ML20151C364

Insp Rept 50-312/87-44 on 871205-880203.Violation Noted. Major Areas Inspected:Operational Safety Verification,Maint, Surveillance & Followup Items

ML20151C364
Person / Time
Site:	Rancho Seco
Issue date:	03/24/1988
From:	Dangelo A, Miller L, Myers C, Perez G, Qualls P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151C355	List: ML20151C354 ML20151C361 ML20151C364
References
50-312-87-44, IEB-85-003, IEB-85-3, NUDOCS 8804120375
Download: ML20151C364 (33)

See also: IR 05000312/1987044

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U. S. NUCLEAR REGULATORY COMMISSION

REGION Y

Report No: 50-312/87-44 r

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Docket No. 50-312 i

License No. DPR-54 I

Licensee: Sacramento Municipal Utility District -

P. O. Box 15830

Sacramento, California 95813

Facility Name: Rancho Seco Unit 1  !

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Jnspection at: Herald, California (Rancho Seco Site) l

InspectionconductpI-  !

Inskectors:

A/ . D'An

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nior hesident Inspector

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Date Signed t

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]%&NgN' f(w.m k s.J) 3-2m?  :

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! Myers Dato Signeo  !

- [(>twed5,d 7-23-37

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yM Qual y nt InQector(/ / Date Signed '

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3-21-88  !

q/ Perez, Rydent Inspector Date Signed

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Accornpanied G. L. Johnson, Lawrence Livermore National i

Sy: L oratory I

Approved By: 3' b ~f3

j L. W. Miller, Chief, Reactor Projects Section 11 Date Signed i

Sumary:

Inspection between December 5, 1987 and February 3, 1988 (Report

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j 50-312/87-44.)

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Aress This routine inspection by the Resident Inspectors involved

lhe e/. ecsofoFerationalsafetyverification,

Inspected:

! maintenance,surveillanc1,and

! followup items. Tne following inspection manual e.ciptsrs were used during the  !

inspection: 30702, 30703 %701, 37701, 61776, 027f>3, 71707, 71709, */1881,  !

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7;710, 7274, ???GO, 51701. 'J27d?, S272C, 92703, 03702, 94702 and 94703.

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i Restits: in the Greas insbected, oN. viviation m ident)fied and is detailed

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WParsgrph 6 of thir. report.

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DETAILS

1. Persons Contacted

a. Licensee Personnel

G. C. Andognini, Chief Executive Officer, Nuclear

J. Firlit, Assistant General Manager (AGM), Nuclear Power Production

D. Xeuter, Director, Nuclear Operations and Maintenance '

J. McColligan Director, Plant Support

D. Brock, Acting Nuclear Maintenance Manager

• B. Croley, AGM, Technical and Administrative Services

G. Cranston, Nuclear Engineering Manager

W. Kemper, Nuclear Operations Manager

J. Shetler, Director System Review and Test Program

T. Tucker, Nuclear Operations Superintendent

P. Kagel, Nuclear Mechanical Maintenance Superintendent

L. Fossom, Manager, Scheduling and Outage Management

J. Field, Plant Support Group Supervisor

L. Conklin, Manager of Management Controls

• S. Crunk, Manager, Nuclear Licensing

• J. Vinquist Director, Nuclear Quality

T. Fetterman, Electrical Engineering Manager

J. Irwin, Supervisor, I&C Maintenance

T. Shewski, Quality Engineer

• J. Robertson, Licensing Engineer

• P. Bosakowski, Supervisor of Licensing, Technical Support

• G. Legner, Licensing Engineer

Other licensee employees contacted included technicians, operators,

mechanics, security and office personnel.

• Attended the Exit Meeting on February 3, 1988.

2. Operational Safety Verification (including Radiological Protection and

hhysical Security

The inspectors reviewed control room operations which included access

control, staffing, observation of decay heat removal system alignment,

and review of control room logs. Discussions with the shift supervisors

and operators indicated understanding by these personnel of the reasons

l for annunciator indications, abnormal plant conditions and maintenance

A>rk in progress.

One inspector participated in an Operational Safety Team Inspection

(0S11) which occurred December 7-18,1987 (Paragraph 6).

During the period, the reactor coolant system was filled and pressurized

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' in cold shutdown conditions with reactor core cooling provided by the

decay heat removal system (DHR). The inspectors also verified, by

observation of valve and switch postion indications, that DHR and the

emergency power supply systems were properly aligned for the cold

shutdown condition of the facility.

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Tours of the auxiliary, reactor, and turbine buildings, including

exterior areas, were made to assess equipment conditions and plant

conditions. Also the tours were made to assess the effectiveness of '

radiological controls and adherence to regulatory requirements. The

inspectors also observed plant housekeeping and cleanliness, looked for

potential fire and safety hazards, and observed security and safeguards

practices.

The licensee has undertaken a program of high pressure water jet cleaning

of the radiological controlled area within the auxiliary building. The

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program appeared to be conducted in a systematic fashion which has caused

an improvement in access to radiological controlled areas and general

housekeeping. For example, the 20 ft. elevation within the auxiliary

building had been used as an interim storage area for bagged low level

radioactive trash for several months. The cleaning program identified

this practice and cleaned the area. Housekeeping appears to have

significantly improved with the new cleaning program.

Throughout this report period, the plant remained in cold shutdown while

the licensee continued their efforts to restart the plant. During this

period the licensee made two 10 CFR 50.72 notifications. The two

notifications involved having both fire pumps inoperable and are

discussed in Paragraph 7 of this report.

No violations or deviations were identified.

3. ESF System Walkdown

During the inspection period, the licensee performed a hydrostatic test

on the secondary side of both steam generators. For the test, the

licensee established double valve isolation between the pressurized

portions of the steam generator, main steam and main feedwater systems

and the other plant systems which were not part of the systems to be

hydrostatically tested.

All valve boundaries which were part of the test were danger tagged in

, their assigned positions. The inspector walked down the "A" main system

valve lineups to verify their alignment. All valves inspected were found

to be in their correct position. The licensee's valve boundary criteria

was also reviewed. The established boundaries were found to be adequate

for the intended function of dual valve isolation with leak-off

provisions.

l No violations or deviations were identified.

4. Monthly Surveillance Observation and Review of System Review and Test

Program (SRTP) Testing

Special Test Procedures (STP's) were observed and reviewed to ascertain

that they were conducted in accordance with requirements. The

requirements for system functionality were contained in the System Status

Reports (SSR).

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Inpsections and observations were conducted on special test procedures

(STPs) and maintenance activities being conducted in support of the

restart effort to ascertain that they were conducted properly.

I The following testing activities were observed during this reporting

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l a. STP.667 - Emergency Feedwater Initiation and Control (EFIC) Retest.

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During the EFIC Cold Functional Test, several portions were retested

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after initial testing failed to meet acceptance criteria for the

control of OTSG 1evel. The licensee had to adjust controller gains

i and rate values to obtain the-system response to OTSG level changes

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which were within the system design parameters. After the system

adjustments were completed the STP was reperformed to document

system behavior. -This testing was performed with satisfactory

results obtained and all acceptance criteria were met,

b. STP.11348 - New Diesel Generator Retest

This procedure perfonned a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> full load test of the

Transamerica DeLaval Industries (TDI) "B" diesel. Vibration levels

were monitored and found to be to acceptable prior to this STP being

performed. This testing was completed and the test results were

under review by the licensee for acceptance. During the performa e

of this STP several new vibration locations were identified and w. .

be fixed prior to running this engine for any further testing.

Testing appeared to be conducted in compliance with quality program

requirements,

c. STP.1146B - TDI Diesel Generator Safety Control Air System

Functional and Capacity Test.

This test is designed to test the newly installed safety related

control air system for the TDI engine. During a previous review,

the licensee had determined that the diesel engine would become

unstable upon a loss or reduction in control air pressure. Prior to

the modification, control air was obtained from the engine starting

air receivers which are sized for starting the engine but not

maintaining control air pressure over extended periods of time

without the use of the air compressor. The air compressor is not

safety related.

The licensee completed the installation of this safety control air

system, which is safety related, and completed testing of both

trains of control air for each diesel. Test data was being reviewed

by the licensee at the end of the inspection report period.

The installation and testing of the control air system appeared to

meet the quality program requirements.

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d. STP.961 - Loss of Offsite Power Test.  ;

i The performance of this test was observed by the inspector. The  !

subtrain portions of the test that affected the Bruce GM diesel t

generators were completed by the licensee in a satisfactory manner.  !

During the perfonnance of the section of the procedure that dealt

with the operation of the "B" TDL diesel, an' oil leak on the fast

4 start accumulator for the governor required the diesel to be

shutdown. During the shutdown, the diesel generator was erroneously

paralleled to the offsite power grid while it was in the isochronous  ;

mode of operation. This caused the generator to go from 500 KW load .

i to approximately 3000 KW load almost instantly. The operator then  !

j attempted to reduce the generator load which in turn caused the  !

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generator to shed all of the load and become motorized. Normally,

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the generator breaker would have tripped on the reverse power flow,  !

but because the engine had been started by an Engineered Safety

i Features Actuation Signal (SFAS) this protective relay was bypassed.

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The diesel engine operator tripped the diesel by actuating the .

a emergency stcp pushbuttons at the local control panel.  !

The licensee promptly identified the chronology and procedural

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violations which occurred in this event. Neither the STP .961

. procedure nor any other site procedures contained steps to parallel

the generator to offsite power if the engine had been started with

an emergency safety features (SFAS) start signal, as in this case.

(The procedure did exist to parallel the generator to offsite power

when the engine was manually started.) When the diesel generator is

started by an SFAS signal, it is in the isochronous mode of

' operation, since it is the only generator supplying the bus. When ,

the diesel generator is paralleled to offsite power, the machine i

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must be placed in the droop mode by pressing the "LOCA Reset" button f

at the local control panel. As discussed above, the LOCA reset  ;

button was not described in operating or special test procedures at i

the time. ,

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As a result of the erroneous paralleling of the "B" diesel generator .

l to the offsite power grid while it was in the isochronous mode, the i

licensee issued a Stop Work Order for any further restart testing i

until the root cause of this event could be determined and the  !

lessons learned could be transmitted to the plant personnel. As a f

1. result of their investigations, the licensee determined the root

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cause of the event to be twofold. First, an inadequate test .

i briefing was conducted prior to doing the test. The operators had  !

not been briefed as to what to do or how to handle any situations  ;

not identified by the test procedure but created as a result of ,

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performing the test procedure, i.e., casualty or operating l

j procedures to be transfered to in the event of an abnormal situation

or a non obtainable test condition. Secondly, during the briefing '

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1 and the performance of the test procedure no definite criteria was

i specified to identify who was in charge, and at what point their  ;

1 authority would transfer to the next individual, i.e., Test Director

i to Shift Supervisor and vice versa. As a result of these findings,  !

a the licensee issued and required compliance with a Pre-test Briefing l

] Checklist, and established the control of all testing by the i

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Operations Department. The inspector has monitored several test

briefings and test performances since the licensee's implementation

of these new controls and has found them to be acceptable,

e. STP.1134A - New Diesel Generator Retest

This procedure performed a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> full load test with subsequent ,

100% load rejection, system fast restarts with a simulated loss of '

offsite power and safety features actuation signal, and a final

torsiograph run for the "B" TDI diesel. The licensee stated that  ;

vibration levels for this diesel had been brought into acceptable *

ranges, and this testing was performed. Test results review was in

progress by the licensee. The inspector observed that the testing "

had been performed in accordance with the procedure and appeared to

have been successfully completed.

No violations or deviations were identified.

5. Monthly Maintenance Observation - TDI Diesel Maintenance Activities  !

The maintenance activities listed below were observed and reviewed to

ascertain that they were conducted in accordance with' approved

procedures, regulatory guides, industry codes or standards, and the

Technical Specifications.

During this reporting period there were continuing modification ,

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activities being pursued on the TDI diesels. As each modification to .

. system piping was implemented the diesels would be started to perform

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vibration measurements in an attempt to bring the vibration levels down

to acceptable values.

! One of the major modifications installed was the fabrication and i

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installation of lube oil surge suppression chambers on the discharge of

the engine driven lube oil pump. The installation of this chamber did

reduce the vibration levels that were being experienced. The vibration

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levels on the "B" engine were reduced to acceptable values and the engine i

Wds declared ready for further performance testing.

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It was noted however, by the licensee that the drain valve at the bottom

of the chamber should be relocated from its horizontal position to a i

vertical position to reduce vibrations on the valve. During inspection .

i of the chamber on the "A" TDI it was discovered that the drain line had i

an excessive amount of foreign material lodged in it. This material

{ appeared to be metallic in nature and resembled weld slag or splatter. .

The Quality Control Department commenced an investigative effort to  !

I identify the material, locate the source of the material, and clean up i

the lube oil systems to ensure no further introduction of the material

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into the system. The investigation process identified the material as

- weld slag or splatter from the recen'ly fabricated and installed surge

e chamber. The chambers were opened on both engines and inspected. Only

j the chamber on the "A" diesel was found to be contaminated with foreign

j material. The lube oil systems of both diesels were dismantled and

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cleaned. The lube oil pressure control valve ("Bacci" valve) on the "A"

] diesel was found to have slight damage from the foreign material. The

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valve internals were replaced. One bearing cap was removed from the "A" i

engine and inspected for damage. The licensee determined that the

bearing was acceptable as found. A temporary strainer was installed in '

the Bacci valve line to protect it during the. engine lube oil flush run.

Both diesel generators were run for a minimum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at 1500 KW or

i greater with additional temporary filters and strainers installed to

collect any residual debris that was possibly overlooked during the

. inspection program. The "B" lube oil system was found to be clean during

this process. Only the "A" system appeared to have foreign material in

the lube oil strainers. The results of the lube oil flush runs were

determined to be within specification.

The inspector questioned the adequacy of the licensee's foreign material ,

exclusion program to prevent the entry of the weld slag. The material

found in the lube oil system was believed by the licensee to have entered

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the system through the lube oil surge suppression chamber. Prior to  :

installing the chamber, the licensee had the chamber cleaned by an i

offsite contractor and had also conducted a quality assurance

surveillance of the contractor. However, based on the finding of foreign

material in the 'A' chamber, it appeared that for the "A" chamber, the  ;

cleaning process had not been adequate. Although it appears that the  :

licensee's foreign material exclusion' program had not failed as *

implemented onsite, the licensee nevertheless increased quality assurance

control on activities involving the inter.al fluid systems on the

engines. All hose and temporary pumps used to transport fluids were

tagged and flushed prior to use on the fluid systems. Inspections for

cleanliness were performed on both oil chambers, lube oil piping and lube

oil reservoirs prior to refilling with new lube oil, i

The licensee action to investigate and prevent introduction of foreign

material appears to have been thorough and adequate to prevent

j reoccurrence.

j No violations or deviations were identified. ,

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! 6. Quality Programs and Administrative Controls Affecting Quality

l Corrective Action ,

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! In December 1987, as a part of the Operational Safety Team Inspection

(OSTI), the inspector identified some problems concerning licensee  !

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closure of Nonconformance Reports (NCRs). Licensee Procedure QAP-17,

l Revision 7. Nonconforming Material Control, required completion of all

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work specified in an NCR for the NCR to be closed. In addition, if an '

Engineering Change Notice (ECN) was issued in response to a NCR

J disposition, it required that the ECN must be closed prior to NCR

closure. During the inspection, a total of 22 NCRs were reviewed and 3

were found to be closed out not in conformance with licensee procedure  ;

QAP-17. NCR 57295 was closed out before closure of the ECN which resolved

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the Nonconformance. NCR 56053, Revision 1. Was closed out without all ,

! required work being completed. NCR S7272 was closed with a pneumatic

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test performed to verify work instead of the hydrostatic test specified '

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in the NCR disposition. No revision to the NCR disposition had been made

l to allow the pneumatic test. As a result of the inspector's findings,  ;

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the licensee instituted a review of completed NCRs to determine the scope

of the issue. They reemphasized a check sheet for the quality engineers

(QEs) to use for reviewing an NCR, and suspended NCR closure for a week

to retrain the QEs on NCR closure requirements. The actions of licensee

Quality Engineers closing NCRs not in accordance with licensee procedures

areanapparentviolation(87-44-01).

The subject of adequate identification of deficiencies which could

adversely affect quality was the subject of Inspection Report

(50-312/87-37) which also contained a Notice of Violation in this area.

The apparent violation cited here relates to the closure process of NCR's

which was apparently not in compliance with procedures.

The licensee has generated and intends to implement a new quality

reporting system called the Potential Deficiency in Quality (PDQ) system.

The PDQ system is the licensee's corrective action to the previous Notice

of Violation and other deficiencies the licensee has identified in their

corrective action system. The licensee had stated that the PDQ system

will be implemented prior to restart. -

The licensee stated that a review was being conducted of a portion of

previous NCRs to review for proper closure of the NCRs. The licensee

also ccnducted training of personnel involved in the closure process to

increase attention to detail.

One violation was identified.

7. Fire Protection / Prevention Implementation

On January 6,1988, the licensee notified the NRC that both fire pumps

were inoperable due to possibly unsatisfactory flow test results. To

perform the surveillance test for fire pump discharge flow, the licensee

was using a set of site-mada, non-UL listed, flow nozzles. This method

is acceptable under NFPA guidelines; however, the licensee determined

that the procedure assumed a flow friction loss coefficient (Cn)of 0.97

for the nozzles and that the site-manufactured nozzles could hMye a C as

low as 0.80. If a Cn of 0.80 was assumed, then the flow results woulb

have been unsatisfacYory.

To correct this, the licensee obtained a UL listed set of test nozzles

with a listed Cn of 0.97. Subsequent flow testing using the listed

nozzles was satYsfactory.

The licensee did not have a method to control the storage of the listed

nozzles after they were obtained. They were being kept by a site

engineer. Licensee management stated that this storage practice was

unacceptable and a formal method of storage would be located for this

equipment.

No violations or deviations were identified.

8. Followup on Previous Inspection Findinos (

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Enforcement Items

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87-06-06 (CLOSED), "Material Control"

The violation was written because the licensee was using a system of

material control which was not in any licensee procedure. The licensee

subsequentl.y formally documented the system in effect ("green tagging")  !

in AP.605, Revision 12 "General Warehousing" and QAP 6. Revision 3 "QC

Inspection". AP.605 was superseded by RSAP 0701, Revision 0 "Issue and

Return of Items to Storage" effective June 1,1987 but continued to

incorporate this method of material control. This item is closed.

87-20-05 (CLOSED), "Electrical Construction Discrepancies"

The previous inspection (50-312/87-20) discovered several items in the

TDI building which were not installed in accordance with the licensee's

construction standards. A Notice of Violation was issued (87-20-05) for

the items. Each of these items will be discussed individually.

Under-Radius Cable Bends

The inspector found cable in the terminal box for Essential HVAC Air

Handling Unit AH-DG-1B had a bend radius of approximately 3/4". The

minimum radius allowed by licensee procedures is 1.6" for the

installed cable.

Reinspection confirmed correction of the identified problem and did

not identify additional concerns. ,

Missing Cable Tray Edge Bumpers

The previous inspection found several cable installations that did

not contain cable tray edge bumpers required by the licensee's

procedures.

The licensee corrected the identified deficiencies and inspected the

remaining trays in the TDI building for similar conditions. No

additional cases of missing bumpers were found.

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Reinspection confirmed the identified items were corrected. No

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further cases of missing tray edge bumpers were detected.

Incorrect identification of Pull Box

The previous inspection found that electrical pull box H7J2995 was

labeled "black", not safety related. This box contains

safety-related Channel A cable, thus it should have been labeled

"red", indicating Safety Channel A.

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The licensee relabeled this pull box as appropriate. Reinspection

confirmed the labeling correction and did not identify further

i deviations in this area.

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The licensee had adequately addressed this item. This item is

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Followup Items

87-20-02 (CLOSED), "Electrical Cable Separation"

This open item had three parts, train separation of cables within

electrical enclosures, train separation of field cables, and separation

of power and instrumentation cables within manholes. Each of these items

will be discusses individually. A Notice of Violation was issued in

Inspection Report 87-20 (87-20-05) to describe the construction

deficiencies identified.

Cable Separation within Electrical Enclosures

The initial inspection identified several instances in which

separation criteria were not met within Transamerica DeLaval

Industries (TOI) and Emergency Feedwater Initiation and Control

System (EFIC) control panels. The licensee reworked these panels to

correct the identified deficiencies. They also reinspected all TDI

electrical enclosures that had the potential for separation

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concerns. The inspector examined the corrective actions, and

inspected cable separation in EFIC and TDI panels that were not part

of the original inspection sample. These panels showed evidence of

considerable effort by the licensee to identify and rework

installations that did not conform with separation criteria. The

licensee greatly reduced the number of deviations from their own

separation criteria. Nevertheless, a few deviations still existed.

1. In Diesel Generator Panel H2DGA2, a bundle of non-class 1E  !

cables containing cables 1G20GA2A, 112GA121G, 112D713A,

112GA117A, 112GA117B, and 182P003 violated the licensee's

requirement that at least six inches separate non safety

related from safety related wiring. Safety related cables

101A208A, ILIA 423A, 111A423A, IB1CA100P, 1811A100A,

181CA100N, and 1P1A202M were within six inches of the

above cable bundle. A similar installation was noted in

panel H20GB2 where the nonsafety cables were 1G2DGB2A,

112GB121B, 112C813A, 112GB1258, 112GB125A, and IB2P004.

The safety related cables involved were 1118423A,

IL1B423A, IB18100A, 101B203A, and IP18202M. The licensee

documented this finding, along with minor drawing

discrepancies noted during the inspection, in

Nonconformance Report (NCR) S7520. The licensee resolved

the nonconformance by reworking cable routing within the

panel to obtain the required separation. Reinspection of

these panels confirmed that the licensee corrected the

noted deficiencies.

2. In Emergency Feedwater Control Panel HISS, nonsafety

related wiring to device F1-31850 was within six inches of

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safety related wiring to the start /stop switch for P-319,

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The licensee reworked this installation to obtain the

required separation. A secord reinspection after the

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licensee corrected this deficiency identified no

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additional separation concerns within HISS.

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3. In Emergency Feedater Initiation and Control (EFIC) Field

Panels H4FWB and H4 FWD a small hole (abcat 3/8") was noted

in a conduit elbow that serves as the barrier between

nonsafety-related wiring located within six inches. The

licensee has since corrected this concern. The inspector

confirmed these corrections by reinspection.

During cable separation inspections within Panels H2SFA and H2SFB,

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the ir.spector noted several instances of poor vendor' workmanship on

solder connections within these panels. The most serious of these

was an apparent cold solder joint on device 78 in H2SFA. The

licensee documented this, and other findings in NCR S-7522. The

licensee's reinspection of the solder joint in question concluded

that, while workmanship could be improved, the joint was adequately

wetted. The licensee concluded that most of the noted items could

be accepted as-is; however, solder joints containing residual flux

would be cleaned.

The licensee made considerable progress in minimizing the number of

wiring separation problems with EFIC and TDI panels after the

original inspection. Dedication of substantial resources to the

identification and correction of separation problems did not,

however, succeed in eliminating these concerns. This indicated some

impediment to recognition of separation problems by construction,

maintenance, or inspection personnel in identifying separation

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requirements, and implementing separation criteria within

enclosures. The licensee has committed to provide additional

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training to these groups (Rancho Seco Commitment Tracking System

numbers: T880122003,T880122004,T880122005). The inspector

concluded that this comitment acceptably resolved this concern.

Field Cable Separation

The original inspection found several cases where separation of

redundant field cabling did not comply with the guidance of

Regulatory Guide 1.75 (RG 1.75). All of these instances had been

previously identified by the licensee. Each case was reviewed by

the licensee to identify corrective action, or to justify the

. deviation. At the time of the original inspection, the licensee had

completed a draf t report documenting their position on RG 1.75.

The Office of Nuclear Reactor Regulation (NRR) was reviewing the

licensee's position on this Regulatory Guide. In October 1987, the

NRC issued a Safety Evaluation Report accepting the licensee's

actions on all but two of the deviations. The licensee has

submitted additional justification for these two deviations,

i The licensee has acceptably addressed this portion of open item

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87-20-02. Closure of the two open items from RG 1.75 was still

under review by NRR.

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Separation of Power and Instrumentation Cables in Manholes

The previous inspection found that cable installation in Manhole 47

did not meet the Updated Safety Analysis Report (USAR) commitments

to physically separate engineered safety-feature instrumentation

cables from power and control cables. Separation of power and

instrumentation circuits is necessary to minimize electrical

interference in the-instrumentation cables. The previous inspection

found a number of instances where safety-related instrumentation

cable lay directly on top of power cables.

Since the original inspection, the licensee has walked down all

manholes that contain safety-related cable. Many instances of

intennixed power and instrumentation cables were noted and

documented in NCR 56999. The-licensee reviewed each instance of

power and instrumentation intermixing. In many cases, the

instrumentation cable involved was associated with switch contact

inputs to the plant computer. - These are binary signals that

represent switch open.and closed stages by relatively large

differences in voltage and current. These types of circuits are

relatively noise immune, therefore, the licensee has decided to

accept these installations "as is". In Manhole 6 analog

instrumentation cables were found mixad with power cable. The

licensee has committed to correct separation problems in Manhole 6

before restart (T880122002).

As part of the larger issue of instrumentation and power cable

separation, the licensee has revised two plant procedures to include

specific power and instrumentation cable separation criteria, and to

require a safety evaluation for any cases where the required

separation cannot be achieved. The USAR will also be revised to

incorporate the specific criteria.

The licensee has acceptably addressed this open item, 87-20-02. This

open item is closed.

87-20-03 (CLOSED), "Drawing Errors"

Thepreviousinspection(50-312/87-20) found six drawing change notices

(DCNs) which did not conform with the as-built configuration of the

plant. These DCNs were:

DCN DRAWING SHEET REY. FOR ECN

0 E-342 88 0 AS415-AA

0 1-1485 1 1 A5415-AH

0 1-1486 1 1 A5415-AH

0 1-1487 1 2 A5415-AH

0 1-1488 1 2 A5415-AH

(Sheet 3) E-402 19A 0 A5415-AH

The differences between the drawings and the plant were minor. The

licensee has corrected the drawings to reflect the as-built condition.

This item is closed.

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87-20-04 (CLOSED), "Essential HVAC Component Installation Errors"

The previous inspection (50-312/87-20) found two errors in the

installation of a Transamerica DeLaval Industries (TOI) building

essential Heating, Ventilation, and Air Conditioning (HVAC) control

thermocouple. Also noted was a discrepancy between the drawings and the

installed equipment on an HVAC damper. Each of these items will be

discussed individually.

Reversed Lead Markers for Thermocouple TE55701

The lead wire tags (possum tags) for thermocouple TE55701 were found

reversed from the drawing. Licensee inspection of the thermocouple

confirmed the identified problem and also noted that the

thermocouple lead wire insulation appeared cracked. The licensee

prepared a nonconformance report (NCR) which identified the

corrective action as replacement of the thermocouple extension wire.

Originally, the electrician reworking the extension wire had noted

that the insulation was not cracked. The apparent cracks were seams

between segments of shrink tubing installed to physically protect

extension wire insulation. Therefore, replacement was unnecessary.

The electrician then reterminated the leads per the drawing (but

relying on incorrect possum tags) after revising the work request

accordingly. Consequently, the inspector found the extension wires

were still mislabeled. Also, the thermocouple was now miswired.

The licensee again reworked the termination. The inspector

confimed this rework had left the extension leads properly labeled,

and the thermocouple connected properly.

Bottomed-Out Unistrut Bolts on the TE55701 Support

The original inspection (50-312/87-20) found that bolts attaching

the support for TE55701 to a Unistrut mounted on the TDI building

wall were not snugged against the support base plate. This occurred

because the ends of the attachment bolts had bottomed against the

Unistrut channel.

Subsequently, the inspector confinned that the attachment bolts have ,

been appropriately reworked. The reinspection, however, noted a  !

similar problem with seating the nut on an expansion anchor

supporting the equivalent thermocouple in the opposite train. The

licensee moved the opposite train thermocouple to allow installation

of new anchor bolts.

In this inspection, the inspector confirmed that this action had

finally corrected the tieficiency.

I

Discrepancy in HVAC Damper Actuator Model Number

l

This open item also covered a discrepancy between the model number  !

on safety-related HVAC damper actuator HV-55713 and the model number

shown on Drawing M17.07-6 of ECN-3748. The licensee confinred that

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the installed actuator is the correct model. The drawing was

corrected to conform with the field installation.

The licensee has addressed this issue. This open item is closed.

87-20-06 (OPEN), "Seismic Adequacy of Cable Supports

This open item addressed concerns with safety-related cable supports in

manholes and with raceway supports in the TDI building. These two items

will be discussed individually.

Safety-Related Cable Supports in Manholes

The previous inspection found that safety-related cables in manholes

were supported by a cantilevered arm which attaches to a wall

mounted bracket. Only the deadweight load holds the am in place.

The brackets were attached to the manhole walls by bolts to embedded

conduit support (c m only called "Unistrut").

The licensee had completed a calculation indicating that seismic

events will not dislodge the cantilevered ams in manholes

associated with the TDI. Evaluation of other safety-related

manholes was scheduled as a post-restart activity.

It was not clear that the calculation accurately reflected the

as-built condition. For example, one part of the calculation

analyzed the tension that would be present in a single cable if it

were to fall off the cable rack. This analysis showed that tension

in the smallest cable would be slightly below the pulling tension

allowed by the vendor. However, cables were not individually

installed on on the ams. Cables in the manhole are strapped

together in bundles; and these bundles are strapped to the

cantilever arm. Therefore, there was no assurance that the weight

of a cat,le bundle would be appropriately distributed amongst all of

the affected cable, if a bundle of cables slide off an arm, or if an

am disengaged itself from the bracket.

Furthermore, the licensee could not previously provide Quality

Assurance documents demonstrating that the connection of the ams to

the brackets, and anchorage of the brackets to the manhole wall,

were consistent with analytical assumptions. Therefore, there was

no basis on which to conclude that a seismic event would not

disengage the arm from the bracket or detach the bracket fom the

wall. In the extreme, a single cable might support the entire

weight of the cable rack and all attached cables, if the rack became

detached from the manhole wall.

The inspector concluded that the licensee had not yet satisfactorily

demonstrated the seismic adequacy of cable supports in manholes.

This portion of item 87-20-06 remains open.

Over-l.ength Bolts in Embedded Unistrut

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- 14

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The previous inspection identified several cases in which raceway

support attachment bolts in the TDI building were bottomed against

the back of the strut in which they were installed. With the bolts

bottomed out, it was impossible to dettrmine if the bolt / spring-nut

connection was adequately torqued. As corrective action, the

licensee inspected 98 raceway supports in the TDI building and the

Nuclear Services Electrical Building (NSEB). Twelve additional ,

cases of bottomed cut bolts were identified. In all cases the a

discrepant condition involved P1001 Unistrut attached to P3200

embedded Unistrut. Five inch bolts were used in theis configuration

where 4 15/16" depth is available.

As a result of this sample inspection, the licensee inspected all l

cases of the problem configurations in the TDI Building and NSEB. A

total of 2,341 bolts were inspected and 112 were reworked to replace '

.

apparently over-length bolts. Part way through the inspection, the

licensee revised the inspection process to allow the use of feeler

gauges to determine if the bolts were bottomed out. This revised

practice resulted from the observation that some bolts which  ;

visually appeared bottomed were not actually bottomed. Of the 112 '

reworked bolts, 80 were reworked on the basis of the visual  !

inspection alone. Therefore, these may or may not have actually

been bottomed out. Thirty-two were confirmed to be bottomed out by

the feeler gauge test. 7

The licensee performed a similar walkdown in the Reactor Building.

This walkdown inspected all accessible installations of the problem i

configuration. This sample represented about 85 percent of the

installations of concern. No over-length bolts were found. On the '

basis of this sample, further inspection of the Reactor Building was

concluded by the licensee to be unnecessary,

a

The licensee was also performing a walkdown of the Auxiliary

Building during this inspection. The licensee comitted to complete

,

,  ;

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this walkdown and any necessary rework before restart.

i

,

The inspector concluded that the licensee was appropriately

.

addressing this concern. Therefore, this portion of the open item

may be closed based upon the licensee's comitment to inspect and

rework the configurations of concern prior to restart.

'

This item remains open pending satisfactory demonstration of the seismic

l adequacy of the safety-related cable supports in manholes. 87-20-06

open.

1

87-20-07 (CLOSED), "Qualification of Cable-Wrap Hre Barrier"

i During the previous inspection (50-312/87-20), the licensee was unable to

4

produce qualification documentation for fire barrier materials used as

i cable wraps within electrical enclosures. Cable wraps are used to

establish physical independence of wiring where spatial separation is

impractical. These barrier materials have been in use at the site for

some time. Nevertheless, the licensee's representative stated that no

comitments to establish physical independence within panels existed

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until construction of the TDI and EFIC modifications. Therefore,

extablishing qualification of cable wraps for previous construction was

unnecessary.  ;

After the original inspection, the licensee reviewed the qualification of I

4 the fire-wrap materials in use. These reviews were documented in

, engineering reports ERPT-E0220 and ERPT-0223. These reports concluded

that all fire wrap configurations used at the site were acceptably

qualified.

The inspector examined the test report which was the basis for ERPT-0223.

This report showed that two of the configurations used by the licensee i

failed the test.  !

Each qualification test described by this report consisted of two pairs ,

of wire. The test subjected one pair to short circuit current until one

wire became an open circuit. The test was intended to verify that the

barrier material prevented significant damage to the second (target) pair

of wires. Both failed configurations contained type SIS wire as the

.

'

target. In one case, the protection was provided by a Siltemp sleeve

around the target wire. In the other case, the Siltemp was around the

faulted cable. These represent the only tests presented by the licensee

to support the qualification of Siltemp (either sleeve or tape) combined 1

with type SIS wire. After both tests the target wire insulation showed r

evidence of melting and softening. In some sections the insulation of

the two wires had fused together. Theinsulationregstanceofthetest

article dropped froni pre-test values of about 2 x 10 ohms to

S

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approximately 5 x 10 ohms. This post test value is 100,000 times lower

than the prior acceptance criterion which appears to be based upon ICEA

Standard S-19-81. The other configurations tested satisfied the

acceptance criterion. i

The licensee stated that while the accegtance criterion was not met, a

drop in insulation resistance to 5 x 10 ohms would not affect the

4 function of the circuits which use SIS wire. This assertion is valid.  !

However, the test was not designed to predict the insulation resistance

l] resulting from heat damage to the target wires. The test did not

successfully demonstrate that the Siltemp barrier is adequate te prevent

1'

significant damage to the SIS insulation.

Further review of the qualification report showed that the post test ,

'

I insulation resistance for one of the Siltemp/ SIS combinations (Test 14)

was identical to the value measured for a configuration that contained no

barrier (Test 29). The test report states that visual inspection of the *

1

test article from Test 29 found bare conductor showing through the

l insulation. Table 4 indicates that the post test insulation resistance

1 measured in Tests 14 and 29 was less than 500 k ohns, rather than

.!

500 k ohms as ctated in Table 5. These two facts lead to an inference -

that 500 k ohms was the minimum value of insuletion resistance that could

be measured by the test equipment,

,

In response to these concerns, the licensee presented an additional test

report to demonstrate the qualification of Siltemp tape for protection of

type SIS wire. The inspector examined this test report and found that

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the combination of Siltemp tape and SIS wire satisfied all test criteria.

! Although the qualification test did not include insulation resistance i

i measurements of the type specified by ICEA S-19-81, visual examination l

) demonstrated that the SIS insulation was undamaged throughout the test.  !

j Furthermore, temperatures at the target wires were measured to be well  ;

below the temperature that would damage type SIS insulation.  !

1 i

l The licensee also reviewed all applicatiuns of S11 temp sleeves. Their i

review found that, although allowed by procedures Siltemp sleeves have

not been used in conjunction with type SIS wire at the site. Ths

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licensee revised their procedures to remove Siltemp sleeves as an

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acceptable alternative to spatial separation.

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Item 86-20-07 is closed. [

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j 87-30-02 (CLOSED) SRTP $ystem Functional Test Program

!  :

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i in Inspection Report 37-30, the inspector identified two items

(functions) that were required to be tested by the licensee's System

Status Reports (SSRs) but which had not been s!milhrly identified in  !

j their Syttem Functional Test Program Overview documents.

i  ;

j The licensee has reviewed the omission of these items and has provided I

i the inspector with adequate documentation to remove the concern that  !

I

i

these items would be overlooked. The licensee has also provided the  ;

specific testing and suroeillance that will be used to verify that the l

l inadvertantly omitted fonctions would be perfomed prior to restart. The  :

j licensee's Test Review Group (TRG) was tasked with ensuring all of the  !

i function; identified in the SSR are verified by the test program ePt er  !

I by an STP, surveillance or analysis.  !

I

i

l The inspector has reviewed the identified tests for these omitted items  ;

and is satisfied that the concerns identified have been verified or will  !

I

be verified. This ite' is closed.

Il

Temporary Instructions

]I

j TI 2515/73 (CLOSED), "Followup of IE Bulletin 85-03: Motor Operated -  !

j Valve Common Mode Failures during Plant Transients Due to Improper i

Switch Settings"

l

l IE Bulletin No. 85-03, issued November 15, 1985 required the licensee to  !

] develop and implement a program to ensure that switch settings on certain  :

<

safety related motor-operated valves are selected, set and maintained l

i

correctly to accomodate the maximum differential pressures expected on '

l the valve during both nomal and abnomal events within the design basis. (

<.

i In response to IEB 85-03, the licensee submitted a description of the '90V ,

l refurbishnent and test program which they developed and implemented. The l

q licensee's program was submitted in the following doi:uments:  !

i

l

Licensee Correspondence No. Date Subject

l {

{ JEW 86-023 5/16/86 Original Response

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JEW 86-667 11/5/86 Updated Program

GCA 87-373 7/21/87 Correspondence

GCA 87-504 9/8/87 Program Description

GCA 88-005 1/19/88 Final Report

Furthermore, the licensee submitted the following Licensee Event Reports

(LERs) describing the M0V problems encountered during their refurbishment

program:

LER REV. DATED SUBJECT

87-06 0 2/17/87 MOV Operability Problems

87-06 1 4/15/87 Update

87-06 2 7/24/87 Update

87-06 -

9/21/87 Update

87-06 3 10/23/87 Final Revision

Finally, in response to a NRC Region V request for additional information

dated 9/22/87, the licensee submitted the following responses:

LICENSEE CORRESPONDENCE N0. DATE

AGM/TA 87-186 11/2/87

AGM/TA 87-194 11/12/87

At this time, NRR has not yet completed their review of the licensee

submittals in response to IEB 85-03. This review will evaluate the

adequacy of the committed schedule, a detailed review of the valve' switch

setting program and an audit of the design differential pressures.

The licensee's program appeared to address motor operated valve

deficiencies which it had identified. The licensee had developed a

procedure for determining valve differential pressure forces. The

procedure supplied the required torque switch setting without exceeding

valve yoke and body allowable stresses. Trending of valve performance

had been established to provide for validation of empirical equations

used to determine torque switch settings.

The setting of correct valve operator parameters had been established by

procedure. Maintenance personnel were observed by the inspector using

the motor operated valve setup procedure properly.

Inspection followup of the licensee's IEB 85-03 activities was previously

documented in the following NRC Region V inspection reports:

INSPECTION REPORT N0. DATE

50-312/86-21 8/7/86

50-312/86-30 9/18/86

50-312/87-09 5/19/87

50-312/87-20 9/21/87

50-312/87-23 10/1/87

50-312/87-24 10/16/87

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50-312/37-30 1?/1/87- ,

50-312/07-37 2/10/88-

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The inspector inonitored the licensee's tests and corrective actions .

.

during the development and implementation of their program. Based on the-

successful completion of the maximum differential' pressure testing of the

IEB 85-03 valves, and the licensee's trending of motor _ operated valve

failures if they occur, the implementation of the refurbishment program.

appears to be adequate.. Implementation of the motor operated valve

refurbishment program appear to be in accordance with their scheduled ,

commitments and was consistent with their committed program. (TI2515/73 l

- Closed). (IEB 85-03'- Closed). '

Part 21 Reports

87-09-P(CLOSED),"Square"0"Relays"

,

The licensee is revising Electrical Procedure EM 126 to ensure that the

continuously engergized relays are not magnetized to prevent proper '

operation. At each refueling outage, EM 126 will require that the

Square "0" relays be tested for operablitity. This item is closed. '

Licensee Event Reports

83-37-LO, L1 (CLOSED), "Reactor Building Emergency Sumr Valve, HV-26105"  ;

i

Theinspectorreviewedthelicensee'smotor-operatedvalve(MOV)

refurbishment' program and found that the reactor building emergency sump

valve, HV-26105, had oeen refurbished and tested under maximum

differential pressure as part of the licensee's program in response to l

IE Bulletin 85-03. Based on review of the licensee's final report for  !

l IEB 85-03 dated 1/19/88, the inspector found the licensee's corrective

! actions to be adequate. This report involved a motor operator on the "A" l

1 reactor building emergency sump valve failing to open the valve. The

I valve operator torque switch had opened, indicating sufficient torque had

'-

been developed during the opening cycle. Investigation by the licensee i

had not determined exact root cause, however the licensee believes the

problem was caused by an incorrectly set torque switch bypass. ,

'

The motor operated valve refurbishment program had included an aspect

which included setting of the torque switch bypass. Under that program

the break away torque which is needed to pull the valve globe off of the ,

, valve seat is measured. Limit switch position for the torque switch l

bypass is determined by the measured break away torque.

"

This method for setting the limit switch appears to be successful in that

this type of problem has not reoccurred with valves which have completed I

the refurbishment program. This LER is closed.

86-24-L0 (CLOSED), "Decay Heat Isolation Due To Loss of Inverter Power"

Licensee Event Report 86-20 described an inadvertent isolation of the

,

decay heat removal system due to a power failure on one inverter.

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The inverters in question contained four Silicon Controlled Rectifier

(SCR) bridges that were used to generate alternating current from the

direct current input. DC power to the SCR bridges was supplied through

two fuses. Each fuse supplied power to two bridges. Opening of one fuse

reduces the inverter output voltage, but does not cause total loss of

output.

Prior to the event, one of the fuses in Inverter SIA opened. Fuse

operation in this and similar inverters was not an uncomon occurrence.

Opening of the DC side fuse was believed to result from a lack of

coordination of protective devices downstream of the inverter with the

input fuses. While an electrician was preparing to bypass the inverter

to allow replacement of the fuse, the inverter tripped off line.

The licensee has experienced other problems with the inverters in

question. As a result, the licensee decided to abandon the inverters in

question and supply their loads from the newer NSEB inverters. These

iraerters are not su,bject to the coordination problem that caused the

need for the maintenance that initiated this event.

The licensee has also installed permanent provisions to bypass the

inverters to allow for maintenance. They installed regulating

transformers and static switchers that allow energization of each

inverter bus from a safety-related AC bus in the same train. The

switch-ovar occurs automatically on inverter failure; manual initiation

by maintenance personnel is also possible. The static switch provides

for synchronization of the inverter with the AC supply before transfer.

A proposed amendment to plant Technical Specifications will limit the

duration of operation with the inverter bus supplied from an AC source.

Manual or automatic switch-over of an inverter bus to an AC source will

result in a control room alarm.

The licensee has adequately addressed the cause of LER 86-24. Therefore,

this open item is closed.

87-06-L3 (CLOSED), "MOV Operability Problems"

This report described licensee identified problems which were discovered

as a result of response to IE Bulletin 85-03, "Motor Operated Valve

Comon Mode Failures During Plant Transients Due to Improper Switch

Settings". The condition discovered b; the licensee included over thrust

by the valve operator which could possibly ovarstress valve parts. Other

conditions identified included improper valve operator brake application,

undersized power cables, stem nuts not staked, identified valve internals

damaged, requalified grease and voltages out of specification.

Based on the review of the licensee's final report dated 1/19/88 which

reported the results of their program in response to IE Bulletin 85-03,

the inspector found the licensee's corrective actions to be adequate. In

particular, the test program implementation for maximum differential

pressure conditions appears to have been implemented adequately. This l

LER is closed.

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87-07-L0 (CLOSED), "Bailey Relay Module Lamp Short"

When replacing a burned out lamp in a Bailey relay module, a short to

ground occured when the bulb metal case touched the screw-in holder and

the panel simutaneously. Licensee investigation showed that, contrary to

standard lighting wiring practices of having the metal screw-in casing

for lamp bulbs at ground and the center as the source of potential, a

number of lamps were wired with the casing at potential and the center at

ground. This resulted in potential short circuits, when screwing a bulb

in, if the metal bulb casing should contact the screw and panel face at

the same time. The panels had been received from the vendor in this

condition. The licensee rewired the bulb receptacles and corrected the

problem. The inspector concluded that the licensee's corrective action

was adequate. This item is closed.

87-16-L0 (CLOSED), "Unterminated Cables Stored in Safety-Related

Electrical Enclosures "

LER 87-16 notified the NRC that the licensee discovered cable pulls made

into several safety-related breaker cubical cabinets and left unsecured

for a period of several weeks to three years. The unsecured cables were

believed to invalidate cabinet seismic qualification due to a potential

for seismically induced motion of the cable damaging or spuriously

actuating components in the cabinet.

The licensee committed in the LER to revise cable installation and

termination procedures to prevent recurrence of this type of event.

Additionally, the licensee committed to revise the plant modification

procedure to require verification that work requests provide for securing

or terminating cables imediately after pulls into permanent plant

equipment. Five procedures were to be revised:

MP/IS 307, Cable Installation

MP/IS 311, Low Voltage Termination and Splices

EM.145, Installation and Control of Temporary Cables

EM.163, Installation of Permanent Plant Cables

AP.44, Plant Modifications

In this inspection, review of the current versions of these procedures

found that MP/IS 307 and MP/IS 311 were appropriately changed. EM.163

has been replaced by IS-E-E5304.8 "Electrical Cable Installation and

Termination" which does not contain the requirement to secure cables if

termination does not immediately follow cable pull. AP.44 also had not

been revised in accordance with the LER commitment.

The licensee recognized that the commitment to revise these procedures

was still outstanding. They have further committed to revise

LER 87-16-L0 to indicate the new schedule for procedure revisions.

The open item is closed based upon the licensee's commitment to revise

the appropriate procedures. ,

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87-21-L0 (CLOSED), "Pressurizer Heater Damage After Relying on Inoperable

Pressurizer Level Indication"

This report identified the damage to two of three pressurizer heater

bundles while the bundles were energized and not sufficiently covered

with water. The low water level was not detected due to the reliance on

two of three pressurizer level channels which were not functioning

correctly.

The two channels ("A" and "D") were in error due to reference legs not

being full. The. status of.the two channels was being monitored in the

control room on a chalkboard which was misinterpreted by personnel and

believed to be operable at the time.

The licensee has revised their administrative control program to ensure ,

equipment status is documented and current. Increased attention by the l

licensee has been placed on labeling of out of service equipment in the

control room.

The licensee has also revised their procedures requiring redundant

instrumentation for some evolutions which are not governed by the

Technical Specifications. The licensee has replaced both affected heater

bundles and completed an evaluation of the pressurizer wall for potential

damage from heating by the uncovered heater bundles. The Office of

Nuclear Reactor Regulation is separately reviewing this evaluation for  ;

acceptability. The licensee appears to have resolved this issue.and this

item is considered closed.

87-34-L0 (CLOSED), "High Pressure Injection Minimum Flow Line was

Designated Non-Seismic"

This report involves the incorrect classification of the minimum flow

line from each high pressure injection pump and the makeup pump. These

lines were designated on the licensee's Master Equipment List as

non-seismic piping.

The licensee has corrected the classification error on the Master ,

Equipment List and has issued an engineering change notice (dR-1884) )

which upgraded the lines to a Seismic Class I line. Analysis and '

replacement of the piping had been complete along with 24 pipe support

modifications. The current configuration meets Quality Class I

requirements.

The inspector had previously identified incorrect classifications on the

Master Equipment List. The specific previously identified items have

been addressed and corrected. In addition, the licensee has established

a post restart item to review and update the Master Equipment List to

ensure equipment classifications are correct.

For restart all 33 selected systems (all nuclear safety related systems

plus selected non-safety systems) have been reviewed to ensure proper

seismic classification during the development of the System Status

Reports and are correct as-is to perfonn their intended functions as

stated in the System Status Reports.

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This item is considered closed based'on the licensee action which

upgraded the minimum flow lines on the high pressure injection. pumps and

the makeup pumps, and the commitment to review the Master Equipment List

for correct classification of equipment post restart.

87-37-L0 (CLOSED), "Makeup Tank Level"

The level of the Makeup tank slightly varied above the Technical

Specification limit due to an abnormal system line-up during the current

outage. The licensee took prompt actions to correct the level and the

operators-were subsequently briefed.on the event and its causes. These

corrective actions appeared adequate to prevent recurrence. This item is

closed.. ,

87-41-L0 (CLOSED), Potential Trip of Nuclear Service Cooling Water P0mps

.

Due to Design Deficiency"

This report involves the discovery of a Seismic Class II level switch

which during a postulated failure could cause a loss of Nuclear Service

Cooling Water. The switch in question monitors the level in the surge

tank and upon low level in the tank would trip the nuclear service

cooling water system pumps.

Licensee corrective action was to remove the level trip from the system

and rely only on level. indication. The nuclear service cooling water

system has three annunciator windows in the control room (low level,

low-low level and low pressure) and the licensee believes this would >

provide sufficient information to the operators to take necessary

corrective action. Licensee action appears adequate and this item is

closed.

87-42-L0 (CLOSED), "Amphenol Blue Ribbon Connector Failure Due to

Non-Conductive Coating" ,

'

This report involved the discovery by the' licensee of an organic

contamination of electrical connectors manufactured by Amphenol, Style

Type "Blue Ribbon". The source of the contamination appeared to be a

combination of the use of a commercial grade cleaner which contained a

plasticizer and the residue from the solder flux of the original

soldering of the field wires to the connectors.

The combination of the cleaner and solder flux appears to have led to the

formation of non-conductive contamination on the connectors, as stated by

the licensee's contractor. The affected connectors involved were in the

integrated control system, non-nuclear instrumentation, reactor

a

protection system and the emergency safety features system logic

cabinets. F

The licensee has completed the cleaning of all known affected connectors.

This was observed by the inspector. The cleaning was accomplished with

the use of a freon bath and demineralized water rinse with a chemical t

analysis to identify residue. All new cleaning of connectors by the

licensee was accomplished with cleaners of known chemical composition to

prevent reoccurrence. This item is considered closed.

'

No violations or deviations were identified.

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Unresolved Items

Master Tracking Item 86-08-05 (Closed)

This Master Tracking Item was used to envelop all the individual items

which pertained to the station batteries.

86-05-L0 (CLOSED), "Seismic Spacing of Batteries"

This open item tracked the licensee's action on LER 86-05 in which the

licensee reported the findings of open items 86-07-17 and 86-08-03 in

accordance with the requirements of 10 CFR 50.73. Licensee action on

these were discussed in open items 86-07-17 and 86-08-03. This item is

closed based on the closure of the two open items.

86-07-12 (Closed) "Station Battery Weekly Surveillance"

The previous inspection (50-312/86-07) noted two instances in which

surveillance test records indicated that battery "DB" pilot cell specific

gravity was low, but the licensee failed to perform the required

equalization charge.

The licensee produced additional documentation showing that an

equalization charge was provided in one of the above noted instances. In

the other instance, the monthly surveillance test coincidentally occurred

on the same date that the low pilot cell specific gravity was noted.

This test found the specific gravity of all other cells to be within the

normal range. The average specific gravity of the battery was such that

the battery's capacity was shown to be acceptable despite the pilot

cell's state of discharge.

The weekly battery surveillance procedure had at least two deficiencies.

First, there was no mechanism to identify and replace a degraded cell.

Second, the procedure contained no specific steps requiring equalizing

charge if the pilot cell specific gravity was low. The procedure

required equalizing only if the specific gravity had dropped at least

fivu points since the last surveillance.

Since the previous inspection, the licensee had issued a new weekly

surveillance procedure, "Weekly Nuclear Service Battery Test", SP.300.

This procedure corrected the identified deficiencies. The licensee

implemented procedures that require a Maintenance Engineering Department

review of battery surveillance data. Also, a board of maintenance

, personnel review surveillance and maintenance data for each quarter. The

licensee has further committed to trend battery test results on a long

term basis to identify slow degradation.

The licensee has demonstrated that the failure to place battery "BD" on

equalize charge after the pilot cell failed the weekly surveillance test

on November 4, 1985 did not jeopardize battery operability. Also, the

deficiencies in the surveillance procedure have been corrrected.

Therefore, this open item is closed.

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86-07-13 (CLOSED), " Station Battery Monthly Surveillance"

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The previous inspection (50-312/86-07) found that the licensee's monthly

surveillance procedure did not correct specific gravity readings for cell

electrolyte level. This could result in specific. gravity measurements

that read erroneously high. The licensee has since issued a new monthly

surveillance procedure, "Monthly Nuclear Service Battery Test", SP.301.

Both this procedure and the new weekly surveillance procedure correct

-specific gravity readings for level. Examination of the new procedures

she vs that together they address all of the recomended monthly

surveillance actions recommended by IEEE 450-1980.

The licensee has corrected the identified deficiencies in the monthly

surveillance test. Therefore, this item is closed.

86-07-14 (CLOSED),"Station Battery Service Testing"

At each refueling the Technical Specifications require that the licensee

conduct a battery service test. This test demonstrates the battery's

ability to supply bus loads. The previous inspection found the

licensee's service test procedure allowed adjustment of cell electrolyte

level and battery recharge prior to the load test. This action could

invalidate the test results.

The licensee has issued new service test procedures, SP.302 A, B, C, and

D "Refueling Interval Battery Service Test", and SP.323 A, B, C, and D.

"Battery Service Test". Examination of SP.302 A and SP.323 A showed that

they conformed with the recommendations of IEEE 450-1980. The design ,

load profiles have been revised since the issuance of these procedures.

The licensee has scheduled revision of these procedures prior to the next

refueling, when the service test is next planned.

The licensee has corrected the identified deficiency in the station

battery service tests. The item is closed.

86-07-15 (CLOSED), "Station Battery Maintenance Training"

Maintenance personnel interviews during the previous inspection

(50-312/86-07) found that the licensee had provided little training in

battery operating characteristics, early warning signs of degradation, or

proper preventive maintenance. Since the inspection, the licensee has

developed a new approach to battery maintenance, strengthened the

qualification standards applicable to battery maintenance personnel, and

improved maintenance personnel training.

The licensee has assigned a plant mt.intenance engineer and an electrician

to take primary responsibility for the battery maintenance program. This

was done with the intent that the day-to-day involvement of specific

individuals will improve the licensee's sensitivity to changes in. battery

condition.

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Qualifications standards for electricians who conduct battery preventive

maintenance and surveillances have been established. To qualify to work

on the station batteries, electricians must successfully complete courses

on battery theory and battery maintenance. Furthemore, knowledge of

battery maintenance activities must be demonstrated via a formal

on-the-job-training evaluation. The lead battery electrician, as well as i

several other electricians, have satisfied the battery maintenance '

qualification standards. Surveillances and maintenance are normally

conducted by a team comprised of a battery qualified electrician and

another electrician in process of qualification in this area.

, Qualification must be renewed no less than every two years. Review of

records for battery surveillances conducted since installation of the new

auxiliary building batteries showed that the lead electrician was

involved in all reviewed activities. The licensee expects to receive

INP0 accreditation of their battery maintenance training program.

In response to the previous inspection finding, the licensee also

provided maintenance personnel with vendor conducted training on battery

maintenance and indications of degradation. The licensee instituted the

requirement for battery maintenance personnel to complete on-the-job

training activities. The licensee had the battery vendor provide onsite

training regarding battery inspection. Furthermore, a discussion of the

care and operation of station batteries was added to licensed operator

requalification training. This discussion was intended to provide

operators with basic knowledge of battery theory and to sensitize

operators to battery problems that might be detected during operator ,

tours.

The licensee has appropriately modified the training m for station

personnel regarding station batteries. The inspects # , ' that the

battery training did not include discussion of any , ces in

'

characteristics between the new lead-calcium station bacteries and the

other types of cells previously used as station batteries, and currently

used in other applications on site. The licensee acknowledged the

inspector's comments. i

This item is closed.

86-07-16 (CLOSED), "Station Battery Replacement Criteria"

The licensee's station battery surveillance program was previously found

not to include testing that could be used to predict when the battery

should be replaced. The licensee has since developed battery capacity

test procedures, SP.324 A, B, C, and D, "Battery Service Test", and

SP.325 A, B, C, and 0, "Battery Performance Test". These procedures will

,

be performed every five years to monitor the degradation of battery i

capacity with time. The licensee has not yet developed procedures for i

trending the results of capactiy testing. They have, however, comitted i

to implement such procedures. Examination of SP.324 A and SP.325 A shows j

,

these procedures conform with IEEE 450-1980 recommendations regarding ,

'

capacity tests, with two exceptions. The pretest equalize charge and '

terminal inspections allowed by the IEEE standard are not included. The

omissions were intended to allow the capacity test to serve the purpose

of the Technical Specification required service test, and are acceptable.

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The licensee has corrected the deficiency in the previous inspection.

This item is closed.

86-07-17 (CLOSED), "Seismic Qualification of Battery Racks"

The previous inspection (50-312/86-07) found the station batteries were

installed with a greater gap between the last' cell and the rack than the

vendor recomends. The basis for the vendor recommendation was the

configuration used during the battery seismic qualification test. The

licensee had been aware of the vendor's limitations on end gap for

approximately one year.

In response to the finding, the licensee corrected the battery spacing.

The existing battery racks were subsequently replaced by racks for the

new station batteries. Inspection of a sample rack found it to be

installed in accordance with the vendor recommendations. The specific

rack anchorage used has been evaluated by the licensee.

The licensee stated that the failure to act on the vendor notification of

end gap requirements was due to a misunderstanding of the applicability

of these requirements. Similar batteries had recently been installed in

the Nuclear Service. Electrical Building (NSEB). The licensee erroneously

believed that the vendor notice applied only to those batteries. Thuc,

they took no action to correct the gap on the main station batteries.

The installation of new batteries and racks has addressed the previous

concern about battery rack qualification. This item is closed.

,

86-08-03 (CLOSED), "Station Battery Seismic Qualification"

The previous inspection (50-312/86-08) questioned the seismic

qualification of the station batteries based upon the above discussed

findings regarding end gap and battery degradation. Furthermore, the

inspection found the installed intercell spacing to be different than

that specified by licensee drawings, and from the seismic test

configuration.

The licensee justified the seismic qualification of the inspected

batteries based upon successful completion of service and load tests, and

experience data from the utility Seismic Qualification Users' Group

(SQUG), SQUG reviewed 72 examples of commercial batteries installed on

racks and that experienced major earthquakes. These earthquakes

represented peak ground accelerations up to .6 g, more than twice the  ;

design value for Rancho Seco. The sample included batteries and racks

manufactured by the vendor of the licensee's batteries, and included

batteries up to 14 years old. No failures were found.

Due to the concerns about existing battery degradation, the licensee

replaced the batteries in question. ECN R-608 documents the design of

the replacement batteries and racks. '

This item is closed.

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i

86-08-04 (CLOSED), "Battery Operability" '

This finding questioned the operability of the licensee's station

batteries based upon the observed deterioration of the plates' attachment

to posts. The licensee's efforts to demonstrate seismic adequacy of the

old batteries was already discussed in open item 86-08-03 of this report.

To demonstrate the operability of the new batteries, the licensee

performed capacity tests during the last quarter of 1987. All capacity

tests were successful. The testing, however, resulted in electrolyte

stratification that has caused the measured specific gravity for many

cells to be-below the nominal. The licensee recognizes that correction

of this condition is necessary before restart. The vendor normally

recomends continuous equalization for about a month to correct

stratification. The licensee cannot implement this recommendation and  :

still perform the required weekly surveillances. Therefore, the licensee

is equalizing as much as possible without interfering with the

surveillance testing. Measured specific gravity appears to be responding

to this treatment. Individual cell voltages and tattery voltage are

above the specified values.

Based upon the operability demonstration for the new batteries, the open

item is closed.

86-08-05 (CLOSED), "Battery Surveillance Program; "85-08-02" Battery

Surveillance Program"

i

The previous inspections questioned whether.the licensee's surveillance

testing was adequate to determine station battery operability. This

concern stemmed from the fact that the visible deterioration of the cells

was not reflected in the results of the battery surveillance tests.

Furthermore, as discussed in Open Item 86-07-14 in this report, the

battery service test procedures allowed battery refurbishment before

testing.

The licensee justified the operability of the old batteries via a

combination of testing and analysis as discussed in Open Items 86-08-03

and 86-05-03 in this report. The old batteries were replaced and their

operability demonstrated by the performance of battery capacity tests.

The service and capacity testing of both the old and new batteries were

conducted using new service and capacity test procedures. Review of the l

procedures confirmed that they conform with the recomendations of l

IEEE 450-1980. The capacity tests of the new batteries included battery l

maintenance prior to the test, as suggested by the IEEE standard. The '

licensee's position was that this was justifiable because the test

represented an acceptance test for r.ew batteries rather than proof that

existing batteries would have had sufficient capacity if called upon to

carry rated load. Current licensee procedures do not allow rework of the

batteries before capacity testing in order to ensure that the tests

demonstrate the as-found condition of the batteries, as required by the

Technical Specifications.

4

Review of the current battery service tests and battery sizing

calculations showed that the current demand curves are more severe than

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those included in the test proceaures. The licensse is aware of this

difference and will appropriately revise the tesc prCcedures before the

next surveillance tc3t. The difference :n reouirements does '1ot affect

the capacity test used to ded.onstJate battery opertbility for d i tup.

The inspector concluded that the licaste had corrected the identified

deficiencies in t e battery surveillance program. Therefore, */11s open

item is closed.

This coinpletes the Ma:tn Tracking Item hbiters. Master Tracking Item

86-08-05 is closed.

87-21-02 (CLOSED), "Cable Ampacity"

The original inspection questioned the accuracy of cable ampacity

calculations used as the basis for accepting cable tray filled beyond the

USAR fill limits. The inspection found that specified overload current

margins had not been considered, evaluation of overfilled conduit did not

address ampacity effects, and design standards did not correlate with the

USAR commitments.

Subsequent to these findings the licensee reviewed the bases for cable

sizing during various intervals of the plant life. They also reviewed

cable sizing for a set of cables selected as the most likely candidates

for undersizing. This study, documented in ERPT-E0294, "Report for Power

Cable Sizing and Derating Review" concluded:

1) The Rancho Seco Design Guide based upon the number of

conductors method of ICEA-P-42-426 (1962) was used prior to

1975,

2) Bechtel Power Corporation standards and licensee standards

based upon the percent fill method of ICEA 54-440(1979)were

used after July 12, 1982.

3) For the interval between 1975 and July 12, 1982, it was riot

evident that either the Rancho Seco Design Guide or the

applicable standards formed the basis for cable sizing.

4) Calculations used to derate cable in fire-wrapped raceway

contained a number of deficiencies that could cause the

derating to be nonconservative.

5) Current design guides may not be applicable to all tray

configurations in use.

6) The sample of cables studied included a number of cables which

were not sized for the overload condition. One cable was noted

which was not adequately sized for normal load conditions. The

number of undersized cables identified led to a recommendation

that the licensee review ampacities of additional cables.

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As a result of this study the licensee has:

1) Revised the calculations addressing fire-wrapped raceway. The

revised calculations identified additional cables that were

insufficiently derated.

2) Planned for revision of cable sizing design guides shortly

after restart. Meanwhile, the sizing of all power cables added

to the plant were being reviewed by individuals involved in the

cable ampacity studies.

3) Reviewed the ampacity of all 4160 V and 480 V power cable not

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already evaluated by an existing calculation, and not contained

in duct bank. This review identified several additional cables

that did not meet the existing sizing criteria.

4) Reviewed a sample of 125 VDC and 120 VAC power cables expected

to be the most likely candidates for ampacity concerns. This

review identified no cable sizing problems in these voltage

classes.

5) Developed a calculation addressing the specific instances of

,

under-rated cable identified by the previous inspection.

. 6) Developed calculations covering new installations of

fire-wrapped raceway.

7) Calculated the maximum allowable raceway fill. Their cables

were found to be adequate given the current raceway fill, but

undersized for the design limit of 40 percent fill. The

licensee will modify the Circuit and Raceway Tracking System

(CRTS) to block fill of these raceways beyond the calculated

limit. In the interim, the review process mentioned in item 2

,

above is assuring fill limits are not exceeded.

i The reviews described above represent, with two exceptions, a 100 percent

review of 4160 V and 480 V power cable ampacity. The two exceptions are

cable continued in duct bank and power cable containment penetrations.

The licensee has examined these areas and has concluded that sizing

concerns do not exist. Formal calculations addressing these items are

scheduled for completion after restart.

The above studies did not apply the 125 percent overload factor committed

to in the USAR to transformer, load center, motor control center,

receptacle, or heater supply cables. Furthermore, where a single feeder

supplies more than one motor, the 125 percent factor was applied only to

the largest rated motor on the feeder. The licensee interprets the USAR

comitment on applying the overload factor as pertaining only to loads,

not to distribution components in the supply path. This is a reasonable

'

approach because simultaneous overload conditions on all loads served by  ;

the distribution components is unlikely. The only item which may not be

consistent with USAR comitments is the decision not to apply the

overload factor to heater feeds. The approach is technically acceptable,

because overload conditions in heater circuits would be difficult to

,

obtain.

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For all undersized cables the licensee has either:

Implemented modifications to correct the problem,

Performed a more detailed analysis of the specific installation

and/or service to establish that the existing cable's ampacity is

indeed adequate, or

Justified interim operation based upon existing cable condition,

loading condition, or operating restriction. In these cases,

replacement of the undersized cable is sc.eduled on the Long Range

Scope List.

Included in the third category above are Cables 121A127A, 121A129A,

121B131A, 121B133A, and 122C150A, which power the Auxiliary Building

Battery Chargers. These cables were undersized for the current drawn by

the chargers when supplying equalize current to their respective

batteries. These cables and one other, 121A174A, were also marginally

underprotected if a fault were to occur at the time of an equalization

charge. The licensee planned to correct these conditions before restart

from the next refueling. Licensee calculation Z-EDS-E0755 shows that a

fault at maximum charger current would raise the conductor temperature a

few degrees above the lowest point where insulation damage might be

expected. The licensee planned to implement a temporary procedure change

to indicate that the spare chargers should be used if recharge of a

completely discharged battery was necessary.

These same six cables were not protected for line-to-line faults low ,

enough in impedance to cause a damaging current level, but of such high l

impedance that the fault current is below the breaker trip setting.

Indeed, a continuously maintained line-to-line fault current at or just

below the breaker thermal setting would raise the conductor temperature

above the insulation igMtion temperature. The licensee has justified

interim operation in this condition based upon the extreme improbability

of long-term, high impedance, line-to-line faults. The most likely type

of fault would be a line-to-ground fault. A ground current relay set at

10 Amps provides protection for this type of fault. If a high impedance

line-to-line fault were to occur, the initial damage to cable insulation

would be expected to cause a line-to-line fault impedance enough that the

breaker trips. In fact, the licensee has performed an informal

calculation that shows this would happened before significant conductor

temperature is obtained. A formal calculation to this effect is being

prepared. There is no credible comon cause which could produce a high

impedance, line-to-line fault in more than one train.

The licensee documented these problems in NCR S7684 and performed a l

10 CFR 50.59 review of the basis for interim acceptance of these cables. l

The review concluded that interim use does not present an unreviewed 1

safety question, and that the limitations placed upon charger operation

are consistent with the Technical Specifications.

Four cables in the third category were found to have sufficient ampacity

and to be adequately protected for short-circuit fault currents.

However, these cables, 1228134A, 122B1348, 122A130A, and 122A130B, which

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power the nonsafety battery charger H4BEF, have a similar problem

regarding protection for high impedance line-to-line faults. In these i

cases, the worst possible steady state fault current would raise the ,

conductor temperature enough to shorten the cable's life, but not enough '

to ignite the insulation.

1

One other set of cables in the third category 'above were too small -for l

the normal load. These were power cables to the turbine building exhaust

fans, which was not a safety-related application. The excess load would

reduce the cable's lifetime, but would not cause immediate, catastrophic

failure. The licensee has visually inspected the affected cables and has I

measured their insulation resistance to confirm the integrity of their l

insulation. The inspector also visually inspected conductor insulation

at one end of the affected cables and confirmed there is no visual

evidence of damage. Based upon the visual and insulation resistance

tests, the licensee has decided to postpone replacement of the affected I

cables until after restart. j

This open item is closed based upon the conclusion of the licensee's

50.59 evaluation, the inspector's evaluation, and the licensee's

commitment to correct the identified problems before restart from the

next refueling. This item is closed.

9. Facility Modifications

1

Review of Stress Analysis on TDI Lube Oil Piping l

The inspector reviewed the stress analysis calculations performed for the

Transamerica DeLaval Industries (TDI) emergency diesel generator lube oil

discharge piping (Calculation #Z-LOS-M2350). The diesel engine skid .

piping has had several piping configuration changes during the current I

outage to resolve piping vibration problems with the lube oil return

piping. The calculation was reviewed for compliance with ANSI B31.1-1980

(the piping code which the licensee has committed to) and quality

assurance program design control requirements.

The calculation was prepared prior to the final configuration of the

piping having been established. Although the analytical model used in

the current calculation at the time (December 8, 1987) did not agree with

the as-found condition of the diesel, the licensee had the engineering

change notice which controlled tb work effort open and engineering

personnel were aware of the piping differences.

Review of the calculation revealed that the engine driven lube oil pump

did not contain vendor supplied allowable nozzle load data. Licensee

engineering had determined the pump nozzle load allowable through the use

of a procedure found in the Bechtel Design Guide (#P-2.6.1.11 Rev.1).

The approach used is conventional industry practice and appeared to meet

the piping code rules.

However, the licensee's calculations o' piping stresses revealed that for

the thermal case, nozzle load allowables were exceeded. The calculated

= 1136# and F = 1501

loads

F = were F*The justification prov#

1133#. idedasinopposed to allowables

the licensee's analysis of

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accept the overload was based on the fact that the empirically determined

allowable from the design guide was very conservative, and also that the

engine had been run and tested for an extended period of time without any

indication of failure.

Although no apparent damage to the diesel engine has resulted, the

justification did not appear to be sufficient evidence to defend the

overload condition. No other discussion was included within the

calculation to address either a refinement to the determination of the

nozzle load allowable or an acceptable reduction in margin when the

allowable load is exceeded in the analysis. The licensee agreed that the

justification provided in the analysis for exceeding the allowable

criteria was not acceptable, and would be revised when the final analysis

was performed on the as-built piping.

Calculation Z-LOS-M2350 was revised on February 20, 1988 and did reflect

the current as-built piping configuration. In addition, the revised

piping arrangement also has reduced the lube oil pump nozzle load to

below calculated allowable loads (F* = 713#, F z=68#) for the deadweight

plus thermal loadcase.

The inspector's review of the February 20, 1988 stress analysis did not

reveal any discrepancy with piping code requirements. The analysis

appeared to meet quality assurance program requirements with no

deviations or violations identified.

10. Unresolved Items

Unresolved items are matters about which more information is required to

detemine whether they are acceptable or may involve violations or

deviations.

11. Exit Meeting

The inspector met with licensee representatives (noted in Paragraph 1) at

various times during the report period and formally on February 3,1988.

The scope and findings of the inspection activities described in this

report were sumarized at the meeting. Licensee representatives

acknowledged the inspector's findings and the violation identified.