ML20214W409
| ML20214W409 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 12/01/1986 |
| From: | Alexander S, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20214W379 | List: |
| References | |
| 50-369-86-20, 50-370-86-20, NUDOCS 8612100215 | |
| Download: ML20214W409 (17) | |
See also: IR 05000369/1986020
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U.S. NUCLEAR REGULA10DJ COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
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Report No.:
50-369,370/86-20
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Docket No.:
50-3M , 50-370
. I License No.:
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Juke Power Company
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Licensee:
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Post Office Box 33189
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' Tharlotte, North Carolina 28242
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McGuiid Nuclear Station, Units 1 and 2
Facility Name:
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. Inspection At:
. Duke Power Company, Nuclear Design Engineering
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522 South Church Street, Charlotte, North Carolina
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McG0 ire-1 and 2
,Cornelius, North Carolina
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Inspection Conducted:~ July 28 to August 1, 1986
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. Inspector:
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b.'DT Alexander, Equipment Qualification
(Yate
Inspection Section (E0lS)
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Alsr> Sarticipathg in the inspection and cdntributing to the report were:
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U. Potapovi, Chief, (quipment, Qualification Inspection Section, IE
M. Yost, Consbitant' Engineer, Idaho National- Engineering Laboratory
W. Carpenter, Cons 61 tant Engineer, Idaho National Engineering Laboratory
J. Grossman, Member of Technical Staff, Sandia National Laboratories
N. Merriweather, Reactor Engineer, RII
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MMP
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U. Potapovs, Chief, EQlSa Vendor Program
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Branch, Division of Quality Assurance,
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Vendor and Technical Training Center Programs
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Office of Inspection and Enforcement '
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INSPECTION SLMMARY:
Inspection on July 28 to August 1, 1986 (Peport No. 50-369,370/86-20)
Areas Inspected:
Special,
announced
inspection
to evaluate Duke Power
Company's (DUKE) implementation of a program for establishing and maintaining
the qualification of-electric equipment important to safety at McGuire Nuclear
,
Station (McCUIRE) in compliance with 10 CFR 50.49.
EQ-related documentation
was reviewed and a plant walkdown was conducted on both units. The inspection
also included evaluations of the implementation of environmental qualification
(EQ) corrective action commitments made by DUKE as a result of deficiencies
identified in Safety Evaluation Reports (SER) and the Franklin Research Center
Technical Evaluation Report (FRC TER),
Results:
The inspection determined that DUKE has implemented a program to
meet xthe requirements of 10 CFR 50.49 for McGUIRE except for certain
deficiencies listed below. No deficiencies were found in DUKE's implementation
of SER/TER corrective action commitments.
Unit I was in a refueling outage and inspections and repairs to equipment
affected by inspection results were to be made prior to startup.
Unit 2 was
operating, but DUKE was evaluating operabili ty of affected equipment and
preparing i ustifications for Continued Operation (JCO),.
Affected equipment in
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Uni t 2 was to be inspected and repaired at the next opportunity and in
accordance with Technical Specification requirements.
Potential Enforcement / Unresolved Items:
Report
Item
Paragraph
Item Number
1.
Unqualified Limitorque Wiring
4.A(1) and
50-369,370/86-20-01
4.E(2) through (7)
2.
timitorque Gear Case Grease
4.E(2),(4),
50-369,370/86-20-02
Relief Caps
(5) and (8)
3.
Raychem Splice Configurations
4.A(1)
50-369,370/86-20-03
and4.E(9)
4.
Cable Performance Requirerents
4.A(1)
50-369,370/86-20-04
and 4.D
5.
ITT Barton 386A Pressure
4.D(1)
50-369,370/86-20-05
Transmitter Test Anomalies
6.
Rockbestos Silicone Rubber
4.A(1)
50-369,370/86-20-06
Insulated Cable /IN 84-44
and 4.D(2)
7.
Samuel Moore (Eaton) PVC Cable
4.D(3)
50-369,370/86-20-07
Similarity
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Open Items:
Report
Item
Paragraph
Item Number
8.
EQ Procurement
4.A(3)
50-369,370/86-20-08
9.
EQ Personnel Training
4.A(2)
50-369,370/86-20-09
10. Electrical Penetration Assembly
4.A(1)
50-369,370/86-20-10
Performance Requirements
and 4.D
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DETAILS
1.
Persons Contacted
1.1 Duke Power Company (DUKE)
- R. B. Priory, VP, Design Engineering
- R. L. Gill, Licensing Engineer
- J. E. Thomas, Senior Engineer, Design Engineering-Electrical
- R. J. Smith, Design Engineer I
- T. P. Harrall, Supervising Design Engineer
Barry Propst, Primary Engineer, IAE Staff
Tim Cline, Primary Engineer,
- T. C. Roberts, QA Supervisor, TS
- R. W. Pierce, Support Engineer, MNS-IAE
- C. A. Little, System I&E Engineer
- W. H. Messer, Maintenance Engineer, I&E
- T. C. McMeekin, Chief Engineer
- D. W. Murdock, Principal Engineer
- R. E. Miller, Principal Engineer
- R. F. Wyke, Chief Engineer, Mechanical & Nuclear
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- J. M. Frye, Manager, QA Audit Division
- N. G. Atherton, Associate Chemist, MNS
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- J. A. Effinger, QA Audit Supervisor
R. Sokal, Technical Assistant III
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J. Voglewede, Supervising Design Engineer
R. R. Weidler, Senior Engineer
J. K. Ray, Supervising Design Engineer
J. Richardson, Design Engineer, HVAC
J. Reed, Design Engineer, HVAC
J. L. Crenshaw, Senior Engineer
R. M. Sandifer, Principal Engineer, MN Div.
T. .R. Dimmer, Supervising Design Engineer
L. B. Castles, Design Engineer I
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T. L. Edwards, Design Engineer I
E. W. Fritz, Design Engineer I
D. G. Watson, Design Engineer I
V. Keller, Cable Records
G. Sanders
A. Hinson
J. Lee
T. E. Sanders
D. Rains, Superintendent of Maintenance
R. White, IAE Engineer
M. Sample, Superintendent, Integrated Scheduling
E. Estep, Projects Engineer
1.2 Consultants to DUKE
None
1.3 Observer
None
1.4 NRC
W. T. Orders, Senior Resident Inspector, McGUIRE Nuclear Station
- Denotes those present at exit meeting at corporate offices on August 1,1986.
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2.
Purpose
The purpose of this inspection was to review DUKE's implementation of the
requirements of 10 CFR 50.49 for McGuire Nuclear Station (McGUIRE) and the
implementation of corrective action commitments made as a result of
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deficiencies identified in the FRC TER and SER's.
3.
Background
On March 29, 1983, the NRC held a meeting with DUKE to discuss all
remaining open issues regarding environmental qualification, including
acceptability of the environmental conditions for equipment qualification,
DUKE's proposed resolution of the deficiencies identified in the February
17, 1983 SER and January 25, 1983 FRC TER, DUKE's general method for
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compliance with 10 CFR 50.49, and justifications for continued safe
operation (JCO) for equipment for which environmental qualification was
not yet
completed.
DUKE's
post-meeting
submittal,
" Response
to
NUREG-0588", documents resolutions to outstanding items.
Also included
are descriptions of the McGUIRE EQ categories, method of compliance with
10 CFR 50.49, 650.49(b)(1), (b)(2) and (b)(3) and DUKE's position on and
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compliance with NUREG-0588, Category II under which McGUIRE equipment
purchased before the $50.49 effective date (February 22, 1983) must be
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qualified.
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4.
Findings:
The
NRC
inspectors
examined
DUKE's
program
for establishing
the
qualification of equipment within the scope of 10 CFR 50.49. The program
was evaluated by examination of DUKE's qualification documentation files,
review of procedures for controlling DUKE's EQ efforts, and verification
of adequacy and accuracy of DUKE's program for maintaining the qualified
status of the applicable equipment.
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Based on the inspection findings, which are discussed in more detail
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below, the inspection team determined that DUKE has implemented a program
to meet the requirements of 10 CFR 50.49 for McGUIRE although some
deficiencies were identified.
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A.
Program / Procedures
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The inspectors examined the implementation and adequacy of corporate
and site policies and procedures for establishing and maintaining the
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environmental qualification of electrical equipment in compliance
with the requirements of 10 CFR 50.49.
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The general overview document for Duke's EQ Program at McGuire and
other Duke sites is Design Engineering Department Manual, Section
11.4.5, dated January 31, 1986, entitled " Environmental Qualification
of Electric Equipment."
This document describes Duke's commitments
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for EQ at McGuire and delineates the responsibilities of Design
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Engineering as they relate to the EQ Program.
This manual states
that Design Engineering shall:
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(1) Determine which electrical
equipment requires environmental
cualification.
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.(2) Specify the applicable environmental parameters in procurement
documents.
(3) Review and approve qualification test plans.
(4) Assure qualification documentation review and approval.
(5) Provide updates to EQ licensing documents.
(6) Provide information to maintain qualification to the station.
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Other procedures which address McGuire's EQ Program are Nuclear
Production Department (NPD) Directive No. 3.3.1(M), " Maintaining
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Equipment Qualification,"
dated February 27,
1986 and Station
Directive
No.
3.3.9,
"McGuire
Nuclear
Station
Equipment
Qualification," dated February 12, 1986.
Directive No. 3.3.1(M) defines guidelines and responsibilities for
the Nuclear Production Department to maintain an equipment qualifi-
cation program to meet the guidelines of 10 CFR 50.49 including
guidance on procurement and maintenance of qualified equipment.
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Station ' Directive No. 3.3.9 identifies the requirements of the E0
Program which must be implemented by the Station.
This directive
defines responsibilities of station personnel and gives instructions
to station personnel on procurement of EQ equipment, EQ maintenance
and scheduling, nonconformances, ECRI discrepancies or revision,
equipment spares evaluation and EQ equipment identification.
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The following observations were made with regard to other aspects of
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DUKE'S EQ program:
(1)
IE Information Notices (IN) and Bulletins (IEB)
DUKE's procedures provide for screening, evaluation and tracking
of Information Notices, Pulletins and industrial notices and for
disseminating the information to responsible individuals.
The
files contained documentation of DUKE's actions in response to
EQ-related ins and IEBs through IN 86-53. Review of these files
for items applicable to McGUIRE resulted in the following
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comments:
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IN 84-44 impunes the validity of original Rockbestos cable EQ
test reports and for cases where no other basis for cualifi-
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cation can be obtained,
provides guidance for augmenting
qualification based on those reports.
DUKE action on IN 84-44
was limited to following the Rockbestos retest program.
The
methods suggested in IN 84-44 for establishing qualification
such as considering large margins for some applications, and
supplementing the Rockbestos data were not used.
DUKE'e
position on this issue was that all retest results thus far have
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validated the original
test conclusions.
Therefore, they
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contended that all original test reports could be used to
qualify Rockbestos cable.
However, while retest results were
consistent with original test report conclusions for cross-
linkeo polyethylene insulated cable, they did not necessarily
validate the original
test methods and 0A.
Furthermore,
Rockbestos has not yet retested the "Firewall
SR",
rubber insulated cable, and although the test method will be
essentially the same as other retests in the series, that is
insufficient basis for predicting the performance of the SR
insulated cable.
DUKE's position resulted in their failure to
establish qualification for Rockbestos Firewall SR cable at
McGUIRE as discussed in paragraph 4.D(2) below.
IN 84-47 deals with the effects of instrument loop component
insulation resistance (IR) (and its resultant leakage currents)
on instrument accuracy.
The evaluation of this IN by DUKE with
respect to McGUIRE was completed, but the results of the
analysis were not incorporated or referenced in cable and pene-
tration E0 files to demonstrate that plant specific performance
requirements were met.
This is discussed further in paragraph
4.0 below.
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IN 84-68 deals with underrated field wiring terminated internal
to normally energized Target Rock and Valcor solenoid operated
valves (thereby being exposed to higher temperatures than
qualified) due to self heating.
McGUIRE's Valcor V70900
solenoid valves (File MC-1205.00) were supplied with high
temperature lead wires.
Therefore, no modifications were
necessary.
The Valcor 526 solenoid valves (File MC-1205.00)
lead wire was replaced with Rockbestos SP166 high temperature
wire connected to the qualified field run wire with a Raychem
splice.
(File
L-16)
are
normally deenergized and are operated only intermittently and
were not subject.to the high internal temperatures.
IN 83-72 concerns multiple EQ issues.
E0 Notice 24 in IN 83-72
deals with qualification problems in Limitorque valve actuators.
DUKE had evaluated these problems and had taken corrective
actions they considered necessary at that time. DUKE determined
that no further action on the issue of potentially unidentified
(and unqualified) degradable materials such as wiring insulation
mentioned in EQ Notice 24 was necessary for Limitorques required
to be qualified at McGUIRE until the problem was again identi-
fied in IN 86-03.
DUKE action on IN 86-03 for McGUIRE on Limitorque wiring did not
include inspecting Limitorques and replacing unidentifiable
wiring.
Instead, DUKE provided Limitorque with the shop order
numbers for MOVs purchased for McGUIRE and received definitive
information on some MOVs with respect to what wiring Limitorque
records showed was supplied.
On other MOVs, Limitorque could
only identify what wire was typically used at the time those
MOVs were assembled.
DUKE stated that they then attempted to
contact valve manufacturers. Those which DUKE was able to reach
reportedly did not change original wiring or install
any
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additional wire.
DUKE produced records which they had reviewed
to determine what was done at the plant. The records indicated
that during construction, in-containment hookup wire was suppo-
sedly replaced with " qualified or safety-related" wire either
stripped from 37-conductor cable or " orange" single conductor
wire procured for this purpose.
Based on the information
available, DUKE concluded that they had adequately established
what wire was installed in McGUIRE Limitorques and based on
evaluation of applications and locations concluded that it was
all qualified.
However, these records, consisting of general
procedures and memoranda were not conclusive and even more
detailed
installation records
provided did not positively
establish traceability of a particular type of wire to either
qualification documentation or to specific M0V's.
During the walkdown inspection (discussed in detail in paragraph
4.E below), the NRC inspectors found unidentified jumper wire in
most Limitorques inspected which did not fit the description of
these wires in the records.
Eight of 15 MOVs inspected con-
tained unidentified white jumper wire which was later identified
by DUKE based on its unique appearance as ITT "Suprenant" or
Raychem wire with cross-linked polyalkene insulation and "Halar"
Jacket, manufactured to Milspec MIL-W-81'044.
However, this wire
had not been formally qualified by DUKE and available qualifi-
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cation data was incomplete and did not include a LOCA or HELB
type test. Other wire observed by inspectors remained unidenti-
fied at the end of the inspection. As a result of the walkdown,
DUKE committed to inspect all Unit 1 Limitorques and replace
wiring with qualified wire as required prior to startup from the
outage in progress. They also initiated operability evaluations
on Unit 2 MOVs and committed to provide justifications for
continued operation to NRC Region II or comply with Technical
Specifications as
the
required.
The DUKE inspections in Unit I resulted in at least partial
replacement of wire in all 32 Limitorques.
According to a DUKE
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submittal to NRC Region II of August 11, 1986 McGUIRE personnel
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entered Unit 2 containment at power on August 2,
1986 and
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inspected internally the switch compartments of all Limitoques
with the following results: two out of six Limitorques in
containment were rewired, one was determined to have identifi-
able and qualified wiring and three were deenergized in the safe
(design basis event) (DBE) position.
One out of 22 Limitoraues
outside containment was rewired, 17 were deenergized, and four
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were found to have qualified wire.
All four Limitorques in the
" doghouses" were found to have qualified wire.
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Duke EQ personnel subsequently reported that materials analysis
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of the insulation of unidentified wires removed from the
Limitorques indicated nine different types of wire had been
installed at one time or another.
Limitorque drawing Number
15 476-1525-3, dated 10-9-70, shows a factory installed jumper
between terminals "Cll" (open) and "CL1" (closed) on the limit
switch f'nger base terminal board of some McGUIRE Models.
The
jumper found in this position in Limitorques at McGUIRE was one
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of the consistotly unidentified wires and was determined by
materials analysis to be a type of chlorosulfunated polyethylene
("Hypalon-30"). No record thus far has been found of the use of
this ' wire by DUKE or its contractors or valve manufacturers
which DUKE was able to contact.
DUKE's failure to ensure that
all Limitorque internal control wiring was identified and
qualification files included documentation of qualification of
plant / vendor installed wiring constitutes Potential Enforcement /
Unresolved Item 50-369,370/86-20-01.
IN 84-90 Concerns Qualification Problems resulting from the
superheated steam environment which is created when, during a
large MSLB, steam generator tubes are uncovered by the resulting
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blowdown producing superheated steam.
The NRC had previously
approved DUKE's analysis of this event at McGUIRE which con-
cluded that the high temperatures resulting from this accident
would not prevent safe shutdown of the plant or impair the
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ability to maintain it in a safe shutdown condition. NRC issued
an SER on August 13,1984 which declared IN 84-90 issues for
McGUIRE-1 and 2 to be resolved.
IN 86-53 concerns Raychem heat shrink sleeving in unqualified
configurations. DUKE provided documenta' tion of their actions on
IN 86-53 which included inspections of qualified sleeving in the
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plant and review of the station's installation procedure.
All
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problems identified during the DUKE inspections were documented
and reported to be satisfactorily resolved.
Installation proce-
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dure IP/0/A/3090/06 (change 8) included Design Specification No.
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MCS-1390.01-00-0063, Rev. 20 which addressed the concerns of IE
Notice 86-53 with the exception of bend radius specifications.
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However, Rev. 22 of the design spec. to be implemented July 24,
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1986, included the Raychem bend radius criterion.
Also, DUKE
- had on file a July 11, 1986 Raychem letter detailing recomen-
dations for splices that had a tight bend radius.
DUKE's
position was that the McGUIRE Raychem splices were qualified
based on this information. DUKE further indicated that junction
boxes had been installed at qualified components to facilitate
installation and prevent over-bending of splices. The inspector
reviewed the thus far completed DUKE inspection sheets, dated
July 24, 1986, for seven splice installations in the Unit I
doghouse.
McGUIRE inspectors found them satisfactory except
the Raychem sleeves on pigtail splices for ASCO solenoid valves
(SOV) ISMSV0034 and 1SMSV0055 were installed over the braided
jackets of the valve pigtails. DUKE explained that these' valves
would fail safe on pigtail splice moisture intrusion during
The sleeves were to be reinstalled per
Raychem specifications prior to Unit I restart or a JC0 would be
prepared. The results of the NRC walkdown inspection of Raychem
splices are reported in paragraph 4.E(9).
Duke committed to
follow Raychem recommendations for splices with small bend
radii.
Also, DUKE was following the Utility EQ Group sponsored
E0 testing of non-standard splice sleeve configurations.
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(2) Training
The NRC inspector reviewed McGUIRE EQ training procedures and
records including:
Quality Assurance Training Roster for
Electrical QC Procedure Update Training on IP/0/A/3090/08,
IP/0/A/3066/02A,
MCS-1390-36,
MCS-1390-96, MCS-1390-63 and
QCE-2 completed October 23, 1985, Qualified Reviewer Training
Records for Training conducted on January 13 and 14, June 30,
July
1,
and July
9,
1986, Station Equipment Qualification
Training Lesson Plan No. G01E-01 and the Employee Training and
Qualification System Manual Index.
The records indicated that
EQ Training for maintenance and QC personnel had been primarily
limited
to
newly
hired
technicians,
qualified
procedure
reviewers and new engineers.
No EQ training had been given to
experienced technicians or QC personnel although DUKE had
scheduled E0 training for the Instrumentation and Electrical
(IAE) staff, supervisors, and planners 'for September, 1986.
DUKE considered this to be acceptable since the experienced
craft and QC personnel were qualified on procedures and instal-
lation specifications.
The NRC inspector recommended that DUKE
provide some type of overall EQ orientation training to all
plant personnel in Maintenance and QC.
DUKE agreed to review
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the need to provide this training.
Pending future NRC review,
this is identified as Open Item 50-369,370/86-20-09.
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(3) Procurement
The EQRI gives instructions on the procurement of spare parts
and replacement equipment which are implemented in Station
Directive No. 3.3.9.
Review of the portion of this station
directive covering EQ procurement revealed that the procedure
requires the EQ coordinator to review a copy of all "QA
condition 1" requisitions, but it does not require that the EQ
coordinator review the original reouisition.
DUKE indicated
that the review performed by the EQ coordinator is not a hold
point for purchase requisitions. Purchase requisitions could be
processed and material procured without prior review by the EQ
coordinator.
Thus, positive control over the EQ technical
content of EQ purchase requisitions is degraded.
If the intent
of the review is to verify that all EQ requirements are included
in purchase requisitions prior to release to the General Office
for procurement, this review should be a 0A hold point or
required series step in the process.
DUKE committed to review
their
procedures
for
processing
CA
condition
1
purchase
requisitions to confirm that controls are adequate to assure
that EQ requirements have been incorporated into purchase
requisitions.
Pending future NRC review, this is identified as
Open Item 50-369,370/86-20-08.
B.
Maintenance
In accordance with Nuclear Production Departm6nt Directive No. 3.3.1,
(M), " Maintaining Equipment Qualification," dated February 27, 1986.
and Station Directive No. 3.3.9, "McGuire Nuclear Station Equipment
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Qualification" dated February 12, 1986, the station is responsible
for maintenance of qualified equipment as specified by Design
Engineering to preserve the qualified status over plant life.
The
required EQ maintenance items are identified in the EQRI for each
qualified
component
including
surveillance,
monitoring,
and
refurbishment and/or replacement.
EQRI requirements for selected
items were verified to be incorporated into station maintenance
procedures and schedules.
This evaluation included review of the
following procedures:
McGuire Nuclear Station Procedure No. IP/0/N3190/10 "Limitorque
Operator Preventive Maintenance," dated November 19, 1985.
Design
Engineering
Installation
Specification
No,
MCS-1390.01-0068, Cable Termination Sealing Inside Containment
and Doghouses," implementation dated of January 8,1986.
McGuire
Nuclear
Station
Procedure
No.
MP/0/A/7300/34,
" Centrifugal Charging Pump Gear Reducer and Motor Oil Sampling
and Oil Change Procedure," dated September 26, 1985.
Station Lube Sheet for the Centrifugal Charging Pump dated
December 1, 1976.
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Memorandum To File from R.
W.
Pierce regarding IAE Section
Yearly Review of Rotork Actuator Work Requests (PM-IAE2) for the
period June 1, 1985 thru March 20, 1986.
Equipment Qualification Reference Index for Limitorque valve
motor operators, Rotork Actuators, Centrifugal Charging Pump
Motor RHR Pump Motor and 3M Scotchcast No. 9 Resin Termination
Sealant.
Nuclear Station Modification Manual, Revision 2, Effective Date:
March 1, 1986.
Station Directive 4.4.1, Processing Nuclear Station
Modifications."
The review indicated that these procedures were adequate to control
EQ maintenance, but walkown observations indicated that maintenance
controls may not have been fully effective. (See paragraph 4.E.)
C.
Environmental Qualification Master List (EQML)
Design Engineering Department Manual, Section 11.4.5, " Environmental
Qualification of Electrical
Equipment," dated January 31,
1986
governs maintenance of the EQML.
Its development is described in
Duke Power Company McGuire Nuclear Station Response to NUREG-0588.
Equipment required to be environmentally qualified in accordance with
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10 CFR 50.49 is identified by type and environmental category in the
NUREG-0588 response.
A more detailed list of EQ equipment by plant
equipment tag number (TAG No.) is contained in the McGuire Equipment
Qualification Reference Index (EQRI).
The EQRI also includes
instructions for updating and revising information it contains.
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The NRC inspection team reviewed the McGUIRE EQML, Revision 4 and
associated documents discussed below to verify the adequacy of the
implementation of McGUIRE's master list development and maintenance
. procedures.
As a validation check of the EQML, the inspector reviewed Emergency
,
.
Operating Procedures (EOP) with plant operations experts. A group of
components was selected at random from equipment identified in the
'
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E0P review as being required to support and/or carry them out.
The
'
inspector verified that all were either required to be qualified and
'
were listed in the EQML or that DUKE was able to justify their
,
exclusion. Documentation pertaining to individual deletions from the
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EMQL was also reviewed with no unjustified removals identified.
D.
Environmental Qualification Documenta_t_i_on Files
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The files consist of component qualification files, 10 CFR 50.49
Master List, system component evaluation worksheets (SCEW), accident
profiles, EQ test reports, regulatory and general correspondence, and
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documentati): ir' ( le t t 1E itefrs determined to be outside the scope of
the EQ program,
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A component file is prepared for each specific type of electrical
,
i
equipment, designated by manufacturer and model, in 'a plant area
exposed to the same environmental service conditions.
They each
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contain cover sheets with preparation, review and approval signa-
tures, Summary Evaluation forms with component descriptions, SCEW's
,
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with level of qualification data and supporting documents including
test reports, IEBs and ins, calculations, analyses and memoranda.
I
The NRC inspectors examined EQ files for 20 selected equipment items
to verify the qualified status of equipment within the scope of 10 CFR 50.49.
In addition to comparing plant service conditions from
3
the "McGuire Nuclear. Station Plant Environmental Parameters Manual"
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with qualification test conditions and verifying the bases for these
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condi tions,
the
inspectors
selectively reviewed areas such as
required post-accident operating time compared to the duration of
!
time the equipment has been demonstrated to be qualified, similarity
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of tested equipment to that installed in the plant (e.g., insulation
class, materials of components of the equipment, tested configuration
compared to installed configuration, and documentation of both),
'
evaluation of adequacy of test conditions, aging calculations for
qualified life and replacement interval determination, effects of
,
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decreases in insulation resistance on equipment performance, adequacy
,
of. demonstrated
accuracy,
evaluation
of
test
anomalies,
and
applicability of EQ problems reported in NRC IE Information Notices /
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Bulletins and their resolution.
!
EQ Documentation File Observations
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Several examples were identified by the NRC inspection team where the
E0 documentation files failed to establish qualification due to
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errors, incorrect calculations, missing documents, not addressing
anomalies,
incorrect
SCEW
sheet
changes,
clarifications,
and
'
requirements
for
additional
documentation,
which
were
either
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resolved, still require correction, or were adequately corrected
,
during the inspection.
These are identified as Potential Enforce-
ment / Unresolved Items 50-369,370/86-20-04, 05, 06 and 07 and Open
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Item 50-369,370/86-20-10, described below.
Ultimately, the files
were found to be auditable. However, the unique manner in which they
were organized was not conducive to expeditious review.
While
required information was retrievable, it was very difficult to
compile all the information needed to verify the qualification of a
particular equipment item without considerable assistance from DUKE
personnel.
Cable files reviewed had no evaluation of functional performance
requirements.
DUKE's files on instrument loop accuracy analysis
prepared in response to other concerns including those discussed in
IN 84-47, considered performance requirements for cables indirectly.
Analyses of electrical penetration assemblies' (EPA) leakage current
effects on instrument loop accuracy had been prepared for NRR to
address concerns on the D. G. O'Brien EPA tests, but, since files on
cable leakage effects could not be found, analyses for them were
regenerated during the inspection.
The NRC inspector was satisfied
with the technical content of these analyses and DUKE committed to
reference this information in the appropriate files.
This consti-
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tutes
Potential
Enforcement / Unresolved
Item 50-369,370/86-20-04.
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EPA EQ files also did not include the EPA functional performance
evaluation described above.
DUKE consnitted to include appropriate
references in the EPA EQ files to analyses prepared for them. This
is identified as Open Item 50-369,370/86-20-10.
Observations pertaining to specific files are as follows:
(1) Barton 386A Transmitter (MCM1210.04-0226) The qualification
criteria for this file is NUREG-0588 Category II. The file has
Wyle test report No. 43904-1.
The file included information
from Barton that the instruments were electrically similar to
the Model 764 (except different temperature compensation) and
"TEFZEL 200" was used for the instrument leads.
The reviewer
identified the following concerns:
a.
The circuit boards on specimens 2 and 3 were modified after
the retest inspection.
It was not clear whether this
modification was consistent with the installed configu-
ration of the instrument or how it affected the validity of
the results.
b.
Specimen #3 was considered to have failed randomly during
the test, but the cause of the failure was not adequately
explained, nor was the conclusion of random failure fully
substantiated.
c.
Anomalous readings from the post irradiation functional
test and the accident data were attributed to cracks in the
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lead wires
ostensibly caused
by excessive
radiation
exposure and handling.
The problems were considered to be
test artifacts not applicable to installed equipment.
The above anomalies and explanations provided in the file render
the test results inconclusive. Therefore, there was insufficient
,
information in the file to clearly demonstrate satisfactory
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accident performance and establish qualification.
DUKE provided
the NRC auditors with additional
technical
information justifying the McGUIRE application of the Barton
386A.
DUKE also committed to augment the qualification file
with an analysis of similarity to the Barton 764 transmitter. A
draft of the analysis was reviewed and found to be acceptable.
DUVE failed to adequately explain all test anomalies and to
demonstrate that they did not indicate common mode failures or
that they did not invalidate the test results upon which the
Barton 386A qualification was based. Neither did DUKE establish
qualification by other means such as by similarity to success-
fully tested transmitters.
This is identified as Potential
Enforcement / Unresolved Item 50-369,370/8,6-20-05.
- (2) Rockbestos SR Silicon Rubber Insulated Cable qualified under
file MCM-1354.00-0042 001 to NUREG-0588 Category II based on the
Rockbestos SR test report dated March 2,1978.
There was no
analysis using any of the options of IN 84-44 to augment the
original test report or establish qualification separately. The
file did contain a memo indicating DUKE was awaiting the results
of the Rockbestos retest of SR cable.
Qualification was
contingent on its success.
This test has not yet been done.
DUKE's position was that all retest results have validated the
' original test conclusions.
DUKE considers the original test
conclusions of the Rockbestos SR cable to be valid.
This issue
is discussed in paragraph 4.A(1) above under IN 84-44. DUKE's
failure to provide analysis in the Rockbestos file to augment
the Rockbestos data and evaluate margins or to provide other
qualification reports to support qualification is identified as
Potential
Enforcement / Unresolved
Item
50-369,370/86-20-06.
DUKE
presented
the
inspection
team
with
supplemental
documentation to show the substantial conservatism for the
McGUIRE applications. This documentation will be filed with the
applicable Rockbestos qualification files.
Upon completion of
remaining
Rockbestos
retests,
applicable
files
will
be
supplemented with the test reports.
(3) Samuel Moore PVC insulated instrument Cable qualified under file
PCM 1354.00-0022 001 to NUREG-0588 Category II. The file had
DUKE test report TR-032.
The test was performed with Brand Rex
PVC cable.
Qualification was claimed for Brand Rex and Samuel
Moore cable with a statement of generic material similarity.
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The worst case plant Parameters were for 300 F and 0.9 x 10
RADS.
The file did not support qualification because generic
material
qualification
is generally unacceptable in harsh
environments and its use was not justified in the file.
DUKE indicated that the parameters listed were much more severe
than the actual environment the Samuel Moore cable is exposed
to.
They contended the actual environment would be below the
threshold values for the onset of temperature and radiation
degradation.
In addition,
the temperature and radiation
environments occur during different accident scenarios.
DUKE
had prepared an analysis to justify generic qualification of PVC
in a draft revision to the Limitorque files.
The revision to
the Samuel Moore PVC file was reviewed prior to the end of the
inspection.
It included parameters for the Samuel Moore cable
and an analysis which included the arguments described above.
The file as originally reviewed was deficient in that no such
analysis had been included.
This is identified as Potential
Enforcement / Unresolved Item 50-369,370/86-20-07.
E.
Plant Physical Inspection
The NRC inspection team, physically inspected 25 components at
McGUIRE.
The
inspection
team examined characteristics such as
mounting configurations, orientation,
interfaces, model numbers,
ambient environment, and physical condition. Results of the walkdown
inspection are discussed below:
(1) Eleven cables were selected by the inspectors to evaluate
McGUIRE's
cable
traceability.
McGUIRE personnel
produced
documentation which demonstrated them all to be qualified.
(2) Limitorque SMB000 MOVs
with Class RH Insulation
TAG Numbers
IVX0001A and IVX0002B located in containment in Unit I which
operate the H skimmer fans' suction dampers between upper and
lower contai
nt were inspected.
(file MCM-1205.34-0002/
Limitorque Test Reports B0058 and 600376A) The inspector noted
that:
Jumper wires on torque switches or limit switches could not be
positively identified, although some appeared similar to field
cables.
Raychem splices on motor leads had 180-degree bends with bend
radii about equal to the splice diameter.
The grease relief valve shipping caps had not been removed from
either valve operator af ter operator installation.
Maintenance related items noted included:
(a) Several terminal
lugs on the limit switches were bent back 180 degrees from the
direction in which the lug was installed, thus placing bare
wires in close proximity to the limit switch compartment cover.
(b) M0V IVX001A had damaged insulation on one motor lead.
(c) Two of the flex conduits were damaged to M0V IVX001A.
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(d) A wire on MOV IVX002B was pinched between the limit switch
housing cover and the limit switch housing base.
(e) The limit
switch phenolic on MOV IVX002B was damaged on one of the upper
corners.
(f) Cleanliness and preservation of limit switch
compartment internals, cable and jumper wire routing, and
workmanship were poor.
(3) Limitorque SMB00 MOV
with Class B Insulation,
TAG
Number
1RN0086A, located in the auxiliary building and used in the Unit
1 Nuclear Service Raw Water System to provide Unit I component
cooling heat exchanger isolation (file MCM 1205. 34-0002/
Limitorque Test Reports B0058 and B0003) had two unidentified
jumper wires on the limit switch which did not resemble field
run cable or qualified wire in the MOV.
(4) Limitorque SMB000 MOVs
with Class RH Insulation TAG Numbers
INSSV5560, 5570, 5580, and 5590 located in the annulus in Unit 1
provide containment isolation for the containment spray system
(file MCM-1205.34-0002/Limitorque Reports B0058 and 600376A)
were examined externally.
Only 1NSSV5560 could be inspected
internally.
INSSV5560 had one unidentifiable white jumper wire on the limit
switch.
The jumper did not resemble the field cable or the
qualified wire in the MOV.
INSSV5570 still had its grease relief valve shipping cap on.
(5) Limitorque SMB00 MOVs
with Class RH Insulation
TAG
Numbers
ICA00388, ICA00508, ICA0054AC, and ICA0066AC located in the Unit
I doghouse are used in the Auxiliary Feedwater System to provide
feedwater line break isolation for steam generators. (file MCM
1205.34-0002/Limitorque Test Reports B0058 and 600456)
1CA0038B and ICA0054AC had one unidentified white jumper wire on
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each of their limit switches.
These wires (marked "149-9046
6-149" in ICA0054AC) resemb?ed neither the field run cable nor
the qualified wire in the MOVs.
ICA00508
ICA0054AC, and ICA0066AC still had their grease
,
relief shipping caps.
(6) 2RN01878 located in the Unit 2 auxiliary building which provides
No. 2B Component Cooling Water Heat Exchanger supply isolation
had two unidentified white jumper wires on the limit switch.
The jumpers resembled neither the field run cable nor the
qualified wire in the MOV.
(7) 2RN0279B located in the Unit 2 auxiliary building which provides
No. 2B Essential Cooloing Water Return Header isolation had two
unidentified white jumper wires on the limit switch.
The
jumpers resembled neither the field run cable nor the qualified
wire in the POV.
Paragraphs 4.E(2) through 4.E(7) relate to Potential Enforcement /
Unresolved Item 50-369,370/86-20-01 cited in paragraph 4.A(1).
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(8) DUKE provided an analysis during the inspection to show that the
shipping caps would not impsir the ability of the grease reliefs
to perform their safety function during the postulated accident.
DUKE later reported that the analysis has been fomalized and
included in EQ files.
Work requests were written to assure all
shipping caps are removed.
A specific instruction was to be
added to the Limitorque Installation / Instruction Manual
to
require removal of the caps at the time operators are wired for
power.
This is identified as Potential Enforcement / Unresolved
Item 50-369,370/86-20-02.
(9) The inspector examined eight Raychem splice heat-shrink sleeving
installations including three (S0Vs ISMSV0034,
ISV0191 and
ISV0192) which had been previously inspected by McGUIRE.
The
inspector confirmed McGUIRE's findings on 1SMSV0034, but where
McGUIRE inspectors had found the sleeve bend radius satisfactory,
i.e., at least five times the sleeve outside diameter (0.D.), at
SOVs ISV0191 and ISV0192 in the Unit 1 doghouse, the NRC
inspector observed splice sleeving on pigtails at both SOVs to
be bent at least 90* with radii about equal to zero.
The NRC
inspector observed no radial cracks in the. sleeving. The reason
resolved, but no other
for the differing observations was not, d
differing
observations were noted an
McGUIRE maintenance
personnel documented the problems and committed to take appropri-
-
ate action.
The results of the other splice sleeve inspections
in the Unit I doghouse were as follows:
(a) ASCO S0V ISMSV0014 had one pigtail splice bent into an "S"
with radii equal to one times sleeve 0.D.
No cracks were
observed.
(b) Borg Warner feedwater
isolation valve actuator ICF35
splices were satisfactory.
Results of the ~ inspection of Raychem sleeves in Unit I upper
i
containment were as follows: (Note that these components' pig-
!
tail splices were in condulets in stead of junction boxes.)
(c) ASCO containment isolation S0V IVPSV0020 had satisfactory
splice sleeves.
(d) ASCO containment isolation 50V IVpSV0040 sleeves were over
pigtail braided jackets and bent to 180* on one side of the
butt connectors with one-tenth 0.D. radii.
(e) ASCO containment isolation 50V IVPSV0060 sleeves were bent
90* to 180* with 1 - 1 0.D. radii. Sleeves were stuffed so
tightly into the condulet that the inspector could not see
if they were installed over braid.
The observed Raychem discrepancies listed above constitute
Potential Enforcement / Unresolved Item 50-369,370/86-20-03.
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