ML20150E128
| 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: |
| References | |
| 50-423-88-04, 50-423-88-4, NUDOCS 8807150010 | |
| Download: ML20150E128 (23) | |
See also: IR 05000423/1988004
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U.S. NUCLEAR. REGULATORY COMMISSION-
REGION I
Report No. , 50-423/88-04
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' Docket No.
50-423
License No.
Priority
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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
below.
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. Description
-Paragraph
Item No.
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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.
Technical Specifications
Final Safety Analysis Report
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
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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
equipment to preserve its qualified status, ensure that equipment and
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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
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acceptable.
The inspector reviewed implementing procedures and systems
and associated records and conducted observations and interviews to
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confirm its adequacy in practice.
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The EQ information submitted by NNECo indicated that a design temperature
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of 90 F was used as a basis for Arrhenius qualified life calculations for
equipment located inside containment. This low value was questioned by
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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
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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
of the JC0 process and corrective action.
(50-286/88-04-01).
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The inspector:also r_eviewed audit Find'ng No. 3-10 (dated May-July 1987)
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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.
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Prior.to licensing MP-3, it was determined that this qualification of the
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-
tory Guide 1.97 revision 2 and the requirements of 10 CFR 50.49. The
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Kamans.were removed from the EQ Master List in the March 13, 1988 revi-
sion.- Licensee Reportability Evaluation No. REF-87-21, dated February 9,
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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)
indicates IR problems with the HRRM cable assembly which impacts on
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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.
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appears that the licensee was still in the process of evaluating the
In spite of several statements declaring qualification of the GA HRRM, it
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
equipment important to safety be qualified. The licensee has not
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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
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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
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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
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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
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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- 11.1.2 EEQ File 2474.303-L24 (General Atomics Radiation Monitor)
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
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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 , A , and A ) were
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terminated with 4 conductor #16 BIW instrument cables. The
second set of samples (8 , 8 , and 8 ) were terminated with 3
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conductor #14 Okonite control cables. The third set of samples
(C , C , and C ) were for thermocouple applications. The third
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sample in each set (namely A , 8 , and C ) was not pre-aged or
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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 A and 8 consistently showed IR
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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 and B ) had higher IR values.
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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)
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- Exo-Sensors, H Ana;yzer Bell and Howell 3 SSP /PT56A. Zone HR-01
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- Insulated Transmitters (Superheat Issue), Rosemount 3 MSS /PT514,
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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
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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
devices during the next refueling outage.
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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
scope of the inspection and the inspection findings.
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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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