ML20151V995
| ML20151V995 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/22/1988 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8805030265 | |
| Download: ML20151V995 (2) | |
See also: IR 05000245/1987017
Text
{{#Wiki_filter:I e , APR 2 21988 Docket Nos. 50-245 50-336 Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen: Subject: Inspection No. 50-245/87-17 and 50-336/87-15 This refers to your letter dated December 18, 1987, in response to the subject inspection report. Thank you for informing us of the corrective and preventive actions taken on violations 87-15-01, 02, and 87-17-01. These actions will be examined during a future inspection of your licensed program. With regard to your discussion of the two deficiencies identified and corrected by NNECO in 1986, i.e., qualificaiton of ideal wire nuts and spray pump motor terminations, we have noted the discrepancies identified by you in our inspection report. The additional qualification information provided by you to support operation of these items in the event of an accident will be given consideration as a part of any forthcoming enforcement actions. Your cooperation with us is appreciated. Sincerely, Or16 LalSIM*d?/8 1 [ William V. Johnston, Acting Director Division of Reactor Safety , cc w/ encl: W. D. Romberg, Vice President Nuclear Operations S. E. Scace, Station Superintendent D. O. Nordquist, Manager of Quality Assurance R. M. Kacich, Manager, Generation Facilities Licensing [[dh Gerald Garfield, Esquire Public Document Room (POR) local Public Document Room (LPOR) i Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of Connecticut OFFICIAL RECORD COPY RL MILL 87-17/15 - 0001.0.0 04/15/88 8805030265 880422 PDR ADOCK 05000245 s Q PDR - p
. " Northeast Nuclear Energy Company 2 bec w/ enc 1: Region I Docket Room (with concurrences) Management Assistant, DRPA (w/o encl) ORP Section Chief P. Swetland, SRI, Haddam Neck J. Shediosky, SRI, Millstone 3 D. Jaffe, LPM, NRR M. Boyle, LPM, NRR R. Bores, DRSS , i 1 ' 1 I RI:DRSh RI:DRS / RI DRS R TKoshy/sh/pj RPaolin CAnderson JDurr 04//S/88 04//8/88 04// i'/88 04/ /8C OFFICIAL RECORD COPY RL MILL 87-17/15 - 0002.0.0 04/15/88 . i _-
, , ~ . . . . NORTHEAST UTILITIES o... On.c. . s.m.n si...t e..,,s. crmi,c u ,,-....:.. 9 . .c,% ..mw.ua c % a , PO Box 270 . m . . i . .. . w J . . .v vo u .i u.-. H ARTFOAD. CONNECTICUT 061410270 .e mi .. (203) 665 s000 _ December 13,19S7 Docket Nos. 50-243 50-336 A0693S Re: 10C F R 50.49 Mr. William V. Johnson, Acting Director Division of iteactor Safety Region i U. S. Nuclear Regulatory Commission 631 Park A<enue King of Prussia, PA 19406 Gentlemen: Milhtone Nuclear Power Station Unit Nos. I and 2 Subject: Response to inspection Report Nos. 50-245/S7-17 and 50-336/S7-15 1. INTRODUCTION By letter of Noveinber 19,1957, the NRC Staf f transmitted its Inspection Report Nos. 50-245/S7-17 and 50-336/37-15 and associated Notice of Violation relating to the Region 1 Staf f's unannounced inspection of July 15-17,19S7, of Millstone Nuclear Power Station, Unit Nos. I and 2. In its letter the Staff identified three proposed Severity Level IV violations and requested that Nor theast Nuclear Energy Company (NNECO) respond to each within thirty days. In addition, the Staf f stated that it was considerind enforcement action regarding two other "Equipment Qualifiu tion (EQ) deficiencies" which were previousl/ identified and corrected by NNECO (b, Ideal wire nuts and spray pump motor terminations without qualification docu nentation). By this letter, NNECO responds to each proposed violation and provides additional information to the Staf f reguding ideal wire nuts and spray pump motor tersninations to assist the Stc.fi in its e / a lua tion. II. NNECO RESPONSE TO VIOLA flONS NNECO's response to the three proposed Severity Level IV violations identified by the Staff is set forth below: A. General Electric SIS Wire 1. Staf f Statement of the Proposed Violation: "10CFR 50.43(f) requires that qualification of each component be based on testing or experience with identical equipment or with
_ _ ' ' . , . . Mr. William V. Johnson A0693S/Page 2 December 13,1937 . sitnilar equipment with a supporting ar.alysis to show that the equipment to be qualified is acceptable. 10CFR50.49(k) requires, tha t electrical equipment need not be requalified if it was previously required by the Commission to be qualified in accordance with the ' Guideline for Eialuating En< iron- mental Qualification of Class lE Electrical Equipment in Operating Reactors' (DOR Guidelines). Section 5.2.2 of the DOR Guidelines requires that the type test is only valid for equiprnent identical in design and rnaterial construction to the test specimen, and any deviations should be etaluated. Contrary to the above, as of July 17,19S7 the licensee was not able to provide docuinentation to establish qualification by test or analjsis , of General Electrical (GE) SIS wire used in Valves 2 51-651, 2-CH-501 and 2-S!-644 This is Se<erity Level IV (Supplement 1) applicable to Unit 2." 2. NNECO Statement of Position and Root Cause Analysis: Prior to the July 1937 audit, NNECO was not aware of the difference between the two GE Vulkene S15 wire types. During the July 15-17, 1937 audit, the NRC Staff discussed with NNECO a 1934 letter from GE te Bechtel alleging a substantial difference in performance between General Electric (CE) Yulkene SIS and GE Vulkene Supreme SIS wire. Qualification of the GE Yulkene wire installed at Millstone was based on a walkdown in 1936 and on a 1977 FIRL test report F- C4497-2. Froin further review it was determined that this report qualifies e trious Vulkene insulated wires and cables including Yulkene Supreme 515, but not Vulkene S!S wire which was installed in the , ' plant. Accordingly, NNECO does not contest the violation. ,f' , 3. Corrective Action Taken: , After notification of the different Vulkene wire types, NNECO reviewed installed applications of the wire and expeditiously replaced the wire in equipment subject to 10CFR50.49 require:nents. Subse- quent to the removal of the Vulkene SIS wire, NNECO obtained a test report that established qualifiability of the wire. NNECO belic<es that the conservative actions taken by Millstone Unir No. 2 were consistent with corporate priority placed on Environinental Qualifi- cation. 4. Actions Taken to Prevent Further Violations: The following actions have been taken to minimize the risk of future violations of this type l
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. . , 1 . Mr. William V. Johnson A06933/Page 3 December 13,19S7 . NNECO had previously completed a review of the EQ prograrn and o equipment which provides increased assurance that this situation is isolated. o NNECO EQ engineers have been counseled to rnore closely scrutinize possible model/ type differences between installed equipment and equipment qualification files, < NNECO will continue to be active in industry EQ group efforts o which will assist in identifying any new discrepancies of this na ture. B. Bis 5cc Ts. e c ' l. Staff statement of the Proposed Violations "10CFR50.49(1) requires that replacement equipment be qualified in i accordance with the provisions of this section unless there are sound reasons to the contrary. j 1 Contrary to the above, it was observed on July 17, 1937 that the ' Bishop cable splice installed on inctor operated <alie 2-S1-654 o') the \\tay 31,19S6 was not qualified to the requirements of 10CFR30.l.9 and as of July 17, 1937 the licensee had not addressed any sound reasons to the contrary. This is Severity Level IV (Supplement 1) applicable to Unit 2." 2. NNECO State nent of Position and Root Cause Analysis: Daring the May,1936 turbine inspection outage at Millstone Unit i No. 2, an inspection was performed on motor operated val <e (MOY) 2- S1-65:. for the purpose of identifying motor control wire. In the course of this inspection, it was noted that the motor leads were not terrninated on a tertninal block, but instead were terininated with a taped splice joint. The tape used on the splice joint could not be positively identified at that time and was removed for further , ! inspection and to examine the splice joint itself. It was obviously ! necessary to rewrap the splice joint prior to restarting. At the time, there was no NUREG-0533 Category I splice materials in stock. The only inaterial available to support the outage work schedule was , Bishop tape which was considered to be DOR qualified. The decision was rnade to rewrap the splice using the Bishop tape. Therefore, at the time the splice joint was rewrapped a justification (sound reason) existed for using the DOR qualified Bishop tape and not upgrading. However, this sound reason was never documented in the EEQ file, i . _ . . _ _ _
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, 1 Mr. William V. Johnson A0693S/Page 4 December IS,1937
Accordingly, NNECO does not contest the violation.(l) NNECO contends that due to the underlying circumstances at the time (i.e., unscheduled outage straining the electricity pool and a lack of NUREG 0538 Category I splice material on supply for upgrade), i Millstone Unit No. 2 acted prudently by replacing the splice and bringing the unit on line.
3. Correctise Action Taken: The sound reason for not upgrading noted above is now documented in NNECO files. 4. Actions Taken to Prevent Further Violations: ! The following actions will help prevent further similar violations: o Plant procedures will be revised to more clearly state the need for w ritten "sound reasons" to be on file whenever DOR qualified equipment is replaced and not upgraded to NUREG- , ' 0333 Category 1 standards. . Appropriate personnel have been cautioned to assure that such o written justifications are on file when required, as need abo <e. C. Curtis t.. Terminal Blocks 4 1. Staf f Statement of the Proposed Violation: , "10CFR50.49(e)(1) requires that the electric equipment qualification
{ program must include and be based on the time dependent tempera- ! ture far the most severe Dasign Basis Accident during or fo!!owing ! which this equipment is required to remain functional. Contrary to the above, on July 17, 1987, the Curtis L type terminal i blocks used in valve 1-IC-l was not qualified based on the time dependent temperature for the most severe Design Basis Accident in ' that the Limitorque Test Repor t B0119 qualifie6 these terminal 2 blocks only to 3120F, but was used in an application where the Design Basis Accident temperature was 3300F following which the equip- ment was required to remain functional. This is Severity Level IV (Supplement 1) applicable to Unit 1." - { 4 i (1) By telephone conference between the Region I staff and NNECO, NNECO alerted the staf f to discrepancies in Section 5.1 of Inspection Report Nos. , 30-2'.5/37-17 and 50 3 % /37-15 relating to this violation. Based on inisunderstandings reflected in coinmunications with the Staf f, Section 5.1 does not accurately reflect the violation identified by the Staff. NNECO's . understanding of this violation is reflected in Section ll.B of this !ctter. < t - - - - - - - - -
.' . Mr. William V. Johnson
A06933/Page 5 December 13,1937 i 2. NNECO Statement of Position and Root Cause Analysis: /, NNECO failed to fully review the qualification file of the trictor operator to identify separately qualified sub cornponent parts. NNECO does not contest the violation. ' 3. Correcti<e Action i The terininal blocks for limitorque actuators inside the drywell at , \\lillstone Unit No. I were removed and the anotor leads for these
actuators have been spliced with NUHEC 0$SS Category I sphce material. , 1. . Correctiee Action to Prevent Further Violations: The following actions have been taken to minitnize the possibility of further similar violations: NNECO is perforrning a review of qualification files where the o separately qualified item is a sabcomponent of EQ equipment. ' This will provide further assurance that this violation is an isolated instance of the inodified environmental profile nr.,1 being fully applied to separately qualified subcornpartrnent parts, NNECO qualification engineers have been reminded of the o irnportance of considering the effects of the environmental j parameters on each susceptible part of a qualified dence. 1 111. OTiiEll EQUIP \\1ENT QUALIFICATION ISSUEF In adaition to the three See:rity 1.cect IV violations discussed above, the Staff j raised two "deficiencies" identified and corrected by NNECO in 1956, b, qualification of. ! deal wire nuts and spray pump anotor termir.ations. It should be j noted that the Staf f's description of the two issues contains some discrepancies (e.e., for Ideal wire nuts they were not used in limitorque actuators and were used in 125 VDC and not 4 SOY applications.) NNECO provides in the attachment ) ddditional infortnJtion supporting its ConCidsion that dJring the short period of I operation with these cornponents e.g., from November 19S5 to Jul> 19S6, the equipinent would likely have operated in the event of accident conditions.(2) (2) That this infortnation was not requested or supplied to the Staff during its unannounced audit s,hould not impact its consideration in our view. In this ; regard, NNECO was tut aware that the Staf f was seeking additional information regarding these two issue, until af ter issuance of the November 19, 1937 inspection report. NNECO's actions in response have k been tienely. (Footnote continue on page 6) s
. . Mr. William V. Johnson A06933/Page 6 December IS,19S7 _ IV. CONCL USION In conclusion, NNECO does not contest the three proposed Severity Level lY violatio,s identified in the Staf f's Novernber 19, letter. The corrective actions noted above will address the specific differences noted and will help prevent similar violations from occurring, in addition to these correcti/e measures, NNECO is reviewing the resources and structure of the organization tasked to address EQ issues to determine if impro/ements can be made to the EQ progra:n. If you have questions regarding the information contained in this letter, we would welcome the opportunity to discuss further these issues. Very truly yours, NORTHEAST NUCLEAR ENERGY CON 1PANY
s/ E. .),troc E P ~ Seni5r Vice President cc: W. T. Russell, Region 1 Ad ninistrator \\1. L. Boyle, NRC Project \\ tanager, \\lillstone Unit No. I D. H. Jaf fe, NRC Project Manager, \\lillstone Unit No. 2 W. J. Raymond, Senior Resident inspector, \\lillstone Unit Nos.1,2, and 3 . _ _ NNECO is aware of Sta f f policy that infor: nation suppor ting qualification / operation of a piece of equipment should be provided to the Staff during its audit or shortly thereaf ter. However, NNECO contends that this position applies solely to installed equipment. Application of this policy to equipment no longer installed in the plant is not supported by either Commission regulations or Staff guidance, would not improve public health and safety, and is impractical. For exarnple, this would require complete files on equipment reinoved froin the plant over its entire life to be readily available (not in historical storage) for a Staff EQ audit, or as in this case an unannounced inspection.
. . . , . . Docket No. 50-336 A06938 . Attachment , Millstone Unit No. 2 Additional Information - Wire Nuts / Motor Terminations December 19S7 _
. . . . The drawings detailing ther , design and materials specified for the SKV termination found on these motors have been evaluated. Two components manufactured by AMP Products Corporation, AMPLISEAL Tape and AMP Sealing & Dielectric Compound, were used. The materials used in the manufacture of these components were identified by AMP. Since the formulation of these products had been changed, each of the possible compounds was evaluated against the normal and accident plant parameters. Accident radiation is the limiting parameter, and in each case the radiation tolerance values exceeded the required plant qualification values. It is therefore concluded that these motor terminations were operable as required for both normal and accident environments. M4-3:87 Page 2 of 2 - - - - - , ,
. .- ATTACHMENT ADDITIONAL EQUIPMENT QUALIFICATION INFORMATION -NRC INSPECTION REPORT NO. 50-336/87-15' The following details are submitted as additional information relevant to findings 5.2 and 5.3: (A) Qualification of Wire Nuts Ideal Model 74B wire nuts were observed only in certain junction boxes associated with 16 Air Operated Valves. No wire nuts were observed in any Limitorque Motor Operator compartments. The materials of construction for the Model 74B wire nut were obtained from Ideal. For the environmental zones where these wire nuts were found, the limiting parameters for thermal life, radiation and accident conditions were evaluated. For all parameters except accident temperature, the material properties of the wire nut envelop the plant parameters. Further evaluation of the specific installation was performed, and it was determined that the heat transfer lags induced by the junction boxes were sufficient to preclude the short duration peak temperature spikes from raising the actual wire nut temperature to the material's limiting temperature. It was, therefore, concluded that these wire nuts were operable as required for both normal and accident environments. (B) Qualification of Motor Termination Subsequent to the 1986 outage walkdown and licensee letter dated December 10, 1986, additional specific data was located which identifies the motor termination method observed on Containment Spray Pump motors P.43A and P.43B. This documentation supports our previous statement regarding the engineering of and materials used in the splices. The Containment Spray Pumps are part of the Containment Spray System which is one of the MP2 Engineered Safety Features (ESF) for containment heat removal. The two pumps are located in two of the three ESF rooms in the Auxiliary Building. They are required to operate only for accidents inside containment, and radiation is the only harsh environment to which the pump motors and terminations are exposed during their accident mitigating function. Page 1 of 2 . . . ..
,. . - . . The drawings detailing the design and materials specified for the SKV termination found on these motors have been evaluated. Two components manufactured by AMP P.roducts Corporation, AMPLISEAL Tape and AMP Sealing & Dielectric Compound, were used. The materials used in the manufacture of these components were identified by AMP. Since the formulation of these products had been changed, each of the possible compounds was evaluated against the normal and accident plant parameters. Accident radiation is the limiting parameter, and in each case the radiation tolerance values exceeded the required plant qualification values. It is therefore concluded that these motor terminations were operable as required for both normal and accident environments. , 1 M4-3:87 Page 2 of 2 ___ _ _. ._ _ ____ _ _ _ _ _
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. . . _ . _ ' c, ak December 10,1986 Docket No. 50-336 b *' B12347 @ n.lI6 \\ / O ') 1. W/ - Office of Nuclear Reactor Regulation , , C' ' " , A ttn Mr. Ashok C. Thadani, Director W . ,. D 4. ~ PWR Project Directorate #8 3 _ f,. j L Division of PWR l.icensing - B U.S. Nuclear Regulatory Commission "YJ # p 4,,u,, ) Washington, D.C. 20535 ) Gentlemen: Millstone Nuclear Power Station, Unit No. 2 Environmental Qualification Review introduction Northeast Nuclear Energy Company (NNECO) has recently completed a compre- hensive review of equipment qualification (EQ) at Millstone Nuclear Power Station, Unit No. 2, taking advantage of increased equipment availabil!ty for inspection during the current refueling outage. While some discrepancies were identified during the re view, none were of safety significance warranting ) reporting pursuant to 10 CFR 50.72 or 50.73. NNECO believes that the results of the review reflect the overall success of implementation of previous EQ commitments for Millstone Unit No. 2. The purpose of this letter is to Inform the Staff of the results of the reverification program and to assure the Staff that j ' all discrepaneles noted (as described in Attachment 1) have been corrected to support power operation. Also, this letter provides additional Information in response to IE Information Notice 36-53 related to Raychem splices at Millstone Unit No. 2. Overview of the Reverification Program Specific elements of the reverification program include the followings Reverification of the EQ master list to assure completeness and accuracy. o Review of maintenance records to locate areas where additional informa- o tion was needed to fully integrate qualification requirements and main- tenance procedures, inspection of certain equipment in the Millstone Unit No. 2 EQ program to o reverify pertinent as-built conditions. . . .e () 4 N -
9 i -2- . o Evaluation of discrepaneles and identification of corrective actions. - Initiation of corrective actions with the goal of completion prior to start- o up from the current outage. Review of discrepancies identified for reportability pursuut to 10 CFR o 30.72 and 30.73. The program is, to a large extent, an independent review of the initial EQ program developed for Millstone Unit No. 2. The results of the program are discussed below. Results of the Reverification Program The reverification program constitutes a comprehensive review and analysis of the EQ status at Millstone Unit No. 2. In large measure, the results of the program reflect the success of the initial Millstone Unit No. 2 qualification e f forts. A detailed discussion of the discrepancies identified and corrective actions taken are set forth in Attachment 1. Each discrepancy noted was evaluated pursuant to 10 CFR 50.72 and 10 CFR
50.73. Based on these evaluations, no prompt notification or LER reportability requirements are applicable, since in each case it was determined that the specific equipment would have been able to perform its safety function. A revised EQ master list will be provided to the Staff during the first quarter of 1987. IE Information Notice 86-53 During the reverification program, NNECO decided to reevaluate the installation of heat shrinkable tubing (IE Information Notice 86-53) at Millstone Unit No. 2. This issue had been previously addressed during a routine safety inspectig conducted by Mr. A. Finkel of the NRC Region 1 Office on July 7-11,1986.W During the Staff inspection, the installation procedures, Quality Control (QC) records and three Plant Design Change Requests (PDCRs) were reviewed and determined to be in order. The inspector observed sample splices being terminated using the Raychem material. This inspection closed out this issue. However, as a result of increased NRC concerns and our involvement with the Nuclear Utility Group on Equipment Qualification (NUGEQ), NNECO decided to further review this issue. Installational procedures, PDCRs and work orders were reviewed and yielded results similar to those reported in the NRC inspection. A sample of Raychem termination inspections verified that the appropriate documentation was in order and that the terminations were properly installed. A detailed discussion of this review is set forth in Attachment 1. (I) S.D. Ebneter letter to J.F. Opeka, dated August 8, 1986, "!E Inspection Report No. 50-336/86-14 (July 7-11,1986)". .._ . __ . .- - . _ _ _ _ _ . . ,_-
_ _ _____ _ _ _ - 3 . Regulatory Guide 1.97 Items During the reverification program, previous decisions impacting the qualification program were reviewed and,in some cases, modified to take a more conservative posture regarding certain Regulatory Guide 1.97 equipment. As a result, we have identified the need to qualify certain equipment to conditions more severe than previously required. Since this particular Regulatory Guide 1.97 equipment is not governed by the schedule in 10 CFR 50.49 and only applies to the criteria
4 contained in Regulatory Guide 1.97, the resolution cf this issue will be addressed in a future submittal to the NRC on or about January 30,1987. Conclusion The purpose of this letter is to inform the Staff of the results of the NNECO EQ reverification program. Results of the program reflect the general success of the initial qualification efforts at Millstone Unit No. 2. For the discrepancies identified, corrective actions noted in Attachment I have been completed. No discrepancies have been determined to be reportable pursuant to 10 CFR 50.72 or 10 CFR 50.73. The extensive nature of the reverification program provides reasonable assurance that all equipment governed by 10 CFR 50.49 is on the master list and j qualified, as indicated in Attachment 1, to support power operation. As EQ - Issues evolve, the possibility exists that additional qualification activities will be required. If you have any questions, please contact us. Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY a) E.J. K cika g Senio ice President cc T.E. Murley ..t if . - . -- . . - - --- . _ _ _ _ - _ _ _ __
1 ' ATTACHMENT ! Results of Millstone Unit No. 2 Equipment Qualification Reverification & Supplemental Walkdown A comprehensive review of electrical equipment qualification required by 10 CFR j 30.49 was recently completed at Millstone Unit No. 2. Discrepancies identified and ) corresponding corrective actions taken. For all discrepancies, reportability evaluations have been done in accordance with 10CFR50.72 and 10CFR30.73. 1. Terminations 1. During the reverification program, reinspection of certain junction boxes and terminal boxes associated with equipment qualification (EQ) devices was performed. As a result of these inspections, qualification of two types of terminations was further evaluated. These were dispositioned as follows: a) Numerous taped terminations were found of the Bishop Tape type normally used in the past. (Bishop Tape terminations have been shown to be qualified to DOR guidelines at other NU nuclear power plants.) Rather than researching the work order records for the documentation to complete the walkdown file, it was decided to remove the tape to inspect the lug-conductor condition and retape using a NU_ REG-0518 qualified method These reworked s terminations are now s7pect scally documented in the EQ walkdown files. Since it was determined that these terminations would have performed their safety function, this discrepancy was determined to be not reportable. b) Several conductor terminations were found utilizing Ideal Model 74B wirenuts. Qualification of these devices was evaluated for the appropriate scenarios accident scenarios against the known physical properties of the wirenut. For the environmental zones in which i these wirenuts were located, the limiting material parameters would ( f not have been exceeded during either normal or accident conditions Q t and the end devices would have performed their safety functions. Although the existing termination method was determined to be adequate, these wirenuts were removed and the terminations were n i remade using NUREG-0338 qualified methods. This discrepancy was J I determined to be not reportable. P 2. An inspection of the termination of all EQ Master List motors was conducted. The qualification of three sets of motor terminations was evaluated as a result of these findings. These were dispositioned as ' follows: ' a) The Containment Spray Pump motors P43A and P43B were found to have original plant installation terminations for which no specific design documentation was found. Original installation procedures required an engineered termination method for motors of this nature, and the EQ walkdown Inspections indicated that the subject l ' 4 - - - - - - - - _ - - , . ~ , - - - - - r,-.m- , - - - - -m,,p +my ,* . , w
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r , - - - - h b' ' . in p r / -2- - . sI terminations were well engineered, were in excellent condition, and 7 utilized typical tape system materials of that time. A review of the appropriate accident scenarlos concluded that the motor terminations as found would not have failed and would not have prevented the pumps from performing their safety function. Since the qualificaticn of these terminations could not be fully demonstrated, the motors were reterminated using a NUREG4388 qualified method. This discrepancy was determined to be not reportable, b) The 1. PSI Pump motors P-42A&B and the Charging Pump motors P- 18A, B&C were found to have terminations that had been replaced subsequent to original plant Installation. As found, these terminations were a Bishop Tape type normally used in the past. Since the terminations were scheduled to be disassembled for normal plant maintenance purposes, the motors were scheduled for retermination using a NUREG4388 quallfled method. As of this date, only P-18A has not been completed, and this pump will not be declared operable until quallfled terminations are installed. These new terminations are now fully documented in the EQ walkdown files. Since it was determined that these terminations would have performed their safety functions, these discrepancies were determined to be not reportable. 3. To address the concerns identified in IE Informatien Notice 86-33, an inspection of a sample of Installed Raychem terminations was con- ducted as discussed belows a) Containment Electrical Penetrations - 15 percent of these were , inspected in accordance with the Raychem inspection celteria and the inspections were documented en QA Work Orders. Allinspected terminations were found to be acceptable and quallfled for 40 years per Raychem test reports. b) Rosemount Transmitters (ECSA buttsp!!ce) - 100 percent of these were inspected in accordance with the Raychem inspection criteria and the inspections were documented on QA Work Orders. NNECO decided to inspect 100 percent of these particular splices because their installation procedures specified an overlap of one and one half (IM) Inches rather than the two (2) inches recommended by ! Raychem. The inspections verified that the overlap length was consistent with the existing documentation. All inspected buttsp!!ces were found to be acceptable and quallfled for 10 years per Toledo Edison and TVA qualification testing of Raychem splices. As a matter of plant convenience, these splices were reterminated to achieve 40-year quallfled lives per Raychem test reports. Evaluation of these findings determined them not to be reportable. !!. Limitorque Motor Operators in response to IE Information Notice 86-02 and 86-03, special attention was directed to Limitorque operators during the walkdown. Five issues related to .- --. . - - - . _ ,-. . - _ . -_ . - _ - . . _ - - - . _ . _ _ _ - - - . .
. . - -3- these operators evolved during the walkdown. These are addressed as , follows: 1. The walkdowns determined that T-drains had not been installed on 2-RC-405, 2-51414, 2-51424, 2-S1434, 2-S!444, 2-51451, and 2-51- 652. A review of the accident scenarios concluded that the lack of T- drains would not have prevented these valves from performing their safety function. Although the existing Installation was determined to be adequate, T-drains were Installed in these operators. This discrepancy was determined to be not reportabh. 2. Eleven other Limitorque operators were found to have lug and tape type terminations for the motor lead wire termination. Since this was not a Limitorque tested configuration, these valves were evaluated for operability. The terminations were of the plant standard Bishop Tape method, and a review of the accident scenarios concluded that this configuration would not have prevented the valves from performing their safety function. In each case, the existing tape was removed to inspect the lug / conductor condition and the termination was remade using a NUREG-0588 qualified method. This discrepancy was deter- mined to be not reportable. 3. Four operators were found to contain sildewire resistors., Since this was not a Limitorque tested configuration, these valves were evaluated for operability. A revle e of the accident scenarios concluded that the installed sildewire res,stors do not affect the MOV's ability to perform their safety function. Therefore, the only corrective action was to update the documentation to include this information. This condition was determined to be not reportable. 4. During the May,1986 turbine inspection, NNECO in:pected five (5) randomly chosen Limitorque actuators out of a total of forty-two (42) so as to perform a visual Inspection of the Internal wiring. The results of thip,) inspection were reported to the Staff via an August 5,1986 letteru . As stated in that letter, it was NNECO's intention to inspect ' the remaining thirty-seven (37) Limitorque actuators during the refuel- j ing outage scheduled to begin in September,1986. These actuators ' were in fact all inspected and were verified to be environmentally quallfled. Therefore, all wiring Internal to each EQ Master List Limitorque operator has been visually confirmed as quallfled. This action resolves the concern identified in IE Information Notice 86-03. 5. To address the concerns identified in IE Information Notice 86-02, motor serial numbers which were verified during the walkdown will be submitted to Reliance Electric Company. This will determine which (1) 3.F. Opeka letter to T.E. Murley, dated August 3,1986, "Millstone Nuclear Power Station, Unit Nos. I and 2 - Inspection Report Nos. 50- 245/85-30; 50-336/85-35." . - .. ...-- -. . . .- -. - .- - . -- -- - . - - - . -
. 4 ' - motors, if any, contain magnesium rotors. While the currently installed motor operators are not located in areas which will experience the environments noted in the General Electric tests cited in IE Information Notice 86-02 and ar- still quallfled by test reports, we will ensure that information from Reliance is added to our EQ files. This status report is being provided for informational purposes only. Ill. Solenoid Operated Valves and Limit Switches Three SOV's and the asseclated limit switches in the Control Room HVAC System were identified as requiring qualification and not listed in the EQ Master List. These devices had been installed as qualified and have been maintained as quallfled. They have been added to the EQ Master List. This discrepancy was determined to be not reportable. IV. Providing Additional Conservatism to Previous Decisions in the reverification process, previous decisions regarding qualification activities were evaluated. In the cases noted below, while the end conclu- sions (i.e., that the environment would not adversely affect the operability of , the equipment) were not altered, additional qualification efforts were implemented to provide added assurance. 1. Investigation into the Auxiliary Feed Pumps, the DC Switchgear Room Fans and the Enclosure Building Filtration System Fans determined that the motors for these devices should be qualified as a conservative 1 measure for certain HELBs in their respective locations. The qualifica- tion of each of these motors has been established as follows: a) The qualification of the Auxillary Feed Pump motors has been confirmed through the vendor. The motor terminations were found to have been replaced subsequent to original plant installation. The terminations were a Bish@ Tg r My wmally used in the past. ' Rather than researching the work order records for &e documanmisAcom ikdown f was decided to and These reworked terminations at w fully documen alkdown files, and the motors have been added to the EQ Master List. Since it was determined that these terminations would have performed their safety function, these discrepancies were determined to be not reportable, b) The DC Switchgear Room Fan motors have been confirmed as qualifiable by the vendor and appropriate documentation is being procured. Qualification of these motors will replace previously credited manual actions. The motor terminations were found to have been replaced subsequent to original plant installation. The terminations were a Bishop Tape type normally used by the plant in the past. Rather than researching the work order records for the documentation to complete the walkdown ille, it was decided to ! < . . . . - - - - - _ . - -, _ _ - . ~ - - . _ , - , . _ . - - - , -
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5- \\ . . remove the tape to inspect the lug / conductor condition and reterml- nate using a NUREG-0588 quallfled method. These reworked terminations are now fully documented in the EQ walkdown files, and the motors have been added to the EQ Master List. Since it was determined that these terminations would have performed their , safety functions, these discrepancies were determined to be not reportable. c) The qualification of the Enclosure Building Filtration System Fan motors has been confirmed through the vendor. The motor termina- tions in each case were Inspected and determined to be original - plant installation, and quallfled to DOR Guidelines. The motors have been added to the EQ Master List. These discrepancies were determined to be not reportable. 2. A review of Solenoid Operated Valves resulted in a decision to qualify eleven devices that had previously been evaluated as not requiring qualification. These original evaluations had been made based on their immediate function at the onset of a design basis accident, prior to ) being exposed to any harsh environment. A decision was made to fully qualify these SOVs for post-accident environments to provide additional i , assurance of safety function. This has been accomp!!shed as fo!!ows: a) Three of these SOVs were quallfled types as Installed and have been maintained as qualified. These have been added to the EQ Master List. These discrepancies were determined to be not reportable. b) Seven of the SOVs were not quallfled types as Installed and were evaluated against the appropriate accident scenarios for long term operability. For the environmental zones in which these SOVs were located, the limiting material parameters would not have been exceeded during either normal or accident conditions and they would have performed their safety functions. Although the existing installations were determined to be adequate, each SOY was replaced with a NUREG-0588 fully quallfled component and added to the EQ Master List. These discrepancies were determined to be l not reportable. j c) The remaining SOY was not a quallfled type as installed and was evaluated against the appropriate accident scenario for long-term i operability. For the environmental zone in which this SOV was located, the limiting material parameters would not have been exceeded during either normal or accident conditions and it would have performed its safety function. Although the existing installa- tion was determined to be adequate, this SOY was replaced with a NUREG 0588 qualified component and added to the EQ Master List. During pre-startup testing, it was discovered that the replacement SOY as installed caused the closure time for the main valve to exceed the Technical Specification requirement. The original. SOY j had to be reinstalled to correct the closure time problem. Since this valve had been aded to the EQ Master List, it will be declared i _ __
- _ _ _ -. . . . , .' ' ' 6 ' operable with a Justification for continued operation (JCO)In place until a suitable fully qualified replacement is available. This replacement SOY will be Installed during operation following start- up. This discrepancy was deterrnined to be not reportable. ' / . 1 . .o . --a }}