ML20248C891

Insp Repts 50-324/89-24 & 50-325/89-24 on 890814-18.No Violations or Deviations Noted.Major Areas Inspected: Corrective Actions in Response to Previous Insp Findings Re Environ Qualification of Electrical Equipment & LER 84-16

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: ML20248C862 ML20248C891
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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[* , pDCec UNITED STATES

/- o. NUCLEAR REGULATORY COMMisstOM '

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REGION il .

q 101 MARIETTA STREET, N.W.

2 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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q Facility Name: Brunswick 1 and 2 ., <

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Inspection Conducted: August 14-18, 19 9 ,

Inspector: Y ks-nw c ur ~7-'/8- E7~

N. Merriweather Date Signed -

~ Approved  : 49//

. E.'Tonlon, Section JChiEf

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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

PDR 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 j

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=1. . . . Persons: Contacted

Licensee. Employees 1

• 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 :l

. 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 q

Levis, Resident Inspector

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• W.

D. Nelson. Resident Inspector  ;

• Attended exit interview

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2. Followup-onLic'nseeEventReport(92700)

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.(Closed) Licensee Event Report (LER) 50-324/84-16, Loss of Plant Emergency l

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4160 Volt AC Bus E-3

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 )

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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3. 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.

b. (Closed): Violations Effecting Qualification of Limitorque Operators

(1) Violation 50-324/87-22-02, Whitney -

Blake Wire Not

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  !

EQ

(4) Violation 50-324/87-22-04, Cinch Terminal Blocks Not Documented

EQ

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

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components. The licensee was able to develop qualification files for

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,

324/89-24-01, Demonstrate Qualification for Limitorque Operators with

l Continuously Energized Motor Heaters.

I c. (Closed) Violation 50-325, 324/87-22-03, SBGT Relays Not Documented

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EQ

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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e. (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

1: 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

l 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

. seal. A question -also remains regarding- the. acceptability of -the.  ;

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Raychem Coax Cable to meet ~ required loop error requirements during

Design Basis accidents. The- Victoreen Radiation Monitors wereL

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qualified with .the . cables 'in sealed conduit. ' The cables. at;

Brunswic.k are not in a sealed conduit.. The licensee has not clearly

demonstrated why this is acceptable.

4. Exit Interview- l

Tiie inspection scope and results were summarized on August 18, 1989,- with .!

those persons indicated in paragraph 1. The inspector described.the areas  ;

inspected and discussed in detail the-inspection results _. listed below..  !

Although reviewed during this inspection, proprietary information is not'  !

contained in this report. Dissenting comments were.not received from the l

licensee.  !

.(0 pen).UnresolvedItem 50-325,.324/89-24-01, Demonstrate Qualification for'

Limitorque Operators with Continuously Energized Motor Heaters,

' paragraph 3.b. .l

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