ML20214E287
| ML20214E287 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/28/1987 |
| From: | Anderson C, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214E253 | List: |
| References | |
| 50-289-87-01, 50-289-87-1, IEIN-86-003, IEIN-86-053, IEIN-86-3, IEIN-86-53, NUDOCS 8705220027 | |
| Download: ML20214E287 (25) | |
See also: IR 05000289/1987001
Text
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O.S' .NUCLEAR REGULATORY COMMISSION
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REGION I
" Report No. 50-289/87-01
Docket No. '50-289
License No. DPR-50 Priority --
' Category C
Licensee: GPU Nuclear Corporation
P.O. Box 480
Middletown, Pennsylvania 17057
Facility Name: Three Mile Island, Unit 1
' Inspection At: Parsippany, New Jersey
Inspection Conducted: January 12-16, 1987: January 20-21, 1987
' Inspectors: Cl M
R. JR Paolino, Lead Reactor Engineer
- {P/M
'da te i
Also participating in the inspection and contributing to the report were:
L. Cheung, Reactor Engineer - R1/PSS
0. Gormley, Equipment Qualification and Test Engineer, EQIS/IE
M. Jacobus, Member Technical Staff - Sandia National Laboratories
T. Koshy, Reactor Engineer - R1/PSS
J. Stoffel, Consultant Engineer - Idaho National Engineering Laboratory '
A. Sugarman, Consultant - ENRAC
Approved by: & V JI 7
C. Jr Anderson, Chief, Plant Systems date
Section/ ORS
Inspection Summary: Inspection on January 12-16, 1987 (Corporate Office)
January 20-21, 1987 (TMI-Site) - Inspection Report No. 50-289/87-01
Areas Inspected: Announced inspection to review licensee's implementation of
a program for establishing and maintaining the qualification of electrical
equipment within the scope of 10 CFR 50.49. The inspection also included a
site verification of installed EQ equipment and a review of the licensee's
response to Information Notices 86-03 and 86-53.
Results: The inspection team determined that THI-1 has an EQ Program that
meets the requirements of 10 CFR 50.49 and is maintaining the qualification of
. electrical equipment important to safety in compliance with 10 CFR 50.49,
except as noted below. As a result of this inspection there is one violation
of 10 CFR 50, Appendix B, criterion V, failure to follow procedures for
mounting Foxboro transmitters and eight Potential Enforcement Items for which
the Itcensee failed to demonstrate availability of qualification data prior to
this inspection.
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Violation Paragraph Item No. (s)
Seismic adequacy of mounting for 4.11 50-289/87-01-15
Foxboro transmitter not established.
Potential Enforcement items
1. Adequacy and auditability of EQ files 4.9.1 50-289/87-01-01
2. Qualification of Limitorque 4.10.2 50-289/87-01-03
Switch Cam Material - Durez 791
(black phenolic)
3. Consideration of Rockbestos Cable 4.10.3 50-289/87-01-04
Insulation Resistance / Leakage
Currents in Instrument accuracy
requirements
4. Qualification of Weed RTD's 4.10.4 50-289/87-01-05
5. Qualification of Foxboro Instruments 4.10.5 50-289/87-01-06
6. Consideration of Brand-Rex Cable 4.10.9 50-289/87-01-09
Insulation Resistance / Leakage
Currents on Instrument Accuracy
Requirements
7. Qualification of Kerite Splice 4.10.12 50-289/87-01-12
8. Qualification of Static-0-Ring 4.10.13 50-289/87-01-13
Pressure Switches
Unresolved Items
1. Qualification of Eaton Cable 4.10.1 50-289/87-01-02
not readily available
2. Rosemont Installation Interfaces not 4.10.6 50-28S/87-01-07
addressed and Incorrect Checklist
response
3. TOR Walkdown file for GE penetration 4.10.7 50-289/87-01-08
does not reflect as-built condition
4. Conflicting maintenance requirements 4.10.10 50-289/87-01-10
for H 2Recombiner
5. Confiteting requirements for Ross 4.10.11 50-289/87-01-11
Solenoid Valve splices
6. Response to Franklin Institute 4.10.13 50-289/87-01-14
TER concerns not addressed in EQ
File
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DETAILS
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1.0 ' Persons Contacted
'1.1 General Public Utility Corporation (GPUN)
- +J. C. Auger, Engineer - PWR Licensing ,
- P. E. Boucher, EQ Engineer-
J. Bowman, Lead Electrical Maintenance Foreman
+T.'G. Broughton, Director Systems Engineering
- J. Colitz, Director Plant Engineering
+L.-W. Harding, Manager QC Electrical
R. Harper, Manager.-
- C. E. Hartman, Manager Plant Engineering
+D. Hassler, Licensing Engineer TMI-1
+H. D. Hukill, Director TMI-1
- C. L. Incorvati, Audit Supervisor TMI-1
- B. Kalenevitch, Engineer Document Control Group
P. Karish, Lead Electrical Engineer
+N. Kazanas, Director Engineering Projects
+R. W. Keaten. Director Quality Assurance
- P. G. Levine, Senior Engineer I
+R. W. Liscom, QA Engineer i
- +J. F. Mancinelli, Manager EQ
+R. J. Markowski, Manager Qa Prog. Div./ Audit
+R. J. McGoey, Manager PWR Licensing
Y. Nagai, Licensing Engineer
V. Orlandi, Lead Electrical Engineer
- +E. Pagan, Manager EQ
- L. G. Robinson, Media Representative
M. Sanford, Manager, Mechanical Systems
+0 Slear, Director Engineering Services
- C. W. Smyth, Manager Licensing TMI-1
N. Trikourous, Manager System Analysis and Plant Control
- R. J. Toole, Operations & Maintenance Director
- +C. R. Tracy, Director Engineering Assurance
+R. F. Wilson, Vice President Technical
1.2 Eco Tech. Inc.
+L. P. Gradin, Director Engineering (GPU Consultant)
1.3 U.S. Nuclear Regulatory Commission
- C, A. Anderson, Chief, Plant System Section NRC/RI
+R. J. Conte, Reactor Project Section lA
+J. Durr, Chief. Engineering Branch NRC/RI
+D. M. Johnson, Resident Inspector TMI-1 .
- U. Potapovs Chief. EQ Section NRC/IE/HQ :
+J. O. Thoma, Project Manager TMI-1 '
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- denotes personnel present at the Corporate site meeting of January 16,
1987
+ denotes personnel present at the Site exit meeting of January 21, 1987,
2.0 Purpose
The purpose of this inspection was to review the licensee's EQ Program for
electrical equipment, important to safety and located in a harsh environ-
ment as required by 10 CFR 50.49, including the licensee's follow up to
commitments for resolving outstanding issues identified in the NRC equip-
ment qualification (EQ) safety evaluation report (SER).
3.0 Background
On January 14, 1980, the NRC issued IE Bulletin (IEB)79-018, with
attached Division of Operating Reactor (DOR) Guidelines and NUREG-
0588. Subsequently, on May 23, 1980 Commission Memorandum and Order
CLI-80-21 was issued and stated that the 00R Guidelines or NUREG-0588
form the requirements that licensees must meet regarding the environ-
mental qualification of safety related Electrical Equipment. The
" final rule",10 CFR 50.49 became effective on February 23, 1983.
This rule specifies the requirements to be met for demonstrating, the
environmental qualification of electrical equipment important to
safety located in areas that could be subjected to a harsh environment
resulting from a design basis accident. By letter dated December 10,
1982, the NRC transmitted to GPUN a Safety Evaluation Report (SER)
augmented by a Franklin Research Center (FRC) Technical Evaluation
Report (TER) for the EQ of Safety related electrical equipment at
THI-1. The TER identified numerous deficiencies relating to lack of
documentation to support qualification of components. By letter
dated March 1, 1983 GPUN (Technical Functions and Licensing)
requested a meeting with the NRC and FRC to discuss the "misunder-
standing" noted in the TER.
Prior to holding the requested meeting and in response to 10 CFR
50.49(g), GPUN submitted a letter dated May 20, 1983 wherein they
identified components within the scope of 50.49 concluding that the
components Itsted were qualified in accordance with 00R guidelines
dated November 1979. On October 5, 1983 GPUN personnel met with the
NRC EQ section to discuss TER deficiencies identified in the NRC's
December 10, 1982 SER. As a result of this meeting GPUN committed to
providing the NRC a written resolution to each TER deficiency and
concluded they were currently in compliance with the Environmental
Qualification Rule 10 CFR 50.49 as applicable to THI-1.
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4.0 EQ Program Requirements '
4.1 The NRC' inspectors examined the implementation and adequacy of the
licensee's EQ program for establishing and maintaining the
environmental qualification of electrical equipment in compliance
with the requirements of 10 CFR 50.49. The licensee's EQ program
is defined in the following procedures:
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' Corporate Policy and Procedure Manual No. 1000-POL-7317.01
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Plant Modification Engineered by Plant Engineering No.
1000-ADM-7350.01
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Plant Configuration Control Lists No.1000-ADM-1211.02
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Environmental Qualification of Equipment No. 1000-ADM-7317.01
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Quality Classification List No. 5000-ADM-7370.02
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Plant Configuration Control Lists No.1000-ADM-1211.02
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TMI-I Equipment Locations and Environments No. TDR-282
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Project Reviews No. 5000-ADM-7311.03
These procedures prescribe the method by which GPUN establishes
environmental qualification of electrical equipment and assures
compliance.with 10 CFR 50.49. The program includes certain post-
accident monitoring equipment as defined in Regulatory Guide 1.97 as
well as non-1E electrical equipment whose failure under postulated
environmental conditions could prevent satisfactory accomplishment of ;
safety functions. The EQ program does not address electrical equip-
ment in a mild environment (10 CFR 50.49, subparagraph (c)(iii)] or
mechanical equipment. Overall quality assurance or quality control
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requirements for Environmental Qualification is delegated within the :
Nuclear Assurance Division. Responsibilities include establishing
and maintaining an inspection and monitoring function for EQ compon-
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ents/ equipment, audit records and files required to implement and
sustain systems, procedures and programs to ensure proper control of
environmentally qualified equipment. In addition, program procedures
were reviewed to evaluate the procedural methods and their effective-
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ness for:
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Requiring that all electrical equipment in a harsh environment l
and within the scope of 10 CFR 50.49 be included on the list of
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equipment requiring qualification (EQ Master List).
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Control of additions / deletions and distribution of EQ Master !
List
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Establishing, evaluating and maintaining EQ documentation
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Defining and differentiating between a harsh and mild
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environment
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Controlling plant modifications for replacing and maintaining EQ
equipment.
Based on the above, the inspection team determined that the licensee
has implemented a program to meet the requirements of 10 CFR 50.49,
although some deficiencies were identified and are discussed in
paragraph 4.10 of this report.
4.2 10 CFR 50.49(d) List (EQ Master List)
The licensee is required to establish and maintain a current list of
equipment which must be qualified under 10 CFR 50.49. At GPU an
extensive review of electric equipment in THI-I was performed by the
licensee to determine the equipment to be qualified and included on
the EQ Master List (EQML). The criteria used for determining the
electric equipment requiring qualification included the identifica-
tion of Class 1E equipment required to function to mitigate the
consequences of design basis events, and which must operate in harsh
environments. This included devices required for the initiation of
automatic protective functions as well as those required for post-
accident recovery actions. In addition, equipment located in areas
subject to a harsh environment and not required to perform a safety
function but whose failure or misoperation could cause degradation of
required safety equipment was considered. Devices or components
which provide operator information or indication required for
operator action were also included in the EQML.
GPUN Nuclear Corporate Policy and Procedure manual number 1000-POL-
7317.01 Rev. O dated May 31, 1985, entitled " Environmental Qualifi-
cation of Equipment," assigns responsibility for the EQ program,
including the establishment and maintenance of the EQML to the
Director, Technical Functions Division. The responsibility is
delegated to the Director, Engineering Assurance / Manager Equipment
Qualification. Paragraph 5.1.1.a requires the preparation of the
master list. The procedures for preparing and maintaining the EQML
are contained in Technical Functions Division Procedure number
5000-ADM-7317.01 (EP031) Rev. I dated September 30, 1986 entitled
" Equipment Environmental Qualification." Changes to the EQML are
through the Design Change Notice / Field Change Notice (DCN/FCN)
process as required by EMP-008. A computer based system maintains a
current listing of DCNs filed against the EQML since the last
revision. Review / approval / distribution is controlled by the
DCN/ routing / sign-off sheets and the provisions of procedure no.
5000-ADM-7706.011 (TAP-006) and procedure no. 1000-ADM-1211.02
(EMP016). However, the EQML revision itself is performed by the EQ
section without further procedural controls.
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The NRC inspector performed an audit of the EQML to determine its -
validity. The review took place in three phases. First, the-
inspector examined'the list itself and selected System Component-
Evaluation-Worksheets (SCEW) in order to evaluate the treatment of
certain auxiliary systems. The systems reviewed were~the Post- l
Accident Exhaust Sampling System, the Fuel Handling ESF Ventilation
. System, and the Post-LOCA Hydrogen Recombiner. .Next, 12 Piping and .
Instrumentation Diagrams (P&ID) were examined to make an independent
determination of functional flow path, control and indication as
follows:
1. H2 Recombiner 302722, Rev. O, 7/13/84
2. Emergency Feedwater, 302082, Rev. 3, 8/29/84
3. Fire Service Water, 302231, Rev. 33, 6/20/84
4. Instrumentation, 302271, Rev. 28, 6/21/84
5. Backup Instrumentation, 302272, Rev. 1, 2/17/83
6. 2 Hour Emergency Air, 302273, Rev. 3, 9/13/84
7. Post Accident Reactor Coolant Sampling, 302673,
Rev. 1, 8/23/84
8. Vital Instrumentation, 206501, Rev. 17, 10/12/83
, 9. 4160V Engrd. Safeguards Sw. Gr. , 206022, Rev. 8, (date
illegible)
10. 480V Engrd. Safeguards Sw. Gr., 206032, Rev. 10, 6/7/83
j 11. Building Spray, 302712, Rev. 23, 8/8/86
12. Core Flood, 302711, Rev. 11, 6/4/72 /<
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In the third phase, three emergency operating procedures (EOP) were
reviewed as follows: Small Break LOCA Cooldown 1210-6, revision 4
dated July 2, 1986; large Break LOCA 1210-7, revision 7, dated
June 13, 1986 and Lack of Primary to Secondary Heat Transfer 1210-4, .
revision 5, dated June 13, 1986. This last phase produced a number- '
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of components which operate during the respective events but which
are not or. the EQML. However, the licensee was able to provide
justification for all components included on the E0P's but not on the
EQML.
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No~ deficiencies were. identified in.the Itcensee's. program for-
establishing and maintaining the EQML in'accordance with the-
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requirements of'10 CFR 50.49.
- 4.3L Control of EQ Related Plant Modifications
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The licensee's! Technical' Functions .- Functional Engineering' Section .
performs'all modifications that involve EQ components in accordance
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J.with the governing Technical Functions procedure. Plant Engineering
or. Technical Functions as applicable:
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estabitshes that the component must be environmentally
qualified for a harsh a environment and specifies what
the harsh environment.
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Defines _ performance requirements for components and ensures that
-the' final design complies with such requirements.
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Defines, specific environment parameters and requests qualifi-
. cation data on Purchase Requisition if required.
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Assures-that_-installation requirements are defined so.that the
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installed configuration adequately represents the tested
configuration.
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Ensures that-the modification will not have a negative impact on
any harsh environment that contains existing qualified compon-
ents.
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Ensures that the EQ Section has reviewed all qualification prior
to release for construction,
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Obtains concurrences from the EQ Section=for modifications
involving EQ equipment and releases for construction per pro-
cedure EMP-008.
Technical. Functions Procedures which must be followed by Plant
Engineering personnel when performing modifications include:
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Procedure No. 1000-ADM-1211.02 " Plant Configuration
Control Lists" (EMP-016)
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Procedure No. 5000-ADM-1291.01 " Nuclear Safety /
Environmental Impact Evaluation" (EP-016)
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Procedure No. 5000-ADM-7313.02 " Quality
Classification List" (EP-011)
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Procedure No. 5000-ADM-7313.03 " Power Plant System
List" (EP-012)
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u_ ___________m__ _ _ _ _ _ . . _ _ _ _ _ _ - _ _ _ _ . . . _ _ _ . . . . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . . _ _ _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _________m
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Procedure No. 1504'-ADM-7350.ls" Plant Modtfications
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. Engineered by Plant Engineering"-(EMP-019)
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Procedure No. 5000-ADM-7350.02 "Insta11at1on
- Specifications"(EP-020) :
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Procedure No. 5000-ADM'-7313-01 "Modttication and
System Design Description"_(EP-005) -
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Procedure No. 5000-ADM-7350.05 " Mini Mods"
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Procedure No. 5000-ADM-7311.03-" Project Reviews" (EMP-014)
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. Procedure No. 500-ADM-7317.01'" Equipment Environmental Quali-
fication" (EP-031)- ;
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Procedure No. ES-011'" Methodology'and Content.of GPUN Quality i
Classification List"
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Procedure No.:AP-1043 " Engineering Chang'e Modifications"
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The following EQ work activities were reviewed for compliance'with
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established procedures: Job Ticket No. CK784, Technical Function
Work No. B00830, Design Change Notice C048157 and BA412458P1.
No deficiencies were identified in the GPUN program to control '
- - plant modifications involving EQ equipment.
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- ' 4.4- E0 Maintenance Program
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The required maintenance for each type of qualified equipment is -
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defined in the Supplemental SCEW sheet for the qualified equipment. ,
Two types of maintenance activities'are involved, preventive main- ;
tenance-(PM) and corrective maintenance. Procedures governing these ;
' activities were reviewed by the NRC inspectors. Procedure No. '
1407-2, revision 3 provides guidelines.to ensure that the Environmental
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Qualification-(EQ) of designated safety-related equipment is not
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degraded during maintenance activities. ' Procedure No. 1027, revision 14,
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' outlines the scope references,' responsibilities and requirements of
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the Preventive Maintenance Program.
s The Preventf ve Maintenance Program is designed to perform tasks that
include. lubrication, inspections, tests for. proper operability, '
. calibrations, and programmed replacement of parts. Corrective
Maintenance is performed to ensure that the environmental qualifi-
,, cation of equipment is not degraded during maintenance to ensure that
material with a design life of less than 40 years is periodically
replaced.
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- The _ Environmental Qualification Section (EQS) performs sample reviews
of applicable maintenance and surveillance procedures to ensure that
the environmental qualification requirements are maintained. The EQS
. monitors plant maintenance and surveillance data for potential-impact
on _ environmental qualification components and performs evaluations to
ensure lubricants and solvents used during maintenance do not degrade 3
the environmental qualification of safety related equipment. The
LGeneration Maintenance System (GMS) Coordinator assists the PM Group
in the implementation, scheduling and assessment of the PM Program by
operating the Generation Maintenance. System to provide scheduling
information and the results of the scheduled activity.
The inspector's review of the licensee's EQ maintenance activity
identified no deficiencies in the areas reviewed. .
4.5 Training of EQ Personnel
GPU Procedure No. 5000-ADM-2131.01 revision 1-00, " Technical Func -
tions Personnel Indoctrination and Training", dated October 17, 1984
prescribes general training requirements for their engineering
personnel. Procedure No. 1407.2, section 2.1 requires that mainte-
nance department personnel be properly trained in environmental
qualification requirements. The inspector reviewed licensee training
records which indicate that EQ managerial and engineering personnel
.did received various EQ Training from~outside agencies. EQ training
for site personnel was given on October 9, 1986. The material
covered included the regulatory requirements and the current status
of GPUN EQ program. In addition, three hour seminars entitled
" Control of Environmental Qualification for Safety Related-Electrical
Equipment" was given to 92 electrical and I&C personnel during the
period between April 10, 1985 to June 17, 1985. Discussions with
craft personnel indicate personnel to be knowledgeable and aware of
EQ requirements.
No deficiencies were identified in the licensee's program to provide
EQ training to site and corporate personnel.
4.6 IE Information Notices and Bulletins
Licensee Procedure No. 1000-ADM-1216.03 revision 1-00, defines and
establishes the GPUN system for control and management of incoming
and outgoing regulatory correspondence. Generic regulatory
correspondence, including those items that GPUN intends to comment
on, are handled in accordance with Procedure No. 1000-ADM-7330.02.
GpVN licensing is designated as the corporate recipient of GPUN
regulatory correspondence. Regulatory items are tracked on the
Action Item Tracking System (AITS). A tracking system status report
is sent monthly to all applicable Department Managers.
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The inspector reviewed licensee action and documentation in response
to IE Bulletin 82-04, Information Notices 82-11, 83-45, 83-72, 84-44,
84-57 and 84-78. .The inspectors concluded that the licensee does.
have a program for distributing, reviewing and evaluating Infomation
Notices and IE Bulletins and recommending action to ensure environ-
mental qualification of electrical equipment within the scope of 10
CFR 50.49,
4.7 EQ Replacement and Spare Parts Procurement.
Procedure No. 5000-ADM-6230.01 (TAP-Oll) revision'l-00, establishesa
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the methods for preparation, review, approval and release of purchase
requisition originating in GPUN Technical Functions Division in
support of engineering activities.
Other applicable procedures reviewed include:
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Procedure No. 5000-ADM-1215.02 " Technical Document Release"
(EMP-008)
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Procedure No. 5000-ADM-7313.02 " Quality Classification
List" (EP-011)
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Procedure No. 5000-ADM-7315.01 " Technical Specifica-
tions" (EP-004)
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Procedure No. 7000-ADM-6333.9 " Limited Purchase Order"
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Procedure No. 1000-ADM-POL-1011.02 " Procurement Control - Level
of Signature Authority".
Materials and components associated with safety related structures or
systems are purchased to specifications and codes equivalent to those
specified for original equipment or as specified by a properly
reviewed and approved revision. In those cases where the EQ
requirements of the original item cannot be determined an engineering
evaluation is conducted to establish the requirements and controls.
This evaluation is documented and ensures that interfaces, inter-
changeability, safety, fit and function are not adversely affected.
All Purchase Requisition or attached technical specifications must
define the applicable environmental qualification requirements.
The inspector reviewed Procurement Document Nos. TP-038388 and
TP-038586. No deficiencies were identified in the licensee's program
for procurement of EQ equipment and replacement parts.
4.8 QA/QC Interface
The licensee's QA audit department consists of three branches, one in
the corporate office, one at the TMI-1 site and one at the Oyster
Creek site. The corporate QA and site QA departments conducted three
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audits of the TMI-1 EQ program. The first audit (No. 0-TMI-84-04) ,
was conducted by the corporate QA department on June 29,.1984 to !
verify that the Babcock & Wilcox Owners. Group EQ Summary Report was
supported by adequate documented tests or analysis and that records
were being maintained. No findings were identified. The second
audit (No. 0-TMI-84-02) on June 4-13, 1984 also performed by the
~ Corporate QA department, audited the licensee's implementation of
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.their EQ program. Three deficiencies were identified pertaining to l
EQ procedures and maintenance areas. These deficiencies were
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resolved prior to May,1985. '
The third audit-(S-TMI-85-05) was conducted by TMI-1 site QA-on April
15 through May 10, 1985 to reivew the status and adequacy of EQ
activities performed at the site. Four deficiencies were identified.
All'of these findings were resolved prior to October 2, 1985. The
findings were in the areas of site EQ procedures, site personnel
training, materials and site use of SCEW sheets. The inspector
reviewed the audit reports and pertinent records of these audits
versus the GPU procedure requirements. No unacceptable conditions
were identified.
.
4.9 Equipment / Component Environmental Qualification File
The licensee's EQ files were examined to verify the qualified status
of the safety related class IE equipment within the scope of 10 CFR
50.49. The review consisted of comparing plant service conditions
with qualification test conditions and verification of the basis for
these conditions. The inspectors selectively reviewed areas such as
required operating time compared to the duration of time the equip-
ment has been demonstrated to be qualified; similarity of tested
equipment to that installed in the plant (e.g. insulation class,
component materials, tested configuration versus installed configura-
tion and documentation for both); evaluation of adequacy of test
conditions; aging calculations for qualified life and replacement
interval determination; effects of decreases in insulation resistance
on equipment performance; adequacy of demonstrated equipment
accuracy; evaluation of anomalies; and applicability of EQ problems
reported in IE Information Notices /Bullutins and their resolution.
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Of the licensee's 57 EQ files, the inspectors sampled 31 EQ files.
The EQ files selected, covered such areas as electrical cables,
limitorque motor operated valves, pump motors, solenoid operated
valves, cable splices, radiation detectors and pressure / level trans-
mitters. These files contain documentation utilized by GPU to pro-
vide the basis for demonstrating that the equipment type is quali-
fied. The equipment type being a specific component or equipment,
designated by the manufacturer and model number, which is represen-
tative of all identical equipment / components in a plant area exposed
to the same or less severe environmental service condition.
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Based on'the NRC review of the EQ files, the licensee had not
established guidelines for controlling file content to ensure
auditability. In fifteen EQ files the inspectors identified a number
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of sin 11ar file. deficiencies ' consisting of: Inadequate or missing.
-component / equipment description and installation instructions;
, incomplete checklists; installation interface not addressed;
conflicting maintenance instructions or lack thereof; applicable
resolutions for previously identified TER open items not in files;
inadequate information on accuracy and performance requirements.
Specific deficiencies of the type noted above are discussed in
paragraph section 4.10.
Based on the inspection findings the licensee was informed that the
EQ file deficiency was in violation of 10 CFR'50.49, paragraph (J)
which states: "a record of qualification, including documentation in
paragraph (d) of the regulation, must be maintained in an auditable
form..."Section III of IEEE-std-323-1971 and 1974 defines auditable
data as information.that is documented and organized so as to be
readily understandable and traceable to permit independent verifi-
cation of inferences or conclusions based on the information.
This item is a Potential Enforcement Item (50-289/87-01-01).
4.10 Specific File deficiencies were identified as follows:
4.10.1 Eaton Cable File No. EQT1-156
The Eaton Cable file was reviewed by the inspector to determine
whether the file contained sufficient information to support
qualification of the cable for use in the environmental condi-
tions in which it must function.
File documents reviewed include:
--
National Technical System Report No. 558-1088, dated
October 9, 1981
--
SCEW sheet No. TI-770-031.032 for Eaton Cable No.
FR-EPDM/CSPE
--
EQ Assessment for file No. EQ-TI-156 dated August 18, 1986
--
Isomedix Report "LOCA Nuclear Qualification of
EDPM/Hypalon Composite Cable" dated June, 1978
_- . __ , .- . - - _ _ . _ . _ .- .
_
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13
Qualification was based on four test specimens. Cable
Specimen No. 3 (XLP0/8E-8) is the type used at TMI-1. The-
results of the simulated LOCA test indicate that during the
second transient, the insulation resistance for this cable-
dropped to 2.84 x 10' ohms. The reason for this occurrence was
unknown. -This test anomaly was not addressed nor justified by
l any'of the documents in the EQ file or the SCEW sheet.
Subsequent to this finding and within the inspection period the
licensee issued a Design Change Notice (DCN-048156) dated
January 13, 1987 providing a resolution of the test anomaly.
This item is unresolved pending NRC verification of licensee
action to incorporate resolution in the EQ file, revise the
SCEW sheet and other applicable file documents.
(50-289/87-01-02)
4.10.2 Limitorque Motor Valve Operators (MOV)-
Inside Containment File No. EQTI-103
The inspector reviewed the Limitorque MOV file for' MOV operators
used inside the containment to determine whether the file con-
tained documented and adequate data to support qualification for
use of the MOVs in the environmental conditions in which they
must function.
Documents examined include:
--
Limitorque Report No. 600198 " Test of Limitorque Valve
Operator to Meet General Requirement of Electric Valve
Actuator in Nuclear Reactor Containment Environment"
--
Limitorque Report No. 60037A "Limitorque Power Station
Type Test Report"
--
Limitorque Report No. B0058 "Limitorque Valve Actuator
qualification for Nuclear Power Station Service"
--
Limitorque No. 80119 " Qualification type test Report of
terminal Strips for use in Limitorque type Actuator for
PWR Services."
--
TMI-1 Limitorque Walk-down data book.
The Limitorque EQTI-103 file did not contain or reference
resolutions to TER deficiencies, identified by Franklin
Institute on aging for Limitorque Model Nos. SMB, SMB-2, SMB-3
and SMB-000. However, the licensee was able to provide the
information from another source which was not referenced in the
EQ file. (Auditability of the EQ file is to be addressed in
response to 50-289/87-01-01).
_
..
- 14-
During this review,D the inspector noted that the TMI-1 Limitor-
que walk-down_ data book contained photographs (dated December
20, 1986).in which the Limitorque switch cam shaft for MOVs
RC-V-3 and WD-G-3 appeared to be of ' phenolic black material .
The limit switch and torque' switch insulation materials quali-
-
fied for use inside containment applicationsfare Melamine and
Fibrite. Melamine is whitish grey and generally.found in older
actuators. Fibrite is brown and found in actuators of recent
manufacture. The qualified material .for outside containment
applications is Durez, which is a phenolic and comes in either
black or red.
~
Qualification data supporting use of the phenolic limit switch
~
cam shaft in containment was not included in the Vendors
Limitorque inside containment testing program. However, data
generated by the licensee as a result of this inspection
(DCN-048169 dated January.18, 1987) concludes that the black
Durez material is qualified for the TMI-1 containment
environment. OCN-048169, which includes =GPUN calculations
C1101-200-5710-006, extrapolates the test data of limitorque-
report no. 80003 to provide the basis for the similarity
discussion for the tested material and the black (Durez 791)
-
material used at TMI-1. Prior to this inspection the licensee
did not adequately demonstrate qualification of the Limitorque
limit switch cam (phenolic) for in-containment use in violation
of 10 CFR 50.49, paragraph (d)(1). This item is a Potential
Enforcement Item. -(50-289/87-01-03)
4.10.3 Rockbestos Cable File No. EQTI-150
The inspector reviewed the Rockbestos cable file, including
coaxial cable, Radiation cross linked polyethylene (RXLPE-
formulation 760G), and chemically cross-linked polyethylene-
(CXLPE-formulation 7600). The Rockbestos cable was qualified in
accordance with NUREG-0588, Category 1. The test specimens were
identified in formulation as the installed cables with the test
profile enveloping the plant profile. The file contained all
the latest Rockbestos cable test documents of tests performed by
Rockbestos. However, the file did not contain analysis of how
measured parameters taken during the type test (e.g. Insulation
resistance, degradation of neoprene Jacket in the Rockbestos
type tests) would affect plant circuits.
The licensee is responding to similar concerns identified
during a 10 CFR 50.49 EQ inspection at Oyster Creek, see
inspection report 50-219/86-08. The Utility has contracted with
a consultant to evaluate the effects of insulation resistance on
plant circuits at Oyster Creek. The licensee has issued a
Design Change Notice (DCN-048180) whicn references preliminary
results of this study, indicating that Oyster Creek, which has a
more severe environmental profile than TMI-1, had no problems
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'.with respect to degra'ded insulation' resistance. The report
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(ETR-2028) . is in draft form and is not yet' referenced by the
-
file. s However, the report' indicates that the cable compound ..
- '(KXL-760G) on which the analysis is based, is:not u' sed-at TMI-1. ~
DCN-056832 was' issued following theLinspection to address NRC.
< concern on cable compound similarity.' The'DCN indicates that
minor composition changes from compound to compound will have.
no appreciable effect'on performance'of instrument circuits
using Rockbestos-Cable.' The DCN cites Rockbestos Report -
No. TR-6801 which demonstrates ~that'Rockbestos cross-linked,
~
. polyethylene compuunds~are-sufficiently-similar.that LOCA test
results taken on~one-would be applicable to all compounds.
Prior to this inspection the licensee'had'not ad' dressed the
effects:of-lowered insulation resistance on instrument circuits-
for TMI-1.
This item is considered to'be a Potential Enforcement Item in
violation of NUREG-0588,. Category I requirements.
(50-289/87-01-04)
4.10.4~ Weed RTD's File No.'E0TI-136
The inspector reviewed the:EQ file for Weed RTD Models 6120,
N90170,-1A00/611 and 1AOD/6120. In addition, the file was
reviewed to establish Victoreen High Range Radiation monitor
connector similarity; performance requirements and radiation
-qualification of the Teflon insulator-used in the connector.
The qualification of the connector was based on the' D0R guide-
lines.
-
A. Based on the specification requirement of- 1 megohm for
cable insulation resistance (IR) for the radiation. monitor
' cable in the Oyster Creek accuracy assessment report (ETR q"
2028 by ECOTECH), tests indicate a minimum IR for the
penetration / connector assembly of about 3 megohms ~at 325*F--
and 21 megohms at 250*F, which is much better than the 1
megohm requirement. An analysis of the radiation effects-
on the teflon insulator was included'and determined that ,
even though mechnical property loss of~the insulator is
expected, electrical property degradation is not expected
and the teflon is' confined in the connector. The file
cites EPRI-2129 which reports that the teflon performed
satisfactorily at low mechanical stress at levels above:20
-
Mrads (required dose).
W1 thin the scope of this inspection no deficiencies were I
identified.
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B. RTO qualification was based on_ NUREG-0588, Category 1
l guidelines. The plant profile, enveloped by the test ~
condition is similar to the IEEE-std-323 profile. The test
specimens were claimed to be similar to the installed
equipment in the plant, however, because of the differences
between the 611 series and the 612 series, which are not
described in the file,, traceability of similarity from the ,
test specimen to the installed equipment was not possible. '
The RTD's were inspected only twice, once before the test
began'and once after the post LOCA test. No evaluation
of the effects of aging, transportation of test specimens
between the test facilities, radiation and post LOCA con-
_ditions'could be found in the test reports. The error
analysis of the test results could not be found in the EQ
file. _No positive statement was found to indicate that the
equipment was successfully tested.
Section 2.1(3)(a) of NUREG-0588, Category 1 requirements,
state, in part that " Equipment that must function in order
to mitigate any accident should be qualified by test..."
Section 2.2 of NUREG-0588, Category 1 requirements states,
in part, that': "1) failure criteria should be established
prior to testing, and 2) test results should demonstrate
that the equipment can perform its required function..."
The licensee has issued DCN 04891 containing information
generated after this inspection to address NRC concerns.
l The licensee will revise the EQ file, EQTI-136 to include
! this data.
Prior to this inspection, the licensee had not adequately
demonstrated qualification of the Weed Resistance Tempera-
ture Detector (RTD's) in violation of NUREG-0588,
Category I requirements and is therefore determined to be a
Potential Enforcement Item. (50-289/87-01-05)
4.10.5 Foxboro Transmitter File No. EQT1-122
The inspector reviewed the EQ file for Foxboro Pressure
Transmitter Models N-E11GH, N-N1MN2, N-E11GM-SAE-1 and
N-E11AM-SAH2. Qualification of the transmitters was based on
the D0R guidelines. The plant profile, enveloped by the test
conditions is similar to the IEEE-Std-323 profile. The test
specimens were different from the installed equipment, however,
the licensee performed a similarity analysis justifying the
difference between test specimens and the installed equipment.
Some of the test results for the effects of steam and radiation
on the test specimens showed unusually high measurement errors
L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
--__--
.,
17
with no explanation of the anomalies. No plant performance
requirements for assessing the acceptability of the test
results could be found in the EQ file.
The~ licensee. issued a Design Change Notice.(DCN-048164)
containing additional data generated during this inspection
to address the issues. This information will be. included in
the EQ file, EQTI-122 and the SCEW sheet will be revised to
reflect the latest information.
Prior to this inspection the licensee did not demonstrate
qualification of the Foxboro Pressure Transmitters. This item
is in violation of section 5.2 of D0R Guidelines and is there-
fore considered to be a Potential Enforcement Item.
(50-289/87-01-06)
4.10.6 Rosemount Transmitters File No. EQT1-129
The inspector reviewed the EQ file for Rosemount Pressure
Transmitter Model 1152GP9A92T0010PB. Qualification of the
Rosemount Transmitter was based on the D0R guidelines. The plant ;
profile, enveloped by the test conditions is similar to the
IEEE-Std-323 profile. The test specimens were identical to the
equipment installed in the plant. The " checklist" in the front of
the EQ file was incorrectly marked "yes" for item 8 for beta.
radiation being included in the total integrated dose (TID) to
the tested equipment. The installation interfaces (i.e. Conax l
Connector) used for testing the transmitter were not identified
in the test report.
The licensee issued a Design Change Notice (DCN-048154) to
l change the " checklist" response to say "No" for item 8 in the
next revision. In addition, Note 2 of the checklist will be
expanded by citing page 4 of reference 129-07 which documents 4
that the transmitter is housed in a stainless steel enclosure.
The purpose of this is to show why beta radiation does not have
to be included in the TID. The reference will also note that
Conax connectors are used for the installed and the tested
r equipment. An additional reference will be made in Note 6 of
( the checklist. The reference will state that the interfaces
f'
for the subject equipment are field run cables, qualified
Raychem Splices and Conax connectors.
This item is unresolved pending NRC verification that the above
document changes are made as noted. (50-289/87-01-07)
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14'.10.7/ GE Electitcal Penitration' AssemblyiFile No. EQTI-137 >
4' '
The' inspector reviewed.the EQ-file for the GE F01 electrical:
penetration to determine qualification.of electrical-
_ interfaces.
'
f, The qualification assessment report for these penetrations-
~
contained statements regarding the electrical interfaces
'
indicating-that~the Outboard electrical interfaces in_useLat
. TMI-1 are GE termina11 blocks (qualified per EQ file No. -EQTI-
112)'and the inboard electrical interfaces in useLare.Raychem-
splices (qualified per EQ file no.'EQTI-134). The F01 quali-
, fication file references TDR-6560- Environmentally Qualified
Equipment Field; Verifications _for the as-installed configuration
of.this equipment._ In describing:the=as-installed. condition of
penetrations.201 and 204 (inside containment), the TDR file-
indicates that there are multi pin connectors that have no.
Raychem Splices and that terminal blocks are still in use.
Visual inspections of. penetration 201, 204, and 311 by the NRC
"
.
inspector did not- substantiate the TDR statements, ._since
Raychem splices were observed on safety related electrical
-
interfaces inside the containment. The licensee has agreed to
>, update'the TDR file'.to reflect the as-installed conditions.
This item is unresolved pending NRC verification of licensee
corrective action. (50-289/87-01-08).
-
4;10.8. File No. EQTI-113, ASCO Solenoid Valves
.
The inspector reviewed the EQ file for ASCO Solenoid Val've
-
, Models 206-3816RVE'and'206-3817RVF for use in areas free from-
steam and spray, and the NP-8316 66E Valve for general use.
The inspector determined that the file did not contain ~a
-sufficient description of the valve. This deficiency was - . O
corrected during the inspection.- - The licensee issued a Design
Change Notice (DCN-041538) to add available catalog data-
. supplied by the vendor, to the file. The data covered service
data, mounting restrictions, maintenance instructions and
expanded views which allowed internal elastomers to be identi-
fied and located.
Within the scope of this review no further action is required.
4.10.9 Brand-Rex Cable File No. EQTI-153
The inspector reviewed the EQ file for Brand-Rex crosslinked
polyethelyne (XLPE) and chlorosulfonated polyethelyne (CSPE)
cable types RG-11A/V and RG-598/V used for power, control and
instrumentation. While the tests performed met vendor
stipulated acceptance criteria and enveloped plant conditions,
no plant related acceptance criteria were specified.
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Of particulariconcern is whether lowered insulation resistance;
will allow una'cceptable degradation of instrument s1gnals. This'
~
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- deficiency was detected during;an EQ related inspection atz
'
~ 0yster Creek- and the licensee is in:the: process.of preparing .
.theJrequired loop analyses to allow'. specification'of minimum
L
-
required insulation resistance values during. accident or test.
conditions. The licensse uas issued a~ Design Change Notice?
C (DCN-048165) which' references preliminary results of an Oyster
Creek study (re:;Rockbestos Cable para. 4.10.3) that addresses-
,_ the insulation resistance measurement' errors.
L 2
The Preliminary studies, addressing similar concerns at Oyster :
Creek, have not identified any degraded insulation resistance
~
_
1!
problems. Since _0yster Creek has.a.more severe enviornmental
profile it.is reasonable to conclude that TMI-1 would:not
-experience degraded-insulation resistance problems in
Linstrument circuitry.
'
,
Prior to this inspection.the licensee had'not addressed the.
effects of lowered insulation resistance-on-instrument circuits
~
for TMI-1. This item is considered to be a Potential Enforce-
ment Item in violation of 10 CFR 50.49 paragraph (d)(1).
~
-(50-289/87-01-09)
4.10.10- Rockwell Hydrogen Recombiner File No. EQTI-142
The-inspector reviewed the EQ file.for the-Hydrogen Recombiner
located in the intermediate building.- Qualification for the
4 Hydrogen Recombiner was based on DOR guidelines.
.The qualified service life'was stated by the SCEW sheets TI
~
901-005'and TI-901-006 to be based on an annual inspection of~
-
cable, cable splices, blower motor, cooler fan motor, heater-
assembly and thermocouple assembly. The licensee did not
-provide evidence that the inspections were performed.
The licensee issued a Design Change Notice (DCN-048170)
which uses the analyses and calculations in the EQ file (ref.
142-05) in establishing that the' phenolic in the terminal block
is-the most thermal-aging sensitive and Radiation = sensitive
material in the recombiner. The DCN indicates that the phenolic
material has a qualified life of 40 years at.230*F which
envelopes both plant normal and accident conditions. Since the
Recombiner is located in the intermediate building, the tempera-
-
ture during its DBA (LOCA) is considered mild (90-106*F).
Based on the Radiation properties of phenolic and the large
amount of margin which exists over the specified base of 0.2
MRads the licensee is deleting the statement, " Maintenance
Required to Maintain Life". The SCEW sheets TI-901-005 and
-
_ _ _ _ _ _ _
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TI-901-006 and the~EQ file EQTI-142 will be revised accordingly.
This. item is unresolved pending NRC review of licensee correc-
tive action. (50-289/87-01-10)'
~4.10.11- Ross Solenoid Val'ves File No. EQTI-138
-The inspector reviewed the EQ ' file for ROSS Solenoid Valve
Model 2676-A-4011. These pilot valves are located in the
Auxiliary Building'and are qualified to D0R guidelines. .The
' file contains conflicting requirements with' respect to
maintenance requirements to maintain equipment qualification.
The Equipment Summary (page 5 of 5) section 3.0 and 4.4
requires a preventive maintenance inspection of interface
splices to maintain qualification. EQ checklist no. 25
indicated no interface' requirements.
Visual inspection by the licensee and the NRC inspector of Ross
Valves Nos. MU-V-18 and MU-V-20 indicated that tape splices are
not used and that the wires terminate at GE type.EB-5 terminal
blocks, therefore no, inspections are necessary. ' The licensee
has issued a Design Change Notice (DCN-048159) to. revise the EQ
file to reflect the as-installed configuration and to delete the
instructions that do not. apply.
This item .is unresolved pending NRC review of licensee
corrective action. -(50-289/87-01-11)
4.10.12 Kerit'e Splice File No. EQTI-126
The inspector reviewed the EQ file for Kerite Splice Model No.
SS-NS-NVC-DISC. The disconnectable splices are used on the
Emergency Feedwater pump motors in the Intermediate Building.
The files did not contain acceptance criteria related to
required performance at TMI-1. In addition, the files did not
contain descriptive information which sufficiently addressed
similarity between plant, and test configuration and conditions.
Test anomalies including water intrusion.into splice and other
failures were not satisfactorily addressed. The file only
stated that the tailures do not apply at TMI-1 because the
tested configuration was different than the installed condition.
The licensee has issued a Design Change Notice (DCN-048138)
describing TMI-1 mounting configuration, performance criteria
for TMI-1 application. This information will be included in
the EQ file, EQTI-126 at its next revision.
Prior to this inspection the licensee had not adequately
demonstrated qualification of the Kerite splice. This item is
considered a Potential Enforcement Item in violation of 10 CFR
50.49 paragraph (d)(1). (50-289/87-01-12)
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4.:10.13 Static-0-Ring: Pressure Switches File No. EQTI-117 !
Theinspectobreviewe'd the EQ-file for Static-0-Ring l(SOR)
~
-
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'
J- - Pressure Switch Models 9TA,'=4N6, 12N6. Qualification.for-
- the: Static-0-Ring: Pressure Switches.was based on 10 CFR >
'50.49. guidelines. The 9TA switches'are.usediin containment .
, - ~
=.to detect the decrease in-steam.line steam pressure associated.
-with'a steam line break'and to, actuate feedwater isolation. .The
4N6 switches' are used.in the Auxiliary Building for-low oil. .
. pressure trip on.the makeup' pump. Numerous file deficiencies
were observed. Performance / acceptance criteria were not pro-
vided. This made evaluation of< set point changes associated
with the te'sts-impossible. .No similarity analysis was provided -
,
and test anomalies were not adequately addressed. *
~
SOR qualification testing results. appeared to provide a i
basis-for qualification for'the 4N6 type switches used
- outside the containment, but this could not be confirmed-in
the. absence of' plant related performance /acceptan'ce ,
,
criteria.-
There were no_ test results to support qualification of the
9TA' type switches used for feedwater isolation. The very . . .
-limited number of SOR tests on switches with the TA (explosion
proof) housing either; exhibited performance well below normal >
expectations or were not tested in a configuration similar'to
. that installed at TMI-1.- In addition, significant_setpoint
changes. occurred or were predicted to occur in' circumstances
similar ~to the TMI-1 application. The licensee has issued a
- Design Change Notice (DCN-048148) containing descriptive
material and an-analysis to demonstrate similarity between the
sensitive-components in the switches tested and those installed
in the plant. The delayed actuation from^ a predicted 28 psi
decrease in set point expected to result from heatup of the
switch was addressed. The EQ file will. be updated to reflect '
the analysis and resolutions presented in the DCN.
Prior to this_ inspection the licens'ee had not adequately. demon-
strated qualification of the Static-0-Ring Pressure- Switches in !
violation of 10 CFR 50.49 paragraph (f)(1). This-item is being
,
considered a Potential Enforcement Item. (50-289/87-01-13)
The Static-0-Ring Pressure Switch TER concerns (Franklin
Institute TER Report Item 57) were not addressed or referenced
in the EQ file. The licensee indicated that the earlier TER was
for switches which had been replaced. However, the same concern
exists for the installed replacment switches. Written demon- .
'
stration of qualification is being completed in the file to
close out the TER concerns.
.
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1This item 11s' unresolved:pending NRC review of licensee
'
- - correctiv'e action. (50-289/87-01-14)-
-e 4.'111 Plant Physical Inspection of Electrical Equipment
The p1 ant physical inspection consisted of an examination-of safety
s
v :related. electrical ' equipment: selected from the EQ Master List. The
e'quipment selected was, located and installed inside/outside
containment and consisted-of Limitorque Motor Valve _0perators,1
Foxboro Transmitters,;Rosemount Transmitters, TargetLRock Solenoid.
Valves,-Level Switches, Resistance Temperature Detectors, Radiation
^
Detectors and' Electrical-Splices.
The inspectors examined characteristics such as mounting configura '
'
.' . tion, orientation, connection interfaces, Model/ Type, bend radius,'
seals, environment,. accessability, cleanliness and-physical condi '
' tion,
.
r
During this inspection, the inspector observed that Foxboro Mod'el ,
_
Ell-GHT S/N 2428970 and.2428971, designated RC-3A-PT4 and RC-38-PT3
'
_
respectively had loose mounting bolts. In addition, the; inspector.
noted.that the Foxboro Transmitters are mounted on-the vertical leg
-
of'an 'L! shaped.2_ inch pipe bracket, which have the lower
- horizontal 2 inch pipe leg welded to a flange 'that is fastened to.
.the "D: Ring" wall with four bolts. The Foxboro Transmitters are
-held in place on the vertical section of. pipe-with two U-Bolts. The
, inspectors observed that lower U-Bolts on both units were loose.
Vendor Manual No.-020-165, for NEll and NE-13 Transmitters, specifies
a special' seismic mounting bracket for use on vertical pipe. U-bolts
are not used in the Vendor qualified seismic mounting.
Engineering justification for using the U-Bolt configuration was not
available.
This item is a violation of 10 CFR 50, Appendix B, Criterion III
which states, in part that: " Activities effecting quality shall be
prescribed by documented instructions ... -and shall be accomplished
in accordance with these instructions". (50-289/87-01-15)
4.12 Licensee Response to NRC Information Notices
4.12.1 Information Notice 86-03
On January 14, 1986 NRC issued Information Notice 86-03,
" Potential Deficiencies in Environmental Qualification of
Limitorque Motor Valve Operator Wiring" to alert licensees to
potential problems regarding qualification of electrical wiring
used in Limitorque M0V's. In response to this Notice, the
licensee reviewed its applicability to TMI-1 and conducted an
.
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23
inspection of all Limitorque Motor Valve.0perators requiring
environmental qualification. (Action Item No. 86-9030) :The
results of this inspection are documented in the licensee's
Walkdown Report TDR-658.
As a result of this inspection, the licensee replaced all
wiring whose qualification could not be established during the
1986 outage.
During the interim period,.from the time the MOV's were inspec-
ted, until the wiring was replaced, the licensee performed an
operability evaluation for those MOV's containing wiring whose
qualification status was unknown. "
Within the scope of this inspection no deficiencies were
identified.
4.12.2 Information Notice 86-53
On June 26, 1986 the NRC issued Information Notice 86-53,
" Improper Installation of Heat Shrinkable Tubing". The Notice
was issued to alert licensees to a potentially generic safety
problem involving improper installation of heat shrinkable
tubing over electrical splices and terminations.
"
The Notice was reviewed by the licensee with documentation and
comments for completion of appropriate action.
Installation of Raychem Heat Shrinkable tubing at TMI-1 has
been installed in accordance with procedure No. 1420-4-24
" Installation of Raychem Splices". This procedure was developed
based on Raychem installation instructions. In addition, some
TMI-1 plant electricians, I&C technicians and Foremen have been
trained by Raychem or the TMI Maintenance Training Department in
the proper installation methods. QC personnel have also
received training in this manner.
Procedure No. 1420-4-24 has been changed to incorporate Raychem
instructions on Heat Shrink tube bend radius.
Visual inspection by the NRC inspector of Raychem Splice
installations in the plant did not result in the identification
of any Raychem splices installation deficiencies.
Within.the scope of this inspection no deficiencies were
identified.
_ . . .
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8=,
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24
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4.13 Unresolved Items.
Unresolved items are matters which require more information in order
to ascertain whether they are acceptable items or violations.
Unresolved items identified during this inspection are discussed in
Details paragraph ~4.10.2, 4.10.7, 4.10.8, 4.10.10, 4.10.11 and j
4.10.14.
4.14 Exit Meeting
L The inspectors met with licensee corporate and site personnel
! (denoted in Details, paragraph 1) at the conclusion of the inspection
! on January 16, 1987 and January 21, 1987 at the corporate office and
! plant site, respectively. '
l
I The inspector summarized the scope of thE inspection and the inspec-
l; tion findings.
At no time during this inspection was written material provided-to
+
the licensee.
i ..
. . . . . .
.. _ _ _ _ _ _ _ _ _ _ . - _