ML20244D283
| ML20244D283 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/07/1989 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20244D276 | List: |
| References | |
| 50-302-89-09, 50-302-89-9, IEB-83-72, IEIN-84-47, IEIN-86-003, IEIN-86-3, NUDOCS 8906160196 | |
| Download: ML20244D283 (22) | |
See also: IR 05000302/1989009
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UNITED STATES
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REGION il
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NUCLEAR REGULATORY COMMISslON
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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Report No.: 50-302/89-09
Licensee:
Florida Power Corporation
320134th Street, South
St. Pet,rsburg, FL 33733
Docket No.: 50-302
License No.:
Facility Name: Crystal River 3
Inspection Conducted: April 24-28, 1989
Inspector: N% M/d/,8 NM
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N.MerriWeather,TeamLehdtir
Ddte' Signed
Team Members:
T. Humphrey, Consultant Engineer, Idaho National
Engineering Laboratory
. M. Hunt, Reactor Inspector, RII
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C. Paulk, Reactor Inspector, RII
A. Ruff, Assistant Team Leader, RII
Accompanying Personne :,
T.
Conlon, Chief, RII
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Approved by.
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/#PPI W
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T. E. Conlon, Chief
Uate Signed
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Plant Systems Section
Engineering Branch
Division of Reactor Safety
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SUMMARY
Scope:
This routine, announced team inspection was conducted in the areas of
Environmental Qualification of Electrical Equipment and followup on previous
inspection findings.
The inspection included:
a review of Florida Power
Company's implementation of a program to meet the requirements of 10 CFR 50.49
at the Crystal River Plant; walkdown inspections of EQ equipment; review of
selected. vendor qualification files; review of EQ maintenance activities; and
review of actions taken by the licensee in response to new emerging EQ issues
as a result of vendor and NRC initiatives.
Resul ts:
In the areas inspected,10 violations were identified, including two licensee
identified violations reported in Licensee Event Reports 88-27 and 88-28 and
additional examples of EQ violations identified shortly after the inspection.
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This . inspection concluded -that the -licensee's' EQ program continues to be
marginal and has not improved greatly since the initial EQ inspection which was
performed during March 1985.
Several of. the same types of EQ issues which are
discussed in Inspection Report : 50-302/85-09- were also . concerns during this
inspection.
Furthermore,'there appears to be indications that the licensee's
EQ Program has not kept abreast of recent EQ issues which have been the.subjectL
of numerous NRC' inspection ~ reports over the past'two' years.
As stated in'NRC
Inspection Report 50-302/88-27 the staff considere'd that.FPC had a'significant-
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breakdown in the implementation of their EQ Program over the.past three ' years.
This position seems .to be further' substantiated by the total number of apparent-
' violations : identified, both by NRC and the' licensee, during and . shortly after
the inspection. . Thus,' collectively these apparent. violations seem to indicate
a significant weakness in how the FPC EQ Program was implemented. -In response-
to the findings, however, the licensee.has initiated inspectionsLand r'epairs to
be in full compliance prior to plant restart. .
-Within the areas' inspected, the following apparent violations were identified:
On December 9,1988 the licensee discovered by Engineering Analysis' that a
postulated crack of an auxiliary steam line, passing through the Auxiliary
Building, could cause a harsh environment which would exceed the-design-
specifications of the Safety-related Motor Control Centers.
Previous 1
analyses assumed this area to be mild, thus, the equipment was not
required to be environmentally qualified.
The ' licensee reported this
problem to NRC in Licensee Event Report'88-27, dated January 9 1989-(see
paragraph 2.9 of report details).
On December 16, 1988 during an inspection of safety-related EQ valve motor
operators the licensee discovered that three operators. contained cable
tape splices which could not' be shown to meet EQ requirements. The three
valve operators' were identified as FWV 14 'and 15, and WDV-406.
The
licensee reported this problem to NRC in Licensee Event Report 88-28,
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dated January 19, 1989 (see paragraph 2.b of report details).
The licensee did not-have kerite tape splices in their EQ Program.' 'The.
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licensee initially claimed that the tape splices were;not required for
environmental qualification.
Later.the licensee concluded that the tape
qualified life (quired for qualification and that, they have a ten year
splices were re see paragraph 3.a.(1)(b) of report details).
The inspection team considered procedures MP 405, and PM-133 inadequate to
maintain the qualified status of EQ equipment (see paragraphs 3.a.(9) and
3.a(12) of report details).
The GEMS Containment Sump Level transmitters were not found in the
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qualified tested configuration in that the junction boxes were not filled
with the silicone oil which prevents moisture ingress under accident
conditions.
During a plant walkdown three transmitters (WD 303-LT-A&B,
and WD 302-LT-B) were inspected.
All three had low silicone fluid level
in their instrument termination junction boxes (see paragraph 3.a.(2)(a)
of report details).
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The licensee's qualification file for ASCO solenoid valves was deficient
in that it did not adequately support a 40 year qualified-life when
localized temperature increases due to hot process piping were considered
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for the valves on the Main Steam. Isolation Valves
-(see
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paragraph 3.a.(8) of report details.
The licensee failed to include R.G._1.97 EQ equipment on the EQ Master
List of electric equipment important to safety.
Specifically the licensee
failed - to include R.G.1.97 electrical penetration NO.128 on the EQ
Master List.
This is also'similar to another violation issued in NRC.
Inspection Report 88-27 for failure to have components associated with the
Main Feedwater Startup Block Valves (Tag Numbers FWV-33 and 36) on the EQ
Master List of electric equipment important to safety' (see paragraph
3.a.(1)(a) of report details).
The licensee had four limitorque valve operators installed inside
containment without functioning T-Drains and Grease Reli?fs in accordance
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with the tested configuration. These operators are for RCV-11 (RCS Spray)
and CAV 1, 3 and 4 (Sample System Chemical Additional Valves), paragraph
3.a.(4).
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The licensee's EQ file on Weidmuller' tbs was deficient at the time of the
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inspection in that it did not support the qualification of _the . terminal
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block for use in RTD circuits insido containment.
No IR data was taken
during the accident profile.
Only Pre and Post LOCA IR measurements were
made. Furthermore, the installed configuration did not have weep holes in
the junction box similar to the tested configuration.
(paragraph 3.a.(10)
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The licensee recently identified other examples of apparent EQ violations
as follows (paragraph 3.c):
(1) PORV RC-11 wiring cracked and grease in gear box " Bad".
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(2) Found 17 cables and splices unqualified for submergence below the DBA
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flood zone.
This wiring involved both trains A and B and served
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Reactor Vessel Level transmitters (RC-163 ALT, RC-163BLT, RC-164 ALT,
RC-641BLT), six Reactor Coolant System Differential Pressure
transmitters (RC-14ADPT, RC-14BDPT), six level transmitters _ (SP-31LT,
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SP-32LT, SP-21LT, SP-22LT, SP-23LT, SP-24LT) which provide emergency
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feedwater pump initiation signals, and make up/ purification- system
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valve No. 505 on the letdown cooler outlet.
(3) Found 11 unqualified Raychem Butt Splices used on Main Steam Pressure
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transmitters (MS-106 PT thru MS-113PT) and Emergency Feedwater Flow
Transmitters (EF-24FT thru EF-26FT).
The problem resulted because
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Raychem WCSF-115 sleeves were used instead of WCSF-070.
For more information on the above see paragtaph 3.c of report
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details.
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REPORT DETAILS
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Persons Contacted.
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Licensee Employees
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L*D. J. Adler, Equipment Qualification Specialist
'*F. R. Bailey, Superintendent of Projects ' .
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- K. B.. Baker, Manager, Nuclear Engineering. Assurance-
- D..H.' Beach,,Superviser Site NuclearJEngineering Services
- G. Boldt, Vice President, Nuclear Production
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- P. D. Breedlove, Records. Management' Supervisor-
- G. V. Castleberry,: Nuclear . Engineering Supervisor -
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- J. Cooper Jr. . -Nuclear Technical Support Superintendent
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- S. N. Jasien, Senior Electrical: Engineer
- D. Kargel, Instrumentation and Control Supervisor
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- K. Lancaster, Manager, Site Nuclear Quality. Assurance
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- P. F. McKee, Director Nuclear Plant Operations ~
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- D. M. Nash, Nuclear Master Mechanic-
- S. C. Powell, -Supervisor Quality Systems
- V. R. Roppel, Manager, Nuclear Plant' Maintenance
- W. L. Rossfeld, Manager,' Nuclear Compliance,
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- B. L. Serrano, Senior Instrumentation and: Controls'(I&C) Procurement
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Engineer
- D. A. Shook, Manager,. Nuclear Electrical /I&C Engineering
- P. R.- Tanguay, Manager, Nuclear Operations Engineering-
- C. Tillman,~ Manager, Material Control
- L. Tiscione, Manager, Nuclear Procurement Engineering Services
- K. R. Wilson, Manager, Nuclear Licensing
- L. E. Wise, Electrical Engineer
Other licensee employees contacted during. this inspection included'
craftsmen, engineers, operators
mechanics, -- security force ' members,
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technicians, and administrative personnel.-
Other NRC Personnel-
- P. Holmes-Ray, -Senior Resident Inspector .
- J. E. Tedrow, Resident Inspector
- R. L. Pettis, Jr., Senior Reactor Engineer
- Attended exit interview.-
2.
Onsite followup of Licensee Event. Reports 88-27.and 88-28
a.
LER 88-27:
Violation- of 10 CFR 50.59 due to design. failure to
consider cracks in the Auxiliary Steam Line in the- Auxiliary Building
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Auxiliary Steam is: supplied.to the Auxiliary Building to provide. heat
for the Miscellaneous and ' Reactor Coolant? Waste Evaporators.
The'
system is designed. such that steam can;be.- supplied .to thelaste
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Evaporator units from Main Steam through, pressure regulating -valvei
' ASV-26 or Auxiliary Steam from= Fossil units.1~ and 2 via pressure -
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regulating valve ASV -27.7 Downstream of the' regulating valves there'
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are two series ' isolation : valves ' (ASV-195 and ASV-196)L that were .
' designed to isolate the. four: inch line when the pressure switches:
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downstream sense'115 psia.. This setpoint is based on.a severed line-
break.
FPC' was linformed by GAI on October 27, 1988,- that the? design lfor-
isolating'the Auxiliary Steam.Line failed to consider.a crack or a
small break in the.-line. . . The . original 1 design specification -
classified this-line.as " Moderate Energy": requiring that;only'_ cracks
be postulated.. However, a design change was. implemented in 1983 in
response to NRC Bulletin 79-01B which assumed a complete break.in the
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pipe that could be detected by' pressure switches which would actuate
isolation valves, thus, ~ preventing a harsh environment .in the
Auxiliary. Building. 'Therefore,' eliminating'the need to EQ. equipment
in the area.
Based on the above, on!0ctober'28,'1988, the licensee took compensa--
tory measures to verify that the auxiliary steam line was isolated
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and not in service and instructions were given to' operations to' keep _
this line isolated until further notice.
Meanwhile an analysis was.
initiated to determine the significance of. this concern ' and to
determine if the resulting conditions could exceed previouf y assumed
environmental conditions.
On December 7,1988 the analysis was completed. - The resul'.s of the -
calculations indicate that a maximum temperature 'of 172 Wegrees F:
could be reached with no line . isolation.- . The . qualification
temperature for the MCC's was determined by the. licensee to be .122
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degrees F (50 degrees C).
For the analysis performed, assuming line
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pressure at 195 psia,'the qualification . temperature is reached in-
approximately 13.5 minutes after the crack occurs. . The licensee also
discovered during this review that ' the high pressure regulator
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setpoints for ASV-26 and 27 had been increased at least twice since
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1983 without an evaluation to determine if the pressure switch
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setpoints should also be increased.
The most recent change occurred
in 1988 when the regulator; setpoints were increased to 175 psia..
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Based on the analysis performed the net affect of.various_ regulating
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line pressures only impacts the time it takes to reach the ~equilib-
rium temperature.-
As. a result of these. findings 1 the licensee
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reported this item to NRC on December 9,1988, as a one-hour
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notification in accordance with 10 CFR 50.72.
The' licensee
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determined that this problem could have affected safety-related class
1E -MCCs 3A1, 3B2 and 3B3.
Included in LER 88-27 is a list of
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components affected. -The following table is a sample _of the components
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identified as being . affected on MCC 3A1.-
Similar tables were
provided for MCCs 3B2 and 3B3.
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Components Affected
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ES MCC 3Al [JE, MCC] Subcomponents:
Tag #
Code
Description'
ACDP-51/41
ED,PL
Control Complex Distribution Panels
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AHF-8A-
DA FAN'
Spent Fuel Cooling Pump Fan
AHF-15A
CC, FAN'
D.H. Closed Cycle Coolirig Pump Fan
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AHF-20A
VI, FAN
Controlled Area Access Fan
AHF-24A
VK, FAN
Intermediate Building Supply. Fan
AHF-29A
VK, FAN
Intermediate Building Exhaust Fan
AHF-44A
VI, FAN
Sample Room Exhaust Fan 3A
AHV-1B/1C
VA ISV.
Reactor Building Purge Isolation
BSV-3
BE,V
. Building Spray Header Inlet
BSV-12
BE,V
Nach Tank Discharge (BST-1)
BSV-17
BE,V
Building Spray. Pump 1A Suction Valve
BSV-36
BE,ISV
Isolation Valve Between BST-2 and D.H.
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CAHE-3A
Boric Acid Storage Tank Heat Tracing
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CAP-1A
BQ,P
Boric Acid Pump 3A
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CC-3/5
Lighting Transformer
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CFV-11/12
BP.SMV
Core Flood Sample Valve
CFV-15/16
BP,VTV
Vent to Waste Gas Decay Tank
DHV-3
BP V
Decay Heat. Suction From Reactor Vessel
DHV-5
BP INV
Low Pressure Injection Valve
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DHV-11
BP,V
Discharge Valve from D.H. to M.U. Pump
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Suction
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DHV-34
BP,V
D.H. Suction Valve from BWST
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DHV-39
BP,ISV
D.H. Isolation Valve to D.H. Pump 1A
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DHV-42
BP,V
D.H. Suction Valve from Reactor Building
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Sump.
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DHV-110
BP,V
D.H. Heat Exchanger Discharge Valve
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DOP-2A
KK,P
Flush Water Pump
KK,SHV
SW Water to RW Pumps Shutoff Valve
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FWV-15
SJ,V
Feedwater Pump 3B Suction Valve
FWV-30
SJ,ISV
Main Feedwater Block Valve
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FWV-31
SJ,ISV
Low Load Feedwater Block Valve
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HTTR-3A/1A
FD,XFMR
Heat Tracing Transformer
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MTTR-5
EC,XFMR
Transformer for Misc. Chem Rad Loads
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MUV-23/24
BQ,1NV
High Pressure Injection Valves
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RMP-Al
IL,P
Radiation Monitor Pump (RB Exhaust)
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RMP-A2
IL,P
Radiation Monitor Pump (Aux Building
Exhaust)
RMP-A7
IL.P
Radiation Monitor Pump (Nuclear Sample
Room)
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RMP-A14
IL,P
Radiation Monitoring Pump (Spare)
SFP-1A
DA,P
Spent Fuel Pump
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VBIT-1A/1C
EC,1NVT-
Vital Bus Inverter 3A and-ICL
VBTR-2A/2C-
EC,XFMR'
Power; Supply Transfer
The licensee concluded that this eventiwas_ . caused by failure. to
- recognizeLand fully. implement the guidance in NRCiBulletin 79-01B
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its; supplements. These documents. directed!thatcEQ design' criteria 1 bel
. based onL plant specific HELB criteria.- This criteria for- Crystal
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-River is contained in GAI Report #1811 which was not followed.-
The . failure to-adequ'ately evaluate the pressure 'regulatorEsetpoint-
changes was determinedt to be causedLby incomplete design basis
documentation.
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This problem is an apparent: violation of.10 CFR 50'.49 and'will be :
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identified as Violation 50-302/89-09-01..
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LER 88-28:
Deficiency in Environmental Equipment' Upgradel Program -
Methodology Results .in Failure to Recognize Cable. Splices as _ Separate'
Components
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On December 16 -1988, during an inspection' of _ safety-relate'd EQ valve.
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motor operators the licensee discovered that _three ' operators
contained cable type splices which could _not be shown.to meet EQ
requirements.
The licensee reported a this . item pursuant'; to
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10 CFR 50.73.a.2.ii.B. . The three, valve operators were'= identified as
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FWV 14 and 15 and WDV-406.
Valves FWV- 14 and 15"are. located in the
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turbine building and valve WDV-406 is inside containment..
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The licensee identified that the safety. function of. FWV-14 and: FWV-15
is to close on a steam generator isolation signal to prevent the:
addition of feedwater- to a steam generator with. a-steam or feedwater:
leak, thus limiting the cooldown resulting from :these- accidents. : The
safety function of WDV-406 is to close on a containment" isolation
signal to prevent leakage of; fission products from,the, containment.
The failure to have. qualified ~ splices on_these EQ operator could have.
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prevented them from performing their safety functions lduring'a design
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basis accident.
The failure to have qualified tape splices in-the motor operators is
an apparent violation of 10 CFR 50.49.
The licensee indicated that
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the root'cause for the violation was due to a deficiency in.the EQ
Upgrade Program _ methodology. which .allcwed cable ' splices - to be
addressed generically and-not'on a component by component basis.
The failure to install EQ qualified tape splices on the above EQ-
operators will be tracked as violation 50-302/89-09-02.
3.
Evaluation of Licensee's Program for Qualification of Electrical Equipment
Located in Harsh Environments (TI 2515/25, TI 2515/76 and 2500/17).
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During the period of April 24-28, 1989, members of the Nuclear Regulatory
Commission (NRC) Region 11 and their consultant (Idaho National.
Engineering Laboratory) conducted a phase II EQ inspection at the Florida
Power Corporation (FPC) Crystal River site to assess their implementation
of a program for Environmental . Qualification (EQ) of Electrical Equipment
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important to safety.
A previous phase 1 EQ inspection (conducted.
March 4-8,1985) had examined the as-built configuration of EQ equipment
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located outside containment. The inspection resulted in eight Open Items.
These items were examined during this inspection on a sample bais and. are
now considered closed.
Areas where corrective actions were found
inadequate are discussed in this report.
However, the primary objective
of this phase II EQ inspection was to evaluate the effectiveness of the
licensee's EQ Program by sampling EQ components located inside
containment. NRC Temporary Instructions 2515/25, 76 and 2500/17 were used
as the guidelines for planning and condocting this inspection.
The team
examined EQ files; performed physical walkdown inspections of selected EQ
equipment (both inside and outside containment), reviewed the overall
implementation of the EQ Maintenance Program, and examined what actions,
if any, FPC had taken in response to vendor and NRC information notices
and bulletins concerr.ing EQ issues.
The results and conclusions reached
are discussed as follows:
a.
In-Plant Physical Inspection and EQ File Review
The inspection team physically inspected samples of important to
safety EQ components and associated field cables inside containment
for as-built installation characteristics such as mounting,
configuration, orientation, interfaces, nameplate data, moisture
intrusion seals, submergence, splices / terminations, internal wiring,
and preservation and protection.
A review of EQ files-was performed
to confirm special installation or maintenance requirements, model-
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number and equipment qualified life.
The results of the reviews
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(both file and field walkdowns) and cable traceability are discussed
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in the paragraphs below:
(1) Electrical Penetration Assemblies (EPA)-EQ File C515PENET
Two electrical penetration assemblies, manufactured by Conax,
were inspected inside the containment for mounting configura-
tion, stressing of conductors, terminations of conductors and
general cleanliness around the EPA.
The two penetrations are
identified b Crystal River's tag numbers MTBD-10A (EPA #128)
and MTBD-2B EPA #412).
(a) EPA 128 penetration was up-graded to an EQ status item when
R.G. 1.97 circuits were routed via this penetration;
however, the penetration was _not added to the Licensee's
Environmental
Qualification
Master
List
(EQML).
10 CFR 50.49 paragraph (d) states that, "The applicant or
licensee shall prepare a list of electrical equipment
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important to safety covered by this section."
Since EPA
128 was not on the EQML, this is considered to be an-
. apparent violation and is identified as 50-302/89-09-03,
EPA-128 for R.G.1.97 circuits was not on the licensee's
EQML.
The penetration is safety related and qualification
documentation is included in the existing file.
Raychem Heat Shrink tubing was used on the terminations of
field wiring to EPA-128 penetration conductors for these
R.G.1.97 circuits.
These terminations appeared to be
satisfactory.
(b) EPA-412 is a low voltage AC power distribution
The field cable to penetration conductor
termination employed a taped-type configuration.
This
taped termination was not used in the as tested Environ-
mental Qualification (EQ) configuration.
The tape-type
termination was questioned during the NRC's 1985 EQ
inspection.
After that inspection the itcensee's analysis
determined taped termination was for personnel protection
only and did not affect the operational ability of the
electrical connection during a DBA.
This analysis is felt
to be deficient in that it appears that the licensee
considered the feed through conductors of the EPA at the
containment end to be uninsulated.
10 CFR 50.49 section
(f) states "Each item of electrical equipment important to
safety must be qualified by one of the following methods:",
subparagraph (4) of this section. states, " Analysis in
combination with partial type test data that support
analytical assumptions and conclusions."
Since there was
no EQ file for taped-type terminations and analysis appears
to be deficient, this is considered an apparent violation
and is identified as 50-302/89-09-04, Tape-type Termination
in containment not supported by EQ file.
NRC Information Notice (IN) 88-89, Degradation of Kapton
Electrical Insulation, discusses possible failure of Kapton
due to mechanical damage combined with exposure to moisture
and prolonged contact with a strong alkaline - solution.
Since the EPA's use Kapton electrical insulation on the
feed through assemblies, the licensee was asked for their
evaluation of this notice with regard to the EPAs.
The
Licensee's position and evaluation based on Conax Service
Bulletin (NI Revision 3, dated March 13,1989) is that the
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EPA installation meets Conax's criteria and that there is
no impact to their qualification.
Based on the above and
the inspection of the two EPAs, Kapton electrical
insulation degradation is not considered to be a problem
for Crystal River's Conax EPAs.
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(c) 'NRCfreport 85-097 on pages. 6' and 14 ' had two1 items with
regard to open Litem 85-09-01 on EQ file for'Conax ' EPA. ,
These11tems are closed. with thisiinspection. ' The' EQ Con'ax-
test report has been included..in the EQ file:and' thisifile
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was reviewed and up-graded by. the licensee .to meet their'
Engineering Procedure . (formerly . SREP-24) .
This;up-grade-
review and documentation is now also'a part of'this" file.
1(2) Gem /Delaval Liquid Level Transmitter-EQ File G050LT.
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-(a) The licensee 1uses model . XM-54852 Land 54853 Gem /Delavai
liquid lev'el Ltransmitte-s; to monitor?the' reactor building;
(RB) water-level.
During a plant walkdown three4 transmit '-
ters (WD 303-LT A&B,-and WD 302-LT B) were inspected'. All-
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three had low silicone- fluid ~ level in their4 instrument-
termination junctions boxes. This low fluid level puts the3
instruments in a' condition that does not-agree with the as
tested qualified configuration. . 10 CFR 50.49(f). requires,.
in part,'thatieach item of. electric equipment important to?
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safety shall. be qualified by testing of,. or.' experience with '
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identical or similar' equipment, and.the qualification shall) <
include a supporting analysisito show that the equipment to
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be qualified is acceptable. : Since the qualification . test -
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had the' silicone fluid -ati the. top of the junctio'n boxes,
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this
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an
apparent- violation. identified 1 as.
50-302/89-09-05, RB Level Transmitter's Fluid Level Not' at :
Top of Instrument Termination- Junction-Box.
The licensee
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stated that the' additional silicone fluid would be added to'
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the junction boxes prior- to' restart, and that'.they. would :
revise the maintenance proceduresand EQ files to clearly?
state the silicone fluid!1evel requirements.
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(b) NRC report 85-09 on; page -13 had two_ items:with regard to:
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open item 85-09-01 on :the EQ file for - the ' Gem /Delaval
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liquid Level Transmitters. -These items are' closed with this
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inspection report. The transmitter modelinumbers have been
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corrected 'and added to the. System' Component Evaluation
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Worksheet (SCEW).
The variation between specified,'and ~
1
actual test voltage and frequency limits 'is' discussed in-
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Attachment 1 of Document Review Summary in the EQ File.
(3) General Atomic Radiation Detectors-EQ File G063RM
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Radiation Detectors RM-G29 and RM-G30 inside. the containment
were examined during the walkdown.. The mounting configuration
and cable / connector interface appeared to meet the: requirements
1
shown and referenced in the EQ file.
The Rockbestos Coaxial:
Cable (RSS6-104) used in this installation is referenced in this
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file and was considered to be part of General Atomic's EQ test
configuration.
During the walkdown, it was noted that Crystal'
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River's unique tag identifying numbers were missing from the
detectors,
lhe licensee stated that new tags would be made and
applied to the equipment.
(4) Limitorque Actuators (Inside Containment), Models SMB-000-2 and
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MSB-00-10
Four Limitorque actuators (CAV-1, 3, and 4, and'RCV-11)'inside
containment were inspected during the audit. All were inspected
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for .T-drains, grease reliefs, internal wiring, limit: switch
compartment heaters, mounting configuration, and nameplate data.
Three of the actuators had the limit switch covers off for
inspection of the compartment internals (valve RCV-11 was
located in a high radiation area so the cover was not removed).
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All of the valves inspected had the holes'in the T-drains either
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totally or partially blocked with paint. All grease reliefs had
the shipoing caps still installed and were painted over.
Loose materials (washers, nuts, pieces of wire, grease, etc.) .
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were noted in the limit switch compartments. Also, poor quality
crimp connections were found.
These are examples of apparently
poor quality workmanship and post-maintenance clean-up.
]
The licensee committed to inspect all Limitorque actuators
1
located in the plant and correct the deficiencies noted above in
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all actuators.
The failure to have functional T-Drains and
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grease reliefs is an apparent violation of 10 CFR 50.49 for not
!
having the valve operators installed in. the tested configura-
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tion. This item will be identified as 50-302/89-09-06.
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Subsequent to-this inspection, the licensee discovered that the
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pressurizer PORV (Pilot Operated Relief Valve)' Isolation Valve
,
RCV-11 showed signs of heat damage.
Wiring inside the valve
operator was found to have cracked insulation and grease in the
gear box was " Bad."
1
These are considered examples of an apparent violation of -
and will
be identified as violation
50-302/89-09-11.
The valves inspected had limit switch compartment' heaters
installed and capable of being energized.
The licensee has
recognized the problem with the heaters being energized in
qualified operators and is presently removing these heaters.
The work is being done under MAR's 87-03-13-02, 88-02-04-01, and
88-06-15-02 and will be completed during the next refueling
outage.
The effect on the qualified life of the operators will
be analyzed and documented in the EQ files after completion of
the field work.
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The requirement that Limitorque actuators be cycled twice per
year was not included in the maintenance section of the
licensee's EQ files.
However, the licensee did produce
documentation to show that all but three of 'the Limitorque
actuators at the plant were cycled 'at least twice per year. The
three not cycled this frequently were cycled .during each
refueling outage.
(5) Limitorque Actuators (Outside Containment) Models SMB-0-25,
SMB-0-15, SMB-00-7.5, and SMB-00-10
Five Limitorque actuators outside- containment were inspected
during the audit.
All were inspected for grease reliefs,
internal wiring, limit switch compartment heaters, mounting
configuration, and nameplate data.
All of the actuators had the limit switch covers off for
inspection of the compartment internals.
All of the valves had
loose materials (washers, nuts, pieces of wire, grease, etc.)-
in the limit switch compartment.
The shipping caps on the
grease reliefs appeared to have recently been removed.
The.
comments on valve inspections, heaters, and actuator cycling
noted for actuators inside containment also apply to the
actuatcrs outside containment.
(6) Target Rock Solenoid Valves, Model 81PP-001
Two Target Rock solenoid valves were inspected. All appeared to
be in good condition and rigidly mounted with sealed electrical
connections.
The licensee removed the covers from_both' valves
for inspection of the internal wiring.
0ne of the lead wires
from a reed switch had a crack in the insulation where the wire
enters the white potting compound. The licensee, has obtained a
Target Rock service bulletin concerning this same problem at
other plants and committed to inspect all Target Rock valves at
Crystal River and replace any switches with cracked insulation.
Also noted were cracked terminal blocks. The camage appeared to
be caused by poor workmanship and improper sizing of wire lugs
to fit the . terminal strips.
The licensee agreed to replace the
cracked terminal blocks and do further investigation and
replacement if necessary.
(7) NAMC0 Limit Switches, Model EA-740
Three NAMC0 limit switches for MSV-411-KS1, 2, and 3 were
inspected.
All appeared to be rigidly mounted and in good
condition.
No switch covers were removed for inspection.
Electrical connections were through NAMC0 " quick disconnect"
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electrical connectors. The ' leads from the ' switches 1were
terminated on Marathon 1500 terminal blocks ,in ' a NEMA 3
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junction box.
The licensee originally responded that the NEMA.3 junction box
was not ~ qualified.: . However, ~ a revised response was' prepared
during. the week after the inspection.
The revised' response
indicates that the terminal blocks'.were ' tested and qualified
without 'any enclosure.
It was also noted that another ~ junction box:in. the: vicinity of
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the one ' inspected had the same label' (TB-3).
The licensee-
stated that this was:a generic problem because all of the boxes =
received from the vendor were labeled as' TB-3.
The licensee-
stated that labeling will" be correc_ted.-
(8)' ASCO Solenoid Va?ves
Although ASCO valves were not included on the walkdown -list
because there were no EQ ASCOs inside containment, a question
was raised concerning the qualified life of those located in~ the
area of the MSIVs. -The SCEW sheets for these valves: indicated a.
40 year qualified life.
When questioned as'to how the 40 year life was calculated, the
licensee provided the. calculation package for- the 'ASCOs.
In
order to obtain -the' qualified life for the ~ valves .the licensee
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used a weighted average'for.the temperatures of the areas in.
which the valves were located.
The temperature profiles were
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for the average area temperatures, not.the temperature that'the
valve is subjected to.
Had the licensee used the maximum
temperature of 140 F for the area, a qualified life of eight
years could have been justified ~since these valves are normally,'
de-energized.
'
This is considered an apparent violation of 10 CFR 50.49(f) in -
that the analysis to determine the. qualified life was erroneous.
It will be identified as violation 50-302/89-09-07.
The licensee, as part of its corrective action, will use the -
existing test data and the 140
F~ temperature to: establish an~
eight year life for the valves in Zones.16 and 17. .To verify -
the conservatism of the 140*F for the MSIV solenoids, the-
licensee will take temperature measurements for a : reasonable -
period of plant operation at 100% power. These values will then
be documented and noted on the -Zone Environmental Data Sheets-
for Zones 16 and 17.
The licensee did not include the temperature rise due to
self-heating affects for six normally- energized service water
valves. The maximum normal temperature'in this area is 95 F and
the qualified life will be verified by. the licensee since~ the
self heating was not originally considered.
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(9) Reactor Building Fan Motor AHF-1A
f
The-walkdown of_ the motor installation did not restilt.in 'any
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discrepancies being noted.
A review "of' the lubrication PM
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procedure did ' identify that.- the procedure lacked. vendor
instructions for properly lubr.icating the bearings. The vendor.
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requires that the drain plug be removed prior to adding the new
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lubricant.
It also requires th'at the motor be run for a period
of time after lubricating with the drain plug open to' allow for
expansion.
' Procedure PM-133 did not contain these vendor
requirements.
This is an example of Violation 50-302/89-09-08,
Inadequate Procedure.
(10) Weidmuller Terminal Blocks
Terminal blocks RC-106 and 108 used for the temperature
compensating )RTDs in the Reactor Coolant Inventory Tracking
System (RCITS
were inspected on the walkdown. .The terminal
blocks were found mounted horizontally in NEMA-4 enclosures
without weepholes installed.
At the time of the inspection, the licensee did not have a test-
report that would qualify these terminal blocks for use in.-
instrument circuits.
Subsequent to the inspection, the licensee.
obtained a report that would qualify ~ them with the exception of
chemical spray. The licensee claims that RCITS is not necessary
for large break LOCAs and that a small break LOCA will not cause
actuation of containment spray.
This will be verified during a
future inspection and is identified as Inspector Follow-up Item
IFI 50-302/89-09-09, Operability of Reactor Coolant Inventory
Tracking System (RCITS).
In this latest test report, weepholes were required, as they
!
were in the previous report.
Without the weepholes, moisture /
condensation can accumulate and submerge the terminal block. A
junction box above the one for RC-106 did not have its cover
installed properly.
It was open to.the containment atmosphere.
,'
In the event of a LOCA, moisture could enter that box, drain-
down to the box for RC-106 and cause the terminal . block to
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become submerged.
Not having a qualification test report to demonstrate 'the
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qualification of the terminal blocks for use in RTD circuits and
not having the terminal blocks installed in accordance with the
tested configuration are violations of 10 CFR 50.49. These are
considered
as
examples
of
an
apparent
violation
(50-302/89-09-10).
Furthermore, prcblems with the use of
terminal blocks in instrument appilcations had been identified
to licensees in NRC Information Notice 84-47.
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(11) Cables Traceable to'EQ Files
During the walkdown cables were. randomlyj selected by,the NRCi
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inspectors from either the End: Device or the EPAs. -The licensee
was requested to:show how the' selected cables were. traceable to
their EQ files. The licensee informed the inspector that. cables
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are' traceable to.the EQ fileiby a. specific cable code designa-
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. tion.
Byj using the cable pull cards which includes the cable
reel number and cable code designation, the licensee.was able.to
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show that.the cables.were traceable. The following cables were
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used to verify traceability.to the licensee's EQ file. - No open
items were. identified during this review. .
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Cable No.
EPA No.-
End Device
Reel No.
Cable Code
EQ File No.
ASH 168
128
AH537TE
1001
EK-24B-
B365-CBL-001'
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RCH 3
128
RC4A-TE2
EK56C-1
EK-36C
C595-CBL-001
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RCH 27
128
RC4A-TE3
-2
EK-45C.
C595-CBL-001.-
RCH 41
128-
RC14A-DPT4
001-
EX-46C-
C595-CBL-001
RMR 347
128
RM-G30
C32208
EK-XBY
G063-RM-001
,
RMR 349
128
RM-G30
C32208
EK-XBt
G063-RM-001
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SPS 115
128
SP-17-LT-
006
EK-36A '
B365-CBL-001
1
SPS 139
'128
344
EK-35
B365-CBL-001-
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AHC 112
412
MTR AHF-1A-
002'
EK-15A
K080-CBL-001-
(12) Rosemont Series Transmitter, Models 1153 and 1154
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The transmitters selected for visual inspection were located.
inside containment and according to documentation required :
,
replacement of the 0-ring everytime ' the cover is removed, and
calibration every 18 mos. The inspectors verified the~ location,
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orientation, tag number, model number and qualified electrical:
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connections. The following transmitters were examined:
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Model No.
Inst'No.
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1154GP9RA
RC-003A-PT1
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1154GP9RA
RC-003A-PT2:
1154GP9RA-
RC-003A-PT3
,
1154DP5RA
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1154DP5RA
SP-020'LT'
1153HD6PA-
RC-014A-DPT1
4
1153HD6PA
RC-014A-DPT2
1153HD6PA
RC-014A-0PT3
All Rosemont' transmitters models'1153 and 1154 are. qualified for-
12 years and with Rosemount conduit seals.
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During the inspection of the transmitter ' terminations it was -
found that the Raychem splices were frequently made in 3/4"
condulet fittings. When these fittings were opened it was found
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that the splice joints were tightly packed into the fittings.
It was found that the Kapton insulation had broken exposing the
bare conductor in one instance and in all cases there appeared
to be a violation of the bend radius of the Raychem splice
material. The Raychem manual specifies a minimum bend radius of
five times the diameter of the splice material.
Maintenance
procedure MP-405, Installing, Repairing and Terminating Control,
Power and Instrumentation Cables, does not include instructions
regarding bend radius of Raychem splices.
Further, sheet 2 of 2
for Enclosure 5 of this procedures indicates that a 6"x4"x4"
splice box is to be used to enclose these splices. This appears
to be another example of an inadequate procedure and will be
tracked as violation 50-302/89-09-08.
The licensee, during
followup inspections, identified additional instances in which
Raychem splices were packed into a too smil (condulet fitting)
enclosure.
(13) Resistance Temperature Detectors (RTD)
A visual inspection was conducted to review the installation of
various resistance temperature detectors located inside
containment.
Three of four RTDs used to measure containment
atmosphere temperature were examined.
These units had to be
located by drawings as no plant ID tags were attached to
identify them.
The manner in which they are mounted made model
verification difficult.
The licensee has agreed that the ID
tags should be attached and committed to installing the tags.
These RTDs are Conax Model 7Q 22-10000 and are located as follows
AH 536 TE
elevation 100'
AH 537 TE
elevation 125'
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AH 538 TE
elevation 180'
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The inspectors examined the RTDs used to measure Hot Leg Reactor
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Coolant Temperature at the Once Through Steam Generators (OTSG).
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These are dual units and identified as RC-004A 1&2 and
RC-004A-TE 3&4.
These are Rosemont Model No. RTD-177HW.
The
inspector noted that the stainless steel flex conduit which was
shown on the drawings in the qualification file had been
replaced with 1/2 copper tubing between the RTD head and the
conduit seal assembly.
The file did not contain sufficient
information to determine how the copper tubing was installed as
a replacement for the flexible stainless steel conduit.
In
addition the file did not reference or contain test data or
analysis to support the design change.
Subsequent to the
inspection, the licensee furnished additional information
whereby the copper tube was installed per MAR 82-05-24-01.
The
copper tube is being used as a conduit for wires between the
Rosemount RTD and the Conax electrical conductor assembly.
The
tubing provides the water tight integrity and rigidity required.
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The inspector concluded that the installation was adequate and
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the licensee stated that the files would be updated.
b.
Maintenance Procedures
The team reviewed various maintenance procedures relating to
instrumentation calibration and repair.
The purpose of the review
was to ascertain if EQ guide lines were noted/ observed / addressed in
these procedures.
Listed below are the procedures reviewed and
comments concerning the procedure.
Surveillance Procedure 170, Pressurizer Level Instrumentation
Step 3.5.4 requires 0-ring replacement during
Calibration
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calibration and trouble shooting surveillance procedure, SP-193,
Emergency Feedwater Initiation and Control (EFIC) Transmitter Channel
Calibration. This procedure list Quality 0-ring and 0-ring grease as
other required equipment but does not mention 0-ring installation or
provide for installation sign-off.
Surveillance Procedure, SP-132, Engineered Safeguards Channel
Calibration Step 3.5.3 requires replacement of the 0-ring prior to
returning to service when final reassembly of the transmitter cover
is performed. Enclosure 7 of this procedure requires replacement and
sign off by NQC Inspection.
Procedure contain a " caution" regarding
0-ring replacement.
Surveillance Procedure SP-122, Calibration of the Reactor Protection
System
If during the course of troubleshooting Rosemount pressure
transmitters, or Rosemount RTD's and temperature elements that are
designated as "QQ" on the Safety Listing, the cover is removed or the
equipment is disassembled, a new "0"
ring shall be installed prior to
reassembly.
Rosemount 1153 and 1154 transmitters use 0-ring, MMIS No. 52-600-513;
Rosemount 177HW RTD uses 0-ring, MMIS No. 52-601-067.
The 0-rings
shall be lubricated wiht Dow Corning Molykote 55M, MMIS
No. 01-430-265, before installation.
Retorque transmitter covers to
198 in. lbs.
12 in. lbs.; RTD covers handtight.
Work shall be handled through CP-113A for any of this equipment that
requires part to be replaced.
This "0" ring replacement procedure
shall also apply if for any reason (i.e., calibration, inspection)
the equipment is disassembled or the cover is removed.
A review of maintenance for selected items indicated that required EQ
maintenance activities were being scheduled and accomplished.
No
discrepancies were noted for the items reviewed.
c.
Other EQ Issues Identified Subsequent to the Onsite Inspection
4.
..
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15'
The licensee recently identified other EQ issues as follows:
(1) PORV RC-11 wiring' cracked and grease in' gear box " Bad".
(2) Found 17 Cables and splices unqualified for submergence
below the' DBA flood zone. This wiring involved both trains
A and B and several' Reactor Vessel Level transmitters
(RC-163 ALT, RC-163 ALT, RC-164 ALT, RC-641BLT),. six Reactor
Coolant ~ System Differential
Pressure
transmitters
(RC-14A OPT, RC-14B OPT), six level transmitters (SP-31LT,
SP-32LT, SP-21LT, SP-22LT, SP-23LT, SP-24LT) which provide
emergency feedwater pump initiation signals, and make up
purification system valve No. 505 on the letdown cooler
outlet.
(3) Found eleven unqualified Raychem Butt Splices used on Main
Steam Pressure transmitters (MS-106 PT thru MS-113 PT) and
Emergency Feedwater Flow Transmitters (EF-24FT thru
EF-26FT).
Raychem'WSCF-115 sleeves were used'instead of-
WCSF-070.
These are considered additional examples of an apparent
violation of 10 CFR 50.49 which will be tracked as
Violation 50-302/89-09-11.-
4.
Action on Previous Inspection Findings (92701) (92702)
a.
(Closed) Licensee Action on Unresolved Item 302/86-31-05, Environmen-
tal Qualification of Limitorque Motor Operators.
In August of 1986 the NRC contacted Florida Power Corporation and
Crystal River concerning their 10 CFR 50.49 Limitorque motor-operated
valves with regard to IEN 86-03, Potential Deficiencies in
Environmental Qualification of Limitorque Motor Valve Operator
Wiring. A similar deficiency was discussed on Page 15 of IEB 83-72.
At that time the licensee stated that Crystal River, Unit 3 was. shut
I
down the first part of the year as a result of a-repair outage.
!
received IEN 86-03 the latter part of _ January 1986 and made the
I
decision to inspect their 10 CFR 50.49 Limitorque motor operators. A
procedure was written to cover the inspection which included the
replacement of unidentifiable wiring and a work request generated for
each Limitorque motor operator.
The inspection and wiring
replacement were completed by June 10, 1986.
This information was
reported to the NRC in LER No. 86-007-00, dated June 20, 1986.
j
As a result of the inspection of the Limitorque motor operator wiring
made during the plant walkdown as' well as a review of the procedure
for wiring changeout and a review of a sampling of the work requests
for the changeout, Unresolved Item 302/86-31-05 is considered closed.
It should be noted, however, that the procedure for wiring changeout
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included an : inspection 'of;T-drains. and grease reliefs.. . If the-
procedure.had'been followed then some of'the items'noted in the plant',
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walkdown would.have.been resolved earlier.
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b.
(Closed) . Open ~ Items 50-302/89 O9-01 thru . 08:
! correction + of'
Qualification Documentation 1 Files; Qualification Maintenance Program
Manuali Review; Revision of . Plant : Procedure; Implementation _ of EQ
Procedures during Refuel .V; Training , Implementation;: .and -EQ
Maintenance Procedures.
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The above Open Items _are now considered closed based on the:results;
.of this e inspection and ~ the1 inspection' conducted.- August:29,1988
(Inspection. Report 88-27).
Only. a, sample review was made of- those3 - ,
concerns addressed in the.. report.' If corrective actions lwere. deemed
inadequate they are discussed in this report as a' finding. Thelteam
did observe that some previousDinspection; concerns such as terminal:
blocks, limitorque valve. operators, kerite tapes type terminals,- and'
Rosemount RTS seals were- also issues during , this inspection.--
.
Indicating that the licensee's corrective tactions were inadequate.
.
5.
Exit Interview
The. inspection scope and results' were summarized on April 28; ~1089, with
those persons ' indicated in paragraph 1.
The inspectors described lthu
areas inspected and discussed in detail the inspection. results listed.
above.- Although reviewed during this-inspection, proprietary.information
is not contained in this Report'J No- dissenting comments were received
.
from the licensee.
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a.
(0 pen) Violation 50-302/89-09-01, The . licensee L discovered by -
1I
engineering analysis that a postulated crack Lof an. auxiliary steam -
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line, passing through the. auxiliary building. could' cause' a harsh
environment which would exceed the design specifications of =the -
safety-related motor control centers, paragraph 2.a.
b.
(0 pen) Vio1'ation 50-302/89-09-02, The licensee discovered that three-
EQ operators contained cable type splices which could not be shown.to-
-be environmentally qualified, paragraph 2.b.
c.
(0 pen) Violation 50-302/89-09-03, The licensee failed to : include
10 CFR 50.49 . Category b(3) equipment on the ~ EQ Master ' List,-
1
paragraph 3.a.(1)(9).-
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d.
(0 pen) Violation 50-302/89-09-04, The licensee did not have kerite
1
tape type splices in the EQ program.
The splices had been removed
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from the EQ program as corrective. action- for, a previous finding,
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paragraph 3.a.(1)(b)
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e.
(0 pen) Violation 50-302/89-09-05, The GEMS Reactor Building level
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transmitter's silicone fluid level was not at top of junction box,
I
paragraph 3.a.(2)(9).
f.
(0 pen) Violation 50-302/89-09-06, Four limitorque valves inside
containment did not have functional T-drains and grease reliefs,
paragraph 3.a. (4),
g.
(0 pen) Violation 50-302/89-09-07, ASCO solenoid valve EQ file failed
to demonstrate a 40 year qualified life, paragraph 3.a.(8),
h.
(0 pen) Violation 50-302/89-09-08, Plant procedures MP 405, and PM 133
were found to be inadequate to maintain the qualified status of EQ
!
equipment, paragraph 3.a.(9) and 3.a.(12).
)
1.
(0 pen) IFI 50-302/89-09-09, Operability of Reactor Coolant Inventory
f
Tracking System (RCITS) during LOCA conditions, paragraph 3.a.(10).
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(0 pen) Violation 50-302/89-09-10, Weidmuller tbs did not have weep
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holes in the boxes and the EQ files was deficient,
1
paragraph 3.a.(10).
k.
(0 pen) Violation 50-302/89-09-11, Other Licensee Identified EQ
violations prompted by NRC as a result of this inspection.
These
items were identified by the licensee shortly after the inspection,
paragraph 3.c.
1.
(Closed) URI 50-302/86-31-05 EQ of Limitorque Motor Operators. This
item involved the licensee's corrective actions in response to IEN
86-03, paragraph 4.a.
m.
(Closed) Open Items 50-302/85-09-01 thru 08 First Round EQ Inspection
Findings, Paragraph 4.b
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6.
Acronyms and Initialisms
,
ASV
Auxiliary Steam Valve
Design Bases Accident
Emergency Feedwater Initiation and Control
Electrical Penetration Assembly
Environmental Qualification
EQML
Environmental Qualification Master List
Florida Power Corporation
FWV
Main Feedwater Valve
GAI
Gilbert Associates, Inc.
IFI
Inspector Followup Item
IN
NRC Information Notices
LER
Licensee Event Report
LT
Level Transmitter
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Modification Approval Record
Main Control Center
Maintenance Procedure
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NQC
Nuclear' Quality Control
0TSG
Once Through. Steam Generator
Preventative Maintenance.
PORY
- Pressurizer Power Operated Relief Valve
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Reactor. Building
RCITS
Reactor Coolant Inventory Tracking System
Resistance Temperature Detector
.
SCEW
System Component Evaluation Worksheet
SP-
Surveillance Procedure
SREP
Safety Related Engineering Procedure
Stainless Steel
Terminal Blocks
TI
Temporary Instruction
l
Unresolved Item
!
'
WDV
Waste Disposal Valve
l
,
I
l
.
l
l
. _ _ _ _
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