ML20247A510

Insp Rept 50-382/89-05 on 890213-17.Violation Noted.Major Areas Inspected:Licensee Action on Previously Identified Violations & Unresolved Items Re Equipment Qualification of Electric Equipment

ML20247A510
Person / Time
Site:	Waterford
Issue date:	03/14/1989
From:	Andrea Johnson, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247A477	List: ML20247A471 ML20247A510
References
50-382-89-05, 50-382-89-5, IEIN-86-003, IEIN-86-3, NUDOCS 8903290136
Download: ML20247A510 (6)

See also: IR 05000382/1989005

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APPENDIX

- U.S. NUCLEAR REGULATORY COMMISSION

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• REGION I\

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NRC Inspection Report: 50-382/89-05 Operating License: NPF-38

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4 Docket: -50-382-

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l; ' , Licensee: LouisianaPower&LightCompany(LP&L)

317 Baronne Street

New Orleans, Louisiana 70160

Facility Name:: Waterford Steam Electric Station, Unit 3

Inspection At: . .Taft,": Louisiana

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. Inspection-Conducted: February 13-17, 1989

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< i Inspector: 'M. / M $ /t 30

-A. . Johnso , Reactor Inspector, Plant Systems Date

'< ection, ivision of Reactor Safety i --

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Approved: A U27 _

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T. FJ Sretka, Chief, Plant Systems Section Date

Division of Reactor Safety

Inspection Summary

Inspection Conducted February 13-17, 1989 (Report 50-382/89-05)

Areas Inspected- Routine, unannounced inspection of licensee's action on

previously identified violations and unresolved items regarding eculpment

qualification (EQ) of electric equipment for compliance with 10 CFR 50.49.

Results: Within the areas inspected, one apparent violation was identified.

T 'The apparent violation involves a failure of the licensee to fully establish

__ qualification of Okonite T95/35 splice tape assemblies. The splice tape

assemblies are for safety-related (SR) cable located below the postulated

c submergence level inside containment. The potentially submerged SR cable

splices relate to some 16 electrical terminations of installed instrument and

. control (I&C) devices.

8903290136 890317

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PDR ADOCK 05000382 PDC

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DETAILS

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1.  ! Persons Co'ntacted

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LP&L

• P.; V. Prasankumar, Assistant Plant Manager >

• M. J. Meisner,-Licensing Manager ,

• J. J. Zabritski Operations Quality Assurance' Manager

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• L. L. Bass, Nuclear Operations Engineering Supervisor

• G. M. Davis, Event Analysis & Reporting Manager

• R. J.'.Murillo Licensing Engineer

• C, R. Gaines, Event Analysis Supervisor

• J. E. Howard, Procurement / Programs Engineering Manager

Nuclear Regulatory Comi<. ' ion

• T. F. Stetka, Chief, Plant Systems Section, Region IV

• W. F. Smith, Senior Resident Inspector

• Denotes attendance at the exit meeting on February 17, 1989.

.TheNRCinspectoralsocontactedotherpersonnh1fromtheLP&Lstaff

during the inspection. <

2. Licensee Actions on Previously Identified Items

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2.1.(C1csed)tJnresolvedItem(382/8632-02): This urresolved' item involved

the potential submergence of ITT Barton pressure transmitters._ The NRC:

inspector reviewed EQ file (EQF) 8.2, "ITT Barton Model 763 Gage Pressure-

Electronic Transmitter,"Section IV of this EOF contained an LP&L EQ I

assessment on the use of ITT Barton Model 764' differential pressure

transndtters wnich are used at Waterford Unit 3 (W3). In addition,

Section IV included Report No. LPL-EQA-8.2.c, Revision.0, dated April 27,

1987, which stated that the W3 containment sump level transmitters (narrw

range) (Tag No.'s SP-ILT-6705A and B) were ori$ ally intended to be  ;

qualified for submergence conditions. This report further states that ]

this requirement was deleted because of redundantly installed (wide range) j

transmitters were available that measured the level in the safety j

injection (SI) rump and have overlapping ranges (Tag No.'s SI-ILTe7145A

and-B). The narrow range transmitter safety functions will be substituted

by the wide range transmitters once the narrow range transmitters.become  !

submerged. The postulated submerged conditions were analyzed in LP&L  !

letter W3B87-0218 dated January P9, 1987, ar.d discussed during L'P&L's

summary of information presented at the enforcement conference held in NRC

Region IV on October 4, 1E38.

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The NRC inspector determined that the LP&L analysis demonstrates the use .

of the narrow range transmitters until the postulated flood level is  !

reached. The qualified SI sump instrumentation with overlapping readout .l

ranges would be used as the primary indicators beyond the point of

submergence.

This unresolved item is closed.

2.2 (Closed) Violation (382/8827-02): This violation involved qualification

of RTV silicone rubber sealant used to seal Rosemount transmitters. The

NRC inspector reviewed the EQF EEQD 8.1/8.1A for the required documentation

to establish use of General Electric (GE) RTV silicone rubber sealant,

Type 106/116/8262, in lieu of electrical seal assemblies on Rosemount

transmitters. The85-162,

Evaluation Report NRC inspector

dated February reviewed (1) LP&L's S20,Engineering

Digital 1985; (2) pare Parts E

Incorporated Test Report No. DEI-TR-850100-18 for Borg Warner Actuators;

and (3) an EBASCO Thennal Lag Analysis, Report No. LPL-EQA-8.1, Revision 2.

These documents were contained in, or referenced, in the EEQD 8.1/8.1A

file. The thermal lag analysis document is used to establish qualification

of the GE RTV applied to Rosemount transmitters for the projected 414*F

temperatures that would occur during the postulated 120-day accident

duration period at W3. The analysis /calculat. ions demonstrated that

although the GE RTV sealant has only been tested to a maximum temperature

of 350 F, it was capable of withstanding brief temperature peaks above

350*F for short periods. The duration of these periods are in agreement

and within the LP&L W3 accident profile for the location of the Rosemount

electrical seal assemblies.

This violation is considered closed.

2.3 (Closed) Unresolved Item (382/8632-05): This unresolved item involved

qualification of internal wiring on Limitorque motor operators. LP&L

inspections of Limitorque motor operators for internal wiring qualification

requirements in accordance with NRC Information Notice (IN) 86-03, was

completed at W3 on June 19, 1986. The inspection program was initiated by

LP&L on January 15, 1986, during which 64 motor operators were scheduled

for inspection. When LP&L identified indeterminate internal wiring in

these motor operators, the wiring was immediately replaced with fully

qualified Rockbestos SIS wire. This wire replacement is documented in

Equipment Qualification Assessment (EQA) 6.3/6.3A.

This item is considered closed.

2.4 (0 pen) Unresolved Item (382/8831-01): This unresolved item involved

submergence qualification of Okonite T95/35 spliced tape assemblies. LP&L

identified in Condition Identification Report No. 260306, dated December 5,

1988, that Okonite T95 (insulation)/35 (jacket) spliced tape assemblies,

related to some 16 SR instal k d I&C devices, are potentially located below

the postulated flooding level inside containment.

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A revision to EQA No. 6.2/16.2 for Okonite T95/35 splice tapes (EQF-45

dated January 18,1989) did not adequately establish submergence

qualification. The EQF-45 documentation described a brief dielectric high

potential withstand test. The NRC has determined that this test is

insufficient to establish qualification for submergence during the design

basis accident (DBA) and post DBA periods. The NRC inspector also noted

that the withstand test was performed at the end of the full scale LOCA

tests only to demonstrate ink ity of the tested cable splice. To

determine the licensee's qua~ ication basis, the NRC inspector reviewed

three test reports contained in EQF-45 as follows:

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" Final Test Report on Okonite Tape Splice Insulation for Power and j

Control cables and Rockbestos Pyrotrol III and Firewall III Cables"; J

Patel Engineers Report No. PEI-TR-842900-1, May 24, 1985, for New

York Power Authority

" Final Report on the Qualification of Parallel Splice Insulation

Systems Used on Power and Control Cables in the James A. Fitzpatrick

Nuclear Power Plant"; Patel Engineers Report No. PEI-TR-840704-1, l

July 11, 1984, for New York Power Authority

" Qualification Test Program on Splices Fabricated with 3M Scotch

Super 33 Vinyl Plastic Electrical Tape and Okonite Splicing Tapes

No. 35 and T-95 for the Alabama Power Company for use in the Farley

Nuclear Generating Station"; Wyle Report No. 17947-01, October 1987

Patel Report PET-TR-842900-1 represents a full LOCA test and includes a

high voltage withstand (high potential dielectric) test after the accifent

exposure. This type test was mandated by IEEE Standard 383 and included:

(1) straightening; (2) inspection and rebending of each cable splice

assembly; and (3) immersion of each cable splice assembly in tap water

while being subjected to a high potential test in excess of its rated

voltage. The immersion test is nominally a 5-minute test performed on a

steel mandrel for the purpose of verifying the integrity of the cable

jacket. The NRC has not accepted this immersing testing sequence as

sufficient to demonstrate the capability of the splice assembly to

withstand submergence successfully during LOCA exposure for the

postulated 120 days.

The NRC inspector also noted that Patel Report PEI-TR-840704-1, which used

heat rise equations as consideration to determine thermal aging, was only

partially used by LP&L to establish the qualified life aging requirements

for the test specimens prior to LOCA accident testing. Although a high

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potential integrity test was performed at the conclusion of this testing,

there was no documented evidence to demonstrate submergence of the cable

splice assemblies in tap water.

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The NRC inspector also noted that Wyle Report 17947-01 was used'to extend

the qualification of the in-line splice configuration of the Patel

PEI-TR-842900-1 testing to other configurations, including the "V" type.

Tne similarity of measurements during the Patel and Wyle tests was used by

LP&L to demonstrate qualification of alternate splice configurations. No

' dielectric high potential or tap water submergence integrity tests were

documented in the Wyle report.

The NRC inspector determined that the above three reports involved LOCA

testing of T95/35 tape splice assemblies on 600 volt Rockbestos Firewall III

XLPE and 1000 volt Rockbestos Pyrotrol III instrument and control cable.

The licensee uses other applications of the T95/35 tape splice assemblies,

that are below the postulated flood levels, on cables manufactured by

Samuel Moore, Anaconda, and ITT Barton (Tefzel). LP&L has not analyzed

the material compatibilities of these splice configurations to other cable

- manufacturer's jacket and insulation materials. Therefore, these

. configurations are not considered to be qualified.

The SR installed I&C equipment associated with the T95/35 tape splice

- assemblies located below the postulated submergence level are as follows:

Tag No. Equipment

CCS-IDPT-5153B Containment Fan Cooler: Rosemount

CCS-IDPT-51588 Model 1153 Series A, Differential i

Pressure Transmitter

RC-IPT-106A Saturation Margin Monitor, Reactor

RC-IPT-106B Coolant System (RCS) Hot Leg:

ITT Barton Model 763, Pressure

Transmitter

SG-ILT-1115A Steam Generator Level Transmitters

SG-ILT-1115B (Wide Range): ITT Barton Model 764

SG-ILT-1124A

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SG-ILT-1125B

SI-ISV-343 Containment Isolation Solenoid

SI-IZS-343-1 Operated Valve, Safety Injection

SI-12S-343-2 Tank (SIT) Drain Line to Reactor

Water Storage Pool (RWSP): ASCO

Solenoid Model NP831664E, Namco

Position Switches Model EA18021302

BM-ISV-109 Containment Isolation Solenoid

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BM-IZS-109-1 Operated Valve, Reactor Drain

, BM-IZS-109-2 Tank (RDT) Drain: ASCO Solenoid

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.Model NP831665E, Nan.co Position

Switches Model EA18015302

SI-ILT-7145A SI Sump Level Transmitters (Wide

SI-ILT-71458 Range): ITT Barton Model 764

Failure to quilify the T95/35 splices for submergence during the

postulated strident is considered to be contrary to the requirements of

10 CFR 50.40 if) and (k). This is considered to be an apparent violation.

3. Exit Interview

The inspection scope and findings were summarized on February 17, 1989,

with the licensee personnel indicated in paragraph 1. The licensee did

not identify as proprietary any of the materials provided to, or reviewed

by, the NRC inspector during the inspection.

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