ML20215E905

Insp Repts 50-313/86-23 & 50-368/86-24 on 860714-18.Major Areas Inspected:Review of Licensee Implementation of Program Per 10CFR50.49 for Equipment Qualification.Implementation Satisfactory.Potential Enforcement/Unresolved Items Noted

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: ML20215E841 ML20215E905
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

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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 ,

Facility Name: Arkansas Nuclear One, Units 1 and 2

Inspection Conducted: July 14-18, 1986

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Inspector: 12 t[96 '

R. C. Wilson, Equipment Qualification Date-

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

! Approved By: bb M

U. Potapbys Chief Equipment Qualification

I?_/ tim /;

Dats -

Inspection Section, Vendor Program Branch

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8612230163 861211 3

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 ,

the scope of 10 CFR 50.49. l

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 '

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

3. 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 -

• 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

• L. L. Bass, Engr. Supv., Louisiana Pnwer & Light Co.

• C. L. Wilson, Lead Engineer, Texas Utilities Generating Co.

1.4 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

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Shelf Life for Environmentally Qualified (EQ)

• Replacement Components," June 12, 1985.

• ESD T-202 " Environmental Qualification Evaluations,"

September 30,-1985.

Identification: -

• 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: .

• ESP-202 " Design Process Procedure."

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• ESP-211 " Environmental Qualification Evaluation Process," -

Rev. 1, September 1, 1981.

ESP-213 " Nuclear Procurement."

'* ESP-214 " Baseline Ouality Requirements."

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." .

1033.02 "" Control of Material."

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• 1033.05 " Spare Parts Authorization." l

• . 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."

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• 1025.06 " Equipment Environmental Qualification Maintenance .

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

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

Master List.

- Defining and differentiating between mild and harsh environments.

- Establishing harsh environmental conditions at the location of

equipment through engineering analysis and evaluation.

- Establishing, evaluating, and maintaining EQ documentation.

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- Training personnel in the environmental qualification of equipment.

- Controlling plant modifications including installation of new and

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 )

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meeting 10 CFR 50.49. It. covers the bases for identifying master list

components, definition of environmental service conditions, the qualifi-

cation evaluation process, and documentation criteria. The EQ Master List I

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 ,

Worksheet (SCEW sheet). The set of SCEW sheets provides a complete summary I

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description of the qualified equipment and its applications. The qualifi- 1

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 -

10 CFR 50.49 requirements. Documents inspected included:

Farwell and Hendricks, Inc.-Safety-Related Equipment Qualification

Seminar Manual. .

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

i 1981 and Farwell and Hendricks in 1984. The licensee also stated that

! 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

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required following each use. Specifically, the EQ Data / Record

Summary Sheets contain the following information:

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- Component data (Manufacturer /Model #, etc.). -

- Limited Life components (including start dates).

- Safety function.

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Qualification documentation references.

- Qualification Requirements.

- " Good Maintenance Practices."

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Qualification schematic.

- Maintenance References (assorted).

- Activity record for equipment condition.

- 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 '

include or reference supporting information such as calculations and

test reports. The 211 package format specifically addresses the -

following items:

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 '

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 1 configuration, and

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documentation of both); evaluation of adequacy of test conditions;

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

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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. ~

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(1) Limitorque valve motor operators, EQ Files V-33 (inside  !

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

of qualification deficiencies. The NRC inspectors fourd that

' several of the identified concerns existed in AN0-2; accordingly,

'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

i 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 l

potential unqualified Limitorque valve operator wiring. The l

licensee concluded that adequate assurance existed that ]

unqualified wiring in the operators did not constitute an ,

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

- unable to provide qualification documentation, but

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 -

worst case environmental conditions. Justifications

for continued operation (JCOs) had been prepared for

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inside containment operators and were a part of the

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

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did not address the validity of partial test data and

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.

.(iii) Three operators had questionable splices.

(iv) Two operators which required motor T-drains did not

have the drains. .

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:- -

a. Mixing of grease types was evident.

b. Grease was found to be contaminated.

c. Grease was found to be hardened.

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(ii) Grease reliefs were found to have shipping caps

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(iii) T-drains were not installed on all MOVs that require

T-drain installation.

(iv) Terminal blocks have been replaced for the

following reasons:

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a. Terminal blocks were found to be underrated for

adjacent point terminations.

b. Terminal blocks were found to be corroded.

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c. Terminal blocks were found to be unidentifiable

2 and/or unqualified with on-hand test reports.

(v) Internal wires have been replaced for the following

reasons:

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a. Internal wiring could not be identified.

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. b. Internal wiring was identified as TW, TEW, or

. TFF. Qualification documentation had not been

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 -

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

s required by the referenced Limitorque qualifi-

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, ,

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

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):

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a. Two of the limit switch to torque switch connec-

tion wires were in direct contact with the limit

switch area heaters,

b. Many of the installed terminal blocks could not be '

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

life has been addressed.

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d. Additional actions

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Preliminary review of the information cited above suggested

j that continuing operation of ANO-1 during the NRC inspec-

tion might be in noncom

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Letter 85-15, since (i)pliance the ANO-2 with 10 CFRresults

inspection 50.49 and Generic

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

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

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

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the inspection, and was accompanied by extensive document-

4 ation (much of it from the Nuclear Utility Group on Equipment '

Qualification).

Based on review of this material during and after inspectinn,

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the NRC inspectors conclude that it still does not document

qualification of the ANO Limitorque operators. The walkdown

information and generic material contain the basis for

addressing most of the deficiencies observed during the

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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.

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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 l

i

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

2VSFM-31C-1

Reel 2742 Anaconda FIRL Report F-C3341

2VSFM-310-2

2CV-2201-1 Reel 2593 Anaconda FIRL Report F-C3341

2SV-8273-1 Reel 2189 Anaconda FIRL Report F-C3341

2CF-8233-1 Reel 2878 Anaconda FIRL Report F-C3694

CF-3800 Reel 15080C Okonite FIRL Report F-C3694

Reel 15080A Okonite FIRL Report F-C3694

CV-3803 F-C3694

CV-3801 Reel 15080A Okonite FIRL Report

Reel 15080C Okonite FIRL Report F-C3694

CV-3802 F-C4033-1

2LE-5646-2 Reel 2486 Raychem FIRL Report

Reel 2064 Raychem FIRL Report F-C4033-1

2TE-4635-1 F-C4033-1

2PT-5602-2 Reel 2080 Raychem FIRL Report

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2PT-5604-4 Reel 2031 Raychem FIRL Report F-C4033-1

2VBE-4634-2 Special Order Endevco TEC Report 517-TR-03

2tBE-4633-2 Special Order Endevco TEC Report 517-TR-03

2VBE-4614-1 Special Order Endevco TEC Report 517-TR-03

2VBE-4633-1 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.

- Cable ref no. NFA-24 Okonite Company,1000 volt control cable.

The NRC inspectors determined that the licensee had demonstrated

cable traceability from procurement through in'sta11ation and

replacement.

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