ML20215G644
| ML20215G644 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/17/1987 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CNSS877263, TAC-68378, NUDOCS 8706230332 | |
| Download: ML20215G644 (11) | |
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Nebraska Public Power District
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CNSS877263 June 17, 1987 l
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Nebraska Public Power District Response to Inspection Report Docket 50-298/86-28 Gentlemen:
This letter is written in response to your letter dated April 1,.1987, which transmitted IE. Inspection Report No. 50-298/86-28.
Therein you identified nine Potential Enforcement / Unresolved Items and nineteen (19) Open Items regarding NPPD's implementation of a program for establishing and maintaining the qualification of electrical equipment in accordance with 10CFR50.49.
NPPD. has evaluated the scope of work required to achieve resolution of the Potential Enforcement / Unresolved Items and the Open Items. NPPD will complete the resolution of the Potential Enforcement / Unresolved Items by November, 1987, except for Items 3 and 4, which will be resolved following the completion of Open Item 19.
Open Item 19 involves the review of cables which will require an. extensive effort to locate and analyze applicable documentation.
An evaluation of' this Open Item will be completed by June, 1988.
Should any hardware modifications be required as a result of this evaluation,.they will be completed during Refueling Outage 12, scheduled for the spring of 1989.
The Potential Enforcement / Unresolved Items, the Open Items, and our responses are given below.
Potential Enforcement / Unresolved Items:
1.
Statement of Finding Contrary to paragraphs (f) and (k) of 10CFR50.49 and Section 5.2.5 of the D0R Guidelines, the EQ documentation files (EQF) for Boston Insulated Wire (BIW) cable, type Bostrad 7E, EQ Data Package (EQDP) No. 6, did not adequately demonstrate qualification because of failure to show that the
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equipment functional performance requirements were satisfied.
The analysis used a 20 foot length of cable from the supporting type test, rather than the fully installed cable length (including considerations given to splices and penetrations in the cable runs), of the installed g
configuration at the CNS plant (paragraph 4.f.(1), 50-298/8628-01).
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I' Reason for Finding The analysis in EQDP No. 6 did not clearly state' the result of_ the BIW testing as it applies to the cable used at CNS.
Corrective Steps Taken and Results Achieved EQDP No. 6 was reviewed and it was determined that further clarification and analysis would improve the auditability of. this~ cable.
Corrective Steps Which Will Be Taken NPPD will further analyze the functional aspects of the Bostrad 7E cable and ' revise EQDP 'No. 6 as necessary to include the.results of the-additional analysis.
Date When Corrective Steps Will Be Achieved-By Wovember, 1987.
q 2.
Statement of Finding I
contrary to paragraphs (f) and (j) of 10CFR50.49, the EQF for BIW coaxial cable, type RG 59 B/4, EQDP No. 6A, did not document and demonstrate
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qualification in that BIW Test Report No. 76J049 was not auditable. to.
permit verification that this item is qualified for its application. The documented test report was incomplete, consisted of only a single page summary, and was not traceable to permit independent verification of conclusions (paragraph 4.f.(2), 50-298/8628-02).
1 Reason for Finding l
l Detailed backup documentation of this type is difficult to locate and i
obtain.
This testing was performed 'during the 1970's when the level of i
nuclear environmental testing sophistication was not fully developed.
i Backup documentation is generally scattered and, in some cases, not i
retrievable.
Corrective Steps Taken and Results Achieved BIW has been contacted and will research and provide the backup documentation available for Test Report No. 76J049.
l Corrective Steps Which Will Be Taken q
When the available backup documentation is received, it will be included in the EQ file to further substantiate the test report.
Date When Corrective Steps Will Be Achieved By November, 1987.
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U.S. Nuclear Regulatory Commission 1
Page 3 June 17, 1987 j
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Statement of Finding
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Contrary to paragraphs (f) and (k) of 10CFR$0.49 and Section 5.2.5 of the D0R Guidelines, the EQF for Kerite 600 volt cable, type HTK/FR, EQDP No. 5, did not adequately support qualification in that the documented f
test results did not meet the acceptance criteria of adequate insulation 1
resistance during DBE testing, and numerous failures during the post-DBE high pot test occurred (paragraph 4.f.(3), 50-298/8628-03).
Reason for Finding The cable qualification information supplied by Kerite was not accurately analyzed and the actual use of the Kerite 600 volt cable at CNS was not identified.
Corrective Steps Taken and Results Achieved The installation of 600 volt Kerite cable at CNS was reviewed.
This initial review determined that Kerite cable was not used in EQ applications and its apparent lack of qualification is not an immediate EQ concern.
Corrective Steps Which Will Be Taken As part of the proposed cable review in response to Open Item 19, the use of the 600 volt Kerite cable at CNS will be verified.
If it is determined that this cable is used in EQ applications, an appropriate qualification will be established or the cable will be replaced, if qualification is not feasible.
Date When Corrective Steps Will Be Achieved Cable review by June, 1988.
If found to be necessary, cable will be replaced during the 1989 Refueling Outage.
4.
Statement of Finding Contrary to paragraphs (f) and (k) of 10CFR50.49 and Section 5.2.2 of the D0R Guidelines, the EQF for Raychem coaxial cable, type Rayolin R and Rayolin F, XLPE, EQDP No. 4, did not adequately demonstrate qualification because of failure to demonstrate similarity between the tested and insi,elled cables.
The claim for material similarity in the analysis is unclear (par: graph 4.f.(5), 50-298/8628-04).
Reason for Finding EQDP No. 4 was not clearly worded concerning the designations of Rayolin R and Rayolin F cable. Also, the actual use of this cable at CNS has not been determined.
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U.S. Nuclear _ Regulatory Commission -
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June 17, 1987 6
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Corrective Steps,Taken and Risults Achieved
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NPPD has ' erified that Ra'yolin' R'is regular cross-linked polyolefin and v
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Rayolin F is foam cross-linked polyolefin.
Raychem has indicated.that the M1, M2, and M3 type cables were standard service cables that are i
generally 'not suitable for_ Class 1E harsh environment applications.
Since the' District does not believe that this cable type exists in IE harsh environment applications, these cable types have been removed from EQDP No. 4 and are not considered qualified.
c Corrective Steps Which Will Be Taken '.
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The cable review task to be completed in response to Open Item 19 will confir.t that M1,. M2, and h3' type cables are not installed in EQ j
f app 7ications,
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D:te When Corre_ctive Steps Will Be Achieved
/ By June, 1988.
j 5.
Statement of Finding Contrary to paragraphs (f) and (k) of 10CFR50.49 and Section 5.2.2 of the 00R Guidelines, the EQF for General Electric (G.E.) electrical power and control penetrations, type 238X600NSG1, EQDP No. 8, did not adequately establish qualification because of failure to demonstrate similarity between the tested and installed components.
The analysis in the EQDP was inadequate in that no link between the test results and the installed 7
electrical penetrations F01-NS02, F01-NS03, and F01-NSO4 at CNS was available (paragraph 4.f.(6), 50-298/8628-05).
Reason for Finding It appears that all of the documentation in support of EQDP No. 8 was not J
reviewed during the audit.
Subsequent review of this qualification does confirm that similarity is established.
Corrective Steps Taken and Results Achieved 1
EQDP No. 8 (with references) clearly states that the CNS electrical I
penetrations are the " canister" type of penetration, one of three general I
types supplied by G.E. for use at various nuclear power plants.
It is also clear that the referenced supporting test data is for the G.E.
" canister" type of penetrations.
Corrective Steps Which Will Be Taken No further action is anticipated.
U.S. Nuclear ~ Regulatory Commission Page 5 June 17, 1987 6.
Statement of Finding Contrary to paragraphs (f) and (k) of 10CFR50.49 and Section 5.2.6 of the D0R Guidelines, the EQF for various pressure / level switches and transmitters contained in EQDP No.'s 12, 13, 36, 37, 49, 76, 81, 217, 222, and 228 did not adequately establish qualification because the equipment documentation failed to address mounting, orientation, and interface requirements.
From the EQF, it could not be verified that the equipment in the CNS as-built configuration was installed as tested (paragraph 4.f.(7),50-298/8628-06).
Reason for Finding.
The lack of a clear evaluation of orientation and interface requirements is a weakness in these EQDP's and is an oversight in the preparation and review of these qualifications.
Corrective Steps Taken and Results Achieved NPPD has reviewed the noted EQDP's and determined that the installed orientation does not appear to significantly impact the current qualification.
Corrective Steps Which Will Be Taken The EQDP's will be revised to incorporate any necessary mounting, orientation, and interface requirements that are not currently addressed.
Date When Corrective Steps Will Be Achieved By November, 1987.
7.
Statement of Finding Contrary to (f) and (k) of 10CFR50.49 and Section 5.1 of the D0R Guidelines, the EQF for Fenwal/Patel temperature switches, Model No.
01-170230-090, EQDP No. 220A, did not adequately establish qualification because of failure to base the qualification of the interfacing cable splices on full accident conditions, including service life for radiation and aging effects.
The T & B STA-KON friction crimped splices were qualified for steam testing only (paragraph 4.f.(8), 50-298/8628-07).
Reason for Finding Originally, it was felt that the qualification of the STA-K0H connectors l
was adequate for their use in this application.
Corrective Steps Taken and Results Achieved EQDP No. 235 has been generated to specifically address the qualification of the STA-K0N connectors.
This was transmitted to Region IV as a priority item by our letter CNSS877215, dated April 16, 1987.
i U.S. Nuclear Regulatory Commission Page 6 June 17, 1987 Corrective Steps Which Will Be Taken No'further action is anticipated at this time.
1 Date When Corrective Steps Will Be Achieved j
i Corrective steps have been completed.
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8.
Statement of Finding Contrary to paragraphs (f) and (k) of 10CFR50.49 and Sections 4.3, 5.1, and 5.2 of the D0R Guidelines, the EQF for 25 Limitorque motor operators, 1
model SMB series, did not adequately establish qualification as follows:
I a.
No supporting analysis was available in the EQF to address the HELB accident conditions in which glass braided butyl rubber (polybutadiene) insulated, internal jumper wire, was used.
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{i b.
No documentation was available in the EQF to substantiate (by test results or other laboratory methods) the similarity of material construction of the internal wiring reported to the NRC by the l
licensee'in the Equipment Operational Analysis (E0A), Attachment B, i
which correlated like wiring removed from similar equipment at.CNS.
c.
No qualification analysis and test reports were available-in the EQF to support qualification of Scotch taped cable splices, and unidentified blind barrel cable splices in eight Limitorque motor operators.
In the above Items a, b, and c, the licensee failed to demonstrate similarity between the tested motor operator configuration and the installed configurations with regard to materials of construction (paragraph 4.g, 50-298/8628-08).
l Reason for Finding NPPD believed the Limitorque operators were qualified, as indicated in our responses to IEN 86-03.
Corrective Steps Taken and Results Achieved j
The glass braided butyl rubber jumper wires and the Scotch taped cable splices have been removed and replaced with qualified Rockbestos cable and Okonite splices.
Corrective Steps Which Wil' Be Taken The Limitorque walkdown data and Equipment Operational Analysis will be i
reviewed and correlated to further substantiate the qualification of the Limitorque operators.
Date When Corrective Steps Will Be Achieved 4
By November, 1987.
U.S. Nuclear Regulatory Commission Page 7 June 17, 1987 9.
Statement of Finding Contrary to paragraphs (f) and (k) of 10CFR50.49 and Section 5.2.2 of the D0R Guidelines, the EQF for Limitorque motor operator, Series SMB, particularly Okonite motor lead splices, found in EQDP No. 31A (B0003 qualification series), did not adequately establish qualification because of failure to demonstrate similarity between the splice type tested and those installed in motor operators at the CNS plant.
No evidence was contained in the EQF which could demonstrate qualification of Okonite splice installations over braided jacket motor leads.
The EQDP in the EQF only demonstrates Okonite motor lead splice testing over unjacketed insulated cable (paragraph 4.h.(1)(a), 50-298/8628-09).
Reason for Finding Based on EQDP No. 224, the Okonite tape splices were considered qualified.
Corrective Steps Taken and Results Achieved Additional testing of Okonite splices over braided jacket cable has been conducted, which indicates that the qualification of this configuration is acceptable.
Corrective Steps Which Will Be Taken i
The additional testing of Okonite tape splices over braided jacket cable will be finalized and a revised qualification data package will be prepared.
Date When Corrective Steps Will Be Achieved By November, 1987.
Open Items:
1.
Rockbestos Cerro Firewall III 4.f.(9) 298/8628-10 Cable; documentation deficiencies.
RESPONSE
NPPD has corrected the reference sections of the EQDP numbers 7 and 205 based on the inspection exit.
NPPD will again review these documents in light of the inspection report and make any further appropriate changes.
2.
Microswitch Limit Switches, 4.f.(10)(b) 298/8628-11 Models OP-N; maintenance identified in EQDP inadequate.
RESPONSE
NPPD will identify the surveillance activities associated with these switches and reference them in EQDP No. 33A for clarification of this concern.
f U.S. Nuclear Regulatory Commission Page-8 June 17, 1987 3.
Microswitch (Limit Switches) 4.f.(11)(b) 298/8628-12 Model DTE6-2RQ62; 4.f.(11)(c) documentation deficiencies.
RESPONSE
This component is currently qualified by analysis rather than by type test.
Since type testing is the preferred qualification method under the D0R Guidelines, NPPD.will perform type testing for the existing components or evaluate replacements for these switches to provide more acceptable qualification.
- 4. 'Microswitch Limit Switches 4.h.(5) 298/8628-13
. Models OP-N and DTE 6-2RQ62; walkdown deficiencies.
RESPONSE
NPPD will correct the observed deficiencies.
5.
ASCO Solenoid Valves, 4.f.(12)(b) 298/8628-14 Type HVA-90-405-2A, 4.f.(12)(c)
WPHT-8316E-36, and NP-1; 4.f.(12)(d) documentation deficiencies.
4.f.(12)(e) 4.f.(12)(f)
RESPONSE
Concern 4.f(12)(d) has been resolved based on the operating characteristics of the plant air system which limits system pressure to 110 psig.
The other 4 items are now being reviewed. After this review the EQDP's will be revised.to reflect any appropriate changes.
6.
ASCO-Temperature Switch, 4.f.(13)(b) 298/8628-15 Model SA11AR and 4.f.(13)(c) 0J11A4R; 4.f.(13)(d) documentation deficiencies.
RESPONSE
NPPD will revise EQDP No. 77 to clarify the fill fluid, include a more detailed wear aging analysis and establish a stronger similarity review to support qualification of this switch.
7.
ASCO Solenoid Valves, Type 4.h.(4)(a) 298/8628-16 HVA-90-405-2A, WPHT 8316E-36, 4.h.(4)(b) and NP-1; walkdown deficiencies.
RESPONSE
NPPD believes these splices are acceptable and do not degrade the qualification of these components.
The EQDP's will be revised to clarify the justification of this configuration.
C U.S. Nuclear Regulatory: Commission Page 9 June'17, 1987
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l 8.
Target Rock Solenoid Valves, 4.f.(14)(b) 298/8628-17 I
Model 1/2-SMS-A-01-01; 4.f.(14)(c) documentation deficiencies.
- 4. f. (14)(d)
RESPONSE
NPPD will review 'and correct as necessary, the referenced documentation deficiencies.
EQDP No. 51 will be revised to correct the expected life. inconsistency and to reference installation /
replacement requirements.
9.
Static-0-Ring Pressure 4.f.(15) 298/8628-18 Switches, TA Series (1) venting of replacement switch housings.
(2) documentation deficiencies.
RESPONSE
NPPD will document the venting scheme and correct the EQDP No. 222 documentation deficiencies.
10.
Barksdale Pressure Switch, 4.f.(16) 298/8628-19 Model 82TM1255 and 82T-AISS; documentation deficiencies.
RESPONSE
NPPD will revise EQDP No.12 to clarify the pressure conditions.
11.
Rosemount Transmitters 4.f.(17) 298/8628-20 Model 1153 Series B; additional analysis for synergistics effects required.
RESPONSE
NPPD has reviewed the Rosemount Test Report and has confirmed that the qualification testing did adequately address synergism.
NPPD will revise the synergism section of EQDP No. 81 to more clearly describe the applicable synergistic effects.
12.
Rosemount Transmitter, Model 4.f.(18) 298/8628-21 i
1153D B/1159DP, with Remote Seal System; additional analysis to include capillary insulation is required.
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RESPONSE
NPPD will add the capillary insulation analysis to the design input file and to EQDP No. 226 as a reference.
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U.S. Nuclear Regulatory Commission Page 10 June 17, 1987 13.
Limit'orque Motor Operators 4.f.(19) 298/8628-22 i
Model SMB-00 and SMB-2; documentation deficiencies.
RESPONSE
Recent revisions to the EQDP No. 31 series have' corrected these documentation deficiencies.
No further work on ' this item is anticipated.
1 14.
Limitorque Motor Operators 4.h.(1)(b) 298/8628-23 Model SMB-4; broken wire lead.
RESPONSE-The broken wire has been repaired.
4 15.
Limitorque Motor Operators-4.h(2) 298/8628-24 Model SMB-3 and SMB-00; removal of grease relief shipping caps.
RESPONSE
All applicable Limitorque Motor Operators have been inspected for 4
removal of the grease relief shipping caps.
16.
Reliance Motors; 4.f.(20) 298/8628-25 documentation deficiencies.
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RESPONSE
NPPD will revise EQDP No. 219 to include the motor serial numbers.
I 17.
G.E. Motor, Model 4.f.(21) 298/8628-26 5K6346XC74A and SK6346XC83A; i
documentation deficiencies,
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RESPONSE
f NPPD will revise EQDP No. 23 to include the motor serial numbers.
j NOTE:
G.E. model numbers were mistyped in Item 17, Table II, Open Items of the report.
4 18.
G.E. Motors, Model 5K6346XC74A 4.h.(3)(a) 298/8628-27 and 5K6346XC83A; inadequate 4.h.(3)(b) maintenance.
RESPONSE
NPPD will provide instructions to plant personnel to observe and correct housekeeping type problems during future routine surveillances of these coaponents.
Observed deficiencies CS-MOT-CSPIB were corrected.
e U.S. Nuclear Regulatory Commission Page 11 June 17, 1987 19.-
EQ Cable Identification;~
'4.f.(4) 298/8628-28
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generic cable traceability problem.
RESPONSE
NPPD will initiate an extensive plant document' review to establish the _ type-and manufacturer of the installed EQ cables.
This
'information will be gathered and analyzed, as necessary, to provide a reasonable assurance that the installed cable is adequate.
If you have any questions regarding this response, please contact me or G. R. Horn at Cooper Nuclear Station.
. Trevors v
Division Manager of Nuclear Support GAT:SJJ:ss/mhl7/1 (15A)'
cc:
U.S. Nuclear Regulatory Commission 3
Regional Office, Region IV j
NRC Resident Inspector Cooper Nuclear Station 1
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