ML20154Q386
| ML20154Q386 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/27/1988 |
| From: | Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20154Q384 | List: |
| References | |
| 50-456-88-05, 50-456-88-5, 50-457-88-06, 50-457-88-6, GL-88-07, GL-88-7, NUDOCS 8806070006 | |
| Download: ML20154Q386 (18) | |
See also: IR 05000456/1988005
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/88005(DRS);50-457/88006(DRS)
Docket Nos. 50-456; 50-457
Licenses No. NPF-72; No. NPF-75
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Licensee: Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name:
Braidwood Station, Units 1 and 2
Inspection At:
Braidwood Site and Glen Ellyn, Illinois
Inspection Conducted: ' February 29 through May 4, 1988
Inspector:
A. S. Gautam
Regional Inspector, Region III
Date
Also participating in the inspection and contributing to the report were:
M. Kopp, RIII
R. Wilson, NRR
J. Hanek, INEL
R. Vanderbeek, INEL
K. Iepson, Schneider Enggs
V. Nicolette, San i
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Approved By:
. Gardner, Chief
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Plant Systems Section, Region III
Date
Inspection Summary
Inspection on February 29 through May 4,1988 (Reports No. 50-456/88005(DRS);
No. 50-457/88006(DRS))
Areas Inspected: Special, announced safety inspection of the environmental
qualification (EQ) of electric equipment within the scope of 10 CFR 50.49.
The inspection included licensee action on SER/TER commitments; EQ program
compliance to 10 CFR 50.49; adequacy of EQ documentation; and a plant physical
inspection of EQ equipment (Modules No. 30703 and No. 25576).
-Results: The licensee has not adequately implemented their program to meet
the requirements of 10 CFR 50.49.
Deficiencies in the areas inspected are
suninarized below:
8806070006 880527
ADOCK 05000456
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POTENTIALLY ENFORCEAB'LE UNRESOLVED ITEMS-
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Item No.
~ Description
Report Section
50-456/88005-01(DRS)
. Inadequate documentation'for
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50-457/88006-01(DRS)
the EQ of Johnson Control
supplied.HVAC components.
50 456/88005-02(DRS)
Sealing, torquing and'lubri-
4c
50-457/88006-02(DRS)
cation (maintenance)
(1 2)(3)(4)
deficiencies resulting in
(5 6)(7)(8)
unqualified EQ equipment.
(9 10)
50-456/88005-04(DRS)
Inadequate documentation
5a
50-457/88006-04(DRS)
for the EQ of Bunker Ramo
instrumentation penetrations.
50-456/88005-09(DRS)
Missing weep holes and drip
6a
50-457/88006-09(DRS)
shields in 10 CFR 50.49
designat2d junction boxes.
50-456/88005-10(DRS)
' Inadequate documentation
6b
50-457/88006-10(DRS)
to qualify GEC0 pressure
switches.
50-456/88005-11(DRS)
Inadequate documentation
6c
'50-457/88006-11(DRS)
to qualify mixed greases
in Limitorque actuator
main gear cases.
OPEN ITEMS
Item No.
Description
Report Section
-50-456/88005-03(DRS)
Inadequate quality assurance
4e(1)(2)
50-457/88006-03(DRS)
and training program in regard
to EQ.
50-456/88005-05(DRS)
Revision of EQ file for
5b
50-457/88006-05(DRS)
Joy / Reliance Fan Motors
to include EQ Calculation.
50-456/88005-06(DRS)
Revision of EQ file for
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.50-457/88006-06(DRS)
Target Rock Solenoid
valves to include EQ
calculation.
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Item No.
Description
Report Section
50-456/88005-07(DRS)
Revision of EQ file for
5d
50-457/88006-07(DRS)
ITT Barton Model 752
Transmitters to include
missing EQ documentation.
50-456/88005-08(DRS)
Revision of EQ file for
Se
50-457/88006-08(DRS)
General Atomic Radiation
monitor to include EQ
documentation.
50-456/88005-12(DRS)
Deficient Raychem Splice
6d
50-457/88006-12(DRS)
found on General Atomic
high range radiation
monitor.
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DETAILS
1.
Persons Contacted
a.
Commonwealth Edison Company (CECO)
C. Reed, Senior Vice President
L. DelGeorge, Assistant Vice President, Licensing and Plant Support
M. Wallace, Manager, Projects and Construction
B. Shelton, Manager, Power Engineering
K. L. Graesser, General Manager, Power Operations
- D. Elias, Superintendent, Power Engineering
- E. R. Wendorf, Assistant Superintendent, Project Construction
+R. Querio, Station Manager
- G. Fitzpatrick, Station Manager
- K. Kofron, Superintendent, Production
- D. O'Brien, Superintendent, Services
M. Lohmann, Construction Superintendent, Project Startup
- G. Masters, Assistant Superintendent, Operations
- D. Paquette, Assistant Superintendent, Maintenance
- P. Cretens, Assistant Superintendent, Work Planning
- L. Davis, Assistant Superintendent, Technical Services
+*P. Barnes, Regulatory Assurance Supervisor
- R. Lemke, Technical Staff Supervisor
J. Gosnell, QC Supervisor
R. Kyrouac, QA Supervisor
S. Hedden, Master Instrument Mechanic
J. Smith, Master Electrician
J. Huffman, Master Mechanic
- D. Kapinus, Assistant Technical Staff Supervisor
- L. Woldridge, Technical Staff Parts & EQ Group Leader
- J. Roth, Station EQ Coordinator, Technical Staff
B. Rosenmeier, Technical Staff, Parts & EQ
R. Grams, PSD - Engineering
C. Moerke, General Design Engineer, Power Engineering
- W. Groszko, Configurat;on Management, Power Engineering
- E. Adams, BW/BY EQ Coordinator
F. Lentine, Supervisor, Licensing
+*S. Hunsader, Administrator, Licensing
- T. W. Simpkin, Regulatory Assurance
- D. Kruger, Technical Staff, Byron EQ Coordinator
- W. B. McCue, Operating ENGG, BWR
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R. D. Branson, Byron, Master Electrician
- J. Snyder, Electrical Maintenance
b.
Consultants - Sargent and Lundy (S&L)
- S. M. Malak, EQ Coordinator, Project Management Division
- M. M. Hassaballa, Supervisor
- A. Mohiudidin, Senior Component Engineer
- D. P. Galanis, Electrical Engineer
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- A.-Alsammaroc, EQ Engineer
- S
Akhtar, EQ Engineer
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- R. Hoke, EQ Engineer
- A. Behera, Consultant
- H. Heidarisafa, EQ Engineer
- B. Pandit, EQ Engineer
- R.-John, EQ Engineer
- D. Drankhan, EQ Engineer
S. Malak, PMED
B. Kornbreck, EPED
M. Banogon, Control & Instrumentation Division (CID)
C. B. Kornoker, Electrical Engineer
- W. Poirier,' Project Manager, Westinghouse
c.
Nuclear Regulatory Commission (NRC)
A. B. Davis, Regional Administrator, RIII
C. J. Paperiello, Deputy Regional Administrator, RIII
H. J. Miller, Director, DRS
E. G. Greenman, Director, DRP
- J. J. Harrison, Chief. Engineering Branch, DRS
W. L. Forney, Chief, Projects Branch 1, DRP
- R. N. Gardner, Chief, Plant Systems Section, DRS
- U. Potapovs, Chief, iendors Program Branch, NRR
J. M. Hinds, Chief, Projects Section 1A, DRP
- T. Tongue, Senior Resident Inspector, Braidwood
- Denotes those attending the interim site exit meetings on March 4,
1988.
+ Denotes those attending the exit interview on May 4, 1988, at the
conclusion of the inspection.
2.
Allegation Follow-up (RIII-86-A-0131)
During July and August 1986, an unidentified alleger contacted the NRC
regarding concerns with components supplied by Westinghouse to Johnson
Controls, Inc. (JCI) for installation at Byron and Braidwood, Units 1
and 2.
The alleger stated that W-2 and 0T-2 switches, AR relays, and
EZC indicating lights were not properly environmentally qualified to
the requirements of 10 CFR 50.49, Paragraph (f). As a result of this
allegation, an :nspection was performed at Johnson Controls by inspectors
of the NRC Vendor Branch (Inspection R> port No. 99901072/86001) who
concluded that the HVAC systems provided by JCI at Byron and Braidwood
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were located in mild environments and were not required to meet
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10 CFR 50.49. As a followup, Region III was requested by the NRC Vendor
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Branch to confirm whether the HVAC equipment supplied by Johnson Controls
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per JCI specification F/L 2783, was in fact located in a mild environment.
During this current inspection, the NRC inspectors con'frmed that the
Westinghouse W-2 switches in question were located in mild environments,
and therefore were not within the scope of 10 CFR 50.49.
The inspector
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also observed, however, that the Westinghouse OT-2 switches, EZC
indicating lights, and the AR relays in question were located in harsh
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environments.
The licensee could not provide evidence that the
Westinghouse components installed by JCI were similar or identical to the
components tested by JCI.
Subsequent to these NRC findings, the licensee
presented an engineering analysis to evaluate the Westinghouse OT-2
switches, EZC lights and AR relays, for use in various HVAC panels at
Braidwood Station. This analysis concluded that (1) the subject
components were installed in a relatively mild environment - radiation
harsh only; (2) the only failure mode of concern was loss of dielectric
strength of the insulating parts and the loss of mechanical properties
of the moving parts'and; (3) there was a 400% margin in the design
electrical stress for these components.
A checklist for comparison of Westinghouse EZC lights, AR 440 relays,
AR 660 relays and 0T-2A switches had been used by the site to walkdown
the Johnson Controls provided components.
The checklist permitted
comparison of the installed components to the tested devices.
Some
color discrepancies were noted. Westinghouse indicated that they were
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attributable to pigmentation and did not represent a materials change.
Discrepancies in the data printed on the EZC Light and AR 440 relays were
also noted during the licensee's walkdown.
The licensee attributed these
discrepancies to differences in the color of light lenses and the job
number, respectively.
The licensee has committed to confirming their conclusions by destructive
tes ting .
Eight Johnson Control provided components (2 OT-2 switches,
2 EZC lights, 2 AR-440 relays and 2 AR 660 relays) have been removed from
the Johnson Controls panels and hand carried to Westinghouse for
diagnostic examination.
This examination is intended to identify the
materials in the components and confirm their qualification.
Pending NRC
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review of the results of this examination, this is considered a Potentially
Enforceable / Unresolved Item (No. 50-456/88005-01(DRS);
(No. 50-457/88006-01(DRS)).
3.
Licensee Action on SER/TER Commitments
The NRC inspection team evaluated the implementation of the licensee's EQ
corrective action commitments discussed in Braidwood SSER 2 included in
the Braidwood FSAR. SSER 2 noted that the scope of the staff review for
Braidwood Unit I was limited to an evaluation of those 10 CFR 50.49 desig-
nated electrical components that were different from equipment installed
in Byron Unit 1.
Since the licensee did not identify any 10 CFR 50.49
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equipment installed in Braidwood Unit 1 as different from 10 CFR 50.49
equipment installed at Byron Unit 1, the staff's review of the EQ program
for Byron Unit 1 was considered applicable to Braidwood, Unit 1.
The majority of the deficiencies identified in the SER addressed
documentation, similarity, aging, qualified life, and replacement schedules.
All open items identified in the NRC June 21-23, 1983 audit were addressed
by the licensee in their July through October 1986 responses to the NRC
staff.
The licensee's proposed resolutions to these items were found
acceptable by the NRC, as stated in Section 3.11 of the Braidwood SSER 2.
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The primary objective of the current Region III EQ Audit in this area was
to verify that appropriate analyses and necessary documentation to support
the licensee's proposed and accepted resolutions were contained in the
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licensee's EQ files, and that appropriate modifications or replacements of
equipment had been implemented.
During this review, the NRC inspection team reviewed EQ documentation and
-examined equipnent in the plant relevant to prior discrepancies identified
in the SERs, including replacement of equipment having qualification
deficiencies.
- No violations of NRC requirements in recard to the SER commitments were
identified.
4.
EQ Program Compliance to 10 CFR 50.49
The inspectors reviewed selected areas of the licensee's EQ Program to
verify compliance to 10 CFR 50.49. The licensee's EQ program was found
to identify methods of equipment qualification; provide for evaluation
and maintenance of EQ documentation in an auditable form; provide for
upgrading of replacement equipment; and incorporate controls for plant
modifications. Based on their review, the inspectors determined that the
licensee had estabiished an EQ program to address the requirements of
10 CFR 50.49, The licensee's methods for establishing and maintaining
the environmental qualification of electrical equipment were reviewed in
the following areas:
a.
EQ Program Procedures
The inspectors examined the adequacy of the licensee's policies and
procedures for establishing and maintaining the environmental
qualification of equipment within the scope of 10 CFR 50.49.
The
licensee's EQ program was reviewed for procurement of qualified
equipment; maintenance of qualified equipment; modifications to the
plant that could affect qualified equipment; updating of the EQ
master list; and review and approval of EQ documentation.
Procedures
reviewed included the following documents.
BWAP 370-1, Revision 2, "Station Lubrication Program"
BWAP 500-5, Revision 0, "EQ Program"
BWAP 1600-1, Revision 13, "Maintenance Work Request Procedure"
BWAP 1610-1, Revision 0, "Modification Requests"
BWAP 800-2, Revision 1, "Control of Requests for Purchase"
BWAP 800-1, Revision 4, "Classification of Parts, Safety-Related
Components"
BWAP 800-3, Revision 0, "Technical Evaluation of Components and
Parts"
BWIP 2400-111, Revision 0, "EQ Requirements for Plant Instrumentation"
BWHP 4006-009, Revision 1, (NAMC0)
BWHP 4006-017, Revision 4,(LIMITORQUE)
BWMP 3305-044, Revision 0,(LIMITORQUE)
Specific areas reviewed in these procedures included requirements
for review and acceptance of the EQ files, responsibilities of
key individuals and departments, EQ definitions, maintenance
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and surveillance.
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No violations of NRC requirements were identified,
b.-
10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment
10 CFR 50.49, Paragraph (d), requires licensees to prepare a list of
electrical equipment important to safety, and within the scope of the
rule.
The NRC inspectors reviewed the licensee's MEL for compliance
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to 10 CFR 50.49. Areas reviewed included adequacy of the MEL,
technical justifications for removal of items from -the MEL, and
licensee reviews of the MEL changes due to field modifications. The
inspectors verified the completeness / adequacy of the list in tems of
equipment needed during accident conditions through review of piping
and instrumentation drawings (P&IOS), emergency procedures, technical
specifications, and FSARs.
No vic/.ations of NRC requirements were identified,
c.
EQ Maintenance and Surveillance Program
The inspector reviewed specific maintenance, replacement, surveillance
tests and inspections necessary to preserve the environmental qualifi-
cation of EQ components identified on the MEL.
EQ requirements in the
licensee's maintenance procedures and EQ files were reviewed against
maintenance records of selected equipment to verify perfonnance of
maintenance and surveillance activities at prescribed intervals.
Several deficiencies were identified in regard to gasket ('0' ring)
inspection, lubrication, and torquing of EQ components.
Subsequent
to the NRC findings, the licensee performed an onsite review (OSR) of
EQ equipment requiring maintenance and surveillance.
The OSR resulted
in several additional deficiencies being identified by licensee.
Details of all findings are noted below.
(1) Target Rock Solenoid Valves, EQ Binder EQ-BB-HE10A
EQ-BB-HE10A, Tab E, requires replacement of the RTV silicone
rubber gasket every time the valve cover is removed.
The
licensee could not provide evidence that the cover gasket
was replaced on solenoid valve 1CV-8114 after the cover
was removed during completion of Work Request A99999, dated
Janua y 31, 1987.
(2) Rosemount Pressure Transmitters, EQ Binder EQ-BB-061
EQ-BB-061, Tab E, requires inspection and cleaning of mating
surfaces, lubrication of '0' rings, and torquing of the housing
cover each time the cover is removed.
The licensee could not
provide evidence that these activities were performed for
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pressure transmitters IPT-MS-042, 1PT-MS-043, IPT-MS-004 during
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calibration in May 1986 or prior to Unit 1 criticality in May
1987.
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(3) Westinghouse Motors, EQ Binder EQDP-AE-2
EQDP-AE-2 states that motor qualification presumes that
recommended maintenance procedures are followed. An engineering
study performed by Mobil Oil Company requires motor bearing oil
to be replaced every twelve months.
EQDP-AE-2 allows changing
motor bearing)cil every second refueling outage (every three
years or more . For example pump motor 1RH0!PA bearing oil was
replaced on March 20, 1987, while the next oil replacement is
scheduled for November 30, 1989.
The licensee did not have
adequate justification for not meeting the vendor (Mobil Oil)
requirements.
(4) Limitorque Valves, EQ Binder EQ-BB-027
EQ-BB-027, Tab E, requires the main gear case lubricant to be
inspected in accordance with Limitorque Lubrication Inspection
Procedure, LC-8.
Procedure LC-8 specifies lubricant inspection
every 18 months until operation history indicates otherwise.
EQ-BB-027, Tab E, as revised on October 17, 1986, however, also
contains conflicting requirements that allow lubricant inspection
to be performed at every second refueling outage (every three
years or more). The licensee could not provide operating history
data or engineering justification for extending the lubricant
inspection frequency from 18 months to three years.
For example the EQ General Surveillance System (GSRV) for
Limitorque Valve ICS-001A-LOS indicated that the last inspection
date of the main gear case lubricant was October 14, 1986, and
that the next due date was November 30, 1989.
In addition,- the
inspectors observed that the last lubricant inspection actually
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occurred on January 1,1986 and not on October 14, 1986 as
recorded in the EQ GSRV program.
These discrepancies in EQ
scheduling could have resulted in a lubricant inspection frequency
of over three (3) years and eleven (11) months for Limitorque
valve ICS-001A-L05.
(5) Valcor Valves, EQ Binder EQ-BB-064
Braidwood EQ maintenance instructions required installation of
new 'O' rings whenever the housing cover of the solenoid valve
is removed. The OSR identified 'O' rings as not having been
replaced on Units 1 and 2 Valcor valves PS-228A and B, PS-229A
and B, PS-230A and B, IRC 014C and D, and 2RC014A, B, C, and D.
The licensee has subsequently replaced the 'O' rings on reactor
head vent valves 1RC014C and D, and 2RC014A, B, C and D.
The
licensee also provided evidence that the remaining primary
process sampling valves do not require sealing from moisture
intrusion based on the postulated accident environment at the
valve location.
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(6)
Incore Thermocouple Reference Junction Box, EQ Binder EQDF ESE-44A
Braidwood EQ maintenance instructions require replacement of
the enclosure 'O' ring each time the cover of the junction
box is opened.
The OSR identified that the 'O' ring was not
replaced-when the cover was removed on Junction Box.21T-01J,
during performance of Work Request A99999, dated February 5,
1988.
The licensee has subsequently installed a new '0' ring
in the junction box.
(7) NAMC0 Limit Switch ISI-001B-A-Z5
The licensee was unable to verify that the Limit Switch cover
had been torqued as required by EQ maintenance instructions.
The licensee subseauently torqued the cover, as required, per
Nuclear Work Request A20704.
(8) Limitorque Operators, Unit 1
The licensee could not provide evidence that EQ installation
requirements for torquing of mounting bolts and valve actuator
housings had been met.
Subsequent to this finding, the
licensee initiated Nuclear Work Request A20661 to torque the
mounting bolts on approximately (86) Limitorque operators.
(9) Westinghouse Pump Motors, EQ Binder EQDP-AE-2
The OSR identified unqualified Mobil DTE Heavy Medium oil being
used for motor bearing lubrication.
The qualified lubricant is
Mobil DTE Medium oil, as required by the EQ maintenance documen-
tation. The licensee subsequently replaced the Heavy Medium oil
in Westinghouse Motors with Medium oil.
(10) Reliance and Westinghouse Fan Motors, EQ Binders EQ-BB-008
E0-BB-008 specifies Chevron SRI-2 as the qualified trotor bearing
lubricant.
The OSR, however, identified the use of Mobilux EP in
lieu of the Chevron SRI-2 for these motors.
The licensee has
subsequently replaced Mobilux EP with Chevron SRI-2, per Nuclear
Work Requests A20738, A20739, and A20771.
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Each of the 1'ndings described in Section 4c (1) through (10) is
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considered a posantial violation of 10 CFR 50.49, in that the
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components were nt,' qualified for their installed conditions.
Pending furthcr NRC 'eview, these concerns are considered part
of one Potentially Enforceable Unresolved Item (No. 456/88005-02(DRS);
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No. 457/88006-02(DRS)).
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d.
Plant Procurement of 10 CFR 50.49 Designated Equipment
Licensee procedures were found to adequately address procurement of
appropriate replacement equipment.
Procurement procedures and docu-
ments were found to adequately address appropriate quality and
regulatory requirements regarding the environmental qualification
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of equipment within the scope of 10 CFR 50.49.
Checklists were
observed to have been used to provide evidence of reviews and ane mvals.
No violations of NRC requirements were identified.
e.
Quality Assurance (QA) and Training Program
(1) During review of licensee quality assurance activities, the
inspectors determined that the licensee had implemented a
program to menitor the quality of EQ activities through
surveillance, audits, and reviews of the records and files
for plant modifications and equipment procurement. NRC
inspectors reviewed the licensee's QA audits including QA Audit
Nos. 06-80-15 and 06-87-15 conducted in May 1986 and May 1987,
and found the methodology acceptable.
The inspectors were,
however, concerned that in view of the NRC findings identified
during this EQ inspection the scope of the licensee's quality
assurance activities may not be adequate.
(2)
The NRC inspectors also reviewed the licensee's staff training
program and associated records relative to the performance
of EQ activities. The training records indicated that the
licensee had implemented a formal EQ training program for
newly hired personnel; however, there was no evidence that
other appropriate staff (management, operations and maintenance)
responsible for EQ activities had received this training.
In
addition, the inspectors were concerned that the deficiencies
identified in the implementation of maintenance activities
(as noted in Section 4c of this report) were a result of
inadequate training of appropriate personnel. The licensee
has agreed to incorporate EQ training into an ongoing training
program for appropriate plant personnel.
Pending further review of the licensee's QA and training activities in
regard to EQ this is considered an Open item (No. 456/88005-03(DRS);
No. 50-457/88006-03(DRS)).
5.
Detailed Review of Qualification Files
The licensee qualified their EQ equipment to the requirements of
NUREG 0588, Category 1 (10 CFR 50.49, Paragraph K).
The inspectors
reviewed over 40 equipment qualification files for evidence of the
environmental qualification of equipment within the scope of 10 CFR 50.49,
and evidence of equipment qualification to NUREG 0588, Category I.
Files
addressed the description of the equipment; similarity analysis of tested
equipment to that installed in the plant; allowed mounting methods and
orientation; qualification of interfaces (conduit, housing, seal, etc.);
evaluation of aging effects on equipment; description of test sequence
and methodology; environmental conditions for the equipment during an
accident; qualification for submergence of applicable equipment;
resolution of test anomalies; and maintenance /surveiilance criteria for
the preservation of the qualified status of equipment.
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The inspectors selectively reviewed the above areas, as applicable,
including special reviews for the required duration of operability of
equipment; licensee evaluation of tested materials and configurations
relative to actual plant installations; adequacy of test conditions;
aging calculations for qualified life and replacement intervals; effects
of decreases in insulation resistance on equipment performance; adequacy
of demonstrated accuracy of equipment and interfaces during an accident;
and licensee evaluations of discrepancies identified in IE Notices and
Bulletins.
EQ files were reviewed for electrical cables, cable splices, terminations,
terminal blocks, electric motors, solenoid valves, electrical penetrations,
seals, lubricants, transmitters, temperature elements, radiation monitors,
control and position switches, switchgear, control panels and miscellaneous
electrical devices.
The inspectors identified several deficiencies in the
adequacy of the test documentation. Details are noted below.
a.
Bunker Ramo Electrical Penetration Assemblies, File EQ-BB-058
The inspectors reviewed the following reports contained in the EQ
file for the qualification of low voltage Bunker Ramo electrical
assemblies to the requirements of NUREG 0588, Category I.
Amphenol Report 123-2220, "Design Qualification Report for
Electrical Penetration Assemblies," Revision 4, October 10,
1979.
Amphenol Report 123-2159, "Qualification Test Procedure for
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Nuclear Power Generating Station Electrical Penetration
Assemblies," June 1, 1979.
The licensee confirmed that 10 CFR 50.49 designated Bunker Ramo
penetrations were used in Braidwood Unit 2 for instrumentation
circuits inside the containment.
The Amphenol test report 123-2220 addressed a generic qualification
of several models of Bunker Ramo penetrations but did not test a
penetration identical to that installed at Braidwood.
During the
EQ file review, the inspectors observed that significantly low
insulation resistance (IR) readings were recorded during the LOCA
test on the instrumentation penetrations. Of (81) measurements
taken only (14) were at the design minimum value of 106 ohms or
higher.
The licensee identified these low readings as "anomalies,"
and claimed that the suspected anomalies were due to terminal blocks
used in the tested configuration.
The licensee also stated that
these anomalies had been corrected by installing qualified splices
instead of terminal blocks in the plant. The inspectors, however,
noted that the licensee had not confirmed through additional testing
whether the low IR values had in fact been corrected by the installed
qualified splices.
NUREG 0588, Category I, Section 2.1(3)(a), requires equipment to be
qualified by test to demonstrate its operability under harsh
conditions. NUREG 0588, Category I, Section 2.2(a) requires that
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the failure criteria be established prior to testing.
The inspectors
concluded that the licensee had not performed a test to qualify the
instrument penetrations in their installed configurations (with the
splices).
The inspectors also noted that the Bunker Ramo test was
inadequate in that no failure criterion had been established for the
LOCA portion of the testing.
The inspectors concluded that the
penetrations were unqualified based on inadequate documentation.
Subsequent to this NRC finding, the licensee identified four suspect
Bunker Ramo instrument penetrations (2S105E, 2S106E, 2S107E and 2S108E)
installed at Braidwood Unit 2.
None were reported in Unit 1.
The
specific instruments associated with these circuits provide necessary
inputs to the Reactor Protection System (RPS) and Engineering Safety
Features (ESF) actuation systems.
Some instruments also provide post
accident monitoring functions.
The affected instruments are required to mitigate a LOCA, main
feedwater line break, and a main steam line break in the resulting
harsh environments.
Parameters measured by the instruments for RPS
and ESF actuation include hot leg and cold leg temperature, reactor
coolant loop hot leg wide range temperature, reactor coolant loop
flow, steain generator loop steam flow, steam generator narrow and
wide range level, pressurizer pressure, pressurizer level, hot' leg
wide range pressure, reactor coolant pump bearing water flow, source
and intermediate range neutron detection, and power range neutron
l
detection.
The inspectors informed the licensee of the need to follow the
requirements of Generic Letter 88-07 and submit an operability analysis,
or retest the suspect penetrations, or replace the penetrations. On
March 5,1988, the licensee submitted an operability analysis to the
NRC.
Subsequent to the Rill findings, NRR assumed the lead responsi-
bility for reviewing the qualification of the Bunker Ramo penetrations.
Pending further NRC review this is a Potentially Enforceable Unresolved
Item (No. 456/88005-04(DRS); No. 457/88006-04(DRS)).
b.
Joy / Reliance Fan Motors, Model 500826-2047, EQ Binder EQ-88-009
The EQ file stated that the motor bearings were qualified for 40 years.
The Reliance report, NUC-12, dated October 30, 1978 (in the licensee's
EQ file), however, stated that according to the Antifriction Bearing
Manufacturers Association (AFBMA) Standard No. 9, bearings of motors
cannot have a specific qualified life.
In addition, Reliance Electric
(vendor) recommended that the bearings be treated as a replaceable
element.
The licensee was requested to provide documentation to
support their claim that the motor bearing were qualified for 40 years.
Subsequent to this concern, the licensee provided a calculation
supporting a motor bearing life of 40 years. The calculation, Sargent
and Lundy document CQD-010212 dated August 31, 1978 is to be added to
the EQ file.
Pending review of revised files, this is considered an
Open Item (No. 456/88005-05(DRS); No. 457/88006-05(DRS)).
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c.
Target Rock Solenoid Valves Model 79AB-010, EQ Binder EQ-BB-HE10A
Review of this file indicated that the qualified life calculations
for the solenoid valves were based en : normal maximum temperature
of 122 F.
The valves, however, are located in a zone where the
maximum temperature is expected to reach 130 F.
Subsequent to this
concern, the licensee produced a calculation by Sargent and Lundy
(transmittal C00-037264, dated September 9, 1987) which used the
correct temperature data basis and adjusted the qualification life.
The licensee indicated that the calculation is still awaiting final
approval.
The maintenance data sheet in the EQ binders will also
be changed to reflect the correct qualified life and replacement
schedule.
Pending further review, this is considered an Open Item
-
(No. 456/88005-06(DRS); No. 457/88006-06(DRS)).
d.
ITT Barton Model 752 Transmitters, EQ Binder EQDP-ESE-4A
The inspectors noted that the "auditable link" document for the
qualification of the Barton transmitters provided by Westinghouse
was not included in the EQ file.
The licensee comitted to
incorporate this document into the next revision of EQ Binder
EQDP-ESE-4A.
The inspectors also noted that no thermal aging analysis or raaiation
analysis had been provided in the binder - merely a statement that
the five year qualified life would be verified. The licensee stated
i
that the radiation analysis is provided in Westinghouse WCAP-8587,
and that this document has been reviewed and accepted by the NRC.
The
licensee agreed to include the aging analysis in the qualification
binder when it is revised.
Pending NRC review of licensee corrective
action of both the above issues, this is an Open Item
(No. 456/88005-0/(DRS); No. 457/88006-0/(DRS)).
e.
General Atomic Area Radiation Monitors EQ Binder, EQ-BB-060
The inspectors observed that no documentation had been provided for
the qualification of the Tefzel insulation (Tab C), in that the
referenced reports (0konite and Clinton) were not in the binder.
The
inspector concluded that the similarity between the detector wiring
and tested wiring had not been established. The licensee stated that
the referenced documents would be included in the next revision of
the binder to establish similarity.
Sufficient interim information
4
was provided by the licensee to mitigate any immediate safety concerns.
The inspectors also observed that no qualification documentation had
been provided in the binder for the penetration connector interface,
in that the the connector has not been properly identified or analyzed.
The licensee stated that since the subject device did not have to be
functional during LOCA or post LOCA conditions, the qualification of
the connector was not of concern, and that the adequacy of the cable
assembly and the connector would be verified during calibration for
normal operation.
The licensee agreed that the connector will be
,
identified in the next revision of the binder.
.
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1
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, ,
m,.,,,_,_,..w~_
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Pending further review of licensee corrective action of both of the
above issues, this is an Open Item (No. 456/88005-08(DRS);
No. 457/88006-08(ORS)).
6.
Plant Physical Inspection
The NRC inspectors selected over 50 items.on the MEL for examination in
the plant.
The EQ file of each item had been reviewed, and information
regarding the location, manufacturer, model/ serial number, mounting,
orientation, environment, and interfaces had been noted.
The-inspectors
examined the selected items in the field, as accessible, and examined
each item to confirm if it conformed to its environmental qualification.
Specific areas reviewed included traceability of installed items to
EQ files, ambient environmental conditions, qualification of interfaces
(connectors, wires, seals, insulation, lubricants, etc.), evidence of
significant temperature rise from process, drainage, mounting methods,
physical conditions, and housekeeping. Certain significant deficiencies
were identified in regard to EQ equipment not being qualified by test or
analysis for their installed configuration.
Details are noted below:
a.
Marathon 1600 NUC Terminal Blocks
The Marathon terminal blocks were addressed by the licensee as
qualified to the requirements of NUREG 0588, Category I.
These
blocks are used in control circuits inside the containment. During
the EQ test conducted at Wyle, terminal blocks located directly
beneath the top-entry conduits were observed to experience higher
leakage currents (300 MA) than the block not directly below the top
conduit entry (30 MA). In order to address this deficiency, the
licensee required drip shields and weep holes to be provided for all
Marathon terminal blocks located directly below top entry conduits
and in a steam environment.
Subsequent to NRC inspector findings in the area of maintenance and
surveillance (see Section 4c of this report), the licensee conducted
an onsite review (OSR) of EQ equipment. During this review, the
.
licensee examined all (40) EQ designated junction boxes inside the
,
containment. Of the boxes inspected (16) weep holes and (8) drip
shields were found missing.
4
The inspectors determined that the lack of weep holes and drip shields
'
compromised the EQ of the circaits in the boxes, in that spray and/or
moisture intrusion into the boxes would cause the circuits to fail.
The licensee has subsequently performed corrective action and reported
that no other junction boxes were affected.
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Enforceable Unresolved
Pending further review, this is a Potentially(DRS)).
Item (No. 456/88005-09(DRS); No. 457/88006-09
b.
GEC0 Pressure Switches
,
EQ binders BB-025, 56 and 57 specify Whitman General Pressure switches,
Models 86819, 88739, 88743, 88946, 86915, 88736 as qualified for use
in the borg Warner Actuators.
During the OSR, the licensee identified
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the use of a pressure switch, Model J505, made by GEC0 and installed
in conjunction with several EQ salves in the plant. Subsequent to
this finding, the licensee reported that they did not have sufricient
data to qualify the J505 GEC0 switch for its EQ application in the
plant.
The licensee identified the use of several of these switches in
conjunction with the feedwater isolation valves, containment purge
isolation valves, and steam generator power operated relief valves.
The licensee has subsequently replaced the switches for the feedwater
isolation valves, and has submitted an adequate operability analysis
,
for the switches associated with the containment purge and steam
'
generator power operated valves.
The remaining switches will be
replaced or qualified by the next outage.
Pending further review,
this is considered a Potentially Enforceable Unresolved Item
(No. 456/88005-10(DRS); No. 457/88006-10(DRS)).
c.
Mixed Lubricants in Limitorgae Operators
During review of the licensee's maintenance activities (see Section 4c
of thir. report), the NRC inspectors identified deficiencies in the
frequency of lubricant surveillance / replacement in EQ actuators, motors
and fans.
Subsequent to these NRC findings, the licensee performed an
onsite review to examine the installed lubricants to determine if any
degradation had occurred since they were last replaced.
Based on this
review, the licensee reported mixed proportions of a Calcium based and
a Lithium base lubricant in several EQ actuators.
The mixed proportions
were reported to range from 2% Lithium /98% Calcium to 50% Lithium /50%
Calcium based lubricants in different actuators.
These lubricants are
stated by the licensee to be Exxon Nebula EP-0, Exxon Nebula EP-1
(Calcium complex base) and Sun EP-50 (Lead Lithium base). Tho licensee,
horover, could not present adequate test data or analysis based on
the test data to demonstrate that the mixed greases were qualified
for the postulated ambient plus accident environments.
Region III
subsequently informed the licensee that the affected 10 CFR 50.49
designated valve actuators were unqualified based on inadequate
documentation.
The licensee performed the following corrective actions:
'1)
Sampling of (222) potentially affected 10 CFR 50.49 designated
Limitorque actuators. Sampling included drawing samples from
the Limitorque main gear cases as accessible.
These samples
were then reported to be reviewed visually for quality (dirt,
water, metal filings) and for consistency.
If visual inconsis-
tencies were found, the lubricant was reported to be replaced.
(2) All drawn samples then underwent a chemical analysis so as to
identify any mixed greases. Any sample having a mixture of
over 1:50 Lithium to Calcium was subjected to a penetration
test. Any lubricant having a mixture of 1:50 or less Lithium
to Calcium was declared acceptable by the licensee.
(3) The proposed penetration test was conducted with an acceptance
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range of 130 points above or below an acceptance median of
325 points for Exxon Nebula EP-1 and 370 points for Exxon
Nebula EP-0.
Any sample having a Calcium / Lithium mixture with
a. Lithium contaminant of over 5% will be rejected, and the
affected valve will be regreased prior to plant startup.
Samples having a contaminant of 2 to 5% will be replaced in
Unit 2 prior to criticality. Samples having a contaminant of
2 to 5% in Unit 1 will also be subsequently replaced during the
next outage. Samples having a containment of up to 2% is being
considered acceptable by the licensee.
Subsequent to the Region III findings, NRR assumed the lead in
reviewing the qualification and operability of the affected Limitorque
operators in regard to mixed lubricants.
Pending further NRC review,
this is a Potenticily Enforceable Unresolved Item (No. 456/88005-11(ORS);-
No. 457/88006-11(DRS)).
d.
General Atomic Radiation Monitor
During examination of the General Atomic high range radiation monitor
assembly, a split (crack) was noted on one Raychea heat shrink tube
insulating a coaxial connector. The inspectors were concerned that
this deficiency would increase leakage currents and affect the
accuracy of the monitor.
The licensee's response stated that this was an isolated deficiency
and that NWR A20577 had been written for replacement of the tubing.
They also agreed to check both high range monitors for any other
such deficiency. Pending further review of licensee action in
this area, this is considered an Open Item (No. 456/88005-12(DRS);
No.457/88006-12(DRS)).
e.
Tobar Pressure Transmitters
Tobar transmitter 2PT-403 was found in the field to have one loose
I
cover bolt.
This pressure transmitter was calibrated on February 25,
1988. Subsequent to the finding, the licensee took corrective action
and confirmed that the cover screw was tightened as required per
NWR A20549 on March 3, 1988.
The inspectors also noted that the nameplate on Tobar Transmitter
2PT-407 indicated Model No. 32PA1212/94002/1.A2, while the SCEW
l
sheet indicated 76PH24-333/94002. The licensee resoonded that both
models were identical, even though the model (76PH2) shown on the
SCEW sheets was that of a Veritrak transmitter and the model
(No. 32PA1) shown on the nameplate of 2PT-407 was that of a Tobar
transmitter. Apparently after Veritrak was acquired by Tobar, this
model was re-designated as model No. 32PA1 (by Tobar). The licensee
agreed to revise the SCEW sheets to eliminate this concern.
No further concerns were identified.
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f.
Limitorque Actuator 2CC-9438
During examination of this actuator in the field, the inspectors
noted that a shipping cap was installed in the grease relief valve.
The licensee apparently had not looked for shipping caps installed
inside the grease relief valves during previous inspections. Another
inspection was performed by the licensee for all Limitorque operators
inside the containment and the licensee identified no additional
shipping caps installed inside the grease relief valves. The licensee
subsequently issued a maintenance work order to remove the cap.
No further concerns were identified,
g.
Bunker Ramo Electrical Penetration Assembly
Two 3-lb coffee cans filled with a white granular substance were
found inside the penetration junction box assembly for penetration
21C19E.
The licensee was not able to provide information on the
purpose of these cans or identify the substance.
The cans have
subsequently been removed.
No further concerns were identified.
h.
ASCO NP Series Solenoid Valves
During the plant walkdown of ASCO valve 2IA066-FSV (plant
identification number), it was noted that an associated valve
was tagged 1A0V-IA066, while it should have been tagged 2A0V-IA066.
The licensee subsequently corrected the tag.
No further concerns
were identified.
7.
Open Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involve some action
on the part of the NRC or licensee or both. Open Items disclosed during
this inspection are discussed in Paragraphs 4e, 5b, Sc, 5d, Se, and 6d.
l
8.
Potentially Enforceable / Unresolved Items
An unresolved item is a matter about which more information is required
in order to ascertain whether it is an acceptable item, an open item, a
discussed in Paragraphs 2, 4c(1)(2)(3)y Enforceable / Unresolved Items are
deviation, or a violation.
Potentiall (4)(5)(6)(7)(8)(9)(10),Sa,6a,6b,
and 6c.
9.
Exit interview
The Region III inspectors met with the licensee's representatives
(denoted under Paragraph 1) during an interim exit on March 4,1988,
and discussed their findings at the conclusion of the inspection on
May 4, 1988.
The inspectors discussed the likely content of the
inspection report with regard to document or processes reviewed by
the inspectors. The licensee did not identify any such documents
or processes as proprietary.
18