ML20235J513
| ML20235J513 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/11/1987 |
| From: | Anderson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235J498 | List: |
| References | |
| 50-333-87-14, GL-81-15, IEIN-86-053, IEIN-86-53, NUDOCS 8710010471 | |
| Download: ML20235J513 (29) | |
See also: IR 05000333/1987014
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U.S. NUCLEAR REGULATORY COMMISSION )
REGION I )
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Report No. 50-333/87-14-
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Docket No. 50-333
License No. DRP-59- Priority -
' Category C
Licensee: Power Authority of State of New York-
P.O. Box 41
Scriba, New York
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Facility Name: James A. Fitzpatrick Nuclear' Power Plant (JAFNPP) j
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Inspection At: Scriba, New York j
inspection Conducted: April 27, 1987 - May 1, 1987 N
Inspectors: k w* b. 9 / J7
R.'J. Paolino, Lead Reactor Engineer, PSS/DRS. date
Other participants and contributors to the report include:
V. Eacanskas, Consultant - Frankl.in Research Center
R. Carpenter, Engineer - Idaho National Engineering
Laboratory (INEL)
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L. Cheung, Reactor Engineer, NRC/RI
J. Jacobson,~ Equipment Qualification & Test Engineer! NRC/NRR/HQ
M. Trojovsky, Engineer - Idaho Nation Engineering j
Laboratory I EL) '
Approved by: b'
C. J. AMderson, Chief, Plant Systems
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date ;
Section, EB/DRS
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Inspection Summary: Inspection on April 27, 1987 - May 1, 1987
(Inspection Report No. 50-333/87-14) R
Areas Inspected: Announced inspection to 1) review the licensee's Environ-
mental Qualification Program and its implementation in accordance with'
10 CFR 50.49 for maintaining.the qualification status of safety related
electrical equipment in' a harsh environment, 2) review licensee response and. i
s esolutions to. equipment concerns identified.in the Technical Evalut. tion
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Report (TER) issued by the Franklin Research Center, 3) Review licensee acti-
vity in response to NRC Information Notice No. 86-53 pertaining.to Raychem
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splices. 1
Results: The inspection determined that the licensee has implemeiited a program
L -to meet the requirements of 10 CFR 50.49, except for certain deficiencies. !
I listed below.
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Violations (10 CFR 50.49 except as Noted) Paragraph- Item Number (s)
1) 10 CFR 50, Appendix B, Criterion VII 7.0 87-14-02'
violation involving failure to provide
documentary evidence that a critical
component characteristic (seismic) had
been met for determining acceptability
of commercial grade equipment for use 1
in safety related applications. I
2) Failure to maintain complete an'd 10.0 87-14-03 !
auditable electrical equipment EQ l
Reference File.
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3) Qualification of Brand-Rex cable not 10.3 87-14-04 l
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l established prior to this inspection.
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4) Qualification of Cerro KXL-760 cable not 10.4 87-14-05 i
established prior to this inspection.
5) Qualification of Limitorque MOV Reliance 10.11 87-14-11
Motors (outside containment) not
established prior to this inspection.
6) Qualification of Limitorque MOV (inside 10.12 87-14-12
containment) for 518 VAC operation not
established prior to this inspection.
7) Qualification of AAA-solenoid valves not 10.16 87-14-16
established prior to this inspection.
l 8) Qualification of General Electric cannister- 10.18 87-14-17
type electrical penetration not established
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prior to this inspection.
9) Qualification of Cerro KXL-510 cable not 10.2 87-14-18
established prior to this inspection.
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Unresolved Items Paragraph Item Number (s)
1) EQ maintenance / surveillance procedures 5.0. 87-14-01
incomplete.
2) Licensee to provide basis for deletion 10.5 87-14-06 j
of accident condition in qualifying i
BIW-XLPE cable.
3) Licensee to provide basis for deleting 10.6 87-14-07 )
Eaton cable from EQ Master List. I
4) Licensee to revise Rosemount FQ Reference- 10.7 87'-14-08
File to incorporate new data. !
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5) Licensee to revise Magnetrol EQ Reference 10.8 87-14-09
File to incorporate new data.
6) Licensee to revise Thomas & Betts EQ 10.10 87-14-10 ;
Reference File to include new data. i
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7) Licensee to revise General Atomic high 10.14 87-14-14 ]
range radiation monitor EQ Reference )
File to include new data. I
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8) Licensee to revise Anaconda-Continental 10.15 87-14-15
and General Electric SIS wire EQ Reference
File to incorporate clarifying note. ;
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9) Qualification of Motor Control Center 10.13 87-14-13 -I
BMCC-2 needs to consider potentialf for !
water condensation. Complete corrective ,
actions to upgrade MCCs water tight <
integrity. ,
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DETAILS
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1.0 Persons Contacted
1.1 New York Power Authority (NYPA)
R. Baker, Maintenance Superintendent
F. A. Blouise, Project Support Engineer
C. Caputo, Supervisory Engineer
R. Converse, Resident Manager
J. M. Erkam, Senior Plant Engineer
W. Fernandez, Superintendent of Power
! 8. W. Grandy, Electrical Supervisor
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M. Hansen, Senior Plant Engineer
D. Holliday, Q.A. Engineer i
H. N. Keith, I&C Superintendent ,
J. Lazarus, Assistant Plant-Engineer
D. Lindsey, Operations Superintendent
R. Matthews, I&C General Supervisor
R. L. Patch, Quality Assurance Superintendent
D. A. Ruddy, Senior Plant Engineer
D. Simpson, Training Superintendent 1
S. M..Toth, Senior Nuclear. Licensing Engineer
V. Walz, Technical Service Superintendent ,
W. R. Wiese, Jr. , Assistant Maintenance Superintendent
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1.2 EPM
R. Ho, Senior Engineer
1.3 Patel Enterprise, Inc.
G. Elam, Engineer
F. Roy, Engineer
1.4 Ecotech, Inc.
L. Gradin, Consultant
S. Savino, Consultant
1.5 U.S. Nuclear Regulatory Commission
W. V. Johnston, Acting Director, Division Reactor Safety /RI
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A. Luptak, Senior Resident Inspector'
U. Potapovs, Chief, SPIS Section/VPB/NRR/HQ
- All of the personnel listed above were present at the exit meeting of,
May 1, 1987.
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2.0 Background I
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The NRC previously reviewed the New York Power Authority's methods for
compliance with the 10 CFR 50.49 requirements as part of the NRC licensing
review for the James A. FitzPatrick facility.
The NRC licensing review was based primarily on information supplied by
the licensee on environmental qualification' activities reported in
correspondence with the NRC on September 24, 1981, February 5, 1981,
June 2, 1982, June 7, 1982, April 19, 1983, May 20, 1983, and ,
August 19, 1983. On March 30, 1984, a meeting was held to discuss the
New York Power Authority's proposed method to resolve the environmental
qualification deficiencies identified in the April 19, 1983 SER and the
March 18, 1983 Franklin Research Center TER. The majority of deficiencies
identified pertained to documentation, similarity, aging, qualified life
and replacement schedule.
In the June 15 and October 15, 1984 submittals, the licensee described
their approach used to identify equipment within: the scope of para- ,
graph (b)(1) of 10 CFR 50.49 relied upon to' remain functional during and
following design basis events. These submittals included a Justification
for Continued Operation (JCO) for each item of equipment for which the
environmental qualification was not yet completed.
Based on the above, the NRC staff, in the March 12, 1985- letter to the
l licensee, concluded that the equipment qualification program at FitzPatrick
l generally meets the requirements of 10 CFR 50.49.
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An NRC Region I Inspection, 50-333/86-14, was conducted at'JAFNPP of
Licensee activity regarding Information Notice No. 86-03 on Limitorque
internal wiring qualification during the period of August 25-28, 1986.
During that inspection, a potential violation was identified regarding
unqualified tape splices.
3.0 EQProgram
The NRC inspectors examined the licensee's EQ program for establishing and
maintaining the environmental qualification of electrical equipment in
compliance with the requirements of 10 CFR 50.49. The. licensee's program
for establishing and maintaining qualification of electrical equipment
within the scope of 10 CFR 50.49 is defined in the following. Work Activity
Control Procedures (WACPs) and Engineering and Design Procedures (EDPs):
WACP-10.1.11, Environmental Qualification Program Procedure
- WACP-10.1.1, Procedure for Control of Maintenance
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- WACP-10.1.4, Procedure for Procurement of Material and Services
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- WACP-10.1.5, Procedures for Control and Identification of Purchased
Material and Services
WACP-10.1.6, Procedure for Control of Modifications, Component
Changes and Safety and Environmental Impact Evaluation Reports.
- EDP-24, Revision 0, Procedure for Documentation of Sound Reasons to
the Contrary for not Upgrading Replacement Environmentally Qualified
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Electrical Equipment.
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EDP-22, Revision 1, Procedure for Preparation of Plant Specific
Qualification Reports.
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EDP-21, Revision 0, Procedure for Control of Environmental
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Qualification Documentation (EQ).
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EDP-3, Revision 3, Procedure for Design Verification.
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- EDP-16, Revision 2, Procedure for Technical Review of Procurement i
Documents. I
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EDP-20, Revision 0, Procedure for Establishing Plant Electrical I
Equipment is within the Scope of 10 CFR 50.49 (EQ). J
The licensee's program was reviewed to verify that adequate procedures had i
been established to meet the requirements of 10 CFR 50.49. Program )
procedures were 'eviewed to evaluate procedural methods and their i
effectiveness for:
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Identifying equipment within the scope of 10 CFR 50.49.
Performing functional qualification assessment of specific plant
components requiring qualification.
Maintenance of qualified electrical equipment.
Controlling the generation, maintenance and distribution of the EQ
Master List.
Control of spare and replacement part orders for qualified safety-
I related equipment.
The Technical Service Department has overall responsibility for the
plant's qualification program for electrical equipment important to
safety.
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This ' department administers the environmental qualification program and -
reference files in accordance with the above procedures. Engineering
personnel, normally assigned to'the Technical Service Department perform -)
reviews and approval of qualification test reports and do the functional
qualification assessment of components in the program. The Instruments-
tion and Control (I&C) Department and the Maintenance Department are
responsible for performing preventative maintenance necessary to maintain !
the electrical equipment in .the program and to maintain the qualified
status of the electrical equipment. q
Environmental Qualification Reference Files are used to document equipment .
qualification and are maintained in the Technical Service Department.
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Based on the above, the inspector concluded that the licensee had imple- )
mented a program that meets the requirements of 10 CFR 50.49 for enviro-
mental qualification of electrical equipment except for deficiencies noted.
in paragraph 10.
4.0 EQ Master List 1
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10 CFR 50.49(b) requires licensees operating a nuclear power plant.to 1
establish an EQ program for qualifying electrical equipment important I
to safety. Licensee Procedure No. WACP-10.1.11 entitled " Environmental ,
Qualification Program for Harsh Environment Plant Electrical Equipment", i
was developed to address.the requirements of 10 CFR 50.49. The. procedure
defines department responsibilities and performance qualification assess-
ments of components requiring qualification.
The Technical Service Department has overall responsibility"for the plants R
EQ qualification program for electrical equipment importart to. safety.
Engineering personnel in the Technical Service Department perform com- 1
ponent functional assessments to determine the applicable qualification
requirements of a given component. This evaluation considered the func--
tion of the component, its location and its requirement for operabi.lity
during and after postulated accidents. The licensee's review included
logic circuitry associated with various safety related systems. The i
logic (energized or de energized) and power source (AC or DC) were deter-
minec; and failures at field sensors and components located in potential
post-accident harsh environments were postulated. Safety related equip-
ment determined to experience postulated harsh ' environments as a result
of these events'was included in the 10 CFR 50.49 equipment listing.
Revisions, corrections, and additions to the EQ Master List are made in
accordance with licensee Procedure No. WACP-10.1.11.
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Procedure No. EDP-20 provides instructions for determining if plant elec -
trical equipment requires environmental = qualification per 10 CFR 50.49. . "
The procedure defines applicable harsh environmental. design basis event (s)
which apply and the- post-accident operating time for specific equipment.
Verification of the JAFNPP EQ list _ of safety-related system equipment to
mitigate Design Basis Event was performed for system No. 02 (Nuclear-
Boiler and Pressure Relief-ADS) and system No 16 (Containment and Contain-
mentInstrumentation).
Within the scope of this review, no deficiencies were identified.
5.0 EQ Maintenance Program ,
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The NRC inspector reviewed the Environmental Qualification Maintenance ~ !
Program to determine the licensee's provisions for preserving the quali-
fied status of equipment qualified to 10 CFR 50.49. j
Procedure No. EDP-23, entitled, " Establishment of EQ Maintenance Require- 4
ments," Revision 0, dated December 10, 1985, defines the responsibility and ;
the process for establishing and implementing the maintenance requirements i
for environmentally qualified equipment. The Technical Service Super.in- ;
tendent is responsible for identification and documentation of EQ mainte- 1
nance requirements and for transmitting these requirements to the proper
department heads for implementation.
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The Maintenance and I&C Department Superintendents'are responsible for
acceptance of the EQ requirements and the incorporation of these require-
ments into plant maintenance procedures and the documentation of com-
pliance with the requirements.
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An EQ maintenance form (EDP-23, enclosure 6.1)' is' prepared for each plant
component on the EQ Master List for which the EQ maintenance is required.
The form contains equipment data, technical references, applicable surveil- ,
lance and maintenance procedures and environmental qualification require- !
ments. The EQ maintenance requirements include: mounting and interfaces,
qualified life, operational cycle, power requirements, maintenance and
parts replacement.
The licensee stated that their EQ maintenance / surveillance procedures
were in the draft stage awaiting review and approval. Pending
implementation of the final EQ maintenance program, they are using an
interim program to maintain the qualified. status of the EQ components as
follows:
FitzPatrick EQ maintenance activities are categorized as Preventive
Maintenance (PM), Corrective Maintenance (CM), and maintenance activities
related to the replacement of end-of-life items. For PM and CM,'mainte-
nance activities are accomplished by using existing maintenance procedures-
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together with vendor technical manuals which identify EQ specific main-
tenance requirements. These technical manuals were reviewed and selected
by the EQ engineers and maintained.in a library under the administrative ,
control of the EQ engineers.
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.The inspector randomly selected the following maintenance / surveillance
packages for review, and did not identify.any deficiencies: '
- H2 /02 Analyzer Instrument Nos. 27-PCA-101A, 27-PCR-101A
and 27-PCX-101A (Procedure No. F-ISP-30-1).
Post-Accident Containment Pressure Instrument No. 27-PT-115A1
(Procedure No. F-ISP-4-7).
RHR Service Water Flow Instrument No. 10-FT-97A (Procedure
No. F-IMP-10.1).
The licensee replaced EQ items requiring replacement based on aging con- i
siderations in 1985, using existing procedures and vendor technical
manuals. The next scheduled aging-replacement will be in 1988. At that
time, the dedicated EQ maintenance procedures are scheduled to be in
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place. This item is unresolved pending NRC review and verification'of the
licensee's completion of EQ related surveillance / maintenance procedures
(050-333/87-14-01).
l 6.0 QA/QC Inte..' acec
The Quality Assurance Department is responsible for performing quality
assurance activities which may be required by the plant's electrical
equipment environmental qualification program. An integrated audit was
! conducted on the FitzPatrick EQ program in 1985 by the licensee's Qt.
group. The auditors consisted of licensee QA personnel and outside
Technical Consultants. The audit results were reported in Audit Report
No. SA-21J, dated October 16, 1985. Subjects covered by the audit include
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the review of programmatic procedures and the technical review of EQ file
packages.
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The technical review covered the design input data (e.g. , Design Basis
l Events, EQ Master List, environmental condition, maintenance and opera-
tions) and five EQ file packages (No. 239, 285, 182, 227 and Solenoid
Valves).
Thirteen deficiencies and concerns were identified by the auditors in
reviewing the design input data. Twenty-eight deficiencies and concerns
were identified in the auditors EQ file review. The EQ file deficiencies
consisted mainly of paper correction. All of the deficiencies were
resolved.
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The programmatic review covered design control, procurement documents,
receipt inspection, storage, maintenance,-Information Notices /IE' Bulletin
processing and data sheets (SCEW) for electrical EQ equipment (e.g.
Raychem Cable Splices, Terminal Blocks, Pressure Transmitters, Solenoid
Operated Valves, Motor Operated Valve Actuators and Mot _or' Control
Centers). The inspector interviewed QA personnel regarding the QA audit '
and concluded that the QA involvement in the EQ program is adequate;.
however, the findings of this inspection should be factored into future
licensee audits.
Within the scope of this inspection, no violations were identified.
7.0 E_Q Procurement, Spare Parts and Replacement Control
The inspector conducted a review of the NYPA procedures which govern the
purchase and replacement of EQ parts and equipment. Procedure.No. 10.1.4,
Procurement of Materials and Services and Procedure No. EDP-16, Proce-
dure for Technical Review of Procurement Documents,=are the two procedures
used in the procurement of EQ safety related materials. A review of
selected documents confirmed that all EQ parts are. ordered in'accordance ,
with the proper procedures and that appropriate specifications are
included in the associated purchase orders. EDP-16 requires a technical
review of all safety related " Class I" equipment purchase' documentation
to ensure all required specification and purchase information is correct.
Enclosure 6.1, Part I, to EDP-16 provides a checklist as.an aid to- 1
l accomplishing this review. !
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During this review, the inspector noted that paragraph 5.6 of EDP-16
provided means for. procuring commercial grade items for safety. related .(
applications (Class I). Enclosure 6.1, Part II, the' checklist used to !
determine whether a commercial grade part is acceptable for use in a safety J
related app?ication was determined to be insufficient. .Specifically, the !
checklist does not require that receipt. inspection,' testing, or other-
methods be invoked t'o ensure that critical component characteristics are
met when conimercial grade parts are used in safety related-applications. .
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. Two examples of components purchased commercial grade and used in. safety- i
! related applications were identified. The'first example was a Mercury )
Wetted Relay (GE P/N/ 225A 5365 P001) which is part of the Reactor Manual 1
Control System. The checklist (Enclostre 6.1', Part II,' to EDP-16) filled )
out for this ' component stated that seism'c design requirements were appli- i
cable, however, no receipt inspection, testing or other documentation was j
available to ensure the relay met the seismic requirements. j
The second example was an Ampere meter (GE P/N AB-40) ordered' under - j
Purchase Requisition 87-1493. This part was also designated as having i
seismic design requirements, however,'no receipt inspection, testing or ,
other documentation was available to demonstrate the meter met the re- 'l
quirements nor was any testing done to verify the required accuracy of the
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meter.
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This is a Violation of 10 CFR 50, Appendix B, Criterion VII which states,
in part, that: Documentary. evidence that material and equipment conform
to procurement requirements shall be available...." (50-333/87-14-02). j
8.0' EQ Training !
l The general training requirements for personnel are prescribed in l
Section 17.2.2.5 of the FitzPatrick QA Manual. There are no dedicated EQ )
training requirements prescribed in the EQ program procedures, however,- (
the licensee was able to demonstrate that personnel involved in maintain-
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ing the qualified status of EQ equipment did receive applicable EQ 1
training. !
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The inspector reviewed training records and attendance sheets indicating i
that three on-site training courses were given to plant site personnel,
using the " Environmental Qualification Program for Harsh Environment Plant
Electrical Equipment" procedure No. WACP-10.1.11. Personnel were in- ]
structed on the use of applicable EQ procedures for maintaining the quali- 1
fied status of electrical equipment within the scope of 10 CFR 50.49. -]
Records reviewed by the NRC inspector indicate that classes were held on i
January 6,10 and 13,1986. Thirty-four plant personnel, consisting of j
I&C, Maintenance, QA and Technical Staff, attended these classes. Addi- )
tional instruction was provided to twenty-eight individuals on Procedure
No. WACP-10.1.9, Control of Plant Drawings and Cable / Raceway List.
Specific instructions were provided to eighteen individuals (I&C, and i
Maintenance personnel) dealing with electrical splices. Records reviewed l
by the inspector indicated the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> classes, pertaining to Raychem Heat l
Shrinkable Nuclear Splice Kits (Procedure No. ET 5002.08a), were held on
December 19, 23, 1986 and January 9, 1987. In addition, key engineering
personnel (2) received EQ training at- Wyle Laboratory.
Based on the above, the inspector concluded that the. licensee is imple- l
menting an adequate EQ Training Program for personnel involved in main- l
taining qualified status of EQ electrical equipment. '
9.0 EQ Documentation
Procedure No. EDP-21, Revision 0, dated December 10, 1985, describes how
the environmental qualification documentation is generated, revised and
stored. The procedure applies to all documentation which is required to:
demonstrate that plant electrical equipment on the EQ Master List
conforms to the requirements of 10 CFR 50.49. t
The Technical Service Superintendent is responsible for maintenance and
control of all environmental qualification documentation. The
Maintenance and I&C Superintendents are responsible for forwarding to the
Technical Service Department all technical and ' installation data for '
maintenance and repair work on plant equipment <isted on the EQ Master
List for incorporation into the EQ Design Reference file.
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Environmental qualification design documentation consist of a) System
Component Evaluation Work (SCEW) Sheet, b) Plant Specific Qualification-
Reports, c) Environmental Reports-, and d) Environmental Report Summary.
The inspector reviewed licensee EQ Reference File.Nos. 213, 239, 273
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and 310 verifying compliance with procedure No. EDP-21. j
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Based on the above review, the inspectors concluded that the licensee i
controls on EQ Documentation are adequate.
10.0 EQ File Review j
10.1 The licensee's EQ files were examined to verify the qualified status
l 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,selec- ;
tively reviewed areas such as post-accident operating time compared 1
to the duration of time the equipment has been demonstrated to be 1
qualified; similarity of tested electrical components / equipment to -l
that installed in the plant (e.g. , insulation class, component I
materials, test configuration compared to installed configuration and
documentation of both); evaluation of adequacy of test conditions;
' aging calculations for qualified life and replacement interval
determination; effects of decrease in insulation resistance on
equipment performance; adequacy of demonstrated equipment accuracy;
evaluation of test anomalies; and applicability of EQ problems-
reported in IE Information Notices / Bulletins and their resolution.
The inspectors reviewed a selected sample of 24 EQ files. associated
with 24 equipment types. These 24 equipment types; covered such-areas
as electrical cables, limitorque motor valve operators, pump motors, l
l solenoid operated valves, cable splices, radiation detectors and
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pressure / level transmitters. An equipment type is defined as a :
specific type of electrical equipment, designated by manufacturer <
and model, which is representative of all identical equipment in a
plant area exposed to the same or less severe environmental service
conditions.
I The inspectors identified three generic file deficiencies consist-
ing of inadequate information provided in the files to address
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equipment acceptability. The EQ files consisted of review and
l analysis by contract personnel of data furnished by the licensee for-
use in qualification of electrical equipment in harsh environment.
There was no positive statement in the EQ Reference File for each
item of electrical equipment to indicate the licensee had reviewed
the content and verified equipment qualification. Acceptance.and
performance criteria for electrical equipment was not specified,
requiring considerable dialogue between the inspectors and licensee
personnel to interpret and establish the basis for acceptance.
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This is a violation of 10 CFR 50.49 paragraph (j) which requires
that a record.of qualification be maintained in an auditable form to
permit verification that each item of electrical . equipment important
to safety is qualified (050-333/87-14-03).
Specific deficiencies are discussed in the following sections. ;
10.2 EQ Reference File No. 250-Cerro KXL-510 Cable
The inspector reviewed EQ Reference File No. 250 for Cerro KXL-510
cable for primary containment application to determine whether the
package contains sufficient. evidence that these cables are qualified l
for the environmental conditions in which they must operate and that
the qualification documents in the package are adequate.
Documents reviewed for this determination included: ,
- Franklin Research Center Report No. F-C2927 entitled " Test of :
Electric Cables Under Simulated Post-Accident Reactor
Containment Service" dated October 1970.
Franklin Research Center Report No. F-C2857 entitled " Test of
Electric Cables Under Simulated Post-Accident Reactor-
Containment Service" dated September 1970.
- Patel Report No. PEI-TR-82-4-123 Revision A, dated
July 27,1983.
Licensee Document on " Resolution of Discrepancies in the EQ
Testing of Rockbestos Cable for Use in the JAF Nuclear Power
Plant" dated July 2,1986.
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SCEW sheet for Cable-08, Revision 2 dated November 4, 1986.
In reviewing the above documents, the inspector noted that the SCEW
sheet indicates that the Cerro KXL-510 cable is to be qualified
generically for primary containment application. Franklin Research
Center Report Nos. F-C2927 and F-C2857 were used by the licensee as
the basis for. qualification of the Cerro 'KXL-510 cable. There was
! no evidence in any of the reports that insulation resistance' measure-
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ments were made nor any other measurements that would enable the
l' determination of small leakage currents (e.g. SmA). This small
l leakage current can cause a transmitter to function unacceptably.
i Paragraph 2.2.4 of Patel Report No. PEI-TR-82-4123 indicates that
the insulation resistance (IR) functional requirement for this type
l- of cable must be 1 x 10E5 chms minimum for 200 ft. cable, both
l during and af ter a Design Basis Event (DBE). In paragraph 4.5 of
the same report, the licensee calculated the IR based on the test
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data to be 1.5 x 10E5 ohms for "after DBE" condition. This test
data was measured after the cable was removed from the. test chamber,
apparently at room temperature. -
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Experience dictates that during a DBE, when the temperature,
pressure and relative humidity are all higher, the IR decreases,
typically by a factor of 10E3 to 10ES. .By using even the lower
factor of 10E3, it can be concluded that during a DBE the cable IR
would be 1.5 x 102 ohms and fail to meet the functional requirement.-
Prior to this inspection, the licensee'was not able'to establish
qualification of the Cerro KXL-510 cable for general use in the -
This is a violation of 10 CFR 50.49, paragraphs (f) and (g) which j
requires that each item of electric equipment important to safety '
be qualified and that qualification.must be completed at a time no
later than November 30, 1985.
In preparing a Justification for Continued Operation (JC0 No.
'
'
JAF-EQ-JCO-87-002 dated May 18, 1987) the licensee determined in a
review of plant cabling associated with all instruments identified
in the WCAP 10.1.11, Table 10J EQ Master List, that the Cerro cable
using the KXL-510 compound is used only as a thermocouple TC)-
extension wire. Since thermocouple are low impedance voltage
sources which input into high-impedance amplifiers, the licensee
was able to show that the thermocouple will retain original
accuracy within the insulation resistance range of this cable. The :
licensee has committed to establishing qualifiability of the Cerro
KXL-510 cable for the specific applications in the facility and to
ensure that controls are in place for the limited use of this
cable.
10.3 EQ Reference File No. 231 - Brand-Rex Cable
The inspector reviewed EQ Reference File No. 231 for Brand-Rex
cable Model T-7600 for the Reactor Building generic application to I
determine whether the file contains sufficient evidence that these i
cables are qualified for the environmental conditions in whict; they i
must operate and that the qualification documents in the file are
'
j
auditable. l
.j
Documents reviewed for this determination include:
Patel Report No. PEI-TR-82-4-47, Revision 4,' dated May 9,-1987.
l
Franklin Research Center Report No. F-C5120-1, entitled I
'
" Qualification tests of Electrical Cable in a Simulated Steam
Line Break and Loss-of-Coolant Accident Environment," _ dated
l August 19, 1980. q
1
l ,
l
i
l 1
l !
- _ - _ __ _ _ . -
..
15
.
- Franklin Research Center Report No. F-C5120-4, entitled- I
" Qualification test of Instrument Cables in a Simulated Steam
Line Break and Loss-of-Coolant Accident Environment," dated-
January 11, 1982.
SCEW sheet for cable-01.
- Telecon by T. Hancock to Brand-Rex dated May 5, 1983.
In reviewing Franklin Report No. F-C5120-1 and a telecon by ;
T. Hancock to Brand Rex Company, the inspector noted that eighteen !
cables were tested and only 5 of these cables applied to the I
FitzPatrick facility. These cables were identified as Nos.
C5120-5-1, C5120-5-2, C5120-6-1, C5120-6-2 and C5120-7. Of thes'e 5
Brand-Rex cables, all but one (C5120-5-1) was. removed from the test
sequence due to test anomalies. In response to NRC concerns regard- )
ing the qualification of Brand-Rex cable which'was based on the one
'
cable that passed the test, the licensee generated additional data
during this inspection to show that the Model T-7600 cable was
similar to a qualified Model T-7506 cable. Qualification of the
Model T-7506 is supported by Franklin Research Center Report No.
F-C5120-4. In addition, the licensee was able to resolve the test l
anomalies by additional documents that indicate the test anomalies j
were due to insulation damage at the test chamber penetrations.
This item is a violation of 10 CFR 50.49, paragraphs (f) and (g),
which requires that each item of electric equipment important to i
safety be qualified and that qualification must be completed at a '
time no later than November 30, 1985. Prior to this inspection, the
licensee had not established qualification of the Brand-Rex cable
(050-333/87-14-04). i
10.4 EQ Reference File No. 205b-Cerro KXL-760 Cables
The inspector reviewed the Cerro KXL-760 cable file, for Primary
Containment application, to determine whether the package contains
. sufficient evidence that these cables are qualified for the environ-
I
mental conditions in which they must operate and that the qualifica-
tion documents in the package are auditable.
Documents reviewed for this determination included:
l
Plant Specific Qualification Report for Rockbestos Firewall III
and Pyrotrol III Cable, dated November 18, 1986.
Rockbestos Report No. TR-6801, entitled " Similarity Analysis of
KXL-780, KXL-760-5, KXL-760 and KXL-760-0," Revision 1, dated
July 31, 1986.
1
1
t
.
16
.
i
- Rockbestos Report No. QR-5804, entitled " Report on Qualification l
Tests for Firewall III Chemically Cross-Linked Polyethylene j
Construction for Class 1E Service in Nuclear Generating i
Stations," dated September 13, 1985.
- Rockbest'os Report No. QR-5805, entitled " Report on Qualification !
Tests for Firewall III Chemically Cross-Linked Polyethylene
Construction for Class 1E Service in Nuclear Generating
Stations," dated October 8, 1985.
- SCEW sheet for cable-11
The licensee performed a similarity analysis and attempted to qual _1fy
the Cerro KXL-760 cable by similarity to Rockbestos Firewall III. 4
The functional analysis in the EQ package is for Firewall III l
power / control cable application only. However, the SCEW sheet for
the Cerro KXL-760 cable indicates that the service is for control /
instrumentation cable / thermocouple extension wire and for generic
inside Primary Containment application. There is no calculation or
analysis in the EQ package to justify use of Cerro KXL-760 cable for ,
" generic instrument cable" application.
]
In response to the NRC concerns, the licensee performed an analysis
to justify the RTD ciible application and stated that no other generic j
instruments used the Cerro KXL-760 cable. >
l 'I
This item is a violation of 10 CFR 50.49, paragraphs (f) and (g), j
!
which requires that each item of electrical equipment important to ;
safety be qualified and that qualification must be completed at a
time no later than November 30, 1985. j
1
.]
I
Prior to this inspection, the licensee had not established qualifica- l
tion of the Cerro KXL-760 cable (050-333/87-14-05). j
i 10.5 EQ Reference File No. 212-BIW XLPE Cable
The inspector reviewed the BIW XLPE Reference File for the Reactor j
Building generic application to determine-whether the package ;
contains sufficient evidence that these cables are qualified for the j
environmental conditions in which they must operate and that the l
qualification package is auditable. j
Documents reviewed for this determination included:
Patel Report No. PEI-TR-82-4-12, Revision C, dated June 11, 1985.
-
BIW " Flame and Radiation Resistant Test Report" No. B916, dated
April 1980. j
l
l- *
SCEW sheet for cable-02.
l
1
j
a _ _--_ _-
.
'17
-The SCEW sheet' indicates that these cables are qualified for generic
Reactor Building High Energy Line Break, l.oss of Coolant Accident
(HELB, LOCA) instrumentation applications with accident peak tem .
perature of 285 F and peak pressure of 23.5 psia. However, there is
no accident test report in .the EQ File to substantiate the qualifi-
cation for accident conditions at the temperature and pressure .(
stated. { l
In response to the NRC concerns, the licensee revised the SCEW sheet i
to exclude the accident conditions and stated that the cables are to l
be used in a " radiation only" environment.
The licensee did not provide a basis for its determination to-
exclude the accident conditions. This item is unresolved, pending
NRC review of licensee's evaluation and justification for the- 1
I exclusion (050-333/87-14-06), i
10.6 EQ Reference File No. 230-Eaton Cables
The inspector reviewed the EQ Reference File for the Eaton cable for '!
Primary Containment generic application.to determine whether the l
package contains sufficient evidence that the cables are qualified l
for the environmental conditions in which they must function. l
The SCEW sheet indicates that the Eator; cables are qualified for
generic inside Primary Containment application. However, note 2 on
the SCEW sheet states that the cable has been moved to a mild
environment. The licensee later determined to withdraw this type
'
of cable from the EQ Master List. j
l This item is unresolved, pending NRC verification that: 1) no Eaton
I
cables (Model 1952-68310) are used in harsh environment' for safety
application; and 2) this type of cable is deleted from the EQ Master l
List (050-333/87-14-07).
10.7 EQ Reference File No. 276-Rosemount Model 1153 Series B Transmitter
The inspector reviewed the EQ Reference File for the Rosemount
Model 1153 Series B Transmitters. These transmitters are located
inside the Reactor Building on the 276' level and are used.to detect
and to initiate an isolation signal in the event of.a Main' Steam 4
Line Break (MSLB). Because these transmitters are not required to
function during a LOCA and are remotely located away from the ,
postulated MSLB area, the environment for which these transmitters
are required to operate under is relatively mild. The SCEW sheet
for these transmitters actually has a notation of N/A (Not Applic-
able) for the specified accident environments. However, the file ';
review resulted in deficiencies that the licensee committed to ad-
dress in revisions to the file. The following lists the deficien-
cies that were noted during the file review.
-___ ___-_-_- -
_ _ _ _ _ _
l
a
18
,
.;
- The qualification documented in Rosemount Test Reports 108025,.
Revision 0; 3825, Revision D; and D8300131, Revision A, (which
documents the results of a test on.the type "R" transmitters) is
highly dependent on the results documented in a test performed
on type "P" transmitters (Rosemount Test Reports 108025 and
108026 Revision,None). It was recommended that the results of
the test performed on the type "P" transmitters be added or
summarized in Patel's evaluation report, PEI-TR-82-4-25. The
main reason for this concern is that the test performed on the ]
i
type "R" transmitter (which are those installed at FNPP) was not 1
'
a fu?1 sequential type test as defined in IEEE Standard 323-1974
and the justification for omitting the functional and thermal
pre-aging steps of the recommended sequence is based on the
results of the test performed on the type "P" transmitters.
- In Rosemount Reports 108025, Revision D; 3825, Revision 0; and
08300131, Revision A, Rosemount tested both the Series B and
Series D transmitters. The major difference between the two
series is the housing material. The Series B housing is made of 1
aluminum and was qualified to 265F while the Series 0 housing '
is made of stainless steel and was qualified to 350 F. There
was sufficient analysis in the file to address the differences
,
(if any) in the circuitry of the two series, but the file did .
not have sufficient justification in regard to.the housing l
material differences that would support the claim that the '
Series B was qualified to the higher temperature demonstrated by
the Series D transmitters. It should be noted that the 265 F
demonstrated by the Series B transmitters envelops the highest 1
specificd temperature, with sufficient margin, for the locations ]
where these types of transmitters are installed at FNPP.
Inconsistencies were also noted in the qualified lives that. )
were presented on SCEW sheet and that was found in Patel's '
Assessment Report PEI-TR-82-4-25. The FNPP personnel acknow-
ledged this inconsistency and provided an analysis to show that
a qualified life of 40 years was established for these trans- i
mitters provided that the 0-rings were replaced every time the ;
cover is removed.
This item is unresolved, pending NRC review and verification of
licensee revisions to the EQ Reference File to incorporate the above
data (050-333/87-14-08).
10.8 EQ Reference File No. 267-Magnetrol Level Switch
The inspector reviewed the.EQ Reference File for the Magnetrol Level l
Switch, Model No. 402-EP/VPX-SIMD4C. :
P
1
_ _ - - - _ - _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ . . _ - _ - _ _ . _ _ _ . . - _ - - - _ _ _ _ _ _)
.
-19
.
i
These switches are located in the Reactor Building'on the 272' level:
and are used to initiate a SCRAM on a high Scram Instrument Volume
(SIV) water level. Documentation used to establish qualification
for these switches was contained in the following test. reports:
Acton Test Report 17344-82N-A which describes testing of a model 402
switch, type SIMD4H. .Wyle Test Report 43235,' dated May 2, 1977 was ,
used to supplement the previous test performed on the type SIMD4H l
-switch by testing a model 402 with a type.SIMD4C switch. Both of 1
these tests subjected the switches to functional and' thermal
pre-aging with emphasis placed on establishing the durability of the-
switch contacts throughout the components' 40 year' qualified life.
Because there was some difference between the NEMA enclosures
j
incorporated in the tested switches and those installed at FNPP,
Conax seals were incorporated at the cable entrances of the instal ,
l
led switches.
1
The assessment of the above two test reports was found in Patel's i
Report PEI-TR-82-4-15, " Final Report on the Evaluation of the J
Qualification of the Model 402-EP/VPX/SIM4DC Liquid Level Control )
Provided by Magnetrol International, Inc. for use in .the James A. j
FitzPatrick Nuclear Power Plant". ' l
I
One deficiency was noted in the' file for these switches. These 1
switches are supplied with interna 1' wiring that.is' manufactured by
Rockbestos. The Acton Report references Rockbestos Report 1806 to-
establish the qualification of this wire. .It was suggested to.the i
FNPP personnel to reference the new Rockbestos report, which was j
already part of their EQ p.rogram, in order to address the concerns l
of TN 84-44.
As a result of the file review, it was concluded that documentation
l does exist in the licensees. files to support qualification of these -;
I switches to the conditions specified at the' James A.- FitzPatrick' ;
l Nuclear Power Plant, provided revisions are made to the files-' to'
l
address the concerns of IN 84-44.
i
- This item is unresolved, pending NRC review and verification of ;
I
licensee action to incorporate the concerns of IN 84-44 in the EQ '
Reference File No. 267'(50-333/87-14-09). ;
10.9 EQ Reference File No. 255-ITT Barton level Indicating Switch i
The inspector reviewed the EQ Reference File for the ITT Barten Level
Indicating Switch Model 288A.
This ITT Barton Model 288A, GE P/N/ 159C4384P004, SN288A-9940 is
located in the Reactor Building at elevation 300' which'is'above
flood level. It monitors reactor water level andLits safety func- .
tion is to provide isolation of the HPCI turbine on high reactor !
i)
i
-!
!
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
___._________.._______.._.__._____1___m_______j
-
.
.
L 20'
.
,
water level during HPCI operation for a LOCA'.- Documentation support-
l ing qualification of.the Barton 288A and 289 pressure switches is
located in FNPP Refernce File 255.. The summary report is PEI-TR-
82-4-117 which references ITT Barton TR 9999.1217.2. Qualification
of the Tech-SIL Moisture Seal incorporated on these switches is
contained in Reference File 294, which contains PEI-TR-843000-01,
and PEI-TR-82-4-20. Reference File 294 contains the documentation >
supporting Environmental Qualification of all the " potted" type-
moisture seals used at FNPP to the level of 10 CFR 50.49. The j
qualification level of the Barton pressure switches is to the 00R l
guidelines.
The Franklin TER noted four deficiencies with the environmental
qualification of these Bartons. All were resolved either by switch
replacement or additions to the EQ: file documentation. Although the .
Bartons are environmentally qualified to the 00R Guidelines, a .
Model 289A was procured and installed at FNPP after February 22, 1983.
During the audit, FNPP personnel furnished documentation to justify a
not upgrading the EQ 1evel by sighting " sound reasons to the
contrary" as provided by Regulatory Guide 1.89. The inspector had
no further concerns regarding this issue. ;
i
10.10 EQ Reference File No. 261-Thomas & Betts Crimp Lugs
The inspector reviewed the'EQ Reference File for'the Thomas & Betts .;
Tefzel Insulated STA-KON terminals. These Thomas & Betts crimp lugs
are environmentally qualified for generic plant use as wire
connectors. )
Environmental qualification to 10 CFR 50.49 is contained in Reference
File 261 which contains the summary report PEI-TR-82-4-45A, and the
Thomas & Betts Test Report QPS-TB (CH)-878, Revision 0. This EQ file
supports qualification to 50.49 except,'as noted -in the Frantiin TER,
Item 161, which states that functional testing during the LOCA test-
ing was not performed, The NRC position is that the insulation
,
j
resistance of the Tefzel insulator should have been measured before,. !
during, and following the LOCA. FNPP agrees with this position and j
takes no credit for the insulating capabilities provided by the
Tefzel sections of these connectors in any of their installation. !
Instead, the' required dielectric strength is provided by properly
installed, configured, and qualified terminal boards and insulated i
splices. This resolution of the Franklin TER concern is considered j
acceptable. However, it is not documented in the EQ file (Reference 1
File 261).
'
This item is unresolved, pending NRC review and verifica' tion of'
licensee action to incorporate the resolution'of the Franklin TER
concern in the EQ Reference File (050-333/87-14-10).
!
1
9
!
.
.
~
!
21 )
. ;
1
l
10.11 EQ Reference File No. 239-Limitorque Motor Operated Valves .
.j
The inspector reviewed the EQ Reference File " Digital. Engineering- 1
Report No. DE-EQA-8603-00-01," for Limitorqu'e Motor Operated Valves
installed outside the Primary Containment. . The file qualification-
was based upon Limitorque Test Report'No. B-0003 and was found to be q
deficient in that similarity between'the installed actuators.and j
those tested by Limitorque was not established. Specifically, ;
qualification was inconclusive 1y based upon statements made by
Limitorque and Stone & Webster that the installed Class B, DC-
Peerless motors are made of materials that are equal to or better !
L
than the Class B, AC Reliance motors which were tested by Limitorque. -)
No material analysis of the Peerless motors was contained.in.the j
file, nor was there any indication that NYPA had reviewed a material 1
analysis done by either Limitorque or Stone and Webster, However,
during the inspection the NRC inspector concluded that these
'
,
Limitorque Motor Operated Valves were qualifiable. Subsequent to !
the inspection, the licensee indicated that they performed-the i
necessary analysis to establish qualification of the Limitorque .j
Motor Operated Valves, j
This item is in violation of 30 CFR 50.49, paragraphs (f) and. (g),
which requires that each item of electrical equipment important to ;
safety be qualified'and that qualification must be completed at a j
time no later than November 30, 1985. Prior to this inspection, _the. j
licensee had not established qualification by similarity
.
j
(50-333/87-14-11). )
10.12 EQ Reference File No. 247-Limitorque Motor Operate Valves
i
The inspector reviewed the EQ Reference File (Digital Engineering !
Report No. DE-EQA-8603-00-03) for Limitorque motor operated valves - ;
used inside the containment. This-file was used to qualify four 575 j
VAC Limitorque actuators to NUREG-0588 Category I requirements, ;
Qualification was based upon Limitorque test reports B0058, dated , 1
January 11, 1980 and 600376A dated May 13, 1976. This file was found j
to be deficient in that qualification was based on testing done on !
actuators whose similarity to the installed actuators has not been !
demonstrated. The tested actuator contained a 480 VAC motor and !
testing was done at this nominal voltage. The actuators installed'
at FitzPatrick are 575 VAC actuators and.are required to operate ,
over a range of 10%. The files contained no test data or analysis '!
to show that the installed actuators would operate properly at a 1
degraded voltage condition of 575 minus 10 percent (518 VAC). Cal--
culated torque output of the installed actuators at 518 VAC would
be 81% of that at nominal voltage. However, during the inspection- i
the NRC inspector concluded that. these Limitorque actuators were ';
qualifiable in that the licensee demonstrated that the calculated
output torque of the installed actuators at 518 VAC was adequate to- 1
satisfy specific plant installation requirements.
!
!
i
_ _ _ _ _ _ - _ _ _ _ _ _ _ - - - - _ _ _ _ _ _ _ - - - - - _ - - - - - _ _ - - - - _ - - - - _ _ - - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
1
i
.
22 )
j;
I
This is in violation of 10 CFR 50.49, paragraphs (f) and (g), which
requires that each item of electrical equipment important to safety ,
be qualified and that qualification must be completed at a time no 1
later than November 30, 1985. Prior to this inspection, qualification
of the Limitorque motor operated valve actuators used in containment
was not established (50-333/87-14-12).
10.13 EQ Reference File No. 182-BMCC-2 Motor Control Center
i
The inspector reviewed the EQ Reference File for the BMCC-2 Motor I
Control Center (MCC). The MCC's qualification was based on testing-
'
done at 95 percent humidity. The Design Basis Accident (DBA) en-
vironment calculated for this MCC is one with 100% humidity, 138 F
peak temperature and 15,4 psia peak pressure. The inspector noted
that the Motor Control Center (BMCC-2) was the subject of two recent
NYPA LER reports to' the NRC (LER Nos. 86-21 and 86-12). In both j
reports, water which was either sprayed or drained onto the environ- !
. mentally qualified motor control centers entered the MCC and caused :
shorting of safety related circuits. As reported in LER 86-12, one i
gallon of water which was drained onto the MCC during a fire protec-
tion system test, entered the MCC tripping breaker overloads to the
High Pressure Coolant Injection steam supply valve and the Main Steam
Line Drain outboard isolation valve. It appears from the results of
the two incidents reported in the LERs that the MCCs are susceptible
to the impingement of'small amounts of water. This could occur when
I water resulting from steam condensation on equipment above the MCC
l would fall through open deck grating onto the top of the MCC. ;
1
No mention of the event's significance in terms of the MCC's environ-
mental qualification was mentioned in either LER. However, the long ;
term corrective action to LER 86-21 states that a design change will !
be initiated to increase the MCC's water' tight integrity.
The licensees stated that the two reported events' constituted an !
accident more severe than the design basis event for which the MCCs
are qualified. They performed preliminary analysis to show that
water condensation of the magnitude described in.the two reported
events is not likely during a design basis events. The licensee's
final analysis along with their corrective actions to upgrade the
MCCs water tight integrity is an unresolved item (50-333/87-14-13).
10.14 EQ Reference File No. 262-General Atomic High Range Radiation Monitor
The inspector reviewed the EQ Reference File for the General Atomic
(GA) high range radiation monitors, qualified to 00R Guidelines.
The GA radiation monitors are used for post-accident monitoring of
the drywell radiation levels to support the instrumentation require-
ments of Regulatory Guide 1.97. The Licensee's file consisted of a
GA test report, supporting analysis, and an evaluation of'the suit-
ability of the equipment for use in safety-related applications at
FitzPatrick.
.
_ - _ _ _ - . - _ _ _ _ _ . _ _ _ _ _ . _-
_
.
23
.
During review of the licensee's file, two issues were noted. The
thermal aging evaluation included in the reference file had assumed
that the material of construction of the Amphenol connector used to
connect the instrument cable to the radiation detector was similar
to a material used in the Conax electrical penetration assembly.
The material used in the Conax penetration assembly was identified
as tetrafluoroethylene (TFE), whereas the material in the amphenol i
connector was cross-linked polystyrene, ,
'l
Sufficient difference exist in the chemical formulation of. the two i
materials to indicate that their thermal aging characteristics are. 7
not similar. Prior to completion of the inspection, the;1icensee l
provided an additional test report which stated that the material was-
polyethylene, and thermal aging testing had been performed which ;
demonstrated suitability of the material at FitzPatrick. The-
licensee will revise EQ Reference File 262 to include the additional .
l
information.
This item is unresolved, pending NRC review and verification of.
licensee action to incorporate the additional test report in the EQ
Reference File (50-333/87-14-14).
During review of the file, it was also noted that page 2, Section 2-
of the GA test report stated: " Aluminum electrolytic capacitors ;
listed in Section 3.1 are replaced every 10 years with new components
or modules." Equipment Qualification Maintenance Program (EQMP) form
No. 262 does not address this maintenance requirement. When ques 7
tioned, the licensee stated that the electronic components are
located in a mild environment and need not be addressed in the same
manner as the components located in a harsh environment. The
licensee's response was determined to be adequate, and the mainte-
nance information was not considered deficient.
10.15 EQ Reference File No 318-Anaconda-Continental & General Electr'ic
Vulkene SIS Wire
The inspector reviewed the EQ Reference File for Anaconda-Conti-
nental Single Insulated Stranded (SIS) and General Electric Vulkene
SIS wire. EQ reference 318 provided the licensee's basis for quali-
fication of Anaconda-Continental Single Insulated Stranded (SIS), and
General Electric Vulkene SIS wire. The EQ file stated the wire was-
qualified for use as jumper wire for control circuits -in-Limitorque
operators only. No deficiencies were notes in the EQ file, however,-
the licensee's Systematic Component Evaluation Work (SCEW) sheet
stated that the wire was qualified fn generic use in the reactor
building. The licensee has committe o add a clarifying note to
the SCEW sheet to state that the wire is to be used only for control
circuits.in the Limitorque operators.
L________________________________1__________________._____________ _ _ _ _ . . . _ . . _ _ _ _ _ . _ . _ _ ._____.
.
24
.
I
This item is unresolved, pending NRC review and verification of
licensee action to incorporate the limiting application for SIS wire
in the EQ Reference File (050-333/87-14-15).
10.16 Ej Reference File No. 282-AAA Solenoid Operated Valves
The inspector reviewed the EQ Reference File for AAA-solenoid
operated valves (SOVs) qualified to' DOR Guidelines. The SOVs are
used to actuate two primary containment isolation valves in the rad-- )
waste' system, and are located in the Reactor Building. The thermal-
'
aging analysis included in the documentation file assumed that the
solenoid coil:was similar in construction to the motors contained in ;
the Limitorque operators. The motors used in the Limitorque operator .i
are generally form wound vacuum pressure impregnated windings,.and i
i solenoid coils are normally random wound magnet wire. . The Licensee's
j thermal aging basis was questioned, and during the course of the ;
'
inspection, the licensee provided a new thermal aging analysis based -'
on appropriate assumptions of material composition. The EQ file
will be revised to incorporate the new thermal aging analysis.
l Prior to this inspection, qualification of the AAA-solenoid operated
, valves had not been established. The licensee generated'new thermal
! aging analysis during the inspection to qualify the solenoid coil
l material. This item is in violation .of 10 CFR 50.49, paragraphs (f)
and (g), which requires that each item of electrical equipment
! important to safety be qualified and that qualification must be
completed at a time no later than November 30, 1985
(050-333/87-14-16).
10.17 EQ Reference File No. 214-Conax Penetration
l
The inspector reviewed the EQ Reference File for the Conax electrical
,
'
penetration qualified to NUREG-0588, Category 1. The principal
application for the Conax penetration is for feedthrough of the ;
.
electrical signal from the GA radiation monitors through the drywell
l wall. The file contained a Conax test report IPS-231. The test ,
l report is a summary report' using- similarity to previously tested )
- . penetration assemblies to qualify the penetration used at FitzPatrick.
NRC policy (reference SECY-81-119) states that summary information
in and of itself is insufficient to establish equipment qualifica-
tion. On this basis, the licensee was asked to determine if addi-
tional information was available on the' qualification of the Conax
penetration. The licensee provided the Conax test reports on which
IPS-231 was based. The test reports will be incorporated into the
EQ Reference File.
No other deficiencies were noted.
!
!
s
_ - __ _ __ - _ - _ -
',
. y
1
25 j
-
j
10.18 EQ Reference File No. 244-General Electric Canister-type Electrical i
Penetration ]
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The inspector reviewed the EQ Reference File for the General Electric i
Canister-type penetration qualified to the DDR Guidelines. The i
electrical penetration assemblies are used for feedthrough of low- I
voltage power and control circuits through the drywell wall. In
addition, the electrical penetration assemblies are used for one-
train of the GA high range radiation monitors. .The licensee's file
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consisted of analysis of the thermal degradation of the penetrations,
as well as the degradation to be expected for the postulated radia- l
tion exposure. A General Electric test report from 1970 was used to. {
demonstrate the capability of the penetration to withstand a Loss I
of Coolant Accident.
Several deficiencies were identified-during ' review of the file, and
each will be discussed along with the licensee's resolution of the ,
deficiency. $
1) The licensee's file stated that a minimum insulation-resistance 1
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of 1.0 x 10 ohms minimum was required during the LOCA test, yet
tabulated data in the test report showed that the insulation i
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resistance for cable specimen No. I was 1.2 x 10_ at 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />
elapsed time of the test. The licensee stated that the insula- j
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tion resistance value was a typographical error because the test
report stated in two other places that the insulation resistance
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for all cables exceeded a value of 1.0 x 10 ohms throughout the
test. To further support qualification of the' cable, the
licensee supplied an additional test report which demonstrated
the suitability of the cable for the' application at FitzPatrict.
The deficiency will be resolved by the addition of this data to j
the EQ file.
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l 2) The test report indicated that the peak temperature experienced
during the LOCA was not reached until 45 minutes elapsed time.
The licensee stated that no credit,was taken in its evaluation
of the LOCA event until the test had reached the required peak
temperature.
3) The licensee's radiation analysis was based upon a letter from
General Electric to the NRC which indicated that testing had (
.been performed on the electrical penetration assemblies, and
the radiation exposure was listed in thel letter. The licensee
was asked to provide any data supporting the GE letter,.or if
the data had been reviewed by the licensee and determined to be
applicable to the installed equipment. The licensee replied
that the NRC did not require that the data be maintained onsite
by the licensee.per NRC Generic Letter.81-15. When the
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inspector's question was clarified, the licensee provided
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additional analysis that supported qualification of the
electrical penetration assemblies for a radiation environment.
The additional analysis was performed during the course of the
inspection by the licensee.
4) The licensee's qualification specification required an
operability period of 180 days during an accident for the
penetration. The GE test report contained within the
licensee's file documented a test program lasting only 69 hours7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br />
l in duration. The licensee had performed a calculation using
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the Arrhenius model to extrapolate the 69 hour7.986111e-4 days <br />0.0192 hours <br />1.140873e-4 weeks <br />2.62545e-5 months <br /> test to envelope
the required 180 day operability period. When questioned on
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the validity of the extrapolation, the licensee replied that
l IEEE std. 317-1976 allows extrapolation of the accident
. simulation in this manner. Since IEEE std.' 317-1976 requires
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thermal aging and irradiation of'a single specimen prior to the
accident exposure, using the provisions of IEEE std. 317-1976,
to allow extrapolation of the exposure was determined to be
inappropriate. The Licensee provided an additional analysis,
which followed Section 5.2.1 of the DOR guidelines to
demonstrate that the materials involved will not experience any
significant accelerated aging during the period not tested.
The analyses were performed during the course of the
inspection.
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5) The licensee's qualification specification required that
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penetration leakage during the' test not exceed 1.0 x 10 6
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cc/sec, yet leakage of 1.0 x 10 ' was reported for the
l penetration. The test report stated that the leakage was
l associated with triax cables and after completion of the LOCA
( test, the penetrations were resealed'and tested to 63 psig with
no leakage detected. Since the post-LOCA resealing does not
demonstrate that the penetration would meet the required
leakage criteria during an accident, the licensee was asked to
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provide additional information that demonstrated the
leak-tightness of the penetration assembly. During the
inspection, the licensee obtained additional test data that
demonstrated the leak-tightness of the penetration. The' data
will be added to the EQ file.
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6) The licensee's qualification. specification stated that~ the EQ-
file demonstrated the qualification of the GE coax cable
contained within the penetration for use with the GA radiation
monitor. No coax cable was included in the test. The licensee-
provided clarification that the triax cable is used with the QA
radiation monitor and not coax cable as initially indicated.
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7) The licensee's qualification specification for this penetration
listed a aifferent radiation exposure than was provided for the
Conax penetration discussed previously and performing the same
essential function. A clarification was . requested from the
licensee. The licensee stated that the radiation value
provided in EQ Reference File 214 (Conax penetration) was a
typographical error and an addendum will be issued to correct
the error.
8) The licensee was requested to provide its response to NRC
Information Notice IEN 86-104 which discussed qualification of
splice material used with the GE penetrations.. The licensee's
review of the Information Notice was contained in the licensing
file. The licensee had determined during review of IN 86-104
l that only qualified splices (Raychem) are.used with the
electrical penetration' assemblies.
Based on the above review, qualification of the General Electric
Canister-type electrical penetration had not been established prior
to this inspection.
This is in violation of'10 CFR 50.49, paragraphs (f) and (g), which
requires that each item of electrical equipment important to safety
be qualified and that qualification must be completed at a time no
later than November 30, 1985 (050-333/87-14-17).
11.0 Plant Walkdown
The plant physical inspection consisted of an examination'of safety-re- !
lated EQ equipment located inside and outside tr mtainment. The
inspectors examined various environmentally qualified components including
solenoid operated valves, pressure transmitters, electrical penetration
assemblies and Limitorque motor operated valves.
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i Covers were removed from several solenoid operated valve condulet boxes to l
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determine pigtail lead splice configuration.
Specific equipment items inspected during the plant walkdown included: 1
Solenoid Valve Numbers 20SOV-83 and 2050V-95.
The two solenoid operated valves (SOVs) are AAA S0Vs qualified under
EQ Reference File 282. The SOVs are located in the pipe tunnel and
are used as pilot operators for primary containment isolation
valves. During the plant walkdown, it was noted that the sealtight
flexible conduit for 20SOV-95 had become separated from the solenoid
coil housing and was supported by the coil lead wires. The licensee .!
provided the inspector with a copy of Work Request No. 51675,
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dated April 29, 1987, which addressed repair of the conduit; No
deficiencies were noted.
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- General Electric Canister-type Penetration Number JB-X110F
located in the Reactor Building. The licensee removed the outboard l1
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penetration cover to facilitate internal inspection. The penetra-
tion contained low voltage power and control cable terminated at- ;
terminal blocks. The terminal blocks were coated with a conformal ;
coating which had also coated the electrical cable. The Licensee '
was able to provide an EQ reference file for the coating material. j
No deficiencies were noted. !
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- Conax Modular Electrical Penetration Number JB-X1100 containing low
voltage power and control circuits. The outboard penetration cover
was removed by the licensee to facilitate internal inspection. The
installed configuration of the penetration reflected the information
contained within the qualification file, and all cables were spliced
with a qualified Raychem splicing material, i
Limitorque Actuator Number 10MOV398. NYPA personnel _ removed the
limit switch compartment cover to allow a thorough inspection. The
actuator was observed to have the proper (brown) limit and torque
switches, and was found to be fitted with T-Drain and a grease
I relief. Electrical connections were made to the actuator by taped j
l splices. Space heaters were disconnected. No deficiencies were
noted. :
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BMCC2 Motor Control Center. The MCC was found to have several small i
- screws missing at various locations on the front of the panel which i
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could possibly allow water entry. It was noted that the MCC is
located under open deck grating which could allow water drainage j
onto the top of the panel. j
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The licensee stated a design change will be initiated to increase i
the MCC's water tightness integrity (reference paragraph 11.14).
Transmitter numbers 02DPT-117B&C were found to have incorrect serial ,
numbers on the SCEW sheets. The licensee agreed to revise the SCEW !
sheet to reflect the correct serial numbers. No deficiencies were !
identified. I
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12.0 Unresolved Items
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Unresolved items are matters about which more information is required in I
order to ascertain whether they are acceptable items or violations.
Unresolved item (s) identified during this inspection are discussed in
Details, paragraphs 5.0, 10.5, 10.6, 10.7, 10.8, 10.11, 10.15 and 10.16,
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13.0 Exit Meeting
The inspector met with licensee' corporate personnel and licensee repre-
sentatives (denoted in Details, paragraph 1) at the conclusion of the
inspection on May 1, 1987, .The inspector summarized the scope of the.
inspection and the inspection findings.
At no time during this inspection was written material given to the
licensee.
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