ML20149M988
| ML20149M988 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/07/1988 |
| From: | Anderson C, Cheung L, Dev M, Thomas Koshy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20149M972 | List: |
| References | |
| 50-271-87-19, NUDOCS 8802290349 | |
| Download: ML20149M988 (24) | |
See also: IR 05000271/1987019
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-271/87-19
Docket No.
50-271
License No. DPR-28
Licensee: Vermont Yankee Nuclear Power Corporation
Brattleboro, Vermont 05301
Facility Name:
Vermont Yankee Nuclear Power Station
Inspection At:
Vernon, Vermog
Inspection Conducted: October 19-23, 1987
Inspectors:
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Leonard Cheung, Reactor Eng
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Thomas Koshy, ReactoY Engineer
date
Other participants and contributors to this report include:
R. Moist, Engineer, NRC-NRR/DRIS-VIB
E. Clairborne, Engineer, Saudia National Lab
W. R. Carpenter, Engineer, Idaho National Ergineering Lab
Q. Decker, Sr. Engineer, Idaho National Engineering Lab
C. Miller, e gineering Specialist, Idaho National Engineering Lab
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Approved by:
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C. Q/ Anderson, Chief plant System Section
date
Inspection Summary:
Inspection on October 19-23,1987 (Inspection Report
No. 050-271/87-19).
Areas Inspected:
Special, announced inspection to review the licensee's
implementation of a program for establisning and maintaining the qualification
of electrical equipment within the scope of 10 CFR 50.49.
Results: The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49 except for certain deficiencies listed
below:
8002290349 800222
ADOCK 05000271
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Violations
Paragraph
Item Number (s).
1) Qualification of Cerro.
12.1
50-271/87-19-01
_EP/Hypalon Cables
.2)-QualificationofRome
12.2-
50-271/87-19-02
XLPE/PVC Cables-
3) Qualification of Lewis PE/PVC
12.3.
50-271/87-19-03
instrumentation cables
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4) ~ Qualification of 3M tape
12.4
50-271/87-19-04
splices
5)' Qualification of GE EB-5
12.5
50-271/87-19-05
terminal blocks
6) Qualification of Dings brakes
12.6
50-271/87-19-06
Unresolved Items
1) Limitorque Motor
13.1'
50-271/87-19-07
wire connectors
2) Limitorque Motor wire leads
13.2
50-271/87-19-08
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3) Rosemount transmitter
13.3
50-271/87-19-09
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Details
1.0 Persons' Contacted
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1.1=~ Vermont Yankee Nuclear Power Corp-
L'. Anson, EQ Coordinator
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D. Bauer, Assistant to Managers of Operation
P. Donnelly, Maintenance Supervisor
- H. Heilman, I&C Engineer
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J. Herron, Operation Support
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Legere, Senior Maintenance Engineer
W. Limburger, Purchasing Manager
- R. McCullough, Assessment Coordinator
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H. Metell, Engineering Support Supervisor
W. Murphy..Vice President and Manager of Operations
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R. ~Pagodin, Technical Service Superintendent
D. Reid, Operation Support Manager
R. Wanczyk, Operation Superintendent
T. White, Project Engineer
1.2 Yankee Atomic Electric Company
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- D. Oyer, QA Engineer
R. Grippardi, QA Supervisor
P. Johnson, Lead Electrical Engineer
S. Miller, Project Manager
C. Nichols, Engineer
- W. Peterson, QA Manager, Audits
M. Saniuk, EQ Cognizant Engineer
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- A. Shepard, Director of QA
J. Thayer, Engineering Manager
1.3 DiBenedetto Associate
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- P. DiBenedetto, President
1.4 Vermont Public Ser.vice Department
P. Paull, Nuclear Engineer
1.5 United States Nuclear Regulatory Commission
C. Anderson, Acting Chief, Engineering Branch, DRS
G. Grant, Senior Resident Inspectors
- Denotes those not present at the exit meeting at the Vermont Yankee
Corporate office on October 23, 1987.
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2.0 Parpose
The purpose of this inspection was to review the' licensee's implementation
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of a program to meet the requirements of 10 CFR 50,49 for Vermont Yankee
Nuclear Fower Station and their implementation of corrective action com-
mitments resulting from deficiencies identified in the Franklin Research
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Center Technical Evaluation Report (FRC-TER).
3.0 Background
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On February 8,1979, the NRC Office of Inspection and Enforcement (IE)
issued to all licensees of operating plants, (except those included in
the Systematic Evaluation Program (SEP)), IE Bulletin (IEB) 79-01,
"Environmental Qualification of Class IE Equipment."
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On January 14, 1980, the NRC Issued IEB-79-01B which included DOR Guide-
lines and NUREG-0588 as attachments 4 and 5, respectively.
Subsequently
on May 23, 1980 Commission Memorandum and Order CLI-80-21 was issued
and stated that the DOR Guidelines and portions of NUREG-0588 form the
requirements that licensee must meei regarding environmental qualification
of safety related electrical equipment in order to satisfy those aspe.ts
of 10 CFR 50, Appendix A, General Design Criterion (GDC) 4.
Supplements
to IEB-79-018 were issued for further clarification and definition of the
staff's needs.
These supplements were issued on February 29, September 30
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and October 24, 1980.
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A final rule on the environmental qualification (EQ) of electrical equip-
ment important to safety for nuclear power plants became effective on
February 22, 1983. This rule, Section 50.49 of 10 CFR Part 50, specified
requirements of electrical equipment important to safety located in a
harsh environment.
In accordance with this rule, electrical equipment
for Vermont Yankee may be qualified to the criteria specified in either
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the D0R Guidelines or 10 CFR 50.49, except for replacement equipment.
Replacement equipment installed subsequent to February 22, 1983 must be
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qualified in accordance with the provisions of 10 CFR 50.49, using the
guidance of Regulatory Guide 1.89, unless there are sound reasons to the
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contrary.
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On April 18, 1984, a meeting was held to discuss Vermont Yankee's pro-
posed method to resolve the environmental qualification deficiencies
identified in the April 11, 1983 Safety Evaluation Report (SER) and
February 17, 1983 FRC-TER.
Discussions also included Vermont Yankee's
general methodology for compliance with 10 CFR 50.49, and justification
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for continued operation for those equipment items for which environmental
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qualification was not yet completed.
The minutes of the meeting and pro-
posed method of resolution for each of the environmental qualification
deficiencies are documented in the April 11, June 29, July 10,15,19 and
August 10, 1984 submittals from the licensee.
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A safety evaluation report on environmental qualification of electrical
equipment important to safety was issued on December 12, 1984, describing
the licensee's proposed resolution of identified deficiencies in the TER.
The SER concluded that Vermont Yankee's electrical equipment environmental
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qualification program complies with the requirements of 10 CFR 50.49.
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The Vermont Yankee EQ Program Manual (EQPM) establishes the EQ require-
ments for the Vermont Yankee plant.
The following information specific
to the Vermont Yankee plant is included in this EQPM:
a)
Administration of the EQPM, including preparation, review and
approval of the EQPM sections; distribution and revision of the
manual,
b)
Vermont Yankee EQ program scope, including Vermont Yankee's
objective and its approach to the EQ issues, such as the EQ impact
on overall plant safety and-reliability, and on the operational
maintenance burden for plant staff; ALARA and human factors
consideration,
c)
EQPM organization, including plant maintenance and surveillance
program, and description and location of major EQ documents.
d)
Use of the EQPM, including how to determine a component's
qualification (the EQ process), and how to trace a components
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qualification documentation trail,
e)
EQ methodology - including master equipment list (MEL) development;
failure moce and effect analysis (FMEA) development; determination
of environmental conditions, such as radiation, temperature, pressure
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and humidity environments; field verification and maintaining equip-
ment quali fication status,
f)
Historical overview - discussion of historical development of EQ
requirements, including IE Circular 78-08 and IE Bulletin 79-018.
g)
Electrical component matrix - this matrix lists the equipment
by tag number, functional system, functional service, equipment
location, and the postulated design basis events (D8E).
h)
Master equipment list - this list identifies the equinment by ID
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number, equipment manufacturer, model number, qualification status
and qualification basis, and the EQ file number.
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Plant environmental conditions - this section documents how the
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environmental conditions (both normal operating conditions and DBE
conditions) were derived,
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EQ file preparation - this section documents the guidance and rules
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for completing the EQ files, including thermal aging calculation,
system component evaluation worksheet (SCEW) preparation, submergence
consideration, qualification margins, and consideration of IE
bulletins and Information Notices.
To supplement the EQPM, an individual Qualification Document Review (QDR)
package is provided tu support the qualifi;etion of each equipment type
within the scope of 10 CFR 50.49. Each 00R consists of 7 sections (tabs).
The tabs contain a summary of the qualification of the equipment, including
equipment qualification assessment and equipment description, the SCEW
sheets of the equipment, the references to the qualification test reports,
discussion of the qualification parameters, the installation and maintenance
requirements, equipment traceability (e.g., procurement documents and
certificate of compliance) and QA documentation, the qualification test
report and other qualification documents which ;re used to support the
equipment qualification.
The inspectors reviewed the latest revisions of the EQPM (various revisions
and dates for various sections) and twenty QDRs and found that the documents
are organized in a logical manner and that the materials contained therein
are auditable.
Based on the above, the inspectors concluded that the licensee has implemented
a program that meets the requirements of 10 CFR 50.49 for environmental
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qualification of electrical equipment for those portions audited except
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for the deficiencies identified in the Inspection Summary.
5.0 EQ Master List
Section 5.3 of Vermont Yankee EQPM prescribed the methodology for the
development, control, update and issue of the EQ Master list (EQML) for
Vermont Yankee.
Considered in the preparation of the EQML by the licensee
was the review of the Final Safety Analysis Report, emergency operating
procedures, shutdown sequence diagrams, flow diagrams, electrical control
wiring diagrams and failure modes and effect analysis for the equipment
that is located in a harsh erwironment which requires qualification.
The EQML appears in Sedtion 6 of the EQPM. The inspector reviewed
revision 5 of the EQML, dated November 21, 1986.
The EQML identifies
each item of equipment by ID number, Manufacturer and Model number,
qualification status and qualification levels (i.e., DDR Guidelines or 10 CFR 50.49) and the EQ file number, which is used to support qualification
of the equipment,
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The inspectors verified the completeness of the E' ML by selecting specific
components from Vermont Yankee alectrical control wiring diagrams (800
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series) of the Reactor Protection System, and checking them against the
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EQML. No deficiencies were identified.
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6.0 IE Bulletins and Information Notices
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The inspectors reviewed Section-8, paragraph 8.2.9, of the Vermont Yankee
EQPH titled "Demonstrating Component's Environmental Qualification".
This
section stated that during the qualification review of specific components
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Vermont Yankee staff considered known deficiencies reported in NRC Information
Notices and Bulletins.
Specific references to those Notices and Bulletins
that were available at the time of the Qualification Documentation Review
(QDR) package preparation were included in the summary section of the QDR.
The inspector verified that applicable Information Notices and Bulletins
were included in the qualification data packages.
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The inspector reviewed Administrative Procedure A.P. 0028 titled
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"Operating Experience Review and Assessment / Commitment Tracking."
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Revision 7, dated May 5,1987. This procedure identifies organiza-
tional responsibilities for the review of information important to plant
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safety, defines and tracks the course of action resulting from reviews,
and provides a mechanism for documenting that such actions are accom-
p11shed in an efficient and timely manner by appropriate plant personnel.
This procedure specifies that information resulting from these reviews
be incorporated when applicable into plant procedures and training pro-
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grams and establishes periodic internal audits of the review process to
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ensure its proper implementation, and provides an effective tracking
mechanism for plant commitments.
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The inspectors randomly selected six Information Notices and reviewed
Vermont Yankee's action as annotated on Vermont Yankee's operating
experience information review forms (VYAPF 0028.01/.02/.03) for each
Information Notice. The inspector also reviewed Vermont Yankee's tracking
system which shows the current status of all Information Notices.
The inspectors concluded that appropriate actions were taken by Vermont
Yankee staff for each Information Notice selected for review,
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7.0 QA/QC Interfaces
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The Yankee Atomic Quality Assurance Audit Group is responsible for con-
dccting audits to verify the licensee's compliance to the EQ requirements
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set forth in 10 CFR 50.49 and the Vermont Yankee QA Program Manual.
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inspector reviewed the licensee's QA audit report VY-86-19, Environmental
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Qualification of Electrical Equipment, conducted March 31-April 4,1986.
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The audit was performed in accordance with YAEC QA Plan 0QA-XVIII-2, for
Qualification Documentation Review Packages, and EQ related training for
the project personnel of Yankee Atomic Corporate Engineering Service
Division at Framingham; and reviewed the EQ related maintenance and sur-
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veillance program, and EQ related training of the plant personnel at
Vermont Yankee Nuclear Power Station. The audit identified three defi-
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ciencies relating to:
(i) control of vendor manual used for equipment
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maintenance, (ii) revision control for the EQ program manual and QDRs, and
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(iii) failure to address test anomalies in the QORs. As a result, the
licensee issued a Plant Position report and incorporated the Manager of
Operation (M00) implementation directive to-implement corrective actions.
The inspector reviewed the records of these activities and verified that
the licensee properly resolved the audit concerns and implemented the
corrective actions in a timely manner.
During the initial phase of.the EQ program implementation the licensee
contracted the services of DiBenedetto Associates, Inc. to conduct a
third party audit in December, 1984 to assess the licensee's EQ program.
The audit focust 3 on three major areas:
(i) regulatory requirements,
(ii) Vermont Yankee commitments, and (iii) tangible evidence of the envi-
ronmental qualification of the required plant equipment.
The audit re-
viewed 47 Vermont Yankee EQ program documents, including 12 00Rs. The
audit identified several deficiencies ranging from the use of an inap-
propriate approach for calculating thermal aging to missing test reports.
The audit results also indicated that the licensee had not established a
formal EQ program, and as such, preparation of the EQ Master List and
accident scenarios were_not controlled. Subsequently, the licensee
established an administrative control for the preparation, review and
approval of EQ documentation and qualification of the station equipment.
Subsequently, the licensee conducted another QA audit VY-85-19 on
November 4-11, 1985, to followup the findings of the DiBenedetto audit.
The report of this audit indicates that all findings were properly
resolved in a timely manner.
The Yankee Atomic Onlity Assurance staff at the Vermont Yankee Nuclear
power Station is responsible to conduct quality assurance surveillance
activities in accordance with QA Procedure 00A-X-1, Quality Assurance
Surveillance. This precedure delineates administrative control for
planning, implementing, reporting and resolving nonconformances and
deficiencies identified during the QA surveillance activities.
The
program is an intermediate level of activity between the inspector
and audit functions. A cognizant QA engineer performing the Surveil-
lance initiates a surveillance report.
The discrepant items are tracked
through "Close-Out" utilizing a surveillance item status report (SISR).
The QA engineer has been delegated with the authority to "Stop Work" as
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delineated in the licensee's QA Plan YOQAP-1-A. Any significant condition
adverse to quality and identified as escalated corrective actions are
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forwarded to the upper management through Management Action Report (MAR).
The QA department trends the surveillance activities in accordance with
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the Trending Program Procedure Q-122.
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During the Calendar year, the QA surveillance group conducted three EQ
related surveillances to independently verify the adequacy and effective-
ness of the' activities performed by (i) maintenance group (Surveillance
Report 87-127), (ii) I&C group (Surveillance Report 87-121).
These were
conducted in 1987. Within the scope of these surveillances, the QA sur-
veillance staff determined that the maintenance and surveillance require-
ments were accurately delineated in the QDRs; and specific replacement
parts and preventive maintenance were incorporated therein to maintain
equipment operability.
EQ files were referenced in applicable maintenance
and surveillance procedures, the Equipment History Cards were properly
maintained and the surveillance program did not identify any significant
EQ related problems.
Within the scope of this review, the inspectors did not identify any
deficiencies.
8.0 EQ Maintenance Program
The inspectors reviewed the licensee's EQ maintenance program to determine
the adequacy and effectiveness of the licensee provisions for preserving
the qualified status of the station equipment in accordance with the
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requirements of 10 CFR 50.49.
Administrative Procedure AP-0200, Maintenance Program, Revision 11, dated
July 1,1987 delineates the maintenance department program for maintaining
the plant safety-related and/or environmentally qualified equipment at the
quality level required to perform its intended safety functions.
The
major features of the program are:
(i) records system, (ii) preventive
maintenance, (iii) corrective maintenance, and (iv) maintenance planning
and administration.
The maintenance records system (Visi-Record Cards)
provides for scheduled and non-scheduled maintenance and repair activities
performed on the equipment in the plant and documented on the preventive
maintenance work order form.
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Administrative Procedure AP-0021, Maintenance Request, Revision 15,
dated August 17, 1987 provides for handling plant equipment malfunctions,
performing corrective maintenance, and documenting the repair efforts.
The maintenance supervisor is responsible for planning and coordinating
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the maintenance activities with other plant departments. The maintenance
records are maintained under the cognizance of the senior maintenance
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engineer, who also reviews the machinery records and maintenance trending
files for significant trends. Any equipment determined to exhibit
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unsatisfactory reliability is submitted to the maintenance supervisor
for evaluation and implementation of corrective action.
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Administrative Procedure AP-305, I&C Department EQ Maintenance and
surveillance program, Revision 1 dated October 11, 1985, provides guid-
ance and establishes a mechanism for the I&C department to maintain
qualification of the instruments, and delineates responsibility for
establishing and maintaining the maintenance and surveillance program.
The lac supervisor has overall responsibility and general oversight of
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the station equipment maintenance and surveillance program. Maintenance
and update of the equipment maintenance and surveillance files is con-
ducted under the cognizance of an I&C coordinator.
The I&C foremen and
specialists are responsible for the review of the maintenance requests
and assuring that the maintenance activities are performed in conformance
with the station maintenance and-surveillance procedures including EQ
requirements.
The inspectors discussed the station EQ maintenance program with the
cognizant electrical, mechanical maintenance and I&C maintenance and
surveillance personnel, and reviewed the following completed maintenance
work request oackages:
MR 87 0687 for Cable for TE-16-19-41.
MR 87 1132 for CAD Isolation Valve, VG-22A.
MR 87 1139 for RCIC Isolation Valve, V13-16.
MR 87 1150 for Load Shed, Relay MCC 98.
These packages were found to have adequately described the associated
equipment problems; the work requests were reviewed for EQ concerns; and
the maintenance was performed, inspected, tested, and accepted by opera-
tions in accordance with the station procedures.
The related maintenance
procedures were also reviewed and found to have included attributes to
provide assurance that the EQ requirements were factored into these
procedures.
Based on the review of the maintenance procedures and maintenance work
activities, the inspectors determined that, for the portions reviewed, the
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licensee's EQ maintenance program was adequate.
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9.0 EQ Training Program
The engineering support department training procedure DP-0082 delineates
the licensee's training program to provide, maintain and upgrade the
training and qualification status of the personnel performing safety-related
design, modification review and approval, including EQ related activities.
This procedure implements the intent of the licensee's Administrative
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Procedures AP-0011 entitled "Environmental Qualification Document Review
Instruction," and AP-0013 entitled "Replacement of Environmentally Quali-
fied Electrical Equipment."
The station maintenance department supplemented the INPO accredited Plant
Mechanics Training Program Description by instituting AP-0200 entitled
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"Maintenance Program," in the curriculum to provide EQ related training to
the plant maintenance personnel.
The station I&C Department Training and
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Retraining Procedure, DP-0303, provides the means to ensure that I&C
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personnel receive proper training for their job activities, including the
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environmental qualification of the electrical equipment.
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The licensee and the contracted consultants have conducted several EQ
related training and indoctrination classes for the engineering support
personnel and the station operations, and maintenance personnel. The
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Raychem Heat Shrink Tubing manufacturing company also conducted proce-
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dural and "hands-on" installation training on EQ related Raychem Heat
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Shrink cable splicing-and terminations for the licensee cognizant person-
nel. Several of the licensee Key EQ personnel were found to have parti-
cipated in other EQ courses and Seminars sponsored by outside agencies,
such as Wyle Laboratories, EPRI and American Nuclear Society.
The train-
ing records and the discussions with selected personnel performing quality
control EQ activities, indicated that they were conversant with the
regulatory requirements of 10 CFR 50.49, other related NRC Information
Notices such as 86-53 and 86-03, and industry's- standards.
The inspectors also reviewed the EQ related training program given to
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station personnel performing maintenance activities.
These individuals
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were adequately trained and indoctrinated to conduct EQ related mainte-
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nance as required by the station procedures.
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Based on the above, the inspector determined that the licensee had
established and implemented an EQ training program.
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10.0 EQ procurement Procram
The licensee has separate procedures controlling EQ equipment replacement
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and procurement at the station and at the corporate office. Operations
Support Department procedure VY-0SD-102, Revision 2, "Review of Safety
Related Purchases" is the station procedure that provides instructions for
the procurement of all safety related equipment including EQ equipment.
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Material and Service Purchase requests are reviewed using this procedure.
This procedure assigns the Operations Support Engineer the responsibility
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for invoking all the quality assurance and other technical requirements.
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The procedure contains a mandatory check list to be filled in for EQ
equipment.
This list itemizes various EQ standards for NUREG 0588 category
I equipment, and the need to reference a qualification test report and
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other related documents.
If the operations support engineer feels the
need for an additional review, the procurement data is forwarded to Yankee
Nuclear Services Division (YNSD).
Usually all procurements that contain
EQ equipment are forwarded to YNSD for a detailed review.
Procurement activity at the corporate office is governed by Administrative
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procedure A.P. 0013 entitled "Replacement of Environmentally Qualified
Electrical Equipment." This procedure provides specific guidelines for EQ
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replacement equipment.
This procedure applies to all corporate engineers
that perform EQ procuren ent.
The licensee followed RG 1.89, Revision 2, for
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evaluating the EQ requirements on replacement equipment.
Procedure
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VYP:317 dated September 25, 1987, entitled "Purchase Order Processing
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Procedure" is used to track the MSPRs and to assure inclusion of reviews
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.of EQ related purchases in/ the operations support department and by YNSD
as needed. The safety classification section of the MSPR has a block to
be checked to identify "EQ Required". This identification further assures -
adequate attention to EQ attributes.
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The inspectors selected the following purchase orders for review:
P.O. 27761
Namco Limit Switches
P.O. 30461
Master Trip Card for Rosemount Transmitter
P.O. 30243
Miscellaneous Rosemount Transmitter parts
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P.O. 32582
Raychem splices
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P.O. 31012
Raychem splices
P.O. 27765
Rockbestoes wires
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P.O. 28096
Non EQ
P.O. 28567
Non EQ
P.O. 27366
Non EQ
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The above samples included some purchase orders that did not have any EQ
procurement requirements.
These were reviewed to ensure that the applica-
tions for these devices were not included in the EQ program. The purchase
orders that dealt with EQ equipment did have sufficient requirements
invoked into the purchase orders.
This was accomplished through compitance
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to the EQ test reports, IEEE standards or other specific requirements.
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The control and handling of EQ equipment in the warehouse is accom-
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plished as follows.
The EQ equipment parts are uniquely identified in
the warehouse. Administrative procedure 0806, Revision 5 entitled
"Issuing and Returning of P3terial Parts and Components" provides special
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instruction for the control of EQ parts.
The inspectors verified
Rosemount parts procured under Purchase Orders 23021, 22116, 22237, and
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22300 to verify that the EQ components are uniquely identified and that
the shelf life has not expired where applicable. Administrative procedure
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A.P. 6015 Revision 0 en+1tled "Receipt Inspection of Safety Class or
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Safety Related Materials" has specific instructions for establishing an
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approved EQ test report. The typical check list in this procedure for
receipt inspection is supplemented as needed for augmenting any additional
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EQ requirements.
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Within the scope of this review, no deficiencies were identified.
11.0 Control of EQ Related Plant Modifications,
The licensee has two Administrative procedures that govern the plant
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modifications. The plant uses AP 6000 Revision 12, entitled "Plant Design
!
Change Request" (PDCR) for processing all modifications to safety related
components including EQ equipment. The YNSD procedure for the same func-
'
tion is AP 6004, entitled "Engineering Design Change Requests". An
,
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- .. ._ -
. .--
.
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.
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.
.
13
.
appendix to the PDCR procedure includes 15. design inputs and one of them
deals with EQ requirements.
It addresses the Qualification Documentation
Review Sheets, walk-down data and the supporting documents for establish-
ing qualification.
These documents become a part of the PDCR and are
subjected to a multi-disciplinary review.
The YNSD organization utilizes specification YA-GEN-11 Revision 1,
entitled "Design guidance for Environmental Qualific tion of Electrical
a
Equipment" for plant modification. This specification provides detailed
guidance for the inclusion of EQ requirements into plant modifications,
It addresses the upgrade requirements of 10 CFR 50.49 and the bases for
qualifying equipment.
These procedures are further supplemented through Engineering Instructions.
The following are some of the instructions that address EQ requirements:
WE-100, Revision 14, Engineering Design Change Request
WE-104, Revision 4,
Qualification tests
WE-107, Revision 8,
Specifications.
These instructions form a part of the Engineering Manual which applies to
plant modifications. The documents generated by the site organization
and YNSD are reviewed by each other for technical adequacy including EQ
concerns. The inspectors selected the following modification psckages
for review:
EDCR-85-405 and Revision 1, for replacement of pressure switches on
High Pressure Coolant Injection System, Static 0 Ring
TA Series.
EDCR-84-429, for transmitter upgrade to Rosemount 1153B - RG 1.97
Commitment.
EDCR-84-430, for replacement of torus air space temperature sensor.
EDCR-84-417, for Cable Replacement for Reactor Core Isolation Cooling
System.
The above modifications were completed during the 1986 plant outage.
No
JCOs were required because the plant was shut down from September 1985
until June 1986.
The inspectors observed 3 completed equipment replacements for compliance
i
to EQ requirements and did not identify any deficiencies.
Even though the EQ function is not performed by a dedicated group, the
EQ requirements were sufficiently addressed in these modification
packages. The revisions to the Master list, EQ files, qualification
documentation etc., were included in the above modification packages,
i
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_ _ _ _ _ _ _ _ _ _ _
_
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14
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Within the scope of review of the plant modification activities, no
deficiencies were identified.
'12.0 Detail Review of EQ Files
The licensee's EQ files were examined to verify the qualification 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 basis for these conditions, the inspectors selectively reviewed areas
such as required post-accident operating time compared to the duration of
time the equipment has been demonstrated to be qualified;' similarity of
tested equipment has been demonstrated to be qualifted; similarity of
tested equipment to that installed in the plant (insulation class, compo-
nent materials, test configuration versus installed configuration and
documentation for both); evaluation of adequacy of test conditions, aging
calculations for qualified life and replacement interval determination;
effects of decrease in insulation resistance on equipment performance;
adequacy of demonstrated equipment accuracy; evaluation of test anomalies;
and applicability of EQ problems reported in IE Bulletins and Information
Notices and their resolutions.
The inspectors reviewed twenty EQ files. The types of equipment covered
by these files included areas such as electrical cables, terminal blocks,
Limitorque valve operators, limit switches, solenoid operated valves,
pressure transmitters, pressure switches, cable splices, and radiation
detectors. An equipment type is defined as a specific type of electrical
equipment, designated by manufacturer and model, which is representative
of all identical equipment in the plant area exposed to the same or less
severe environmental service conditions.
The following deficiencies were
identified:
12.1 Cerro Ep/Hypalon Cables (QDR 6.15)
This type of cables is used for power distribution at various ele-
vations in the reactor building.
The cable sizes vary from 14 AWG
to 350 MCM,
The minimum insulation thickness of these cables is 30
mils. Rockbestos test report QR No. 1804 A indicales that a 12 AWG
single conductor with 30 mils insulation was tested by the manufac-
tu re r.
The test profile does envelope the required profile.
The
licensee ralied solely on this report (QR No.1804 A) to support the
cables qualification at the time of the inspection.
However, this
report is considered invalid by NRC to support equipment qualifica-
tion because of deficiencies stated in IE Information Notice 84-44,
which was issued to the licensee on June 8, 1984.
Information Notice 84-44 Summarized sore of the deficiencies as a result of
several NRC audits on Rockbestos test program.
Four of the eight
deficiencies are as follows:
_____ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
.
15
.
a)
The Rockbestos Company did not establish and implement a QA
program in accordance with 10 CFR Part 50, Appendix 8 require-
ments to control Rockbestos EQ testing; i.e... the EQ program
was controlled by a Rockbestos engineering organization which
was not under a QA program until 1983.
b)
Test equipment was not properly calibrated or under the control'
of the calibration system. An internal Rockbestos audit dated
May 10, 1983, documented these generic deficiencies in their
calibration system,
c)
A number of test deficiencies, deviations, and other anomalies
were not documented and evaluated in the test reports.
d)
As a result of inadequate QA controls, testing and the required
documentation were not properly controlled.
Several discrep-
ancies between final qualification reports and supportin] test
data were found.
No further evaluation of this report was found in the EQ file at
the time of the inspection.
During the week of the inspection, the
licensee was able to obtain a Franklin test report (No. F-C3798)
dated March 1974, which documents the qualification tests of four
samples of cables manufactured by Cerro.
This report demonstrates
that Cerro EP cables are qualifiable. However, this report was not
used at the beginning of the inspection to support the cables' quali-
fication.
The inspectors concluded that qualification of this type
of cables was not established at that time. This constitutes a
violation of 10 CFR 50.49 paragraphs (f) and (g) which require that
each item of electrical equipment important to safety be qualified
and that qualification must be completed at a time no later than
November 30, 1985 (50-271/87-19-01).
12.2 Rome (Cyprus) XLPE/PVC Power and Control Cables (QDR No. 6.14)
This type of cable is used both inside and outside the drywell for
power and control,
The qualification basis was the D0R Guidelines.
The file referenced a Franklin Test Report F-C 3016 to support the
cables' qualification. The referenced test did not envelope the
plant conditions. The peak temperature for the test was 303 F for
four hours while the plant required 325*F for three hours.
-
,
%
.
16
I
.
.
The licensee attempted to use test reports of cables made by other
,
manufacturers to show that the plant conditions were enveloped. The
Brand Rex test had an accumulated time of Sh hours at 350 F.
The GE
,
Vulken Supreme SIS cable test had approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at 335 F
,
and the Rockbestos test had an accumulated time of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> at 340 F.
f
The submittal from the licensee on January 27, 1988 indicates that
,
these tests enveloped the plant conditions. However, at the time of
the inspection, the EQ file did not contain sufficient information to
,
show similarity between the cables installed at Vermont Yankee and
i
the cables manufactured by other companies, e.g., a comparison and
evaluation by the licensee of manufacturing tolerance variation (if
any), exact chemical composition, whether the insulation material is
- -
chlorinated or non-chlorinated, electrical properties of the insula-
tion and jacket materials, etc. These are considered essential
because it is the electrical behavior of the electric cable in severe
steam environment that is to be demonstrated. As an example, both GE
Vulken cable and GE Vulken Supreme cable are insulated with chemical-
ly XLPE. The qualification of GE Vulken Supreme cable has been
.
demonstrated while the qualification of GE Vulken cable has not.
As stated previously, qualification data for several cables were used
in an attempt to establish qualification for the peak temperature.
It was later determined by the licensee that all but one of the
'
valves powered by this type of cables would complete the safety
function shortly after a DBA.
For the time required for these com-
ponents to operate, the DBA erivironment can be shown by the licensee
,
'
to be enveloped by the type test report F-C 3016; that is, the
components function in an environment less severe than that demon-
i
strated by test report F-C 3016.
!
'
The other valve was not required to operate until 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after a
small break LOCA. After that time this component must operate.
,
Then the environment has returned to 222 F.
This is well below the
peak temperature demonstrated by test report F-C 3016. However,
this data was not documented in the EQ file at the time of the
inspection.
i
The licensee selected 00R Guidelines (10 CFR 50.49 paragraph k) as
j
the basis for qualification.
Paragraph 5.2.1 of the 00R Guidelines
'
requires that the test conditions envelope the plant required condi-
tion, and paragraph 5.2.2 requires similarity analysis to evaluate
4
'
any differences in design and material construction for the test
specimen and the installed equipment. The inspector concluded that
qualification of the Rome cables was not established at the time of
the inspection. This is a violation of 10 CFR 50.49.k and 10 CFR 50.49 9 which require electrical equipment important to safety be
,
t
qualified and that the qualification be completed at a time no later
!
I
than November 30,1985(50-271/87-19-02).
However, based on the data
furnished by the licensee during and after the inspection, the
inspectors corcluded that the licensee would be able to establish
,
qualification of this cable for the application at Vermont Yankee.
(
2
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17
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-12.3 Lewis PE/PVC Instrumentation Cables (QDR 6.27)
The qualification basis for these cables was the D0R Guidelines.
The EQ file indicated that the cables were to be used both inside and
outside the drywell.
Later, in a discussion with the licensee, it
was learned that the EQ file mistakenly stated that the cables were
to be used inside the drywell.
The EQ file was corrected to show
that the cables are only used in the reactor building which is
outside the drywell in a less harsh environment. The EQ file in-
cludes a test report for a PE/PVC Cable, and Ebasco specifications
No. VYNP-IV-C-1.
The report did not identify the cable manufacturer,
therefore, it could not be determined that the tested cable was the-
same type as the installed cables. There was no analysis in the EQ
file to evaluate the similarity and differences between the installed
cables and the test cable.
In reviewing the test results, the inspectors noticed that the test
temperature profile did not envelope the required temperature profile
as defined in the EQ file for outside-drywell environment.
Following the inspection, on November 5, 1987, the licensee trans-
mitted additional information to NRC to support the qualification
of the Lewis Cables. The licensee used a Wyle test report
(No. 45917-40-1) which documented a type test for Simplex PE/PVC
cable. This report was not available for NRC review. The licensee
also provided comparison between these two types of cables, and
that based on the test data, the Lewis cable is qualifiable.
The licensee selected DOR Guidelines (10 CFR 50.49 paragraph k) as
the basis for qualification.
Paragraph 5.2.1 of the D0R Guidelines
requires that test conditions envelope the plant required conditions.
The inspector concluded that qualification of the Lewis cables was
not established at the time of the inspection. This is a violation
of 10 CFR 50.49.k and 10 CFR 50.49.g which require that electri-
cal equipment important to safety be qualified and that the qualifi-
cation be completed at a time no later than November 30, 1985.
(50-271/87-19-03) However, based on the data furnished by the licensee
during and after the inspection, the inspector concluded that the
licensee would be able to establish qualification of this type of
cable for the application at Vermont Yankee.
l
12.4 3M Tape Splices (QDR 16.1)
The qualification basis of these tape splices was 00R Guidelines.
The EQ file indicates that the 3M splice is made up of Scotch 23 tape
for a thickness of 3/16 inch, plus two half-lapped layers of Scotch
,
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,
,
18
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.
88 covering. The overlapping requirement of the splicing tape onto
the cable insulation is not addressed. The licensee attempted to
qualify this splice by means of similarity to Okonite T-95 tape for a
thickness of 5/16", plus one half-lapped layer of Semicon tape and
three half-lapped layers of Okonite 35 tape covering. The file
contains a statement that both Scotch tape _and Okonite tape are made
of ethylene propylene rubber (EPR).
_
The SCEW sheet in the EQ file indicates that the 3M tape splices are
located in the Reactor Building outside the drywell and subject to a
steam environment as defined by the licensee's temperature profile
TE-1 (268*F for 7 minutes followed by a reduced temperature of 215 F
for 3 minutes, then gradually decreased to 125*F~in 30 minutes).
Based on the above, the inspector concluded t'at similarity between
r
3M tape splice and Okonite tape splice is not justified and quali-
fication of 3M tape splice was not established at the beginning of
the inspection.
This is in Violation of 10 CFR 50.49 paragraphs g
and k, which require that electrical equipment important to safety be
qualified (00R Guidelines) and that the qualification be completed at
a time not later than November 30, 1985.
(50-271/87-19-04).
During the week of the inspection, the licensee provided additional
information to the inspectors stating that out of the 13 valves which
use 3M tape splices, only 2 valves (MOV-10-39A and MOV-12-18) are
required to function during a high energy line break (HELB) outside
the drywell.
The remaining 11 valves are for LOCA (inside drywell)
function only. Therefore not required to be qualified for a steam
environment.
The 2 valves required to function during the HELB are subject to peak
temperatures of 206*F and 213 F, but the temperature reduces to 190 F
in 10 minutes and to ambient conditions in one hour.
In addition,
during the week of the inspection, the licensee obtained a letter
from Wyle Laboratories dated October 21, 1987, stating that Wyle
Laboratories had completed a test of 3M tape splices. However, the
test report was not available for NRC review.
Based on this infor-
mation, the inspector concluded that the 3M tape splices are
qualifiable.
12.5 General Electric EB-5 Terminal Blocks (00R 17.4 A)
The qualification basis of these terminal blocks was the D0R
Guidelines. These terminal blocks are used in the Reactor Building,
potentially subject to a post-accident steam environment as tabulated
below (obtained from the EQ file):
'
. ._
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
l
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19
.
Duration After A_ccident
Step
Temperature (F)
Beginning
End
Duration
1
275 (408 K)
0 Minutes
10 Minutes
10 Minutes
2
200 (366 K)
10 Minutes
1,000 Minutes
990 Minutes
3
175 (352 K)
1,000 Minutes
2,000 Minutes
1,000 Minutes
4
150 (339 K)
2,000 Minutes
6,000 Minutes
4,000 Minutes
4
4
5
125 (325 K)
6,000 Minutes
3.5x10 Minutes 2.9x10 Minutes
4
5
6
100 (311 K)
3.5x10 Minutes
360 Days
4.8x10 Minutes
The required operating time is 7 days. The licensee used Limitorque
test report B0119 to support the qualification of the EB-5 terminal
blocks. This test report indicates an insulation resistance (IR)
value of 2x10' ohms at the end of the third hour and 500 ohms at the
end of the 4th day. Since no measurements were recorded between the
4th hour and the 4th day, the IR value during that pcriod could be as
low as 500 ohms.
The above table indicates that at the 16th hour (960 minutes) after
the accident, the temperature is still 200 F, which still has a
detrimental effect on the terminal block IR.
Low IR values can cause
transmitter circuits to malfunction.
For example, even with an IR
value of 1000 ohms, and for the lowest instrument power supply
voltage of 24 volt, the leakage current for the terminal block alone
will be 24 ma, which is higher than the transmitter output range of 4
to 20 ma if a 4-20 ma transmitter is used.
This leakage current is
also significant even if a 10-50 ma transmitter is used.
The
inspectors concluded that the Limitorque test report (B 0119) did not
demonstrate the qualification of the EB-5 termir.a1 blocks.
Also included in the EQ file is a copy of GE CR ;51B terminal block
test report.
The licensee maintained that the ma'.erial used for both
the EB-5 terminal blocks and CR 151B tertainal blocks were essentially
the same (GE phenolic), and that the terminal bloct dimensions for
both were similar. However, there was no similarity analysis to
identify and evaluate the electrical properties in the construction
of these two types of terminal blocks.
Since the principal function
of the EB-5 terminal blocks is for electric circuits and low IR value
is the concern, proper analysis and evaluation of electrical properties
are considered important to support the qualification of the EB-5
terminal blocks.
During the week of the inspection, the licensee obtained a memorandum
from General Electric Company dated October 22, 1987.
This memo
identified various electrical properties of EB-5 phenolic and CR-1518
phenolic.
The data in this memorandum indicates these two "phenolics"
are similar.
.
20
.
Following completion of the inspection, the licensee transmitted
additional information to NRC stating that the EB-5 terminal blocks
as installed at Vermont Yankee would be subject to a harsh environ-
ment for oniv 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, after that the temperature drops to 100 F.
However, this information was not in the EQ file at the time of the
inspection.
The inspector concluded that the qualification of EB-5
terminal blocks was not established at the time of the inspection.
This is a violation of 10 CFR 50.49 paragraphs (k) and (g) which
require electrical equipment important to safety be qualified
(00R Guidelines provisions) and that qualification must be completed
at a time no later than November 30,1985(50-271/87-19-05).
How-
ever, based on the information supplied by the licensee, the inspectors
concluded that the EB-5 terminal blocks are qualifiable as they are
used at Vermont Yankee.
12.6 Dings Brakes in Limitorque Valve Actuators (QOR 3.1)
During the review of the Limitorque valve actuator EQ file, the
inspectors noticed that the radiation qualification for the Dings
brakes installed at Vermont Yankee was not addressed adequately.
Specifically, the licensee's demonstration of qualification consisted
of a Certification of Compliance from Limitorque stating "the brake
coil materials would be equivalent or superior to the brake motor
included in Limitorque Qualification Report 600198.
The capability
of the motor and brake coil to withstand radiation only can be supported
by Qualification Report 600376A." Qualification Report 600193 did
not include a radiation test. The Reliance motor tested, as documented
in Qualification Report 600376A, was not equipped with a brake.
There
was no other analysis (except a statement from the vendor that both
the Reliance motor tested in Report 600376A and the brake coil installed
at Vermont Yankee used Class H insulation) to justify the radiation
qualification of the Dings brake at the time of the inspection.
The
inspectors concluded that at the time of the inspection, the qualification
of the Dings brake was not established.
This is in Violation of 10 CFR 50.49 paragraphs (f) and (g) which require that electrical equipment
important to safety be qualified and that qualification must be completed
at a time no later than November 30, 1985.
(50-271/87-19-06)
Subsequent to the inspection, on November 5, 1987, the licensee
submitted to the NRC additional qualification data to support the
radiation qualification of the Dings brake.
The licensee listed the
material composition of the Dings brake and the threshold dose of
each material as follows:
.__
. _
_ _ _ _ - _ _ _
_ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - .
.
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Component
Material
Threshold Dose
j
. Magnet Wire; Insulation
Pyre ML
200 MR (Joy X-604)
Crossover Barrier
Pyre ML-Coated Glass
330MR(NP-2129)
>
Fabric
,
Lead Wire
NOMAX, Glass-Braided
330 MR.(NP-2129)
Belden 30718
Core Liner
Pyre ML-Coated Glass
330 MR (NP-2129)-
l
Fabric
.!
Outer Wrap
.007 Thick Glass Tape
100 MR (NP-1558)
Final Coat
Dow Corning 997 Varnish
500 MR (REIC-21)
!
All threshold values exceed the 80 MR required at Vermont Yankee.
The inspectors concluded that the Dings brake is qualifiable,
j
13.0 Plant Physical Inspection
The NRC inspectors conducted a physical inspection on October 21, 1987 of
EQ components in the Reactor Building and the Turbine Building, and at
various elevations. No items were selected in the drywell because of its
'
inaccessibility during plant operations.
Items selected for examination
I
included Limitorque valve operators, limit switches, solenoid operated'
'
valves, pressure transmitters and pressure switches, cables and cable
,
splices, and terminal blocks.
!
The inspectors examined characteristics such as mounting configuration,
orientation, connection interfaces, medel and instrument type, cleanliness.
and physical condition.
The following findings were identified
,
13.1 Limitorque Motor Wire Connectors
l
!
The inspectors performed a physical inspection of six Limitorque
'
valve operators in the Reactor Building. They were: MCV-10-15B and
j
0, normally closed valves in the Residual Heat Removal System;
MOV-70-19A and B, normally open valves in the Service Water System;
,
and MOV-VG-22A and B, normally closed valves in the Containment
Atmosphere Dilution System. During this physical inspection, the
e
inspector identified three Limitorque operators (MOV-10-150,
MOV-70-19A and B) containing unidentified wire connectors (appeared
i
to be nylon wire connectors) on their motor leads.
In addition, the
"
inspector also identified three electrical-tape cable splices on the
motor leads of MOV-10-158.
These electrical tapes were later removed
!
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,
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_ ,
- -
-
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.-
..
.
22'
.
l
by the licensee, revealing the same type of wire connectors as used
in MOV-10-150. There is no documentation present in the Limitorque
valve operator EQ file (QDR 3.1) to support the environmental quali-
i
fication of these wire connectors for either inside or outside
drywell applications.
.
In response to this concern, the licensee stated that they had con-
)
ducted a 100% inspection on the Limitorque operators located inside
-
the drywell.
They verified through review of the inspection records
that no dual voltage motors were used inside the drywell where the
post accident environment is more severe.
Following the inspection,
'
on November 5, 1987, the licensee submitted additional information to
L
NRC to justify the qualification of these connectors. The licensee
claimed that these connectors were type tested together with the
dual-voltage valve motors. Since the Limitorque test reports did not
explicitly indicate that these wire connectors were tested and the EQ
i
file did not identify which type of wire connectors were tested and
!
which type were installed at Vermont Yankee, this item is unresolved
j
pending NRC review of licensee's supporting evidence: -1) to demon-
strate that the tested connectors are the same type (not similar, but
i
identical, since there was no similarity analysis in the EQ file,
-
including manufacturer and model number); and, 2) the tested config-
i
uration is the same as the installed configuration (i.e., whether
i
the tested connector _was touching the metal housing during the entire
test and whether the metal housing was electrically grounded).
(50-271/87-19-07)
i
,
13.2 Limitorque Motor Wire Leads
During the physical inspection of EQ valves, the inspector observed
f
two unique types of wire insulation in the limitorque valve operators.
On MOV-17-19A the wiro leads from the motor had red insulation
[
material. Another valve operator (MOV-70-198) had a grey wire insula-
!
tion for the same application.
These two types of insulation could
l
not be immediately traced to a qualified type of insulation. The
licensee agreed to verify the qualification of this insulation
!
material with the manufacturer. These valves are located inside the
'
reactor building but outside the drywell.
This is an unresclved item
pending NRC review of the licensee's verification for the qualifi-
!
cation of motor leads in valves MOV-17-19A, MOV-70-19B and other
i
valves that may have the same potential prot.lem.
(50-271/87-19-08)
'
,
13.3 Rosemount Transmitter
,
t
During the plant physical inspection on October 25, 1987, the
[
inspector observed water dripping on the floor from a Rosemount
>
'
transmitter instrument tubing drain valve.
This transmitter was
identified as FT-10-2098, which requires environmental qualification.
The licensee promptly tightened the valve and stopped the water
'
dripping.
The licensee explained this is an isolated incident and
!
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.
. - -
--
.
. .--
=
.
. --
..
-
_ _ _ _ . -
- _ _ _ _ _ .
.
23
o
that constant checks are made for these types of problems by the
technicians and auxiliary operators.
The inspector had no further
questions.
It was also observed that the right side cover of the same transmitter
was not properly torqued as required by the installation procedure in
the transmitter EQ file.
The licensee indicated that the transmitter
under consideration is not subject to a steam environment and indi-
cated the existence of a qualification report on the subject trans-
mitters that does not require proper torquing of the side covers.
However, the licensee promptly took measures to correct the problem
and committed to inspect the remaining Rosemount transmitters that
were not attended to in the 1986 outage.
This is an unresolved item
pending NRC's review of the licensee inspection results on the proper
torquing of the Rosemount transmitter side covers.
(50-271/87-19-09)
14.0 Licensee's Response to Information Notice 86-03 (Limitorque Motor Wiring)
The subject notice was reviewed by the licensee at the Corporate Office to
evaluate the extent of the corrective actions needed at Vermont Yankee
station in an internal memo dated February 10, 1986.
The licensee in-
formed their plant staff about the potential deficiencies identified in
the subject notice.
The licensee elected to replace all the internal
wiring rather than to inspect for unqualified wire.
The memo referenced
above identified 50 motor operated valves that were affected. The
licensee ccmpleted the wiring replacement during the 1986 outage.
The
inspectors reviewed the wire replacement records on the following valve
operators:
MR No. 85-12Q5
Valve V23-16
MR No. 85-1229
Valve V10-25A
MR No. 85-1193
Valve V2-53A
>
MR No. 85-1230
Valve V10-258
MR No. 85-1248
Valve V10-388
A physical observation of 4 Limitorque valves Nos: MOV-10-15B, MOV-10-15D,
MOV-70-19A and MOV-70-198 confirmed that the licensee has replaced all
internal wiring with Rockbestos G Firewall III SIS wire. Qualification
documents of this wire is in EQ file QDR 6.4-2.
Within the scope of this review, no deficiencies were identified.
15.0 Licensee's Response to Information Notice 86-53 (Raychem Cable Spli:es)
In response to Information Notice 86-53, the licensee reviewed the site
Raychem solices installation procedures to assure that proper engineering
criteria. inspection, and training existed to prevent installation
problem!.
The cognizant EQ group conducted an inspection of accessible
Raychem iplices at the Vermont Yankee Nuclear Plant.
The inspection
_ _ _ _ _ _ _ _ _
.
24
.
results and the licensee's evaluation supported that these splices meet
the qualification requirements. The inspectors reviewed the inspection
records of Raychem splices, associated with the following instruments, and
conducted a physical inspection to determine the adequacy of the
licensee's action relative to Information Notice (IN) 86-53:
PS-2-134A,B,C and D in the Nuclear Boiler System (Turbine Building)
PS-5-14A ana B in the Reactor Protection System (Turbine Building)
SB-1A, 2A, 28 and 3A in the Standby Gas Treatment System (Reactor
Building)
The inspectors also reviewed the training records of selected individuals
performing quality control activities of installation, modification,
inspection, review and approval of Raychem splices installation Hands-On
training conducted by Raychem and were found conversant with the EQ
requirements to perform their functions.
The inspectors noted that the licensee did not have a plant procedure
to conduct installation of Raychem splices and terminations, but uses
the Raychem Installation Instructions to accomplish this activity.
The
licensee's Raychem splice inspection procedure adequately defined the
inspection attributes and were found properly implemented by the licensee's
inspectors to verify the installation activities.
Bases on the review of the iicensee's documentation, training records,
physical inspection and discussion with the cognizant plant personnel
regarding installation of Raychem splices, tne inspectors determined that
the licensee's action in response to IN 86-53 was adequate.
16.0 Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items or violations.
Unresolved items identified during this inspection are discussed in
Details, Paragraphs 13.1 through 13.3.
17.0 Exit Meeting
The inspectors met with licensee corporate personnel and licensee
representatives (denoted in Details, paragraph 1) at the conclusion of
the inspection on October 23, 1937.
The inspectors summarized the scope
of the inspection, the inspection findings and confirmed with the
,
licensee that the documents reviewed by the team did not contain any
'
proprietary information.
The licensee agreed that the inspection report
may be placed in the Public Document Room without prior licensee review
for proprietary information.