ML20238C922
| ML20238C922 | |
| Person / Time | |
|---|---|
| Issue date: | 08/25/1987 |
| From: | Moist R, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20238C918 | List: |
| References | |
| REF-QA-99900931 NUDOCS 8709100452 | |
| Download: ML20238C922 (10) | |
Text
r~~~
ORGANIZATION: PATEL ENTERPRISES, INCORPORATED HUNTSVILLE, ALABAMA REPORT INSPECTION INSPECTION NO.: 99900931/87-01 DATES- 07/13-17/A7 nN_tTTr unnec.
93 CORRESPONDENCE ADDRESS: Patel Enterprises, Incorporated ATTH: Dr. M. C. Patel, President 3400 Blue Spring Road, Northwest Suite D-3 Huntsville, Alabama 35810 ORGANIZATIONAL CONTACT: Mr. T. Utech c
TELEPHONE NUMBER:
(205) RR9-600n l
NUCLEAR INDUSTRY ACTIVITY: Patel Enterprises, Inc. (PEI) provide nuclear services related to the following: equipment qualification program develop-ment; material aging analysis; qualification documentation assessment; qualification maintenance program; and seismic qualification programs to include design and analysis. Approximately 50 percent of the services are nuclear power related. Approximately 20 employees are devoted to these efforts.
ASSIGNED INSPECTOR:
[M 22. J'V)gM 8/M/f7 R.' N. Molst, Special Projects Inspection Section Date (SPIS)
OTHER INSPECTOR (S):
/
APPROVED BY:
p R-2Sf7 U. Potapovs, SPIS, Vendoq Inspection Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B and 10 CFR Part 21.
B.
SCOPE: This inspection consisted df:
(1) a technical evaluation i
of equipment qualification (EQ) test activities for safety-related d
equipment and (2) verification of implementation of the quality assurance (QA) program.
PLANT SITE APPLICABILITY: Robinson Unit 2 (50-261), Brunswick Units 1 & 2 (50-325, 50-324), Cooper (50-298).
I NO 9h 999009 31 l
A-.---_---_
J' j
F' ORGANIZATION: PATEL ENTERPRISES, INCORPORATED HUNTSVILLE, ALABAMA REPORT INSPECTION Nn_.
4Q000031/R7-01 RESULTS:
PAGE 2 of 9 A.
VIOLATIONS:
None.
B.
NONCONFORMANCES:
(
None.
C.
UNRESOLVED ITEMS:
None.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Nonconformance (86-01-01)
Contrary to Criterion V of Appendix B to 10 CFE PART 50 and paragraph 6.5.2 of the Quality Assurance Manual, test procedures PEI-TR-860500-01 for Job Number (JN) 8605 and PEI-Tk-860100-01 for JN 8601 were revised, however, the original controlled copies of both test proce-dures were not marked VOID or SUPERSEDED.
The NRC inspector verified that both-test procedures have been properly marked SUPERSEDED. The NRC inspector reviewed a Patel letter that identified training had been conducted for key personnel at Patel by the Director of Product Assurance on June 23, 1986. The scope of the training reflected on selected sections of the QA manual and Quality Engineering procedures such as document control, control
'{
of engineering and design calculations, procurement document control j
and control of technical documents. The NRC inspector also reviewed and verified that original controlled copies of test reports and test procedures for JN's 8617, 8701 and 8702 were marked SUPERSEDED.
2.
(Closed) Nanconformance (86-01-02)
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section
)
3.4 of Quality Engineering Procedure 4.1, Patel orally authorized j
their vendor to perform testing to different requirements than 1
saecified in Purchase Order 1024 for JN 8603 without documenting t'iis authorization.
The NRC inspector verified that Patel had revised test procedure PEI-TR-860300-01 to revision A and that the changes requatted by New York Power Authority were included in the revision.
NRC
ORGANIZATION: PATEL ENTERPRISES, INCORPORATED HUNTSVILLE, ALABAMA i
i REPORT INSPECTION Mn - QC0nr.Q11/n7-n1 RFSulTS:
PAGF 3 nf Q inspector reviewed a Patel letter that identified training had been conducted for key personnel at Patel by the Director of Product Assurance on June 23, 1986. The scope of the training reflected on Section 4.0 of Patel's QA Manual relating to procurement document control. The four test programs reviewed by the NRC inspector on.
c this visit demonstrated that the requirements of purchase orders to 4
Patel's vendors were being followed.
3.
(Closed) Nonconformance (86-01-03)
Contrary to Criterion V of Append 1x B to 10 CFR PART 50 and Section j
3.1 of Quality Engineering Procedure 3.4, it.could not be determined i
that the final conclusions in assessment reports PEI-TR-83-4-33..JN 8305-12 and PEI-TR-82-4-50, JN 8201 were sound and accurate.
The NRC inspector verified that both assessment reports for JN 8305-1 12 and JN 8201 has been revised to include a section relating to functional requirements and functional analysis. With the additional information provided, it was determined that the firal conclusions in both assessment reports were sound and accurate. The qualifica-tion documentation analysis checklist format in the Patel EQ Assessment Report now contains a reference column. This reference column requires a definitive answer to each question and provides a cross check back to the qualification documentation. Patel Engineering Verifier Log Form No. 912 now contains mandantory check points relating to performance requirements and testing results.
E.
OTHER FINDINGS OR COMMENTS:
1 Technical Evaluation - The NRC inspector performed a technical evalu-ation of four test programs for qualification testing of safety-related electrical equipment. The following table summarizes the job number (JN) files examined, including equipment type, plant &
types of documents examined.
JN Equipment Type Plant Documents Examined 8702 Limitorque wiring Cooper Test Report (TR), Test
& Okonite splices Procedure (TP), Purchase Orders (P0's) & Test data (TD), Certification test report (CTR) 8701 Sta-Kon connectors Cooper TR, TP, P0, TD, CTR
~
ORGANIZATION: PATEL ENTERPRISES, INCORPORATED HUhTSVILLE, ALABAMA REPORT INSPECTION Nn - 444nr431/E7-01 RESULTS:
PAGE 4 of 9 E
Equipment Type Plant Documents Examined 8628 Preamp enclosure Robinson TR, TP, P0, TD',~CTR 8617 Patel conduit Seal Brunswick TR, TP, P0, TD, CTR c
The NRC inspector reviewed the EQ process prescribed in each test report / test procedure and reviewed test results for the above programs, including the bases for accelerated thermal aging and radiation for one program.
Four test programs were examinec to ensure that Patel had controlled the following as applicable:
a.
Adequate test instrumentation and their accuracies were described and used to meet the requirements of IEEE-STD-323/1974.
I I
b.
Equipment interfaces were addressed.
c.
Test acceptance criteria were established as described in the test specification or in the design engineering documents, such i
as calculations and engineering letterc to meet the requirements l
of IEEE-ST['-323/1974.
d.
Same test assembly was used for all phases of testing and j
represented a standard production item.
e.
Environmental conditions were established and described (e.g.,
pressure and temperature profiles, and thermal aging factors) and were consistent with those outlined in the test specification or test procedure.
f.
Test results were adequately reduced and evaluated against established acceptance criteria described in customer test specifications or purchase orders.
l g.
All prerequisites for the giVen tests as outlined in the test a
specification had been met.
l h.
Test equipment included a description of all materials, parts, and subcomponents.
i.
Notice of Anomaly reports were properly documented.
l i
T A
r ORGAN 42ATION: PATEL ENTERPRISES, INCORPORATED HUNTSVILLE, ALABAMA i
REPORT INSPECTION un - oponno11/R7-n1 RESULTS:
PAGE 5 of 9 j.
Appropriate margins were applied, s,
3 k.
Functional performance requirements were met.
No nonconformances were noted during this review. The following describes each program:
c a.
JN-8702
Purpose:
The purpose of this test program was to qualify i
natural aged limitorque torque switch cabling, limitorque natural aged motor lead wiring and okonite splices for Cooper 1
Nuclear Station (CNS).
Eguipment
Description:
The test assembly consisted of two cable /
l splice circuit loops inside a NEMA 4 enclosure. The enclosure did not have a drilled weep hole. Circuit Loop 1 consisted of two segments of torque switch cabling (black braid) and th'ree bolted Okonite T35/#95 tape splices. Both segments had been naturally aged in service at CNS for twelve years and had been installed in valve operators located in the steam tunnel. The environmental conditions in the steam tunnel consisted of a high radiation ar.d elevated ambient temperature.
Circuit Loop 2 consisted of two segments of motor lead wire (yellow braid) and three bolted Okonite T35/#95 tape splices.
Both segments were naturally aged in service et CNS for twelve years and installed in a valve operator located in the steam tunnel. Environmental conditions were the same as circuit loop 1 above. The lead wires for both loops were Rockbestos Firewall SIS 16 AWG 600V nuclear cable.
Test specimen mounting / setup: Review of the Patel test report showed that the test assembly was installed in the test chamber with the conduit opening oriented downward. The test assembly was electrically energized and subjected to the steam accident simulation test.
t Res41ts: Approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> ir.to the steam accident test Thi Esulation resistance measurements were below one megohm and rer ained below one megohm for the remainder of the test for cit:uit loop 2.
At fifty three hours 50 minutes into the steam accident simulation test, leakage current for circuit loop 2 was measured at 671 ma. This measurement did not meet the acceptance criteria for leakage current which states that the
1 N
ORGANIZATION: PATEL ENTERPRISES, INCORPORATED
'i HUNTSVILLE, ALABAMA
' REPORT =
-INSPECTION en - ooonnc?1/A7-01 RESULTS:
PAGE 6 of 9 leakage current shall remain below 300 ma. However, - subsec;uent j
measurements showed that the feakage currents-returned to below 200 ma. Patel directed their -vendor to deenergi'ze' circuit loop 2 at sixty hours 30 minutes into the accident simulation test.:
- 1 Vis'ual inspection after the accident simulation test showed that.
both segments.of the motor lead wire (yellow braid) were frayed.
However, one segment was damaged more. extensively than the other.
.{R The conclusion in Patel test report stated that the failure of the naturally aged limitorque power wiring'(circuit. loop 2) to meet the defined functional. requirements was the result of an interruption in the cable. insulation due to unknown causes.
b.
JN-8701:
Purpose:
The purpose of this test program was to de nonstrate the operability of T&B Sta-Kon connectors when subjected to steam accident and functional simulations for CNS.
Equipment
Description:
Patel test report showed that the' test assembly consisted of four Sta-Kon connector pairs.(RA18-250F and 18RA-250T) inside a NEMA-4 enclosure, assembled and provided J
by CNS. The enclosure did.not have a wee) hole. The connecting wiring used in the test assembly was Rock)estos Firewall SIS AWG 600 V Nuclear cable. The enclosure simulated the gasketed condulets at CNS. Two specimens were insulated with 3/8 " PVC tubing. The other two specimens were coated with Patel conformal coating and then covered with 3/8" PVC tubing.
Test Specimen Hounting/ Setup: The entire test assembly was
. installed in t_he test chamber with the conduit opening oriented downward. The specimens were than electrically energized and subjected to the steam accident simulation.
Results: The Sta-Kon connectors were successfully qualified under steam accident and functional simulations.- All visual inspections implemented during the course of testing revealed j
no damage as discussed in the test report.
It was determined by the NRC inspector that all acceptance criteria had been met.
c.
JN-8628:
Purpose:
The purpose of this test program was to demonstrate that the Patel preamp enclosure will protect a remote charge amplifier from environmental conditions inside containment at
i ORGANIZATION: PATEL ENTERPRISES, INCORPORATED HUNTSVILLE, ALABAMA' REPORT INSPECTION Nn
_90$nn931/87-01 RESULTS:
PAGE 7 of 9 all times of required operability of the preamplifier including during and following a postulated design bases eye _nt.
Equipment
Description:
The Patel preamp enclosure is a sealed enclosure outfitted with a Patel conduit seal to provide the necessary sealing for the conduit opening into the enclosure.
c The enclosure itself is sealed using a GRAFOIL gasket which is compressed by the enclosure cover via 1/4" bolts. The only non-metallic materials in the enclosure assembly are the GRAFOIL gasket and fiberglass insulation.
Test Specimen Mounting / Setup: A hardline ceax was ccvered with Raychem WC5F-050-N heat shrinkable tubing along its entire i
length inside the test chamber and to a point immediately outside a second Patel conduit seal which was used to seal tne chamber pressure. The crimp splices inside the enclosure were covered with (from 3" to 5") of Raychem WCSF-070-N heat q
shrinkable tubing to provide suitable electrical insulation.
Results: Visual inspection after steam enviroment and chemical
)
spray revealed extensive damage to the paint on the outer surface of the enclosure, but there was no indication of moisture inside the enclosure or on the fiberglass insulation as indicated by l
Patel test report. Although the enclosure internal temperature did exceed the normal operating temperature during the testing the enclosure still permitted the preamp to remain operable by protecting it from the pressure transients.and the borated water spray, d.
JN-8617:
Purpose:
The purpose of this test program was to extend the qualified life of the Patel Conduit Seal for use inside contain-ment at the Brunswick Steam Electric Plant and to demonstrate reusability of the conduit seal grommets for use in the reactor building.
Equipment
Description:
The Patel conduit seal is a multi-cable mechanical interface that may be used to seal existing conduits and lead wires. The conduit seal will accept up to six (6) #12 AWG or #14 AWG cables, or up to eight (8) #16 AWG or #18 AWG cables by use of installed grormets.
- p 14 4,
4, 4.;;$a,* ',"'5k' &,,:,a s
J e
q
,.,. + e'n
'*:e.+.+ts 3
^
s, 8
- +*r 4 iti:[!$it qq,x,s, n *gqg q'h)g""I$,h$
<g
^^ I4%
,3, $:l$^[4;;j((f4;[$? h,
)
s
'8 "'
, ::tyR s
win n
bS
$$'+:.
42W"':
%'fgp:fllxg,e;,
k ii k :
yk il 9:
g
~~::.
w:,$sm?k'h?"%.
AN
- A'$#N,:!i,[f' "}l4
+
ORGANIZATION: PATEL ENTERPRISES, INCORPORATED HUNTSVILLE, ALABAMA REPORT INSPECTION en. ooonnc11/n7_n1 RESULTS:
PAGE 8 of 9 Thermal Aging: Every twenty four hours which simulate.= five years of service the seal coupling net was loosened, in,
~~
grommet removed from housing, re-greased and retorqued, pressure boundry test performed and the assembly returned to the thermal aging oven until the aging goal was reached. This was performed on the four specimens to demonstrate reusability c
of the grommet.
Test Specimen Mounting / Setup: The test roecimens were mounted vertically to penetrate the test chamber eall through 3/4" NPT threads. The test specimens was than subjected to steam accident simulation test.
Results: Post Accident visual inspecton revealed that the housings was discolored and dirty from the boiler chemical residue and pipe corrosion products from the LOCA exposure. No damage was observed which could affect the operation of the conduit ceals. The conduit seals met all functional requirements prior to and throughout the eccident simulation.
It was further deraonstrated that the qualified life of the conduit seals may be extended from previous qulificatior. Sevels and that grommet:
for use in the reactor building may be re.?oved and replaced as many as seven times during their qualified i fe.
2.
Development of Qualification and Assessment Reports:
The NRC inspector reviewed Patels' Quality Assurance Manual and Quality Assurance Engineering precedures to determine what controls were established to assure proper development of qualification packages end assessment reports. Six QA engineering procedures were reHewed that addressed the above topic and appeared to be adequate to maintain control of engineering documents.
The NRC inspector reviewed a document titled "EQ program for Robinson" dated January 25, 1965. The purpose of this document was to present the philosopy and methodolgy used to pertorm and document the EQ of the electrical equipment classified as important to safety at HBR-2.
d Procedure PEI-TR 831011-01 titled " Procedure for review of EQ of each individual siece of safety-related electrical equipment utilized at the H.B. Ro)inson Nuclear Plant" dated September 11, 1984 was a part of the above docment which prescribed the methodolgy of preparing EQ i
documentation. Topics included in this procedure were: 1) equipment /
l nameplate data 3 2) environmental Category, 3) safety related function, i
- 4) EQ system component evaluation worksheet, 5) qualification
4 9
ORGANIZATION: PATEL ENTERPRISES, INCORPORATED M
- ~
HUNTSVILLE, ALABAf1A A
3 n
REPORT INSPECTION Nn. QQQnn091/R7-n1 RFSUITS:
1 PAGF,9 nf p u
limitations, 6) operations, 7) calibrations and maintenance procedures, 8) conclusions, 9) seismic qualification evaluation
g sheet and 10) quality assurance in accordance with Patel engineering QA program.
Also an external interface document No. 5 Rev 3 dated October 19, 1984 between Patel Enterprises, Inc. & H. B. Robinson steam electric plant was reviewed. The purpose of the external a
interface document was to identify the interface, scope of responsi-bilities, lines of concunication and document control methods betw en outside engineering, consulting and A/E's and the Nuclear Engineering & Licensing Department (NELD).
It was determined tha+
g,.
Patels line of communication involving EQ was through NELD for
- ~
design information and that interface between Patel's QA organiza-tion and CP&'.'s QA/QC organization need not involve NELD.
3.
QA Program Implementation Review:
The NRC inspector reviewed four JN tiles containing documentation which supported testing efforts. Documentation included purchase orders, EQ test procedures / reports, certification test reports and test cata.
It was determined that Patel was implementing their QA program in accordance with their QA Manual.
4.
QA Manual Review:
The NRC inspector reviewed four changes that were incorpotc+.ed into revision G of the QA Mar,ual. It was determined that the changes were minor and did not impact Patel's QA program with respect to the
'~
^
requirements of Appendix B to 10 CFR Part 50.
PERSONS CONTA,CTED o
- Dr. Patel, President, Patel "T.Utech, Director Product Assurance, Patel f
G. Elam, Program Manager, Patel F. Roy, Project Engineer, Patel
- J. Jenkins, Vice President Nuclear Engineering, Patel
- Attended Exit Meeting.
. e
- Separate Exit Neet'.og.
x W
v O
if O
's w
a g*
o
i i
P u) 4 C3 60 Q~
M i
b 0"s u>
v a
b l
0 9
3 e
}
}
t s
l I
l
%._