ML20213D735

Forwards Info Re Potential Enforcement/Unresolved Items Identified in Insp of Environ Qualification Program on 860811-15.Summary of Util Position on Each Item Presented

ML20213D735
Person / Time
Site:	Salem
Issue date:	11/07/1986
From:	Corbin McNeil Public Service Enterprise Group
To:	Grimes B, Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
IEIN-84-44, IEIN-84-49, NLR-N86150, NUDOCS 8611120210
Download: ML20213D735 (7)

Text

-.

Pubhc Service Electric and Gas Company

' Corbin A. McNeill, Jr. Public Service Electric and Gas Company P.O. 6cx 236, Hancocks Bridge.NJ 08038 609339-4800 Vice President-Nuclear November 7, 1966 NLn-!,86]SO Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Brian K. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Program Gentlemen:

ENVIRONMENTAL QUALIFICATION INSPECTION SALEM CENERATING STATION DOCKET NOS. 50-272 AND 50-311 As a.. result of the recent inspection of the Environmental Quall'fication program at the Salen Generating Station during the week of August 11-15, 1986, five (5) Potential Enforcement / Unresolved Items were identified. Public Service Electric and Gas Company (PSE&G; believes that the equipment referenced in 4 of these items was appropriately qualified in accordance with 10 CFR 50.49 requirements. A sumnary of our position on each of these items is presented in Attachment A.

Attachment B (1-3) presents additional detail.

We ask that you review the attached information and provide un with the results of that review. Your cooperation in this matter is appreciated.

Sincerely,

-+.

Attachrents 8611120210 861107 $N

{DR ADOCK 05000272 PDR di 1

L

.~ . - - . . - . _ -- .-. ..

. -Of fi'ce of Inspection arid 2 11-7-86 I Enforcement 4

~

C 'Mr. D..C. Fischer Licensing Project Manager -

i i

' M r. T. .J. Kenny

. Senior Resident Inspector ,

Mr. Uldis Potapovs

. Vendor Program Banch i

5 i

i I

I i

1 W

k i

4 i

r I

ROCKBESTOS FIREWALL III EP & COAXIAL CABLE Two potential enforcement items were identified by the NRC related to unacceptable documentation to establish qualification for Rockbestos Firewall III EP cable and Firewall III coax cable. This was based on potential concerns identified in IE Notice No. 84-49.

WE BELIEVE THESE POTENTIAL ENFORCEMENT ITEMS ARE UNWARRANTED FOR THE FOLLOWING REASONS:

Rockbestos Firewall III EP cable was not identified in the IE Notice.

-Retest of Rockbestos Firewall III coax cable completed in March 1986, reinforced the conclusions of the identified test report.

NRC inspection of San Onofre did not question the acceptability of the test reports.

The test performed during the time period in question was not used to qualify the Rockbestos Firewall III EP cable; a subsequent test was utilized.with the results on file.

All retesting has resulted in confirmation of the previous tests.

PSE&G utilized the option provided by the IE Notice to prove qualification, " perform analysis of existing reports".

Attachment A

LIMITOROUE ACTUATOR GREASE RELIEF i

A' potential enforcement item was identified by the NRC related to the absence of gear box grease ~ reliefs on Limitorque actuators located in containment.

WE BELIEVE THIS POTENTIAL ENFORCEMENT ITEM IS UNWARRANTED FOR

-THE FOLLOWING REASONS:

The Limitorque operators are not designed for absolute sealing and need not be considered for qualification.

The test anamoly where grease escaped from the actuator housing was not due to the accident conditions.

The test conditions during the anamoly simulated the less severe out-of-containment conditions, rather than the harsher containment environment.

Test performed by Limitorque indicated that even under extreme super heat conditions, the actuator internals never exceed 315'F.

Mobil grease 28 which is utilized ac Salem, has a dropping point in excess of 500*F. Appreciable expansion of the grease vould not occur until a liquid state is attained.

Attachment A nn, -s. -

,x ,-<-y,-, ,,

EXO SENSOR HYDROGEN ANALYZER A potential enforcement item was identified by the NRC t

- related'to documentation on file not supporting the Salem-10 year maintenance cycle of the pressure transducer and RTD for the Exo Sensor hydrogen analyzer.--

WE BELIEVE THIS POTENTIAL ' ENFORCEMENT -ITEM IG UNWARRANTED FOR THE FOLLOWING REASONS:

Design life was originally stated as significantly in excess of the levels required, therefore,rthe original ,

aging tests were not required to be extended past 2 years.

Rather, an 18-month surveillance was specified which would

-visually identify any degradation.  !

.Exo Sensor had, subsequent to-the original test, supplied

, documentation extending the aging analysis to 10 years.

i- The Exo Sensor stated maintenance cycle of 120 months for

q. .the pressure transducer and RTD was backed-up by test data.

t 4

i I

J 1

Attachment A 4

.f 4

r i

- w _g W- t, r

ATTACHMENT nB - 1 Two potential enforcement items were identified by the NRC related to unacceptable documentation to establish qualification for Rockbestos Firewall III EP cable and Firewall III Coax cable. This was based on potential generic problems regarding Rockbestos environmental qualification testing which was promulgated to the industry in IE Information Notice No. 84-44 (Attachment 1).

It is suggested by this IE Information Notice that there may have been inconsistencies in the quality assurance and the documentation practices used in the testing of certain Rockbestos cable. The types of cable were Firewall III (RXLPE, CXLPE insulation), Firewall III coaxial (RXLPE insulation) and Firewall SR (silicon insulation). This Information Notice was generated as a result of an NRC inspection of Rockbestos as described in Attachment 2. The Information Notice suggested three possible courses of action which should be considered by an affected utility. These were 1) to perform a new qualification test, 2) obtain documentation from other tests, and 3) perform analyses of existing reports.

-It was also stated that..."It appears that the validity of some of the Rockbostos qualification reports is in doubt, however the NRC staff has concluded at this time that no immediate safety problem exists in the use of Rockbestos cables. The NRC staff considers that it is the responsibility of the user utilities to review the information provided above and take applicable corrective action to ensure the qualification of Rockbestos cables in their plants."

Note that IE Information Notice 84-44 states that a safety problem does not exist.

! Salem uses two types of Rockbestos cable in safety related l

applications, both inside and outside containment. The type names are Firewall-EP, which was qualified by the test reports in' Salem Equipment Qualification Report No. EO-08, and l

Firewall-III coaxial cable, which was qualified in Salem l Equipment Qualification Report No. EO-32.

Firewall-EP is of particular concern because it is used in safety-related applications inside containment. One of the qualification test reports performed by an outside test organization (Franklin) during the years of concern is F-C3798.

This report was identified by the NRC as possibly being problematic (Attachment 2). This report is not, however, required for the successful qualification of this cable.

Utilization of OR No. 1804A (in EO-08), performed in 1982 establishes the qualified status. Of f urther significance, neither Attachment 2 nor Attachment 6 identifies Firewall-EP as a cable of concern.

q

m 1 ^ = e ,

? s

' 5 l

Firewall EP (Ethylene-Propylene Rubber insulation - the most-

- commonly used and' accepted for Class lE cable insulation) has-never been identified as having possibly questionable QA

- practices in testing. It has never been discussed or'even mentioned in-IE Information Notices or NRC inspection reports.

Firewall III - Coaxial is used at Salem, but only outside of containment for both units. This cable was mentioned in IE 84-44,-and.Rockbestos was immediately contacted by PSE&G for discussion (Attachment 6). A complete requalification program for.Firewall III - Coaxial was completed in March 12, 1986.

This test program reinforced the . conclusions of the previous Rockbestos tests of Class IE cable of similar construction. It also reconfirms the similarity between first _ and second generation coax cable previously established in Addendum 1 to Rockbestos technical report TS1981 - YJR-3.

A recent NRC inspection at Rockbestos resulted in several observations and comments as identified on page113 of Inspection Report No. 9900277/85-02 (Attachment 3). Because this cable is used.only outside containment in Salem, most of the NRC comments are not applicable. The applicable and useful observations to Salem are that after the cable was irradiated, a visual examination revealed no degradation, and an aging test

' determined an activation energy of 2.75 eV. .This aging test has not yet been fully reviewed, but an activation energy this large indicates equipment life of substantially greater than 40 years.

Of interest is the fact that San Onofre recently underwent an NRC EO inspection. NRC Inspection Report No. 50-312/85-14 (Attachment 4), mentioned the Rockbestos cable on page 13. It

-is stressed that the ability of Firewall III and Firewall SR to

' survive-a LOCA is not-questioned. The only concern was that San Onofre had not adequately established similarity between the cable in their plant and the specimens tested in their Qualification Reports.

Although Salem does not utilize Firewall III SR cable, it is interesting to note that the NRC's concern is not the establishment of ' qualification per the test report but of similarity to the plant cable, thereby stating that once simiarlity is established qualification would also'be established. This is contrary to what is indicated as a potential enforcement item for Salem.

It is concluded that Salem did not have a safety concern with Rockbestos cable. The existing in-house documentation (EO-32;

- EO-08; and Attachments 1-6) sufficiently demonstrated qualification, and the test which is currently in progress at Rockbestos will serve only to supplement the existing reports currenty found in EO-32.

It should also be noted that, to date, all retesting has resulted in ' confirmation of the previous results questioned by IE'Information Notice 84-44.

QMdlMEW ,

gjq -~sAliKdER NUCLEAR 1

j

{ G LICENstNG 5 INSaSd Nn REGULATIO 935 IN 84-44

- - -  ; jd 21 '84 u

.. UNITED STATES #

l j . E . '.

. NUCLEAR REGULATORY COMMISSION -

T d%@ ji I0FFICE OF INSPECTION AND ENFORCEMEN r 1

/

, j ,,, ?_*i WASHINGTON, D.C. 20555 -.- . .

1:Ci > . I I June 8, 1984 -

7 v-NOTICl; NO 84-44:

WQ ENVIRONMENTAL QUALIFICAl 1Un IESTINC AC IErINFO

- ROCK 8ESTOS CABLES a.my n e Addressees: pm w. ne All holders of a nuclear power reactor operating license (OL) or construction permit (CP). . ,

Purpose:

This information notice is provided to inform licensees and construction permit holders of potential aeneric oroblems reaardina Rockbestas enviennmental '

qualification (EQ) testing of Class 1E electrical cables. Addressees are expected to review the information for applicability to their facilities.

No specific action or response is required.

Description of Circumstances:

The NRC has performed a number of inspections of the QA programs established at several environmental testing facilities. This effort was started in late August 1982 to assess the facilities' establishment and implementation of a QA program based on the requirements of 10 CFR Part 50, Appendix B.

Several such inspections were recently conducted at the Rockbestos Company in New Haven, Connecticut. The NRC inspection team reviewed qualification .

related documents such as EQ reports, associated supporting items including test plans, test procedures, test instruments, test log books, related raw data and QA documents. The inspections revealed several QA nonconformancos and related testing / documentation problems. Details of these nonconformances and inspection findings are documented in the following NRC Inspection Reports:

99900277/83-01, 99900277/83-02, and 99900277/83-04. Listed below are some of the QA nonconformances and related testing / documentation problems which may affect the qualification of Rockbestos cables that are installed at licensees' facilities:

1. The Rockbestos Comnanv did not impose cuality assurance / test control re-ouirements on an outside test oraanization which performed testing (LOCA/

HELB) during ti.e period of 1969-1979.

2. The Rockbestos Company did not establish and implement a QA program.in accordance with 10 CFR Part 50, Appendix B requirements to control Rock-bestos EQ testing; i.e., the EQ program was controlled by a Rockbestos engineering organization which was not under a QA program until 1983.

__- . _ _ _ _ 6% - ,

IN 84-44 June 8, 1984 Page 2 of 3

3. As a result of inadequate QA controls, testing and the required documen-

~

tation were not properly controlled. Several discrepancies oetween final qualification reports and supporting test data were found.

4. Rockbestos' QA and engineering organizations did not imoose OA and techni-cal reouirements/ acceptance criteria on organizations that performed qualification testing for Rockbestos between 1969 and 1979. Furthermore, no supporting test data for these tests were available for audit at Rock-bestos or subtier test organizations. ,

5. Test equipment and instrumentation were observed to have inadequate reso-lution to record LOCA test parameters and functioning of test specimen during testing.

6. Test equipment was not properly calibrated or under the control of the calibration system. An internal Rockbestos audit dated May 10, 1983, documented these generic deficiencies in their calibration s:ystem.

7. Test plans, acceptance criteria, and test procedures for certain quali- ,

fication tests were not made available during the NRC audits.

8. A number of test deficiencies, deviations, and other anomalies were not documented and evaluated in the test reports.

• Discussion:

The results of the NRC inspections show that several deficiencies were present in the Rockbestos Company qualification programs in effect at time of the audit.

Individually, some deficiencies could be adequately reconciled, but taken col-lectively, the nature and number of deficiencies identified would not adequately demonstrate that acceptable qualification had been established. It appears that the validity of some of the Rockbestos qualification reports is i doubt. how-ever. the NRC staff has concluded at this time that no immediate safety problem exists in the use of Rockbestos cables. The NRC staf f considers that it is the retnantibility of the user utilities to review the information provided above and take aDolicable corrective action to ensure the qualification of Rockbestos cables installed in their plants. The following possible courses of corrective action should be considered:

a) Perform a valid qualification test of the installed Rockbestos cables.

b) Obtain documentation from other available qualification tests alreacy performed and determine its applicability to the install-ed cables.

- . , . . - . , _ , . o-_.,-. - -- ,,.- .__ -. .,,._.,.---.,--,_..,_._-..._e,---_,,. ,__.-e -- - . - . , ~ . , - . . . . , ,

.i IN 84-44 June 8, 1984 Page 3 of 3 c) Perform analyses of existing qualification reports applicable to tne installed caotes to ensure tnat tne oocumentation relied upon to demonstrate environmental qualification supports such a conclusion.

The NRC staff considers this review to be part of the on going activities that_ V ~

the licensees are currently undertaking to resolve other environmental quali- % ,

fication deficiencies to meet the deadline and requirements set forth in the EQ final rule, 10 CFR 50.49.

Questions regarding details of, and resolutions to the NRC inspection findings described above should be directed either to the equipment manufacturer, or the cognizant design / test agency. If you have questions regarding this information notice, contact the Regional Administrator of the appropriate NRC Regional Office, or this office. , ,

di Jordan, Director dward -

Divisi of Emergency Preparedness and gineering Response Office of Inspection and Enforcement Technical Contacts: R. G. LaGrange, NRR (301) 492-8208 N. B. Le, IE (301) 492-9673

Attachment:

List of Recently Issued IE Information Notices i

l l

4 , e o

i PSlaG l

l TO: E. A. Liden Manager - Nucit.ar Licensing and Regulation FROM: 7. T. S tacJ ey

.sta.,ager - N :c J e: 2.r Systems Engineecing l

SUBJECT:

EQUIPMENT QUALIFICATION TEE'.rNG OF ROCKBESTOS CABLE i S-C-A910-EEE- 0 0 8 7-k0 i DATE: August 12, 1935 l The attached Engine .t ing F. valuation, Equip:nent Qual ifir . tion Testing of Rockbestos Cabje., Ic perwarded for yoer information. IE Notice No. E4-44 cescri'aec a possible

• inadequacy in the quality t ce.acco o r t.:.'. i c e n o f th . .ock:>esto .

Company. Engineering in ir. t.c r ; ? r r ier, o . ~. to s t 1.p.. f ts. shic!.

demonstrate the ability of the 'teceLut<cos LO.~.: in safety-related syste.ns s t SC.cm to n .eet all specifications and a letter from Rockbestos addressing each item in TE Notice 84-44 individually.

l Should any further informatior, bc requiree please contact the

_ Systems Analysis Group.

n.

- \{ ' 4' (

BGH: jab Attachment C 1 General Manager - Nuclear Quality Assurance 1 General Manager - Nuclear Services 1 General Manager - Salem Operations l 1 Assistant General Manager.- iiuclear Engineering 1 Manager - Nuclear Systems Engi.neering 1 Manager - Nuclear Plant F.ngineering 1 Manager - Nuclear Engineering Design 3 Manager - Nuclear Engineering Co.itrol 1 Manager - Nuclear Safety & Assurance 1 On-Site Safety 1 Site Engineering 1 Station OA Engineer - Salem 1 Salem Operations Response Coordinatcz 1 M. Levine 1 B. G. Horst 1 SAG File 1 TDR GH-BGH/l

~

< - -- ~_

-