ML20215E905
| ML20215E905 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/11/1986 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20215E843 | List: |
| References | |
| 50-313-86-23, 50-368-86-24, NUDOCS 8612230163 | |
| Download: ML20215E905 (18) | |
See also: IR 05000313/1986023
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
0FFICE OF INSPECTION AND ENFORCEMENT
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Report No.:
50-313/86-23 and 50-368/86-24
Docket No.:
50-313 and 50-368
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Licensee:
Arkansas Power & Light Company
Post Office Box 551
Little Rock, Arkansas 72203
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Facility Name:
Arkansas Nuclear One, Units 1 and 2
Inspection Conducted:
July 14-18, 1986
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Inspector:
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R. C. Wilson, Equipment Qualification
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and Test Engineer
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Also participating in the inspection and contributing to the report were:
U. Potapovs Chief, Equipment Qualification Inspection Section, I&E
R. E. Ireland, Chief Engineering Section, Region IV
J. E. Bess, Reactor Inspector, Region IV
D. E. Norman, Reactor Inspector, Region IV
J. M. Fehringer, Engineering Specialist, Idaho National Engineering Laboratory
M. Trojovsky, Consultant Engineer, Idaho National Engineering Laboratory
J. Grossman, Member of Technical Staff, Sandia National Laboratories
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Approved By:
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I?_/ tim /;
U. Potapbys Chief Equipment Qualification
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Inspection Section, Vendor Program Branch
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8612230163 861211
ADOCK 0500
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INSPECTION SUMMARY
Inspection dn July 14-18, 1986 (Inspection Report Nos. 50-313/86-23
and 50-368/86-24) -
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Areas Inspected: Special, announced inspection to review the licensee's
implementation of a program per the requirements of 10 CFR 50.49 for
establishing and maintaining the qualification of electric equipment within
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the scope of 10 CFR 50.49.
Results: The inspection determined that the licensee has implemented a program
to meet the requirements of 10 CFR 50.49, except for certain deficiencies
listed below.
Name
Report Paragraph
Item Number
Potential Enforcement / Unresolved Items:
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1.
Limitorque operators
4.D(1)
50-313/86-23-1;
50-368/86-24-1
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2.
Rockbestos coaxial cable
4.D(2)
50-313/86-23-2; -
50-368/86-24-2
3.
Instrument accuracy
4.D(3)
50-313/86-23-3;
50-368/86-24-3
4.
Amphenol penetration assembly
4.D(4)
50-368/86-24-4
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Open Items:
1.
Eaton cable
4.D(5)
50-368/86-24-5
2.
BIW Bostrad cable
4.D(6)
50-313-86-23-4
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Rotork operator
4.0(7)
50-368/86-24-6
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DETAILS
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1.
Persons Contacted
1.1 Arkansas Power & Light Company (AP&L):
- T. G. Campbell, Vice President Nuclear Operations
M. L. Pendergrass, Vice President Generation Engineering
- D. R. Sikes, General Manager Generation Engineering
- J. Levine, Director Site Nuclear Operations
T. Cogburn, General Manager Nuclear Services.
- L. W. Humphrey, General Manager Nuclear Quality
- J. T. Enos, Manager Nuclear Engrg. and Licensing
- C. H. Turk, Supervisor Nuclear Engrg.
- M. W. Cawthon, Manager Electrical Engrg.
- A. J. Wrape III, Manager Nuclear Services
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- J. McWilliams, Manager Site Maintenance
- P. Jones, Superintendent Site Maint. (Acting EQ Coordinator)
- G. Holt, Site Maintenance Coordinator
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- D. Howard, Special Projects Manager
- H. R. Rothwell, Manager I&C Engrg.
- R. O. Oakley, Supervisor I&C Engrg.
- W. Cottingham, Supervisor.I&C Engrg.
D. G._Horton, Superintendent Quality Assurance
- V. Bardwaj, Engineer Electrical Section
1.2 Consultants to AP&L
- K. Iepson, Principal Engineer, Schneider Engineering
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M. H. Philips, Attorney; Bishop, Liberman
1.3 Observers
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U.S. NRC
- R. S. Lee, Project Manager, NRR/PWR-5
- Denotes those present at exit meeting in Little Rock on July 18, 1986
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2.
PURPOSE
The purpose of this inspection was to review the licensee's
implementation of a program to meet the requirements of 10 CFR 50.49.
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3.
BACKGROUND
The NRC held a meeting with AP&L on April 26, 1984 to discuss AP&L's
proposed methods to resolve the EQ deficiencies identified in the Safety
Evaluation Reports dated January 26, 1983 for ANO-1 and April 15, 1983
for ANO-2, and in the FRC TERs dated December 28, 1987 for ANO-1 and
March 24, 1983 for ANO-2. Discussion also included AP&L's general
methodology for compliance with 10 CFR 50.49 and justification for
contirued operation (JCO) for those equipment items for which
environmental qualification was not completed. The minutes of the
meeting and proposed method of resolution for each of the EQ deficiencies
were documented in an AP&L submittal dated August 6, 1984. The final
SERs transmitted December 3, 1984 for ANO-1 and November 28, 1984 for
ANO-2 identified that certain equipment was still under JCO. At the time
of the inspection, no JCOs or extensions applied. Staff review of the
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licensee's R.G. 1.97 submittals dated June, 1984 for ANO-1 and April,
1984 for ANO-2 was in progress at the time of the inspection;
qualification of additional post-accident monitoring equipment may be
required at a future date as a result of that review.
4.
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
documentation files, review of procedures for controlling the licensee's
EQ efforts, verification of 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 electrical equipment.
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 50.49, although some
deficiencies were identified.
A.
E0 Program Procedures
The NRC inspectors examined the implementation and adequacy of the
licensee's EQ program by reviewing the following procedures and
documents (those identified by date were reviewed prior to the
inspection).
EQ Program:
ESMP #71 "EEQ Program Manual," Rev. 2, December 16, 1985.
ESD T-197 " Content of Environmental Qualification
Documentation," June 12, 1985.
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ESD T-200 " Determination of Qualified Service and
Shelf Life for Environmentally Qualified (EQ)
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Replacement Components," June 12, 1985.
ESD T-202 " Environmental Qualification Evaluations,"
September 30,-1985.
Identification:
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ESP-302 " Nuclear Licensing Document Control."
Licensing Section Procedure "EQ Master Li,st Revision
Process," Rev. 1, May 3, 1985.
ANO-1 and ANO-2 Master Lists, Rev. 3, June 17, 1986.
Evaluation:
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ESP-202 " Design Process Procedure."
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ESP-211 " Environmental Qualification Evaluation Process,"
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Rev. 1, September 1, 1981.
ESP-213 " Nuclear Procurement."
ESP-214 " Baseline Ouality Requirements."
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EEPN 00003 " Control of EQ Documents," May 30, 1985.
Design / Installation:
1000.13 " Control of Station Modifications."
1032.01 " Design Control."
1032.02 " Installation Technical Support."
1032.06 " Procurement Technical Assistance."
4001.02 " Construction Management Organization and
Responsibilities."
4001.05 " Control of Construction."
Material Management:
1000.10 " Control of Procurement."
1000.11 " Purchase Requisition Preparation and Control."
1033.01 " Receipt Inspection."
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1033.02 "" Control of Material."
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1033.05 " Spare Parts Authorization."
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1033.06 " Stores Receipt Issue and Return."
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Control of Work Activities:
'1000.24 " Control of Maintenance."
1000.50 " Control of Preventive Maintenance."
1000.09 " Surveillance Test Program Control."
1001.04 " Preventive Maintenance Program."
1001.06 " Work Control Center Planning."
1001.07 " Work Control Center Maintenance flistory."
1025.03 " Conduct of Maintenance."
1025.06 " Equipment Environmental Qualification Maintenance
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Program," Rev. 6, October 14, 1985."
1025.7 "EQ Listed Equipment-Approved Lubricants."
In addition, the NRC Inspectors were given a presentation describing the
licensee's EQ program during the entrance meeting in which requirements
and procedures covered in the above documents were discussed.
The licensee's program was reviewed to verify that adequate procedures
and controls had been established to meet the requirements of 10 CFR 50.49. Areas of the program reviewed included methods and their
effectiveness for:
Requiring all equipment that is located in harsh environments and is
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within the scope of 10 CFR 50.49 to be included on the Master List
of equipment requiring qualification.
Controlling the generation, maintenance, and distribution of the EQ
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Master List.
Defining and differentiating between mild and harsh environments.
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Establishing harsh environmental conditions at the location of
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equipment through engineering analysis and evaluation.
Establishing, evaluating, and maintaining EQ documentation.
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Training personnel in the environmental qualification of equipment.
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Controlling plant modifications including installation of new and
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replacement equipment, and providing for updating replacement
equipment to 10 CFR 50.49 criteria.
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EEQ Program Manual ESMP #71 describes the licensee's overall program for
meeting 10 CFR 50.49. It. covers the bases for identifying master list
components, definition of environmental service conditions, the qualifi-
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cation evaluation process, and documentation criteria. The EQ Master List
is supported by System Review Worksheets describing safety-related functions,
and by a verification process relating to NRC correspondence. Each Master
List component is covered by a conventional System Component Evaluation
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Worksheet (SCEW sheet). The set of SCEW sheets provides a complete summary
description of the qualified equipment and its applications. The qualifi-
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cation evaluation for each component is contained in a file package prepared
according to procedure ESP-211 (a 211 package), described further in section
4.D of this report. The 211 packages end SCEW sheets reference environmental
calculations, aging and accuracy evaluations, walkdown sheets, IEBs and IENs,
vendor test reports and the like as appropriate.
The NRC inspectors concluded that the procedures cover EQ requirements.
The EQ program appears well planned, documented, and implemented as
required by 10<CFR 50.49.
The NRC inspectors also interviewed corporate and site personnel
concerning the depth to which individuals were trained in accordance with
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10 CFR 50.49 requirements. Documents inspected included:
Farwell and Hendricks, Inc.-Safety-Related Equipment Qualification
Seminar Manual.
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Wyle Laboratories Nuclear Environmental Qualification Seminar
Instruction Manual.
Environmental Qualification Specifics - course no. AE-30800-00.
Course Outline Qualification of Safety-Related Equipment in
accordance with IEEE-323-1974.
Discussion with the licensee revealed that AP&L hired consultants to
conduct in-house seminars on environmental qualification: Ebasco in
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1981 and Farwell and Hendricks in 1984. The licensee also stated that
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office and plant staff personnel were sent to seminars conducted by Wyle
and EPRI in 1982, 1983 and 1985. Based on the EPRI seminar fomat, AP&L
conducted in-house training for personnel in plant maintenance, work
control, Quality Assurance, Quality Control, operations, and document
control. The NRC inspectors were given a list of licensee personnel who
had received EQ training. Ongoing EQ training is being performed in
accordance with plant procedures and policies. The NRC inspectors
concluded that the licensee has implemented a well planned and thoroughly
documented EQ program meeting the requirements of 10 CFR 50.49.
B.
E0 Maintenance Program
The ANO EQ Maintenance Program is an integral part of the licensee's
overall EQ program, and is specifically addressed in Procedure
1025.06. Design Change and Procurement Controls are similar to rest
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plants, and are covered in procedures cited in section 4.A of this
report. General and specific maintenance tasks are specified in
pTant instructions and scheduled for parformance by a manual program
administered at the site.
For each master list component (or group of identical components),
plant maintenance personnel have prepared a two-page EQ Data / Record
Summary Sheet describing the' component and listing all required
maintenance. Where appropriate, a sketch is included showing
interfaces such as cable entrance seal, cable type, splice
identification, and junction box designation. The set of Sumary
Sheets provides the plant with a complete description of EQ
requirements under plant control; however, procedures require that
the EQ Master List is periodically reviewed for changes, and that
headquarters identified changes to maintenance requirements are
provided to the plant. The relevant Summary Sheets are included in
all work packages involving qualified equipment, and are updated as
required following each use. Specifically, the EQ Data / Record
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Summary Sheets contain the following information:
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Component data (Manufacturer /Model #, etc.).
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Limited Life components (including start dates).
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Safety function.
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Qualification documentation references.
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Qualification Requirements.
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" Good Maintenance Practices."
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Qualification schematic.
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Maintenance References (assorted).
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Activity record for equipment condition.
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Deficiency Identification / Evaluation.
In addition to procedural reviews and personnel interviews, the NRC
inspectors on a sampling basis reviewed maintenance procedures and
records for selected componerts covered in the file reviews and plant
walkdown inspection. Based on these inspections, the inspectors
concluded that the ANO EQ maintenance program appears well planned
and implemented.
C.
E0 Master List
The licensee is required to maintain an up-to-date list of the
equipment that must be qualified under 10 CFR 50.49. Considered in
the preparation and maintenance of this list are the environmental
effects resulting from all of the postulated design basis accidents
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documented in the Updated Safety Analysis Reports; Technical
Specification limiting conditions of operation; emergency operating
pr,ocedures; Material Equipment and Parts Lists; Piping and
Instrumentation Diagrams (P&ID's); and Plant Design Change
Requests". The EQ Master List is maintained under the licensing
section procedure cited in section 4.A of this report.
In order to
test the completeness of the Master List, several components were
selected for verification.
In each case the licensee was~able to
either show that the selected equipment was 'on the Master List or
justify its exclusion, using applicable P&ID's and the EQ files.
D.-
EQ Documentation Files
As described in section 4.A of this report, the AP&L EQ
documentation centers on SCEW sheets supported by 211 files which
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include or reference supporting information such as calculations and
test reports. The 211 package format specifically addresses the
following items:
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Component identification.
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Qualification rules (upgrading).
Service conditions.
Qualified parameters.
Interfaces.
Installation details.
. Comparison of required vs. qualified.
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EQ maintenance requirements.
Affirmation of oualification.
Road Map for auditability.
The NRC inspectors examined files for 22 equipment items, where an
item is defined as a specific type of electrical equipment, designated
by manufacturer and model, which is representative cf all identical
equipment in a plant area exposed to the same environmental service
conditions. The items were selected in advance by the inspection
team and identified to the licensee during the entrance meeting.
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The files were examined to verify the qualified status of equipment
within the scope of 10 CFR 50.49.
In addition to comparing plant-
- service conditions with qualification test conditions and verifying
the bases for these conditions, the inspectors selectively reviewed
areas such as required post-accident operating time compared to the
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duration of time the equipment has.been demonstrated to be qualified;
plant (e.g., insulation class, materials of components of the equip-
ment, tested configuration compared to insta.1ed configuration, and
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documentation of both); evaluation of adequacy of test conditions;
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aging calculations for qualified life and replacement interval deter-
mination; effects of decreases in insulation resistance on equipment
performance; adequacy of demonstrated accuracy; evaluation of test
anomalies; and applicability of EQ problems reported in IE ins /
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Bulletins and their resolution,
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The files adequately documented qualification of the equipment except
as described below. Although the organization of supporting informa-
tion was less rigidly structured than at some 'other. facilities, the
inspectors were able to obtain necessary information and the files
are considered auditable.
(1) Limitorque valve motor operators, EQ Files V-33 (inside
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containment) and V-34 (outside containment) - IE Information
Notices 83-72 and 86-03 identified several internal parts or
design features of Limitorque operators as possible sources
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of qualification deficiencies. The NRC inspectors fourd that
several of the identified concerns existed in AN0-2; accordingly,
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'the inspectors carefully examined AP&L actions concerning these
two ins as part of the Limitorque operator review. At the time
of the inspection ANO-2 was shut down for refueling and ANO-1
was operating; both units had operated for several mnths early
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in 1986. None of the ANO-1 Limitorque operators had been
inspected for these deficiencies in 1986 and AP&L did not plan
to inspect them until the fall, 1986 refueling outage.
a.
Licensee evaluations before NRC inspection
The NRC inspectors reviewed AP&L intra-company correspondence
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NEC-046-38, dated April 14, 1986 to detemine the licensee's
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actions in respect to IE Information Notice 86-03 concerning
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potential unqualified Limitorque valve operator wiring. The
licensee concluded that adequate assurance existed that
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unqualified wiring in the operators did not constitute an
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insnediate safety concern for operation of ANO-1 and ANO-2
and that measures would be taken to resolve the issue by
the next refueling outage. The rationale for the conclusion
was stated to be as follows:
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(i) The majority of Limitorque valve operators in ANO-2
probably contain Canadian Standards Association (CSA)
type TEW wiring for which Limitorque is apparently
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unable to provide qualification documentation, but
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which is believed to be qualified b Limitorque
Report 600198 and Franklin Repet F-C4124.
(ii) Based on published data for testing of polyvinyl
chloride (PVC) samples it is AP&L's engineering
judgement that PVC material is generally capable of
surviving exposures greater than 10E8 rads.
(iii) A specific evaluation of Limitdrque valve operator
applications at ANO-1 and ANO-2 demonstrates that
many of the devices are not exposed to overly severe
environmental conditions.
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(iv) Based on radiation dose, temperatures and the time
during an accident for which operators are required
to function it was concluded that operators outside
containment would not be seriously challenged by the
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worst case environmental conditions. Justifications
for continued operation (JCOs) had been prepared for
inside containment operators and were a part of the
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April 14 correspondence.
The NRC inspectors found the rationale for continued
operation to be inadequate in that JCO's for inside
containment operators were not adequate (e.g., they
did not address the validity of partial test data and
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information in support of qualification, and they did
not address the possibility that failures after comple-
tien of short-term safety functions could degrade safety
functions or mislead the operator), and JCO's had not
been prepared for outside containment operators. The
NRC inspectors further noted that the AP&L evaluation
failed to consider (a) wiring that may have been
installed by third parties such as valve and system
suppliers and (b) other deficiencies identified during
the subsequent AP&L and NRC walkdown inspections, such
as T-drains and terminal blocks.
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b.
Licensee inspection results (Interim)
At the time of the NRC inspection a licensee walkdown of
ANO-2 Limitorque operators was in progress using procedures
1407.37 and 1407.38.
Information provided at the beginning of
the NRC inspection indicated that of 81 operators inspected
to date (out of 127 planned), 44 had unidentified internal
wiring, 8 lacked T-drains,13 had terminal blocks replaced,
and 6 were regreased. The NRC inspectors then requested
component-specific infomation for 20 of these operators.
Documentation for the sample of 20 operators which had been
inspected revealed the following deficiencies:
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(i)
12 operators had questionable wiring.
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(ii)
10 operators had questionable terminal blocks.
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.(iii) Three operators had questionable splices.
(iv)
Two operators which required motor T-drains did not
have the drains.
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As previously discussed, the licensee had assumed;in the
rationale presented for JCO's for ANO-1 and ANO-2 that the
majority of operator wiring was probably CSA type TEW.-
The licensee has not documented the' type of wiring removed
from operators; however, a sample shown to NRC inspectors
consisted of various marked and unmarked wires, but none
with CSA markings.
The NRC inspectors review of the lic'ensee's inspection
results noted the following concerns:
(i) Grease has been replaced for the following reasons:-
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a.
Mixing of grease types was evident.
b.
Grease was found to be contaminated.
c.
Grease was found to be hardened.
(ii) Grease reliefs were found to have shipping caps
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still installed.
(iii) T-drains were not installed on all MOVs that require
T-drain installation.
(iv) Terminal blocks have been replaced for the
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following reasons:
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Terminal blocks were found to be underrated for
adjacent point terminations.
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Terminal blocks were found to be corroded.
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Terminal blocks were found to be unidentifiable
and/or unqualified with on-hand test reports.
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(v)
Internal wires have been replaced for the following
reasons:
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a.
Internal wiring could not be identified.
b.
Internal wiring was identified as TW, TEW, or
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TFF. Qualification documentation had not been
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provided that establishes qualification of these
wires for in-containment uses.
(This is mainly
because different manufacturers use different
formulations, different inanufacturing process,
and different quality control standards. Thus,
qualification due to similarity analysis is very
difficult.)
c.
NRC walkdown inspection
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The NRC walked down six Limitorque operators which had
already been inspected during the licensee's ANO-2
walkdown. All of these operators required qualificatier
to the DOR Guidelines. The followin'g concerns were noted
for these components:
(1) Tag number 2CV-3850-2, model SMB-00-71, file V-33:
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a.
The motor T-Drains were not installed as
required by the referenced Limitorque qualifi-
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cation Test Report 600456. AP&L stated that
the T-drains are on order and will be installed
'later.
b.
The conduit entering the top of the limit switch
housing was split open. This could allow
excessive moisture buildup (the formation of a
water level) in the limit switch housing.
c.
The motor leads are terminated with blind barrel
crimp connectors. The installed conrectors could
not be identified as to manufacturer, model, etc.
In addition, the referenced Limitorque Test
Report B0119 only qualifies Thomas Betts RB-873,
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Burndy VAE-14N53, and Hollingsworth XSS-20826
terminal lugs. Limitorque stated that only blind
barrel crimps of the same family were used
during qualification testing. Also, no mention
is made concerning mounting configuration of the
test specimen crimps, which would further compli-
cate similarity analysis between the tested and
the installed crimps. The inspectors could not
verify that the installed crimps are original
Limitorque-supplied equipment.
Information
concerning these crimps was not contained in
the EQ file.
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(ii) Tag number 2CV-8233-1, model SMB000, file V-33.
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a.
The motor T-drains were not installed as
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required by the referenced Limitorque
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Qualification Test Report 600456. AP&L stated
that the T-drains are on order and will be
installed later.
(iii) Tag numbers 2CV-1560-2 (model'SMB-00-25-4T),
2CV-5613-2 (model SMB-0-15), 2CV-1074-1 (model SB-3),
and 2CV-1543-1 (model SMB-00-15-4T):
a.
Two of the limit switch to torque switch connec-
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tion wires were in direct contact with the limit
switch area heaters,
b.
Many of the installed terminal blocks could not be
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specifically identified.
c.
All limit switch compartment heaters were energized.
The qualification files do not specifically state
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that the effect of energized heaters on qualified
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life has been addressed.
d.
Additional actions
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Preliminary review of the information cited above suggested
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that continuing operation of ANO-1 during the NRC inspec-
Letter 85-15, since (i)pliance with 10 CFR 50.49 and Generic
tion might be in noncom
the ANO-2 inspection results showed
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i.nat numerous Limitorque operators in that plant had ouali-
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fication deficiencies, and there was no reason to believe
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that ANO-1 was free from the same types of deficiencies; and
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(ii) documentation reviewed during the first part of the
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inspection failed to adequately demonstrate either qualifi-
cation or justification for continued operation for ANO-1.
In response to these concerns, AP&L provided an internal
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memorandum dated July 16, 1986 and on July 18 a set of JCOs
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for ANO-1 Limitorque operators. The July 16 memo. reiterated
positions presented in the April 14 memo and orally during
the inspection, and was accompanied by extensive document-
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ation (much of it from the Nuclear Utility Group on Equipment
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Qualification).
Based on review of this material during and after inspectinn,
the NRC inspectors conclude that it still does not document
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qualification of the ANO Limitorque operators. The walkdown
information and generic material contain the basis for
addressing most of the deficiencies observed during the
inspection, but the plant-specific and component-specific
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evaluations to document qualification of specific equipment
at ANO are not complete. With regard to the ANO-1 JCOs,
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the NRC completed a review on July 22. A telephone conver-
sation with AP&L on that date resolved most of the NRC
questions. Revised JCOs were submitted by AP&L on July 31,
,
.1986, and a letter from the NRC Region IV office to AP&L
documents the acceptability of continued operation of ANO-1
until a refueling outage beginning no later than early
September, 1986.
Failure to demonstrate qualification of"Limitorque operators in
,
ANO-1 and ANO-2; and operation of ANO-2 until the beginning of
the refueling outage taking place during the inspection, and of
ANO-1 until preparation of JCOs on July 18, 1986; constitute
Potential Enforcement / Unresolved Item 50 313/86-23-1; 50-368/
86-24-1.
(2) Rockbestos coaxial cable for GA RD23 high range radiation
monitor, tag no. GEN 1030 - The file contains Rockbestos Test
Report QR 6802 which covers third generation "LE" cable,
<
whereas the plant uses second generation "LD" cable.
Qualification to 10 CFR 50.49 was not established as noted in
an attachment to the 211 package because of the difference in.
,
models. The 211 attachment stated that a similarity analysis
was being obtained from Rockbestos. The attachment erroneously
stated that the difference between "LD" and "LE" cable is the
braid angle of the shield; in fact the braid angle was changed
between the first and second generations, and the difference
between "LD" and "LE" cables is the inner dielectric material .
Before the end of the inspection A&PL obtained a letter from
Rockbestos stating that AP&L had "LD" cable and clarifying the
differences between "LD" and "LE".
File acceptability requires
that an acceptable similarity evaluation be obtained and
incorporated into the file. Rockbestos coaxial cable comprises
Potential Enforcement / Unresolved Item 50-313/86-23-2;
50-368/86-24-2.
(3)
Instrument accuracy - AP&L general calculation 86-EQ-00101
addresses the effects of low cable insulation resistances on
instrument accuracy. The calculation assumed worst case
conditions and was performed for the lowest resistance value
applicable to each type of instrument cable. The calculation
showed that the worst case error would be 2.72 percent for
transmitters and 2.03 percent for RTDs. The analysis did not
address how these errors combined with other errors (such as
for transmitters and terminal blocks) would relate to required
instrunent accuracies. A letter written during the inspection
(July 18) further addressed this subject, stating that analyses
were performed for instrument loops using 20 percent error in
most cases, and specifically evaluating either more restrictive
requirements or worse calculated errors. The July 18 letter
stated that the result of generic calculation 86-EQ-00102 were
not included in these analyses, but the 2.7 percent error was
subsequently considered together with the loop error analyses
and found to be acceptable. The worst case cable error was also
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evaluated against automatic actuation setpoints and determined
by the licensee to be acceptable. The NRC inspectors concluded
that the files and other information shown to the inspectors
failed to document the specific plant accuracy requirements for
instruments, and show that these requirements are satisfied, as
,
necessary to satisfy the DOR Guidelines. Instrument accuracy
constitutes Potential Enforcement / Unresolved Item 50-313/86-23-3;
56-368/86-24-3.
,
(4)- Amphenol electrical penetration assembly model 50009752-07, tag
no. 2 GEN 1001D, EQ File No. V4, Item No. 8 - The test report for
these containment penetration assemblies contains no data taken
during the transient portion of the LOCA test to establish
potential leakage current values. Because of this deficiency,
the licensee's. loop accuracy evaluations used insulation
resistance values for a Conax penetration assembly. This
approach does not provide qualification to the DOR Guidelines
because the file did not adequately demonstrate similarity
between the Conax and Amphenol penetrations, although a
plausible argument was advanced during the inspection. Two
minor concerns were also noted involving the use of RTV
,
silicone for temporary repair of penetrations: the file did ~
not clearly state that the RTV is only a temporary repair, and
the file establishing qualification of the RTV was not
referenced. Amphenol penetration assembly comprises Potential
Enforcement / Unresolved Item 50-368/86-24-4.
(5) Eaton cable, tag no. 2 GEN 1013 - Qualification to 10 CFR 50.49
was not demonstrated because the basis for claiming a 40 year
qualified life was not presented in the file. However, the
necessary information was pressnt, and the licensee stated that
the file will be revised to clarify that life is detemined
based on a data point on the curve used to establish an
activation energy value, corresponding to retention of 40
percent elongation after 40 years at 90 C.
The 211 package also
contains conflicting identification of the jacket material; the
licensee determined from purchase orders that the material is
hypalon, and will revise the file accordingly. Eaton cable
constitutes Open Item 50-368/86-24-5.
(6) BIW Bostrad cable, tag no. GEN 1002 - Qualification to the 00R
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Guidelines was not established because the 211 form failed to
reference information contained in the file that showed
qualification for the required 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> post-LOCA operation.
The licensee agreed to revise the file to reference the proper
supporting material. BIW Bostrad cable constitutes Open Item
50-313/86-23-4
(7) Rotork valve operator model 11NA1, tag no. 2CV-2202-1, EQ File
No. V-44 Item 16 - Rotork qualification report TR116 dated
October 12, 1973 describes four test anomalies. Both the
Rotork report and the AP8L file are ambiguous concerning the
resolution of the test anomalies. Rotork valve operator
constitutes Open Item 50-368/86-24-6.
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(8)
IE Information Notices and Bulletins - The NRC inspectors
reviewed and evaluated the licensee's activities related to the
reviewofEQ-relatedIEInformationNotices(ins)and
Bulletins. The inspector's review included examination of
.,
procedures and EQ documentation packages relative to
Infomation Notices and Bulletins. The procedure review
determined that the licensee has a system for distributing,
reviewing and evaluating ins / Bulletins relative to equipment
within the scope of 10 CFR 50.49, and that ins and Bulletins
are addressed in appropriate component EQ files. During the
review of the individual component files, the NRC inspectors
evaluated the licensee's action with respect to ins and
Bulletins. No concerns were identified during this review
except as described.in section 4.D(1) of this report for
Limitorque operators.
E.
Plant Physical Inspection
.
The NRC inspectors, with component accessibility input from licensee
personnel, established a list of 15 component types in both units for
physical inspection. Multiple specimens of most types were examined.
,
Almost all were accessible at the time of inspection. The inspectors
examined characteristics such as mounting configuration, orientation,
interfaces, model number, ambient environment, and physical condition.
Concerns noted during the walkdown inspection are addressed in section
4.D(1)above.
F.
Cable Identification Verification
The NRC inspectors selected ten of the walkdown component types (17
components) as specimens for testing the licensee's ability to
identify plant cables and demonstrate the existence of qualification
files for them. The NRC inspectors independently examined these
cables during the walkdown to verify the identifications provided by
the licensee's documentation; information such as cable manufacturer,
type, size, voltage, and plant identification number was obtaired as
available. Splices were also inspected.
The NRC inspectors reviewed documentation provided by the licensee
which showed traceability of cable to qualification test reports for
field cable routed to the following devices:
Reel 2744
Anaconda FIRL Report
F-C335
Reel 2742
Anaconda FIRL Report
F-C3341
Reel 2593
Anaconda FIRL Report
F-C3341
Reel 2189
Anaconda FIRL Report
F-C3341
Reel 2878
Anaconda FIRL Report
F-C3694
CF-3800
Reel 15080C
Okonite
FIRL Report
F-C3694
CV-3803
Reel 15080A
Okonite
FIRL Report
F-C3694
CV-3801
Reel 15080A
Okonite
FIRL Report
F-C3694
CV-3802
Reel 15080C
Okonite
FIRL Report
F-C3694
Reel 2486
Raychem
FIRL Report
Reel 2064
Raychem
FIRL Report
Reel 2080
Raychem
FIRL Report
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Reel 2031
Raychem
FIRL Report
Special Order
Endevco
TEC Report
517-TR-03
Special Order
Endevco
TEC Report
517-TR-03
Special Order
Endevco
TEC Report
517-TR-03
Special Order
Endevco
TEC Report
517-TR-03
The licensee verified cable qualification by using the cable
reference number noted above for each cable to locate cable
manufacturer and supporting data. All selected cables were from
two manufacturers, as follows:
Cable ref. no. NFC-01 Continental Wire and Cable Company,
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Instrument Cable.
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Cable ref no. NFA-24 Okonite Company,1000 volt control cable.
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The NRC inspectors determined that the licensee had demonstrated
cable traceability from procurement through in'sta11ation and
replacement.
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