ML20148P709
| ML20148P709 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/01/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20148P661 | List: |
| References | |
| 50-416-87-32, NUDOCS 8804120072 | |
| Download: ML20148P709 (4) | |
See also: IR 05000416/1987032
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b.
Violation 50-416/87-32-02, Limitorque MOV, T Drains and Grease
Relief, Paragraph 13.c.(2).
c.
Violation 50-416/87-32-03, Raychem Heat Shrink Tubing in Unqualified
Configuration, Paragraph 13.c.(4) and 13.c.(10).
d.
Violation 50-416/87-32-04, Qualification Package for Lubricants,
Paragraph 13.c.(1).
e.
Unresolved Item 50-416/87-32-05, Nylon Wire Crimped Connectors on
Limitorque Dual Voltage Motors, Paragraph 13.c.(2).
f.
Unresolved Item 50-416/87-32-06, Accuracy Calculations for PAM
Instruments for Postulated Harsh Environments, Paragraph 13.c.(7).
g.
Unresolved Item 50-416/87-32-07, Summary Test Reports for Terminal
Blocks to Category 1 Requirements to be Upgraded, Paragraph 13.c.(8),
h.
Unresolved Item 50-416/87-32-08, Seal Assembly for Victoreen
Radiation Monitor Connectors, Paragraph 13.c.(11).
The licensee did identify some material as proprietary during this
inspection, but this material is not included in this inspection report.
3.
Licensee Action on Previous Enforcement Matters
NRC's Unresolved Items 50-416/86-39-04 concerning wiring in Bettis and
Hiller actuators and 50-416/86-37-02 concerning Raychem splices are closed
with this report.
These items are discussed in Paragraphs 13.c.(5) and
13.c.(10),respectively.
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.
Four unresolved items identified durin
discussed in paragraphs 13.c.(2),13.c.(7),13.c.(8)g this inspection are
and 13.c.(11).
5.
Electrical Equipment Environmental Qualification Program and Procedure
Review
The inspectors reviewed SERI/ Grand Gulf EQ Program directives to verify
establishment of an EQ Program in compliance with 10 CFR 50.49 including
the following:
Engineering Standard (ES) 21
Environmental Qualification Program.
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8804120072 880401
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ADOCK 05000416
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Material Nonconformance Report (MNCR) No. 454-87 was written on
December 7,
1987, to document the procurement and installation of
commercial grade replacement parts in EQ equipment.
The scope of the
problem appears to be limited.
This is based on the inspector's review of
the disposition of the MNCR by NPE of the various equipment types and
systems involved.
It was determined that the root cause was poor
personnel-procedural interface within the Material Specialist group in
th9, (1) the procurement procedures were deficient and (2) the staff were
inadequately traired in the requirements of the EQ program.
This
situation was made worse by a deficient dedication process for
comercially procured replacement parts which did not require an
engineering review by NPE.
The use of commercial grade material in EQ
application is a design change and is sut' ject to design control measures
delineated in ANSI N45.2.11-1974.
In response to the inspector's
question concerning corrective actions taken to assure the continued EQ
0-Rings for
86164006)gement stated:
licensee mana
status of installed equipment,
and Solenoids for ASCO Kit
ASCO Kit #302-9296E (stock code GG
- 8321 AGE (stock code GG 85336008) were determined to be dispositioned as
"Rework".
Qualified replacement parts have been ordered, and Maintenance
Work Orders (MW0s) have been prepared for their installation.
Upon
receipt of the ordered parts the MW0s will be implemented and the removed
components will be forwarded to NPE for examination and if necessary
destructive tests.
Additionally, items in the warehouse associated with
stock codes GG 86164006, GG 85336008, and 6G 81106090 1.e. ASCO Solenoid
Valve #29701-5 have been dispositioned as "Reject", and will be scrapped
to prevent recurrence of installation.
At the time of the inspection, the environmental qualification status of
equipment having spare or replacement parts associated with the above
stock codes was indeterminate.
The above material nonconformance is,
there fore, classified as a licensee identified violation, in that
comercially procured spares and replacement parts were installed in EQ
equipment without an adequate dedication process.
This is identified as
Violation 50-416/87-32-01, Use of and Failure to Evaluate Commercial Grade
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Parts for EQ Applications.
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13.
Environmental Qualification Documentation Packages and In-Plant Physical
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Inspection
a.
Environmental Qualifica :f on Documentation Packages (EQDP)
System Energy Resources's EQDP are prepared and controlled by the
Nuclear Plant Enginee r ng Department.
The packages included an
Equipment Evaluation C' ecklist, Aging and Radiation Calculation /
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Analysis, Environmental Parameters, Test Reports, NRC IENs and IEBs
reconciliations, Vendor Notifications etc.
An EQDP is prepared for each specific type of qualified component
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designated by manufacturer and model that are exposed to the same
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environmental service conditions.
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Prior to the NRC inspection team's arrival, walkdowns were being
performed by the licensee on various components identified by
previous inspections.
The splices on the hydrogen recombiner
were characterized by the licensee as "cosmetically"
unacceptable and work requests had been initiated to replace the
existing splices because of their appearance.
The NRC inspector
detemined that the effects of spray and high humidity war not
adequately evaluated.
The licensee stated that there was no
sealing requirement for the splices in that the splices were
located in an enclosure.
The inspector determined that the
enclosure was not moisture proof.
At the exit, the licensee
stated that the splices would be replaced with qualified Raychem
kits.
This replacement was completed under MWO-E76966 and
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MWO-E76967 by December 31, 1987.
This is identified as an
example of Violation 50-416/87-32-03, Raychem Heat Shiink Tubing
Installed in Unqualified Configuration.
(5)
Bettis & Hiller Actuators - The inspector reviewed licensee
activities with regard to a previously reported problem
concerning the potential use of unqualified wiring with Bettis
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and Hiller actuators on air operated valves (A0V's).
This was
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identified in NRC Report No. 50-416/86-39 as Unresolved Item
50-416/85-39-04.
As a result of IEN 86-53, which was received
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by the Mcensee in July 1986, the licensee decided to initiate a
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comprehensive review of their Raychem splices at their earliest
available opportunity, which occurred during their first
refueling outage in September 1986.
During the course of their
inspection, the licensee identified 19 out of 99 valves that
contained unidentified wiring.
The installation of this wire
was traced to a construction / maintenance activity in 1982.
At
the time this wire was installed, GGNs' constructions standards,
purchase and procurement specifications required class IE wire
to be used in class IE applications. The unidentified wiring was
immediately replaced with known qualified and traceable wiring.
The wiring which was removed was categorized into eight different
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wire types.
A representative sample of each of the wire types
was sent off to a materials analysis fim to identify the
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specific insulation materials used. Once the specific materials
were identified the licensee performed an analysis, documented
in calculation EC-Q111-87001, R0 which demonstrates the wiring
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had sufficient thermal and radiation withstand capability to
perform its function.
Based on this calculation, the inspector
concluded that the wiring was qualifiable for its intended
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application.
The licensee also stated that none of the 19
valves were in the ECCS System and that all these valves would
have performed their safety (isolation) function within a minute
of the postulated harsh environment accident. Because this item
was licensee identified, would fit in the Severity Level IV
t;ategory, had prompt corrective action taken and could not have
been reasonably expected to have been prevented by any
licensee's corrective action for a previous violation, no
citation will be issued in accordance with the guidelines of
10 CFR 2 Appendix C, Paragraph V. A.
This Unresolved Item is
closed.
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IEN 86-53, Improper Installation of Heat Shrinkable Tubing,
dated June 26, 1986, was received at the utility in the early
part of July.
The first opportunity for inspection after
receipt of this IEN, was the refueling outage of Se ' amber 5,
1986 to January 1987.
At this time, the licensee .
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routine walkdown inside containment for 10 CFR 50.49 equipment
and the IEN concerns.
As a resul t, some acn-standard raychem
heat shrink tubing installations were identified.
The license
determined from their records that the.e non-standard
installations were not covered by existing GGNS test reports.
Being in an outage, the licensee replaced all non-standard
configurations as a conservative measure to insure that this
item would not impact restart.
The licensee stated that they performed additional analysis and
obtained additional test data to show that the non-standard
Raychem configuration would have remained operable in the event
of a DBA.
(See 3ERI's Letter AECM-87/C045 of March 20, 1987 to
the NRC.)
This unresolved item is closed and up-graded to a
violation identified as an example of 50-416/87-32-03, Raychem
Heat Shrink Tubing Installed in Unqualified Configurations.
(11) dQDP 14.1, Victoreen Radiation Monitor - The file for the
Victoreen radiation monitors for high-range containment
monitoring was reviewed.
The qualification basis was
NUREG"0588, Category I.
The test conditions enveloped the plant
profile and the accuracy of detector was properly addressed and
is discussed in paragraph 13.c.(7) above. The test specimen was
identical to the plant installed item except for installation.
This component wt s tested by Victoreen 'i a number of
configuration $.
Af ter eight unsuccessful . tempts, the cable,
and connector were sealed in stainless steel conduit from the
detector to the LOCA chamber penetration.
This was the only
configuration that parsed the LOCA test.
The test report stated
that the intention was to seal the connector, but that the
proximity to the penetration made it convenient to seal up the
cable as well.
A+ GGNS, the connector assemblies are contained
in a stainless steel (SS) box, connected to the detector housing
with sealed high pressure metal bellows flex conduit, and sealed
at the cable entrance points.
During the walkdown inspectior.,
the NRC inspector requested that the access cover on the SS box
be removed in order to examine the splices.
The GGNS technician
had nc trouble loosening the approximately 7 'nch diameter cover
cap and screwing it off of the 6-inch diameter threaded collar
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n the front Of the junction box.
It was clear that the cap had
taen only hand teg'.t and also there was no gasket, or 0-ring or
ither apparent sealing device for the heavy, machined stainless
' teel cap.
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