ML20214W409

Insp Repts 50-369/86-20 & 50-370/86-20 on 860728-0801.Major Areas Inspected:Implementation of 10CFR50.59 Program for Environ Qualification of Electrical Equipment Important to Safety.Potential Enforcement/Unresolved Items Noted

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: ML20214W378 ML20214W409
References
50-369-86-20, 50-370-86-20, NUDOCS 8612100215
Download: ML20214W409 (17)

See also: IR 05000369/1986020

Text

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J"' U.S. NUCLEAR REGULA10DJ COMMISSION

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Report No.: 50-369,370/86-20

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J, Docket No.: 50-3M , 50-370

. I License No.: NPF-9, NPF-17

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'. Licensee: .- . Juke Power Company

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/ Post Office Box 33189

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' Tharlotte, North Carolina 28242

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Facility Name: McGuiid Nuclear Station, Units 1 and 2

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.1, . Inspection At: . Duke Power Company, Nuclear Design Engineering

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522 South Church Street, Charlotte, North Carolina

N McG0 ire-1 and 2

,Cornelius, North Carolina

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b Inspection Conducted:~ July 28 to August 1, 1986 e

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. Inspector:

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b.'DT Alexander, Equipment Qualification (Yate

Inspection Section (E0lS) , e

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Alsr> Sarticipathg in the inspection and cdntributing to the report were:

"- 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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' Approved by: # MMP -

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U. Potapovs, Chief, EQlSa Vendor Program Date '

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Branch, Division of Quality Assurance, '

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

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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 il ustifications for Continued Operation (JCO),. Affected equipment in

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 l

50-369,370/86-20-10 l

10. Electrical Penetration Assembly 4.A(1)

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

• 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

i L. B. Castles, Design Engineer I

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

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implementation of corrective action commitments made as a result of

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 '

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

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10 CFR 50.49, 650.49(b)(1), (b)(2) and (b)(3) and DUKE's position on and

compliance with NUREG-0588, Category II under which McGUIRE equipment

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purchased before the $50.49 effective date (February 22, 1983) must be

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

i 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

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

for EQ at McGuire and delineates the responsibilities of Design l

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.

l Other procedures which address McGuire's EQ Program are Nuclear

Production Department (NPD) Directive No. 3.3.1(M), " Maintaining

l 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

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guidance on procurement and maintenance of qualified equipment.

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,

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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

l 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-

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

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position on this issue was that all retest results thus far have

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", silicon

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. Target Rock Solenoid Valves (File EGS 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-

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 operability determinations required.

The DUKE inspections in Unit I resulted in at least partial

replacement of wire in all 32 Limitorques. According to a DUKE

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

l were found to have qualified wire. All four Limitorques in the

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" doghouses" were found to have qualified wire.

l Duke EQ personnel subsequently reported that materials analysis

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 l

blowdown producing superheated steam. The NRC had previously I

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 '

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

plant and review of the station's installation procedure. All

l problems identified during the DUKE inspections were documented

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and reported to be satisfactorily resolved. Installation proce-

l dure IP/0/A/3090/06 (change 8) included Design Specification No.

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,

l 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

their DBE. (HELB). 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

i plant personnel in Maintenance and QC. DUKE agreed to review

the need to provide this training. Pending future NRC review,

- this is identified as Open Item 50-369,370/86-20-09.

(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

Its development is described in

governs maintenance of the EQML.

Duke Power Company McGuire Nuclear Station Response to NUREG-0588.

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Equipment required to be environmentally qualified in accordance with

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.

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As a validation check of the EQML, the inspector reviewed Emergency

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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

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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.

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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

L 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

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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

i with level of qualification data and supporting documents including

test reports, IEBs and ins, calculations, analyses and memoranda.

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The NRC inspectors examined EQ files for 20 selected equipment items

to verify the qualified status of equipment within the scope of 10

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CFR 50.49. In addition to comparing plant service conditions from

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the "McGuire Nuclear. Station Plant Environmental Parameters Manual"

} with qualification test conditions and verifying the bases for these

l

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

l

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

,

i

,

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 /

l Bulletins and their resolution.

!

'

EQ Documentation File Observations

l Several examples were identified by the NRC inspection team where the

1

E0 documentation files failed to establish qualification due to

l errors, incorrect calculations, missing documents, not addressing

anomalies, incorrect SCEW sheet changes, and

'

clarifications,

'

requirements for additional documentation, which were either

12

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

___ _. .. .

__ . _ _ _

'.

resolved, still require correction, or were adequately corrected

These are identified as Potential Enforce-

,

during the inspection.

ment / Unresolved Items 50-369,370/86-20-04, 05, 06 and 07 and Open J

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-

l tutes Potential Enforcement / Unresolved Item 50-369,370/86-20-04.

l

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

13

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

. '. i

l

lead wires ostensibly caused by excessive radiation l

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 i

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.

14

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• '

.

7

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.

15

_ . _ _ _ . _ _ _ _ _ ___

. ,

(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

J 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).

16

__

.,- ..

,

(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

differing observations observations

were was not,

noted and 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.

i Results of the ~ inspection of Raychem sleeves in Unit I upper

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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