ML20238A224

Safety Insp Repts 50-254/87-11 & 50-265/87-11 on 870608-0728.Violations Noted.Major Areas Inspected:Environ Qualification of Electric Equipment within Scope of 10CFR50.49

ML20238A224
Person / Time
Site:	Quad Cities
Issue date:	08/31/1987
From:	Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20238A165	List: ML20238A163 ML20238A189 ML20238A224
References
50-254-87-11, 50-265-87-11, IEB-79-01, IEB-79-1, IEIN-86-104, NUDOCS 8709090198
Download: ML20238A224 (18)

See also: IR 05000254/1987011

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-254/87011(DRS); 50-265/87011(DRS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30

Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2

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Inspection At: Quad Cities Site, Cordova, Illinois; j

NRC RIII Office, Glen Ellyn, Illinois

Inspection Conducted: June 8 through July 28, 1987

Inspector: A. S. Gautam h h

Reactor Inspector, Region III 'Date

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

M. Kopp, RIII

R. Moist, NRR

J. Stoffel, INEL

H. Stromberg, INEL

M. Jacobus, SANDIA

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Approved By: R. N. Gardner, Chief 31!bl

Plant Systems Section Date

Inspection Summary

Inspection on June 8 through July 28, 1987 (Report Nos. 50-254/87011(DRS);

50-265/87011(DRS))

' Areas Inspected: Special announced safety inspection of the environmental

qualification (EQ) of electric equipment within the scepe 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 No. 25576).

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

10 CFR 50.49. Deficiencies in the areas inspected are summarized below:

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VIOLATIONS

Item No. Description Report Section

50-254/87011-07(DRS) Inadequate documentation to Se

50-265/87011-07(DRS) qualify AVC0 solenoid valves

50-254/87011-08(DRS) BIW and OKONITE cable EQ Sf

50-265/87011-08(DaS) files not auditable to

permit verification of the

environmental qualification

of cables

POTENTIALLY ENFORCEABLE / UNRESOLVED ITEMS

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Item No. Description Report Section

50-254/87011-01(DRS) Unqualified Nylon AMP 2

50-265/87011-01(DRS) Butt splices

50-254/87011-03(DRS) Unqualified SIMPLEX Sa

50-265/87011-03(DRS) butyl rubber insulated

cables

50-254/87011-04(DRS) Ur, qualified SIMPLEX Sb

50-265/87011-04(DRS) polyethylene insulated

cable

50-254/87011-06(DRS) Unqualified GE butyl 5d

50-265/87011-06(DRS) rubber insulated cable

OPEN ITEMS

, Item No. Description Report Section

50-254/87011-02(DRS) Lack of a formal EQ training 4e

50-265/87011-02(DRS) program; lack of EQ training

for subcontractor personnel

50-254/87011-05(DRS) Replacement of GE butyl Sc

50-265/87011-05(DRS) rubber insulated cable

in Units 1 and 2

50-254/87011-09(DR3) Replacement of Nyon AMP butt 6a

50-265/67011-09(DRS) splices in EQ applications

in Units 1 and 2

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DETAILS

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1. Persons Contacted

a. Commonwealth Edison Company (CECO)

• R. L. Bax, Station Manager, Quad Cities Plant

• D. A. Gibson, QA Superintendent

• R. Robey, Services Superintendent

L. Petrie, Assistant Superintendent Maintenance

G. C. Tietz, Assistant Superintendent Operations

+S. Hunsader, Nuclear Li,:ensing Administrator

• M. Kooi, Ragulatory Assurance Supervisor

• J. J. Kopacz, Tech Staff Supervisor

• C. Smith, QC Supervisor

• M. Sievert, EQ Site Coordinator

• Z. J. Boxer, EQ Engineer, SNED

• G. D. Young, Electrical Engineer

M. Reed, Engineer

• M. Brown, QA Inspector

C. Sack, QC Inspector .

• J. Ford, QC Inspector l

• D. Craddick, Master Electrician

• D. Rajcerich, Master IM

B. Viehl,. Engineer

J. E. Housman, Pro.iect Engineer

J. S. Abel, SNED Manager

• I.. M. Johnson, Nuclear Licensing

b. Consultants to CECO

• C, J. Crane, WESTEC

• J. R. Wahl, Independent

• M. J. Wylie, Bechtel Power

A. Behera, S&L

J. Sinnoppan, S&L

C. T. Nieh, General Electric

c. Nuclear Regulatory Commission (NRC)

• R. Higgins, Senior Resident Inspector

A. Morrongiello, Resident Inspector

• T. M. Ross, Project Manager, NRR

• Denotes those attending the interim site exit meeting on June 12,

1987.

+ Denotes those attending the exit interview conducted on the telephone

on July 28, 1987 at the conclusion of the inspection.

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[1- 2. Response to NRC Bulletins

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h a. (Closed) IE Bulletin (50-254/79001-1B; 50-265/79001-1B): This item

addressed requirements of Bul'.etin 79-01A dated June 6,1979, and

_r. ' required the licensee to review qualification and preventative

4 maintenance of ASCO solenoid valves installed in their plant.

During this inspectico, the licensee confirmed that they had

qualified ASCO solenoid valves in EQ applications. These valves

were considered acceptable in regard to problems identified in j

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the bulletin. No concerns were identified. i

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b. (Closed) IE Bulletin (50-254/79001-2B; 50-265/79001-2B): This item

, addressed requirements of IE Bulletin 79-01B dated January 14, 1980,

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regarding the environmental qualification of class IE electrical

equipment required to function during and following postulated

accident conditions. Licensee action was required in the following l

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areas:

(1) A master list was required to be provided for all Engineered '

Safety Feature (ESF) Systems required to function under

postulated accident conditions, including identification

..... of class IE electrical equipment items within these systems

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required to function under accident conditions. Appropriate

submittals were niade by the licensee and found adequate by

, the NRC.

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(2) For each item of class IE electrical equipment identified on

the master list, written evidence was required to be provided

to support the capability of the item to function under

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postulated accident conditions.

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During this inspection, the inspectors reviewed the licensee's

submittals to the NRC which included written evidence of the

qualification of items on the master list. Qualification

e deficiencies had been previously identified by the NRC in the

Franklin Research Center (FRC) Technical Evaluation Report

(TER). The licensee's approach to resolve outstanding

deficiencies was accepted by the NRC in their final July 19,

-c 1984 SER on EQ equipment.

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(3) Service condition profiles (i.e., temperature, pressure,

humidity, radiation as a function of time) were required

to be provided for EQ equipment. The NRC reviewed plant

service condition profiles provided by the licensee. No

concerns were identified.

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(4)79-01B required evaluation of the qualification of EQ '

equipment against the guidelines provided in Enclosure 4

and 5 of the bulletin, and required an equipment

qualification plan including schedules for completing the-

qualification of outstanding items.

The licensee's submittals and subsequent NRC TER/SERs

identified the licensee's evaluation required by 79-01B, 'l

and its acceptance by the NRC. The licensee sutmitted

and met their equipment qualification plan as approved

by the NRC.

(5) Maximum expected flood levels resulting from postulated

accidents were required to be identified inside the

containment. The inspectors found appropriate information

on flood levels for the equipment reviewed.

(6) Licensee Event Reports (LERs) were required to be submitted for

equipment not capable of meeting environmental qualification

requirements for the intended services. No concerns were

identified in this area.

3. Review of Unqualified AMP N2 1on Butt Splices

IE Information Notice No.86-104 alerted licensees regarding unqualified

butt splice connectors supplied by General Electric in conjunction with  ;

qualified F01 series penetration enclosures. This discrepancy was

identified by the NRC during an EQ inspection at Dresden Nuclear Power

Station on May 19-23, 1986. Subsequently Ceco tested eight sample

splicos (Q13-Q20) removed from Quad Cities Nuclear Station at Wyle

Laboratory to verify their qualification. During the testing performed

at Wyle Laboratory on Test Report 17859-02B dated March 11, 1987, all

samples failed during the LOCA exposure in 132 VAC and 528 VAC circuits.

Failures were due to severe insulation degradation and excessive leakage

currers t. Consequently CECO declared the splices unqualified and shut

down its Quad Cities Unit I to rework the splices by taping them with

qualified tape. l

During the current inspection the NRC reviewed the licensee's EQ

documentation to determine if the AMP splices were unqualified..and -

if the licensee clearly should have known that these AMP splices were g

unqualified prior to the 10 CFR 50.49 EQ deadline of Novembar 30, 1985. l

The inspectors reviewed the following reports:

e. Qualification Test for F01 Electrical Penetration assembly by

R. M. Schuster, April 30, 1971.

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b. Qualification Test Summary,100 Series Electrical Penetrations,

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Document No. 994-75-011, April 23,1975.

c. Bechtel Power Corporation Evaluation of the EQ of Nylon Butt Splices

used in GE penetrations, Chron No. 11558, August 20, 1986.

, d. Ceco - Documentation for Tested and Installed Splices (AMP, T&B, and

Hollingsworth)

e. CECO - Review of EQ documentation for Penetration Splices; Meeting

Notes from December 30, 1986.

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f. CECO - Similarity Evaluation for Nylon Butt Splices used in

GE Penetrations.

g. Qualification Test Program on Raychem Nuclear Cable Splices, Okonite

tape splices, Kerite Tape Splices, Scotch Tape Splices and AMP Butt

splices; Wyle Test Report No. 17859-02B, Volumes I and II, March 11,

1987.

Based on their review of EQ testing, analysis, evaluations and

discussions with the licensee, the inspectors concluded that the AMP  !

nylon butt splices were unqualified for use in HELB/LOCA environments at

Quad Cities Station.

The NRC is continuing to evaluate if the licensee clearly should have

known that the AMP splices were unqualified past the EQ deadline of

November 30, 1985. Enforcement action is also being considered in

accordance with the NRC EQ guidance outlined in Generic Letter 86-15.

Pending further NRC review this is a Potentially Enforceable / Unresolved

Item. (50-254/87011-01(DRS); 50-265/87011-01(DRS))

4. Licensee Action on SER/TER Commitments

The NRC inspection team evaluated the implementation of the licensee's

EQ corrective action commitments made as a result of EQ deficiencies

identified by the NRC in their July 23, 1982 Franklin Research Center

(FRC) Technical Evaluation Report (TER), the January 18, 1983 Safety

Evaluation Report (SER), and the July 19, 1984, final EQ SER.

The majority of the deficiencies identified in the SERs addressed

documentation, similarity, aging, qualified life, and replacement

schedules. All open items identified in the SERs were discussed with

the NRC staff, and the licensee's proposed resolutions to these items

were found acceptable by the NRC, as stated in their July 19, 1984, SER.

The primary objective of the Region III EQ Audit in this area was to

veri'y that appropriate analyses and necessary documentation to support

the licensee's proposed and accepted resolutions to NRR were contained in

the licensee's EQ files, and that appropriate modifications or replacements

of equipment had been implemented.

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During this review, the NRC inspection team selectively reviewed EQ

documentation and examined equipment in the plant relevant to prior

discrepancies identified in the SERs. For example, the inspectors

selectively reviewed the licensee's commitment to complete the

qualification of various EQ items identified on the JC0 list-in the

July 19, 1984 NRC SER. The inspectors noted that the licensee had

qualified or removed items (with technical justification) on this

' list relative to their'10 CFR 50.49 program. No-concerns were

identified.

5. . 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 license's EQ program was found

to identify methods of equipment qualification; provide for evaluation

and maintenance of EQ documentation in an auditable form including

maintenance records; provide for upgrading of replacement equipment; and

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

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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:

-SNED Procedure Q.6, " Environmental Qualification Design Review,"

Revision 15

-SNED/PE Procedure Q.42, " Environmental Qualification Documentation

Preparation, Control and Acceptance," Revision 4, dated May 23, 1986.

-QAP 500-13. " Environmental Qualification Program," Revision 4,

dated November 1986.

-QAP 500-14, " Environmentally Qualified Equipment Maintenance and

Surveillance," Revision 3, dated November 1986.

-QAP 500-16, " Environmental Qualification (E.Q.) Maintenance History

File and Trending Program," Revision 2, dated November 1986.

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-QAP 500-17. "E.Q. Surveillance Scheduling," Revision 1, dated

August 1986

-QAP 600-1, " Request for Purchase, Requisition Card and Purchase

Requisition," Revision 23, dated May 1987

-QAP 600-4, " Technical Evaluation of Replacement Parts," Revision 4,

November 1986.

-QAP 1200-1, " Deviation Report Procedure," Revision 14, dated

November 1986.

-QAP 1500-2, " Work Request Procedure for Station Maintenance,"

Revision 27, dated February 1987.

-QAP 1500-4, " Work Request Procedure for Station Construction.

Substation Construction and 0.A.D.," Revision 3, dated

February 1987.

-QAP 1800-9, " Control of Vendor Equipment Technical Information,"

Revision 3, dated November 1986.

-QTP 050-1, " Equipment Qualification Guidelines for the Need to

Upgrade Qualified Components," Revision 2, dated November 1986.

-QTP 050-2, " Environmental Qualification Binder Review," Revision 2,

dated November 1986.

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

lucilities 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.

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

list of electric equipment important to scfety and within the

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

MEL for compliance to 10 CFR 50.49. Areas reviewed included

adequacy of the MEL, technical justifications for removal of

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

due to field modifications.

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L The inspectors verified the completeness / adequacy of the list in

terms of. equipment needed during accident conditions throu

selective reviews of piping and instrumentation drawingsP& (gh IDS),

emergency procedures, technical specifications, and FSARs.

No violations of NRC requirements were identified.

c. EQ Maintenance and Surveillance Program

The inspector reviewed specific maintenance, replacement,

surveillance tests, and inspections necessary to preserve the

environmental qualification of EQ equipment identified on the MEL.

The NRC inspectors compared the EQ requirements in the licensee's

maintenance procedures and EQ binders against maintenance records

of selected equipment to verify performance of maintenance and

surveillance activities at prescribed intervals. Activities

reviewed included gasket inspections, lubrication, torquing of

housing covers and installation of replacement parts. Maintenance

and surveillance records were reviewed for General Electric 4KV ECCS

pump motors, Westinghouse 460V RC fan motor, Limitorque actuators,

Rosemount pressure transmitters, ASCO solenoid valves, and Conax

thermocouple. The following exceptions'were identified:

(1) The inspectors noted that the replacement schedule for solenoids,

coils and viton elastomers in ASCO solenoid valves varied from

3 years to 37 years. This schedule was not consistent with the

licensee's EQ qualification report which identified the average

qualified life of the ASCO valves to be four years. The licensee

provided documentation to evidence that the actual qualification

life of these valves did vary from 3 to 37 years, and the

licensee agreed to clarify their files. No further concerns were

identified.

(2) During review of EQ maintenance activities for ASCO solenoid

valves the inspector noted that the maintenance schedule allowed

the exceeding of scheduled maintenance dates by 25%. The licensee

agreed that this was not consistent with their EQ requirements

and revised EQ surveillance scheduling procedure QAP 500-17 to

require maintenance and surveillance prior to qualified

intervals. No further concerns were identified.

(3) The inspectors noted that the ASCO Vendor Bulletin recommended

monthly cycling of the valves. The ASCO EQ files, however,

called for yearly cycling of these valves. The licensee

reviewed these requirements with ASCO and reported that monthly

cycling intervals did not affect the environmental qualification

of these valves. ASCO also confirmed to the licensee that

yearly cycling was acceptable. No further concerns were

identified.

No violations of NRC requirements were identitied.

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d. Plant Procurement and Upgrading of Replacement Equipment

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Licensee procedures 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. For example, the procurement-

package for th? replacement of Limitorque MD 2-202-5A was found to

properly address upgrading to the requirements of IEEE 323-1974.

No violations of NRC requirements were identified.

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 through

surveillance, audits, and reviews of the records and files for plant

modifications and procurement of equipment; NRC inspectors reviewed

the licensee's QA audits, including QA Audit No, QAS-4-86-174 conducted

on July 8-9, 1986, and found the methodology, .results and followup

corrective action relative to the audits acceptable.

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 personnel, including

management, operations and maintenance personne? responsible for

EQ activities.

During this review the inspectors noted that the licensee did not

have-a procedure to control the onsite training program. Based on

the inspectors review, key personnel had received EQ training, however,

there were no specific requirements'in place to control such training.

The licensee stated that a controlled training program was planned

to be implemented, however,'there was no planned schedule for its

implementation. The inspectors also noted that subcontractor

personnel were not being given any EQ training.

At the inspection exit the licensee committed to incorporating a

controlled procedure for EQ training at the plant, and to ensure

that all appropriate sub-contractor personnel were trained for EQ

activities. Pending further review of the licensee's training

program this is an Open Item (50-254/87011-02(DRS);

50-265/87011-02(DRS)).

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6. Detailed Review of Qualification Files

The licensee qualified their EQ equipment to the requirements of the 00R

Guidelines (10 CFR 50.49, Paragraph K). The inspectors reviewed over 32

equipment qualification files for evidence of the environmental

qualification of equipment within the scope of 10 CFR 50.49 and evidence

of equipment qualification to NUREG 0588 Cat I. Files were found to

include a 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

EQ equipment; licensee evaluation of tested materials and configurations

relative to actual plant installations; adequacy of EQ 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;

ar; licensee evaluations of discrepancies identified in IE Notices end

Bulletins.

EQ files were reviewed for electrical cables, cable splices,

terminations, terminal blocks, electric 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 minor deficiencies such as incorrect model numbers and

location elevations on the SCEW sheets. These were corrected by the

licensee. The inspectors also found that in certain cases the files

did not allow verification of equipment qualification to a specified

performance for accident conditions. Details are noted below:

a. SIMPLEX Butyl Rubber Insulated Cables (File No. 29, CQD-014973)

The above file was reviewed for the qualification of SIMPLEX

butyl rubber insulated /PVC jacketed cable to the requirements

of NUREG 0588 Cat. I. This cable was identified by the licensee

to be used in SKV power applications. Subsequent to the site '

inspection the licensee identified the SIMPLEX butyl rubber

cables to be also used in 480VAC, 208VAC, 120VAC, and 125VDC low

power and control applications in HELB and radiation harsh

environments outside the drywell. The licensee stated that the

environmental qualification of all the SIMPLEX cables was based

on Wyle Lab Report No. 45917-40-4 which documented the testing

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of eight SKV SIMPLEX butyl rubber cable specimens. The inspectors

noted that no insulation resistance was measured during the HELB

exposure of this test and that the test configuration was such that

conductor to conductor shorts may have gone undetected. The

licensee stated that the post accident dielectric withstand test

performed by Wyle fir submerged cable at 5000 VAC, and the radiation

harsh only location of the SKV cables in the plant was evidence of

the qualification of the SIMPLEX SKV and 600V rated cables, however,

the inspectors concluded that the Wyle report was not adequate to

qualify the SIMPLEX butyl rubber cable for applications of less than

4160 volts.

Subsequent to this finding, on June 30, 1987 the licensee provided

an enhanced EQ package which included additional justification for

the qualified life of the butyl rubber insulated cables (CQD

No. 014973) relative to the DDR Guidelines (DOR is applicable to

Quad Cities). .This EQ package was also transmitted by the licensee

to NRR. Based on the regional review of the above package,

hgion-III had the following concerns:

(1) Based on testing in the industry, butyl ' rubber is known to be a

very degradable material susceptible to significant radiation

damage. For example, the IEEE Transactions Paper by

R. B. Blodgett and R. G. Fisher, July 12, 1986, states that

during testing conducted on Butyl-Neoprene (ozone resisting

-butyl based insulation) having a polychloroprene based jacket,

the butyl was cegraded to a tar like liquid between 5X10' and

10' Rads. The DOR Guidelines, Paragraph 5.2.3, states that

for such degradable materials the radiation doses should be

applied prior to or concurrent with exposure to elevated

temperature and pressure steam / air environment. The Wyle test

presented by CECO did not meet these DOR-Guideline requirements,

in that the Wyle test (Report, No. 45917-40-4) did not expose

the same butyl rubber specimens to appropr? ate doses of

radiation and elevated temperatures.

(2) The referenced Wyle test was performed on a SKV rated 3/c,

500 MCM, butyl rubber insulated, PVC jacketed cable. The

insulation had a thickness of 171.875 mils and the jacket had

a thickness of 125 mils. The low voltage power and control

cables at Quad Cities, however, have an insulation thickness

of 46.875 mils with a 62.5 mils overall jacket. The inspectors

were concerned that the Wyle test done on the SKV cable did not

account for the postulated aging due to oxidation and subsequent

surface cracking of the thinner cables.

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During a conference call on July 9,1987, the licensee-was-

informed that based on NRC concerns relative to the

documentation provided, the _ licensee was required to submit

an operability analysis to justify continued operation. The

licensee was also requested to address the qualification of

any EQ application of butyl rubber cable at the Dresden Plant

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Units 2'and 3.

On July 17,.1987 the licensee provided additional documentation

. to enhance thdr qualification documentation for the butyl

rubber insulatec: cables at both Quad Cities and Dresden. In

this package the licensee stated that the cables were qualified

to the D0R Guidelines, and that actual environmental parameters

during an accident were less harsh than previously addressed.

This package is being currently reviewed by the NRC. Pending

further review of this package by the NRC, this is a Potentially

Enforceable / Unresolved, Item (50-254/87011-03(DRS);

(50-265/87011-03(DRS)).

b. Simplex Polyethylene Insulated Cable (File No. 29, CQD 014973)

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The inspectors reviewed the EQ file for SIMPLEX polyethylene

insulated /PVC jacketed instrument cable for qualification to

NUREG-0588, Category I. The cable was tested by Wyle Labs,

Report No. 45917-04-1, and the HELB test was monitored by means

of an indicating lamp which was connected in series with the

cables being tested and powered by approximately 135.mA current.

The test configuration was such that any decreased insulation

resistance (including shorts) would apparently not be c'etected as

no IR measurements were taken during the test. The licensee stated

that.these cables were used outside the drywell. The SCEW sheet

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in the EQ file indicated a severely harsh environment of 304 F,

20 psia, 100% RH,.and 3.9 x 107 Rads for these cables during an

accident. The inspectors concluded that these cables were

unqualified in the absence of IR data to evidence the performance

of these cables during accident conditions at Quad Cities.

Subsequent to the finding the licensee stated that after further

evaluation they had determined that the SIMPLEX polyethylene

instrument cables would be exposed to a low " radiation harsh only"

environment, and that the cables were not required to function in

HELB areas. The licensee submitted revised SCEW sheets to evidence

the less severe environment. Pending further review of the revised

qualification files of these cables, this is a Potentially

Enforceable Unresolved Item (50-254/87011-04(DRS);

50-265/87011-04(DRS)).

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c. General Electric SKV Butyl Rubber Insulated Cables (File No. 25-1,

CQD-015110)

The inspectors reviewed the above file for the qualification of GE-

SKV~ butyl rubber insulated cable to the requirements of NUREG 0588

. Cat. I. The licensee stated that this cable was used outside the

drywell, and that it would not be required to function in an

environment where maximum temperature / steam and high radiation

levels occur' simultaneously.

Some of this cable is used within the steam tunnel where the ambient

temperature is 150'F. Tne testing attempted to attain a qualified

' life of 40 years at 150"F, however, the specimen aged to the i

equivalent of 40 years at 150*F failed the qualification test. I

Other SKV power cable specimens including one aged to the equivalent i

of 13.2 years at 150 F did pass the test. Based on the installed I

life, the SKV EQ cable located in the steam tunnel is scheduled for

replacement at the next plant outage.

The inspectors noted that no insulation resistance was measured during

the test, and that the test configuration was such that conductor-to-  !

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conductor shorts may have gone u'ndetected. The LOCA test was

conducted on a plant specific naturally aged cable with a radiation

exposure followed by thermal aging. The inspectors concluded that

certain conservatism in the test including a subsequent successful  ;

post-accident withstand test justified use of this cable for 4160 VAC i

power cable applications. Pending review of the licensee's replacement

of this cable during the next plant outage, this is considered an Open 4

Item (50-254/87011-05(DRS);50-265/87011-05(DRS)).  ;

d. General Electric Low Power and Control Butyl Rubber i

Insulated Cable  !

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Subsequent to the site inspection and after being questioned by the  !

NRC, the licensee revealed that GE butyl rubber insulated cables ,

(discussed in Section Sc) were also used in 480V, 208V, 120VAC and '

125VDC circuits outside the drywell. The licensee was informed that  ;

based on inadequate documentation in the EQ files, this cable was

unqualified for accident conditions _in low voltage power and control i

applications at Quad Cites. The licensee stated they could provide  ;

additional responses to justify the qualification of the cable, i

Pending further review of the licensee's responses in regard to the

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qualification of these cables, this is a Potentially Enforceable / t

Unresolved Item (50-254/87011-06(DRS); 50-265/87011-06(DRS)).

e. AVC0 Solenoid Valves, (FILE No. C00 015004)

AVC0 solenoid valves were reviewed for qualification to the D0R

Guidelines. The inspectors observed that during the testing of  :

the AVC0 valve, excessive air leakage was recorded. The file i

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did not contain a technical justification for the acceptability

of this air leakage. The inspectors also observed that during

the LOCA testing a Parker 0-lube lubricant was used in the

solenoid valve. The EQ file maintenance documents, however,

indicated that another lubricant, Super Parker 0-Lebe was being

used in the installed AVC0 valves at Quad Cities. Since the EQ

file did not address the qualification of the Super Parker 0-Lube

lubricant, the licensee was informed that the AVC0 solenoid valves

in Units 1 and 2 were unqualified based on inadequate documentation,

and that a prompt operability analysis was required. The licensee

stated that the AVC0 valve was part of the Automatic Depressurization

System (ADS) and that based on their technical specifications the

plant could operate for seven days if one ADS valve was declared

inoperable. 1he licensee also stated that additional documentation

existed to qualify these valves. Subsequent to the finding the

licensee procured new qualification tests and performed an additional

evaluation to demonstrate that the rate of air leakage noted during

the EQ test did not compromise the function of the valve, and that

the Super Parker 0-lube lubricant was qualified. The licensee was

informed that their failure to qualify the AVC0 solenoid valve by

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

a violation of 10 CFR 50.49, Paragraph (f) and (g), Severity Level IV,

Supplement 10. (50-254/87011-07(DRS); 50-265/87011-07(DRS)).

f. File Auditibility

10 CFR 50.49, Paragraph (j) and NUREG 0588 Category I, Paragraph 5

require records of qualification to be maintained in an auditable

form for the entire period during which an EQ item is installed in

the plant to permit verification that the item is qualified for its ,

application and meets specified requirements. During this review '

the inspeccors identified the following exceptions.

(1) BIW Cable (File No. 24, CQD No. 015821)

The inspectors reviewed the file for low voltage BIW

multiconductor signal cable for qualification to NUREG 0588,

Category I. The inspectors noted that the file did not contain

sufficient documentation (such as test data to support results,

and evidence of the test profile being maintained as stated in j

the report) to meet NUREG 0588 Category I EQ requirements.

Subseauent to this finding the licensee submitted additional

documentation from BIW Cable Systems Inc., and additional

technical justifications to establish the qualification of

the BIW wire and cable for normal and accident conditions at

the Quad Cities Station.

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(2) Okonite Cables (File No. 26, CQD-015880)

The inspectors reviewed the EQ package for Okonite EPR insulated

cable to the requirements of NUREG-0588, Category I. The

inspectors noted that the level of documentation included in the

test report (Engineering Report No. 266-R.1) was insufficient to

support Category 1 qualification. The licensee stated that the

0Fonite Company had a new test report available and that they

planned to add this report to their file to meet Category I

requirements.

The licensee was informed that their failure to maintain a record

of qualification of BIW and Okonite cables (Sections 6f(1) and (2))

in an auditable form to permit verification that the cables were

qualified was considered a violation of 10 CFR 50.49, Paragraph (j),

Severity Level V, Supplement ID. (50-254/87011-08(DRS);

50-265/87011-08(DRS))

g. Marathon 1500 Terminal Blocks (File No.19, CQD-014893)

The inspectors reviewed the EQ package for Marathon 1500 Series

terminal blocks, for qualification to NUREG 0588, Category I. A

test of Marathon blocks was done by Wyle (Report No. 45603-1),

which indicated to the inspectors that the terminal block:; were

not qualified for 480V service. During this test a 12A fuse

did not fail in the 132V circuit, however, there was no measurement

taken for irs or leakage current. The lack of failure of this fuse

was not considered adequate to determine the qualification of the

blocks in 120V circuits at Quad Cities. A subsequent test (included

in the EQ file) of the same terminal blocks (Wyle Report No. 17657)

measured a leakage current of 50mA for terminal blocks in junction

boxes with top entry conduits. Since Quad Cities has demineralized

water spray and the test used chemical spray, this leakage current

is considered conservative. In order to justify the 50mA leakage

current recorded in the report, the licensee had initiated field

modifications to ensure that all applicable terminal blocks were

not mounted directly below conduit openings. This effort included

re-routing of installed conduits for bottom conduit entry. During

the current EQ inspection the inspectors noted that there was no

evidence in the EQ files that this effort had been completed,

however, the licensee reviewed their records and confirmed that all

modifications had been completed for terminal blocks in LOCA/HELB

areas inside and outside the drywell. No further concerns were

identified.

7. 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,

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

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

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

its environmental qualification. Specific areas reviewed included

traceability of installed items of EQ files, ambient environmental

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

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

rise from process, drainage, mounting methods, physical conditions

and housekeeping. In almost all cases, items examined in the field

during this walkdown were found to meet their appropriate EQ

-requirements with the following exceptions:

a. AMP Splices

During review of cables in the Reactor Building the-inspectors

identified a nylon AMP butt splice in Unit 1 Motor Control

Center 19-4, Cubicle A-2. This was noted as a discrepancy; because

the licensee had stated that they did not have AMP splices in any

application except the General Electric F01 penetrations. Further

review of maintenance documents indicated various nylon AMP splices

had been identified during EQ reviews in Unit 1, however, the

licensee stated that these splices were all taped or covered with

heat shrink tubing when identified. The inspectors were concerned

that nylon AMP splices may have been used~in EQ applications, other

than the GE F01 penetration, inside the' Unit 2 drywell. The

licensee stated that there were no unqualified nylon Amp splices )

in any EQ applications in Units 1 and 2. The licensee further '

stated that they planned to perform an additional EQ review of

Unit 2 during their upcoming outage to replace the remaining nylon

AMP splices in appropriate EQ applications. Pending review of the

licensee's actions, this is an Open Item (50-254/07011-09(DRS);

50-265/87011-09(DRS)).

b. Marathon Terminal Blocks

During the examination of terminal blocks the inspectors observed

that the end of a Marathou block was stamped " Screw torque 25 inch

pounds." The licensee had not addressed this requirement in their

EQ files or installation criterion, After further review with the

manufacturer the licensee stated that this was the maximum torque

value for the terminals to prevent terminal damage. The licensee

committed to include this requirement into the appropriate documents.

No further concerns were identified.

c. Comsip Delphi Hydrogen Monitor HM-1-2402A

The above panel was examined and found to have an incorrect

identification. Similar deficiencies were found on other panels.

The licensee took corrective action and applied the correct

identification labels. No further concerns were identified.

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8. Open Items

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

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

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on the part of the NRC or-licensee or both. Open Items disclosed during

l this inspection are discussed'in' Paragraphs 4e, Sc, and 6a. 'l

9. Potentially Enforceable / Unresolved Item

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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 beifollowed

up with enforcement action in accordance with NRC enforcement guidance on

10.CFR 50.49. Potentially Enforceable / Unresolved Items are discussed in

Paragraphs 2, Sa, Sb, and 5d.

10. Exit Interview

The Region III inspectors met with the licensee's representatives

(denoted under Paragraph 1) during an interim exit on June 12, 1987, and

discussed their findings by phone at the conclusion of the inspection ~on

July 28, 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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