ML20236S451

Insp Repts 50-245/87-17 & 50-336/87-15 on 870715-17. Violations & One Unresolved Item Noted.Major Areas Inspected:Followup of Equipment Qualification Findings Identified in Insp Repts 50-245/85-30 & 50-336/85-35

ML20236S451
Person / Time
Site:	Millstone
Issue date:	11/17/1987
From:	Anderson C, Thomas Koshy, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236S447	List: ML20236S444 ML20236S448 ML20236S451
References
50-245-87-17, 50-336-87-15, NUDOCS 8711250178
Download: ML20236S451 (9)

See also: IR 05000245/1987017

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U.S.' NUCLEAR REGULATORY COMMISSION

REGION I-

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Report.Nos. 50-245/87-17:

4 0 50-336/87-15

Doc'k'et 'Nos. : 50-245/50-336

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License'Nos. DPR-21/DPR-65 Priority 1

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License'ie . Northeast Nuclear Energy Company

P.O. Box:270

Hartford, Connecticut 06141-0270

. , , Facility Name:'. Millstone-Nuclear Power' Station Unit 1 and 2

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IInspection At: East Berlin Corporate Office and the Site

9 Inspection Conducted: ~ July 15 - 17, 1987

LInspectors:

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T.-Koshi, Reactgr Engineer date

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fcg.;: R. PaoTino, e Reactor Engineer date

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C. An14rson,~ Chief . date

P1 ant Systems Section

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Inspection Summary: Inspection 'on July 15 - 17, -1987 (Combined Report No.

4 50-245/87-17 and 50-336/87-15)

. . , ' Areas Inspected: An. unannounced regional inspection to follow up EQ findings l

4 identified in the Equipment' Qualification inspection 50-245/85-30 and

250-336/85-35 conducted in November 1985. The insnection involved reviewing

LLicensee. EQ files at the corporate office, evaluating licensee corrective

actions, Land verification of licensee action for conformance with 10 CFR 50.49

requirements.:

LResults: Five violations and one unresolved item were identified. The

(violations =and the unresolved item are identified in the following table.

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Summary of Inspection Findings

Violations ' Paragraph Item No.

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1. Unqualified General Electric 4.1 50-336'/87-15-01

SIS Vulkene Wire

f- 2. Temperature Profile for Curtis Type L 4.2 50-245/87-17-01 l

Terminal Blocks.

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g -3. Unqu'lified.

a Replacement Bishop Tape Splice 5.1 50-336/87-15-02

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4. Ideal Model 798 Wire' Nuts 5.2 50-336/87-15-03

5. Spray Pump Motor Terminations 5.3 50-336/87-15-04

Unresolved Item. Paragraph Item No.

1. MOV wiring . terminal blocks and ' cable 4.1 50-336/87-15-05

splice qualification

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e DETAILS

1. Persons Contacted

1.1 Northeast Nuclear Energy Company (NNECo.)

F. Dacimo, Engineering Supervisor

B. Hutchins, License Engineer

J. Ferraro, Manager, General Electric Engineering

-J. S. Niosia, General Electric Engineer

. B. Tuthall,. Supervisor, General Electric Engineering

G. Saller, MPI. Engineering

R. Palmeri, Operations Supervisor

J. Summa, Assistant Engineering Supervisor

-K. D. Deslarek, Engineer

• J. Rodearmel, Lead Technician

• R. Bates

P.A. Blasioli, Supervisor, Generation Facilities, Licensing

S. Scace, Station Superintendent (via intercom from Haddem Neck

facility)

1.2. U.S. Nuclear Regulatory Commission (NRC)

T. Rebelowski, Senior Resident Inspector

• Denotes those not present at exit meeting on July 7, 1987.

2. Purpose

The purpose of this inspection was to review and verify the licensee's

corrective action for previously identified EQ inspection findings.

3. Background

During November 18 - 22, 1985, the NRC conducted an EQ team inspection

50-245/85-30, 50-336/85-35. The inspection identified four potential

enforcement items and five unresolved' items. The licensee responded to

the concerns by a letter dated August 5, 1986. A follow up letter dated

December 10, 1986 addressed the licensee's Equipment Qualification

reverification and supplemental walkdown. This walkdown identified  ;

several potential EQ problems on cable terminations, splices Limitorque j

wiring, solenoid operated valves, etc., the corrective actions and the

justification for interim qualification is mentioned in this letter. Some

of the items are addressed in this report. This inspection reviewed the

licensee's corrective actions.

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4. Followup of Previous Inspection Findings

4.1 (Closed) Unresolved Item (50-245/85-30-1; 50-336/85-35-1) Limitorque

Operator Wiring

Licensee Corrective Actions

During the previous refueling outage, the licensee performed a

complete walkdown of all Limitorque motor operated valves in Unit 2.

The NRC inspectors reviewed the walkdown data for motor

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operated valves nos.:

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2-SI-616h, 2-SI-651, 2-RC-405, 2-51-615, 2-MS-202, 2-RB-372

2-MS-65A, and 2-RB-30.1 A and B.

The walkdown sheets had the following inspection attributes to ensure

compliance to the environmental qualification requirements including

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the terminal block concerns addressed in Information Notice (IN)

83-72:

1. Control wiring make, type and model

2. Limit switch type

3. Power cable splice type

4. Limit switch assembly material

l The inspector determined that the discrepancies identified as a

l result of the walkdown were corrected before Unit 2 start up.

Vulkene SIS Wire Deficiencies

The inspector observed that walkdown sheets for three valves, nos.

2-SI-644, 2-RB-37-2A and 2RB-30-1A indicated the use of Vulkene SIS

wire. The licensee qualified this type of wire per Franklin test

l report F-C4497-2 dated March, 1977. NRC review of this report

revealed that the report applied only to SIS Vulkene Supreme wire

also identified as non-Chlorinated Vulkene. The licensee had assumed

that SIS Vulkene is identical to Vulkene Supreme. The inspectors

pointed out the differences between the two types of cables and con-

cluded that the licensee had not established similarity between the

tested sample and the installed SIS Vulkene wire. This is a viola-

tion of 10 CFR 50.49(f) which requires that qualification of each

component be based on testing or experience with identical equipment

or with similar equipment with a supporting analysis to show that the

equipment to be qualified is acceptable (50-336/87-15-01).

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Subsequent to the inspection the licensee provided Wyle test report

No. 47839-02 where the subject wire is tested in a penetration,

Even though this test does not meet the full requirements of wire

qualification, for relatively short length applications, this test

establishes operability. Moreover the licensee committed to take

immediate corrective actions.

The licensee promptly inspected all the potentially affected valves

and identified 13 valves that utilized unqualified wire in the control /

instrumentation circuits. The following corrective actions were performed

and justifications developed for the continued operation of the plant.

The licensee was able to establish similarity of wire used in valves

2-CS-16-1A, 2-SI-656 and 2-SI-646. The unqualified wires in valves

2-CH-501, 2-SI-654 and 2-SI-635 were replaced with qualified wire.

The wire used in 5 valves (2-RB-37-2A, 2-RB-37-28, 2-RB-30-1A,

2-RB-30-1B and 2-SI-651) had no contiol function for the valves.

These wires were used only for position indications function which

is not relied on for plant operational control during Design Basis

Events. The safety injection tank outlet valves 2-SI-614 and

2-SI-644 are kept open during normal and accident conditions. The

closing capability of this valve is disabled during the operating

modes of the reactor. Any potential cable failure to these control

cables will not impact the valve's safety function as the valve is

not required to change status.

Motor Operated Valves Terminal Blocks and Cable Splices

As a part of the NRC follow up on unresolved item (50-245/85-30-1;

50-336/85-35-1) on Limitorque operator wiring, the inspectors

requested the records on wiring verification and corrective action.

At the time of this inspection, Millstone Unit I was shut down for

refueling and the Limitorque wiring activity was in progress. The

corrective actions on Unit 2 was complete and the unit was operating.

Out of the 42 motor operated valves for Unit 2, the licensee was able

to substantiate wiring terminal blocks and cable splice qualification

of only eight MOVs. This item is unresolved (50-336/87-15-05) pending

NRC review of the field verification data on the remaining motor

operated valves.

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4.2 @ pen) (50-245/85-30-3) Potential Enforcement / Unresolved Item. j

Limitorque Terminal Block j

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The EQ inspection conducted in November 1985, documented certain j

concerns on Curtis Terminal blocks in Limitorque compartments. The i

licensee letter dated August 5, 1986 stated that the terminal block ]

under question was verified to be the qualified type "Curtis Develop- '

ment and Manufacturing Type L." The inspector examined the qualifi-

cation data for the subject terminal block. The qualification report

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identified as 80119 is included in Limitorque file MP1-122. This

test report qualifies the terminal blocks only up to 312 F, The

licensee has utilized these terminal blocks in drywell applications

where the peak temperature is 330 F during postulated accident

conditions. The licensee walkdown' data on isolation condenser valve

1-IC-1 indicates the use of Curtis L type terminal blocks inside the

Limitorque compartment. As the temperature difference in the quali-

fication profile is only 18 F, the subject terminal blocks is

qualifiable for the interim operation. However, lack of qualifica-

tion data during the inspection constitutes a violation of 10 CFR

50.49(e)(1) which requires equipment qualification be based on the

time dependent temperature for the most severe Design Base Accident

during or following which this equipment is required to remain

functional (50-245/87-17-01) .

The other aspects of the subject unresolved item that deal with other

types of terminal blocks and their application in Limitorque compartments

will be inspected at a later audit.

4.3 [Open) Open Item (50-245/85-30-4; 50-336/85-35-3) Replacement

Equipment Procurement This item addresses the lack of specific

requirements to include the current qualification criteria. The

licensee is in the process of revising their procedure NE&O 6.02 to

direct purchase requisitions to the special programs and study groups

for review and approval. NE&O procedure 2.21 is also in the revision

process to incorporate the necessary EQ requirements. This' procedure

is expected to be issued by August 31, 1987. This item remains

open pending NRC review of the licensee procurement procedures.

4.4 (0 pen) Open item (50-245/85-30-5; 50-336/85-35-4) Completion of

Maintenance Program This item deals with forwarding EQ maintenance

data to Plant Maintenance department. The EQ maintenance data is

identified in the SCEW sheets. This information is compiled into a

book and forwarded to plant maintenance for scheduling maintenance

activities. The first issue of the maintenance books has been

incorporated into plant procedures. The second revision to this

book has been issued. This information is stored in a maintenance

computer which generates work orders and instructions based on the

required schedule.

In order to check the adequacy of the maintenance data transfer into

the computer, the inspectors selected the following example. The

licensee's EQ files on General Electric Vulkene cable contained a

consultant report No. GSP-87-203 which required General Electric

Vulkene cable be inspected for replacement in 1989 due to its limited

qualified life for the specific application. The inspectors randomly

selected valves SI-644 and SI-651 with GE Vulkene cable to confirm if

this EQ requirement is included in the maintenance program. The

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inspectors reviewed all the maintenance activities scheduled for the

two outages for these two valves. The licensee inspection or )

replacement of the GE Vulkene' wire was not addressed. 1

This item remains open pending NRC review and verification of the

licensee's maintenance program for transferring maintenance data into

plant procedures / computer to maintain the environmental qualification i

of 10 CFR 50.49 component / equipment. l

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4.5- (0 pen) Open Item (50-245/85-30-6) Solenoid Valve Wiring This item

deals with the replacement of solenoid valve wiring that could j

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potentially degrade due to the self heating effect of the solenoids.

The licensee corrective action on this subject is in progress. The

licensee intends to complete this activity before the end of the .

current outage. This item remains open pending NRC review of the  !

solenoid valve wiring replacement.

4.6 [0 pen)OpenItem(50-245/85-30-7) Conduit Weep Holes This item

addresses the addition of a weep hole at the conduit entrance nearest

to the solenoid valve housing. The existing weep hole at the junc-

, tion box is considered adequate. This additional weep hole is an

l improvement, not a requirement. At the time of the inspection, this

activity was not performed.

4.7 (0 pen) Open item (50-245/85-30-8; 50-336/85-35-5) Motor Maintenance

Requirements This item addresses the omitted manufacturer's

recommendations for maintenance of motors. As these omissions are

identified to be not critical to the current qualified status of the

motors, the licensee intends on reviewing the specified maintenance

and determine its' applicability.

5. NRC Follow up to EQ Issues Discussed in NNECo December 10, 1986 Letter

During the refueling outage of Unit No. 2, the licensee completed a

comprehensive walkdown of the EQ equipment. A synopsis of the findings

and corrective actions were documented in a letter to the NRC dated

December 10, 1986. Each of the discrepancy identified was evaluated by

the licensee for deportability and the justifications for not reporting

were also addressed in this letter. Several of the discrepancies identi-

fied by the licensee were reviewed by the NRC inspectors to determine the

significance of the issues and the adequacy of the licensee's corrective

actions. Our findings are discussed below.

5.1 Lack of Upgraded 0. qualification for Replacement Splices

In order to correct a qualification problem on motor lead wires and

field cables, the licensee replaced the cables that are connected to

high pressure safety injection pump motor. The power feeder cable

was terminated using a Bishop tape splice. This activity was done

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during the refueling outage in May,1986. The NRC inspectors reviewed

the qualification records on Bishop splice. File EE2-MP-147 contained

a similarity analysis of the Bishop tape to Okonite tape. The file

[ did not contain any test data to support the qualification of the

Bishop tape splice configuration. The licensee letter to NRC dated

December 10, 1986 stated that the Bishop tapes were replaced with

NUREG 0588 qualified terminations. However, the inspectors could not

find any test data to support qualification of this splice to NUREG

0588, Category I requirements. This approach of qualifying equipment

based purely on analyses and no type test data, does not meet the

requirements of 10 CFR 50.49. This is a violation of 10 CFR 50.49(1)

which requires replacement equipment be qualified in accordance with

the provisions of this section by testing an identical item under

identical condition or similar conditions unless there are sound

reasons to the contrary. As of July 17, 1987, the licensee had not

addressed the sound reasons to the contrary (50-336/87-15-02).

Subsequent to the inspection, the licensee submitted the following

reasons:

(a) The DDR qualifications assure an operable splice. <

(b) The qualified environmental capability of the Bishop tape

splice is substantially greater than that required for the

application.

(c) NUREG 0588 Category I qualified materials were not available at

the time of installation.

The reasons (a) and (b) establish the operability of the subject

splices. However, these reasons do not satisfy the upgrade requirements

of 10 CFR 50.49. Considering the fact that this splice was replaced

in May 1986, the reason (c) cannot be well supported as splices

qualified to NUREG 0588 Category I requirements were readily avail-

able from the manufacturer.

5.2 Qualification of Wire Nuts

During the walkdown of Limitorque Motor Operated Valves conducted in

1986 outage, the licensee observed several wire terminations using

Ideal Model 74B wire nuts. These wire nuts are used on control and

motor power supply leads inside Limitorque compartment. The licensee

letter dated December 10, 1986 to NRC indicated that Ideal Model 74B

wire nuts used in limitorque valves were evaluated for normal and

accident conditions and found to be adequate for interim operation.

The licensee was unable to provide any documented evidence to support

this conclusion. These wire nuts were replaced in the 1986 outage.

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This is a violation of 10 CFR 50.49(f) which requires qualification

of each component be based on testing or experience with identical

. equipment or with similar equipment with supporting analysis.

(50-336/87-15-03)

5.3 Qualification of Motor Termination

The outage walkdown in 1986 verified the adequacy of the power cable

termination to motors located in harsh environment. The licensee

letter dated December 10, 1986 also addressed containment spray pump

motor terminations for P-43A and P-438. The licensee stated that no

specific data was available as they were original plant installation.

The licensee's qualification basis was that the " terminations were

well engineered, were in excellent condition and utilized typical

tape system materials of that time". The inspectors were unable to

find any sound basis to support the qualification of these terminations.

This is a violation of 10 CFR 50.49(f) which requires qualification

of each component be based on testing or experience with identical

equipment or with similar equipment with supporting analysis

(50-336/87-15-04). These splices were replaced with qualified

splices in the 1986 outage.

6. Unresolved Item

Unresolved items are matters about which more information is needed in

order to ascertain whether they are acceptable items or violations. An

unresolved item identifed during this inspection is discussed in Section

4.1 of this report.

7. Exit Meeting

The inspectors met with the licensee corporate personnel and the

representatives from both plants at the conclusion of the inspection on

July 17, 1987. The inspectors 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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