ML20248C891
| ML20248C891 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/18/1989 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20248C866 | List: |
| References | |
| 50-324-89-24, 50-325-89-24, IEIN-86-071, IEIN-86-71, NUDOCS 8910040053 | |
| Download: ML20248C891 (7) | |
See also: IR 05000324/1989024
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UNITED STATES
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NUCLEAR REGULATORY COMMisstOM '
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REGION il
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101 MARIETTA STREET, N.W.
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ATLANT A, GEORGI A 30323
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Report Nos'.:.50-325/89-24 and 324/89-24
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Licensee: Carolina Power and Light Company
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P. O. Box 1551
Raleigh,-NC 27602
Docket Nos.: 50-325 and 50-324
License Nos.: DPR-71 arid'DPR-62
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Facility Name: Brunswick 1 and 2
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Inspection Conducted: August 14-18, 19 9
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Inspector: Y
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N. Merriweather
Date Signed
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9-/M 8
~ Approved
. E.'Tonlon, Section JChiEf
Date Signed
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Plant Systems Section
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine unannounced inspection was conducted to review the licensee's
corrective actions in response to previous inspection findings involving
environmental qualification (EQ) of electrical equipment and to followup on a
licensee event Report (84-16).
Results:
In the areas inspected, violations or deviations were not identified.
The
inspection concentrated on those corrective actions taken by the licensee to
resolve previous inspection findings and a reportable design deficiency.
No
specific strengths or weakness were observed in the actions taken by the
licensee to correct these problems.
The licensee is now considered to be in
full compliance on the matters. Review of a previous unresolved item involvin
the qualification of the Viccoreen High Range Radiation Monitor (325/88-15-03)g
ravealed a concern regarding the use of Raychem shrink sleeving as a qualified
conduit seal over stainless steel.
As far as the inspector knows this
configuration has not been qualified for use inside the drywell. The licensee
committed to provide additional information relating to qualification of this
design.
The inspection 1;cluded a review of known limitorque problems to
determine the status of the licensee's corrective actions. One new unresolved
item was identified involving the qualification of Limitorque operators with
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8910040053 890926
ADOCK 05000324
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continuously energized motor heaters.
The qualification of the motor heaters
has not been addressed in the qualification files and the vendor does not
support qualification for these heaters.
Thus, additional information is
needed to evaluate what significance the motor heaters may have on the
qualification of-the 'limitorque operators.
The licensee's actions in response
to Information Notice (IN) 86-71 (Limitorque limit switch compartment heater
problems) have been slow and are still incomplete.
No action has been taken on
approximately 33 valves that were exempt from inspection for unqualified
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internal wire problems. The licensee cannot be certain at this time that these
wires are not in contact with limit switch compartment heaters. To insure that
no damage has occurred the licensee should perform wiring inspections on these
33 operators.
This issue remains open and is discussed further in paragraphs
3.b and 3.f of the report details.
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REPORT DETAILS
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. . . Persons: Contacted
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Licensee. Employees
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- J. L. Harness, General Manager
- B..Phillips,EQ. Engineer
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- R. M. Paulk, Project Specialist, Regulatory Compliance
- L. Rothman,'EQ Project Engineer
Othcr licensee employees contacted during this inspection included
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. craftsmen, ~ engineers, security force members, and ' administrative
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personnel.-
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NRC Resident. Inspectors
W. Ru' land, Senior Resident Inspector
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- W. Levis, Resident Inspector
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D. Nelson. Resident Inspector
- Attended exit interview
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Followup-onLic'nseeEventReport(92700)
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.(Closed) Licensee Event Report (LER) 50-324/84-16, Loss of Plant Emergency
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4160 Volt AC Bus E-3
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LER 84-16 describes a design problem involving misapplication of a.certain
type of degraded voltage relay on plant 4160 volt AC emergency buses E-1
thru'E-4.
The design resulted in a situation'of unpredictable transfers
involving the 125 vde control power to the switchgear of those buses. The
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licensee determined that the most reasonable solution was to replace the
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. degraded voltage relays on all the E-buses with another type relay that is
.better suited for this design. The licensee selected a model ITE-27N type
relay- because the output contacts do not change state on a loss of de
control power. This allows transfers from normal to alternate de supplies
without activating the de trip logic to-the E bus supply breakers.
The
inspector toured the Diesel Generator Building to examine the undervoltage
. relays installed on E-buses 1, 2, 3 and 4.
The inspector verified that
the new. type relays were installed on each bus.
The relays had been
installed by plant modification 84-359.
Review of the vendor Technical
Manual for type ITE-27N relays confirmed that the output contacts do not
close on loss of de control power.
Based on the above, this item is now
considered closed.
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Action on Previous Inspection Findings (92701 and 92702)
a.
-(Closed) Violation 50-325, 324/87-22-01, HPCI Speed Senors Not
Environmentally Qualified
CP&L identified in October 1986 that the Woodward speed sensors for
the HPCI speed control on Units I and 2 Steam Turbine Assemblies were
not environmentally qualified. A notice of violation was issued in a
letter dated May 5, 1988.
CP&L responded to the. Notice in a letter
dated July 1, 1988.
A subsequent order imposing a civil monetary
penalty was issued June 26, 1989. The corrective action taken by the
licensee was to replace the speed sensors with fully qualified ones
and conduct a reassessment of skid-mounted component qualification.
Subsequent to the response dated July 1, 1988 the licensee discovered
unacceptable or unqualified EQ splices on the Unit 2 HPCI Auxiliary
011 Pump Motor lead terminations.
This appeared to be another
example of where field verification walkdowns were not accomplished.
The licensee reported this event as LER 88-012.
The corrective
action taken by the licensee was to replace the splices on both
units. The HPCI Speed Control Magnetic Pickups were replaced by Work
Requests using CP&L part No. 729-237-82.
This part is qualified by
the licensee's EQ files.
Based on the above, this item is considered
closed.
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(Closed):
Violations Effecting Qualification of Limitorque Operators
(1) Violation 50-324/87-22-02, Whitney
Blake Wire Not
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Environmentally Qualified
(2) Violation 50-325/87-22-02, Vulkene Wire Not Environmentally
Qualified
(3) Violation 50-325/87-22-04,'Kulka Terminal Blocks Not Documented
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(4) Violation 50-324/87-22-04, Cinch Terminal Blocks Not Documented
NRC Inspection Report 87-22 identified the above examples of EQ
violations for unqualified wire and terminal blocks installed in EQ
Limitorgue Motor Operators.
The wire and terminal blocks had not
been previously qualified by the vendor and the licensee did not have
documentation in the EQ files to support qualification for these
items installed.
The corrective action taken by the licensee was to
replace the unqualified wire and terminal blocks with qualified
components. The licensee was able to develop qualification files for
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Kulka terminal blocks and Vulkene wire. A 100 percent inspection was
performed on those limitorque actuators that were not replaced with
new operators as part of the EQ compliance activities.
This left a
total of approximately 33 valves that were not inspected.
The
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inspections identified other problems such as additional examples.of
- unqualified l wires and terminal blocks, missing .T-drains and grease'
reliefs; Some of these problems were discussed and tracked in an NRC
Inspection. Report as - Unresolved Item - 50-325/87-36-02 and .50-324/ .
87-37-02. The licensee is considered to be in full compliance on the
valve operators that were reinspected.
Of the.33 valves that were.
not inspected the inspector .has a concern regardingethe potential
L damage of jumper wires due to continuously _ energized.11mitL switch :
compartment heaters.
A NRC Notice-86-71 warns against the potential
damage.of internal wiring due to.close proximity _ to heaters.
As of
the' date of this inspection the licensee cannot be certain that these
wires are. not in contact with . limit switch compartment heaters. The
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inspector- informed. the licensee that to ensure that no damage. has
occurred 'CP&L should perform wiring inspections on - those 33
operators.
.This item remains open and is further discussed in
paragraph 3.'f.
Another concern involving Limitorgue operators
involves the qualified status of .the operators with continuously
energized motor heaters.
These heaters are powered from a separate
non-safety 120 vac source.
The' licensee believes that these heaters
are non-safety and do not effect . qualification of the 'Limitorgue
actuator.
However, there is no documentation from the vendor to
support this position.
In fact :there have been no -LOCA' tests
performed on Limitorque operators with continuously energized motor
heaters.
The inspector requested that the licensee evaluate what
significance the motor heaters may have on the qualification of.the
Limitorque operator. This will be tracked as Unresolved Item 50-325,
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324/89-24-01, Demonstrate Qualification for Limitorque Operators with
Continuously Energized Motor Heaters.
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(Closed) Violation 50-325, 324/87-22-03, SBGT Relays Not Documented
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Since identification of this violation, the licensee established
qualification for the Unit I relays (Model CR2810) in Qualification
Data Package (QDP) No. 68.
The Unit 2 relays were replaced-with a
Westinghouse relay (Model AR880) which is also qualified by QDP 68.
The relays have a demonstrated 40 yr qualified life.
Based on the
above this item is closed.
d.
(Closed) Violation 50-325,324/87-22-05, Standby Gas Treatment (SBGT)
Temperature Switch Leads Not Environmentally Qualified (EQ)
The licensee discovered on March 11, 1987 that leads connected to the
IB SBG System deluge temperature Switches (TS1, TS3, TS5, and TS6)
were terminated using unidentified blue colored wire.
A violation
was cited because this unidentified wire was not on the licensee's EQ
master list of qualified equipment.
The licensee replaced the
unqualified wire with qualified Rockbestos wire by approved work
requests. The work requests were reviewed and found acceptable. All
work was documented as complete on March 14, 1987.
Based on the
above this item is considered closed.
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(Closed) LViolation '50-325, 324/87-22-06, HPCI Float Switches Not
Environmentally Qualified.
The : licensee has obtained the documentation from GE to demonstrate
qualification for the switches.
This information is' included in
document reference (DR) 69.2 referenced in QDP 69.. This item is'now
considered closed.
f.
(0 pen) Unresolved Item 50-325/87-36-02, 50-324/87-37-02, Additional.
EQ Items:- Allen-Cradley Nylon 6 Terminal Block (TB); Collier PVC
Wire; GE CRISI TB;'Old Marathan TB; and Additional Whitney Blake Wire:
~The above items are additional examples of unqualified components
identified in Limitorque motor operators.
The inspector. reviewed
computer summaries of sample trouble tickets 1that~ performed EMP 34.6
inspections and repaired the valves to a qualified configuration.
Results of inspections seem to indicate that the bases for exempting
certain new valves from the inspections may. not be supported by
documented evidence to show that the configurations have functional
T-drains and grease reliefs and that internal wiring is not in close
proximity or touching the limit switch compartment heaters.
As'
discussed earlier .the inspector informed the licensee that wiring
inspections should also be performed on those valves.
This: item
remains open pending further inspections of those previous exempt
valves.
The valves are mostly inaccessible during power operations
and should be examined during the next outage.
g.
(0 pen) URI 50-325/88-15-03, Qualification of Victoreen Radiation
Detector
This item remains open because additional information is needed to
establish qualification for the as-installed Victoreen Radiation
Detector and Cable.
It appears from review of an as-built drawing
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that the licensee used Raychem shrink sleeving on a stainless steel
conduit to obtain a cable entrance seal for the detector.
This
design has not been adequately proven to be qualified by the
licensee's EQ files.
The licensee claims that this is equivalent to
an in-line cable splice.
However, the inspector disagrees with the
licensee on the basis that the test report only shows that Raychem
will bond to cable.
It does not prove that the material will bond to
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stainless steel.
Another concern is that there is no way to
correlate the results of the in-line splice test which measured
leakage current by taking insulation resistance measurements versus
leak detection methods necessary to establish qualification for a
moisture intrusion seal.
The licensee did obtain some additional
test data on a Raychem seal using a stainless steel nipple design.
This configuration is not exactly the same as the ones used at
Brunswick.
However, the test does qualify the seal for 15 psig
external pressure.
This does not envelope the environmental profile
for drywell qualification at Brunswick, therefore, to fully
demonstrate qualification for this seal design the licensee agreed
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to ' provide additional _ information in an auditable form which will
clearly' resolve: all concerns ' regarding the qualification of. this
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A question -also remains regarding- the. acceptability of -the.
Raychem Coax Cable to meet ~ required loop error requirements during
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Design Basis accidents.
The- Victoreen Radiation Monitors wereL
qualified with .the . cables 'in sealed conduit.
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Brunswic.k are not in a sealed conduit.. The licensee has not clearly
demonstrated why this is acceptable.
4.
Exit Interview-
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Tiie inspection scope and results were summarized on August 18, 1989,- with
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those persons indicated in paragraph 1.
The inspector described.the areas
inspected and discussed in detail the-inspection results _. listed below..
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Although reviewed during this inspection, proprietary information is not'
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contained in this report.
Dissenting comments were.not received from the
licensee.
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.(0 pen).UnresolvedItem 50-325,.324/89-24-01, Demonstrate Qualification for'
Limitorque Operators with Continuously Energized Motor Heaters,
' paragraph 3.b.
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