ML20140H142
| ML20140H142 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/1986 |
| From: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20140H133 | List: |
| References | |
| GL-85-15, IEIN-86-003, IEIN-86-3, NUDOCS 8604040059 | |
| Download: ML20140H142 (2) | |
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g FEB 2 01985 MEMORANDUM FOR: Charles E. Norelius, Director, Division of Reactor Projects FROM:
Carl J. Paperiello, Director, Division of Reactor Safety
SUBJECT:
IE INFORMATION NOTICE 86-03: POTENTIAL DEFICIENCIES IN ENVIRONMENTAL QUALIFICATION OF LIMITORQUE MOTOR VALVE OPERATOR WIRING On January 14, 1966, the subject Information Notice was issued to all nuclear This Notice was issued to alert recipients of a power reactor facilities.
potential generic problem regarding the environmental qualification (EQ) of internal electrical wiring used in Limitorque operators.
Additionally, Generic Letter 85-15, issued August 6,1985, provided infomation and guidance to licensees of operating reactors related to deadlines, reporting requirements, evaluations and actions that should be taken as a result of discovering equipment that waspin compliance with 50.49.
404 I am requesting that DRP have the Resident Inspectors at each operating reactor and construction site contact the licensee and detemine what action was taken related to IE Information Notice 86-03 and Generic Letter 85-15.
If the licensee determined that the subject problem does exist at their facility, collect and fomard all pertinent infomation such as LERs, Safety Evaluations, planned actions and a schedule to complete those planned action to This will Mr. James W. Muffett, Chief, Plant Systems Section in Region III.
provide the region with the necessary infomation to adequately assess the l
i problem, its safety significance, and enforcement action should any be warranted.
IE Headquarters is currently generating a Temporary Instruction pertaining to l
this issue, your assistance will allow Region III to analyze and resolve this i
issue in a tinely manner.
Should you have any questions regarding this request, please contact J. W. Muffett (FTS 388-5598) or J. J. Harrison (FTS 388-5635) of my staff.
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&E PDR Carl J. Pape tello, Director g
Division of Reactor Safety Misc Attachments:
l 1.
IE Information Notice 86-03 2.
Generic Letter 85-15 See Attached Distribution _
7 f f 8 2 01986 2
' Charles E. Norelius Distribution cc w/ attachments:
A. B. Davis, RIII N. J. Chrissotimos. RIII R. F. Warnick, RIII G. G. Zech, IE U. Potapovs, IE i
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SSINS No.:
6835 IN 86-03 UNITED STATES NUCLEAR REGULATORY Co MISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, DC 20555 January 14, 1986 IE INFORMATION NOTICE NO. 86-03:
POTENTIAL DEFICIENCIES IN ENVIRONMENTAL QUALIFICATION OF LIMITORQUE MOTOR VALVE OPERATOR WIRING Addressees:
All nuclear power reactor facilities holding an operating license (OL) or a construcQ an permit (CP).
Purpose:
This notice is provided to alert recipients of potential generic problems regarding the environmental qualification of electrical wiring used in Limitorque motor valve operators.
It is expected that recipients will review this information for applicability to their facilities and consider actions, if appropriate, to preclude a similar problem occurring at their facilities.
However, suggestions contained in this notice do not constitute NRC requirements; therefore, no specific action or written response is required.
i Description of Circumstances:
On September 30, 1985, Commonwealth Edison (Zion Generating Station) reported to the NRC that it had discovered four Limitorque motor valve operators with jumper wires different from those tested by Limitorque in its environmental qualification program.
Subsequently, the Tennessee Valley Authority (TVA) notified the NRC that the manufacturer of the internal control wiring of its i
Limitorque operators at Sequoyah Nuclear Plant either could not be identified or qualification could not be established where the manufacturer was known.
Similar circumstances have recently been identified at other nuclear plants.
Discussion:
The results of NRC inspections at Limitorque and TVA have determined that even though Limitorque has conducted environmental qualification testing of motor l
valve operators, the qualification test reports do not specifically address wiring cv wiring qualification.
Limitorque has installed wires from several different manufacturers in safety-related operators.
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IN 86-03 January 14, 1986 Page 2 of 2 Limitorque stated that it can provide or reference documentation to support qualification of wires it has installed; however, valve manufacturers, licensees, and/or others may have added additional wires that are not qualified by this data. The NRC physical inspection of Limitorque operators at the Sequoyah plant determined that some valve operators contained wires not qualified by the Limitorque tests.
The NRC staff considers the resolution of this issue to be part of the licensee's environmental qualification program to establish and maintain the qualified status of electrical equipment within the scope of 10 CFR 50.49.
Because qualification of Limitorque installed wiring may be based on separate qualification tests of wire, it is important that adequate analyses have been performed and that documentation exists to demonstrate that the separate wire qualification tests encompass the parameters for the valve operator qualification.
If additional wiring has been added or replaced after operator shipment from Limitorque, then additional documentation may be appropriate for establishing qualification of the additional wires and subsequently the valve operators for the valve operator specific application.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the Regional 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
Contact:
G. Hubbard, IE (301) 492-9759
Attachment:
List of Recently Issued IE Information Notices i
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IN 86-03 January 14, 1986 Page 2 of 2 Limitorque stated that it can provide or reference do::umentation to support qualification of wires it has installed; however, valve manufacturers, licensees, and/or others may have added additional wires that are not qualified by this The NRC physical inspection of Limitorque operators at the Sequoyah plant data.
detemined that some valve operators contained wires not qualified by i.he Limitorque tests.
The NRC staff considers the resolution of this issue to be part of the licensee's environmental qualification program to establish and maintain the qualified status of electrical equipment within the scope of 10 CFR 50.49.
Because qualification of Limitorque installed wiring may be based on separate qualification tests of wire, it is important that adequate analyses have been perfomed and that documentation exists to demonstrate that the separate wire qualification tests encompass the parameters for the valve operator qualification.
If additional wiring has been added or replaced after operator shipment from Limitorque, then additional documentation may be appropriate for establishing qualification of the additional wires and subsequently the valve operators for the valve operator specific application.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the Regional 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
Contact:
G. Hubbard, IE (301) 492-9759
Attachment:
List of Recently Issued IE Information Notices
- DEPER:IE
- DD:DEPER:IE
- D:DEPER:IE
- SEE PREVIOUS CONCURRENCE RLBaer SASchwartz ELJordan 12/23/85 12/31/85 1/2/86
- VPB:DQAVI
- SC/VPB:DQAVT
- BC/VPB:DQAVT
- DIR:DQAVT
- TECH ED/IE GHubbard:sas UPotapovs GGZech BKGrimes DGable 12/19/85 12/19/85 12/19/85 12/23/85 12/20/85
IN 86-03 January 14, 1986 i
LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Date of
'l Information Notice No.
Subject Issue Issued to 86-02 Failure of Valve Operator 1/6/86 All power reactor Motor During Environmental facilities 5olding an OL or CP Qualification Testing 86-01 Failnre Of Main Feedwater 1/6/86 All power reactor Check Valve Causes Loss Of facilities holding Feedwater System Integrity an OL or CP And Water-Mansier Damage 85-101 Applicability of 10 CFR 21 12/31/85 All power reactor To Consulting Fims Providing facilities holding an OL or CP Training 85-100 Rosemount Differential 12/31/85 All power reactor Pressure Transmitter Zero facilities holding an OL or CP Point Shift 85-99 Cracking In Boiling-Water-12/31/85 All BWR facilities Reactor Mark I And Mark II having.a Mark I or Containments Caused By Failure Mark II containment of The Inerting System 85-98 Missing ' Jumpers From Westing-12/26/85 All Westinghouse house Reactor Protection
-designed PWR facilities holding System Cards For The Over-Power Delta Temperature Trip an OL or CP Function 85-97 Jail Ters For Former 12/26/85 All power reactor Contractor Employee Who facilities holding an OL or CP Intentionally Falsified Welding Inspection Records 85-96 Temporary Strainers Left 12/23/85 All power reactor Installed In Pump Suction facilities holding Piping an OL or CP 85-95 Leak Of Reactor Water To 12/23/85 All BWR facilities Reactor Building Caused By holding an OL or CP Scram Solenoid Valve Problem OL = Operating License CP = Construction Permit
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.AUG 4 985 TO ALL LICENSEES OF OPERATING REACTOR 5 q
Gentlemen:
SUBICT: INFORMATION RELATING TO THE DEADLINE 5 FOR COMPLIANCE.
i NITH 10 CFR 50.49, *ENVIRONNENTAL ik!ALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO 5AFETY FOR NUCLEAR POWER PLANT 5" (GENERIC LETTER 85-15)
The deadline for compliance with 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Powerflants" is specified in the rule as the date of the second refueling outage after March 31, 1982 or March 31, 1985, whichever was earlier. Some plants have received extensions to these deadlines.up to November 30, 1985. Where r,vrrent extensions terminate prior to November 30,1985,.the delegation in 10 CF't 50.49(g) permits the Director of NRR to act on further requests for extensions as long es the new deadline is not beyond November 30, 1985. Sectior, 50.49(g) states that "in exceptional cases, the Commission itself any consider and grant extensions,,
beyond November 30, 1985, for completion of environmental qualification." [Jhe purpose of this letter is to advise licensees that it is the Commission's intention that extensions will be granted only in rare circumstances and that enforcement action will be taken againstpicensees that continue to operata their plants with unqualified equipme t beyond November 30, 1985, without extensions approved by the Comission.
It is the Comission's intention that licensees which are not in comp 11ance on November 30, 1985, and which have not been given extensions either,will have to either shut down or, if they have valid staff-approved justifications for contiged operation, select to operate and face civil penalties of $5,000 per item - per day for each day after November 30, 1985, on which a licensee operates in noncompliance with the rule. For noncompliance identified after Novmber 30, 1985, such fines may be made retroactive to November 30, 1985 for each day a licensee cicarly knew, or should have known, that equipment qualification was incomplete.- Some mitigation of any penalty may be considered based upon satisfaction of the following factors:
1/ For purposes of enforcement, unqualified equipment" means equipment for which there is not adequate documentation to establish that this equipment will perform its intended functions in the relevant environment.
- / An item is defined as a specific-type of electrical equipment, designated by r.anufacturer and model, which is representative of sil identical caviprent in a plant area exposed to the sane-envircra er.tal serpce conditions.,
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Did the licensee identify and promptly report the noncog11ance with 10 CFR 50.497 t.
Md the licensee apply best efforts to complete.
environmental qualification within the dead 11nef
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Has the licensee proposed actions which can be espected to result in full compliance within a reasonable time?
For equipment which is discovered (through new test results, NRC inspection, or other means) after November 30, 1985, to be in noncompilance or is susmeted to be in noncompliance with the requirements of 10 CFR 50.49, licensees a muld i
report the finding if the condition found meets the reporting criteria of 10 CFR 50.72 (Prompt Notification) or 10 CFR 50.73 (Licensee Event Neporting System). Evaluations of the significance of and corrective action for all i
- IFtual and potential noncompliances should be documented at.should the i
circumstances of discovery of the noncompliance or suspected noncagliance.
These documents should be mtained in appropriate licensee files.
If equipment i;
addmssed in the plant Technical Specifications is found to be unable to perfors its intended function during an accident because of equipment qualification problems, the licensee is required to follow the. provisions of the Technical 5pecifications. A case by case determination will be made whether ' retroactive enforcement is appropriate for noncampliance identified after Noverter 30, 1985.
-l Licensees desiring an extension beyond November 30, 1985, ausst submit an extension request at the earliest possible date to the Cannission with a copy 1
l to the Director, NRR and the Director. IE. Requests received after September 30, 1985, will be considered untimely, and may be denied on that basis. The basis for any estension request beyond November 30,1985 must clearly identify the i
exceptional nature of the case, e.g., why, through events entirely beyond.its control, the licensee will not be in compliance with the rule on November 30; the date when compliance will be achieved; and a justification.for continued operation until compliance will be achieved.
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 l
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 Axelrad for enforcement questions. Mr. Holahan can be ' reached on (301)492,-7415 and Ms. Axelrad can be reached on (301)492-4909.
vN02 hu h L. Thompson Jr.;
lirector i D vi ion of 1.icensind l
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