ML20205T098

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Forwards First Round Special Team Insp Rept 50-298/86-28 on 861103-07.Nine Deficiencies Re Program Implementation, Involving Equipment Qualification Documentation Files Noted in Encl Notice of Potential Enforcement/Unresolved Items
ML20205T098
Person / Time
Site: Cooper Entergy icon.png
Issue date: 04/01/1987
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Trevors G
NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20205T102 List:
References
TAC-42486, TAC-68378, NUDOCS 8704070212
Download: ML20205T098 (5)


See also: IR 05000298/1986028

Text

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In Reply Refer To:

Docket: 50-298/86-28

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Nebraska Public Power District

ATTN: George A. Treurs

Division Manager - Nuclear Support

P. O. Box 499

Columbus, NE 68601

SUBJECT: EQUIPMENT QUALIFICATION (EQ) INSPECTION - COOPER NUCLEAR STATION

INSPECTION REPORT 50-298/86-28

This refers to the first round special team inspection to review compliance

with 10 CFR 50.49, of activities authorized by License No. DPR-46, conducted by

Mr. A. R. Johnson and other NRC representatives on November 3-7, 1986, at the

Cooper Nuclear Station. The team's findings were discussed with you and

members of your staff at the conclusion of the inspection.

Areas examined during the inspection included your implementation of a program

for establishing and maintaining the qualification of electric equipment within

the scope of 10 CFR 50.49. The inspection also included evaluations of the

implementation of EQ corrective action commitments made as a result of

identified deficiencies of (1) the January 30, 1985 Safety Evaluation

Report (SER); (2) the December 9, 1982 SER and November 24, 1982 Franklin

Research Center Technical Evaluation Report (TER) enclosed with it; and

(3) ycur proposed n,ethod of resolution for each of these EQ deficiencies

documented in Nebraska Public Power District's (NPPD) response letter to NRC of

April 24, 1984, regarding the March 29, 1984 meeting between NPPD and NRC.

Within these areas, the inspection consisted of the examination of selected

procedures and records, interviews with personnel, and observations by the NRC

inspectors. The inspection findings are documented in the enclosed inspection

report.

The inspection determined that you have implemented a program to meet the

requirements of 10 CFR 50.49. Nine deficiencies with respect to your program

implementation, involving EQ documentation files and physically installed

configurations of equipment in your plant, are sumarized in Appendix A and are

classified as Potential Enforcement / Unresolved items requiring further action.

The nine Potential Enforcement / Unresolved Items represent failures to fully

establish the qualification of the following equipment: Boston Insulated Wire

(Bostrad 7E and Coaxial RG59B/4) cable, Kerite HTK/FR 600V cable, Raychem

(Rayolin R and F) coaxial cable, General Electric electrical penetrations.

Limitorque motor operators (SMB Series) Okonite motor lead splices, and Fenwal

temperature switches. Nineteen concerns are classified as Open items and a

future NRC inspection will review or ctions concerning.them.

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i Your corrective actions regarding the identified deficiencies in the enclosed

inspection report should not be delayed pending a future NRC Region IV

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Sincerely,

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J. E. GAGUARDO

J. E. Gagliardo, Chief

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I Enclosures:

1. Appendix A - Potential Enforcement Unresolved Items

j 2. Appendix B - NRC Inspection Report

i 50-298/86-28

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i Guy Horn Division Manager

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of Nuclear Operations ,

1 Cooper Nuclear Station

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P. O. Box 98

Brownville, Nebraska 68321

Kansas Radiation Control Program Director

Nebraska Radiation Control Program Director

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APPENDIX A

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Potential Enforcement / Unresolved Items

As a result of the special equipment qualification (EQ) inspection of

November 3-7, 1986, the following items have been identified by Region IV as

Potential Enforcement / Unresolved Items (paragraph references are to the

detailed portions of the inspection report).

1. Contrarytoparagraphs(f)and(k)of10CFR50.49andSection5.2.5of

the D0R Guidelines, the EQ documentation files (EQF) for (1) Boston

Insulated Wire (BIW) cable, type Bostrad 7E, EQ Data Package (EQDP) No. 6,

did not adequately demonstrate qualification because of failure to show

that the equipment functional performance requirements were satisfied.

The analysis used a 20 foot length of cable from the supporting type test,

rather than the fully installed cable length (including considerations

given to splices and penetrations in the cable runs), of the installed

configuration at the CNS plant (paragraph 4.f(1), 50-298/8628-01).

2. Contrary to paragraphs (f) and (j) of 10 CFR 50.49, the EQF for BIW

coaxial cable, type RG 59 B/4, EQDP No. 6A, did not document and

demonstrate qualification in that BIW test report No. 76J049 was not

auditable to permit verification that this item is qualified for its

application. The documented test report was incomplete, consisted of

only a single page summary, and was not traceable to permit independent

verification of conclusions (paragraph 4.f(2), 50-298/8628-02).

3. Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.5 of

the D0R Guidelines, the EQF for Kerite 600 volt cable, type HTK/FR, EQDP

No.5,didnotadequatelysupportqualificationinthat(1)thedocumented

test results did not meet the acceptance criteria of adequate insulation

resistance during DBE testing; and (2) numerous failures during the post

DDEhighpottestoccurred(paragraph 4.f(3),50-298/8628-03).

4. Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.2 of

the 00R Guidelines, the EQF for Raychem Coaxial Cable, type Rayolin R and

Rayolin F, XLPE, EQDP No. 4, did not adequately demonstrate qualification

because of failure to demonstrate similarity between the tested and

installed cables. The claim for material similarity in the analysis is

unclear (paragraph 4.f.(5),50-298/8628-04).

5. Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.2 of

the 00R Guidelines, the EQF for General Electric (GE) electrical power and i

control penetrations, type 238X600NSG1, EQDP No. 8, did not adequately '

establish qualification because of failure to demonstrate similarity

between the tested and installed ccirponents. The analysis in the EQDP was

inadequate in that no link between the test results and the installed i

electrical penetrations F01-NS02, F01-NS03, and F01-NSO4 at CNS, was '

available(paragraph 4.f.(6),50-298/8628-05).

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6. Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.6. of

the D0R Guidelines, the EQF for various pressure / level switches and

transmitters contained in EQDP No's. 12, 13, 36, 37, 49, 76, 81, 217, 222,

and 228, did not adequately establish qualification because the equipment

documentation failed to address mounting, orientation, and interface

requirements. From the EQF, it could not be verified that the equipment

in the CNS as-built configuration was installed as tested

(paragraph 4.f.(7), 50-298/8628-06).

7. Contrary to (f) and (k) of 10 CFR 50.49, and Section 5.1 of the D0R

Guidelines, the EQF for Fenwal/Patel temperature switches, Model

No. 01-170230-090, EQDP No. 220A, did not adequately establish

qualification because of failure to base the qualification of the

interfacing cable splices on full accident conditions including service

life for radiation and aging effects. The T&B STA-KON fricti7n cr"ged

splices were qualified for steam testing only (paragraph 4.f(8),

50-289/8628-07).

8. Contrary to paragraphs (f) and (k) of 10 CFR 50.49, and Sections 4.3, 5.1,

and 5.2 of the D0R Guidelines, the EQF for 25 Limitorque motor operators,

model SMB series, did not adequately establish qualification as follows:

a. No supporting analysis was available in the EQF to address the HELB

accident conditions in which glass braided butyl rubber

(polybutadiene) insulated, internal jumper wire, was used.

b. No documentation was available in the EQF, to substantiate (by test

results or other laboratory methods) the similarity of material

construction of the internal wiring reported to the NRC by the

licensee in their equipment operational analysis (E0A) Attachment B

which correlated like wiring removed from similar equipment at CNS.

c. No qualification analysis and test reports were available in the EQF

to support qualification of Scotch taped cable splices, and

unidentified blind barrel cable splices, in eight Limitorque motor

operators.

In the above items a., b., and c., the licensee failed to demonstrate

similarity between the tested motor operator configuration and the

installed configurations with regard to materials of construction

(paragraph 4.g, 50-298/8628-08).

9. Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and Section 5.2.2 of

the D0R Guidelines, the EQF for Limitorque motor operator, Series SMB,

particularly Okonite motor lead splices, found in EQDP No. 31A (B0003 ,

qualification series), did not adequately establish qualification because  !

of failure to demonstrate similarity between the splice type tested and

those installed in motor operators at the CNS plant. No evidence was l

contained in the EQF which could demonstrate qualification of Okonite

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splice installations over braided jacket motor leads. The EQDP in the EQF

only demonstrates Okonite motor lead splice testing over unjacketed

insulated cable (paragraph 4.h(1)(a), 50-298/8628-09).

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