ML20205N317
| ML20205N317 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1986 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8605020089 | |
| Download: ML20205N317 (5) | |
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UNITED STATES
' NUCLEAR REGULATORY COMMISSION -
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y j; S REGION lli f
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g GLEN ELLYN, ILUNOIS 60 M 7 APR 2 8 1986 MEMORANDUM FOR: Resident Inspectors, Region III FROM:
Charles E. Norelius, Director, Division of Reactor Projects
SUBJECT:
TEMPORARY INSTRUCTION (TI) 2515/75-INSPECTION OF LIMITORQUE MOTOR VALVE OPERATOR WIRING TO DETERMINE IF WIRING IS ENVIRONMENTALLY QUALIFIED On March 27, 1986, I sent you a request for information relative to IE Information Notice 86-03. Attached to this request was a memo dated February 20, 1986 from Carl J. Paperiello, Director, DRSS, for information on the same subject. Subsequent to that time I.E has issued TI 2515/75 which provides guidance for the inspection of Limitorque Motor Valve Operator Internal Wiring.
I am requesting that you perform the inspection defined in the guidance by June 25, 1986 and document the results of that inspection in a standard inspection report. A copy of the inspection report that addressed this item should be provided to the Technical Support Staff by July 31, 1986.
They will compile all the reports together and forward them to the Office of Inspection and Enforcement, Vendor Program Branch.
Should you have any questions on the technical 1 of this request please contact A. S. Gautam or R. F. Westberg of the n of Reactor Safety.
Time spent on this request should be charged ti.
. 92701.
(&k 5..;. --
Charles E. Norelius, Director Division of Reactor Projects
Attachment:
TI 2515/75 cc w/o attachment:
A. B. Davis, RIII C. J. Paperiello, RIII W. G. Guldemond, RIII W. S. Little, RIII R.' F. Warnick, RIII A. S. Gautam, RIII R. A. Westberg, RIII G. G. Zech, IE U. Potapovs, IE Section Chiefs, DRP 8605020089 860428 PDR I&E GENERAL PDR l
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UNfTED STATES
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NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 5
Washington, D.C. 20EEE
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INSPECTION AND ENFORCEMENT MANUAL gavT TEMPORARY INSTRUCTION 2515/75 INSPECTION OF LIMITORQUE IWTOR VALVE OPERATOR 2
..., WIRING TO DETERMINE IF WIRING IS ENVIRDISENTALLY-QuhLIFIED.
r u-y s
2515/75-01 PURPOSE
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To provide guidance for the inspection of Limitorque motor valve operator internal wiring to determine if licensees (1) have adequately established environmental qualification of the wiring in accordance with the rcquirements of 10 CFR 50.49 and (2) have adequately addressed the concerns of IE Information Notice (IN) 86-03, Potential Deficiencies In Environmental Qualification of Limitorque Motor Valve Operator Wiring."
2515/75-02 OBJECTIVES Physical inspection of Limitorque operator wiring to determine what wiring is actually installed in the operators.
Review of licensee's environmental qualification documentation to ensure qualification of wiring is adequately established.
Review of licensee's action relative to IN 86-03.
2515/75-03 BACKGROUND On September 30, 1985, Commonwealth Edison (Zion Generating Station) reported to the NRC that it had discovered four Limitorque operators with jumper wires different from those tested by Limitorque in its environmental qualification program.
Subsequently, the Tennessee Valley Authority (TVA) notified the NRC that the manufacturer of the internal wiring of its Limitorque operators at Sequoyah Nuclear Plant either could not be identified or qualification could not be established where the manufacturer was known.
Similar circumstances were identified at other nuclear plants.
On the basis of these occurrences and information obtained during NRC inspections, IN 86-03 was issued on January 14, 1986.
2515/75-04 REFERENCES 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," ef f ective February 22, 1983.
s Issue Date:
03/27/86
Regulatsry Guide 1.89, " Environmental Qualification cf Certain Equipner,t Important to Safety for Nuclear Power Plants," Revision 1.
m NUREG 0588, (for Comments Version), " Interim Staff Position on Environnen Qualification of Safety-Related Equipment," July 1981.
" Guidelines for Evaluating Environmental Qualification of ' Class IE Electrical Equipment in Operating Reactors," November 1979.(00R Guideline,s).
.IE _Jnfornation jtlotice _83-72...J" Environmental. Qualification J' osMag..
o Experience,"
Equipment Environmental Qualification Sotice
'90.
14, 1983.
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Dctober 28,f.a w h...
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Deficiencies 4n ~Environmen' W.
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IE 1nformation 16citice :86-03, Fotendal Qualifitation.ef Limitorque'. Motor Valve, Operator. Wiring," January J4A. _ y g
1986.
' -WS@ Mh? -
E F-Licensee qualification documentation and/or files.
~.t.Q Generic Letter 84-24, 'DJ G. Eisenhut to All Licensees of' Operating Reactors and Applicants for An Operating License, dated December 27, 1984,
Subject:
Certification of Compliance to 10 CFR 50.49.
L. Thompson to All Licensees of Operating Reac-tors, dated August 6,1985,
Subject:
Infomation Relating to the Dead-lines for Compliance with 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants."
10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear
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Power Reactors."
10 CFR 50.73, " Licensee Event Report System."
2515/75-05 GENERAL INFORMATION i
temporary instruction should be performed by appropriate regional This inspectors at each nuclear plant site during the next regional inspection While or within 90 days of the issue date of this temporary instruction.
this instruction is specifically established for inspecting operating plants, it also should be performed on plants under construction.
2515/75-06 INSPECTION REQUIREMENTS 06.01 Determination of Installed Wires To determine what wires are installed in a plant's Limitorque operators, the inspector should identify from the licensee's 10 CFR 50.49 List how many operators are installed in safety-related electric systems and harsh at each plant site.
After this number is established the environments inspector should then select a sampling (covering all units at a site) of at least 10 percent of the operators or a minimum of at least four operators per unit for use in determining what wires are actually installed in the operators.
At this time, the inspector should determine also wheth-Issue Date:
03/27/86 2515/74
cr the lic';nsee has plant walkdown cheets that identify the operator wir-(
ing or if a physical inspection of equipment is necessary to identify operator wiring.
It is suggested that even if the licensee.does.have detailed walkdown sheets, the validity of the sheets should be verified for at least two of the selected operators per unit.
In selecting samples for physical identificatrion of wiring, the inspector should consider the physical location and accessibility of the operator because this inspection will require the removal of limit / torque switch compartment covers.
The inspector should try to. include some samples 4inside containment if possi-
.ble; however, this inspection effort is not. intended to disrupt plant
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-eperation..
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-r e v,e.e The inspec. tor should determine.by physical dnspection and/oryeview of -
walkdown sheets what wires are.actually 4mstalled in each of:1tesample operators.. Jame slres 1.n the. operators W-eot have identificati.or) en them'.*lnThese rases, the ~ inspector should observe.whether' the E1 ret ~2re' '
'similar in-appearance to other wires that are identified by markinOs.
If 1.hese trires geo-appear similar,'it'.is -
Je Me -assame.that $he ytres 7
are.the same. - If the - wires ;do.not appear.
.same, the.erires should De considered unidentified.and unqualified unless the licensee. can'4 den.tify them through documentation from a controlled installation program.
06.02 Review of Qualification Documentation 8
When the inspector has identified the wiring for the sample operators located in a harsh environment, the inspector should review the licensee's documentation to determine whether it adequately establishes qualification of the operator wiring for the level of qualification required (refer to 10 CFR 50.49 and DDR Guidelines).
For the wiring to be qualified, the licensee must document that similar or identical wiring has been aged to the installed wire's qualified life and exposed to design-basis event (DBE) testing to demonstrate that it will survive the DBE.
The licensee must document that wires for operators qualified to DDR Guideline requirements have had the same or similar wires tested to plant DBE conditions.
The licensee also must provide an analy-sis of aging considerations to establish the qualified life of these wires.
The inspector snould be aware that wiring qualification tests may be per-formed separately or in conjunction with valve operator qualification test-ing.
If wiring is qualified by separate testing, the licensee's document-ation should ensure that the test environments encompass valve operator plant environrnents.
If the inspector determines that the licensee's documentation for valve operator qualification does not address the issue of operator wiring l
qualification but that the licensee has other documentation that would support qualification of the wiring used in the operators, the inspector should advise the licensee to address this information in the operator qualification documentation.
In such a case, the inspector should consider this issue an open item that the licensee needs to correct.
If the inspector determines that wiring qualification of all operator wir-ing is not established, the inspector should follow the guidance of section 7 of this temporary instruction.
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2515/75 Issue Date:
03/27/86
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.I T
06.03 Licensee's Action en IN 96-03 -*
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's As a part of this inspection,c the lmspector also should feview -the licensee's actions relative to IN 96-03 and assure that the 11censee has
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taken appropriate action.
Guidance for this activity is provided in IE Inspection Procedure 9270}, " Followup," dated November 18, 1985.
2515/75-07 GUIDANCE WHEN WIRING 15 SETERMINED UNQUALIFIED
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, If the licensee does not have deceanMien to estabitsh qualift
.its operator wiring er the wirt
.can-Q be identified, the epgra 4
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I considered 14o be not 4qualifled.t
liennteels V ante J
- Miel-4etermination 1ispuhether.M%spotstaimet.
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10 CFR ;50.73 are -epp11 cable -MIP3MDe.111e~ an3ppnWYlete.
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ilicensee 4s:also expected teidnhvelneitperability.Mme Monasse a t W e-;
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i tempt Jto make a fiading: of Juperability';ms'ing snalpsis wind!-part.14 t..
1 data' to provide reasonable assurance 5that the equipahnt Wilt its. :.c bafety function when-called W44 )titigate the'.acciden'tsW t Ds V.
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needed.: 'In this connection,"18t"mu'sFDe shown t. hat'tdseituent TaileTre W "
the equipment under accident conditions 'will notiresult in~ significant l
degradation of any safety function or provide mi:, leading information to the operator.
If the licensee is unable to demonstrate operability:
For inoperable equipment included in systems covered by plant tech-1 a.
nical specifications, the licensee bears the burden of demonstrating j
that the appropriate action statement is followed which could require the plant to shutdown within a limited period of time (or iemain shut down).
b.
For inoperable equipment not covered by the plant technical specifi-
- cations,
'.M licensee may continue reactor operation:
(1) If the safety function can be accomplished by other designated equipment that is qualified, or (2) If limited administrative controls can be used to ensure that the equipment performs its safety function.
2515n5-08 REPORTING REQUIREMENTS The inspector is responsible for the timely assembly and generation of the inspection report.
The esults of the inspection will be documented in a standard inspection report.
A copy of the report shall be forwarded to the Office of Inspection and Enforcement, Vendor Program Branch.
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2515R5-09 EXPIRATION DATE This temporary instruction shall remain in effect for 1 year from the date of issue.
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2515n5-10 IE CONTACT l
G. T. Hubbard (492-9759)
END I99 R Date:
03/27/86 2515/75