ML20153E482
| ML20153E482 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/26/1988 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20153E471 | List: |
| References | |
| 50-413-88-07, 50-413-88-7, 50-414-88-07, 50-414-88-7, IEIN-79-03, IEIN-79-3, IEIN-81-29, IEIN-82-52, IEIN-83-72, IEIN-86-003, IEIN-86-071, IEIN-86-3, IEIN-86-71, NUDOCS 8805100023 | |
| Download: ML20153E482 (33) | |
See also: IR 05000413/1988007
Text
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UNITED STATES
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NUCLE AR REGULATORY COMMISSION
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Report Nos.:
50-413/88-07 and 50-414/88-07
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.:
50-413 and 50-414
License Nos.:
Facility Name:
Catawba 1 and 2
Inspection Conducted:
F bruary 1-5, 1983
,
Inspector:
j[ht/
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ate $ ned
2h
N. Merriweather,
eam Leader
Team Members:
S. A. Alexander, Equipment Qualification and Test Engineer, NRR
E. Claiborne, Consultant Engineer, Sandia National Laboratories
Q. Decker, Consultant Engineer, Idaho National Engineering
Laboratory
C. Kido, Consultant Engineer, Idaho National Engineering
Laboratory
W. Levis, Reactor Inspector, RII
C. Paulk, Reactor Inspector, RII
C. Smith, Reactor ospector ,RII
._ f@f
g/
/QF
A p pro v e M'_.
. Conlon, Lhief.
Cate Signed
T.
Plant Systems Section
Division of Reactor Safety
SUMMARY
Scope:
This special, announced inspection was in the area of Environmental
Qualification (EQ) of Electrical Ecuipment and included a review of Duke Power
Company's (DPC) implementation of the requirements of 10 CFR 50.49; plant
walkdown inspections of electrical equipment within the scope of 10 CFR 50.49;
a review of the circumstances and corrective actions relating to previously
identified EQ deficiencies and a review of their evaluations of inspection
findings on how they ef fect restart of Unit 2 and continued operation of
Unit 1.
Results:
Seven violations were identified and are discussed in Paragraphs 2,
3, and 6.
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8805100023 G80504
ADOCK 05000413
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- D. Collings, Senior Engineer, Design Engineering Department
- M. Cote', Production Spee!alist II, Nuclear Production Department
- J. Cox, Catawba Training Manager, Production Training Services
- J. Crenshaw, Senior Engineer, Design Engineering Department
- C. Origgers, Supervisor, Design Engineering Department
- G. Gardner, Supervisor, Design Engineering Department
- G. Grier, Corporate Quality Assurance Manager
- S. Grier, Nuclear Production Engineer, Nuclear Production Dep!-tment
- J. Hampton, Manager of Catawba Nuclear Station
- C. Hartzell, Catawba Compliance Engineer, Nuclear Production Department
)
- E. Mite, Maintenance Engineer
- R. Kovacs, Design Engineer - Instrumentation, Design Engineering Department
- C, Little, System Technical Manager - Instrumentation and Electrical
- T. McHeckin, Chief Engineer, Design Engineering Department
- D. Owen, Principal Engineer, Design Engineering Department
- R. Prior, Vice President Design Engineering
- G. Smith, Superintendent of Maintenance, Catawba Nuclear Station
- R. Sokal, Technical Assistant, Design Engineering Department
- J. Stackley, Instrumentation and Electrical Engineer, Catawba Nuclear
Station
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- J. Thomas, Senior Engineer - Electrical, Design Engineering Departirent
- P. Voglewede, Supervisor, Design Engineering Department
- R. Weidler, Senior Engineer - Mechanical, Design Engineering Department
Other Organizations
- H. Vaught, Maintenance Engineer, Georgia Power Company
NRC
- K. Jabbour, Licensing Project Manager - Catawba, NHC, NRR
- T. Peebles, Section Chief, NRC, RII
- P. K. Van Doorn, Senior Resident Inspector, NRC, RII
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were sumarized e February 5,1988,
with those persons indicated in paragraph 1.
The inspector described the
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areas inspected and discussed in detail the inspection findings listed
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beluw.
No dissenting coments were received from the licensee.
Subse-
quant to the inspection, two previously identified unresolved items
have been detemined to be violations of 10 CFR 50.49 ('J,em Nos. 50-413,
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414/88-07-05) for failure to establish qualification of the MINC0 Typa
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RTDs for submergence and (Item Nos. 50-413,414/88-07-07) for T-drains
painted over or lack of T-drains on some inside containment Limitorque
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operators.
In addition, one unresolved item concerning lack of traceabil-
ity for tested versus installed Rosemount transmitters is now considered
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closed.
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The following is a list of new items identified during this inspection.
Item Number
Description / Reference Paragraph
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50-413/88-07-01
Violation, Licensee's EQ files did not
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support qualification of the four-to-one
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electrical tape splice used on the hydrogen
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recombiners in the Unit 1 containment.
The
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installed configuration was not similar to
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the tested configuration in that the files
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demonstrated qualification for an in line
one-to-one tape splice versus a four-to-
one V-configuration tape splice, Paragraph
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6.1.(19).
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504413, 414/88-07-02
Violation. The RCS wide range (hot and cold
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leg) resistance temperature detectors (RTDs)
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(modelRdF)werenotinstalledinaccordance
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with the tested configuration.
The bellows
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or hydrostatic hose assembly which encap.
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sulated the RTD pigtail lead wires from
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moisture egress was removed during installa-
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tion.
Furthermore, the junction box where
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the RTD pigtail wires teminated was not
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qualified for submergence, Paragraph 6.1.(2),
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50-413/88-07-03
Violation, The licensee had unqualified
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limitorque motor operated valves installed
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on both units in the Containment Air Return
and Hydrogen Skimer System (valve Nos.
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IVX1A, IVX28, 2VX1A, and 2VX28).
The
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licensee had previously claimed that these
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valves were qualified for outside contain-
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ment.
However, the licensee could not
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support qualification for the use of these
limitorque operators for either inside or
outside containment because the operators
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were procured as non-safety, Paragraph 3.
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50-414/88-07-04
Violation, The Joy Reliance fan motors used
inside containment on the Hydrogen Skimer
This appar goajhgr-drains
have the .
fans did not
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.e M in
installed.
accordance with the tested configuration
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and the licensee did not have an adequate
evaluation in the file, Paragraph 6.1 (1).
50 413, 414/88-07-05
Violation. Licensee's EQ files did not
support qualification for the Hinco type
RTDs in that the RTDs and associated
junction boxes were located below the flood
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level inside containment.
The file did not
address submergence at the time of the
inspection, Paragraph 6.f.(3).
50-414/88-07-06
Violation
The cover gasket on a Namco
limit switch (tag no. 2NCLLO251) was missing
at one end.
This configuration is not
consideredqualified, Paragraph 6.i.(18).
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50-413, 414/88-07-07
Violation, Linitorque valves on Unit 2 were
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observed to have their T-drains painted
over.
Two out of the three limitorques
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inspected exhibited some kind of obstruction.
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A walkdown by the licensee identified further
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examples of T-drains obstructed or their
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ability to properly drain was uncertain,
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addition, some limitorque operators located
inside containment on Units 1 and 2 were
discovered without any T-drains installed,
Paragraph 6.i.(15),
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50-414/88-07-08
Unresolved Item. T-drains on limitorque
valve No. 2N!-1228 were not installed at the
low point.
This configuration does not
appear to be qualified, Paragraph 6.1.(15),
3.
Licensee Action on Previous Enforcement Matters
(Closed) Violation 50-413/86-05-05, Use of Unqualified Limitorque Motor
d
Operated Yalves Inside Unit 1 Containment
The inspectors followed up on a previously identified Violation
413/86-05-05 which identified the lack of proper documentation for the
environmental qualification of IVX1A and IVX28, hydrogen skimmer fan
isolation valves.
The initial concern was that these motors operated
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valves were intended for outside containment applications but were
actually used inside containment. Duke Power Company Report No. SES-JR-45
dated June 15, 1984, discussed the variations between these outside
containment motor operated valves and those intended for inside
containment applications.
The report concluded that the Class B motor
insulation system was acceptable for inside containment use at Catawba
based on previous testing conducted by limitorque on MOV's with Class B
motors since the environmental parameters experienced by the Catawba
actuators was less severe than that in the limitorque outside containment
test. The following weaknesses were noted this methodology:
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Evaluation considered only the motor and did not include other
electrical components such as torque switch, limit switch and
termination means
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Ef9ets of chemical spray not evaluated. Limitorque tests have shown
that some outside containment materials are not acceptable in
chemical spray environments
In addition, when the licensee was asked to verify that the MOV was indeed
qualified for outside containment harsh environments he discovered the
MOV's were procured comercial grade and that no documentation existed to
justify their ust. in outside containment EQ applications.
These MOV's
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were replaced in February 1986.
As stated in previous Inspection Report
No. 50-413/86-05 the use of these unqualified motor opereted valves
constitutes a violation of 10 CFR 50.49.
However Violation 413/86-05-05
will be closed out and a new number will be assigned to this violation,
413/88-07-03, Use of Unqualified Limitorque Motor Opersted Valves Inside
Unit 1 Containment.
This problem also existed on Unit 2 Valve Nos. 2VXIA
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and 2VX28.
4.
Unresolved Items
Unresolved items are ratters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations.
One unresolved item identified during this inspection is
discussed in paragraph 6.1.(15).
5.
Background
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NUREG-0588 was issued in December 1979 to promote a more orderly and
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systematic implementation of equipment qualification programs by industry
and to provide guidance to the NRC staff for its use in ongoing licensing
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reviews.
The positions contained in that report provide
(1) how to establish environmental service conditions, (2) guidance on
how to select
methods that are considered appropriate for qualifying equipment in
different areas of the plant, and (3) other areas such as margin, aging,
and documentation.
In February 1980, the NRC asked certain near-tem OL
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applicants to review and evaluate the environmental qualification
documentation for each item of safety-related electrical equipment and to
identify the degree to which their qualification programs were in
compliance with the staff positions discussed in -NUREG-0588.
The
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applicable requirements fo' Catawba Units 1 and 2 are - NUREG 0588,
Category II.
A final rule on environmental qualification of electrical equipment
important to safety for nuclear power plants became effective on
February 22, 1983. This rule, 10 CFR 50.49, specifies the requirements to
be met for demonstrating the environmental qualification of electrical
equipment important to safety that is located in a potentially harsh
environment.
This rule also states that equ;pment which was previously
qualified in accordance with NUREG 0588, Category II need not be
requalified to 10 CFR 50.49.
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To document the degree to which the environmental qualification program at
Catawba complies with the NRC environmental qualification requirements and
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criteria, the licensee provided equipment qualification information by
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letters dated June 17, 1982, and February 7, February 8 April 25 May 14,
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and June 6,1984, to supplement the infonnation in FSAR Section 3.11.
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The three categories of electrical equipment that must be qualified in
accordance with the provisions of 10 CFR 50.49 are:
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a.
safety-related electrical (equipment relied to remain functional
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during and following design-basis events),
b.
non-safety-related electrical equipment whose feilure under the
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postulated environmental conditions could prever.t satisfactory
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accomplishment of the safety functions by the safety-related
equipment, and
c.
certain post accident monitoring equipment (RG 1.97, Categories 1
and 2 post-accident monitoring equipment).
The staff reviewed the adequacy of the Catawba environmental qualification
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program for electrical equipment important to safety as defined above.
The results of the staff's evaluations were documented in Safety
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Evaluation Report, NUREG-0954. Supplements 3, 4, 5 and 6 in Section 3.11.
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The status of the licensee's compliance to Regulatory Guide 1.97 for
post-accident monitoring equipment is addressed in Supplements 4 and 5 of
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the Safety Evaluation Report for Units 1 and 2.
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This inspection reviewed the licensee's implementation of a program to
meet the requirements of 10 CFR 50.49 and corrective actions on previously
identified EQ issues.
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6.
Findings
The NRC inspectors examined the licensee's program for establishing the
environmental qualification of electric equipment within the scope of
The program was evaluated by physical inspection of EQ
equipment, examination of the EQ files, interviews of personnel involved
in EQ activities, review of procedures for controlling the EQ Master List,
and examination of the licensee's maintenance program for maintaining the
qualified status of the covered electrical equipment.
Although some significant EQ deficiencies were identified and are being
considered for enforcement,
the inspection team determined that Duke has
implemented a program to meet the requirements of 10 CFR 50.49 for the
Catawba Nuclear Station.
The root cause of the deficiencies identified
may be related to the lack of adequate EQ training for Catawba plant
personnel. The area of EQ training is discussed further in paragraph 6.h.
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A more detail review of maintenance; IE Notices and Bulletins; EQ
procurement; EQ master list; EQ files and walkdown results are discussed
in the paragraph's that follows:
a.
EQ maintenance Program
The EQ maintenance program review was conducted by reviewing
maintenance procedures, EQ maintenance requirements, equipment
histories, and preventative maintenance schedules. The sampling also
included work requests and replacement of equipment at the end of
qualified life.
During the plant walkdown portion of the inspection, several EQ
discrepancies were identified that could be attributed to inadequate
maintenance practices.
One maintenance related item was found on a
NAMC0 limit switch and is discussed in paragraph 6.i.(18).
Another
maintenance related item involved Limitorque actuators with T drains
plugged with paint.
This is discussed further in paragraph 6.i.(15).
The cause for these and other maintenance EQ deficiencies appear to
be the result of inadequate or lack of training provided to site
personnel.
With the exception of the above discrepancies, the licensee has
implemented an acceptable EQ maintenance program and, by strict
procedure compliance, is maintaining equipment in a qualified state.
b.
Inspection and Enforcement Notices (IENs) and Bulletins (IEBs)
IE Notices are handled by the Nuclear Production Department in
accordance with D,rective No. 4.8.1(s), Revision 0,
"Operating
Experience Program Description."
The General Office Licensing
section is responsible for any other NRC generated documents (i.e.,
Bulletins, Generic Letters, and etc.).
Prior to 1987, the licensing
section handled all NRC documents.
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A walkthrough of the directive provided assurance that notices
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affecting EQ would be addressed properly.
It also included
discussions of how the various organizations and sections would
interface to resolve any EQ issue.
Based on the review and walkthrough of the directive, it is concluded
that the licensee has a program for distributing, reviewing, and
evaluating IENs and IEBs relative to equipment within the scope of
Specific IENs examined were:
IEN 86-03, 86-53, and 84-90.
c.
Environmental Qualification Master Equipment List
The methodology used by the licensee to determine which equipment
items require qualification is detailed in Section II.4.5, Paragraph
4.1 of Design Engineering Department Manual, latest revision dated
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January 31, 1986.
This procedure requires that safety-related
equipment located in a harsh environment, as defined in the Environ-
mental Qualification Criteria Manual, and required to mitigate the
consequences of the accident causing the harsh environment be
environmentally qualified.
In addition, any safety-related or
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non-safety-related electrical equipment whose failure under the harsh
environmental parameters experienced during design basis accidents,
would degrade safety systems or mislead the operators are also
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required to be environmentally qualified.
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equipment located in a harsh environment is also covered as shown in
Duke Power Company's response to Regulatory Guide 1.97.
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The list of environmentally qualified equipment is contained in
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Duke Power Company, Catawba Nuclear Station response to NUREG 0588,
document CNLT-1780-03.02.
This document identifies the safety-
related electrical equipment located in a harsh environment by
generic type, manufacturer, and model number along with its worst
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case qualification requirements.
Equipment specific tag numbers are
listed in Tabs A through C of the Equipment Qualification Reference
Index,documentCNLT1780.03-1(Rev 6).
Both documents are controlled and updated in accordance with the
normal design control process.
To assess the completeness of the list, the Safety Injection System
was selected for review.
The following flow diagrams and the FSAR
were reviewed to determine the system comp (onents such as Motor
Operated Valves (MOVs), Solenoid Valves
S0Vs), motors and
instrumentation that are required to bring the plant to a safe
shutdown condition:
CN-1562-1.1 Rev. 5
CN-1562-1.2 Rev. 5
CN-1562-1.3 Rev. 4
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All items noted as requiring qualification were included on the
licensee's equipment list.
The only deficiency identified with the
EQ master list related to a failure to identify some EQ equipment
that becomes submerged during design besis accidents.
This item is
discussed further in paragraphs 6.i.(2) and 6.i.(3).
d.
Cable Identification
During the plant walkdown the inspectors identified cable ID numbers
from cable connected to EQ devices to the licensee so that
traceability could be established to the cables identified on the EQ
list.
In all cases the licensee was able to identify the cable by
manufacturer, cable type, manufacturer order number and cable reel
number and could show the applicable test report for that cable type
was included in their qualification files.
No further questions were
asked in this area.
e.
EQ Equipment Replacement and Spare Parts Procurement
The Environmental Qualification Reference Index (EQRI) procurement
section specifies the administrative controls applicable to the
procurement of equipment within the scope of 10 CFR 50.49.
It
provides for the procurement of new equipment, direct replacement
parts and components, and upgraded procurement in accordance with
the requirements of 10 CFR 50.49(1).
In addition, it provides
administrative controls applicable to the procurement of comercial
grade items and establishes limitations on their use.
Station Directive 2.4.1,
"Purchasing of Materials, Labor, and
Services" describes the procurement process and establishes require-
ments for performance of EQ Reviews of QA Condition 1 procurement
documents.
EQ equipment is procured as QA Condition 1 to ensure
that quality requirements such as applicable tests and vendor-
supplied quality records are specified on the purchase requisition.
The QA organization reviews all QA Condition 1 procurement documents
to verify inclusion of quality requirements on the procurement
documents.
Additionally, the requirements of 10 CFR 21 are imposed
on these procurement activities.
Technical requirements for new procurements are defined during
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the design-engineering process.
Information such as applicable
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specifications, drawings, codes and standards and EQ requirements
are documented on the purchase requisition.
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Upgraded procurement in accordance with the requirements of
10 CFR 50.49(1) are perfomed within the controls of the design-
engineering program.
Design Engineering Department Manual, Section
11.4.9, "Equipment Replacement Summary Form", provides specific
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guidance for documenting the process by which a detennination is
reached to upgrade EQ equipment.
Additional guidance is provided in
the EQRI, "Guidelines for Completing Spares Evaluation and Equipment
Replacement Summary", for performing an annual evaluation to assess
the need for upgrading spares and replacement parts.
Reasons to the
contrary are required to be documented on the form for procurement
activities not in compliance with 10 CFR 50.49(1).
The procurement of commercial grade items for use in EQ applications
is controlled by the nuclear station modification program.
Specific
guidance on the procurement of comercial grade items for use in QA
Condition 1 applications is provided in Design Engineering Department
Manual,Section II.4.1, "Nuclear Station Commercial Grade Evalua-
tion."
A Commercial Grade Items List consisting of a computer data
base with three categories of commercial grade items have been
established by licensee management.
Responsibilities have been
assigned to the Design Engineering organization for performing
commercial grade item evaluations.
Additional requirements for
conditioning (i.e., dedication) prior to use and restriction in use
of the various categories have been established.
The inspector reviewed purchase requisitions and/or purchase orders
for various equipment types within the scope of 10 CFR 50.49.
No EQ
related deficiencies were identified.
f.
QA/QC Interface
Pursuant to discussions with on-site QA organization personnel, the
inspector determined that surveillances had been performed on plant
detivities with a potential for degradation of the environmental
qualification of plant equipment.
Typical of these surveillance is
surveillance No. CN-87-16, Electrical Enclosures - Environmental
Qualification.
This surveillance was conducted from March 23 to
April 3,
1987, and involved an assessment of the problem of
improperly secured NEMA 4 electrical enclosures documented on Problem
Investigation Report (PIR) No. PIR-1-C86-0061.
Other PIR's and
surveillance reports prepared by site QA personnel and/or Nuclear
Production Department (NPD) personnel were reviewed to assess the
adequacy of-the corrective actions developed for EQ related problems.
No deficiencies were identified during this review.
The Corporate QA organization performs audits of the Operational QA
program in accordance with the requirements of the Technical
Specifications.
Interviews with staff members revealed that the
following audit of the environmental qualification program were
performed from July 22 - September 20, 1985, Audit No. SP-85-2 (GO),
Environmental Qualification of Electrical Equipment.
The scope of
the audit included EQ records, station maintenance, personnel
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qualification and training, procurement activities, station modiff-
cation, document control and records management, and QA and QC
inspections.
Deficiencies identified and documented in the audit
report for Catawba were discussed. with . licensee management.
The
inspector performed a review of selected developed corrective action
plans for the identified deficiencies.
No EQ related problems were
identified during this review.
The inspector detennined from additional discussions with licensee
management that the audit schedule does not specifically provide for
audit of the EQ program.
Instead, EQ related activities and/or EQ
program requirements are included within the scope of the audit if
they fall within the performance area being audited.
The following
audits were reviewed by the inspector pursuant to this discussion;
Departmental Audit SP-86-1 (MM), Material Control, and Departmental
Audit ' DE-87-03 (ALL), Design Engineering.
No violations or
deviations were identified in this area.
g.
EQ Modification Program
Station Directive 3.3.12, "Equipment Qualification Program," speci-
fies the program established to ensure equipment within the scope of
10 CFR 50.49 is qualified, and assigns responsibilities to the Design
Engineering organization for maintaining the EQRI (CNLT-1780-03.01
andCNLT-2780-03.01) through the station problem report (SPR) program.
Station problem reports may be dispositioned within the controls
of the nuclear station modification program.
The Nuclear Station
Modification Manual, revision 5, is the controlling procedure for
the preparation and implementation of Design Change Packages (DCPs)
prepared by either the site engineering organization or the corporate
engineering office.
This manual specifies the design controls that
ensure applicable regulatory requirements and design bases are
correctly translated into specifications, drawings, procedures, and
instructions to form a DCP.
Considerations of the environmental
qualification requirements of equipment to be installed via a design
change is included as a design input to the design process.
The Design Engineering Department Manual. Section
11.4.5,
"Environmental Qualification of Electrical Equipment", and Catawba's
Environmental Qualification Criteria Manual provide specific guidance
to the responsible engineer regarding environmental qualification
considerations such as equipment location and environmental
parameters.
The design process further provides for the update of
vendor technical manuals and shop drawings upon implementation of a
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DCP.
The Environmental Qualification Reference Index (EQRI) which
specifies maintenance requirements, replacement schedules, and other
controls necessary to ensure continued EQ status is also updated to
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reflect equipment changes caused by plant modifications.
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The inspector reviewed two design changes (Variation Notices Serial
No. CE-1564, and CE-1237) prepared by the site engineering
organization that involved EQ equipment. No EQ related deficiencies
were identified during this review,
h.
EQ Personnel Training
The Employee Training, Qualification, .and Safety, (ETQS) program
provides for training of craft personnel in specific task.
The
employee is trained to a procedure which is written .to be task
specific.
Discussions with the Training Manager and other licensee
personnel revealed that training in the requirements of Catawba EQ
Program had not been provided to Nuclear Maintenance I&E, or site
QA/QC staff members.
The NRC EQ inspection at McGuire in July 1986
identified similar training deficiencies.
Licensee management, as
part of their corrective action, reviewed this inspection finding for
generic application to other operating facilities.
They determined
that similar EQ training deficiencies existed at Catawba.
Review of an I&E working group meeting minutes dated November 4,
1987, showed that the EQ lesson plan developed for McGuire had been
transmitted to Catawba for review by site personnel who would
detennine its applicability at their location.
Additionally, from
discussions with site personnel it was determined that the Catawba EQ
1esson plan is scheduled to be completed by March 15, 1988.
The issue of providing EQ training to Nuclear Maintenance I&E and
site QA/QC personnel was addressed at the exit interview and the need
for timely corrective action was emphasized.
The Corporate QA organization performed an audit of the EQ program
for electrical equipment during July 22, 1985 to September 20, 1985.
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The results of this audit are documented in Departmental Audit
No. SP-85-2(G0) dated September 24, 1985. Audit finding SP-85-2(G0)(3)
identified a deficiency in training of design engineering personnel.
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In response, the Design Engineering Organization committed to develop
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and implement a formal training class on the requirements of the EQ
program. The inspector reviewed various correspondence on this subject
and conducted interviews with engineering personnel.
It was determined
that engineering personnel had participated in Electrical Power
Research Institute (EPRI) training sessions on environmental qualification
'
of equipment. However, objective evidence was not presented to document
implementation of the EQ training to which.the Design Engineering
organization had comnitted. A memo-to-file dated April 8,1987, from
R. J. Smith, Design Engineer, documents plans to establish an annual
training program beginning in 1988.
Discussions with the Corporate QA organization personnel revealed
that training in the requirements of the EQ program for McGuire,
Oconee, and Catawba had been given by an outside consultant.
This
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training session titled, "Training Seminar on Equipment Qualification
and Replacement Parts and Equipment," was given on December 7 and 8,
1987.
Review of objective evidence further showed that select staff
members from the Catawba site had also been trained in' the
requirements of the EQ program on August 26, 1986.
In summary, the licensee was aware of the weaknesses in the EQ
training program for selective personnel and is now vigorously taking
steps to improve their overall EQ Training Program to be more in-line
with industry standards and NRC requirements,
i.
EQ Documentation Files and Walkdown Items
The required qualification level for Catawba Units 1 and 2 original
10 CFR 50.49 scope equipment is NUREG 0588, Category II, "Interim
Staff Position on Environmental Qualification of Safety-Related
Electrical Equipment."
The replacement equipment is required to
meet the requirements of 10 CFR 50.49 or reasons to the contrary
must be documented.
The EQ documentation is composed of Master
Equipment List (0588 Submittal), Environmental Profiles and the
Central file.
The Central File contains EQ Test Reports; Report
Evaluation Checklists and Summaries; System Component Evaluation
Worksheets (SCEW); EQ Component Lists with Maintenance and Procure-
ment Requirements (EQRI); and other supporting documentation.
The licensee's generic EQ files were reviewed in detail against
the requirements of the rule to determine if qualification had
adequately been established and to determine if records were main-
tained in an auditable fashion.
Some of the EQ files were found
to be deficient requiring additional analysis to establish qualifi-
cation. These deficiencies are identified as Violations 413/88-07-01
)
and 413, 414/88-07-05 and are discussed in Paragraphs 6.i.(19) and
j
6.i.(3), respectively.
The inspection team considered item 01 to
'
be fully qualifiable with the information developed during the
inspection. Thelicensee provided supplemental information on item 05
subsequent to the inspection which indicated that this item may also
be qualifiable. For more details on this item, see Paragraph 6.i.3.
The NRC inspectors examined files for approximately 20 equipment
items, where an item is defined as a specific type of electrical
equipment, designated by manufacturer and model, which is
representative of all identical equipment in a plant area exposed to
the same environmental service conditions.
In addition to comparing
plant service conditions with qualification test conditions and
verifying the bases for these conditions, the inspectors selectively
reviewed areas such as (1) required post-accident operating time
compared to the duration of time the equipment has been demonstrated
to be qualified, (2) similarity of tested equipment to that installed
in the plant (e.g., insulation class, materials of components of the
equipment, test configuration compared to installed configuration,
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13
and documentation of both), (3) evaluation of adequacy of test
conditions, (4) aging calculations for qualified life and replacement
interval detennination , (5) effects of decreases in insulation
resistance on equipment performance, (6) adequacy of demonstrated
'
accuracy, (7) evaluation of test anomalies, and (8) applicability of
EQ problems reported in IEBs/IENs and - their resolution.
Although
deficiencies were identified with the EQ Master List and EQ component
qualification files, overall, a majority of the EQ files were
auditable and documented qualification of. the equipment.
The
following comments on both EQ records and walkdown items are
considered the most significant findings.
(1) Joy / Reliance Fan Motors
During the review of the qualification file for Joy / Reliance fan
motors,
file CNM-1211.00-1009, the inspector noted in
Section I .1.1 Part 5, Rev.1 dated August 29, 1986 of the
Equipment Qualification Reference Index that the installation /
mounting of the Joy / Reliance Fan Motors be accomplished per
reference document CNM-1211.00-1065.
This technical manual,
supplied by the vendor, requires the use of breather drains on
the bottom of the main conduit box and the low point of the
motor.
During the walkdown of this equipment the inspectors
noted that there were no breather drains installed on the
Hydrogen Skimmer Fans for Unit 2 (Tag Numbers HSF 2A and
HSF28).
Further conversation between the licensee and the
vendor on February 4,1988, File No. CN-1211.00-19, show that
the Reliance Fan Motors were qualified with the drain breathers
installed and that in containment applications should have them.
Normally, these devices are installed by the vendor prior to
shipment.
However, the licensee had to replace both motors
after initial installation.
Apparently, when the new motors
were installed, the drain breathers were not removed from the
old motors and put into the new motors as required. The failure
to have adequate documentation in the file, at the time of the
inspection, to support qualification of the fan motors without
the drain breathers installed is a violation of 10 CFR 50.49 (K)
and NUREG 0588, Category II, Section 5.(1).
This item will be
identified as Violation 50-414/88-07-04, Joy / Reliance Fan Motors
not installed in accordance with the tested configuration.
(2) RDF Corporation Wide Range Resistance Temperature Detectors EQ
File No. CNM 1399.03-0328
The qualification basis for these RTDs was NUREG-0588
Category II.
Westinghouse's WCAP 8587 was used to qualify the
RTDs.
The test conditions enveloped the plant requirements and the
test specimens was similar to the equipment to be installed.
The functional test did indicate that the insulation resistance
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I
of the splice was on the order of 10 K-ohms (worst case). This-
insulation resistance resulted in a 8.57% error on the high
temperaturerange(DukePowercalculations). The test specimens
did not have a protective casing and were directly sprayed with
water.
This was the major cause of 10X-ohm reading.
The RTDs
installed at Catawba were supposed to have a protective casing
consisting of a stainless steel bellows hose with a stainless
steel overbraid which was to be terminated in a sealed
enclosure.
During the installation, however, the installer cut
the steel ' bellows hose off and connected the uncovered RTD
cables into the vapor tight box, thus, leaving an unsealed
connection at the box.
On November 5,1987, it was discovered
by a Duke Power engineer that Catawba Unit 1 Reactor Coolant
System W/R RTD's cable termination junction boxes were not
sealed.
On November 13, 1987, following a review of the
problem, the station management was notified of the possible
inoperability of both units hot and cold leg W/R RTDs.
Both
Catawba units have operated in all modes of operation with the
affected W/R RTDs being technically inoperable before corrective
measures were implemented. This was reported to the NRC since the
affected Units 1 and 2 W/R RTDs had been unknowingly technically
inoperable in excess of the time limit specified in the
technical specification (see LER 413/87-43).
In response to NUREG-0588 dated March 1984, Duke Power stated
that the RTDs were hermatically sealed units with Flexonics Type
401 H stainless steel hydrostatic hose covering the RTD leads.
Additionally, the RTD leads terminate to the field cables above
the maximum post accident flood level thereby precluding a
submergence problem with the RTD terminators.
A walkdown verified that the RTDs were not installed in
accordance with the design drawings nor in accordance with the
tested configuration in that the sealed bellows hose had been
removed, the junction box was below submergence level, and the
junction box was not adequately sealed.
The failure to install
the RCS wide range RTDs in accordance with the qualified tested
configuration is considered a violation of 10 CFR 50.49.
This
'
item is being identified as Violation 50-413, 414/88-07-02, RCS
Wide Range RTDs Installed in an Unqualified Configuration.
The problem that existed in Unit 1 RTD junction boxes has been
corrected by completely filling the boxes with qualified epoxy
(Scotchcast 9) and replacing the RTDs with new RTDs. that have
the leads covered with stainless steel bellows hose with a
stainless steel overbraid.
The epoxy filled boxes now
completely cover the Raychem splices, thus reducing the
possibility of any leakage current.
The affected Unit 2 RTD
junction boxes will be sealed with epoxy or replaced with
environmentally qualified (sealed) junction boxes.
It was
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15
determined that the fix for these RTD junction boxes is fully
qualified for their application at Catawba, after reviewing
qualification documents supplied by Duke Power Company.
No findings were identified with the file for the W/R RTDs.
(3) Minco Resistance Temperature Detectors (RTDs), EQ File
No. 1399.03-0357
The inspector reviewed the file for the Mir.co RTDs Numbers S8809
and S8810.
The qualification basis was NUREG-0588 Category II.
The Westinghouse WCAP Report 8587 was used to qualify these
units.
The test specimen was identical to the installed
equipment and the plant profile was enveloped by the test. The
minimum allowable insulation resistance measurements were within
the range to guarantee a functional accuracy of 1.0*F.
Minco Model S8809 and S8810 Resistance Temperature Detectors
(RTDs) are used for temperature / density compensation for the
impulse lines of the reference and variable legs of the reactor
vessel level indication system (RVLIS).
The inspector was not
able to physically examine the termination ends of these RTDs
as desired due to time constraints.
Therefore, the inspector
requested Duke to provide documentation as to the location of
the RTD junction boxes with respect to the DBE submergence
level in their vicinity.
Duke was unable to provide such
documentation stating that there were no drawings that showed
'
the exact installed location of the junction boxes for the
Hinco RTDs.
Duke further stated that since the EQ
documentation contained a letter from Westinghouse stating that
the termination ends of these RTDs should be above flood level,
Duke had purchased them with extra length of stainless steel
sheathed mineral insulated cable to accommodate their
installation above flood level.
They also stated that a site
engineer had personally supervised the installation of the
junction boxes and routing of the RTD cable and termination
.
ends to ensure they were installed above flood level.
Nevertheless, Duke reported subsequent to the inspection that
"
they had walked down the RTDs and had found some junction boxes
and termination ends below DBE submergence level.
Duke also
developed and provided to the NRC shortly after the inspection
information that indicated that the Minco RTDs were qualifiable
for submergence.
After review of the information developed,
the NRC inspector received verbal confirmation from Duke as to
the results of the evaluation of the EQ test parameters being
used with respect to Catawba DBE conditions including
submergence and evaluation of EQ test performance data with
respect to the functional performance requirements of the
specific Catawba application of the RTDs.
Duke determined that
the tests were usable to support qualification of the RTDs for
.
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submergence in that test perfonnance data was acceptable for the
plant specific applications and test environmental parameters '
enveloped Catawba DBE environmental - parameters with sufficient
margin with the exception that the temperature of the water in
the long term water absorption tests at 160*F did not envelope
the peak Catawba submergence water temperature of 190*F.
The ovarall approach to this qualification was a combination
of type testing and analysis based on similarity of the RTD
termination end to a submergence qualified conduit seal and on
loss-of-coolant-accident (LOCA) and long term water absorption
data on the wire of which the RTD external lead wires were made.
Duke had compiled data that indicated that the predominant
factor in determining the degradation of the wire's insulation
resistance (IR) (the functional performance variable of interest)
was temperature.
The data indicated that identical and similar
insulation materials of the same and different manufacturers
consistently behaved similarly in terms of IR and variation of
IR with temperature was consistent with that expected with the
materials in question.
The effects of submergence and water
absorption were observed to be no more significant than LOCA
effects except for temperature.
Since the variation of IR
with temperature was relatively predictable and there was
consistent and bounding data from the RTD LOCA test, Duke
determined the IR at 190 F analytically by interpolation between
the data at 160 F and LOCA temperatures and noted that the irs
had been acceptable at LOCA temperatures for the application.
This method of qualification provided reasonable assurance of
satisfactory post-DBE submerged performance of the RTDs and
after consultation with other knowledgeable NRC staff as well
as NRC technical consultants, the inspector found it to be an
acceptable approach.
However, the EQ documentation files at the time of the inspec-
tion did not have such additional data and analyses as it was
not originally intended to show submergence qualification for
the termination ends and external lead wires of the RTDs because
they had been designed to be terminated in junction boxes above
flood level.
Having some RTDs terminated below flood level
rendered the EQ documentation deficient in that qualification.
for submergence had not been demonstrated.
This constitutes a
violation of NRC regulations pertaining to EQ as specified below
and is identified as Violation 50-413,414/88-07-05, Inadequate
Documentation for Qualification of Minco RTDs.
(4) Rockbestos Firewall III Coaxial Cable EQ File
No. CNM-1354.00-0077
The qualification basis for this cable was NUREG-0588,
l
Category II.
The cables inside the Reactor Containment were
second and third generation, with the third generation
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17
qualification test report and the Rockbestos similarity analysis
for second generation cables used for qualification. The plant
profile was enveloped by the_ test conditions. No findings were
identified.
(5) Brand-Rex Instrument Cable EQ File No. CNM-1354.00-0070
The qualification basis for this cable was NUREG-0588, Category
II.
The cables are used inside and outside the containment
for power, control, and instrumentation.
The file contained
,
Franklin Test report F-C5120-4 dated January 11, 1982.
The
tested specimens had the same materials as the installed cable
with an analysis to qualify other sizes of cable.
The test
conditions enveloped the plant profile.
No findings were
identified.
(6) Rockbestos Firewall (FW) III Chemically Cross-Linked Polyethylene
(XLPE) Cable, EQ File No. CNM-1354.00-0069
The qualification basis for this cable was NUREG-0588, Category
II.
The cable specimens tested used the same insulation as
the installed cables.
The test conditions enveloped the plant
requirements and the cable passed mandrel bend and high poten-
tial testing following the DBA.
The package iricluded the
current Rockbestos test report.
No findings were identified.
(7) Okonite Flame Retardant, Cross-Linked Polyethylene (XLPE) Cable
EQ File No. CNM-1354.00-0063
The qualification basis for this cable was NUREG-0588, Category
II.
A number of different sizes are installed inside and out-
side containment.
All cables installed inside containment are
run in conduit.
The installed cables are identical to the
test specimens with the exception of sizes.
The test environ-
ments enveloped the plant accident profile and the cables had
satisfactory insulation resistance and all passed the withstand
test.
No findings were identified.
(8) Rockbestos Firewall III Irradiation Cross-Linked Polyethylene
(XLPE) Insulated Low Voltage Power, Control, and Instrumentation
'
Cable EQ File No. CNM-1354.00-0072
The qualification basis was NUREG-0588, Category II.
One
concern was identified with this cable file.
The cable was
listed as above flood level.
However, during the review it
was learned that the cable would be submerged.
This issue
was resolved before the end of the inspection changing the
qualification documents to show that the cable would be
submerged and placing submergence qualification dccuments in
the file for this cable.
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The current Rockbestos report on radiation XLPE cable was
included in the file.
The plant conditions are . easily enveloped by the test.
The
installed cables were identical to the tested cable.
No
findings were identified.
(9) Rotork Motor Operated Valve Actuator (Model NA-1, Pre-1978),
File No. ChH-1205.19-65
The actuators covered by this file are qualified by a combina-
tion of type tests and similarity analyses in accordance with
the requirements of NUREG-0588, Category II.
The actuators
are required to be operational for 10 days post-accident.
The
qualified life is 40 years with periodic surveillance of the
oil.
Several concerns were discussed with the licensee and were
adequately resolved.
First, the EQ file was comprised of many
individual test reports, rather than a single qualification
document.
It was not clear that the licensee had reviewed and
approved all of these reports as the basis for qualification of
!
'
the NA-1 actuators.
The licensee explained that in order to
'
comply with the requirements of IEEE 382-1972, Rotork undertook
a complete qualification test program for a model 16NA actuator.
'
The results were documented in TR-116 which became the parent
document for various other test reports (43152-1, TR-334,
TR-408, TR-222, TR-404, and TR-178).
The combination of these
'
test reports applies to the Rotork NA-1 actuators shipped to
Catawba before 1987.
The letters of correspondence between the
licensee and manufacturer were included in the EQ file.
The
'
3-tier signature approval sheet verified that the EQ file was
complete.
This was acceptable.
Second, the basis for qualification by similarity was not
i
readily apparent.
The licensee explained that all of the
"A"
range actuators are constructed of the same materials and are
based on the same design.
The electrical properties, stress
levels, clearances, etc. for the 7NA through 90NA actuators are
similar to the 16NA actuator that was tested. Applicability of
the test reports as the basis for similarity was addressed in
document: AE1/4 and NA1.
These documents were briefly reviewed
and found to be acceptable.
The walkdown inspection was perfonned on equipment tag number
2ND0002A.
The actuator assembly was found to be partially
disassembled; the covers were removed from the terminal box and
switch enclosure, the motor was laying on its side on top of
,
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some adjacent pipes, and oil was spread everywhere. There were
V ,.
.
19
no tags visible to indicate that work was in progress, although
tools were found next to the valve. The manufacturer nameplate
was read and found to match the master equipment list
description except for the lubricant Nucleol 528.
The nameplate identified Nucleol 528 as the lubricant, although
the electricians stated that Spartan EP150 was used for all
Rotork actuators regardless of the nameplate.
During the file
review, the licensee provided the Rotork maintenance manual and
Catawba preventive maintenance procedure for review. The review
confirmed that Rotork recommends either Spartan EP150 or Castrol
Nucleol 528 and that Catawba uses EP150 only.
This was
acceptable.
Internal inspection of the terminal box identified a concern
that was resolved during the audit.
There were six wires from
field cable 2ND20 that were found to be cut off inside the
terminal box.
The cut ends of the wires were not taped over and
the conductors were visible.
The licensee performed an
investigation and verified that the other end of the cable was
grounded, and did not carry any load. This was acceptable.
The partial disassembly of the Rotork actuator for Valve 2ND2A
was discussed with the licensee during the EQ audit.
The
licensee performed an investigation of this matter and issued a
Problem Investigation Report (PIR 2-C88-0048).
The progress of
the investigation is summarized below.
f
The Rotork actuator was found with its motor completely
separated from the actuator gearcase.
The separation
occurred at the bolted flange connection between the motor and
gearcase.
The bolt holes in the replacement motor flange are
larger than the original motor.
There was insufficient load
bearing surface on the flange which allowed the motor operator
to separate from the valve gear box when an extremely high
(stall) torque was applied.
The stall torque condition occurred
after the torque switch had been jumpered out (personnel
.
Judgement error).
All work on the valve was stopped at that
!
time pending an investigation,
i
The licensee determined that the failure mechanism occurs if the
valve is taken :s stall conditions. The licensee evaluated the
various valves using Rotork actuators and determined that the
two valves (NV9 and NV10) with the highest potential torque are
not vulnerable to this problem because they do not have the
subject replacement motors.
The investigation reduced the
population of valves with the subject motor to two (1WL805A and
2NV89A).
Both valves go to the closed position in an accident
and are not required to reposition.
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The investigation war, still in progress at the conclusion of the
EQ audit.
The licensee will assess adequacy of the bolted
flange connection and training of maintenance personnel.
The
licensee has discussed the matter with the NRC Resident
Inspector, who will track the investigation.
This issue has
been transferred to the NRC Resident Inspector for tracking and
closure.
No unresolved /open items were identified during the file review
or walkdown.
(10) Rotork Motor Operated Valve Actuator (Model NA-1, Post 1978),
File No. CNM-1205.66
The actuators covered by this file are qualified by a
combination of type tests and similarity analyses in accordance
with the requirements of NUREG 0588, Category II. The actuators
are required to be operational for 10 days post-accident.
The
qualified life is 40 years with periodic oil checks.
The post-1978 actuators are nearly identical to the products
shipped prior to 1978 except for the switch mechanism.
The
post-1978 design uses an electronic latching mechanism on the
torque switch while the pre-1978 design uses a mechanical latch.
Both switch mechanisms are made from the same material.
Both
switches have been tested to meet the required parameters.
The basis of qualification of the post-1978 actuators was a
general test plan to meet the intent of the October 1978 draft
of IEEE 382.
Rotork undertook a complete qualification test
program for actuator models 11NAZT1 and 90NAZT1.
The results
were documented in TR-4379-1, 43979-3, and 58364 for actuators
shipped to Catawba after 1978.
Additional test reports were
included to address steam impingement and confirmation of
operability for specified seismic loads.
The qualified life
(41.5 years) was determined by accelerated thermal aging tests
(140'F and .8 ey activation energy).
The walkdown was performed on valve number 2N000037A.
The
nameplate was consistent with the EQ file data.
Visual
inspection of the terminal box and switch enclosure did not
identify any concerns.
The connections were secure, wires were
labelled and in good condition; Rockbestos jumper wires were
used, and the electrical cab s connection appeared to be
properly installed.
No violations or unresolved items were discovered during the
file review or component walkdown.
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(11) Rcsemount Transmittar 1153 Series B, File No. CNM-1210.04-0262
The transmitters covered by this EQ file are qualified by a
combination of type tests and similarity analyses in accordance
with the requirements of NUREG-0588 Category II.
The
transmitters are required to be operational for 1/2-hour post-
accident.
The 10-year qualified life was based on the results of thermal
aging tests using 125 C internal temperature for '38 days and
an activation energy of .78 ev.
The Equipment Qualification
Reference Index (EQRI) was reviewed and verified that the
replacement and maintenance activities were consistent with
the results of the qualification report.
Several concerns
were discussed with the licensee and adequately addressed.
First, the licensee was asked to verify that the spare cable
entrance is properly environmentally sealed.
The Duke Power
specification CNS-1390.01-0167 required the spare cable entrance
to be sealed.
The specification references the Rosemount
,
instruction manual CNM-1210.04-0245 which includes the same
sealing requirements. Second, Rosemount Report 108026 paragraph
15.4.1 describes a failure of the fill tube closure solder for
the high static pressure housing.
The recommended fix was to
spot weld the fill tube.
The licensee contacted Rosemount, who
stated that the fill tube qualification fix was implemented
prior to the sale of any high static pressure design units. The
supplemental tests were completed and referenced in Rosemount
reports 108025, Revision D, paragraph 7.1.9 and Report 88114.
Due to limited review time these latter reports were not
reviewed.
However, the record of conversation between the
licensee and the vendor, was reviewed and was acceptable.
The licensee's response to IE Notice 85-100 was reviewed.
In
it, the licensee stated that corrective action has been taken to
compensate for the zero shift in transmitter output due to high
,
static pressure.
The new Rosemount instruction manual has
i
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already been issued for Catawba.
(12)
Rosemount Transmitter Model 1153DB
A walkdown inspection was performed on two Rosemount 1153DB
transmitters, namely tag numbers 2NVLT5740 and 2NVLT6070.
The
Catawba tag numbers were verified by the embossed metal labels
attached to each transmitter.
However, both manufacturer
nameplates were missing.
There were no marking to positively
identify the model type as 1153DB. This concern was brought to
the licensee's attention.
)
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The licensee explained that the equipment tag number is a unique
identification used for tracking all document records.
Due to
the limited audit time, the licensee was unable to present a
review copy of the receipt inspection records which tie the
manufacturer nameplate to the Catawba tag number. The licensee
committed to perform a field inspection of the two transmitters
to confirm the model type, to restore their nameplate data, and
to survey a representative sample of all models of Rosemount
transiaitters to ensure that the miss.ing nameplate concern is an
isolated case.
Subsequent to the inspection the licensee
provided a copy of a Receiving Inspection Report which shows
that the transmitters are model 1153D84 which are qualified by
their Master EQ List.
(13) Barton Transmitter Model 764 (B0P), File CNM-1210.04-0261
The transmitters covered by this file are qualified by a combi-
nation of type tests and similarity analyses in accordance with
'
the requirements of NUREG 0588, Category II.
The transmitters
are required to be operational for 1/2 hour post accident. They
are located in various harsh environments inside the auxiliary
building, reactor building, and dog house.
The review of the EQ files included the following reports:
ITT Barton Report R3-764-9, "Class 1E Qualification Test
Program and Results for ITT Barton Differential Pressure
Electronic Transmitter Model 764," October 1982.
l
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R3-764-11, "Investigation of 763 and 764 DBE Anomalies."
R3-764-16
"Investigation of Post-LOCA Long Term Severe
,
Environmental Anomalies of Model 764, Class IE Nuclear
Grade Transmitters."
R1-764-57, "Post LOCA Severe Environment Test of Model
764," August 1, 1983.
R3-764-17. "Effects of Temperature on Model 764 during DBE
(LOCA/HELB)."
'
R1-764-H2, "Accelerated Aging of Model 764," August 2,
1982.
Addendum to R3-764-9, December 9, 1983.
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23
Several concerns were discussed with the licensee and were
adequately addressed.
First, as reported in Test Report
FR-032175, the lead wire separated at the gland seal of the
housing during the post-test examination of the transmitter.
The recommended fix was to replace the 8-foot copper wire
with stainless steel for added tensile strength and corrosion
resistance.
The licensee was asked to determine how these
suggestions were incorporated into the qualification of the
transmitters.
The licensee determined that the test set-up
method caused an unwanted pressure differential across the wire,
forcing steam and water into the pin area of the gland seal
and along the entire length of the wire.
The installation at
Catawba utilizes a physical discontinuity at the vessel pressure
boundary, resulting in zero differential pressure along the
wire.
Therefore, the licensee considers that the stainless
steel wire does not need to be incorporated into the transmitter
design, qualification, or loop accuracy calculations.
Second, the test report R3-764-9 and Addendum showed that
the
5% error test acceptance criteria for the DBE 5-minute
condition was not met.
The licensee was asked to provide
technical justification for acceptance.
In reply, the licensee
stated that all Balance of Plant (B0P) Barton 764 transmitters
in a LOCA or HELB environment have a 10% accuracy requirement
for environmental effects.
The responses to IE Notices81-029, 82-052, and 83-072 were
reviewed and considered to be acceptable.
The leakage current calculations were reviewed and found to
be acceptable.
The impact of an increased instrument loop
,
inaccuracy due to post-accident cable leakage has been assessed
l
by the licensee for the setpoints used in the station emergency
procedures.
The pressurizer level instrument error was deter-
mined to have increased in the nonconservative direction.
Due
to the magnitude of the instrument error and existing error
allowance, there is no urgent need to reverse the setpoints.
j
The setpoints will be revised on a schedule consistent with
the ongoing emergency procedure maintenance program.
This is
acceptable.
A walkdown inspection was performed on two Barton 386A trans-
mitters, namely 2NILT5260 and 2NILT5270.
The devices were
'
identified by the manufacturer nameplate and Catawba equipment
tag.
The wire splices and cable attachment appeared to be
properly installed.
The Raychem splices were found to be bent
in half to fit inside the conduit housing.
Investigation of the
Raychem splice qualification file determined that the installed
configuration (i.e., small bend radius) was acceptable.
The
junction box for each transmitter could not be easily traced
through the cable tray. However, it was observed that the cable
trays and transmitters were located above flood level.
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(14) Foxboro Pressure Transmitter Model N-E10 Series TX File No.
.CNM 1211.00-1792
These transmitters are located in mild and harsh environments
'
in the auxiliary building.
The transmitters covered by this.
file are qualified by type tests and similarity analyses to
the intent of IEEE 323-1974 and 344-1975, in accordance with
NUREG 0588 Category 11 requirements.
The EQ file included the
Wyle Test Report 45592-4 for Foxboro N-E10 series pressure
transmitters.
A cursory review of the EQ file was performed.
The file
includes a statement of qualification by similarity on the basis
of materials, mounting method, weight, dimension, center of
gravity, and functional performance.
A complete justification
of similarity is provided in Foxboro Document Q0AAC012.
This
report was not reviewed for lack of time.
The licensee's response to IE Notice 85-52 was reviewed.
The
licensee stated that Foxboro Model E controllers are not used at
Ca tawba.
-
The reviewer noted that radiation exposure for the annulus
filter transmitters exceeded the qualification level 2.0E8 Rads.
The licensee provided a letter summarizing.a pinpoint radiation
analysis for these transmitters.
The highest Total Integrated
Dose was calculated as 3.83E7 Rads. This was acceptable.
(15) Limitorque Motor Operated Valves, EQ File CNS-1205.19-00-0001
The file for Limitorque Valve Actuators SMB/SBD (containment-
type) and SMB (outside containment-type) included the following
reports:
Limitorque Test report B0058, dated 1980.
1
Limitorque Test Report 600376A (App. B), dated 1972.
Limitorque Test Report 600456 (App. C), dated 1975.
Limitorque Test Report 80003 (App. D), dated 1975.
Limitorque Lubrication Data Form LC8.
Limitorque Maintenance Form LC9.
)
.
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25
In addition to the above test reports, the licensee supplied
for review the following documents pertaining to EQ issues at
Catawba:
Significant Deficiency Report number SD 413-414/84-15,
dated 7/6/84, and associated letters from Duke Power to the
NRC dated 9/11/84 and 12/27/84.
Duke Power maintenance procedures for Limitorque MOVs.
Environmental Qualification References Index (EQRI).
Duke Power internal letter concerning the resolution to IE
Notice 86-71, dated 10/10/86.
Limitorque Hookup Wire Functional Verification, Duke Power
Test Report Number TR-076, (IE Notice 86-03 response),
Installation Specification Manual, "Inspection of Jooer
Wiring in the Limit Switch Compartment of Limitorque KNs."
dated 9/15/86.
During the review of the files the following issues weri
discussed with the licensee. Each issue / concern w s resolve <. "y
the licensee and are presented below.
Are motor brakes (Ding or Inertia) used on Limitorque M0Vs
at Catawba?
No motor braking devices are used.
Are T-drains and Grease Reliefs installed where required?
j
T-drains not installed during initial installation
were installed per Significant Deficiency Report
413-414/84-15.
Subsequently the EQRI was revised
to note the requirement to install T-drains during
actuator installation.
Actuators receiving grease
reliefs are shipped with these reliefs already
installed as required per the procurement orders.
However, walkdown of limitorque operators on Unit 2
identified that paint had been applied over the
drains .
Address IE Notice 79-03 concerning the use of Beacon 325
lubricant in the main and intermediate gear boxes.
Are
there any actuators in an environment of
140'F that
~
contain Beacon 325 lubricant?
There are no Limitorque actuators installed in
locations where normal (non-accident) temperatures
exceed 140'F.
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What are the procedure for cycling the Limitorque actuators
twice a year as recommended in test report B0058?
All safety-related valves are cycled periodically (as
allowed by nuclear safety or operational criteria) per
the IWV program.
Duke Power considers this item a
'
recommendation rather than a necessity for environ-
mental qualification.
Are any motor or limit switch compartment heaters
installed? If so are they de-energized?
All heaters have been. de-energized per the work
request supplied in response to IE Notice 86-71.
What type of internal wiring (jumpers) are used in the limit
switch compartments?
Duke Power has addressed this issue in their response
to IE Notice 86-03.
All internal jumper wire has been
replaced with qualified Rockbestos or Raychem wire for
in-containment MOVs.
Are there any terminal boards used in the limit switch
compartments?
Inside containment Limitorque MOVs, that are required
for long-term post-accident conditions, utilize
terminal blocks in control circuits only (120 V). All
other Limitorque M0Vs are containment isolation valves
and do not utilize terminal blocks.
Raychem splices
are used in place of connection boards.
Have "Megger" tests been perfonned on the motors and leads?
Megger tests were performed by the Construction Depart-
ment during installation.
Cocumentation is available
at the station and was supplied to the inspector.
Supply documentation identifying the type of cable used to
replace unqualified wire (field run) in the limit switch
compartment as stated in your response to IE Notice 86-03.
Documentation was supplied showing that all unquali-
fied wire installed in the MOVs have been replaced
with qualified Rockbestos or Raychem wire.
The worst-case radiation (TID) parameters for this environ-
mental zone is 6.0E8 rads.
The Limitorques are qualified
to 2.04E8 rads TID.
You have stated that pinpoint analysis
is being conducted to demonstrate a lower required T!D.
Has this analysis been completed?
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The M0Vs in question are 1YE4, IVE9, 2VE4 and 2VE9.
An evaluation of the TIO for these Limitorque
operators was performed. The results of this analysis
can be found in calculation # CNC-1229.00-00-0014,
Rev. 10, page 2421.
The 're:;ults show that the
worst-case is 1.9E7 TID.
,
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Provide justification for submergence requirements for
in-containment Limitorque MOVs.
The submergence question is resolved in FSAR, chapter
6.3, page 6.3.2.1.
This states that there is suffi-
cient time for them to close before being flooded.
To prevent possible repositioning after flooding, the
valves motor control circuits have been modified to
prevent any spurious limit switch operation from
repositioning the valves. Also breakers and fuses are
coordinated such that, in the case of faults caused
by submergence, the faulted valve. circuits will be
isolated without adversely affecting the upstream
class IE power sources.
4
!
During the plant walkdown the following Limitorque Motor
Operators were physically inspected:
2KC3648, size SMB-00, with Reliance Motor class RH
insulation.
2KC345A, size SMB-00, with Reliance motor class R
,
i
insulation.
2VX001A, size SMB-000, with Reliance Motor class RH
insulation.
'
The above actuators and motors were inspected to TI 2515/75
instructions.
The only item of concern that was determined
during the inspection of the actuators was the possibility of
]
the "T-drains" being plugged with paint and not allowing water
l
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to drain as required.
This was brought to the attention of the
i
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licensee as a generic concern.
The licensee later performed an
inspection of all limitorques on both Catawba units for plugged
or missing T-drains.
A total of 42 actuators were discovered
with plugged T-drains or with T-drains not installed at all.
Table 1 is a list of the affected tag numbers.
Functional
T-drains have since been installed on all the affected actua-
tors.
In addition, Duke performed an operability analysis to
show that the limitorque operators could have performed their
safety function.
The root cause of these deficiencies (clogged
,
1
and missing T-drains) appear to be due to inadequate training
and procedures to ensure correct and complete T-drain instal-
J
lation and maintenance.
To prevent recurrence the licensee
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connitted to the following corrective actions (1) the Construc-
tion and Maintenance Department will retrain painter craf t
by March 30, 1988, (2) Station I&E will revise procedures to
clarify T-drain installation requirements by February 25, 1988,
and (3) Station I&E will conduct fonnal T-drain installation
training by March 30, 1988.
This item is a violation of
10 CFR 50.49 for failure to ensure the as-built configuration
was in accordance with the qualified tested configuration.
This item is identified as violation 50-413, 414/88-07-07,
Plugged or Missing T-Drains on Limitorque Valve Motor Operators.
One additional concern was identified regarding the installation
of T-drains on Limitorque Motor Operators.
During the walkdown
T-drains on limitorque valve No. 2NI-1228 were not installed at
the low point.
This configuration does not appear to be quali-
fied.
This item was identified to the licensee as Unresolved
Item 50-414/87-07-08, T-Drains on Limitorque operator not
installed at low point.
Table 1
Total List of Limitorque Actuators With Plugged or Missing T-Drains
IKC364B
INM201A
IVX002B
2KC394A
2NC253A
2NV055A
i
1KC394A
INV055A
IVE004
2KC413B
INM187A
2VC0078
1NI115A
INV066A
IVE009
2KC429B
2NM190A
2WL450A
1NI183B
INV236B
1N0024A
2NC054A
2NM197B
2VE009
f
l
1NM0078
INUO35A
IND059B
2NC250A
2NM2008
2VE004
1NM0269
IVF001A
INIO47A
2NC251B
2NM207A
2NM025A
INM200B
IVX001A
2KC345A
2NC2528
2NM210A
2NI183B
(16) Conax Electrical Penetrations, Type N, EQ File
.
CNS-1361.00-048-001
The qualification file contains the following Conax test
reports:
Report IPS-1037, Rev. D1,10/31/83, "Design Qualification
Report for Electric Penetration Assemblies for McGuire/
Catawba Nuclear Stations 1 and 2."
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Report IPS-1332, Rev. A, 2/18/86, "Design Qualification
Report of 50 Ohm Triac. Feedthrough Kits Installed in
i
Electric Penetration Assemblies for Catawba /McGuire Nuclear
Stations 1 and 2."
Two issues that were identified during the review of the file
were discussed with the licensee and resolved prior to the
conclusion of the audit. They were:
The file did not contain documentation which determined
the qualified life of the Conax Penetrations.
This
documentation was supplied in files CNM-1361.00-0062-001
(conax test report IPS-325) and an auditable trail was
provided to the auditor.
,
It was noted during the walkdown that Litton connectors
were associated with the Conax Penetration enclosure box.
The licensee was requested to provide documentation
supporting the qualification of these connectors. The file
provided was CNM-1354.12-0026-001, which included test
reports:
CE-NPSD-230-P, 4/83; CE-NPSD-275-P; and Retrofit
r
report CE-NPSD-296-P, 5/85.
During the walkdown Conax Electrical Penetration 2 PENT 121 was
physically inspected.
It was observed that plastic caps were
attached to the spare Litton connectors outside of the enclosure
l
box.
When the licensee was asked to justify this, the response
was that they are for housekeeping purposes only. Environmental
sealing is not required since the conductors are solid wire and
,
the connector is potted. Moisture intrusion into the electrical
penetration cannot occur.
They also stated that the caps are
not required for equipment qualification.
Documentation was
provided to the auditor to support the above statements.
No
other discrepancies or anomalies were identified.
(17) D. G. O'Brien Electrical Penetrations, Types F, G and K, EQ Files
CNS-1361.00-0016-002, Rev. 6 and CNS-1351.00-0016-0003, Rev. 7
This equipment penetrates the wall between the inside of
containment and the annulus to form part of the pressure
barrier.
These penetrations are actually installed on the
inside of containment.
The worst case environmental parameters
in both the inside of containment and the annulus have been
considered.
The qualification file numbers are CNS-1361.00-0002 and -0003
which contain the following test reports:
D. G. O'Brien report number ER-252, Rev. A., dated 8/15/77,
"Prototype Test Report low Voltage Power and Instrumenta-
tion Electrical Penetrations."
i
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D. G. O'Brien report number ER-327, "Qualification report
for Triaxial Connectors for Electrical Penetrations."
Wyle Laboratories Report Number 45869-1
A cursory review of the qualification file for the D. G. O'Brien
Electrical Penetrations was made.
One item of concern that was
addressed was how Duke Power responded to IE Notices 81-20 & 29.
The licensee's response was that the Type
"K" electrical
penetration plugs were tested at Wyle Laboratories (Wyle Report
Number 45869-1).
More emphasis was placed on accurately
simulating the actual station environment under accident
conditions.
The qualification of the Type
"K" electrical
penetration plugs were reverified as documented in file
CNM-1361.00-0016-001, pages 5-1 through 5-335, pages 6-1 through
6-91 and pages 7-1 through 7-25.
During the walkdown
D. G. O'Brien Electrical Penetrations
2 PENT 105, Type F, 2 PENT 111, Type K, and 2 PENT 112, Type G were
physically inspected.
No discrepancies or anomalies were
identified during the inspection.
(18)Namco Limit Switches,
Files CNM-1205.19-0042 and
CNM-1225.00-0063
During the plant walkdown inside Unit 2 containment, the NRC
L
inspector noted that the switch compartment cover plate gasket
on a NAMC0 Model EA 180 limit switch, plant ID No. 2NCLLO251,
i
was improperly installed rendering the limit switch environ-
mentally unqualified.
The inspector confirmed that the switch
was listed on the EQ master list as requiring qualification.
No other NAMCO limit switches required to be qualified were
observed to have improperly installed gaskets.
This was
identified as an unresolved item at the exit meeting pending
i
determination of the safety function of the switch and the
i
conditions under which it must perform that function.
Subse-
'
quent to the inspection, Duke informed the NRC that the sole
function of the switch was to provide open indication for
normally-open reactor vessel head inner omega seal leakage
detection line isolation valve 2NC 25A.
Duke stated that the
switch provides non-essential position indication which will
not mislead the operator.
They further stated that the gasket
had been promptly replaced (See Problem Investigation Report
2-C88-0054), that other limit switches had been inspected with
no other deficiencies identified, and that an investigation into
the cause of the improper installation was being initiated.
This is identified as violation 50-414/88-07-06, Unqualified
Namco Limit Switch.
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(19) Electric Hydrogen Recombiners, EQ File WCAP-7709-L
During the walkdown of the Unit 2 Hydrogen Recombiners, the
splice configuration was questioned. The Unit 2 recombiners had
a Raychem sleeve over the splice joint in what appeared to be a
one-to-four configuration.
The inspectors were told that the
Unit 1 configuration was different and was actually a taped
splice done in accordance with an engineering evaluation.
Investigation by the licensee on the Unit 2 recombiners showed
that there was a qualified four-to-one Raychem breakout kit
underneath the sleeve; therefore; the splice was found to be
acceptable.
The licensee also looked at the Unit 1 splices to
measure seal lengths on the conductors.
By using at least three
test reports, the licensee was able to show that the Unit 1
splices were qualifiable.
However, the qualification file did
not demonstrate qualifiability and the licensee stated that
the file would be corrected by the addition of the similarity
analysis and several test reports.
This is identified as
Violation 50-413/88-07-01, Inadequate Documentation of Qualifi-
cation of Splices for Hydrogen Recombiners.
(20) Raychem
The NRC inspector evaluated Duke's actions in response to
IE Information Notice (IN) 86-53 (Improper Installation of
Heatshrink Tubing) for Catawba in accordance with the guide-
lines of Temporary Instruction (TI) 2500/17.
The inspector
reviewed Catawba Nuclear Specification No. CNS 1390.01-0074,
Rev. 20, dated February 14, 1988, for installation of Raychem
heatshrink splice insulation.
Duke stated that plant work and
inspection procedures for installation of Raychem heatshrink
tubing splice insulation are based directly on this specifica-
tion.
The Duke specification was found to be consistent with
Raychem specifications.
While the date of the current revision
to the Raychem specification was quite recent, the acceptance
criteria most often seen violated in the field had been incorpo-
rated in a revision prior to Revision 18, dated October 2, 1986,
indicating that installation specifications consistent with
manufacturer's specifications had been in effect no later than
shortly after the issuance of IN 86-53 (July 1986).
The inspector then reviewed records of Duke walkdown inspections
of Raychem splices in response to IN 86-53.
The documentation
indicated that splices had been chosen on a sample basis with
j
the emphasis on the harshest environments and splices that
i
records showed had been installed before implementation of the
l
installation procedures in accordance with Raychem specifica-
tions.
Duke personnel found that splices were either in com-
pliance with Raychem qualified configurations or that deviations
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32
from Raychem specifications were within the bounds of recent EQ
testing of non-standard configurations sponsored by the Nuclear
Utility Group on Environmental Qualification (NUGEQ) of which
Duke is a member. Duke had incorporated reports of this testing
in EQ documentation files for Raychem splices to demonstrate
qualification for the as-found conditions, however they stated
that many of the splices had been replaced anyway to provide
extra margin and all replacement /new splices are done to the
latest specifications.
Duke further stated that no splices
,
were found that were not qualifiable under the NUGEQ testing.
The NRC inspector's review of training documentation indicated
that ETQS Training and Qualific~ation Guide, Task No. IE-9025,
"Stripping, Splicing, et.
al., Wiring Class 1E Cables and
Devices, Rev. 2, dated June 1,1987, referenced installation
procedure IP/0/A/3890/08C which was based on CNS 1390.01-00-0074,
!
Rev. 20.
Training and Qualification records indicated that the
,
appropriate craft personnel hed been trained in proper Raychem
j
installation techniques and were qualified to Task No. IE-9025
'
by satisfactory perft.,rmance and explanaticn of the referenced
'
procedure.
7.
Inspector Followup Item (IFI)
(Closed) IFI 50-413/87-20-02, Unqualified Wire in Annulus Ventilation
(VE) System.
This item was opened as a result of a licensee review of the
qualification #ile for the VE system.
It was noted that the file
l
required qualification of the wire to 8.0E6 Rads and the file showed
qualification to 1.0E6 Rads.
j
The licensee provided a justification for continued operation in June
1987 which had information showing the wire needed to be qualified for
only 2.0ES.
Additionally, during the inspection, information was
provided to show that the wire was actually qualified for greater than
8.0E6.
Based on the fact that the wire is qualified, this item is considered
closed.
t