connection to the hydrogen recombiner heaters and scheduled an evaluation of this potential problem. The NRC expressed concern about this potential problem during the Region 11 inspection performed the week of September 14, 1987, in response to the concern expressed by the NRC, Alabama Power Company elevated the priority of this potential problem and developed a JC0 for the expected splice configuration. This JC0 was reviewed by tne Plant Operbting Review Committee and approved on September 18, 1987. The 1 A recombiner was inspected on the af ternoon of September 18, 1987 and confirmed to he in the expected configuration (i.e. , one field wire bolted to five heater leads and taped with Okonite T95 insulating tape with Okontte #35 jacketing tape over the 195 tape). The NRC questioned the September 18, 1987 JCO. A revised, more detailed, JC0 was subsequently prepared and provided to the HRC, which is still under review by the NRC. Additionally, Westinghouse provided by letter dated September 22,1987 the original splice test configuration for the Farley NJclear Plant hydrogen recombiners. The configuration used during the test was a taped splice - similar to the as-found 1A configuration. Alabama Power Company is 3 currently pursuing with Bechtel Eastern Power Company and Raychem Company a design that will resolve the concerns with this connection. Alabama Power Company plans to continue to evaluate splices for EQ equipment and components as follows:
- 1. 600V fan motors outside containment.
- 2. Instrumentation inside and outside containment such as transmitters, level switches and radiation monitors. .
- 3. Containment electrical penetration terminations.
4 Any other equipment or components that could potentially De spliced or terminated as a deviation from design.
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,, Dr. J. H. Grace September 30, 1987 U. S. Nuclear Regulatory Commission Page 6 As determined necessary by these reviews, splices a.id terminations will be replaced consistent with the design. All known work , inspections and walkdowns will be completed with evaluations performed by the end of the next refueling outage on each unit.
In addition to the JC0s prepared and corrective actions taken, Alabara Power Company initiated an expedited test program of V-splices. A r. tne time of the September 24, 1987 meeting, the splices had succe' :. fully completed radiation exposure and thermal aging tests, and ht. successfully endured exoosure to tnc peak temperature and pressure of the accident environment. Also at the time of the meeting, the splices were being exposed to a post-accident soak environment with the majority of the chemical spray exposure test completed. N0 failures had been ' m rted. Alabama Power Company noted that testing was scheduled for co- % ion on September 25, 1987. All qualification testing was successfully completed on September 25, 1987. The qualification test results were submitted to Alabama Power Company by letter fr:m Wyle Corporation dated September 28, 1987. The results of t*,e testing presented in the letter states that all of the test specimens demonstrated the capability to conduct the specified currents at the specified voltages throughout the test. The letter concluded that the test specimens are qualified to tne intent of IEEE Standard 323-1983, "lEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating-Gtations." At the September 24, 1987 meeting with the NRC, Alabama Power Company was requested to provide in this letter a discussion of walkdowns to be conducted. Walkdowns inside containment relative to the splice issue will be conducted during the next refueling outage on each unit at Farley Nuclear Plant. The walkdowns will include a sample of ccmponents in representative equipment categories which are subject to the splice issue. The scope of these walkdowns will include instrumentation, penetrations, and anj other categories of equipment determined by reviews to be s'ibject to the splice issue. The Unit 2 walkdown will begin during the first full , week of the outage and will be completed as soon as possible (currently estinated to be within two weeks from initiation). Alabama Power Company is developing a subset of the walkdown plan which will identity a smaller sample of the equipment / components with field wiring connections in order to quickly identify significant issues. This subset of equipment is anticipated to be inspected in three to four days from the beginning of the walkdown. Alabama Power Company will provide this detafled schedule of ,the Unit ? waltdown to the NRC Region 11 Resident inspectors. Additionally, Alabama Power Company will continue to ensure that the Resident inspectors are kept informed of our continuing EQ ef forts and any f urther EQ issues that are identified.
Dr. J. N. Grace September 30, 1987 U. S. Nuclear Regulatory Comrnission Page 7 If there are any questions, please advise. Respectfully submitted. ALABAMA POWE , 'tPAN Y
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Report Nos.: 50-348/87-17 and 50-364/87-17 : ,, t I Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291 Occket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility name: Farley 1 and 2 ,
- Inspection Conducted
- July 10 - August 18, 1987 I i
4 Inspection at Farley site near Dothan, Alabama 1 i Inspectors [M/ bad /b e i: < W. H. Bradfor T h_-/-87 Date Signed l
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er, ' S-ltt / _. - Date f /-Signed ' Approved by: h/ dt U ._ _j / M7 {s. H, C, / Dance, Section Chief Oate Signed j Division of Reactor Projects i
SUMMARY
- Scope
- This routine, onsite inspection involved a review of: previous enforce-ment matters, operational safety verification. surveillance, ob ervat.icn and monthly maintenance observation.
t Results: One procedural violation with three examples was idcotified: ! Technical Specification Amendment (162 for Unit 2 was not irnplemented within the
- specified time, failure to follow procedure and use of an inadequate past maintenance test procedure.
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! 1. Licensee Employees Contacted:
i i J. D. Woodard, General Plant Manager l D. N. Morey, Assistant General Plant Manager l W. D. Shipman, Assistant General Plant Manager R. D. Hill, Operations Manager C. D. Nesbitt, Technical Manager R. G. Berryhill, Systems Performance and Planning Manager L. A. Ward, Maintenance Manager L. W. Enfinger, Administrative Manager B. Moore, Operations Supervisor J. E. Odom Operations Unit Supervisor B. W. Vanlandingham, Operations Unit Supervisor
; T. H. Esteve, Planning Supervisor i J. B. Hudspeth, Document Control Supervisor !' L. K. Jones, Material Supervisor R. H. Marlow Technical Supervisor L. M. Stinson, Plant Modification Manager J. K. Osterholtz, Supervisor, Safety Audit Engineering Review Other licensee employees contacted included technicians, operations personnel, maintenance and 1&C personnel, security force members, and office personnel.
- 2. Exit Interview The inspection scope and findings were summarized during management interviews throughout the report period and on August 17, 1987, with the general plant manager and selected members of his staf f. The inspection findings were discussed in detail. The licensee acknowledged the viola-tions identified in Paragraph 4 The licensee did not identify as proprietary any material reviewed by the inspector during this inspection.
- 3. Licensee Action on Previous Enforcement Matters (92702)
(Closed) Violation 348, 364/87-07-01, Inadequate Number of Fire Brigade Drills Conducted During 1986. Procedure FLP-0-TCP-17,21, Fire Brigade Initial / Retraining Program Implementation has been issued to describe the plant's brigade training program. This procedure requires _ a fire brigade drill schedule to be established for at least six drills per quarter with each operating crew required to participate in at least one drill per quarter. 'The drills are also required to be documented as a training record. The licensee's records were reviewed and indicated that between January 1 and July 8, 1987, a total of 30 fire brigade drills had.been conducted of which at least 6 drills were conducted per quarter. Imple-mentation of Procedure FLP-0-TCP-17.21 should assure that a sufficient-number of quarterly fire brigade drills will be conducted in the future.
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- 4. Operational Safety Verification
- a. P1:nt Operations Review (71707)
The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the report period. Also, the operability of selected emergency systems was verified, tagout records reviewed and proper return to service of affected components was verified. Tours of the auxiliary building, diesel building, turbine building and service water structure were conducted to observe plant equipment conditiuns, including fluid leaks and excessive vibrations and general housekeeping efforts. The verifications were accomplished by direct observation of monitoring instrumentation, valve positions, switch positiens, accessible hydraulic snubbers, and review of completed logs, records, and chemistry results. The licensee's compliance with LC0 action state-ments were reviewed as events occurred. The inspectors routinely attended meetings with certain licensee management and observed various shift turnovers between shift supervisor, shift foremen and licensed operators. These meetings and discussions provided a daily status of plant operations, maintenance, and testing activities in progress, as well as discussions of significant problems. The following procedural discrepancies were identified. (1) No Procedure for Containment penetration Overcurrent Protective Ocvices. During a review of the Unit 2 Limiting Condition for Operation (LCO) log data the inspectors noted that plant procedures were not available to identify the containment penetration conductor overcurrent protective devices which were required to be 4 de-energized or energized under administrative controls by 4- Unit 2 Technical Specification (TS) Section 3.8.3.1. Amend-3 ment 62 to Unit 2 TS, issued April 10, 1987, deleted Table
}' 3.8.1, Containment Penetration Conductor Overcurrent Protective Devices, from the TS and the TS Bases Section 3/4.8.3. states that tabulation of the _ required containment -penetration conductor overcurrent protection devices will be contained in plant procedures which are controlled in accordance with 10 CFR 50.59. The f ailure to establish and implement this procedure as required within 30 days upon receipt of the license amendment is identified as violation 348, 364/87-17-04.
(2) Failure to Follow Operational Procedures. On July 24, 1987 between 8.00 a.m. and 10:00 a.m. the resident inspector witnessed the surveillance - tests performed by proce-dure 1-STP-33.0B, Solid State Protection System Train B Operability Test. This test was satisfactorily accomplished
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- 3 exc.ept, the plant operator performing the test did not follow the prescribed test sequence as required by Scction 4.5 of procedure 1-STP-33.08. The operator did not enter the trip breaker and bypass trip breaker count numbers into the surveil-lance test data book located within the control room and verified that the counter numbers had increased since the last entry as required by procedure section 5.7.11 until all of the procedure steps had been completed. This failure to follow procedure is another example of violation 348, 364/87-17-04.
(3) Failure to Follow Approved Procedures. One June 18, 1987 during the performance of STP 8010 " Diesel Generator 2C 1000KW Load Rejection Test", the licensee found an electrical problem in which 2C diesel generator would not have non-essential (NEEP) engine protection when aligned to 2B battery. (See unresolved Item 348-364/87-14-03). If 2C diesel generator was aligned to 28 battery an electrical circuit path was provided between the positive (+132VDC) of IB battery to the negative (-132VDC) of 2B battery. There was no voltage potential to operate the NEEP relays for 2C O/G. The 2C or 1B diesel generators were capable of performing emergency starting and operation. The cause of the problem was a wiring error in termination cabinet 38B on ITB1-37. The correct point of termination should have been to 2TB1-37. The error was made while performing PCN SE-81-909 under MWR 111291 which modified the control circuitry to prevent the diesel generator from motoring. The licensee did not perform adequate testing of the diesel generator af ter completion of the modification to ensure the modified equipment would perform as designed, as required by I AP-52. This is another example of violation 348,364/87-17-04. f
- b. Radiological Protection Program (71709)
Selected activities of the licensee's Radiological Protection Program were reviewed by the inspectors to verify conformance with plant procedures and NRC regulatory Requirements. The areas reviewed included the organization and management of the plant's health physics staf f; "ALARA" implementation; Radiation Work Pe-mits (RWP's) for compliance to plant procedures; personnel exposure records; observation of work and personnel in radiation areas to verify compliance to radiation protection procedures; and control of radioactive materials,
- c. Physical Security Program (71881)
The licensee's compilance to the approved security plan was reviewed by the inspectors. The inspectors verified by observation and interviews with security force members that measures taken to assure the physical protection of the f acility met current requirements.
4 s Areas inspected included: organization of the security force;. establishment and maintenance of gates, doors, and isolation zones; access control; and, badging procedures. Except as noted above, no additional violations or deviations were identi-fled within the areas inspected. S. Surveillance Observation (61726) Portions of the following surveillance inspections and tests required by the Technical Specifications were witnessed, observed or reviewed by the inspectors: STP-34.1 - Containment inspection (Post Maintenance) Appendix 1 STP-33.0A - Solid State Protection System Train A Operability Test STP-33-0B - Solid State System Train B Operability Test STP-33.1B - Safeguards Test Cabinet Train B Functional Test STP-108 - Incore Thermocouples STP-110 - Determination of Limiting Hot Channel Factors STP-121 - power Range Axial Offset Calibration STP-609.0 - Containment Tendon Surveillance Test No violations or deviations were identified. The inspectors verified that the surveillances were performed in accord-ance with adequate procedures; instrumentation was calibrated; limiting conditions were met; test results met acceptance criteria and were reviewed by personnel other than the individual directing the test; deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel; and personnel conducting the tests were qualified.
- 6. Monthly Maintenance Observation (62703)
The inspectors observed / reviewed the following maintenance activities of ^ safety-related systems and components to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and were in conformance with Technical Specifications: B Diesel Generator oil pump seal replacement.
5 0 Replacement of splices (terminations) f rom T-95 splice material to Raychem shrinkable; splice kits on Units 1 and 2 solenoid valves on the auxiliary feedwater system; 15 motor operated valves on Unit I and 2; and 10 fan motor terminations on each unit. Items considered during the reviev included: verification that limiting conditions for operations were met while components or systems were removed from service; approvals were obtained prior to initiating the work; approved procedures were used; completed work was inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials were properly certified; and, radiological -and fire prevention controls were implemented. Work requests were also reviewed to determine the status of outstanding jobs to assure that priority was assigned to safety-related equipment maintenance which may affect system performance. No discrepancies were identified except for maintenance activities associated with re-terminating electrical leads to solenoid operated valves, motor operated valves, and electrical leads to motors associated with containment building hydrogen mixing and containment building cooling. The inspection and repair work done inside the reactor containment Luildings was completed under adverse personnel environmental conditions. The repair parties were subjected to temperatures up to 139 F. The work was well planned in that personnel exposure was limited to 40 to 50 mrem
- per entry. All personnel wore ice vests and the stay time was limited to 25-30 minutes due to heat stress.
The inspectors observed and/or reviewed certain completed work packages to determine that work was completed in accordance with the procedure, that post maintenance testing was completed and acceptable. On August 9, 1987, the licensee reduced power on Unit I to 37% to complete the inspection and re-work on the motor splices. On August 14, 1987 power was increased to full load. On August 14, 1987 power was reduced to 37% on Unit 2 for inspection and rework of the motor splices. On August 19, 1987 power was increased to full load. l l This is described in paragraph 6a, 6b and 6c.
- a. Re-termination of electrical-leads to solenoid operated valves.
On July 21, 1987 the licensee notified the resident inspector of a possible nonconformance in the environmental qualifications of 125 Cdc splices utilized in certain environmentally qualified air operated valves. The licensee identified a total of 84 affected solenoid valves on each unit. Of the 84 solenoid valves, 62 are de-energized to perform their accident mitigation function and 22 are energized. The licensee has performed a justification for continued
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4 6 operatio.n (JCO) evaluation for the 22 solenoid valves. The inspec-tors reviewed the JCO's and attended the Plant Operations Review Committee (PORC) meeting in which each JC0 was evaluated and approved by the PORC. The licensee initiated a program to change out the as found termina-tion on solenoid valves pertaining to the auxiliary feed water valves and the RCS sample valves. These 50V's are accessible and could be worked separately under administrative _ Limiting conditions for operations (LCO's). The old terminations / splices were pigtail type connections. The two leads were bolted together to form a solid connection. They were then wrapped tightly with insulating tape (okonite T-95) and in most-cases were covered-with T-35 tape for jacket. The insulating tape- ; wrap measured approximately 4/32 to 5/32 inch thick. The inspectors
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observed the performance of a portion of the work on Unit I acxiliary feed pump 50V's -located _ in Unit 1 main steam valve room. TheLold splices (terminations) were-replaced by inline splices using Raychem - splice kits which are environmentally qualified splices. The splices-are all located inside condulet. Each solenoid- valve was re-worked under separate maintenance work request (KdR) which included work sequence __under, separate; but attached referenced instructions. The-work sequence contained step-by step instructions with sign off-verification of appropriate steps. The inspection was done using FNO-0-ETP-4250. Each splice inspection is documented which. includes completed splice physical dimensions. Of the 22 energized solenoids: 11.are in the auxiliary feed' water system and have been replaced; 6 solenoids- associated with the maiw steam isolation valves; I with the component cooling water.the mal barrier; and 4 solenoids associated with the pressurizer . power operated relief valves. _ These will _be replaced during the next unit outage. The solenoids that are de-energized care in-a fail safe condition and will be_ replaced on a subsequent 1 outage. This' item-is unresolved pending completion of the_ solenoid splices, and further review by the NRC-(348-364/87-17-01),
- b. Re-termination of electrical-leads to motor operated valves (MOV's).
The licensee identified 104 MOV's f on each unit which _ may require remfork with Raychen splices to assure environmental- qualificat;on. The licensee has developed a JC0 evaluation. The inspectors have
- reviewed the JCO.
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- 7 The licensee initiated inspection and re-work on MOV's which are required to reposition at approximately 5 minutes or longer after an event. There were 3 MOV's per Unit (A and B hydroger, dilution valves and containment vent path valve to R-11. and R-12) which were inspected and repaired. Since these POV's have been re-worked the licensee has continued to re work splices to approximately 15 MOV's.
The MOV's which cannot be re-worked during power operation will be completed during the next refueling outage. This item is unresolved pending completion of the MOV splices and further review by the NRC (348-364/87-17-02).
- c. Re-termination of electrical: power leads to fan motors inside Unit 1 and Unit 2 containment buildings.
The licensee determined that the electrical connections to the following fan motors, located inside the reactor containment building, may not meet environmental qualifications. (1) Reactor cavity hydrogen diluation fans (2 per Unit) (2) Hydrogen mixing fans (4 per Unit). (3) Containment cooling fans (4 per Unit) Between August 9-19, 1987 the licensee inspected the motor lead terminations and replaced with environmentally qualified Raychem splices. This item is unresolved pending further review by the NRC (348-364/ 87-17-03). i l { l
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.w-July 30, 1987 Docket No. 50-348
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U. S. Nuclear Regulatory Comtnission ATTH: Document Control Desk Washington, D.C. 20555 l Uear Sir: Joseph M. Farley Nucleai Plant - Unit 1 Licensee Event Report No. LER 87-012-00 Joseph M. f arley Nuclear Plant, Unit 1, Licensee Event Report Ho. LER 87-012-U0 is being subinitted in accordance with 10CFRbO.73.
'If you have any questions, please advise.
Respectfully s .44ted, f ,' / l b gh , Q R . P. McDonal d RPM / JAR: dst-D-LER Enclosure cc: IE, Region !!
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Ano.aC,. -,,,. ~ .. ........-.,........-......n..:.o.. In rev iew eig the 1.n v i ronment a l Qu a l i t i t at i on (LQ) tindings et anotner nuclear plant, pronteus wit u the cont i 9uret t wi of LQ solenoid vdive splices and terminations wore noted. t.onsequently d review of enijineering spec 111cattons i and installation pratt9 es for tue l orlef kuc. ear Pldnt was initiated. On
//21/6/ tt mis t.onc luded Lndt such problems might also exist ir, the tarley liuc lear Pl an' . In ou evaluat ian of potential inuperaDility involving the LQ solenoids, it w. tiet ermi nert that no system covered by lechnicdl $pecificotions would be remiered inoperable os a result ut ddverte et t ects by design Da515 dct,idents un the subjett solenutd Vdive5 A Justitication for Continued Uperettun (JCO) was develoued, reviewed by the Plant Operdtions i.teview Committee, and approved on //22/dl.
Inis event was caused f)j the instellation of splices dnd terminettons utilizing methods not evdluated .iy design for environmental qualitication. A JLO wa3 apprnved for the twisting solenoid splice nr termination cont 1 9urntion. A sjstemat ic plon w.is .ieveloped to mocity solenoiin valve splites and ters10ations occthstDie dur1ntj pl ant oper(.* i uti . All atner Ly solenoid valve Spi tte; and terminatiotis will be emnlit ied 'ds plant conditions permit, farley Nuclear Plait is continuing its review of kQ tiles, procedures, records, and other installations reldted to Ly splices and terminations. A tollow-up-report w:li De suonitted upon con,iletion of this review.
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Josepn M. Farley - Unit 1 o js Lo j o j o l3 l 4 l8 8l7 - 011l2 - 0j0 0l 2 or 0 l3 im n . uc % ,,on Plant identification: Westingnouse - Pressurized Water Reactor Energy industry identification system codes are identif ied in tne text as I.XX]. Summary of Event in revier g (ne Environmental Qualification (EQ) findings at anotner nuclear plant, problems with the configuration of Ey solenoid valve splices and terminations were noted. Consequently a review of engineering specifications and Installation practices for tne Farley Nuclear Plant was initiated. On
//21/07 it was concluded that sucn problems might also exist in the Farley Nuclear Plant. In an evaluation of potential inoperability involving tne EQ solenoids, it was determined that no system covered by Tecnnical Specifications would be rendered inoperable as a result of adverse effects on tne desion-basis dCcidents on the subject solenoid valves. A Justification for Continued dperation (JCd) was developed, reviewed by tne Plant Operations Review Committee, and approved on //22/87 De,5,cription of Event Due to industry experience. a program was developed at Farley Nuclear Plant to evaluate concer'is about field installation of environmentally quali!;cd splices and terminations, uuring this evaluation, it was determined tnat certain s splices in wiring to EQ solenoid valves mignt not meet all EQ requirements.
By //21/el, the requirements f or EQ splices and terminations -nad been estdbl1Sned dnd tield inspections were uegun. It was found snat splices or terminations in wiring to Ey solenoid valves mignt not meet all EQ requirements. Inus, the following action was taken:
- 1. Al1 potantially attetted solenoid valves were identif jed. It was-found that tnis included 84 solenoid v61ves in eacn unit.
- 2. Ine operability of eacn af tected system was determined. No system covered by Tecnnical Specifications would nave neen renderea 1.noperable as a result of potential adverse ef fects by design basis accidents on the sub,)ect solenoid valves.
- 3. A JC0 was developed. Solenoid valves accessible during power operation eitner nave been or will be modit ted on a priority basis. All other EQ solenoid valves will ne modified as plant conditions permit.
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LICENSEE EVENT REPGRT (LERI TEXT CONTINUATION
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Joseph M. Farley - Unit 1 o l5 lo j o j o ] 3l4 p 8 17 0 l1l2 - 0 l0 0l3 or 0 l3 m i<e - . w . - .e , . .,in, g cause of Event { This event was caused ny tne installation of splices and terminations utilizing methods not evoluated ny design f or envi ronmental qualif ication. It was determined tnat the configuration of terminations and splices had not been specif ically addressed in the EQ progroiti as submitted to the NRC, that existing design specif icotions may not have been adequate in certain aspects, and that certain aspects of tield installation inay not be in accordance with strict interpretation of existing design directives. Reportabilit1 nalysis A and Safety Assessment Inis report is being submitted voluntarily. Tnere was no effect on the healtn and saf ety of the public. Corrective Action
- 1. A JC0 was approved for the existing solen 1id splice and termination contiguretion. Based on plant conditions, all access 1 Die solenoid volves will he modified to an approved EQ splice and termination contiguration on a priority basis. All ottier solenoid valves will Le modi t e i as plant conditions permit.
- 2. Farley Nuclear Plant is continuing its review of EQ files, procedures, records, orid installations of EQ splices and terminations. ,
Additional _ligormation No iimilar LERs have been submitted by Farley Nuclear Plant. No components failed during this event. l
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yuNngham Axelrad 3/ Regions 1-V MEMORANDUM FOR: Victor Stello, Jr. Executive Director for Operations to FROM () DN'amuel J. Chilk, Secretary
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SUBJECT:
STAFF REQUIREMENTS - SECY-86-122, '
" POLICY FOR ENFORCEMENT OF ENVIRON!tENTAL QUALIFICATION REQUIREMENTS
- The Comission, with all Commissioners agreeing, has approved the attached Policy for Enforcement of Environmental Qualification-Requirements, as modified.
Both the attached policy paper and the enclosure should be distributed to the regions for implementation.
Attachment:
As stated cci Chairman Zech Commissioner Roberts Commissioner Asselstine Commissioner Bernthal OGC 0#U R::'d Oll. EDO Date - 9 '3 ' h f Staff Exh. 8
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Aprii 21. uss POLICY ISSUE ~ sm-es-u2 (NEGATIVE CONSENT) For: The Comissioners From: Victor Stello, Jr. Executive Director for Operations .
Subject:
POLICY FOR ENFORCEMENT OF ENVIRONMENTAL QUAllFICATION REQUIREMENTS
Purpose:
To obtain Commission approval of the staff's proposed criteria for enforcement of the environmental qualification requirements.
Background:
On June 18, 1985, the staff pro'vided the Comission a paper (SECY 85-220) on implementation of the environmental qualification (EQ)requirementswhichincludedthestaff's views on enforcement of the EQ rule and a proposed generic letter describing the staff's enforce:nent policy. The Comission, with the staff's assistance, modified the staff's proposal and directed that the staff issue Generic Letter (GL) 85-15. GL 85-15 advised licensees that if they elected to operate in noncompliance with the EQ rule after the November 30, 1985 deadline without an approved extension, they could face civil penalties et $5,000 per item per day. Gt, 85-15 provided that the . fines could be made retroactive to November 30. 1985 'for each day a licensee clearly knew, or should have kncro, that equipment qualification was incoepicte." On February 18. 1986, in a memorandum from Chaiman Palladino to the Acting Executive Director for Operations, the Comission directed that the staff provide the enforcement criteria it
,j,4 3roposes to implement whenever it is determinad that 4 licensee clanely (new orfshould have known that its equipment was not qualified or for other reasons is found in noncompitance with 10.CFR 50.49.
The Comission directed that the staff answer the following questions in developing the criteria:
- 1. Should a licensee shut down if he is found to be in noncompliance?
- 2. Should a licensee be afforded the option to operate in noncompliance under the daily fine structure?
3 3. Mustalicenseehave(NRC)reviewedandapprovedJCO's in order to continue operation?
"entacts:
Jane Axelrad, IE x24909 I
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Gary Zech, IE 's x29663
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- 4. When should the-defly fine provision of the generic letter, either through a " statute of limitation" or other meclianism expire?
5 . -- What fomula will the staff apply to mitigations relating to the $5000/ day fine? EQ deficiencies have been identified at several plants which operated af ter November 30.-1985.- In addressing these cases. the staff has developed enforcement. criteria which answer the Comission's questions. The proposed criteria and an explanaHon of how the criteria _will te applied is provided in Enclosure-1. The answers to the specific questions posed by the Comission are provided below. Discussion: 1. Should a licensee shut down if he -is found to be in noncompliance? In cases in which licensees discover EQ deftetencies after the deadline, questions arise regarding whether the deficiencies- , in the equipment render systems covered by technical i specifications (TS)-inoperable and whether shutdown is required. The position taken in Generic Letter 85-15. and that taken by the staff. is that whether shutdown is required depends Upon whether the system of which the equipment-is a part is covered by the.T5 and. if so, whether-the-system should be considered inoperable under accident conditions because of the identified EQ deficiencies. For equipment in systems covered.by TS this is a very complex question. In the case of.certain valve operators in which deficiencies in qualification-of wiring have been discovered, several utilities did evaluatter.s which determined that the plants could be operated safely while qualification of the cperators was being established, that the lack =of qualificatirn did not render the systems to which the valves were attached. inoperable, and that shutdown of the plants was not, therefore.- required by the -TS. For some of the valve ' operators.11censees concluded that.the operators were not required to be quellfied because they were-not required to mitigate the consequences of an accident or they were in a slld environment, tne utility argued that the master list of equipment required to be qualified had been developed in a conservative manner without examining each piece of equipment included on it.- Rather, a-systems approach was __ taken and certain piMet of equipment were included that need not have been qualiftsd.
s . The Comissioners . For operators that were required to be qualified, some licensees had detemined that the equipment would not become inoperable during an accident because the valves would fulflil- their function before being exposed to a harsh environment and failure I af ter exposure to the harsh environment would not cause the ) valves to change their position, mislead the reactor operators. or adversely affect other safety related equipment. On the basis of these evaluations, the licensees concluded . that imediate shutdown of the plants was not required. The alternative to this approach would have been to assume without analysis that because the qualification of the equipment had not been established, it was considered inoperable and to require the licensees to either repair the equipment during the time allotted in the action statements or shut down the plants, The staff did not require this approach. In acecrdance with the above-described principles, the staff has developed the following general guidance for situations in which the licensee does not have adequate basis to establish qualification of its equipment, e.g. missing documentation or oniss*on of required maintenance: The licensee is expected to make a detemination of operability. The licensee may attempt 1to shake a finding of operability using analysis and partial test-data to provide reasonable assurance that the equipment will perform its. safety function when called upon to mitigate the accidents-for which it is needed. In this connection it must also be shown to detemine operability that subsequent failure of the equipment under accident conditions , will not result in significant degradation:of any safety function or provide misleading information to the operator. If the 11canste is unable to demonstrate operabillty:-
- a. For inoperable equipment included in-systems covered by plant technical specifications, the licensee shall follow-the appropriate action statement. This could require the plant to shut down within-a ilmited period of time (or remainshutdown).
- b. For inoperable equipment not covered by the plant technics 1_ specifications, the licensee may continue reactor coeration:
(1) If the safety function can-be accomplished by other designated equipment that is qualified, or l
- The Comissioners -42 (2) If limited administrative controls can be used to ensure-the safety function is perfomed.
The licensee should also evaluate whether the findings are reportable under.50.72, 50.73, Part 21. TS, or any other pertinent reporting requirements, particularly if equipment is detemined to be inoperable.
- 2. Should a licens'ee be afforded the option to operate in noncompliance 'ander the daily fine structure?
The staff believes that such licensees should be subject to-fines retroactive to November 30,-1985 if they " clearly knew or t.b.M should have known" that their equipment was not_ cualified by-that deadline. The daily penalty was established as an incentive
' to Itcensees to meet the-November 30 deadline by taking actions
'-! to avoid noncompliance. Penaittes for licensees which failed to take appropriate actions should be levied under the Generic Letter as indicated to ensure that incentives such as this are taken seriously by licensees in the future, andWhu-ses. However, if a licensee has made a ** edit detemination < m im eu.m nW that it is safe to allow continued operation while the ca.u n n s, cualification of-the equipment is being established or the hdda h. equipment is replaced.Othen the licensee should be allowed to i
<tc+. t ka. continue to operate without additional penalty. Once a licensee !
-n c.w uant e , a has erred by failing to establish qualification by November 30, the staff sees no point in continuing _ to assess a penalty once an operability decision has been made. Continuing to assess daily civil penalties until the violation-is corrected would W ene,a f,'. erlbe provide strong incentives for shutdown even though the licensee s m ede r e d .a umus,a and the staff detemine that continued operation is not unsafe.
Nui."t$[O/.iIf the 'icensee's detemination of safety is later found to be-
% 6 4t, .f #As deficient, shutdown may be required and the licensee may also Aw,,,,, fi,, 3 be subject to datly civil penalties.
We =4. - 30, nas,
- 3. Must a licensee have reviewed and approved JCOs in order to continue operation?
Although NRC review and approval of the safety of continued: operation is not necessary when equipment is found to be-in - mgt noncompliance with 50.49, license'esvr: trpen:e te r epe: dC4s-to establish that eqlWnt in question would not affect-safe continued operation. M central guidance discussed in response to question 1 abod W 1d be followed when equipment for which qualification cOu be established is identified. However, the staff expects that Itcensees will conduct an
. . evaluation of any deficiencies identified and, if appropriate,
'adv4ns justfic:Tyns will follow any licable' technical specification action
.e c.ota.ed eten h' 4 statement. Suc eva untionsimust be documented by the licensee and, if applicable, reported to the NRC under the provisions of the existing regulatory requirements (Part 21,50.72,50.73,etc.).
These evaluations will be included in the scope of the NRC inspections at operating plants.
4 The Comissioners 5-
- 4. When should the daily fine provision of the generic letter.
either throvoh a "stetute of Ilmitations' or other mechanisrt expire? 4 AsI d by the question, the concept of a 15000 per item per day finie can be read to make less overall safety sense as time goes on. The last "first round" inspection by special ' teams to review licensees' compliance with to CFR 50.49 is not expected to be completed until the end of FY 1987 at the earliest. By this approach, those licensees inspected later could be . subject to much higher penalties than those which are inspecte(,y, ;f,,,'# - eerlier because tne period over which the fine would be4
- aa. u"v k u m L6 " - i retroactive is much larger. 2.ri otAr h a amf >aPa.a e.t l 1 t a aj , ell h a t wet
- t. k s. o n.aw, a m e s.m. & es...o On the other hsnd, having an " expiration date* for the-provision * *J *a L 5"*
removes the ' incentive" to ensure (Q questions are identified " ' " *"( - and resolved. Accordin ly "'d N S(" - date' it mind for the ekvil.while the staff has no ' expiration penalty of $5000 per item per day. "' ' U the staff will adjust the fines using the mitigation factors and other pertinent information described in r sponse to question-""U " " ' #*
- 5 below t ensure that the fines levied will be comensurate e l lb Irir.rt with the safety significance of the violations.
n eid 4
- 5. What formula will the staff apply to mitigations relating in.senh to the $5000/ day fine?
Generic Letter 8515 describes three factors which the staff will consider in determining whether mitigation of the penalty is appropriate:
- 1. Did the licensee identify and r omptly report the noncompliance with 10 CTt 50.40 D 2. Did the licensee apply best efforts to complete environmental qualificat'ar within the deadlinet
- 3. Has.the licensee proposee actions which can be expected to result in fM 1 compliance within a reasonable time?'
The factorsstaff nor canhas such not developed a fr.rmu14 be developed. any precise Rather, the staffforada to app S will apply these factors in a partic$ar. case and weigh them Q , ,,, and'any other relevant infonnstic,n.such as the signifLeance of 4d6 tha deficiencies identifiati, the' opportunities available to o t.5 a itir.itfy and correct them, the time taken by the licenset to rue a determination.-lhe tus11ty of the svenortinn annivtiti and '.he length of timaLbstora t" "specuen-wa: -- et:L N..-
' I These factors are interrelated and must be balanced to determine M thyppreyr.jetesanction. The steff believes, as described in su.ndwdl Ee encTeleGITilance, thau minimum penalty of $50,000 should ta.4 i u s.a c.u.6 be proposed for any licenses that clearly knew crathould have : a..ely . - known-its equipment was not. qualified on November ~30,1985. If the penalty is over $300.000, under the Enforcemtit Policy, consvitation with the Comission is required.
i The Comissioners 6 Recorrendatten: Unless the Comission directs othervite, this enforcement guidance will be distributed to the Regions for implementation
- within ten days of the date of this paper and by appropriate generic comunications to the Itcensees.
N
^W
'110.-[.
Executive Director for Operations
Enclosure:
Proposed Enforcement criteria SECY !!OTE t In the absence of instructions to the contrary, SECY vill notify the staff on Tuesday, May 6, 1986 that the Commission, by negative consent, assents to the action proposed in this paper. DISTRIBUTIO!!: Com:nis sioners OGC OPE ' 01 OCA OIA OPA PIGIOllAL OrrICES EDO ELD ACRS ASLDP ASIAP SECY
;,i -
Enclosure 1 ENFORCEMENT CRITERIA FOR EQ ENTORCEMENT Application of the ' Clearly knew, or should have known" test The staf f believes it is unlikely that licensees will be identified that
' clearly knew" they had equipment for which qualificatien cannot be established.
The staff believes from discussions with licensees that all lictnsees who were aware before hovember 30 that they had equi:rnent for which qualification could not be established elected to shut down ratier than operate in noncompliance under the dsily penalty arovision. Thus, the issue in most cases vill be for arb.. ~ the staff to detennine wiether the licensee %hould have known" that its equipment was not quallfled. ft case to r.ake the determination.,ie Thestaff will examine factors the staff the will circumstances exsmine include: in each
- 1. Did the licensee have vendor supplied ' documentation that demonstrated that the equipment was qualified?
- 2. Did the Itcensee perform adequate receiving and/or field verification inspection ti determine that the :enfiguration of the installed equipment retched the configuration of the equipment that was qualified by the vendor?
- 3. Did the Itcensee have prior notice from any sou.4e that equipment qualification def tetencies might exist?
- 4. Did some licensees identify similar problems and correct them before the deadline?
To illustrate how these factors would be a pplied in specif t: cases, the staf f will use as an example in the discussion witch follows def tetencies in the qualification of the internal wiring of certain valve oeerators recently identified at several plants. Yendor EQ test reports provided to licensees were ambiguous regarding whether the internal wiring of the operators was qualifted by the reports. It has now been detennined that vendor EQ test reports did not include qualification of the interna) wiring of the operators and that the wiring used in the test operators could be different than the wiring installed in production units. Subsequent wiring modifications by the valve r.anufacturer or by the installer have introduced additional wiring which was not covered by the operator qualification reports. Physical inspection has shown instances of unidentified or not qualified wiring installed in several valve operators. These operators are used on a wide variety of valves at the plants and in many cases were used on valves which were part of systems covered by technical specifications (TS) such as containment isolation valves. The wiring in the 4m{_o3eratort should have been qualified by November .10.1985. Thus. any plants at its4 witch suchideficiencies are identified after the deadline and which operated in noncompliance are subject to a possible penalty of 15.0 per item per day if such licensees clearly knew cr a thould have known of th eficiencies. In some planis, this could amount to a substantial penalty. . ncest-cf-$h00(h00Cr.
* *I* *'N - (,e u%'d .(ut G e d r.s%g o r anal,.gsi s le r e guir e.d +.
estsI,lisi, gulif(ca fh
2-With regard to the first two factors, reliance on vendor suppkied infomation on testing of equipment and performance of receiving and/or field verification inspections, the licensees took the position that the EQ test reports provided by the vendor covered the wiring and did not perform adequate receiving or fleu verification inspections to positively identify the internal wiring. We and the licensees now know that the vendor test reports did not cover the wiring in the operators. In addressing qualification by test, paragraph (f) of 10 CFR 50.49 requires that each item of electrical equipment important to safety must be qualified by testing an identical item or testing a similar item with supporting analysis that the equipment to be qualified is acceptable. It may ncrt be reasonable to rely entirely on vendor supplied information in establishing similarity since changes to complex equipment are likely to occur during the manufacturing process and/or installation. A comprehensive receiving and/or field verification inspection of the equipment by the licensees should be conducted to identify significant discrepancies between the as-installed vs. qualified configurations. With regard to the third factor, prior notice of similar problems, the results of one field verification inspection of equipment prompted IE to issue an Inforention Notice in 1983 to alert Itcensees to several deficiercles affecting equiptent qualification. This notice discussed a construction deficiency report related to inspection of valve operators at a plant under construction. Among several specific qualification related concerns, this Notice stated that 'No identification was evident on certain materials internal to the valve c>trators (e.g., wiring, insulation, etc.)" and stated that "It is not inown whether these types are qualified for the service conditions.gresently This Information Netice aln highlighted the fact that 'Informatter. obtained from purchase order files and qualification flies coes not agree with the installed components.' Based on the above, the staff concluded this document provided prior notice of the potential problems with certain valve operatort. Given this inforntion, it was unreasonable for Itcensees to rely entirely on the vender reports without 2 doing additional work to ensure that the wiring was qualified. With regard to the fourth factor, some licenstes did identify and correct tnis a problem before the November 30,1985 deaditne. The unqualified wiring was identified by these licenstes as a result of walkdown vertitcation of the installed equipment or comprehensive review of qualification files. Af ter consideration of all of these factors, the staf f has concluded thatj_,f,g,,, the case of the 1.imitorque wiring, licensees %hould have known" that the vendor documentation was not adequate to support, qualification. Ti m period to be Considered for Daily Civil Penalty Once the staf f concludes that the ' clearly knew or should have known' test is applicable, the staff rust detennine the appropr!ste phriod over which to assess a d' ally civil penilty. The staff has concbded that the appropriate period is from November 30,1985 to the time the licensee completes its evaluation and schedules carrective action. This approach should encourage timely identification and evaluations by licensees of the qus11fication of the equipment. A Itcenset should not be penalised for each day after the problem
. 3 is identified and appropriate corrective action is scheduled that it elects to operate until the problem is fixed assuming a reasonable determination was made that it was safe to allow continued operation. Imposing daily civil penalties I until the violation is corrected would provide strong incentives for shutdown even though the licenset had determined that continued operation for some reasonable period of time is not unst.fe. However, if the licensee's determination f*6"(
that it was safe to operate is later found to be in error, shut down ray be required and the licensee may be subject to daily civil penalties.0 51milarly. @ since the reasonableness of the schedule for corrective action is a factor if the licensee tobeconsideredformitigationofthedailycivilpenaltylbeconsidered. fails to meet its schedule, additional civil penalties wil In the case of the valve operators described above, in one hypothetical situation, suppose that a Resident inspector notified one Itcenset two weeks after the deadline that th6 qualification of the valve operators was suspect. That Ilcensee evaluated the situation and concluded that the qualification of the wiring Could not ht verified. The licensee performed a final evaluation j two weeks later justifying continued operation with the unqualified equipment ; and planned to replace the equipment at the next scheduled refueling outage in i two. months. The staff would conclude that this licensee would be subject to a daily civil penalty of $5,000/ item / day for 28 days. Application of the Mitigation Factors Once it has been detemined that a licensee may be subject to a daily civil penalty under this test, Generic Letter 85-15 specifies that the staff should apply certain mitigation factors to determine the amount of the proposed penalty. The factors specified in the letter were:
- 1. Did the licensae identif;r and promptly report the noncompliance with
;0 Cic 50.497
- 2. *;9 tre Itcensee apply best efforts to complete environmental qualification within the deadline?
- 3. Has the Itcenset proposed actions which can be expected to result in full comp 11 nce within a reasonable time? Lhe d d m a u.d l
These factors are self explanatory. In addition, the staff would consider e.m h a the circumstances of each particular case includin the significance of the % % .c t. t l deficiencies identified, the opportunities availab e to identify and correct da h b them, the time taken by the licensee to make a dettmination, the cuality of the supporting anilysis, and the length of tie 4%we e:wenuwa. <
*nducted, The following discussion illustrates how these mitigation factors <
would be applied in the hypothetical case of a licensee which identified the valve operator problem. We assure that the licensee identified the potential problem with qualification of the internal wiring of valve operators af ter conversations with the NRC Resident inspector. We assume that it irmulately initiated a timely investigation, determined that qualification of its valve operators was not fully supported due to problems with the internal wiring, and notified the
, , , - - ------e -- - . --- -, v,-.p-,- y + w w i-,emy-- 3g
4 ! F". J the determination via telephone and continued to evaluate the problem. ) Nnin wo weeks of becoming aware of the problem, the licensee submitted a 10 CFR Part 21 report to the NRC. Induded in this submittal was the licensee's justification for continued opernlon of the plant and a plan for correctivie action. Further we assume that the Itcensee actively Worked to af.hiove its.10 CFR 50.49 deadline of the second refueltog cutage af ter March 31,1982 and was able to meet it except for some items of equipment for which justifications for continued operation (JCOs) had been approveo. Later, NRC was notified by telephone that all work on equipment schedulted for replac: ment and/or relocation and covered by the previously approved JCOs had been accomplished. 1henfore, all equi ment 01 thin the scope of 10 CFR 50.4't was believed to be qualified well before tie November 30, 1985 desd11ne. Finally, we assume that this Itcensta's 10 CFR part 21 report submitted to the NRC included a schedule for corrective actions to establish qualification of the wiring of all valve operators within the scope of 10 CFR 50.49 and that I 7"",A this schedule called for the replacement of e'xisting dring with qualified ciring on all affected operators within two months. The staff has concluded that this 1 M nses would_be entitled to corolete - mitigation under these factors. HoweverP;'; 'ittn:: x:: " vt0!stte= ef "::~ the-wh := 5embe- 30 ed :: : 4 M 1 p;nattj ;h;uld b; i p e;d in :ny ;yeet. .'c:: , Thus, the staff has concluded that the daily ; civil penalty should be adjusted in accordance with the factors but the civil penalty levied should not be lower than $50,000. the base civil penalty for en ordinary severity Level !!! violation.
.) in any case in whictahe Itcensee ' clearly knew or should have known" thet-He- '*:~.
etv4perd ett act tJt!"!ed; e.t uted. hd.n. Dt unah e a n dt*J tin e. . 4 Other Enforcement Recardino Violations of t0 Requirements identified at plants Operating Af ter hovember 30 - If violations of the EQ rule identified during firs't round M nspectt6ns i at plants operating after November 30,1965 apparently existed before the deadline, then the " clearly knew or should have known" test should be applied. If the licensee meets the test, enforcement should be taken as described above. If the Itcenses does not meet this test, no enforcement action should be taken. If the licensee could not have reasonably been expected to discover the problem before the November 30 desditne, presumably the noncomp114nce could not have been avoided and enforcement action to deter future noncompliance wov1d serve no purpose. ,s If the violations of the EQ rule identified after November 30, 1985 do not relate back to action or lack of action before the deadline e.g., a modification was made in January 1986 that created the violation, or are, identified after first round inspections are completed, enforcement should be taken under the g current Enforcement Policy. The present policy states as an example of li first round inspections are special team inspectioni to review itcenstes' compliance with 10 CFR 50.49.
5-Severity Level !!!: *2. A system designed to prevent or mitigate ~ a serious safety event not being able to perform its intended function under certain conditions (e.g., safety system not operable unless offsite power is available; r.aterials or components not environmentally qualified)." Thus, no changes to the Enforcement Policy are necessary to t (e into account EQ violations. Consistent with the interpretations of the Enforcement Policy in other areas, less significant violations that indicate a programatic breakdown can also be grouped and cattgortred as Severity Level !!! violations. For Itcensees that were not in compliance with the rule be, o e the November 30, 1985 deadline and did not submit timely requests for tattM ki, but which did not operate in noncompliance af ter the deadline, consistent with the Comission's - (Memorandum from $. J. Chilk to W. J. direction in response Dircks August to SECY 27,1985) 85 220.ll the staff wi exercise enforcement discretion af ter considering whether adequate JCO's were provided and whether an extension would have been granted if timely filed. 4 4
- m. .
l INSERTS FOR SECY 86-122 ) Insert A ,
$1nce such penalties are likely to quickly become abnormally high.
particularly as the length of time between the November 30 deadline and the date of inspection increases, the staff has determined that some cap on the possible amount of the civil penalty should be imposed. The staff has determined that this is appropriate especially for those cases in eleerly which the [hould have known" test is applied as opposed to cases in which the licensee " clearly knew' that they were not in compliance. The staff tw item has selected a cap of $$00,0004 cr approximately the amount that would be imposed for one item that was deficient for 100 days after the deadline. The mitigation factors would then be applied to mitigate from $500,000 per lim down if appropriate. !! th: vhhth; ;;;th;;; hr :n:t:r.th??y hr;;r een ;00 dej;. Oi; .ewid b; ;;neid;r;d in d;temkin; th; ;pr:;rht: citi;;;ien. Similarly, since the reasonableness of the schedule for corrective action is a factor to be . . . Insert B
. . . to be fair and equitable to those licensees who either took appropriate actions prior to November 30 or shutdown on November 30 in order to be in~compilance, some civil penalty should be, imposed.
Insertj
. . . sf gnificant deficiencies remained at the close of the inspection for which further testing or analysis was required to estabitsh qualification and which . . .
I 4
b# Nh'~d W .% f - Of W Sl/ 2f L
/ ...s%, UNITED STATES gpggg,9
[ e NUCLE AR REGULATORY COMMISS totst100
- r. I wAsmotos, o, c. rosas USNRC SEP 2 2 985 I., * " * * / 1 92 nm 13 F12:02 TO ALL LICENSEES AND HOLDERS OF AN APPLICATION FOR AN OPERATlHG LICENEE 6c. ,
... a -
Gentlemen: ,
SUBJECT:
INFORMATION RELATING TO COMPLI ANCE WITH 10 CFR 50.49, " ENVIRONMENTAL QUAL.!FICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANTS", (GENERIC LETTER 86-15) Generic Letters, Bulletins, and Infonnation Notices have been issued to provide guidance and clarify the intention of 10 CFR 50.49, " Environmental Qualification of Electric Equipment important to Safety for Nuclear Power Plants". Generic letter 85-15, issued August 6,1985, provided infonnation related to the deadlines for compliance with 10 CFR 50.49 and possible civil penalties should licensees operate in non compliance with the rule. The purpose of this letter is to provide additional guidelines on 9ppropriate licensee actions in situations where environmental qualification of equipment is suspect and on current NRC policy with regard to enforcement of 10 CFR 50.49. When a licensee discovers a potential deficiency in the environmental qualifi-cation of equipment (i.e., a licensee does not have an adequate basis to establish qualification), the licensee shall make a prompt determination of operability, shall take imediate steps to establish a plan with a reasonable schedule to correct the deficiency, and shall have written justification for continued operation. This justification does not require NRC review and approval. The licensee may be able to make a finding of operability using analysis and partial test data to provide reasonable assurance that the equipment will perform its safety function when called upon to mitigate the accidents for which it is needed, in this connection, it must also be shown that subsequent failure of the equipment under accident conditions will not result in significant degradation of any safety function or provide misleading information to the operator. If the licensee is unable to demonstrate operability: A. For inoperable equipment included in systems covered by plant technical specifications, the licensee shall follow the appropriate action statements. This could require the plant to shut down within a limited period of time (or remain shut down). B. For inoperable equipment not covered by the plant technical specifications, the licensee may continue reactor operation:
- 1. If the safety function can be accomplished by other designated equipment that is qualified, or
- 2. If limited administrative controis can be used to ensure the safety function is performed.
-860923o296~
NUC:! AR N 091 A10Rf f.D'AtT;*,10N D~kil No sh No. -
, n. ..,m a.__gi_m_
_A (Iffaishlery u. sui V ieturinto .,////'/a , Ar e m.t _ - _ trencio $Ag7 a
.m ~ _
,o,ato C:n g Of 9'r 00ttractof () Alt fMb #
Othef _
. Witness l i' -3 Re;0fter
,/ a l
4 ) l l
2-1he licensee should also evaluate whether the findings are reportable under 50.72, 50.73, Part 21, the Technical Specifications or any other pertinent reporting requirements, particularly if equipment is determined to be inoperable. Enclosed is a copy of enforcement guidance related to Generic t.etter 85-15. This letter does not require any response and therefore does not need approval of the Office of Management and Budget. Coment.s on burden and duplication may be directed to the Office of Management and Budget Reports Management Room 3208, New Executive Office Building, Washington, D.C. 20503. Should you have any questions, the staff contacts are Gary Holahan for technical questions and Jane Axeirad for enforcement questions. Mr. Holahan can be reached on (301)492-4410 andMs.Axelradcanbereachedon(301)492-4909. Sincerely, Harold R. Denton, ctot Office of Nuclear Reactor Regulation
Enclosure:
As stated i m __u_------,- - - - - - - _ . ~ - - . - - - . - - - - - - - - -
ENGl.05URE ENFORCEMENT CRITERIA FOR EQ ENFORCEMENT Application of the ' Clearly knew. or should have known" test The staff believes it is un1thely that Itcensees will be-identified that
" clearly knew" they had bquipment for which qualification cannot be estabitshed.
The staff believes from discussions with licensees that all licensees who were-aware before November 30 that they had equi unent for which qualification could not be established elected to shut down ratser than operate in noncompliance under the daily penalty provision. Thus, the issue in most cases will be for the staff to detemine whether the Itcensee ' clearly should have known" that its equipment was not qualif ted. The staff will examine the circumstances in each case to make the setemination. The-factors the staff will examine include: -
- 1. Did the licenses have vendor supplied documentation that demonstrated that the equipment was quellfied?
- 2. Did the licensee perfom adequate receiving and/or field vertf tcation inspection to detemine that the configuration of the installed equipment matched the configuration of the equipment that was qualified by the vendor? ,
- 3. Old the licensee have prior notice from any source that-equipment qualification deficiencies might exist?
- 4. Did some licensees identify similar~ problems and correct them.before the deadline?
To illustrate how these factors would be applied in specific cases, the staff will use as an example in the discussion which follows del'iciencies in the qualification of the internal wiring of certain valve operators recently identified at several plants. Vendor EQ test reports-provided to licensees were ambiguous regarding whether the internal wiring of the operators was ; qualifled by the reports. It has now been determined that vendor EQ test reports did not include quellfication of the internal wiring of the operators and that the wiring used in the test operators could be different than the wiring installed in production units. Subsaquent wiring modifications by the valve manufacturer or by the installer have introduced additional wiring which vs not covered by the operator qualificatica reports. physical inspection-has shown instances of unidentified or not gralified wiring installed in several valve operators. These operators are used on a wide variety oi valves at-the plants and in many cases were used on valves which were part cf lystems covered by technical specifications (TS) such as containment isolation valves.: The wiring-in the operators should have been qualified by November 30, 1985. Thus, plants at which such significant deficiencies are identified after the deadline for-which further testing or analysis is re utred to establish qualification and which operated in noncompliance are sub act to a possible penalty of $5.000 per ites per day if such licensees clos ly knew or clearly should have known of the deficiencies. In some plants, this could amount to a substantial penalty.
4 2 With regard to the first two factors, reliance on vendor supplied information on testing of equipment and earfo mance of receiving and/or field vertf tcation inspections, the Itcensees took the position that the EQ test reports provided by the, vendor covered the w1 ring and dId not perfom adequate receiying or field verification inspections to positively identify the internal wiring. We and the Ilcensees now know that the vendor test reports did not cover the wiring in the operators. In addressing qualtffcation by test, paragraph (f) of 10 CFA 50.49 requires that each item of electrical equipment important to safety must be qualified by testing an identical item or testing a sieller item with supporting analysis that the equipment to be qualifitd Is acceptable. It may not be reasonable to rely entirely on vendor supplied information in establishing similarity since changes to complex equipment are Itkely to occur during the manufacturing process and/or installation. A comprehensive receiving and/or field vertf tcation inspection of the equipment by the Itcensees should be conducted to identify significant discrepancies between the as-installed vs. queltffed configurations. . Wtth regard to the third factor, prior notice of similar problems, the results of one field vertf tcation inspection of equipment prompted IE to issue an Information Notice in 1983 to alert licensees to several deficiencies affecting equipment qualification. This Notice discussed a construction deficienc related to inspection of valve operators at a plant under construction. yAmong report several specific this internal Notice stated that "No o>erators identification was qualification evident on certain related concerns, materials to the valve (e.g., wiring, insulation, etc. " and stated that "It is not Known whether these types are qualif te)d for the service conditions.gresently . This Information Notice also highlighted the fact that "Information obtained from purchase order flies and qualification files does not agree with the installed components." 8ased on the above, the staff concluded this document provided prior notice of the potential problems with certain valve operators. Given this information, it was unreasonable for licensees to rely entirely on the vendor reports without doing additional work to ensure that the wiring was qualified. With regard to the fourth factor, some licensus did identify and correct this problem before the November 30, 1985 deadline. The unqualtfled wiring was identified by these licensees as a result of walkdown verification of the , installed equipment or comprehensive review of que11fication files. Af the staff has concluded known" that that inthe vendor theter case consideration of the wiring, of all of these Itcensees " clearly factors,hould s have documentation was not adequate to support qualification. Time Period to be Considered for Daily Civil Penalty - Once the staff concludes that the " clearly knew or should have known" test is applicable, the staff must determine the appropriate period over which to assess a daily civil penalty. The staff has concluded tiat the appropriate period is from November 30, 1985 to the time the licensu completes its evaluation and schedules corrective action. This approach should encourage timely identification and evaluations by licensees of the qualification of the equipment. A licensee should not be penaltred for each day after the problem
+- . . . . . . ___._____m______._____ __ _
3 is identified and appropriate corrective action is scheduled that it elects to operate until the problem is fixed assuming a reasonable detemination was made that it was safe to allow continued operation. Imposing daily civil penalties until the violation is corrected would provide strong incentives for shutdown even though the Itcensee had detemined that continued operation for some reasonable period of time is not unsafe. However, if the licensee's detemination that it.was safe to operate is later found to be in error, shutdown may be required and the licensee may be subject to daily civil penalties. Since such penalties are Itkely to quickly become abnomally high, particularly as the length of time between the November 30 deadline and the date of inspection increases, the staff has detemined that some cap on the possible amount of the civil penalty should be impoted. The staff has detemined that this is appropriate especially for those cases in which the ' clearly should have known" test is applied as opposed to cases in which the licensee ' clearly knew" that they were not in compliance. The staff has selected a cap of $500,000 per item , or approximately the amount that would be imposed for one item that was deficient for 100 days after the deadline. The mitigation factors would then be applied to mitigate from $500,000 per item down if appropriate. Similarly, since the reasonableness of the schedule for corrective action is a factor to be considered for mitigation of the daily civil penalty, if the licenses fails to meet its schedule, additional civil penalties will be considered. In the case of the valve operators described above in one hypothetical situation,' suppose that a Resident Inspector notified one licensee two weeks after the deadline that the qualification of the valve. operators was suspect. That licensee evaluated the situation and concluded that the qualification of the wiring could not be verified. The licensee perfomed a final evaluation two weeks later justifying continued operation with the unqualified equipment and planned to replace the equipment at the next scheduled refueling outage in two months. The staff would conclude that this licensee would be subjeci to
~
a daily civil penalty of $5,000/ item / day for 28 days. Application of the Mitication factors Once it has been determined that a licensee may be subject to a daily civil penalty under this test, Generic Letter 85-15 specifies that the staff should apply certain mitigation factors to detennine the amount of the proposed penalty. The factors specified in the letter weret
- 1. Did the licensee identify and promptly report the noncompliance with 10 CFA 50.497
- 2. Did tha licensee apply best efforts to complete environmental qualification within the deadline?
- 3. Has the licensee proposed actions which can be expected to result in -
full compliance within a reasonable time? These factors are self explanatory. In addition, the staff would consider the circumstances of each particular case including the significance of the defielencies identified, the opportunities availab e to identify and correct ___m.-.__m._. - _. __ __-____
0 4 them, the time taken by the Itcenses to make a determination, the quality of the supporting analysis, and the length of time the deficiencies existed before identification. The following discussion illustrates how these mitigation factors would be applied in the hypothetical case of a Itcensee which identified the valve operator problem. We assume that the Itcensee identified the potential problem with qualification of the internal wiring of valve operators af ter conversations with the NRC Resident Inspector. We assume that it ingnediately initiated a timely investigation, detemined that qualification of its valve operators was not- # fully supported due to problems with the internal wiring, and notified the NRC of this determination via telephone and continued to evaluate the problem. Within two weeks of becoming aware of the problem, the licensee submitted a 10 CFR Part 21 report to the NRC. Included in this submittal was the licensee's-justification for continued operation of the plant and a pian for corrective action., Further we assume that the licenses actively worked to achieve its 10 CFR 50.49 deadline of the second refueling outage after March 31 meet it except for some items of equipment for which ju.-1982 and was stifications able to for continued operation (JC0s) had been approved.- Later, NRC was stified by telephone that all work on equipment scheduled for replacement anF- relocation and covered by the previously approved JCOs had been accomplit Ac. Therefore. all equi snent within the scope of 10 CFR 50.49 was believed to be qualified well before tie November 30, 1985 deadline. Finally, we assume that this Itcensee's 10 CFR Part 21 report submitted to the NRC included a schedule for corrective actions to establish quellfication of the wiring of all valve operators within the scope'of 10 CFR 50.49 and that this schedule called for the replacement of existin wiring on all affected operators within two months.g wiring with qualified . The staff has concluded that this licensee would be entitled to complete mitigation under these factors. However, to be fair and equitable to those licensees who either took appropriate actions prior to November 30 or shut down on November 30 in order to be in compliance, some civil penalty should be imposed. Thus, the staff has concluded that tie daily civil penalty should-be adjusted in accordance with the factors but the civil penalty levied should not be lower than 550,000, the base civil penalty for an ordinary Severity Level !!! violation, in any case in which significant deficiencies remained at the close of the inspection for which further testing or analysis was required to establish qualification snd which the licensee " clearly knew or should have known" existed before the November 30 deadline. Other Enforcemet,t Recordino Violations of to Recuirements Identified at plants Operettna After November 30 If violations of the EQ rule identified during first round b nspections i at plants operating after November 30,1985 apgarantlyexistedbeforethedeadline, then the " clearly knew or should have known test should be applied. If the y First-rouna Inspections are special team inspections to review Itcensees' compliance with 10 CFR 50.49. 1
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! Itcensee meets the test, enforcement should be taken as described above. If l the licensee does nL' meet this test, no enforcement action should be taken. ' If the Itcenses could not have reasonably been expected to discover the problem l before the November 30 deadline, presumably the noncompliance could not have ! been evolded and enforcement action to deter future noncompliance would serve no purpose. If the violations of the EQ rule identified after November 30, 1985 do not relate back to action or lack of action before the deadline; e.g., a modification was made in January 1986 that created the violation, or are identified after first-round inspections are completed, enforcement should be taken under the current Enforcement Policy. The present policy states as an example of Severity Level !!!! "2. A system designed to prevent or mitigate a serious safety event not being able to perform its intended function under certain conditions (e.g., safety system not operable unless offsite powsr is availablet materials or components the Enforcement Policy are notnecessary environmentally to take qualified)." into accountThus,iolations.no EQ v changes to Consistent with the interpretations of _the Enforcement Policy in other areas, less significant violations that indicate a profirannatic breakdown can also be grouped and. categorized as Severity Level !!! v<olations. For licensees that were not in compliance with the rule before the November 30, 1985 dead 1tne and cid not submit timely requests for extension, but which did not operate in noncomplianca af ter the deadline, consistent with the Consission's (Memorandum from 5. J. Chilk to W. J. I direction in response Dircks August to SECYstaff 27, 1985).the 85 220,ll wi exercise enforcement discretion af ter l considering whether adequate JCO's were provided and whether an extension would have been granted if timely filed. - e 0 0
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, 3-BI 60-MQ YwP ^/3/ve WESTINGHOUSE PROPRIETARY CLASS 3 ) i ot.ollt e i, Staff Exti. 31
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N f i : e ..+ lETAR7 w.i '{'{;,,. . QUALIFICATION TESTING COA MODEL B ELECTRIC HYDROGEN RECOMBINER J. F. Wilson
, 00.1344 July 1978 4
Work performed under Shop Order EJSP 917
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4 4 t TABLE OF CONTENTS Section Title Page 1 INTRODUCTION 1+1 2 CHANGES TO THE MODEL A RECOMBINER WHICH HAVE BEEN INCORPORATED IN THE MODEL B RECOMBINER 21 2 1. Changes Recognized as Desirable During Qualification Testing 21
- 22. Changes to Facilitate Installation 21
- 23. Changes to improve Manufacturing 23 3 QUALIFICATION TESTS 1 . . 31
- 31. Performance Tests , 31
- 32. Heatup Test 31
- 03. Air Flow Test 31 34 Aging Test - 100 Heatup and Cooldown Cycles 34
- 35. Seismic Test 3-4 3-6. Hydrogen Tests 36 Spray Tests 3 7. 36 4
SUMMARY
OF QUALIFICATION TESTS 41 41 IEEE 3441975 (Seismic Qualification) 41 9 003345
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t.!S7 OF ILLUSTRATIONS I I Figure Title Page 21 Hecter Compa6 son Test, Models A and 2 22 31 Temperswre Versus Power 32 32 Air Flow Test 33 33 Random Frequency Test 35 34 Sine Beat input for Testing 3-7 35 Acceleration Versus Frequency 3-8 16 Accderation Frequency 39 3-7 Test Equipment Orientr. tion 3 10 38 Seismic Test in Test Direction #1 3 11
. . . 39. Test Facility (Schematic) 3 13 .
A1' electric Hydrogen Recombiner A2 A2 Typical Hester, Electric Hydrogen Recornbiner A4 i)n 003346 V
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e ( i LIST OF 7 ABLES l l Table Title Page l I A1 Electric Hydrogen Recombiner Model 8' Typucal Parameters 43 4 B l l l i I 003347 vii
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( SECTION 1 INTRODUCTION The Model B recombiner is a technologically improved revision of the Model A recombiner (present model). The Model B recombiner uses the same principle of thermal recombination with flow induced by natural convection as the Model A. The flow arrangement through the Model B is the same as the Model A and in outward appearances, the two are very similar. The Model A recombiner was designed in 1971 and has been subjected to an extensive qualification test program as described in WCAP 7709L, Supplements 1 through 7. No changes which would affect the qualifications were permitted on the Model A recombiner. Suggested changes to improve the recombiner were accumulated from 1971 to 1976 and then incor-porated in a Model B recombiner. A test program has been performed to qualify the festures Of the Model B recombiner that have been incorporated as changes from the Model A. A . complete description of the Model B recombiner is given in appendix A. It should.be noted
. that the power supply and control panel are the same for Models A and B.
The Model A recombiner was approved by the Nuclear Regulatory Commission to be qualified in accorcance with IEEE 323 1974, subject to the conditions in the Staff evaluation. (John F. Stolz, USNRC to Thomas M. Anderson, Westinghouis, June 27 1978) i l { p l. l l, 00334S 11
i SECTION 2 CHANGES TO THE MODEL A RECOMBINER INCORPORATED IN THE MODEL B RECOMBINER The following changes have been made in the Model A design, They are grouped into three categories based on the reason for the changes. 2 1. CHANGES RECOGNIZED AS DESIRABLE DURING QUALIFICATION TESTING a Redesigned support structure, running the main vertical structural members the full height of the recombiner ratner than only to the top of the heater section. This stiffens the structure. s Fastened side panels to main structure by welding rather than bolting to stiffen the structure. e Four heaters banks with increased power capability are used,. rather than five banks. Tests on the Model A show that disconnecting the fifth bank (i.e., the top heater, which generates only 5 kw) does not affect the temperature distribution within the recombiner. This is shown in figure 21. e Redesigned flow channel so that there is more space between heater banks. This pro-motes mixing which results in a more uniform gas temperature and increases gas ve-locity slightly. I a Modified louver blade shape to increase stiffness. e The length to the power cables was reduced by rerouting cables; however, the same cabling as prt.viously qualified to IEEE 3831974 was used.
- 22. CHANGES TO FACILITATE INSTALLATION a
Reduced height of the recombiner to 98 inches. This reduced the installed head room required and made it possible to ship the units on a standard truck rather than a special truck. m Enclosed the thermocouple junction box and the power lead junction box within the recombiner so that they do not protrude from the recombiner. This leaves a smooth exterior surface on the recombiner and facilitates shipping without damage; it also reduces the area required for installation and improves the appearance of the recombiner. 003349 21
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- 23. Ct:ANGES TO IMPROVE MANUFACTURING e The base structure and electrical junction box of the Model A recombiner was made from carbon steel which was then painted., In practice, the painting of these compo.
nents caused a problem in selecting paint systems and colors to match vanous con-tainments it was decided that these components in the Model B should be made of stainless steel; this eliminates the time consuming process of selecting the proper paint colors and painting procedures for each application. e The heater frame on the Model A prototype was made from Incoloy 800 and the heater frame of the Model A production Mode, was inconel 600. Both units were qualified for hi 5h temperatures application, in 1971, it was decided to use inconel 600, since the manufacturing gmup felt it would be easier to fabricate (Both alloys have good high temperature, corrosion-resistant properties). Since 1971, the inconel structural members have become more difficult to obtain. (They are rolled only one time per year and now the production on some members has been discontinued.) These structural members have been eliminated in the heater frame of Model B and incoloy 800 has been substituted. This material was useci satisfactorily in the Model B fabrication and qualification testing. e The thermal insulation system has been redesigned to facilitate insulation installation and to remove air spaces that existed in the Model A reenmbiner. The result has
, been a more compact design which slightly reduces the site of the recombiner.
e.. 003351 23 _. _ _ _ . _ _ _ _ _ _ _ _ . _ m_ _._
f SECTION 3 OUALIFICATION TESTS The following tests were perintmed to requalify the electric hydrogen recombiner. All tests were performed on the first unit of the Mcdel B recombiner.
- 31. PERFORMANCE TESTS 3 2. Heatup Test The purpose of this test was to measure the power required to reach recombination te.Tipera-ture. For this test the recombiner was connected to a recombiner power supply and control panel. Power was then applied in increasing steps. A plot of recombiner temperature as measured in the hottest zone versus power is shown in figure 31. This shows that recom-bination temperature is reached at 49 kW, which leaves a 26 kW reserve of the 75 kW total.
( ' 3 3. Air Flow Test The purpose of this test was to measure the air flow through the recombiner to ascertain that the flow rate was equal to or greater than 100 scfm (14.7 psia, 70 0 F) For this test, the re-combiner was connected to a power suppiv and control panel. The recombiner was heated up to 12500F and the air flow measuring duct, shown in figure 3 2. was attached to the recom-biner. (This is the same equipment used on the Model A). The duct decreases the flow area and thus increases the air velocities to values which can be measured using standard air veloc-ity measuring devices. To compensate for the pressure loss imposed by this duct, a tell tale in-dicator was placed in the measuring duct adjacent to the recombiner inlet. This indicator is a lightweight vane (made of paper) which indicates differential pressure in that it will be pushed in the direction of the greater pressure, i.e., between the measuring duct and surrounding air. For testing, the exhaust of a fan was directed at the duct inlet so that no differential pressure existed across the measuring duct at the recombiner inlet, thereby cancelling the effect of the measuring duct pressure losses. Flow measurements weid made by traversir'3 the duct with a flowmeter. The flows measured were well in excess of the design value of 100 scfm. The flow was measured as 115 scfm at 12500F.
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- 34. Aging Test - 100 Heatup and Cooldown Cycles During the recombiner's 40-year design life it will be subjected to approximately 80 heatup and cooldown cycles to demonstrate its availability (approximately 2 cycles per year). These heatup and coaldown cycles result in trcnsient thermal stresses which are very difficult to analyze. A test program was conducted to demonstrate inat the recombiner structure would not be damaged by these thermal stresses. The test consisted of connecting the recombiner
' to a control panel and power supply and alternately heating the recombiner to 1250*F and then cooling to approximately ambient temperature. This cycle was repeated 100 times, After the cycle test was completed, the recombiner was examined for damage, such as gross warp.
age and cracks in the structure and welds, inspection showed there were no cracks in the structure or welds and that there was no panel warpage, 3 5. Soismic Test The purpose of this test was to demonstrate that the Model B recombiner will perform its intended function after five Operating Basis Earthquakes (OBE) and one Safe Shutdown Earthquake (SSE) in accordance with IEEE 344 1975. ( The seismic test was performed using biaxial motion and both random and si,ne beat input frequencies. The tests were conducted at the Westinghouse Advanced Energy Systems Divisions seismic test facility located at Large, Pennsylvania. The recombiner was mounted on the d'iver plate of the vibration table using the same mounting connections as recommended for installa-tion in a reactor containment. The test series consisted of a resonance frequency search, fol. Iowed by five OBE's using biaxial motion and random frequency input. Following this, four biaxial sine beat and four random motion tests were conducted at SSE level accelerations. The angle of motion of the table was set to produce vertical accelerations equal to the horizontal accelerations for the sine beat and random motion tests; four separate tests were run. First, the equipment was mounted 45 0 to the horizontal plane of motion, then rotated 900 for each of the next three test runs in accordance with paragraph 6.6.6 of IEEE 344-1975. The acceleration levels for the random frequency OBE and SSE tests are shown in figure 3 U. The input motion was made up of decaying sinusoids covering the frequency range of 1.25 to 35 Hz. Fol!owing the random frequency tests, each of which lasted 20 seconds, a series of four biaxial sine beat tests were performed at cach resonant frequency and at the following frequencies: 1.25,1.75, 2.5, 3.5, 5, 7, 9.5,13,18, 24.S and 33.5 Hz. A sine beat test consisted of five beats, each containing 10 cycles as shown in figure 3-4. The peak horizontal input accelerations are shown in figures 3 5 and 3-6. (These are input accelera-tion, not response spectra.) The equipment orientation on the drive plate for all testing is shown in figure 3 7. Accelerometers were located on the frame structure near the top and under the upper louvers. Figure 3-8 shows a photograph of the equipment in the drive table. 34
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For all tests, the recombiner was energized and at operating temperature before, during, and after each vibration test. Following the entire test series, the recombiner was inspected for damage. No disabling damage was found. (Some fine thermal insulation material was found on the floor of the recombiner and no other surfaces.) An air flow test was then conducted and results show no loss of air flow. - This test conforms to the requirements of IEEE 344-1975. 003357 3 6. Hydrogen Tests The purpose of this test series was to demonstrate the safe operation of the Model B recom-biner in an air hydrogen atmosphere and to measure the hydrogen removal rate. To perform this test, a soecial test facility as shown on figure 3 9 was constructed. This facility includes a pressure vessel to house the re.ombiner, hydrogen and air injection equipment, and a spray system. The facility enabled recombiner testing under closely controlled environmental condi-tions in a safe manner. For the test, the Model B recombiner was connected to a production power supply and con-trol panel located remotely from the test facility. ( The procedure for a typical test run was to energize the recombiner and bring the tempera-0 ture to 1225 F The facility blower was actuated to provide cooling air to the recombiner, When the temperature had been stabilized for 30 minutes, hydrogen was injected and samp!ss frem the inlet and outlet of the recombiner were analyzed. (The power setting was not changed during the hydrogen test run) The thermocouples on the heaters were read after the temperatures stabilized. This test was repeated for hydrogen concentrations ranging from 1 v/o to 4.5 v/o hydrogen. Test results show that for 4 v/o hydrogen, the recombiner removes 4 cfm hydrogen. (No measurable hydrogen at the outlet). The temperature stabilized at 1474 F at 4 v/o hydrogen, which is well below the temperature at which the heater elements were tested,[ ] b,c 3 7. Spray Tests Following a LOCA, some containment safeguards systems use a spray system to control the containment environmental conditions. Since the recombiner is located inside the containment. it is subject to spray impingement. The purpose of this test was to demonstrate that the recombiner will operate satisfactorily in post LOCA containment spray environment for an extended period of time. ( 3-6
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t The test facility used for this i?st is shown schematically on figure 3 9. The spray solution used was sodium tetraborate v sich contained 2500 ppm boron as boric acid and sodium hy-droxide.to bring the solution to N pH 10. The spray rate at the intake louvers was set at 0.15 gal / min ret square foot of horizontal area. The spray rate throughout the esst of the re-combiner area was approximately the same. For this test the spray syster, was actuated and then the recombine; was energized and brought to 10'5 0F in tha spa v. The spray test was continued for [ ]b C At the end of this time, hydroran was injected into the containment. Results show no significant amount of spray residue a' Alation on the recombiner in:et and flow through the unit, as measured by electric power r,3 quired to maintain temperature, was not effected. These results are the nme as for the Adodat A recombiner. Following the spray tect, a two percent air-hydrogen mixture was prime:ed with no detectable hydrogen at the recombiner exit. 003363 ( . . l . L i I 3-12
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SUMMARY
OF QUALIFICATIONS TESTS The recombiner power supply and control are unchanged from the Model A design so the environmental and dmic qualifications of these equipment items remains unchanged. These qualifications are summarized in WCAP.7709L Supp;ement 6(ll with additional testing de-scribed in Supplem'ent 7.{2l Certain major hardware items on the recombiner are unchanged. These are: s Heater element design (except length reduced by 9 inches) 33 m Heater bank terminal end design a Thermocouples and mounting design. . ( Therefore, the extensive testing pe.rformed on the? heater design for Model A applies to , Model B. . . Tnese tests include aging in steam for one year, high temperature tests, overpressure tests (for containment leak tests), irradiation tests, long-term operation simulating post LOCA duty. Hardware and structure items which require requalification are: a Recombiner support structure a Heater Frame structural design a Louvers e Orifice plate flow control e insulation (thermal)
, 1. Wilson, J. F., " Electric Hydrogen Recomoiner IEEE 3231974 Qualification". WCAP 7709L Suppl. 6. Oct.1976
*( 2. Wilson. J. F., " Electric Hydrogen Recombiner Lwr. Containments Supplemental Test N meer 2", WCAP 7709L Sucol. 7 Oct.1977 4-1
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e 0032Gy a Heater bank mounting design a Power Cable Junction Box and T/C Junction Boxes. These items must be qualified to IEEE 323 1974 and IEEE 344 1975, in the following paragraph, the requirements of IEEE 344 1975 and IEEE 3231974 are compared with U e tests performed on the recombiner. 4-1. IEEE 3441975 (SEISMIC QUALIFICATION) This Standard establishes recommended practices to verify that the equipment will meet its performance requirements during and following one safe shutdown earthquake (SSE) preceded by a number of OBE's (operating basis earthquakes). The Standard lists several methods for accomplishing this verification. The method selected for qualification of the recombiner is as follows. Since the recombiner is supplied for a number of applications, fragility type testing was per-formed using acceleration values much higher than would be expected for any particular plant application. The acceleration values used were selected from experience in examining
, seismic specificatSns for a number of plant applications for which ,the Model A recombiner ,
. 'was supplied. The specification for the proposed Model B applications will then be compared with the test accelerations to verify that tha applicable portions of the Required Response Spectra (RRS) are enveloped by the Test Response Spectra (TRS). The TRS for the Model B recombiner is derived from the drive plate input spectra shown on figures 3 5 and 3-6.
4-2. QUALIFICATION TO IEEE 323 1974 The Model A recombiner qualification program was described in WCAP 7709L Supplement 6, The qualification recuirements and application requirements are reproduced in the following section: The requirements for qualifying the recombiner are described in IEEE Standard 323 1974. The recombiner has been qualified primarily by type-testing the first production unit. Some analysis was performed to demonstrate performance under environmental conditions which would be difficult to simulate in the laboratory. Since the recombiner is provided for a number of plant applications, the test conditions used were the most severe conditions that could be postulated for any foreseeable plant. The requirements for a particular plant can be compared with actual test conditions to assure individual plant compliance. Margin requirements, as noted in Section 6.3.15 of IEEE 323-1974, are taken into consideration in this evaluation. ( 42 l _-________ l
. 003 E The sequence for type testing is listed under paragraph 6.3.2 of IEEE 3231974. This para-graph is as foliows: 6.3.2 Test Sequence (From IEEE323-1974) The type tests shall be run on the equipment in a specified order. For most equipment and applications, the following constitutes the most se.ere se. . quence; however, the sequence used shall be justified as the most severe for. the item being tested. (1) Inspection may be performed to assure that a test unit has not been damaged due to handling since manufacture and to-determine basic dimensions. This inspection shall not be directed to select a specific unit for type testing. (2) The equipment shall be operated under normal conditions to provide-a data base for comparison with performance under more highly stressed conditions. Certain measurements, such as drift (rate of change with time) of a parameter may be made at this time. (3) The equipment shall be operated to the extremes of all performance and electrical characteristics given in the equipment specifications, ex-cluding design basis event and post design basis event conditions, l_ unless these data are available from othir tests on identical or essen. tially similar equipment. (4) Equipment shall be aged in accordance with Section 6.3.3 to put it in a condition which simulates its expected endof qualifiedlife condition including the effect of radiation (design basis event radiation may be included).-If the required radiation level can be shown to produce less effect than that which would cause loss of the equipment's Class'1E function, radiation need not be included as part of aging. Certain key measurements should be made, following aging, to dctermine if the equipment is performing satisfactorily prior to testing. (5) The aged equipment shall be subjected to such mechanical vibration ; as will be s'en in service. This should include simulated seismic vobra. tion (see IEEE Std. 344-1971), self induced vibration (see IEEE Std. 344 1971, Trial Use Guide for Type Test of Class 1 Elect-ic Valve - Operators for Nuclear Power Generating Stations), or vibration from other causes (such as might be seen by pipe-mounted equipment).
~
(6) The aged equipment shall next be operated while exposed to the simulated design basis event (Section 7) [ radiation may be excluded if incorporated in (4) above). Those functhns which must be per-formed during the simulated design basis event shall be monitored. (. 43
00336S-(7) The aquipmen* shall then be operated while exposed to the simulated. post accident conditions (following exposure to accident conditions). Those functions which must be performed following the simulated 4 design basis event shall be rnonitored during this simulation. (8) Disassemble, to the extent necessary for the inspection of the status and condition of the equipment and record the findings. The requirements for aging are described in paragraph 6.3.3 of IEEE 3231974, and in the Addendum to Foreword to IEEE 323-1974, which are as follows: 6.3.3 Aging - The objective of aging is to put samples in a condition equivalent to the endof. life condition. If previous aging of various devices exists, it can be utilized provided these data are applicable and justifiable in regard to the-service conditions that are required by the performance specifications of the device to be type tested. A short period of accelerated thermal aging merely simulates service life; honever, it produced some deterioration and, when followed by vibration may produce realistic failure modes. Radiation shall be added to other known degrading inf,luences where, appropriate. Margins over that expected + in the gyalified life shall be provided in the application of each influence. Electromechanical equipment (motors, relays, etc.) shall be[ operated to' simulate the expected. mechanical near and electrical contact degradation + (for example, contact pitting) of the device _ to be type tested. An accelerated rate for the number of cycles equal to the required number + during the design life may be utilized provided the rate shall not be accel-erated to any value which results in effects that would not be present at normal rates. For insulating materials, a regression line (see IEEE 1011972 Guide for. Statistical Analysis of Thermal Life Test Data) may be 'used as a basis for selecting the aging time and temperature. Sample aging times of less than-100 hours shall not be permitted. . ADDENDUM TO FOREWORD CLARIFICATION STATEMENT TO IEEE STANDARD 323-1974 % The concept of aging was addressed explicitly for the first time in IEEE Std. 323-1974. The aging guidance therein reflects the requirements of IEEE Std. 279 1971, Section 4.4. It is based on an asereness by members. of IEEE Nuclear Power Engineering Committee that the ability of Class 1E equipment to perform its safety functions might be affected by changes due to natural, operational, and environmental phenomena over time (aging). It was not their intent that aging should be applied to all Class 1E equip-ment, but rather that aging must be considered in the same manner as
- 1. Addendum to Fcrevvord, Clarification Statement. IEEE 3231974 4-4
l ( 003369 other environmental parameters. The need for aging of a particular equip-ment should be determined by an evaluation of its specific design and application. If aging is needed, a further determination must be made on whether accelerated aging techniques: 1) can be applied to the equipment, and 2) will yield valid results that may be correlated to real time, ongoing qualification. The state of the art regarding aging is more advanced for some Class tE equipment than for others. It is expected that known technology will be utilized in any aging program. Optionally, and especially where the state of the art is limiting, aging as part of the qualification program may be addressed by operating experience, analysis, or combined or ongoing quali-fication, as detailed in Sections 5.2, 5.3, 5.4 and 5.5. Further clarification of aging as it applies to specific types of equipment will be provided in individual IEEE Class 1E equipment qualification docu-ments. For example, IEEE P-381 is being prepared to establish criteria for Class 1E modules. IEEE Standards 334, 382, and 383 provide guidance for motors, valve operators, and cables, respectively. 4.1.2 Comparison of Model B Tests with IEEE 323-1974 Requirements A step by-step comparison ,of requirements witt) tests and analyses of the Model B recombiner i follows: . .
\ . . .
The sequence of testing on:the Model B reccambiner followed the sequence given in para-graph 6.3.2 of the Standard. The sequence is justified since it represents the sequence of events which would take place if a hydrogen recombiner were required to perform after a Design Basis Accident (DBA),
- 1. Inspection may be performed to assure that a test unit has not been damaged. . . .
Since the test recombiner was made at the production facility, the normal inspection performed in all recombiners was completed. Ir4 addition, the unit was visually inspected by Westinghouse PWR-SD engineering personnel, a
- 2. Operation under normal conditions. . .
This was accomplished by energizing the unit and then performing an air flow and temperature distribution test. These tests are described in Sections 3.1 and 3.2 of this report.
- 3. The equipment shall be operated to the extremes of performance and electrical characteristics. .
This requirement was accomplished by operating the recombiner at
. (' higher than normal temperatures. The recombiner was operated at
( 1320*F whereas normal test temperature is 1225 F. Further "off. design" tests are reported in Step (7) of this program. 4-5 O
- 4. Equipment shall be aged in accordance with Section 6.3.3 to put it 003370 in a condition which simulates its expected end of qualified life condition. . .
The components of the Model B Recombiner which require qualifi-cation are all located in the recombiner. (The power supply and control panel are the same as the Model A). The following evaluation was made to determine how aging might affect the equipment life: Recombiner The recombiner unit is composed primarily of metallic structural material, metal enclosed thermal insulation, metal clad ceramic insulated heater elements, ar.d power cables. The normal schedule of the recombiner calls for periodic testing to determine system availability plus periods of non-operating time in normal containment environment. Evaluation of these factors leads , to the conclusion that the most significant aging factor was the fatigue life of the structure, due to thermal stresses induced by ths periodic heat up and cool down tests. It was concluded that the metal structures and metal enclosed thermal insulation would not be affected . '! by time alone. The heater life for this type of heater element is far in excess of the duty cycles imposed by the periodic tests; however, the - - duty cycles were ine.8uded in the aging program since they are a necessary part of the recombiner test. The power cables are subject to deterioration due to aging: they are covered by IEEE-383. " Standard for Type Test of Class IE Electric Cables, Field Splices and Connections for Nuclear Power Generating Stations" and have been qualified to this standard. The aging test for the recombiner structure consists of 100 heatup and cooldown cycles as described in section 3-4. Estimating two full tempera-ture tests per year for an installed recombiner leads to a projection of more than 40 years of qualified life. Following the 100 cycle test, the unit was inspected for damage and was found to be in good operating condition. As previously noted, the heaters were also aged in this test.
- 5. The aged equipment shall be subjected to mechanical vibration. . .
The recombiner was subjected to seismic tests as described in paragraph 3 5 cf this report. OBE and DBE test levels, with the recombiner at operating temperature, were conducted using both biaxial random frequency and biuial sine beat inputs. These tests demonstrate the seismic adequacy of the Model B recombiner. 46
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, 6. The aged equipment shall be operated while exposed to a simulated-DBA...
To demonstrate that the recombiner will operate during and immediately J after a DBA, steam pressure transients were performed on Model A recombiner heater banks, electrical cabling and internal electric heater connections. Since the Model A and Model B design of the applicable - portions of these components is identical,-the Model A test results as discussed in WCAP 7709L Supplement 3 Section 3.2 apply. The thermo-couple junction box wiring connections and electrical junction box wiring connections are the same for Model B as for Model A so this part of the Model A qualification spplies. However, since the Model B junction boxes , are now built into the.recomoiner rather than being separate units as in the Model A, the effect of the pressure transient in the box structure must be evaluated. This analysis is shown in Appendix B. Also, since - the Model B recombiner heater frame is structurally =different than the Model A, the effect of a pressure transient was recalculated using'the - same method as used on the Model A recombiner. The louvers were - qualified in section 3 7 by testing with a spray environment.
- 7. The equipment shall be operated while exposed-to.the simulated post-accident conditions. . .
A number of tests were performed on the Model A recombiner which are ( applicable to the Model; B recombi,ner and additional tests were perform 6d on the Model B recombine,r. Model A. tests which apply _ include a11 heater element and heater ' assembly tests.. (High temperature, LOCA trahsient, - . long term post LOCA, external air pressure during containment leak' tests, over voltage and irradiation as reported in WCAP's 7709L Supplement 2, 3, 4 and 5 and as summarized in Supplement 6. Tests were run of the Model'8 recombiner to show .that it will recombine hydrogen efficiently and'that it will withstand the-post LOCA containment spray. These tests are described in this report. The test and analyses described in this report show that the Mooel B recombiner complies with the applicable portions of IEEE 323 1974. (.
. 47
I, 003372 l APPENDIX A DESCRIPTION OF THE MODEL B ELECTRIC HYDROGEN RECOMBINER A 1. DESCRIPTION The electric hydroger, recombiner is shown in figure A 1. A summary of typical design param-etess is presented in table A 1. The recombiner consists essentially of a thermally insulated vertical metal duct with metal sheathed electric resistance heaters provided to heat a continuous flow of containment air (containing a low concentration of hydrogen) up to a temperature l which is sufficient to cause a reaction between hydrogen and oxygen. Air and its contained hydrogen enter the recombiner and flow up through the heated section and out the top by natural convection. The intake of the recombiner is located only on one side and the exhaust ports are located above and on the other three sides of the recombiner. This arrangement of intake and exhaust ports serves to ensure that for downflow air currents external to the recombiner, there would be little tendency for recirculation of the recombiner p'rocess gases (from the exhaust back into the intake). No circulation fans are required and the desired flow rate of air is established by providing the proper size inlet flow area through an orifice plate at the bottom of the recombiner. Thus, with the air flow rate regulated by a fixed orifice and with the supply of electric power determined by a control station outside the containment, controls are not needed in-side the containment. Heat added to the containment air by the recombiner is removed by containment cooling systems already available for other much larger heat loads so that the containment air temperature will remain essentially unaffected by the recombiner. The electric hydrogen recombiner uses conventional type electric resistance heaters sheathed with incoloy 800, which is an excellent corrosion resistant material for this service. These heaters, which are shown in figure A 2, have been designed to operate with the same sheath temperatures as commercial heaters, but at power densities much lower than normal. Each bank contains 60 individus; heating elements. Operation of the unit is virtually unaffected if a few individual heating elements fail to function properly. The major structural components are manufactured primarily of 300-Series stainless steel. Incoloy 800 is used for the heater sheaths and for other parts such as the heater duct, which operates at high temperature. A-1
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( . oo:ma TABLE A 1 ELECTRIC HYDROGEN RECOMBINER MODEL B TYPICAL PARAMETERS Power (Maximum) 75 kW Power (Nominal) 50 kW Capacity (Minimum) At 1 atmosphere 100 scfm Heaters - Number 4 Maximum Heat Flux 7.9 watts /in.2 Maximum Sheath Temperature 15500F Gas Temperature Inlet . 80 td 1550F ( ' in Heater Secti.on . 1150 to 14000F - Exhaust .
~50 F above Ambient Materials Outer Structure 300 Series S.S, inner Structure incoloy-800 Heater Element Sheath incoloy 800 Dimensions Hr!ght 8 ft.
I Width 3.9 ft. ; Depth 4.6 ft, f Weight 4500 ib. . 1 1 A3
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9 ' t { 00:3376- ] A 2. DESIGN CRITERIA - The following are criteria considered in the design of the electric hydrogen recombiner for pressurized water reactor containments: ,
. l a The recombiners are designed to sustain all normal: loads and accident o.ds, includ-ing seismic loads and temperature and pressure transients from a loss-of coolant accident.
e Tha recombiners must be protected from damage from high energy missiles or jet impingement from broken pipes. e The recombiners must be located in the containment such that they process a' flow of containment' air containing hydrogen.at a concentration which is approximately typical of the average concentration throughout the containment. ' s The recombiners must be located away from high velocity air streams, such as could emanate from fan cooler exhaust ports,' or they must be protected from direct impingement of high velocity air streams by suitable barriers such as walls'or floors; e The recombiners are designed for a lifetime consistent with that lof the reactor p'lant. s All materials used in the recombinars are selected to be compatible with the environ. mental conditions inside the reactor containment during normal operation or during
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L , { oorm7s APPENDIX B ANALYSIS OF TRANSIENT PRESSURE LOADS-The purpose of this analysis is to verify the structural adequacy under LOCAL containment pressure transient loads of the heater frame, thermocouple junction box, and electrical junction 1 box for the Model B Recombiner, The same calculational technique as developed for the - Model A heater frame and reported in WCAP 7709L Supplement 2Ill :will be used,' The ca-pacity to withstand a 10 psi per second pressure transient will'be analyzed and this will be the design basis for the Model B Recombiner. (Same as Model __A) The recombiner is basically an open structure and only small differential pressures are devel-oped during a pressure transient. The heater frame, electrical junction box, and thermocouple boxes, although well vented to prevent differential pressure, are the most restrictive compo-nents and have been analyzed.
^
( , The analysis is presented in two parts: (1) The determination.of the pressure acting acrdss the component; and (2) the determination of the stresses in the component resulting'from ttiese pressures, The analysis for the heater frame is presented in detail and the results for the same - analysis applied to the two junction boxes is summarized, B-1. PRESSURE LOADING AND ANALYSIS The heater duct and frame has a volume of about 27,6 ft3 and an inlet area of 0.562 ft3, The external pressure across the walls will be conservatively niculated as follows: Assume that the pressure inside the volume follows the external pressure, i.e., the containment pressure, with no time lag. Determine the mass flow rate into the chamber _ to keep the internal pres-
.ure equal to the external pressure. Determitie the pressure drop across the. inlet area required
-to develop this mass flow rate.
The nomenclature for the calculations is as foljows: A = Flow area into volume gc = gravitational constant hl = Head loss at inlet area 1.- Wilson. J. F-- " Electric Hydrogen Recombmer for PWR Contamments. Equipment oualification Report." WCAP 7709L. Sucpiement 7. September 1973. B1 I l
K = Pressure loss coefficient at inlet m = Mass flow rate into volume
,)
= Volumetric flow into volume R = Gas constant T = Air temperature t = Time V = Heater duct and frame assembly volume v = Velocity through inlet area Ap* = Pressure drop across inlet area hp
- = External pressure rise rate at
, p = Density of air -
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003380 ( - I i I 3 i . J For the case of the heater duct and frame assembly, where V = 27.63ft , and A = 0.562 ft2 ; the differential pressure calculated by this conservative method would be 0.015 psi, which is small as expected. B 2. STRESS ANALYSIS The heater duct and frame assembly is a box structure with 0.156-inch thick incoloy sheet metal sides. The stresses in the box will be conservatively calculated by analyzing a strip of unit width with simply supported ends subjected to a lateral loading of op* and an end load, P. The maximum stress in the strip is given by the formulallI . 1 R w k. R J . " Formulas for stress and Stram." 4th edition. New '.'urk McGrawHill,1965. {. B3
b,c 003381 1 I
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84
4 0 b This stress is much less than the material yield strength under blowdown conditions and is, therefore, acceptable A similar analysis, when applied to the thermocouple junction box and electrical junction box, show them to be acceptable based on low stress during the pressure transient. 003.?80 s 8 (-. B5
s-W d-3g Naf-6 551NS No.: 6835 Ll Staff ihh,44 4N 84-57 ( UN11ED STA1ES IJLtL1LD UWHC NUCLF AR REGULATORY COMMISSION 0FFICE Of lHCPEC110N AND ENTORCEMENT WASHINGTON, DC 20555 g g .g , July 21, 1984 a s.g a y ,ri lt# - M wi i e, ; .
- i #J 9W" INFORMA110N NOTICE NO. 81 57: OPERA 11NG EXPERIENCE RELATED TO M01510RE 1NTRUS10N IN SAFETY-RELATED ELECTRICAL EQUjPMENT Al COMMERCIAL POWErl PLANTS Addressees-All holders of a nuclear power reactor operating license (OL) ur construction pe nnit (CP).
Pyrpose: This notice is provided to alert licensees and applicants of a potentially significant problem pertaining to moisture intrusion into safety related electrical equipment located in high humidity /high tempe'ature areas of the power plant. We ex;,ect that recipients of this notice 6111 review the inf ormation f or spplicability to their f acilities and consider actions, if appropriate, to preclude a similar problem from occurring at their facilities. However, suggestions contained in this information notice do not constitute NRC requirements and, therefore, no specific action or response is required. Description of Circumstances: Numerous occurrences of safety-related equipment failures resulting from moisture intreston have been reported to the NRC since IE Bulletin 79*01B was i s suerl. Most of these f ailures involved electrical terminatin bor:5, junction boxes, pressure switches, etc. Recently the NRC O' 'ct Analysis and Evaluation of Operational Data (AE00) performed a sted on thse operational events with data obtained from 51 reported events that occ c ced fron. July 1980 through February 1984. Most of these ev,ents occurred at boiling water reattor (8WR) plants and involved equipment located outside of primary :entainment, such as in the reactor building basement, and in the high-pressure coolant injectinn (HPCI), low-pressure coolant injection (LPCl), and reactor heat renoval/ reactor core isolation cooling (RHR/RCIC) pump rooms. Details of the aforenentioned study are documented in the AE00 C402 report, which is currently being published by the NRC. Analysis of equipment failures in the AE00 study shows that most of the elec-trical components were short-circuited and corroded when failure occurred. In most cases, the shorting was caused by moisture leaking into the equipment hou, sing and junction boxes, Contributing factors to this moisture intrusion inside the equipment housing were: (1) Installed equipment had lost its vivironmentt' protection bouhoary as a result of maintenance activitie.
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IN 84 57 July 27.1984 Page 2 of 3 l , (2) Many early designs aiid installations did not provide adequate protective boundaries. Unsen ed conduits and other possible pathways were alloted i to exist that pernc tted moisture to leak into the equipment housing. (3) Moisture and steaa may have entered at unsealed conduit ends located at ( higher elevatier.s and eventually found their way down to the equipment housing and junction boxes at lower elevations. l The AE00 stuuy indicates that the licensees nad taken several corrective actions,
; including cleaning and drying the equipment and, in some cases, completely ; replacing components. However, moisture intrusion into electrical equipment housing remains a recurring problem at nuclear pcwer plants.
To prevent moisture-induced degradation and to maintain integrity of safety-related electrical equipment, the NRC staff recommends that holders of operating licenses and construction permits consider the following preventive actions: (1) Provide routine surveillance of areas where equipment is installed to assure that its environmental parameters are within its designed limits during normal plant operations. (2) Ensure that plant maintenance programs include adequate administrative controls to require restoration of vapor barriers, gaskets, and seals to equipment after maintenance or testing activities are completed, such as: i (a) providing watertight sealing to all electrical conduit-to-junction boxes and conduit-to-terminal box connection points for saf ety-' elated equipment located in area", of the reactor building and areat, that are potential $1y subject to high temperature steam or water impingement. i (b) ensuring [ hat the existence (or lack) of bnx drain holes and equipment interfacejareinconformancewiththetest$ctupestablisbecduring equipment qualification testing and with the vendor's recommt.ndations. (3) Pro eide more dt. tails and, when necessary, include pictorial descriptions in tarveillance and/or maintenance procedures that involve the disassembly / reassembly of etJipment housings. (4) Tr/en personnel working on electrical, electronics, and instrumentation eo.ipment in installation techniques to prevent the potential of moisture int %sion into equipment housings. (5) Prrvide adequate' quality assurance review to ensure that approprive-lastrtctions are included in the surveillance and maintenance pratedures and to verify that equipment is properly protected against moistuit-intrusion when rtassembled.
IN 84 67 July 27, l'304 Page 3 of 3 t if you have any questions regarding this matter, please contact the Regioin Administrator of the appropriate NRC Regional office, or this office. Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Tecrai .ri
Contact:
N. B. Le, IE (301) 492-9613 1 H. El Zeftawy, AE00 (301) 492 4434
Attachment:
List of Recently issued IE Information Notices I ( i l See previous concurrences
- DDIR:DQA51Pitt utR:0QA51P:!E RCPB:DQASIP:lE" VPB:0QA5!P:lE' NGrace Glech JPartlow ile/vjj 07/ /84 07/ /84 07/ /84 07/ /84 IE:EGCB OIR:0EPER:IE R8aer EJordan 07/ /84 07/ /04 I
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19 - 6/ gb( b 807 IDGrJ7 prig 3 o c & 3#/3W-W APCo Exhibit 51 0Ge'1) Tdib E n pix i. h/72. TET)CORRESPONDEtCE O IN 84 47 92 mR 13 P4 :37 UNITED STATE $ NUCLEAR REGULATORY CO*I55 OFFICE OF IN$PECTION AND ENFOs W M N _W, "_ . , . WA$HINGTON, D.C. 2055! ' Mhl $ d #"A June 15, 964 IE lh4RMAT10% NOTICE N0 84 47: ENv!RONMENTAL QUALIFICATION TESTS OF ELECTR TEPMINAL BLOCKS affresseet! All nuclea' pc.er reactor f acilities holding an operating If tense (OL) or const' ction perrit (CP). Pua ::ses: This irf
- nation notice is being issued to provide licensees and construction pe Pit h: Ice's with information pertaining to the results of a rect't NRC spon-5:*ec e'hir**.* ental qualification methodology research test conducted on e'e:'.rical te einal blocks. This information notice also serves as an early n:tificatien regarcing the redwetion of insulation resistance values sustained O tj ee tain te*minal biceks used in a Conax Electrical Penetration Assently
- c. in; e cesign basis event simulation test.
- It is en:e: tee that recipients will review the information for applicability to t*eir fa:ilities. Nc specific action or response notice is required.
*es::*4ea of Cirev-stances: '
- l. A::dtittal infermation on N M-sponsored telt on terminal blocks in 1991 the NRC sponsored a research test on terminal blocks to ,
t*.tst4;ete the insv14 tor deterioration of the terminal blocks under
- a:cicett concitions. This test was conducted at the Sandia National Lateratories (5NL) in Albuquerque, New Mexico. The test results of tnis earlier test program were published in IE Information Notice No, 82 03.
?*e results then indicated that the performance of the terminal blocks was questionable, however, the results were inconclusive because there
.ere several areas where test conditions deviated from the actually iestalled conditions. Recently, in order to quantif/ the performance of realistically installed and protected terminal blocks in a LOCA environ *ent, $NL tested 24 more terminal blocks of different models free four selected manufacturers.
Feevioss testing data on the terminal blocks indicated that neither the a:ce'erated aging process nor the seismic testing will significantly affect terminal block performance; therefore aging and seismic simula-tioa was not incorporated in the later $NL test. Terminal blocks were f) V teste; in the "as received" condition to simulate normal handling curing installation. Additionally, no special care was taken during test prepa-ration to prevent t,he deposit of fingerprints or other contaminants on the terminal block surfaces, p 4g , a D
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l IN 84*47 June 15. 1984 Page 2 of 4 Test1/4" with teminal blocks diameter were weep installed holes in theinsidebottom. NEMA 4 electrical enclosures from the side through "licuid tight" conduit. Cables entered the bcses through conduit from a cable tray system, the conduit was terminatedTo sim inside the test chamber and the conduit end was not sealed. The test was i divided into two phases; each phase was tested under temperature profilgs closely fo110 wing the PWR temperature profile as described in Appendia A of IEEE 323*1474. i Phase I consisted of an 11* day esposure to a steam only environment, and i Pnase !! consisted of approximately one day of simulteneous steam /chsmical spray followed by a 5 day exposure to a steam environment. Saturated steam concitions were maintained throughout both test phases. Details of the test and test connections are bein which will soon be pue118hed by the hRC. g documented in NUREG/CR 3418 ed at voltages typical of in plant applications: 4 V de typical of RTD circuits, 45 V de typical of instrumentation circuits, and 125 V de typical of control r,ircuits. The terminal to* terminal leakage currents were monitored during both Phase ! and Phase !! tests, and the terminal-to ground leakage currents were monitored during the Phase !! tests only. The SNL test provides the following significant results: (1) the surface moisture film formed during the test reduced insulation resistance to 108 to 105 ohms from initial values O of 108 to 1050 ohms; the reduction in insulation resistance occurred during the steam exposure portion of the LOCA simulation, (2) at 45 V de, leakage currents were on the order of 0.1 to 10 mA, (3) " 4 V de, insulation resistance was at 5 x 108 to 7 x 10* ohms, and (a) one open failure was observed when leakage currents continued to increase for a 90 minute period to values which causea a 12-A**. wire to separate f rom the terminal point of the terminal block. l The separation occurred at the terminal block wire junction of a 125 V de circuit. 2. Low insulation resistance resulted durinc cualification testino of termina) olocks ele:trical penetrationuseoassemoly in icw voltace (EPA) instrumentation / control (1/C) In a Part 50.55(e) Fotential Reportable De'ficiency Report, the Arizona Public Service Company (APS) has recently reported to the NRC that during the review of a qualification test report on terminal blocks used in lon voltage (1/C) EPA supplied b that insulation resistance (!R) y CONAX Corporation, values between APSpoints terminal has observedof the terminal blocks were substantially reduced during simulation of design basis events. AP5 concluded that the low leve) signals (up to a maximum AB V de and 4 20 eA range) cannot tolerate this low IR condition. This O
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IN 84 47 June 15, 1984 Page 3 of 4 condition could result in erroneous response in the sensing and control functions, accicent which in turn might jeopardize reliable plant operation during conditions. APS reported that the test terminal blocks were eace by Kulka Eler:tric Corporatien and that during an investigative test, the tearinal mitter andblocks also failed the "al-installed conditionn" test in trans-RTO circuits. APS further indicated that Raychem splices are uncer consiceration as replacement for the terminal blocks for trans-mitter anc RTO circuit applications at the Palo Verde units. 0,1, e u s s i o n. Tiis information notice highlights a potential concern that may exist when tirminal Diccks are exposec to a steam anvironment. ThJ results of the SNL test show that a moisture film will form on the of the terminal block during the simulation of the LOCUMSLB events, and will result in the recuction of insulation resistance between terminal points and grounc. anc thus will allow some leakage currents to flow to ground.. Basec on the review of the SNL test and the review of other Qualific reports on terminal blocks, the NRC staff recognizes that leakage currents do exist during LOCA/M5LB simulations and that the leakage currents may be of sigeificance in some applications. Although no written response to this notice CO is recuirec,
- 1) review it is suggested that licensees and construction permit holders their facilities to determine if terminal blocks are used in
- low vcitage acclications, such as in transmitter and RTO circuits, and
- 2) re.ie. terminal block cualification documents to ensure that the funct recotretents and associated loop accuracy of circuits utilizing terminal block will not cegrace to an unacceptable level due to the flow of leakage currents that might occur during design basis events.
to conitor leakage currents, and where failure Instances where fuses were used criteria wara based on the f ailure of trese fuses (1 ampere er less) do not provide information about lesie;e currents of magnitude that are less than the fuse rating. Data pro-vicec c ce- tnese instances are not considered to be acceptable data. The NRC staff consicers this review to be part of the on going activities that the lice sees are currently uncertaking to resolve other environmental qualification ce'iciescies rule, 10 CFR to 50.49.meet the deadline and requirements set forth in the EQ final When supporting data for leakage currents are not substantiated during this review, one of the following possible corrective actions should be considered: 1) Perform a valid qualification test of the installed tereinal blocks with provision for the continuous monitoring of leakage currents t'ircughout the test, and perform analysis to demonstrate that acceDtable loop accuracy and associated response time for instrument circuit variousutilizing operating terminal conditions. block are being maintained throughout
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IN 84 47 June 15, 1984 Page 4 of 4
" 2)
Obtain documentation from valid qualification tests already s performed with substantiated data for leakage currents, and perform appropriate analysis as stated in 1) above. 3) Replace the installed terminal blocks with qualified splices, t in addition to the concern of leakage currents being addressed in this notice licensees and construction permit holders are reminded that other involve periodic inspection of terminations and terminal cleanliness 45 described in the previously published information notice No. 82 03 remains in effect. If you have any questions regarding this matter, please contact the Re A:iinistrator of the appropriate NRC Regional office, or this office. gional
.A J ard L. Je can, Director Division of Emergency Preparedness and Engineering Response office of Inspection and Enforcement Te:Mical
Contact:
R. G. LaGrange, NRR (301) 492-8208 N. B. Le, IE (301) 492-9673 Atta:9ent:}}