IR 05000267/1986024

Insp Rept 50-267/86-24 on 860818-21 & 0908-11.No Violations or Deviations Noted.Major Areas Inspected:Licensee Equipment Qualification Outage Progress

ML20215N782
Person / Time
Site:	Fort Saint Vrain
Issue date:	10/28/1986
From:	Ireland R, Andrea Johnson, Norman D, Greg Pick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215N774	List: IR 05000267/1986024 ML20215N773
References
50-267-86-24, NUDOCS 8611070268
Download: ML20215N782 (9)

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APPENDIX

'U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/86-24 Docket: 50-267 Licensee: Public Service Company of Colorado P.O. Box 840 Denver, Colorado Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: Platteville, Colorado Inspection Conducted: August 18-21, 1986 and September 8-11, 1986 Inspectors: h[ Y%rmw D. E. Norman, Reactor Inspector, Engineering

/o/2 st/8G, Date Section, Reactor Safety Branch w- - & /olZalEL G.~ Pick,\R6 ctor Inspector, Operations Dath

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Sectich,(Jeactor Safety Branch

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A. R. Johnsoi, Reactor Inspector, Engineering Date

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Sect 1 , eactor Safety Branch Approved: 4 ? $i d u /is,, f /0/LV/VX

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R. E. Ireland, ChieT, Ingineering Section, Da'te Reactor Safety Branch Inspection Summary Inspection Conducted August'18-21, 1986, and September 8-11, 1986 (Report 50-267/86-19)

Areas Inspected: The Region IV team made a routine, unannounced inspection of the licensee's equipment qualification outage progres Results: Within the area inspected, no violations or deviations were identifie PDR ADOCK 05000267 P PDR

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DETAILS Persons Contacted Licensee Personnel-D. Warembourg, Manager, Nuclear Engineering J. Eggebroten, Superintendent, Technical Services Er.gineering M. Lehr, Supervisor, QA Engineering

+L. Singleton, Manager,- QA

+*G. Sansman, Consulting Engineer, NED

+*A. Greenwood, Supervisor, QA Auditing-D. Hood, Shift Supervisor Manager, NED

+*R.~Craun, Site Engineering

• J. Jackson, Supervisor, QA /QC

• J. Grambling, Supervisor, Nuclear Licensing, Operations

+* Schwartz, Engineer, DiBenedetto Associates

• R. Doyle, Engineer, QA

• R. Gappa, Engineer, NED

+*M. Capella, Consulting Engineer, Stone and Webster

+*M.~ Ferris,.QA Operations Manager

+*T. Prenger, QA Services Manager

+*W. Ledford, Engineer, QA-

+*D. Brown, Supervisor, I&C

• Fuller, Station Manager-

+ Williams, Vice President, Nuclear Operations

+J..Gahm, Manager, NPD

+J. Selan, PSC Licensing

+G. Redmond, PSC QA

+ Niehoff, PSC Nuclear Design Manager J. Abiles, DiBeneditto Associates F. Novachek, PSC Technical / Administrative Services Manager, NPD NRC Personnel

+P. Shemanski, NRR

+R. Farrell, Senior Resident Inspector, RIV

+J. Fehringer, INEL/NRC Contractor

+ Yost, INEL/NRC Contractor

• Present at exit meeting August 21, 198 +Present at exit meeting September 10, 198 . Environmental Qualification (EQ) Program Review The licensee is in the final stages of completing documents required to fully implement requirements of 10 CFR 50.4 The NRC inspector reviewed the following documents:

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Fort St. Vrain EQ Overview, Second Draft - This document provides

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details necessary to develop procedures for assuring that all aspects of the FSV EQ program have been properly implemented. The overview summarizes the method used to identify equipment to be included in the EQ program, maintenance of equipment qualification status, and assignment of responsibilities for implementation of the EQ progra NPD EQ Program Overview, First Draft - This document identifies requirements for the operation, maintenance, and testing of EQ equipment and interfacing equipment, and the assignment of NPD responsibilities for implementation of this portion of the EQ progra *

Preventive Maintenance Equipment Review (SMAP-27), Issue 1, dated April 2, 1986 - This procedure describes the methods used to identify, review, and incorporate preventive maintenance information of plant equipment into the PM program. Two types of maintenance are addressed in the procedure:

o Required PM - maintenance required by equipment manufacturer, vendor, or others to keep equipment qualifie o Recommended PM - maintenance recommended by manufacturer, vendor, or others to extend equipment lif The EQ master equipment list (MEL), dated August 8, 1986, was reviewed by the NRC inspector. Preparation of the MEL is covered in the FSV EQ overview draft. All data required by the draft is not shown on the MEL; however, it is expected that the additional data will be provided in the MIL in parallel with completion of the overview document. It is also recognized that the MEL is a dynamic document, and equipment listed therein will change as equipment is added to or deleted from the EQ progra . EQ Documentation Package Review l

The NRC inspectors reviewed EQ documentation packages (binders) for Limitorque and Rotork valve operators, realizing that the binders were i incomplete because of ongoing maintenance and/or modifications to the operator Limitorque Operators - The qualification basis for the ten Limitorque operators included on-the MEL was Limitorque Report B0058, dated January 11, 1980, and Sargent and Lundy (S&L) analysis reported'in CQD File No. 027605. The S&L analysis provided justification for corrective actions required to upgrade the operators to requirements of D0R guidelines and 10 CFR 50.49. The following items, which could impact the qualification status of certain equipment, were referred i to the licensee for further consideration:

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Orientation of some operators # stalled in the plant was apparently different than the tested orientation. Justification for the qualification of- the non-testeu sientation should be provide The licensee had not identified whether heaters ws re~ installed in the operators and, if so, whether they were eneigized. Since heaters were not tested and qualified, if installed, they should be analyzed to determine possible impact on the ope"ator Motors with class B insulation were qualified by being wrapped with insulation. This condition should 'be justifi ed by analysi *

Some MOV operator motors were identified as requiring both motor -

-replacement (with RH insulation) and to be wrapped with insulation. This is a possible conflict as both may not be require ,

A maintenance procedure could not be identified which required grease change in the operators. This is reportedly a mandatory

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maintenance ite *

The Limitorque qualification binder did not contain nor did it reference test reports for internal items different from those qualified in the operator test report (e.g., internal wiring),

b. Rotork Operators - The qualification basis for the four Rotork opera. tors on the MEL was Wyle Report 43979-1, Revision A,. dated October 24, 1978, and S&L Analysis reported in CQD File No. 02807 The S&L analysis led to a decision to replace commercial grade operators with nuclear grade operators. It also identified several items in the replacement operators which must be periodically replaced in order to maintain qualification of the operators. The following~ items, which could impact the qualification status of certain equipment, were referred to the licensee for further consideration:

The operator model covered in the test report is not the same as the ones installed at FSV. A similarity analysis is required between tested operators and new operators which are to be installed at FS * In some cases, operators are to be installed in an orientation different than the one covered by the test report. An analysis is required to determine acceptability of the installed orientatio _- - _ - - - -- -

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i -Procedures were not in place for scheduling and performance of

maintenance to maintain qualification. statu Amp Splices - Qualification basis for Amp Butt Splices used at'FSV is

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. Amp Qualification Test Report 110-11004 dated February 2, 1982, and-

! S&L analysis Report CQD-029665, Revision.2, dated August 25, 198 The splice is restricted to use inside a NEMA Type 3 ventilated-electrical box. The licensee stated that the only application of Amp splices is for Parker switches where the pigtails are too short to accommodate Raychem splices and are enclosed in boxes or condolett Cables - The licensee has placed all cables into the following classifications:

Classification 1 - Cable manufacturer is known and a qualification test' report is available.

Classification 2 - Cable manufacturer is known, but no test

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Classification 3 - Cable manufacturer is not known and no test report is availabl Qualification binders were reviewed for the following cables:

(1) Cerro/Rockbestos - This is a classification 2 cable for which the manufacturer is.known, but a qualification' test report was ,

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The basis for qualification of classification 2 cable which did

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not have test reports available.was to select a test report which_ qualified cable with insulstion similar to cable shown on FSV purchase order Analyses were performed and the conclusion

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since both were purchased to meet requirements of IPCEA standards.

I (2) Eastern -~This is classification 3 cable procured from Eastern

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Electric Wire and Cable Company (distributor) for which the

manufacturer is not known and the existence of. specific j manufacturers test reports for FSV cable could not be verifie The qualification is based on similarity analysis between the a . Eastern FSV installed 600 volt control cable and other known

~ manufacturers' tested cable. The qualification basis is primarily_ addressed in the Wyle Laboratories Report No. 17825-FSV 57 Assessment, Revision B, dated July 19, 1986, and 4

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the S&L Justification / Analysis, Calculation No. CQD-028391,

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Revision 00, dated July 19, 1986. The qualification documentation supports qualification ~of Eastern supplied cable i for a normal service life of 35 years followed by a 30-day DBE/ Post OBE condition at FS j i

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Eastern supplied 12 AWG, 600 volt control cable (various number of conductors) with 30 mil cross-linked polyethylene (XLPE)

insulation, and 45 mil polyvinyl chloride (PVC) jacket; it was purchased.from Eastern to conform to IPCEA S-61-402, Section 3.9, and S-66-524, Section 3, per PSC purchase specification No. 93-I-53B, Revision D. Eastern certified these cables as meeting all requirements of PSC specification 93-I-53 The similarity analysis cited above establishes that the XLPE insulated cable used at FSV is representative of a limited range of XLPE formulations regardless of manufacturer. The basis for qualification maintains that cables which meet the above IPCEA-specification performance requirements will' limit the range of cable material compositions. -The similarity analysis concluded that all-XLPE insulated cables manufactured to the above IPCEA specification standards under PSC's procurement specification 93-I-53B, will perform similarly under the relatively mild accident conditions of the FSV plant, and that relatively minor compositional changes between manufactures'

formulations purchased under IPCEA standards will have no appreciable affect on the performance of XLPE insulated cabl The similarity analysis establishes a comparison between the FSV Eastern XLPE cable and other XLPE insulated cable manufacturers (e.g., Rockbestos, G.E., Brand-Rex, and Champlain), which have been purchased to IPCEA standards and successfully tested to IEEE 323-1974 and IEEE 383-197 The similarity analysis fully addresses:

(a) physical and aging requ'irements (tensile, elongation, aging and environmental cracking);

(b) radiation (414 rads during a 40 year life at FSV); and (c) the use and efforts of various types of additives during cable manufacture (antioxidents/ stabilizers, colorants, uross-linking agents, external lubricants, filters / extenders, fire retardants, heat stabilizers, UV stabilizers).

e. Qualification progress was reviewed by plant walkdown and review of binders for the equipment listed below:

(1) NAMC0 Limit Switches (2) NPK ASCO Solenoids (3) Foxboro Transmitters, Model NE 130 Series (4) Honeywell Microswitches

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-(5) .Gould AP-Switches (6) ITT Circ Speed Valves The information in the binders for this equipment. appeared to be acceptabl . Results of Licensee EQ Equipment Walkdown

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.The' licensee conducted ~an EQ walkdown according to Procedure' SEMAP-1,

" Environmental Qual.ification Walkdown Procedure," dated December 6, 198 After reviewing the EQ walkdown procedures and a few walkdown packages and .

after discussions with licensee personnel, the overall walkdown process

. was detc ~nine PSC had. contracted with the Tenera Corporation to conduct a' preliminary walkdown to verify what was actually install.ed at FSV. 'The Tenera Corporation walkdown generated field. verification'worksheets (FVW)

which described components, verified locations',iand identified any discrepancie The licensee's draft EQ overview policy concerning environmental qualification stated that credit was not taken for the Tenera walkdow Fort St. Vrain Nuclear Engineering Division (NED) personnel conducted a second walkdown utilizing SEMAP-1. The walkdown package included the procedures, enclosed corrective action data sheets (CADS), and the FVW from the Tenera walkdown. .After this initial walkdown, personnel from NPD repeated the walkdown,' focusing on the CADS packages to verify the extent of corrective action required and to generate packages to correct deficiencies. In order to get the-CADS into the normal plant programs, Station Service Requests (SSRs) were generated by NPD to cause correction of the deficiencies found.'

Concurrent with the above process, S&L went through analyses, issuing qualification binders on the components identified from the Tenera walkdowns and identifying problems through an "At Risk" memo proces Change Notices (CNs)'and the corresponding controlled work procedur deviation request (CWP-DR) were issued to correct the deficiencie At the time of this inspection, the CADS package corrections had not been-completed for all components at FS The NRC inspector reviewed the CADS packages related to Limitorque Motor Operators. The CADS package consisted of a Comment Section, a Construction / Rework Instructions Section, a Sketch, CADS DIR sheets, and other information as previously mentione The following CADS packages were reviewed:

Valve CADS Packages HV-2237 1670, 1671, and 1672

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HV-2238 1673, 1674, and 1675 HV-3108 1948 HV-3109 '1950 and 1951 HV-3110 1952, 1953, and 1954 HV-31118 1955, 1956, and.1957 HV-31119 1958, 1959, and 1960 HV-31120 1961, 1962, and 1963 HV-4225 1964, 1965, and 1966 HV-4257 1967, 1968, and 1969 The NRC inspector reviewed the rework / reinstallation packages for Limitorque Operators and-Rotork Operators, CNs 2294 and 2232, respectivel The Limitorque rework packages required replacement of unidentifiable wire with qualified wire; the installation of gland seal kits on two valves; and wrapping insulation around eight motor Various-CWP-DR were reviewed and are listed: ,

Valves (s) CWP-DR HV-2237 86-0147

.HV-2238 86-0148 HV-3108 and HV-31118 86-0149 HV-3109 and HV-31119 86-0150 HV-4257 86-0151 HV-3110 and 31120 86-0152 HV-4225 86-0153 The Rotork rework / reinstallation packages required replacement of the four commercial grade operators with environmentally qualified operator ,

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The CWP-DRs utilized are listed:

Valves CWP-DR HV-2291 and HV-22131 86-0101 HV-2290 and HV-22132 86-0102 It was noted by the NRC inspector that SEMAP-1 did not include inspection requirements for all. internal Limitorque items which could possibly deteriorate-due to temperature aging (e.g., terminal blocks, switch material, etc.) nor for motor drains and gear box pressure relief. The licensee stated that a new walkdown procedure for Limitorque operators would be developed and another walkdown performe . Exit Interview Exit meetings were held on August 21, 1986, and September 10, 1986, at which time results of the NRC inspection were discussed with FSV staff members.

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