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Equipment Qualification Safety Insp Rept 50-341/87-39 on 870921-1109.Violations Noted.Major Areas Inspected:Action on Ser/Technical Evaluation Rept Commitments,Equipment Qualification (EQ) Program & Adequacy of EQ Documentation
	ML20237A294
Person / Time
Site:	Fermi
Issue date:	12/07/1987
From:	Gardner R, Gautam A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20237A236	List: ML20237A235; ML20237A258; ML20237A294;
References
	50-341-87-39, IEB-79-01, IEB-79-1, NUDOCS 8712140386
	Download: ML20237A294 (11)
	v • d • e

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/87039(DRS)

Docket No. 50-341 License No. NPF-43

Licensee: Detroit Edison Company

2000 Second Avenue i

Detroit, MI 48224

Facility Name: Fermi 2

Inspection At: Fermi 2 site and Glen Ellyn, Illinois

Inspection Conducted: September 21 through November 9, 1987

Inspector: A. S. Gautam 6t ' '^ '

.C

Date

Also participating in the inspection and contributing to the report were:

M. Kopp, RIII

J. Jacobson, NRR

J. McGhee, INEL

H. Stromberg, INEL

M. Trojovsky, INEL

L. Bustard, Sandia

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Approved By: R. N. Gardner, Section Chief

flant Systems Section, Region III Date

Inspection Summary

Inspection on September 21 through November 9, 1987 (Report No. 50-341/87039(DRS))

Areas Inspected: Special announced safety inspection of the environmental

qualification (EQ) of electric equipment within the scope of 10 CFR 50.49.

The inspection included licensee action on SER/TER commitments; EQ program

compliance to 10 CFR 50.49; adequacy of EQ documentation; and a plant physical

inspection of EQ equipment (Modules No. 30703 and 25576).

Results: The licensee has implemented a program to meet the requirements of

10 CFR 50.49. Deficiencies identified in the areas inspected are summarized

below:

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VIOLATIONS

Item No. O_escription Report Section

50-341/87039-006(DRS) Weidmuller terminal blocks found 3.a

unqualified based on inadequate

documentation.

50-341/87039-007(DRS) AVC0 solenoid valves found 3.b

unqualified based on inadequate

documentation. q

POTENTIALLY ENFORCEABLE / UNRESOLVED ITEM

Item No. Description Report Section

50-341/87039-003(DRS) Deficient Raychem splices used 2.c(3)

in 10 CFR 50.49 circuits.

50-341/87039-004(DRS) Failure to demonstrate qualification 2.c(4)

of nylon wire nuts in Limitorque

operators.

OPEN ITEMS

Item No. Description Report Section

50-341/87039-001(DRS) Incorporation and implementation of 2.c(1)

EQ maintenance and surveillance

requirements into the EQ program.

50-341/87039-002(DRS) Recalculation of qualified life for 2.c(2)

any affected equipment in the drywell

for temperatures identified to be

in excess of aging temperature used

in EQ documentation.

50-341/87039-005(DRS) Lack of formal EQ training for 2.e

maintenance personnel.

50-341/87039-008(DRS) Lack of specific instrument loop 3.c l

accuracy calculations. l

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DETAILS

1. Person Contacted

a. Detroit Edison Company

R. Sylvia, Group Vice President

F. Agosti, Vice President, Nuclear Engineering *

R. Lenart, General Director, Nuclear Engineering

J. Lemon, Director, Plant Safety

T. Randazzo, Director, Regulatory Affairs

G. Trahey, Director, Nuclear QA

L. Schuerman, General Supervisor, Nuclear Engineering

+*Q. Dong, Supervisor, Nuclear Engineering

L. Wooden, Supervisor, Nuclear Technology

J. Rotundo, Supervisor, Maintenance Support

L. Fron, Supervisor, Mechanical / Fluid Systems

L. Bregni, Senior Engineer, Licensing

L. Grant, Lead EQA

F. Konja, EQ Engineer

K. Bandyopadhyay, EQ Engineer

J. Kilpatrick, EQ Engineer

L. Raizanen, EQ Engineer

M. Bowery, EQ Engineer

M. Baxi, EQ Engineer

E. Opland, EQ Coordinator, Maintenance

K. Faulk, EQ Coordinator, Maintenance

b. Consultants-

P. DiBenedetto, DiBenedetto Associates

M. Spisak, Sargent & Lundy

S. Akhtar, Sargent & Lundy

A. Behera, Sargent & Lundy

c. Nuclear Regulatory Commission (NRC)

W. Rogers, Senior Resident Inspector

U. Potapovs, NRR

Denotes those attending the interim site exit meeting on September 25,

1987.

+ Denotes those attending the exit interview on November 9, 1987, at the

conclusion of the inspection.

2. EQ Program Compliance to 10 CFR 50.49

The inspectors reviewed selected areas of the licensee's EQ program to

verify compliance to 10 CFR 50.49. The licensee's EQ program was found

to identify methods of equipment qualification; provide for evaluation

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and maintenance of EQ documentation in an auditable form; provide for

upgrading of replacement equipment; and provide for control of plant

modifications. Based on their review, the inspectors determined that the

licensee had established an adequate EQ program in compliance with the

requirements of 10 CFR 50.49. The licensee's methods for establishing

and maintaining the environmental qualification of electrical equipment

were reviewed in the following areas:

a. EQ Program Procedures

The inspectors examined the adequacy of the licensee's policies

and procedures for establishing and maintaining the environmental

qualification of equipment within the scope of 10 CFR 50.49. The

licensee's EQ program was reviewed for procurement of qualified

equipment; maintenance of qualified equipment; modifications to the

plant that could affect qualified equipment; updating of the EQ

master list; and review and approval of EQ documentation.

Procedures reviewed included the following documents:

NE Procedure 6.02, EQ Central Files, Revision 0 .

NE Procedure 6.7, EQ Review of Design Change Documents,

Revision 0

P0M 12.000.113(SQ), Nuclear Production EQ Program,

Revision 0

N0P 120, Environmental Qualification, Revision 0

NE Procedure 6.5, EQ Review Design Calculations, Revision 0

POM 12.000.017(SQ), Preventive Maintenance Program,

Revision 6

NE Procedure 6.6, EQ Maintenance and Surveillance Program,

Revision 2

NE Procedure 6.03, EQ Equipment Upgrade / List Methodology,

Revision 0

NE Procedure 6.8(SQ), Identification and Disposition

of Potential Noncompliance to 10 CFR 50.49, Revision 0

NE Procedure 6.1, EQ Manuals and Updates, Revision 0

P0M 12.000.015(SQ), Work Requests, Revision 28

NQAP Procedure 1801, Audits, Revision 8

Specific areas reviewed in these procedures included definitions

of harsh and mild environments, equipment qualified life, service

conditions, periodic testing, maintenance and surveillance, and

upgrading of replacement equipment purchased after February 22, 1983.

No violations of NRC requirements were identified,

b. 10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment

IE Bulletin No.79-01B required licensees of all power reactor

facilities with an operating license to provide a MEL that

identified each Class IE electrical equipment item relied upon

to perform a safety function during a design basis event.

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10 CFR 50.49, Paragraph (d), requires licensees to prepare a

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list of electrical equipment important to safety and within the

l scope of the rule. The NRC inspectors reviewed the licensee's

l MEL for compliance to 10 CFR 50.49. Areas reviewed included

adequacy of the MEL, technical justifications for removal of i

items from the MEL, and licensee reviews of the MEL for changes

due to field modifications. The inspectors verified the

completeness / adequacy of the list in terms of equipment needed

during accident conditions through review of piping and

instrumentation drawings (P& ids), emergency procedures, technical

specifications, and FSARs.

Since Fermi 2 E0Ps do not reference specific plant instruments

when describing required operator actions, the inspectors selected

safety-related equipment that the operators would be expected to use

during an accident. Plant emergency procedures reviewed in regard to

the MEL included Reactor Level / Pressure Control (Proc. 29.000.01),

Primary Containment Control (Proc. 29.000.03) and Reactivity Control

(Proc. 29.000.08). P& ids were reviewed for the Core Spray (CS)

System, Residual Heat Removal (RHR) System, Reactor Core Isolation

Cooling (RCIC) System, High Pressure Coolant Injection (HPCI) System,

Combustible Gas Control (CGC) System, Reactor Water Cleanup (RWCU)

System, and Standby Liquid Control (SLC) System. Selected equipment

was verified to be part of the Fermi 2 MEL.

No violations of NRC Requirements were identified.

c. EQ Maintenance and Surveillance Program

The inspector reviewed specific maintenance, component parts

replacement, surveillance tests, and inspections necessary to

preserve the environmental qualification of EQ equipment identified

on the MEL. EQ requirements in the licensee's maintenance 1

procedures and EQ binders were reviewed against maintenance records

of selected equipment to verify performance of maintenance and

surveillance activities at prescribed intervals, including gasket

inspection, lubrication, torquing of housing covers and installation

of replacement parts. The following exceptions were identified:

(1) The inspector observed that certain EQ requirements had

not yet been incorporated into the licensee's maintenance

and surveillance programs, and that several EQ maintenance

requirements had not yet been implemented in the field.

The licensee stated that the Fermi 2 SER, Supplement No. 5,

Section 3.11.5 allowed Fermi 2 to not fully implement their

EQ maintenance program until the plant reached full power

operation. In response to the inspector concerns, however,

the licensee agreed to do the following:

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l * Incorporate all EQ n Mtenance and surveillance

l rm Mrements into tt r EQ program prior to startup

l M Licir current occage.

l * Review past maintenance and surveillance records to

verify if any EQ equipment had been compromised due to

missed activities. If such deficiencies were found,

the licensee agreed to rework the equipment or justify

its operability prior to startup.

Implement all EQ maintenance and surveillance

requirements prior to full power operation.

Subsequent to these findings the inspectors confirmed through

a very limited review that the licensee had taken corrective

action by incorporating appropriate EQ maintenance and

surveillance requirements into their EQ program. The licensee

also r2 worked or justified the operability of equipment in

cases where maintenance may have been missed. Region 111 shall

perform a detailed inspection to further review the licenstie's

corrective action.

Pending further NRC review of this corrective action, this is

considered an Open Item. (50-341/87039-001(DRS))

(2) Monitoring Drywell Area Temperatures

The NRC has recently identified a generic industry concern

regarding BWR containment temperatures being possibly higher

than temperatures considered in the aging calculations of

10 CFR 50.49 designated equipment. The licensee stated that

in order to address this NRC concern the Fermi 2 Nuclear

Station has in place a program for monitoring drywell area

temperatures during power ascension. Input from this program

shall be used to verify / validate analytical values used in

determining the qualified life of Fermi 2 EQ equipment. This

program uses temporary and permanent thermocouple to obtain

area temperatures at various power levels and environmental

conditions, and is scheduled to continue for one year after

the commercial (full power) operation date. In particular,

containment temperatures will be monitored during the hottest

day in summer at full power. Data accumulated to date

indicates that some areas of the drywell above 611' elevation

will see normal conditions in excess of the 135 F containment

average ambient temperature. Fermi 2 has utilized this

information to recalculate the qualified life for affected

equipment.

Pending further NRC review this is considered an Open Item. l

(50-341/87039-002(DRS)) I

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(3) Raychem Splices

The licensee identified numerous deficiencies in the

installation of Raychem splices used in 10 CFR 50.49 circuits.

Most deficiencies appear to be qualifiable through new testing;

however, some deficiencies have not yet been demonstrated to be

qualifiable.

Pending further review by the licensee and the NRC this is

considered a Potentially Enforceable / Unresolved Item.

(50-341/87039-003(DRS)

d. Plant Procurement and Upgrading of Replacement Equipment

- Licensee procejures were found to adequately address upgrading

of replacement equipment purchased after February 22, 1983.

Procurement procedures and documents were found to adequately

address appropriate quality and regulatory requirements regarding

the environmental qualification of equipment within the scope of

10 CFR 50.49. Checklists were observed to have been used to provide

evidence of reviews and approvals. Procurement packages for the

replacement of equipment were found to properly address upgrading

of replacement equipment to the requirements of IEEE 323-1974.

No violations of NRC requirements were identified. l

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e. Quality Assurance (QA) and Training Program

During this review the inspectors determined that the licensee had

implemented a program to monitor the quality of EQ activities I

through surveillance, audits, and reviews of the records and files '

for plant modifications and equipment procurement. NRC inspectors

reviewed the licensee's QA audits including QA Audit

No. A-05-P/TS-86-17 conducted in May 1986. The inspectors found

the methodology, results and followup corrective action relative

to the audit acceptable. No violations of NRC requirements were

identified.

The NRC inspectors also reviewed the licensee's staff training

program and associated records relative to the performance of EQ

activities. The training records indicated that the licensee had

implemented a training program for key engineering personnel,

including management; however, maintenance personnel responsible

for EQ activities were observed to have not been formally trained.

Current training for maintenance personnel consists of informal

instruction. reading of procedures and news letters. The licensee

agreed to upgrade their training program for maintenance personnel.

Pending further NRC review this is considered an Open Item.

(50-341/87039-005(DRS)

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3. Detailed Review of Qualification Files

The licensee qualified their EQ equipment to the requirements of NUREG-05b3

CAT II (10 CFR 50.49, Paragraph K). The inspectors reviewed over

30 equipment qualification files for evidence of the environmental

qualification of equipment within the scope of 10 CFR 50.49. Files were

found to include a full description of the equipment; similarity analysis

of tested equipment to that installed in the plant; allowed mounting ;

methods and orientation; qualification of interfaces (conduit housing, '

seal, etc.); evaluation of aging effects on equipment; description of

test sequence and methodology; environmental conditions for the equipment

during an accident; qualification for submergence of applicable equipment;

resolution of test anomalies; and maintenance / surveillance criteria for

the preservation of the qualified status of equipment.

The inspectors selectively reviewed the above areas, as applicable,

including special reviews for the required duration of operability of

equipment; licensee evaluation of tested materials and configurations

relative to actual plant installations; adequacy of test conditions;

aging calculations for qualified life and replacement intervals; effects

of decreases in insulation resistance on equipment performance; adequacy

of demonstrated accuracy of equipment and interfaces during an accident;

and licensee evaluations of discrepancies identified in IE Notices and

Bulletins.

EQ files were reviewed for electrical cables, cable splices,

terminations, terminal blocks, electrical motors, solenoid valves,

electrical penetrations, seals, lubricants, transmitters, temperature

elements, radiation monitors, control and position switches, switch

gear, control panels and miscellaneous electrical devices.

The inspectors identified various deficiencies in the EQ documentation

contained in the licensee's EQ files. Details are noted below:

a. Weidmuller SAK Terminal Blocks (EQ1-EF2-101)

This file was used to demonstrate the qualification of Weidmuller

SAK terminal blocks for use inside the drywell in 120 VAC control,

460 VAC power, and thermocouple instrumentation circuits. The

inspector noted that the test data did not conclusively demonstrate

operability of the terminal blocks at 460 VAC.

The qualification file described a generic test during which the

Weidmuller SAK terminal blocks were enclosed in NEMA 4 enclosures

and exposed to LOCA/ Spray conditions. Whenever cold sprays were

initiated, the one amp circuit breakers would fail. Failure of

the one amp circuit breakers did not occur when the 600 VAC applied

voltage was reduced to approximately 150 VAC. Therefore, i

operability at 460 VAC was not demonstrated. Subsequent to this

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finding, the licensee provided additional documentation to

demonstrate that the terminal blocks were qualifiable. The licensee

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was informed that the above finding was considered a violation of

10 CFR 50.49, Paragraph (f), failure to qualify equipment by test

or analysis prior to the EQ deadline of November 30, 1985.

This is considered a Level IV violation (Supplement ID).

(50-341/87039-006(DRS))

b. AVC0 Solenoid Valve Assemblies (EQ1-EF2-220)

This file was used to demonstrate qualification of AVC0 solenoid

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valve assemblies for use inside the drywell and steam tunnel on the

MSIVs. The equipment qualification to NUREG-0588, Category II, was

based on a Wyle Laboratory test report 17514-1, Revision A, " Nuclear

Environmental Qualification Test Program on a MSIV Pneumatic Control !

Manifold," dated July 18, 1985, and Addendum I to Wyle Test

Report 17514-1, dated March 21, 1985.

During the test aging sequence, the component was aged to simulate

forty years of qualified life. Following the aging, the assembly

was functionally tested. The assembly failed the functional test by

sticking in an intermediate position. The valve was disassembled

and the failure researched. The failure was determined to have been

caused by the hardening of the lubricant (Parker Super-0-lube) due to

excessive lubrication and high radiation. The lubricant was removed

and the assembly lubricated with a substitute (Houghton 620). A

functional test was satisfactorily performed after reassembly. LOCA

testing was then performed. The assembly was functionally tested

and again stuck in the intermediate position. Like the first time,

this failure was determined to be the result of lubrication failure

at high radiation. The inspectors were concerned that based on

inadequate test documentation, operability under accident conditions

had not been addressed.

The licensee provided additional documentation in their files to

support the Parker Super-0-lube qualification for radiation; however,

the inspectors concluded that the file did not demonstrate the

qualification of the AVC0 when operated in conjunction with the

lubricant under radiation conditions. Subsequent to this finding,

the licensee provided additional documentation to demonstrate that

these valves were qualifiable. The licensee was informed that the

above finding was a violation of 10 CFR 50.49 paragraph (f), failure

to qualify equipment by test or analysis prior to the EQ deadline of

November 30, 1985.

This is considered a Severity Level IV violation (Supplement ID).

(50-341/87039-007(DRS))

c. Instrument Accuracy

During review of instruments required to perform a safety function

during an accident, the inspectors observed that the licensee did

not have site specific instrument loop accuracy calculations to

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justify the performance of the instruments and their interfaces

(cables, terminal blocks, connectors) during harsh accident

conditions. Fermi 2 SSER 5, Section 3.11.5.1, states that the

technical specifications for instrument channel setpoint allowable

values issued for GE/BWR plants (based on the GE setpoint methodology

developed to date) were sufficiently conservative to permit licensing

of the Fermi plant. The SER, however, required the licensee to

perform a confirmatory review of plant specific loop accuracy to

verify that all EQ instruments would perform satisfactorily under

harsh conditions. In a separate letter (Memo from 8. Youngblood,

NRC, to J. Grolyn, Chairman, Utility Licensing Review Group,

February 19, 1985) NRR also apparently indicated to the licensee

that this confirmatory review may start after NRR had reached a

conclusion on the conservatism of the GE setpoint methodology.

This letter further stated that subsequent to a NRR conclusion on the

GE setpoint methodology, the licensee would have six months to

confirm if their instrument accuracy was adequate for plant specific

applications.

The regional team was concerned that such a schedule may result in

the licensee operating with unqualified instruments. Consequently,

the inspectors reviewed six instrument loops and concluded that the

loop accuracy was consistent with the plant tech specs. Based on

NRR's SER comments as well as a Region III discussion with NRR on

this subject, the inspectors identified no immediate safety concerns

regarding the operability of the plant. The licensee stated that

they had completed their confirmatory review for about 30% of the

plant instrument loops but did not expect to complete this review by

full power operation. The licensee was informed by the inspectors

that even though this issue would be further reviewed with NRR,

Region III will expect the licensee to have completed their

confirmatory review for the accuracy of all affected instrument

loops prior to full power operation.

Pending further review of licensee calculations, this is considered

an Open Item. (50-341/87039-008(DRS))

d. Nylon Wire Caps in Limitorque Operators

The licensee identified the installation of nylon wire caps in over

fifty-eight EQ Limitorque operators. Qualification of nylon wire

caps has not been demonstrated by the Limitorque test report. The

licensee has reworked five of these actuators to install Raychem

splices, and determined that the remaining operators would either

not see condensing steam or would not be affected by steam conditions.

This evaluation has not yet been accepted by the inspectors. The

nylon caps are scheduled to be LOCA tested by another licensee at

the Wyle Labs by February 1988. Interim testing submitted by this

licensee was considered adequate for the interim operation of Fermi.

Pending further review this is a Potentially Enforceable / Unresolved

Item. (50-341/87039-004(DRS))

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4. Plant Physical Inspection

The NRC inspectors selected over 40 items on the MEL for examination in

the plant. The EQ file of each item had been reviewed, and information !

regarding the location, manufacturer, model/ serial number, mounting,

orientation, environment, and interfaces had been noted. The inspectors

examined the selected items in the field, as accessible, and verified I

that the method of installation of each item was not in conflict with

its environmental qualification. Specific areas reviewed included ;

traceability of the installed items to the EQ files, ambient environmental l

conditions, qualification of interfaces (connectors, wires, seals,

insulation, lubricants, etc.), evidence of significant temperature rise

from the process fluid, drainage, mounting methods, physical conditions

and housekeeping.

No violations of NRC requirements were identified.

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5. Open Items

Open items are matters which have been discussed with the licensee, which i

will be reviewed further by the inspector, and which involve some action I

on the part of the NRC or licensee or both. Open items disclosed during i

this inspection are discussed in Paragraphs 2.c(1), 2.c(2), 2.e, and 3.c.

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6. Potentially Enforceable / Unresolved Items

An unresolved item is a matter about which more information is required

in order to ascertain whether it is an acceptable item, an open item, a .

deviation, or a violation. Potentially Enforceable / Unresolved Items are )

unresolved items, which if ascertained to be a violation may be followed j

up with enforcement action in accordance with NRC enforcement guidance on 1

environmental qualification. Potentially Enforceable / Unresolved Items

are discussed in Paragraphs 2.c(3) and 2.c(4).

7. Exit Interview

The Region III inspectors met with the licensee's representatives

(denoted under Paragraph 1) during an interim exit on September 25, 1987,

and discussed their findings by phone at the conclusion of the inspection

on November 9, 1987. The inspectors summarized the purpose and findings

of the inspection and the licensee acknowledged this information. The

licensee did not identify any documents / processes reviewed during the

inspection as proprietary. !

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ML20237A294

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