ML20236L376
| ML20236L376 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/04/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| IEIN-84-44, NUDOCS 8711100300 | |
| Download: ML20236L376 (4) | |
Text
g-l q:^'
t,, :l :
.:M 5 '.' y,
.3. 7 :
1 zi, q;a S! '
,?
', L 4 i
s u
- { <;t ;..
. _, c ;
y,;
- > =
- 8 3_,; ;
- }
[
l
- DUKE POWER GOMPANY\\
1 1 P.O. BOX 33189 D
. q' CHARLOTTE, N.O. 28249.:
i TELupuomr.'.
HAL H. TUCKER L-wuotaan rnoosiovion :
1i',
, g ig.
,,vics ens inent
" (704) 0r&4531' 4
.. ]
'i V,]
^
.\\
I t
a November 4,119871 i;
qj
..,g c
.m
'[-
t j
9; 1
(~-
1 U.S. Nuclear. Regulatory, Commission' f
'j
-Document; Control Desk y' l1 Washington, D.C. (20555 s
. 9 h
A s.
l<
Subject:
McGuire Nuclear' Station Docket Nos.- 50-369,?-370
,' WD i
NRC/0IE. Inspection Report.Nos.
50-369/86-20 and 50-370/86'-20.
l ' g..
Gentlemen Pursuant to 10CFR. 2.201,.please find. attached the responso 1to ' the ' violation,
,s J
1 identified in the above referenced inspection report.
.j Very truly'yours,
/~
$]Aeb%c
)
L
/
j
-Hal B. Tucker l
,)
i SEL/141/sbn Attachment xc:
Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission o
Region II l-101 Marietta St., NW, Suite 2900 Atlanta, GA. 30323 t
Mr. Darl Hood' l
A' U.S. Nuclear Regulatory Commission
(
Office of Nuclear Reactor Regulation
- I l:
Washington, D.C.
20555 Mr. W.T. Orders 1
l-
'NRC Resident Inspector McGuire Nuclear Station i
4 8711100300 871104 l
PDR ADDCK 05000369f
, i
..G ;
PDR.
1; q
v a
7
'I t
g
..i 4d c(I DUKE POWER COMPANY-4 McGUIRE NUCLE M STATION j
' VIOLATION RESPONSE 7
o i
Multiple Exampics Were Identifled as 50-369, ;370/86'20-02, '-04,
-05,E-06, and.
-07.
10 CFR 50.49(f)' and (k) respectively require, in part, that - (l) each item - of electric equipment important to safety shall be ' qualtfied by testing of, or experience with, identical or similar equipment, and: the qualification shall-
. include ' a - supporting analysis to show that the equipment to, be qualified is -
acceptnble; and (2) electric equipment with NUREG -0588 (for comment ? version),.
" Interim' Staff Position 'on Environmental -Qualification'.tof - Safety-Related
' Electrical Equip nent", need not be requalified to 10 CFR 50.49.
Contrary to the above, at the time of the inspection and as far sback as November
)
1
/
30, 1985:
)
(1) The qualification documentation for ~ Limitorque ' MOVs ;(TAG Nos'. : 1VX0001A, IVX0002B, INSSV5570, ICA0050B, ICA0054AC, and 1CA0066AC) did not establish
.I similarity between installed MOVs and those tested in' that, unlike those 1
Ll tested, the gear case grease reliefs on the' installed MOVs were covered with-shipping caps.
(2) Qualification was not established for Samuel Moore
-(Eaton) polyvinylcholoride (PVC) insulated cable in that the basis for qualification was the presumption of generic material' similarity between the Samuel Moore
')
PVC and Brand Rex PVC (for which a gitalification test report was in the Samuel Moore EQ file) without supporting analysis or test data.
(3) Qualification was not established for ' Rockbastos "Firewall SR"~ silicon-rubber insulated cable in that the cable's; qualification was based solely on 1
existing Rockbestos test reports which - are considered : inconclusive (as j
discussed in IE Information Notice 84-44) and 'there was no additional 1
information or analysis in the file to augment the original test reports or demonstrate qualification independently.
]
(4) Qualification documentation for generic cable files did not demonstrate that the cables met performance requirements for their plant applications in that the appropriate functional performance requirements were not established and 1
the required analysis was missing from the files.
(M Duke had not established qualification for safety-related Barton 386A pressure transmitters in. that there was no analysis to show similarity t
between the 386A and the qualified 764 transmitter HESPONSE:
(1) Admission or denial of violation:
Duke admits the violation occurred subject to the following clarification.
Certain equipment qualification files were judged. by the auditors to have incomplete information.
It is Duke's position that some of these i
+2-
]J conclusions are subjective and based on,a difference in technical opinion on what is. sufficient to verify qualification.
Duke's specific comments ' in j
this. regard were detailed in H. E. Tuckor's; August 15, 1986 letter to J. M.
ll j
Taylor.
i (2) The reason for the violation if admitted:-
l f
Example 1:
Limitorque MGV'r grease caps-Neither the Limitorque 4
installation ' manual nor the. Limitorque qualification. report specifically required removal of the grease relief shipping j
caps.
As a result, some shipping, caps had not been removed i
during construction.
Example 2:
Similarity analysis for PVC cable-The Samuel Moore cable E.Q.
file based qualification on similarity of materials (PVC) with a Brand Rex test report. The file did not explicitly explain the conservatism.due to the plant specific application being substantially less severe than the test tuvironment.
l Example 3:
Rockbestos "Firewall SR" cable-Duke had not considered IE l
Notice 84-44 to invalidate -Rockbestos qualification for the l
McGuire application.
The Rockbestos E.Q.
file did - not explicitly explain the conservatism of' the McGuire application.
i Example 4:
Performance requirements of cables ard penetrations-Duke Power Company had analyzed " worst case" instrumentation circuits for effects of leakage currents on required instrument accuracy.
This analysis was not refined to include specific cable / penetration types.
l Example 5:
Barton 386A pressure transmitters-The E.Q. file addressed test anomalies and similarity to a Barton 764 transmitter in a manner that was judged to be inconclusive by the auditor.
(3) The corrective steps which have been taken and the results achieved:
I Example 1:
Limitorque MOV's Grease Caps-Duke provided to the NRC prior to 1
the exit interview an evaluation justifying that the shipping l
caps would not impair the ability of the valves to perform i
their required safety function.
This evaluation has been placed in the Limitorque qualification file.
Additionally, 1
l Limitorque MOV's have been inspected and shipping caps, if j
found, were removed.
i Examples 2&5: Similarity Analysis of PVC Cable and Barton 386A Pressure Transmitters-Prior to the exit interview Duke Power Company presented to the auditors draft revisions to the subject files i
to specifically address the similarity concerns expressed by I
the auditors.
These draft revisions were found to be acceptable by the auditors.
Subsequently, these revisions have been formally placed in the appropriate qualification files.
j l
l l
I l
CL j
i u
f L.
3 i,
i Example 3:
Rockbestos "Firewall SR" Cable-Duke ' presented the ' inspection temn with supplemental documentation 1to show the substantial conservatism for the McGuire applications.
This documentation 1 has been filed 'with the applicable Rockbestos : qualification.
j file along with specific applications and justification.
For.
j additional conservatism, appropriate. documentation has been revised te reflect a 20 year replacement interval. for the cable.
It should also be noted that Luke is still following. the -
Rockbestos retest program.
It is anticipated that the fiEl report will substantiate a 40 year qualified life.
j 1
]
Example 4:
Performance Requirements of Cables and Penetrations-Calculations have been completed to address leakage current I
)
data of specific cables and penetrat' ons.
These calculations i
have been referenced in t'no appropriate penetration
-1 qualification files.
]
I (4) The corrective steps which will be taken to avoid further violations:
j s
Example 1:
Limitorque MOV's Grease Caps-Specific instructions have been added to the Limitoroue instruction / installation manual to l
require removal of dust caps at the time operators are wired
)
for power.
{
-l Examples 2&5: Similarity analysis of PVC cable and Barton. 386A - Pressure j
Transmitters-The similarity analyses concerns and results of j
the audit were reviewed with the Engineers-responsible for Equipment Qualification.
Additionally, periodic training for l
appropriate Design Engineering personnel is planned on EQ f
procedures and EQ activities.
)
Example 3:
Rockbestos "Firewall SR" Cable-The Rockbestos cable testing program is considered a unique situation in that anomalies
}
discovered "after the fact".
Duke Power Company actively i
participated in the resolution of this problem with Rockbestos and other members of the Nuclear industry.
f> uke considers its l
response to IE Notice 84-44 to be consistent with regulatory
)
requirements. Future problems of this type will be evaluated i
on a case-by-case basis for app?icability to specific
]
operating station conditions and to ensure related i
qualification files are complete.
.)
1 Example 4:
Performance Requirements of Cable and Penetrations-
)
Instructions have been placed in work place procedures to I
ensure leakage currents of the cables and penetrations are addressed in the E.Q. files, i
(5) The date when full compliance will be achieved:
i i
Examples 1-5: As of the date of this
- response, all revisions to I
qualification manuals / procedures / files as noted above have been completed.
Further additional internal audits have been j
conducted on the E.Q. files to substantiate the completeness j
of the files.
3 i
l