ML20150E128

Insp Rept 50-423/88-04 on 880314-18.Violations Noted.Major Areas Inspected:Equipment Qualification Program,Licensee Response to Equipment Concerns in SER & Configuration for Electrical Equipment from Master List

ML20150E128
Person / Time
Site:	Millstone
Issue date:	06/27/1988
From:	Anderson C, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20150E119	List: ML20150E116 ML20150E124 ML20150E128
References
50-423-88-04, 50-423-88-4, NUDOCS 8807150010
Download: ML20150E128 (23)

See also: IR 05000423/1988004

Text

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U.S. NUCLEAR. REGULATORY COMMISSION-

REGION I

Report No. , 50-423/88-04 ,

' Docket No. 50-423

License No. NPF-49 Priority -

Category C

Licensee: Northeast Nuclear Energy Company

P. O. Box 270

Hartford, Connecticut 06141

Facility Name: Millstone Unit 3

Inspection At: Berlin, Connecticut

Inspection Conducted: March 14-18, 1988

Inspector: (MD M ~7- E #

R. J(/ Paolino, Senior Reactor Engineer, date

EB/PSS

Other participants and contributors to the Report include:

S. Alexander, Equipment Qualification and Test Engineer, NRR/HQ

M. Banerjee, Reactor Engineer, ORP

J. Fehringer, Consultant, Idaho National Engineerins Laboratory

M.-Jacobus, Consultant, Sandia National Laboratory

J. McGhee, Co ultant, Idaho National Engineering Laboratory

Approved by: C v2/

C. J. Anderson, Chief, Plant Systems dat'e

Section, DRS/EB

Inspection Summary: Inspection on March 14-18, 1988 (Inspection No.

50-423/88-04)

Areas ~ Inspected: Announced inspection to 1) review licensee's Equipment

Qualification (EQ) Program and verify its implementation in accordance with 10

CFR 50.49 requirements for maintaining the qualification status of safety-related

electrical equipment in a harsh environment; 2) review licensee response and

resolutions to equipment concerns identified in the Safety Evaluation Report

(SER) issued by the NRC; 3) verification of installed configuration for EQ

electrical equipment selected from EQ master list; and 4) review and verify

licensee activity in response to Information Notices 86-03 and 36-53.

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-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

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. Description -Paragraph Item No.

Potential Violations

1. Ex'isting Raychem Splices do not conform.with' 12.0 88-04-06

Proceduros in'effect at time of installation.

Subsequent tests, dated March 1987, determine

the splice deficiencies to be acceptable.

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2. Litton-Veam (bayonet type) connector 11.1.4 88-04-05

qualification not-established. Operability

statement by licensee in effect for

continued operation.

3. Installed.Litton-Veam (19) not per 11.1.4 88-04-07

test configuration.

4. Qualification of GA HRRM was not established 7.0 88-04-02

prior'to this inspection. ' Justification for

continued operation on file.

Unresolved Items

,1. _ Adequacy of procedural control for 7.0 88-04-01

determining issuance of JCO.

2. Licensee action regarding use of 11.1.2 88-04-03

the High Range Containment

Radiation Monitor.

3. Imprcperly rated field wiring on S0V. 11.1.4 88-04-04

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DETAILS

1.0 Persons Contacted

1.1 Nort'heast Utilities Company

M. Alexandru, Environmental Equipment Qualification (EEQ) Engineer

• J. A. Blaisdell, Safety Analysis Engineer, Manager

• P. A. Blastoli, Superintendent General Facility Licensing

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• C. H. Clement, Plant Superintendent, Millstone Unit 3

H. Cote, Procurement Inspection Services

• T. J. Dente, Supervisor, Nuclear Operations

• J. R. Ferraro, Manager, Generation Electrical Engineering

R. Gavinsky, Procurement Inspection Services

R. Goldsmith, Technical Training

W. J. Hayes, Jr. , EEQ Engineer

K. Hong, Nuclear Training

• W. E. Hutchins, Generation Facilities Licensing EQ Coordinator

• G. L. Johnson, Director, Generation Engineering

R. Joshi, Senior E,gineer, Generation Facilities Licensing

V. Joseph, Engineer, Millstone Unit 3

• R. M. Kacick, Manager, Generation Facilities Licensing

• M. S. Kai, Supervisor, Transient Analysis

B. Kaufman, Supervisor, Assessment and Staff Service

D. McCory, Manager, Procurement Services

• C. J. Mroczka, Senior Vice President, Nuclear Engineering and

Operations

• D.-0. Nordquist, Director, Quality Services

G. "-- Noordennen, Supervisor, Generation Facilities Licensing

P .<urnberger, Quality Service Department (QSD)

. Pr. nam, Procurement Inspection Services, QSD

W. "schter, Assistant Engineering Supervisor, Unit 3

• A. R. Roby, Systems Manager - Generation Engineering

M. Samek, Instrument and Control Engineer

• S. E. Scace, Station Superintendent - Millstone Units 1, 2 and 3

• F. Sears, Vice President - Nuclear Engineering and Operations

T. A. Shaffer, Manager, Instrumentation and Control Engineering

B. J. Smith, EEQ Engineer

• B. A. Tuthill, Supervisor, Environmental Qualification

1.2 U.S. Nuclear Regulatory Commission

• Wm. V. Johnston, Acting Director, Division Reactor Safety

• E. C. McCabe, Jr. , Chief, RPS - 1B

• V. L. Pritchett, Reactor Engineer, RPS - IB

• Wm. Raymond, Senior Resident Inspector

• denotes personnel present at the exit meeting of March 18, 1988

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2.0 Purpose-

The purpose of this inspection was to review the licensee's implementation

of a. program to meet the requirements of 10 CFR 50.49 for electrical

equipment important to safety at the Millstone, Unit 3 facility.

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3.0 Background

Safety related equipment must be demonstrated to be capable-of maintaining

functional operability under all service conditions postulated to occur

during its installed life for the time it is required to operate. Detailed

requirements and guidance related to methods and procedures for demonstra-

ting qualification are in 10 CFR 50.49, "Environmental Qualification of

Electrical Equipment Important to Safety for Nuclear Power Plants"; in

NUREG-0588, "Interim Staff Position on Environmental Qualification of

Safety-Related Electrical Equipment" which supplements IEEE Standard 323;

and various NRC Regulatory Guides and Industry Standards.

.NUREG-0588 was issued in December 1979. This report provides guidance on

1) how to establish. environmental-services conditions; 2)'how to select

methods that are considered appropriate for qualifying equipment in

different areas of the plant; and, 3) other areas such as margin, aging and

documentation. In February 1980, the NRC asked certain near-term

operating license (OL) applicants to review and evaluate the environmental

qualification documentation for each item of safety-related electrical

equipment and to identify the degree to which their qualification programs

were in compliance with the staff positions discussed in NUREG-0588.

i5 Bulletin 79-01B, "Environmental Qualification of Class IE Equipment,"

• ssued by the NRC Office of Inspection and Enforcement (IE) on

Jcnuary 14, 1980, and the supplements dated February 29, September 30, and

October 24, 1980, established environmental qualification requirements for

operating reactors. This bulletin and its supplements were provided to

operatirig license (0L) applicants for consideration in their reviews. A

final rule on environmental qualification of electrical equipment important

- to safety for nuclear power plants 10 CFR 50.49, became effective on

February 22, 1983.

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To document the degree to which the environmental qualification program

complies with the NRC environmental qualification requirements and

criteria, the applicant provided equipment qualification information by

letters dated January 14, March 6, July 31, October 7 and 21, and

November 18, 1985 to supplement the information in FSAR Section 3.11. On

August 13, 14 and 15, 1985 the NRC staff, with assistance.from contract

personnel conducted an audit of the applicant's qualification files and

equipment installed at the plant. Deficiencies identified during this

audit were discussed and formally transmitted to the applicant by a letter

dated September 19, 1985. The applicant proposed acceptable corrective

measures and file revisions to eliminate the deficiencies cited. A revised

compartment analysis using mass and energy release data generated by the

Westinghouse Owners Group Program was provided by licensee letters of

December 20, 1985 and January 7 and 14, 1986. Qualified life calculations

based on actual temperatures inside the containment were submitted by the

licensee in a letter dated January 22, 1988.

On the basis of this review, the staff concluded that the applicant

demonstrated conformance with the requirements of the environmental

qualification as outlined in 10 CFR 50.49, and with the criteria specified

in NUREG-0588.

4.0 EQ Program

Nuclear Engineering and Operations Procedure Number NEO 2.21, "Nuclear

Plant Environmental Qualification Program" establishes the Northeast

Utilities (NU) Flant Environmental Qualification Program within the

Nuclear Operations (NEO) Group. This program was developed to ensure that

environmentai qualification criteria are applied to equipment regulated by

10 CFR 50.49 and to effect a process through which equipment qualification

can be demonstrated. The program applies to all phases of design,

construction, and operation. Implementation'of this program is through

lower tier documents.

The scope of the Millstone 3 (MPS) program is addressed in the

Environmental Qualification Program Procedure Number GE-EQ-02, Revision 1

dated February 23, 1988. The MP-3 program was established before the

classifications of 10 CFR 50.49 (b)(1), (b)(2), and (b)(3) equipment were

documented.

The MP-3 Program includes instructions for the performance of work

associated with the development and revision of documentation files

(EEQ files) which demonstrate the environmental qualification of

safety-related equipment and instructions fer the preparation and revision

to the EQ Master List.

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Procedures included in the Program are.

• MP-3 Technical Specifications

• MP-3 Final Safety Analysis Report

• MP-3 Emergency Operating Procedures

• -MP-3 Production Maintenance Management System (PMMS) and

Supplemental Material, Equipment and Parts List (MEPL)

• WCAP-8587 Revision-6-A dated March 1983; Methodology for qualifying

Westinghouse WRD Supplied NSSS Safety Related Electrical

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Equipment

• NEAM-112 Revision 3 dateu July 23, 1985; M111 stone-3 Environmental

Qualification of Class 1E Electrical Equipment

• NE0-2.21 "Nuclear Plant Environmental Qualification Program"

• NE0-5.03 "Contra 11ed Distribution of Design Documents for Interface,

Review and Transmittal"

• NE0-2.C3 "Identification and Implementation of NRC Reporting Require-

ments for Operating Muclear Power Plants"

• GE-EQ-03 NUSCO Generation Electrical Engineering, "Equipment

Environmental Qualification Inspection Procedure for MP-3".

The _ Generation Electrical Engineering's Qualification Engineering

Supervisor is responsible for the implementation of and revisions to the

MP-3 procedure. The Generation Electrical Engineering's Qualification

Engineer is responsible for maintaining the electrical environmental

qualification files in an auditable form. This responsibility includes,

initiation and changes to Systems Component Evaluation Worksheets (SCEWS)

and Electrical Equipment Qualification (EEQ) files, transmitting electrical

equipment qualification maintenance information and initiating Reportability

Evaluation Forms and performing operability evaluations as assigned.

The development of the MP-3 Environmental Qualification Program came about

in four phases. The first phase was to define the scope of systems

important to safety. A Class 1E Master List of Equipment was prepared

based upon data contained in the MP-3/SWEC specifications. Additions /

-deletions to the Master List were made through criteria set forth in

Procedure NEAM-112.

The second phase was to define the harsh environmental zones, both inside

and outside containment and their composite worst case environment.

Pnase three combines the efforts of the previous two to yield a list of

equipment subject to a harsh environment as defined in NUREG-0588. This

list is entitled the "Electrical Equipment Qualification Information

System" (EEQIS), SCEWS were produced for each component that was identified

on the Master List.

Phase four was to evaluate the qualification status for equipment on the

Master List.

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' Quality Assurance support for the environmental qualification program is

through the NUQAP Topical Report which applies to all safety-related

equipment included in the EQ program.

Based on the above review,.no deficiencies were identified.

5.0 Environmental Qualification Master List-(EQML)

.The NRC inspection. team reviewed the current EQML for Millstone Power.

Station, Unit 3 (MP-3) and associated documents discussed below to verify

the adequacy of the implementation of Northeast Nuclear Energy Company's

(NNECo's) EQML development and maintenance procedures.

The MP-3 EQML was based on a review of technical specifications, emergency

operating procedures (EOPs), "off-normal" operating procedures (ONOPs),

piping and instrumentation diagrams (P& ids), electrical diagrams,

Regulatory Guide 1.97 (Revision 2, Categories 1 and 2), Regulatory

Guide 1.89 (Revision 1), NUREG-0737, NUREG-0588, IE Bulletin 79-018,

10 CFR 50.49, High Energy Line Break (HELB) correspondence, and plant

equipment verification walkdowns.

Most EQ engineering work for NNECo on MP-3 is done by the Generation

Electrical Engineering Branch (GEE) of Northeast Utilities Service Company

(NUSCo), the nuclear engineering support division of NNECo's parent

company, Northeast Utilities (NU). NU's Nuclear Engineering and

Operations (NEO) Group includes both NNECo (MP-3 licensee) and the

Haddam Neck plant licensee, Connecticut Yankee Atomic Power Company

(CYAPCo).

GEE Procedure GE-EQ-01, Revision 1, dated October 3, 1986, "Environmental

Qualification Program for Millstone Unit 3" governs development and

maintenance of the EQML as well as other aspects of the EQ program. EQML

maintenance is also governed by NE0 procedure NE0 2.21, Revision 1, dated

July 24,1987, "Nuclear Plant Environn. ental Qualification Program," and by

NE0 3.03, Revision 6, dated November 21, 1986, "Preparation, Review, and

Disposition of Plant Design Change Records." NE0 procedure NEAM-112,

Revision 3 contains the detailed instructions for EQML operations

including changes, additions and deletions. Review of these procedures

. indicated that all types of equipment required to be qualified at MP-3

would be included. The general procedures and detailed EQML

instructions were adequate to control EQML development and maintenance

within their scope.

In MP-3 Supplemental Safety Evaluation Report Number 4 (SSER 4) the staff

cited a licensee submittal that indicated that all EQML equipment was

qualified with the exception of the hydrogen analyzer stating that it

would be qualified prior to initial critically. The inspector confirmed

that NNECo had prepared an EQ file that qualifies the hydrogen analyzer

(file number 2214.900-035) and that it was added to the EQML.

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As a further validation check on MP-3's EQML, the inspector reviewed MP-3

emergency operating procedures (EOPs) 35E-0 (Reactor Trip and Safety

Injection), E0P 35E-1.2 (Post-LOCA Cooldown and Depressurization), and

E0P 35E-1 (Loss of Reactor or Secondary Coolant) with MP-3 operations

specialists. The inspector selected 22 items of equipment required to be

.used with the E0P (and/or by Technical Specifications) for these events

and verified that they were all either listed in the EQML as qualified or

were exempted for a valid reason,

6.0 Maintenance

L As stated in MP-3 SSER 4, the NRC staff had requested information from the

licensee regarding its EQ-related maintenance and surveillance program.

The program was to provide for control of maintenance of qualified

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equipment to preserve its qualified status, ensure that equipment and

( components would be replaced b2 fore expiration of qualified life and

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surveillance to detect age-related degradation occurring more rapidly than

predicted.

SSER 4 stated that the staff had reviewed NNECo submittals that described

the EQ Maintenance Program for MP-3 and had concluded that it was

! acceptable. The inspector reviewed implementing procedures and systems

and associated records and conducted observations and interviews to

j confirm its adequacy in practice.

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! The EQ information submitted by NNECo indicated that a design temperature

l of 90 F was used as a basis for Arrhenius qualified life calculations for

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equipment located inside containment. This low value was questioned by

the staff. Accordingly, the staff established License Condition 13 which

required that before startup following the first refueling outage, the

qualified lives of electrical equipment within the same scope of 10 CFR

50.49 located inside containment be racalculated based on actual temperatures

monitored inside containment during the first cycle of operation with

adequate consideration of margin.

Prior to that startup, which had occurred shortly before this inspection,

NNECo had completed the recalculations and had submitted the results to

the staff for review. The actual data resulted in the creation of two new

environmental zones within containment at upper elevations and in the

pressurizer cublicle with new design temperatures of 115 F and 130 F

respectively including margin. The inspector reviewed the raw data and

procedures covering its acquisition and reduction with no discrepancies

noted. In addition, the inspector reviewed calculations of new reduced

qualified lifes and confirmed that the revised lifetimes were reflected in

the EQ files in updated component eplacement schedules with the exception

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of those which were greater than 40 years.

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.EQ related maintenance at MP-3 is generally controlled under the same

procedures cited in the discussion of the EQML. Requirements from the EQ

files relating to installation, maintenance and replacement of qualified-

squipment to establish and maintain qualification are' transmitted to-the

MP-3 site via Component Replacement Schedules where they are translated

into detailed installation and maintenance and inspection / surveillance l

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instructions-and schedules by MP-3 EQ engineering and maintenance personnel.

They are then incorporated in the MP-3's Planned Maintenance Management

System (PMMS). PMMS is a comprehensive computer data base and management

system covering all aspects of plant maintenance including EQ.

At the site, the inspector examined the MP-3 computerized Planned

Maintenance Management System (PMMS). Maintenance supervisory and planning

personnel demonstrated how EQ related maintenance and replacement require-

ments from the EQ files are incorporated into maintenance instructions and

schedules. Using as examples, equipment for which new qualified lives had

been calculated from the recently generated zone temperature figures, the

system produced updated maintenance and replacement schedules. The

. inspector reviewed computer generated detailed surveillance / inspection and

maintenance instructions for individual qualified components and completed

work orders documenting use of these instructions including maintenance

performed that day to support the NRC walkdown inspection and restore

examined components to fully qualified and operable condition.

The-inspector performed a review of maintenance procedures, schedules and

records described above, observation of EQ related maintenance in progress,

and interviews with MP-3 maintenance supervisors, planners and technicians.

The inspector concluded that NNEco has satisfactorily implemented their

program at MP-3 for preservation of the qualified status of EQ equipment.

This includes using experience with the equipment, up-to-date service

environmental data, failure analysis information, and direct surveillance

for degradation.

7.0 QA/QC Interfaces

The licensee's Engineering and Operations Procedure NE0 2.21, "Nuclear

Plant Envircnmental Qualification Program," Revision 1, dated July 24,

1987 and Millstone Plant Unit 3 (MP-3) implementing procedure ACP-QA-2.16,

Revision 1, dated October 24, 1987 with the same title require that EQ

Program requirements and activities comply with the Northeast Utility's

Quality Assurance Program (NU QAP). The MP-3 procedure ACP-QA-1.06,

Revision 9, dated November 4,1987, "Quality Assurance / Quality Control

Program," also invokes the NU QAP to the structures and components

designated as EEQ.

The licensee's Quality Services Department (QSD) performs periodic audits,

surveillances, and in process verification of quality related services and

activities. The QSO is divided into four sections. The Procurement

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Quality Services Section performs vendor. audits and evaluations,

procurement document reviews, material receipt inspections, and material

storage surveillances. The Assessment Services Section is responsible for

performing operating plant audits, technical specification audits,_and

field surveillances. The Assessment and Staff Services perform assessment

of engineering. The Plant Quality Services performs automated work order

review,. surveillance activities, and QC hold point activities, at each

nuclear unit.

The . Procedure QS0-2.02, "Performance, Reporting, and Follow-Up of Audits,"

Revision 0, dated August 1, 1987 provides overall instractions for the

performance, reporting, and followup of audits. This procedure addresses

audit schedule and requires that all facets of nuclear plant operational

phase activities be audited at least once every two years. Equipment

Environmental Qualification (EEQ) related ar.tivities are considered as

quality related activities, and the procedure _QSD-2.02 is applied. Audits

are also initiated upon request from the Nuclear Review Board (NRB) in

specific areas of concern.

The inspector reviewed the audit performed by QSD on the EQ program during

a period from May 19 to July 20, 1987. The audit report dated July 24,

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1987 identified 6 findings and 7 unresolved open items. It was detailed

in addressing the key areas of the EQ program. The inspector reviewed the

licensee's response to the audit findings. The audit finding No. 3.2

identified that no procedure or control existed at NU for-providing a

"Justification for Continued Operation" (JCO) when potential EQ deficien-

-cies were identified. It noted that Procedure NEO 2.21 required that the

Generic letter 86-15 guidance be applied in evaluation of potential

noncompliances. The finding indicated that it was further necessary to

proceduralize the licensee's JC0 process. The licensee's response to this

audit finding (dated October 29, 1987) stated that there was no specific

requirement provided in the regulations for a JCO, except Generic Letter 86-15 which offered some guidance. The response concluded that Procedure

NE0 2.25, "Identification and Implementation of NRC Reporting Require-

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ments," would be utilized by the Generation Electrical Engineering

(GEE)-Qualification Engineering group to control the JC0 process.

The inspector reviewed NE0 2.25, Revision 0, dated June 19, 1987, and

could not identify any discussion or requirement for preparing a Justifica-

tion for Continued Plant Operation when a potential EQ deficiency is

identified. During the exit meeting, the licensee stated that they would

consider adding directions in the procedure NE0 2.25 to address the need

for justifying continued plant operation for potential EQ deficiencies.

This item is unresolved pending NRC review of the licensee's evaluation

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of the JC0 process and corrective action. (50-286/88-04-01).

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The inspector:also r_eviewed audit Find'ng i

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No. 3-10 (dated May-July 1987)

which : indicated that the Kaman _and General Atomic High Range Radiation

Monitors were being qualified while in.use. These are the high range

monitors Linstalled in containment prior.to the licensing of Millstone

Unit-3.-

The-licensee's response to the audit Finding-No 3-10 indicates the licensee

is taking credit for the GA High Range Radiation. Monitors (HRRM) since

the HRRMs were qualified when installed. However, on November 6, 1986 the

vendor notified the licensee-of potential problems-regarding insulation

resistance of the cable used by the HRRMs. The licensee's position was

that the cable was qualified until the licensee completed its review of

the vendor data.

Prior.to licensing MP-3, it was determined that this qualification of the

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Kamarf HRRM would be difficult because of the number of outstanding

anomalies. =The licensee attempted to qualify the Kaman HRRM but concluded

.in Spetember 1987 that the GA HRRMs satisfied the provisions of Regula-

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tory Guide 1.97 revision 2 and the requirements of 10 CFR 50.49. The

Kamans.were removed from the EQ Master List in the March 13, 1988 revi-

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sion.- Licensee Reportability Evaluation No. REF-87-21, dated February 9,

1988 in addressing the potential low reading problems with the containment

High. Range Radiation Monitors with DBA LOCA temperatures concludes: 1)

The event is not reportable per 50.72 or.50.73; 2) The monitors should not

beideclared inoperable, and hence, do not require Tech.. Spec. LER compliance.

This conclusion by the licensee is based in part that the monitors have no

automatic. function and only provide post-accident information to assist

decision making needed to minimize public dose consequences. In addition,

the licensee indicated that there are other methods available for detect-

ing containment-radiation levels.

Based on the above review, there are indications that the GA HRRMs were

qualified when installed and prior to licensing of the MP-3 facility.

However, subsequent information from the vendor (dated November 6,1986)

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indicates IR problems with the HRRM cable assembly which impacts on

operability of the GA HRRMs because of potential errors in instrument

accuracy. In addition, there is a licensee internal memo (GSP-88-021)

dated January 13, 1988 which discusses containment high range monitor

uncertainties.

h In spite of several statements declaring qualification of the GA HRRM, it

appears that the licensee was still in the process of evaluating the

qualification of the GA HRRM system at the time of this inspection. The

licensee, apparently has not followed the guidelines of the NRC generic

letter 86-15. The licensee has assumed that the GA HRRM is operable until

the vendor information is confirmed.

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.This item is in violation of 10 CFR 50.49 which requires that electrical

equipment1 important to safety be qualified. The licensee has not

established qualification prior to this inspection in that the vendor

reported Part 21 report on IR deficiencies had not been resolved. A

justification for continued operation is on file for the GA HRRM system.

(50-423/88-04-02)

8.0 EQ Training

Nuclear Engineering and Operations Procedure NEO 2.21, Revision 1, dated

July 24, 1987, requires that the Director, Nuclear Training provide

training for personnel performing activities affecting environmental

o qualification to ensure that they are proficient. In addition to the

training modules developed to ensure that personnel involved comply with

, the general requirements of the program, specific training modules are

developed for personnel involved in the maintenance of equipment falling

within the scope of the Equipment Environmental Qualificatior, (EEQ)

Program. Procedure NEO 2.26, issued on December 31, 1987, charges

individual department management with the responsibility of evaluating the

training needs of their personnel and documenting their personnel's

qualificattans.

The licensee has developed training modules to address the EEQ training

requirements. The EEQ overview course addresses the general program

requirements. Individual lesson plans / modules are prepared for Corporate

Engineering, QA/QC, and site (Electrical and I&C) personnel on EQ

overview. Additional training modules on special EQ issues like Raychem

' heat shrink, and one prepared to address the industry lessons learned

items enhance the basic training program. Corporate EEQ expertise

maintained by the Generation Electrical Engineering (GEE)-Qualification

Engineering Group is utilized in developing these modules.

The inspector reviewed the licensee's lesson plans and attendance sheets.

-The licensee stated that approximately 150 personnel from Enginee ing,

QA/QC, Project Management, Design and Construction attended the corporate

EEQ overview course. Similarly, 9 out of 11 electrical technicians and 20

out of 24 I&C technicians at Millstone 3 attended a similar EEQ overview

training. Per Procedure NE0 2.26, additional training needs will be

assessed and necessary training will be provided by October 1, 1988.

During the course of the inspection, the inspectors discussed basic EEQ

issues with various engineering, QA, and plant technical personnel.

Within the scope of this inspection, the inspector did not identify any

violations or deviations.

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'9.0 -EQ Equipment Replacement and Spare Parts Procurement

The Nuclear Engineering and Operations Procedure NE0 2.21, "Nuclear Plant

Environmental Qualification Program," Revision 1, dated July 24, 1987 and

the Millstone Unit 3 implementing Procedure ACP-QA-2.16, Revision 1, dated

.0ctober 24, 1987 with the same title, require that EQ related purchase

requisitions contain appropriate specifications to ensure the

qualification characteristics and documentation of ordered material. The

NRC inspector reviewed the following procedures which govern the

procurement process for Millstone Unit 3:

• NEO 6.02, Preparation and Review of Quality Related Purchase

Requisitions, Revision 2, dated August 23, 1985.

• QSD-3.01, Procurement Document Review, Revision 0, dated August 1,

1987.

• ACP-QA-4.03A, Classifying and Vograding Spare Parts for Use in QA

Application, Revision 3, dated November 4, 1987.

• QS0-3.08, f'erfornance of Receipt Inspection Activities, Ravision 0,

dated August 1, 1987.

The purchase requisitions that are electrical or instrumentation and

controls related are required to be reviewed for equipment environmental

qualification (EEQ) requirements ar.d approved by Generation Electrical

Engineering (GEE). The licensee depends on the responsible engineer

originating the purchase requisition for incorporating, and GEE-Qualifi-

cation Engineering for verifying that appropriate EQ requirements are

included. Where original equipment parts are not available, GEE-Qualifi-

cation Engineering is required to perform an EQ analysis and provide jus-

tification for use of substitute parts or equipment. The Manager, Nuclear

Quality Assurance (NQA) is responsible for verifying that appropriate

GEE-Qualification Engineering review has taken place. Changes in purchase

orders are subject to the same level of review and approval as original.

Additionally, Procedure QSD-3.01 requires that purchase requisitions for

spare / replacement parts should include a statement requiring the vendor to

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inform the customer of any deviations or changes made to the part number,

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design, and material which differ from the original orders.

Olscussions with Station Procurement Inspection Services Personnel

regarding their method of assuring compliance with 10 CFR 50.49 for

procurement of EQ related equipment and spare parts and a review of the

procurement documents contained in the following Material Receiving

Inspection Report (MRIR) packages support the adequacy of the licensee's

EQ related procurement process:

• MRIR No. 387-076, Raychem Adhesive (Closed).

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• MRIR No. 388-024, Limitorque Nut Stem (0 pen).

• MRIR No. 388-062, Limitorque Tripper (0 pen).

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• MRIR No. 388-082, Limitorque Torque Switch (0 pen).

• MRIR No. 387-138, ITT Hydramotor Parts (Closed).

Within the scope of the inspection, the inspector did not identify any

deficiency in the overall spare parts procurecant program and its-

implementation. However, it was observed in Procedure ACP-QA-4.03a that

the references are misnumbered or inappropriately applied. For example,

the Reference 3.12 is called out in Section 4.8, "EEQ", however, it is

impossible to determine what Reference 3.12 really entails as

Reference 3.12 does not exist under the list of references in Section 3.

The licensee agreed to correct the error.

10.0 HRC Information Notices (ins) and Bulletins

NRC ins and Bulletins are handled administrative 1y as part of a program

called "Vice President, Nuclear Operations Commitment Program," governed

by Nuclear Operations Policy N0P-1.06 (Revision 3, April 15, 1986). The

program provides for distribution, tracking, and assignment of responsibility

for correspondence requiring action and/or response. Such items are tracked

by a system of Nuclear Operations Assignments (NOAs). Specific instructions

for handling of NRC correspondence including ins, IEBs, inspection reports,

are contained in N0P-R-2.04 (Revision 8, February 17,1987). Review of

these procedures revealed that there was no formal requirement to route

all ins and other similar material to EQ personnel for their determination

of applicability to EQ. This decision is made by personnel not directly

involved in EQ. However, the inspector determined that this was being

accomplished satisfactorily in practice due to the EQ training and awareness

of cognizant personnel.

The NRC inspectors reviewed the status of actions on EQ-related ins and

verified implementation of NNECo's program for processing and tracking NRC

bulletins and information notices as they relate primarily to EQ. The

licensee had reviewed and evaluated appropriate EQ-related ins and IE bulletins

from IE8 79-01 through IN 87-08. Actions pertaining to selected ins were

reviewed in detail.

• IN 86-53, titled "Improper Installation of Heat Shrinkable Tubing".

NNECo actions in response to IN 86-53 were reviewed. The licensee

has established Raychem installation procedures to be consistent with

Raychem specifications for qualified splices. Installation training

has been conducted for electricians, QA inspectors and engineers.

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• IN 86-03, concerning unidentified internal wiring in Limitorque motor

operators, was reviewed to assess licensee response to the Information

Notice. Review of the file on this issue including licensee walkdown

and maintenance records indicated that MP-3 had inspected _all

131 Limitorques within the scope of the.EQ program for qualified

-wiring before issuance of their operating license. The inspections

were completed on January 3, 1986. All actuators had internal wiring

that was determined to. be qualified by its markings and traceability

to:EQ files except two. Two jumpers in each of these were replaced

because, although apparently the same as other qualified wire in

other respects, they were cut from the reel such that they bore no

markings. No significant discrepancies in this area were noted in

the NRC's plant physical inspection of selected Limitorque switch

compartment internals.

• IN 86-02 concerns corrosion of magnesium rotors in Reliance AC motors

for Limitorque valve actuators. NNECo had determined on the basis of

a preliminary review that this issue did not adversely affect the

qualification of Limitorques at MP-3.

• IN 84-90 concerns qualification problems resulting from the

superheated steam environment which is created when, during a large

MSLB, steam generator tubes are uncovered by the resulting blowdown

producing superheated steam. The resulting harsh environment

produced can be particularly severe in small enclosed spaces outside

containment in which a break may occur and the ?nvironmental

parameter values to which exposed equipment was qualified may be

exceeded. The analysis and satisfactory disposition of this problem

using the latest Westinghouse mass and energy release data was made

Condition 2.C(3) of the MP-3 Low-Power Operating License as stated in

MP-3 Supplemental Safety Evaluation Report Number 4 (SSER 4). In

SSER 5, the staff found the information submitted by NNECo to be

acceptable for resolving this issue for MP-3 and satisfied the

license condition. The inspector verified completion of measures

taken by NNECo as cited in their submittals to ensure-the

qualification of affected equipment including thermal insulation of

main steam pressure transmitters.

11.0 EQ File Review

11.1 The licensee's EQ files were reviewed to verify the qualified status

of equipment within the scope of 10 CFR 50.49. In addition to

comparing plant service conditions with qualification test conditions

and verifying the bases for these conditions, the inspectors

selectively reviewed areas such as post-accident operating time

compared to the duration of time the equipment has been demonstrated

to be qualified; similarity of tested electrical components / equipment

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to that installed in the plant (e.g. insulation class, component

materials, test configuration compared to installed configuration and

documentation of 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 Information Notices /8ulletins and their resolution (s).

The inspectors reviewed a selected sample of 23 EQ files associated

with various equipment types. These equipment types covered such

areas as electrical cable, Limitorque motor operated valves, cable

splices, radiation detectors and pressure / level transmitters, An

equiptr.ent type is defined as a specific type of electrical equipment,

designated by manufacturer and model, which is representative of all

identical equipment in a plant area exposed to the same or less severe

environmental service conditions.

There is an EQ file for each item of electrical equipment / component

type purchased that falls within the scope of 10 CFR 50.49, except

for generic applications items (e.g. terminal blocks, connectors,

splice kits). These items are placed in one EQ file identified by

the general specification (2240.000-001 and 2400.000-350) "sed to

purchase all of the items. Auditing these EQ files was difficult

because of the number of unrelated qualification documents in the

file which had to be sorted and a determination of applicability

made. In general the EQ-files were auditable and found to be accept-

able except for specific deficiencies defined below:

11.1.1 EEQ File 2412.300-253 (Kerite Cable)

Qualification of the Kerite cable is based on NUREG-0588,

Category 1.

The aging data in the EQ file was based on a statement that

Kerite aged the cables for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> at 150 C. Subsequent to

the inspection, supporting data was available to confirm that

prior to shipment to the Franklin Research Center, the specimens

were preaged at Kerite from September 4 - 9, 1974. Preaging was

done for 101 hours0.00117 days <br />0.0281 hours <br />1.669974e-4 weeks <br />3.84305e-5 months <br /> at 150 C. This information will be included

in the EQ file.

The inspector noted that Nonconformance and Otsposition Report

Numbers Z006, 2007 and Z008 referenced in the EQ file did not

have clear disposition. Subsequent information provided by the

licensee indicates the Nonconformance and Disposition Report had

been resolved but were written when it was noted that the

Franklin Report (F-C4020-2) did not indicate a post-LOCA mandrel

bend test prior to a high potential withstand test.

Within the scope of this inspection no violations were

identified.

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Qualification of the General Atomics high range radiation

monitor:was based on NUREG-0588, Category 1. The test

parameters envelop the plant requirements. The test specimen

was identical to the installed equipment. A GA Part 21 issue

was addressed by considering the worst case insulation resistance

of_the interconnecting cable and electrical penetration. An

error of about 1.7 rad /hr. over the entire range was calculated

by the licensee, exceeding the factor of 2 accuracy requirement

of Regulatory Guide (RG) 1.97 at the lowest end of the

instrument range.

The NRC inspector informed the licensee of the possibility that

the licensee calculated error, noted above, could lead to the

detector going off-scale at the low end and the green "operate"

light going off. This could result in subsequent high radiation

readings which could confuse the operator even though the

readings were accurate.

The licensee committed to revising the operations procedure

number OP-3362, "Radiation Monitor System Display and Control

System", no later that April 30, 1988. A memo was drafted by

Millstone 3 (MP-3) Engineering Departnent notifying MP-3

Training Department of the alarm response addition to OP-3362.

The MP-3 Training Department was directed to incorporate the

HRRM alarm response into their Control Rooms Operator

Requalification Training Program. MP-3 Operations Department

Supervisors will notify control room operators of this newly

incorporated alarm response.

This item remains open pending NRC review and verification of

licensee corrective action. (50-423/88-04-03)

11.1.3 EEQ File Number 2472.110-654 Target Rock Solenoids

The inspector reviewed EEQ File Number 654 for Target Rock

Corporation solenoid valves, Model Number 81V-008, Item Number

3SSR*CV8026 for in-containment use in Zone CS-02. This specific

S0V is used in the Reactor Plant Sampling System for Containment

Isolation. The file was reviewed to determine if there is

sufficient evidence to document qualification of this SOV for

the environmental conditions in which it must operate, as well

as to determine that the qualification documents in the file are

auditable.

Documents reviewed for this determination include:

• Target Rock Test Report 3624A, dated March 22, 1983

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• Target Rock Test Report 3039

• Millstone, Unit 3, Engineering Commitment Follow Program

(Commitment Number 38500011)

• I&E Information Notice 84-68 and associated SWEC and NUSCO  ;

letters

• SCEW sheet; for 3S3R*CV8026

In reviewing EEQ File Number 654, the inspector noted that S0V

3SSR*CV8026 and approximately 27 other SOVs supplied by Target

Rock Corporation are normally energized during plant operation.

Until the time of this inspection, the self-induced heat from

these SOVs had not been taken into account when calculating

component. life and component /part replacement schedules.

Sample calculations performed by the licensee during this

inspection on the effects of the added heat introduced into the

aging calculations produced a qualified life in excess of

40 years fer the components examined.

In addition, in reviewing Information Notice 84-68 it was not

apparent that the licensee had addressed the NRC concerns for

"Improperly Rated Field Wiring to Solenoid Valves." A commitment

follow program for Millstone, Unit 3 (Engineering Commitment

, Number 38500011) was implemented. This item is unresolved

pending NRC review of licensee evaluation and resulting activity.

(50-423/88-04-04)

11.1.4 EQ File Number 537 (Litton-Veam Connector)

The inspector reviewed the environmental qualification documents

for the CIR series Litton-Veam multipin electrical connectors.

These connectors provide cable entry seals for various equipment

including transmitters, temperature elements, and limit switches

located both inside and outside the containment. Following the

requirements of 10 CFR 50.49, - ie connectors are required to

be qualified for the harsh environment of a LOCA or a high

energy line break as appropriate.

Qualification for the licensee's application of the CIR series

Litton-Veam multipin electric cable connector assemblies is

based on two qualification reports, namely NTS Report Nos.

588-1657A, dated November 4, 1985 and 558-16578, dated November

11, 1985. These reports document testing performed to qualify

the subject connectors for in-containment LOCA and outside

containment high energy line break (HELB) environment,

respectively.

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In Test Report No. 558-1657A, three sets of the CIR series.

multipin connector aesemblies with stainless steel bodies were

tested for the LOCA environment. Within each set, three samples

were utilized. The first set of samples (A 3, A 2, and A 3 ) were

terminated with 4 conductor #16 BIW instrument cables. The

second set of samples (8 , 82 , and 83 ) were terminated with 3

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conductor #14 Okonite control cables. The third set of samples

(C , C2 , and C3 ) were for thermocouple applications. The third

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sample in each set (namely A 3 , 83 , and C3) was not pre-aged or

irradiated before LOCA testing. The maintenance of specified

voltage and current values was required as the test acceptance

criteria. The test plan also required periodic monitoring of

the insulation resistance (IR) between cable conductor / connector

pins; however, no pass / fail criterion for IR values were

established.

The first set of IR measurements was performed when the test

environment had stabilized to 150 F and at a pressure as low as

0 psig. Additional IR measurements were taken thereafter at

daily intervals. The samples A2 and 8 2 consistently showed IR

values a few orders of magnitude lower than the IR values for As

and 8 . The first measurement at 150 F during day 1 indicated IR

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values as low as 1.7 x 106 ohms. The unirradiated and unaged

samples (A 3 and B 3 ) had higher IR values.

The Litton-Veam connectors are installed on various instruments

inside containment serving the post accident monitoring, reactor

protection, and ESF functions. The inspector was concerned that

low IR values during LOCA test could be the result of moisture

penetration into the seal. Due to the lack of IR measurements

during the LOCA transient conditions, the worst case IR values

and hence leakage current could not be established, thus making

it impossible to determine the contribution of the connectors to

the instrument loop accuracy under a LOCA environment. The

instrument loop error when not properly accounted for could

affect automatic control function generated at certain instru-

ment setpoints, or could provide erroneous readings to the

operator which could lead to inappropriate operator action under

accident (LOCA) conditions.

Thus, for the Litton-Veam multipin connector assemblies installed

on instruments located inside containment, the licensee did not

adequately establish the equipment performance standards in the

test acceptance criteria rqd did not provide adequate evidence

that this equipment would perform its intended function for all

service conditions postulated to occur during the qualified life.

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Failure to establish qualification of electrical equipment

(Litton-Veam connectors) important to safety under post '.0CA'

,-containment environment is a violatio: of 10 CFR 50.49 require-

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During the test plan review (NTS QPP No. 558-1657, Revision 1),

the inspector observed that the test specimens were prepared

following an assembly procedure, VAP 241. This procedure

required that heat shrink tubing be applied over the contact-wire

crimped termination before potting the rear of the connector.

with epoxy. The licensee's electrical installation

specification No. E-350 which was in place from the initial

commencement of installation of the connectors on March 6, 1984

until its cancellation on March 26, 1984, did not incorporate

the heat shrink tubing over the pia / conductor interface. All

work was stopped pending the issuance of a new procedure on

April 5, 1984 requiring the heat shrink tubing.

As'a result of this inspection, in response to inspector

. questions, the licensee determined that there are approximately'

650 Litton-Veam connectors installed at Millstone Unit 3. Of

these, the licensee identified 21 connectors that were installed-

without heat shrink tubing. Of the 21 connectors identified,

only two cases were found that were required to remain functional

to mitigate a LOCA/HELB event. These two cases involved position

indication for two containment isolation valves. The licensee

has placed administrative controls and the valves cautioned

tagged to remain closed except when needed to be opened. The

licensee has declared the position indication instruments to be

inoperable with permanent correc*ive action to follow.

This item is a violation of 10 CFR 50.49 in that the licensee

installed Litton-Veam connectors in a configuration fr* which

they were not qualified. 10 CFR 50.49 requires that all

electrical equipment important to safety be qualified.

(50-286/88-04-07)

12.0 P_lant Walkdown

The plant physical inspection consisted of an examination of specific

EQ electrical equipment selected from the EQ Master List. Components

selected for inspection include solenoid operated valves (S0V),

pressure / level transmitters, Limitcrque motor operated valves, cable

splices, connectors, radiation detectors, terminal blocks and wiring.

Inspection characteristics include mounting configuration, orientation,

connection interface, model number / type, physical condition and

. housekeeping.

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'Specift: conponents' selected for the walkdown include:

• Weed RTD, 3CCP and TE348, Zone AB-26

• Sulzer Brothers. solenoid valve assemblies, Zone MS-01

• Raycien Splices (various)

jl * Exo-Sensors, H 2Ana;yzer Bell and Howell 3 SSP /PT56A. Zone HR-01

- * Insulated Transmitters (Superheat Issue), Rosemount 3 MSS /PT514,

Zone MS-01

+ MOV-35B Zone ES-05

• Junction Box Number 3JB*7545, Zone ES-05 and 3JB*2649, Zone AB-06

.In addition, the inspectors examined junction Fox 3JB*2649 which contained

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Raychem splices that were applied over cloth braid jacketing material on '

the 50V pigtails. This type of installaticn is not in accordance with the

Raychem '! Product Installation and Inspectico Guide" on cable preparation

which states "Remove all non qualified or braided jacketing materials from

the splice area."

A~ review of licensee walkdown records for Raychem splices indicate

additional non-confor.ning conditions involving excessive splice bends

(less than the recommended 5 X Cable Outside Diameter) and splice seal

length areas of less than two inches.

These deficiencies constitute violation of 10 CFR 50.49 in that the

splices were not qualified per the instructions / procedures in effect at

the time of the installation. However, the current EQ file contains new

test data (issued March 1987) in which the Raychem splice seal length,

splice seals over braid, and splice bends as installed at Millstone Unit 3

are acceptable.

This item is a violation of 10 CFR 50.49 paragraph (f) which requires each

item of electrical equipment be qualified by testing and/or analysis.

(50-286/88-04-06)

13.0 Management Meeting

A management meeting was held on March 21, 1988, at the request of the

licensee, in Region I, to discuss and present (Attachment 1) a basis for

continued operation pending qualification of the Litton-Veam connector

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used-in safety related circuits.

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Matters discussed during'the meeting included a corporate mission state-

ment, introduction and identification of issue, overall adequacy of the

installed equipment, plant operations review, permanent corrective action,

. implications at other NUSCO sites and conclusions.

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During the meeting, the. licensee demonstrated that there was reasonable

. assurance that the installed equipment would operate in.a harsh

environment if required. Justification was made supporting the exclusion

of an anomalous test reading and the extrapolation of IR values to a

higher temperature than was recorded in the test report (No. 558-1657A).

Extrapolation of the LOCA test IR values, to a higher temperature than the

recorded values was based on the HELB qualification test for the unaged

Litton-Veam connectors, which documents recorded IR values at a

temperature of 335 F, exceeding the peak in-containment temperature of

327 . An evaluated IR reduction factor of 100 was used, based upon HELB

test data, in the application of this data to the unaged connectors for

in-containment application to demonstrate acceptable IR values. However,

since the reasonable assurance that the connectors installed in the

containment will function properly when exposed to a harsh environment

diminishes, as the connectors become significantly aged the licensee

tatends to replace this equipment with qualified feed-through devices.

The schedule for completing these replacements is the upcoming second

refueling outage for Millstone Unit 3, currently scheduled to commence in

June-1989. The NRC requested that the licensee provide a basis for

continued use of the existing connector seal (Silicon Rubber) which

appeared to be deteriorating. In order to demonstrate adequate seal

performance of the in-service connectors, the licensee initially proposed

to perform pressure testing on specimens containing both new and aged

seals. This test was to be completed by July 30, 1988.

Subsequent to the management meeting, the licensee had a forced outage at

Millstone 3 and took the opportunity to replace all of the silicon rubber

reals in the Litton-Veam connectors installed in the containment in lieu

of conducting the pressure tests. The NRC determined that these interim

actions were adequate to assure operability of the connectors pending

replacement of the in-containment connectors with qualified feed through

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devices during the next refueling outage.

14.0 Unresolved Items

Unresolved items are items which require additional data to determine

whether they are acceptable or violations. Unresolved items are

identified in details, paragraphs 7, 11.1.2 and 11.1.4.

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15.0 Exit Meeting

The inspector met with licensee representatives on March 18,.1988 at the

corporate offices in Berlin, Connecticut. The inspector summarized the

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At no time during the~ inspection was written material provided to the

licensee.

The licensee informed-the' staff-that there are no Litton-Veam connectors

in safety related circuits at other NUSCO sites. The licensee's

commitment to replace the in-containment connectors is documented in'

their letter-(B12874)-to the NRC dated April 4,1988.

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