IR 05000029/1986018

Insp Rept 50-029/86-18 on 861020-24.Major Areas Inspected: Review of Licensee Implementation Program to Establish & Maintain Qualification of Electric Equipment Per 10CFR50.49

ML20215D411
Person / Time
Site:	Yankee Rowe
Issue date:	12/04/1986
From:	Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20215D382	List: IR 05000029/1986018 ML20215D379
References
50-029-86-18, 50-29-86-18, NUDOCS 8612160355
Download: ML20215D411 (13)

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.. .. U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report No: 50-029/86-18 Docket No: 50-029 Licensee No, dPR-3 Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Rowe Nuclear Power Plant Inspection At: Framingham and Rowe, Massachusetts Inspection Conducted: October 20-24, 1986 Inspector: Mon 2 ws /2/S/[[ G. T. Rubbard, Equipment Qualification & Test Engineer Date

. Also participating in the inspection and contributing to the report were:

L. Cheung, Reactor Engineer, RI M. Dev, Reactor Engineer, RI 0. P. Gormley, Equipment Qualification and Test Engineer M. J. Jacobus, Member of Technical Staff, Sandia National Laboratories D. E. Jackson, Senior Engir.eer, Idaho National Engineering Laboratory (INEL) W. R. Carpenter, Senior Engineer, INEL f Approved by: b U. Potapovs, Chief, Equip

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INSPECTION SUMMARY Inspection on October 20-24, 1986 (Inspection Report No: 50-029/86-18) Areas Inspected: Announced inspection to review 'the licensee's implementation of a program for esbeblishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.4 ' Results: The inspection determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49, except for the deficiency listed belo Report Item Name Paragraph Number Potential Enforcement / Unresolved Item: Qualification of Outside , Containment Limitorque Operator Internal Control Wiring 4.0.(2)(a) 50-029/86-18-01 ,

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DETAILS Persons Contacted: 1.1 Yankee Atomic Electric Company (YAEC) -

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 *L. H. Feider, Vice President
 * G. Jones, Engineering Manager   "
 *N. N. St.Laurent, Plant Superintendent
 *D. A. Hansen, Manager, Plant Engineering Department
 *J. D. Haseltins, Project Manager
 *R. L. Boutwell, Senior Technical Services Engineer S. F. Urbanowski, Maine Yankee E0 Coordinator
 *M. P. Saniuk, Vermont Yankee, 18C and EQ L. D. French, Plant Engineer R. Rossman, Lead 18C Engineer
 *S. P. Fournier, Lead Systems Engineer
 *R. M. Mitchell, Maintenance Support Supervisor
 *R. R. McCoy, Electrical Lead Engineer
 *L. F. Richardson, 18C Engineer
 *P. E. Laird, Plant Maintenance Manager
 *B. L. Drawbridge, Assistant Plant Manager
 *G. Papanic, Jr. , Licensing Engineer
 *L. X. Bozek, Quality Control Supervisor
 *M. E. Gilmore, Quality Assurance Engineer
 *R. A. Mellor, Chemistry Manager, Acting Technical Director E. Carlson, Manager Plant Maintenance D. Fogarty, Maintenance Engineer W. Lommis, Maintenance Engineer E. Begiebing, Maintenance Supervisor C. Johnson, Senior ISC Foreman R. Dobosz, Storekeeper D. Neuman, Quality Assurance Engineer D. Pike, Quality Assurance Manager M. Schuster, Quality Control Engineer 1.2 YAE Contractors:
 *D. E. Kosack, Engineer, Stone & Webster Engineering Corporation
 *L. Gradin, Director of Engineering, EcoTech, In .3 NRC:

E McKenna, Project Manager, NRR

 *J. P. Durr, Chief. Engineering Branch, Region I
 *H. Eichenholz, Senior Resident Inspector l
* Denotes those present at exit meeting i

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. .. PURPOSE:

The purpose of this inspection was to review the licensee's implementation of a program meeting the requirements of 10 CFR 50.49 for Yankee Rowe

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Nuclear Power Plan ' 3. BACKGROUND: The NRC held a meeting with YAEC on January 17, 1984, to discuss the licensee's proposed methods to resolve the deficiencies identified in the Safety Evaluatiori Report (SER) dated December 16, 1982, and Franklin Research Center (FRC) Technical Evaluation Report (TER) dated May 28, 198 Discussions also included YAEC's general methodology for compliance with 10 CFR 50.49 and Justification for Continued Operation (JCO) for those equipment items for which environmental qualification was not complet Minutes of the meeting and proposed methods of resolution for each of the equipment qualification (EO) deficiencies were documented in the licensee submittal dated March 5,1984. The final EQ SER for Yankee Rowe was issued on December 12, 198 . FINDINGS: The NRC inspectors examined the licensee's program for establishing the qualification of electric equipment within the scope of 10 CFR 50.49. The program was evaluated by examination of the licensee's qualification docu-mentation files, review of procedures for controlling the licensee's EQ activities, verification of the adequacy and accuracy of the licensee's 10 CFR 50.49 equipment list, and examination of the licensee's program for maintaining the qualified status of the covered electric equipmen Based on the inspection findings, which are discussed in more detail below, the inspection team determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.4 E0 Program Requirements (1) The NRC inspectors examined the implementation and adequacy of the licensee's EQ prugram for establishing and maintaining the environmental qualification of electric equipment in compliance with the requirements of 10 CFR 50.49. The following licensee procedures were reviewed by the inspector YA-GEN-11. " Specification for the Design Guidance for Environmental Qualification of Electrical Equipment," Revision 1, undate YRP-QP-004, "The Preparation, Review and Approval of Qualification Documentation Review (QDR) Packages," Revision 1, undate YRP-EQP-003, " Procedure to Assess Oualification Documentation, for Safety-Related Electrical Equipment Located Outside Containment," Revision 3, undate YRP-EQP-002, " Equipment Walkdown Verification Procedure," Revision 1, dated August 25, 198 i _ . . . _ _ _ _ , . - - - _ ..._ . _ . _ _ _ _ _ - , _ _ _ . _ _ , _ _ _ _

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WE-100, " Engineering Instruction - Engineering Design Change Request," Revision 13, dated October 8,1985 WE-101, " Engineering Instruction - Plant Design Change Request," Revision 7, dated October 8, 1985 AP-0020, " Operating Information Review," Revision 4, dated September,1985 , AP-0100, " Environmental Qualification Program," Revision 0, dated June,' 1986 AP-0200, " Design Changes and Alterations," Revision 8, dated November,1984 AP-0205, " Maintenance Request," Revision 10, undated AP-0211, " Material & Service Procurement Program," Revision 14, dated January, 19,86 AP-0212 " Control of Purchased Material, Equipment and Services," Revision 12, undated AP-0214, " Maintenance and Change of Safety Classified Systems, Components, or Structures," Revision 10, dated April,1985 AP-0001, " Plant Procedures and Instructions," Revision 12, undated (2) The licensee's program was reviewed to determine that adequate procedures had been established to meet the requirements of 10 CFR 50.49. Program procedures were reviewed to evaluate procedural methods and their effectiveness for:

(a) Requiring all equipment that is located in harsh environ-ments and is within the scope of 10 CFR 50.49 to be included on the list of equipment requiring qualification (E0 Master List).

(b) Controlling the generation, maintenance, and distribution of the EQ Master Lis (c) Defining and differentiating between mild and harsh environ-ments.

 (d) Establishing harsh environmental conditions at the location of equipment through engineering analysis and evaluatio (e) Establishing and maintaining a file of plant condition (f) Establishing, evaluating, and maintaining EQ documentatio (g) Training personnel in the environmental qualification of equipmen _ _ . - _ _ _ _ _ . _ _ _ _ _ _ . _ -.__ ___ _

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(h) Controlling plant modifications such as installations of new and replacement equipment, and providing for t.pdating replacement equipment to 10 CFR 50.49 criteri (3) Procedure AP-0100 establishes the EQ program for Yankee Row It eCablishes the interfaces between existing plant procedures, provides guidance for replacement of EQ equipment, identifies procedures that address specific EQ considerations, assigns plant responsibilities, and implements appropriate addiinistrative controls to ensure that equipment qualified status is maintaine AP-0100 als'o establishes spare part, new equipment, and storage requirements for qualified equipment. EQ maintenance and modi-fication requirements on EQ equipment are addressed by AP-0100; as well as, E0 training requirements. Other elements of the E0 program include the following:

Report YAEC-1227, "EQ of Safety Related Equipment," which documents the review of the plant emergency / operating procedures that were used to determine what equipment was to mitigate the effects of loss-of-coolant necessary(LOCA) and High-Energy-Line Break accident The " Equipment Review Board" which verified the initial and ongoing maintenance and surveillance EQ program to ensure compliance with internal requirement Procedure YA-GEN-11 which provides guidance to assure that EQ is factored into the design proces The " Safety Classification of Systems Manual" which provides the methods for identifying environmentally qualified equipment to plant personne ' The " Yankee Operational Quality Assurance Program (Y00AP-1-A)" and its implementing procedure AP-0288, " Quality Assurance Program," which provide a cuality assurance prograrr. for the design, fabrication, construction, and testing of safety related equipment and equipment requiring quality assuranc (4) The licensee has developed two procedures (WE-100 and WE-101) which use engineering design change requests (EDCRs) and plant , design change requests (PDCRs) to control modifications of structures, systems, and components at Yankee Rowe. In addition, procedure YA-GEN-11 provides specific directions to ensure that EQ considerations are factored into the design change and modi-fication process. The instructions and the procedures delineate responsibilities and prescribe methods for initiation, preparation, review, and approval of design changes and modifications. Subse-quent revisions to design change and modification documentation undergo the same review and approval process as the origina The licensee has processed several EQ related modifications at i the plant; however, no completed modification packages were available for NPC review during this inspection. The inspectors

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reviewed an operation quality inspection document for EDCR No. 84-301, " Equipment Replacement for Environmental Qualification," to evaluate its adequacy and no deficiencies were identifie (5) Administrative procedure AP-0211 establishes measures necessary to en'sure that applicable regulatory requirements are included ~ in the procurement of materials, equipment, and services. The inspectors reviewed the following procurement ddcuments to evaluate the adequacy of the licensee's EQ related procurement activities:' MPR, 86-50A-1 P0, QA-40014, Ca'pacitor/ Filter (HRRM)

MPR,86-7QA-5 P0, QA-40050, PASS Modification MPR, 86-7QA-14 P0, QA-40051, Cow Corning Sylgard-186

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The applicable 10 CFR 50.49 requirements were found to be identified in the procurement documents. They were verified during receipt inspection for vendor compliance at the plan Engineering assistants in the procurement department conduct programmatic receipt inspections. For detailed receipt inspec-tions, the cognizant engineer and his supervisor are responsible i to conduct the receipt inspections to verify that the materials

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meet the requirements and are acceptable. Within the procurement areas reviewed no deficiencies were identified by the NRC inspectors.

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  (6) The licensee has a comprehensive EQ related training program. The
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Nuclear Services Division (NSD) project manager is responsible for i developing this training program and providing E0 training and

indoctrination to the engineering staff performing EQ related

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quality control activities. At Yankee Rowe, the plant superintendent j is responsible for the evaluation and implementation of EQ training ' for plant personnel. The E0 training program provides an over-view of the licensee's EQ program requirements, qualification ! methodology, equipment testing, and the implementation of regu-latory and industry guidelines. At the conclusion of training, ) a test is conducted to assess the participants' familiarity and j understanding of the program. The NRC inspectors reviewed the

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licensee's training program attendance roster and the training records of NSD staff, plant operations and maintenance staff, and the licensee's EQ consultants (EcoTech and Stone and Webster) No deficiencies were identified.

, cognizant staff.

. ! (7) Operation quality assurance (00A) reviews all EQ related EDCRs l and PDCRs to verify the adequacy and effectiveness of the program ' in accordance with procedures WE-100 and WE-101. 00A also conducts verification, surveillance, and monitoring of mainten- , l ance activities of safety class equipment. The NRC inspectors j reviewed the following OC inspection reports: ! !

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0QC-YR-86-199, " Limit Switch Wire Replacement" 00C-YR-86-214, " Jumper Replacement" 0QC-YR-86-215. " Jumper / Wire Replacement" 0QC-YR-86-263, " Limit and Torque Switch Wiring Replacement" 00C-YR-86-366, "Raychem Shrink Tube Installation" NSD QA performs audits of procurement document control, including preparation, review, and approval of purchase requisitions for materials, equipment, and services covered by the 00A progra The licensee conducted an internal QA audit to evaluate their EQ

'  program's c'ompliance with 10 CFR 50.49, Reg. Guide 1.89, IEEE-323-1974, and ANSI N18.7. The audit identified a total of four deficiencies and five observations in the areas of EQ document-ation, maintenance and surveillance procedures, and trainin The inspectors reviewed the audit report and determined that the audit was well planned and comprehensive, and the licensee's corrective actions were adequate and timely. No deficiencies were identified in this are . EQ Maintenance Program The EQ maintenance program for Yankee Rowe is defined in AP-021 It identifies and establishes EQ maintenance requirements to ensure that equipment qualified status is maintained. Implementation of these requirements is accomplished as follows:
(1) The EQ maintenance requirements for specific equipment is iden-tified by the EQ engineer and transmitted to the Yankee Rowe maintenance support group of the maintenance department. This group has the responsibility to develop a maintenance procedure to prescribe required steps for maintenance activities. There are two groups responsible for performing E0 maintenance activ-ities, the instrumentation and control (I&C) group and the main-tenance group which is responsible for electrical equipmen Twenty-four I&C maintenance procedures and eleven electrical maintenance procedures have been developed by the maintenance support group. The inspectors reviewed the following seven procedures for adequacy:

' I&C procedures: No. 6219, "Maintenence of Rosemount 1153B Transmitters," Revision 2, dated May, 1986 No. 6375, " Environmental Equipment Qualification and/or Maintenance of the Comsip KIII Hydrogen Monitor (HV-GA-2)," Revision 1, dated May, 1986

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No. 6854, ATTA "EQ Preventative Maintenance of ASCO Solenoid Valves That are Part of the EQ Program," Revision 1, dated May, 1986 No. 4605, " Steam Generator Narrow Range Water Level Channel Calitration," Revision 14, dated May,1986

Electrical procedures: , No. OP-5101, " Maintenance of Motor Operated Valves," Revision 9,' dated July,1986 No. OP-4517. " Surveillance of Motor Operated Valves," Revision 9, dated October,1986 No. OP-5351, " Maintenance of HPSI Pumps or Motors, P49," Revision 7, dated July, 1986 (2) Both the 18C and electrical maintenance groups have their own computerized mairitenance tracking system to minimize possible overdue maintenance problems. Routine maintenance activities (e.g., instrument calibrations or motor lube oil inspections) are performed within the responsible maintenance group. When non-routine maintenance activities (e.g., replacing an existing solenoid in a solenoid valve) are required for a component, a maintenance request (MR) is issued by the plant staff who identifies the required maintenance. When this MR is approved, it goes to the responsible maintenance group supervisor who directs the craftsman to complete the specified maintenance activities using the specified procedur Appropriate hold points are prescribed in the maintenance proce-dures to have the work inspected by the quality control inspecto The NRC inspectors reviewed the following maintenance activities: MR #86-937, " Replace Limit and Torque Switch Wiring," dated June 27, 1986

 " Surveillance of Motor Operated Valves CS-533, PR-558, PR-559, and PR-560 using procedure No. OP-4517," dated November 14, 1985 No deficiencies in the licensee's maintenance program were identified within the areas reviewe CFR 50.49 List (E0 Master List):

The licensee is required to establish and maintain an up-to-date list of the equipment that must be qualified under 10 CFR 50.49. At Yankee Rowe the EQ List (EQL) is maintained by the NSD and is controlled by procedures, which ensure approval prior to the implementation of changes proposed by plant operating staff. Considered in the prepa-j ration and maintenance of the E0L are environmental effects resulting i i

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from all of the postulated design basis accidents (DBAs) documented in l the Final Safety Analysis Report and the associated operating procedure The design of the Yankee plant resulted in the identificaticn of only two of the fifteen accident categories which required electric equip- . ment to operate in a harsh environment. These were the LOCA and main l steam line and main feedwater breaks in containment. The methodology l used by YAEC in developing the EQL is described in procedure YAEC-122 The NRC inspectors performed an audit of the EQL to determine its validity. The inspectors reviewed the current procedures list and controlled copies of operating procedures to identify the equipment items which are required to function during and following certain DBAs. Since a LOCA is the only accident at Yankee which requires operating type equipment (e.g. pumps and valves versus instruments and sensors) to function in a harsh environment, the inspectors reviewed LOCA Procedure OP 3106, revision 28, and its subtier proce-dure The inspectors' evaluations determined that the licensee had established an E0 list and had implemented procedures to maintain the list in an up-to-date status. No deficiencies in the licensee's list were iden-tified during the revie Environmental Oualification Files (1) The files were examined to verify the qualified status of equip-ment within the scope of 10 CFR 50.4 In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selec- ' tively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified; similarity 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); evalu-ation of adequacy of test conditions; aging calculations for i l qualified life and replacement interval determination; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated equipment accuracy; evaluation of test anamolies; and applicability of EQ problems reported in IE l Information Notices (ins)/ Bulletins and their resolutio The inspectors reviewed 24 qualification files associated with i 24 equipment items for the plant. At Yankee Rowe the document-ation which supports qualification of each equipment item is l contained in qualification document review packages (ODRs) or l equipment qualification assessment packages (EQAs). An equip-i ment item is defined as a specific type of electric equipment, ' designated by manufacturer and model, which is representative of all identical equipment in a plant area exposed to the same environmental service conditions.

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No significant deficiencies were identified by the inspectors during the QDR/EQA review; however, the inspectors recommended ,

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that minor corrections or clarifications be made to four QDRs: Electrical Machinery Motor-QDR 0363; Westinghouse Cable Penetration-QDR 1051; and Marathon ~ and Weidmuller Terminal Blocks-0DRs 0965 and 0968-1. The licensee stated that he would make the recommended changes and in all cases he provided the inspectors with draft changes to the QDRs prior,to the end of ; the inspection. The inspectors reviewed the draft changes and determined ,that they incorporated the inspectors' reconinendation (2) IE Information Notices and Bulletins: The NRC inspectors reviewed twelve information notices (ins) to evaluate the licensee's acti-vites relative to the review of EQ-related ins / Bulletins. The inspectors determined that the licensee has established procedures and a system for distributing, reviewing, and evaluating ins / Bulletins relative to equipment within the scope of 10 CFR 50.4 Administrative pr,ocedure AP-0020 delineates the organizational responsibilities for the review of the information pertinent to plant safety, including EQ related ins / Bulletins. It provides a mechanism for documenting action to ensure that proper assimil-ation of information to the cognizant plant personnel is achieved through an update of procedures and training of personnel as required. Accordingly, an evaluation coordinator from the tech-nical services department (TSD) screens ins / Bulletins for further evaluation by the cognizant EQ project personnel. TSD reviews the completed evaluations for their adequacy and completeness, and forwards the evaluation reports to the plant operational review committee (PORC), cognizant plant entities or NSD for an additional review, if required. The final, completed evaluation of ins / Bulletins is forward to the plant superintendent, NSD project manager, and the administration department. The oper-ational quality assurance department conducts audits to verify the effectiveness of the licensee's program on an annual basi The inspectors also determined that the licensee has established a file and an action tracking system for ins / Bulletin (a) The inspectors review of the licensee's activities relative to IN 83-72 (Notice No. 24) and 86-03 concerning Limitorque motor operated valves determined that the licensee believed that Limitorque operators installed at Yankee Rowe were qualified based on vendor qualification reports. The licen-see assumed that these reports covered all parts of the equipment including internal wiring.

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. .- .. When the licensee received IN 86-03, he started an evalua-tion of his qualified Limitorque operators which included an inspection of qualified operators during an outage in April 1986. This inspection determined that wiring instal-led in the one qualified inside containment operator was jualified; however, the wiring in the three qualified out-side containment operators was not directly traceable to qualification testing. The wiring in the gutside contain-ment operators was identified as polyvinylchloride (PVC) insulated wire (type TEW and TFF) except for two black wires which 'could not be positively identified as being PV Based on the inspection findings, the licensee did an evalu-ation of the qualification of the PVC wires (qualification was required to D0R Guidelines) and determined that they were qualified to the plant's outside containment accident conditions of 120.4*F and 3.5 megarads of radiation maximu This evaluation was documented in calculation number YRC-480, dated May 19, 198 Since the tM black wires could not be positively identified as being PVC, the licensee replaced them with qualified Rockbestos SIS wire in June 1986. Additionally, the licen-see replaced all the PVC wiring with Rockbestos SIS at the same time. The NRC inspectors determined during the plant physical inspection that qualified wiring was installed in the three outside containment operator The licensee's failure to identify outside containment Limitorque operator wiring and establish its qualification or replace it with qualified wire prior to the Yankee Rowe qualification deadline of June 1984 or (with NRC staff approved extensions) of November 30, 1985 and operation of the plant until wiring qualification was established in June 1986 is identified as Potential Enforcement / Unresolved Item 50-029/86-18-0 (b) The inspectors review of IN 86-53 concerning Raychem splices determined that the licensee had evaluated the installation of Raychem splices at Yankee Rowe. The licensee's evalua-tion included reviews of vendor installation requirements, plant splice installation procedures, plant splice instal-lation records, and physical inspection of splices on about 1/3 of the equipment which use Raychem splices. The licensee's evaluation determined that Raychem splices had been installed properl The NRC inspectors reviewed licensee documentation regarding Raychem splices and identified no problems. The licensee only uses the splices for inside containment application Since the plant was operating during the inspection, the inspectors were unable to physically inspect splice instal-lation < .. .- N E. Plant Physical Inspection The plant physical inspection consisted of the examination of ten types of qualified safety-related electric equipment located outside - containment. Since the plant was operating during the inspection, examinatiqp of equipment located inside containment was not possibl The inspectors examined characteristics such as mounting configuration, ' orientation, interfaces, model number, environment, and physical condition. No concerns were identified during the walkdown inspectio ,

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