ML20236S451
| 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: |
| References | |
| 50-245-87-17, 50-336-87-15, NUDOCS 8711250178 | |
| Download: ML20236S451 (9) | |
See also: IR 05000245/1987017
Text
._
..
.
.
_
_ _ _ . _ _ _ _ _ - _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ - - - - _ . - _ _ _ _ - _ _ - _ _ - _ _ _ _ _ _ - _ - -
llf; I?;
'
n.y
-J \\
(e ;;
- ,'
U.S.' NUCLEAR REGULATORY COMMISSION
'
REGION I-
,
Report.Nos. 50-245/87-17:
4
0
50-336/87-15
Doc'k'et 'Nos. : 50-245/50-336
.,
License'Nos. DPR-21/DPR-65
Priority
1
'!
License'i . Northeast Nuclear Energy Company
e
>
P.O. Box:270
Hartford, Connecticut 06141-0270
, Facility Name:'. Millstone-Nuclear Power' Station Unit 1 and 2
. ,
IInspection At:
East Berlin Corporate Office and the Site
,
9
Inspection Conducted: ~ July 15 - 17, 1987
LInspectors:
_
/Nhb7
'
T.-Koshi, Reactgr Engineer
date
'
//-/ 7- 87
fcg.;: R. PaoTino,
e
Reactor Engineer
date
- ei
' Approved by:
O
// /7 N
'
C. An14rson,~ Chief .
date
P1 ant Systems Section
'
Inspection Summary:
Inspection 'on July 15 - 17, -1987 (Combined Report No.
4
50-245/87-17 and 50-336/87-15)
l
' Areas Inspected: An. unannounced regional inspection to follow up EQ findings
. . ,
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.
+
' ' [ .i
2
2 9t
e !'"%1sq
.
sy -
~
L_.__.--.l_---L------.---.--__.__
-__.--___-.L-
___-
- _ _ - - _ _ . - - - _ . -
._-
_ _ _ _ _ _
____-________--_____________________.___w
y
---T-3
,
-.
N
h
.,2
i
!
s;
2.
v.
n' , .
a
'
i
,
Summary of Inspection Findings
Violations
' Paragraph
Item No.
!
- 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.
.!
-3.
Unqu'lified. Replacement Bishop Tape Splice
5.1
50-336/87-15-02
a
g
i-
4.
Ideal Model 798 Wire' Nuts
5.2
50-336/87-15-03
o
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
<
Y
[ .:
l
-
.z
j
!-
,
y
,
p
i
! .,
i
i.
v
!
_ __ - . _ _ _ - .
..
,
u
e
g3
^
. . .
..
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.
I
1
_ _ _ _ _ _ _ _ _ _
_ _ _ _ _ . -
- _..
--
-
-
.j
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ .
_
._
.
4
.
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
.
operated valves nos.:
1
'
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
l
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).
-
.. - _ - _ _ - _ -
t
.
5
.
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.
l
4.2 @ pen) (50-245/85-30-3) Potential Enforcement / Unresolved Item.
j
Limitorque Terminal Block
j
l
The EQ inspection conducted in November 1985, documented certain
j
concerns on Curtis Terminal blocks in Limitorque compartments. The
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
i
_ _ _ _ _ - _ - _ _ _ _ _ _ . - _ _ .
_
_ _ _ .
_ _ _ _ _ _ _ _ _
- .:
6
.
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
_ _ _ _ _ _ _ _ _
. _ _
i
.
7
.
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
!
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
'
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
_ _ _ _ - _ - - _ _ _ _
. - _ _ - _ _ . - - _ _
- _ _ _ _ . __. _ _ _ - _ _ _ _ _ _ _ _ _ .
.
8
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.
i
. -____--- _ -____ _ __-
.D
-- -
-
.__ __
_ _ _ _ _ _ _ _ _ _ _ _ _ _ .
_ _ _ _ _ - _ _ _ _ _ ._.
_
- _ _ _ _ _ _ _ _ _ - _ __ - _ _ _ - _ _ - _ _ _ _ _ _ _ .
.
,
9
I
-
,
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.
l
l
t
<
i
i
_ _ _ _ . _ _ _ _ _