ML20141D038

Special Safety Insp Rept 50-219/85-39 on 851202-06 & 19.No Violation Noted.Major Areas Inspected:Review of Environ Qualification of Main Steam Line Low Pressure Switches & Associated Terminal Blocks & Boxes

ML20141D038
Person / Time
Site:	Oyster Creek
Issue date:	02/06/1986
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20141C998	List: ML20141C995 ML20141D038
References
50-219-85-39, NUDOCS 8602240620
Download: ML20141D038 (6)

See also: IR 05000219/1985039

Text

_

.

.

.

.

t

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-219/85-39

Docket No. 50-219

!

License No. DPR-16 Priority --

Category C

Licensee: GPU Nuclear Corporation

i 100 Interpace Parkway

Parsippany, New Jersey 07054

Facility Name: Oyster Creek Nuclear Generating Station

Inspection At: Forked River, New Jersey

Inspection Conducted: December 2-6 and December 19, 1985

,

Participating Inspectors:

W. H. Bateman, Senior Resident Inspector

l J. F. Wechselberger, Resident Inspector

M. J. Schaeffer, Reactor Engineer

Approved by: / D/4/86

i A. R. Blougtr7 Chief, Reactor Projects Date

Section IA

Inspection Summary:

Wecial safety inspection conducted by the resident inspectors (36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />) to

review the environmental qualification of the main steam line low pressure

switches and associated terminal blocks and terminal boxes.

'

Results:

One violation was identified concerning environmental qualification of electric

equipment important to safety. Three significant unresolved items were

identified.

[

!

8602240620 860214

PDR ADOCM 05000219

G PDR

. _ . _ _ _ _ __ , - --. -- .- - - _ _ _ _ _

.. . . - .

.

.

. .

!

,

j DETAILS

j '

Introduction

4

The Oyster Creek Nuclear Generating Station has just completed a one month

outage (October 18 - November 18,1985) for environmental qualification of

! electric equipment important to safety. The outage was successful in com-

pleting the planned modifications to satisfy the requirements of 10 CFR 50.49,

" Environmental Qualification of Electric Equipment Important to Safety for

j Nuclear Power Plants." ,

The licensee previously had requested an extension of the environmental qualif-

i

ication deadline to November 30, 1985 by letters dated February 22 and March

15, 1985 and supplemented by letters dated March 27, March 29, and March 30,

1985 to the Office of Nuclear Reactor Regulation (NRR). The licensee's letter

dated March 30, 1985 stated GPU Nuclear's commitment to have the equipment

qualified by November 30, 1985, or shut Oyster Creek down on November 30, 1985,

and remain shutdown until the equipment is qualified. NRR reviewed the licen-

see's request and justifications for continued operation and granted the exten-

sion to November 30, 1985 in a letter to Vice President and Director, Oyster

Creek Nuclear Generating Station dated March 30, 1985. This special inspection

was conducted by the resident inspectors to determine if the main steam line

low pressure switches and the associated terminal blocks and boxes were properly

environmentally qualified prior to and after November 30, 1985.

1

1. Summary of Events

i

A. Surveillance 619.3.008, " Low Pressure Main Steam Line Functional and

Calibration Test While Operating," was performed on November 26, 1985

,l and deviation reports were written to document the environmental

qualification discrepancies noted by the surveillance personnel. The

surveillance personnel performed the required steps in the surveil-

lance procedure and the requirements of the attached Supplemental

System Component Evaluation Work (SCEW) sheet.

In performing the requirements of the supplemental SCEW sheet and

, Procedure 105.3, " Maintenance of Oyster Creek Environmental Qualified

(EQ) Equipment," some discrepancies were noted when checks of the

main steam line low pressure switches (RE-23A,B,C, and 0) and terminal

boxes were completed. The following environmental qualification

discrepancies were reported:

,

--

RE-23A Pressure Switch

1

Cover bolts have no retainers;

One cover bolt missing.

_ _ - - _ - - - _ _ _ - _ _ _ _ _ _ - - _ _ _ _ - _ _ _ _ - _ - _ _ - _ _ _ - - - _ _ - _ _ _ _ _ - _ _ _ _ _ - -

.

.

.

. ..

3

--

RE-23A Terminal Box

No cover gasket.

--

RE-23B Terminal Box

No cover gasket;

No internal conduit sealing material.

--

RE-23C Terminal Box

No cover gasket;

No internal conduit sealing material.

--

RE-23D Terminal Box

No cover gasket;

,

No internal conduit sealing material.

Deviation Reports and Maintenance and Construction Short Forms were

written on November 26, 1985 requiring the environmental qualification

discrepancies to be completed by December 3. This was later corrected

to no later than midnight November 30, 1985.

The potential EQ concern with the RE 23's was addressed at the Plan-

of-the-Day meeting prior to November 30 without clear problem defin-

ition or resolution. On November 29, the EQ manager in Parsippany

was contacted by site personnel for problem resolution and guidance.

The direction provided by the EQ manager was essentially to correct

the discrepancies prior to November 30, 1985. Difficulty was encoun-

tered by the licensee in locating the appropriate materials to effec-

tively seal the terminal boxes in accordance with the guidance provided

by the EQ manager in Parsippany. On December 2, at the Plan-of-the-Day

meeting, the status of the environmental qualification of the RE-23

switches and associated terminal boxes was addressed and found to be-

uncorrected.

After the fact, i.e., between December 2 and December 6, 1985, the

licensee determined that the RE-23 terminal blocks were environmentally

qualified despite the deficiencies in the enclosures (terminal boxes).

This issue is discussed later in this report (see Detail 1.B, Unresolved

Item 85-39-02) and will be further reviewed in a future NRC inspection.

Based on this after-the-fact determination that the blocks were qual-

ified, there appears to be no significant technical concern regarding

the failure to correct the terminal box discrepancies by November 30.

However, the manner in which the licensee handled this event raises

concerns regarding (1) communication and evaluation of EQ qualification

information; and (2) coordination of the evaluation and respor.se to

EQ deficiencies:

_ _ - - - _

.

.

. ..

4

(i) The information available on November 30, i.e. , known EQ defic-

iencies with the terminal boxes had not been corrected as of

midnight November 30, indicated that 10 CFR 50.49 requirements

may not have been met. However, no evaluation regarding equip-

ment operability, Technical Specification Limiting Condition for

Operation applicability, or justification for continued operation

was performed. The appropriate people to make such evaluations

were apparently unaware until December 2 of the failure to correct

the deficiencies by midnight of November 30.

(ii) 10 CFR 50.72 requires the licensee to notify the NRC Emergency

~

Operations Center within four hours of any event or condition

that alone could have prevented the fulfillment of the safety

function of systems that are needed to mitigate the consequences

of the accident. The terminal box EQ deficiencies involved all

four subchannels of protection logic. The logic isolates main

steam lines on indications of a line break. Based on the infor-

mation available on November 30, the licensee should have

questioned the ability of the protective feature to function in

a harsh environment and made a four-hour report. No report was

made nor is there evidence one was considered.

(iii) On December 5, 1985, in a telephone conference call among licen-

see corporate EQ personnel, site Technical Functions personnel,

NRC Region I personnel, and the NRC resident inspectors, the

licensee stated that the terminal blocks were qualified despite

the enclosure deficiencies that had existed. In that call, the

licensee failed to make it clear that the determination of

qualification was, in part, based on:

(a) an assumption that the blocks were manufactured by either

General Electric, Weidmuller, or States; and

(b) analysis done after November 30, that, for the specific

RE-23 application, the specific deficiencies in terminal

boxes A through 0 would not invalidate the environment

qualification of Weidmuller blocks. GE and States blocks

are qualified exposed, whereas Weidmuller generally requires

an enclosure.

'

Based on item (i) through (iii) above, the inspector considers

the adequacy of the licensee's management controls over EQ program

information and evaluations to be unresolved (219/85-39-01).

-. . . .

. .

. ..

5

B. During the above noted December 5 conference call, the licensee

l agreed to provide to NRC Region I a copy of the SCEW sheet for the

i RE-23 terminal blocks.

In subsequent conversations the same day with the EQ Manager, the NRC

resident inspectors found that the exact manufacturer of the terminal

! blocks was unknown and field inspection would be necessary to deter-

l mine what SCEW sheet to send to NRC Region I. Thc inspection determined

I the terminal blocks to be manufactured by "Stanwick Electric" and not

by one of the three manufacturers previously known to the licensee

and evaluated for environmental qualification at Oyster Creek. No

j SCEW sheets for Stanwick terminal blocks were included in the Master

l EQ List as of December 5.

The licensee contacted Stanwick Electric Company to determine if they

had performed any EQ testing on the terminal blocks. Stanwick Electric

had not performed any EQ testing but stated that some nuclear utilities

had performed such testing. The licensee discovered that Duke Power

had performed environmental qualification testing on Stanwick Electric

terminal blocks.

The licensee analyzed the information and concluded the blocks could

be qualified for the Oyster Creek application. The licensee developed

a SCEW sheet for the Stanwick Electric terminal block and provided a

copy to NRC Region I. The sheet, dated December 17, 1985, was reviewed

by a NRC Region I specialist inspector. The sheet indicates the block

is qualified for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after a High Energy Line Break. Although

the sheet was generally in order, the inspector questioned the opera-

ting time specification of less than one hour. Also, since the sheet

is summary in nature, inspector review of area environmental profiles

and equipment test reports will be necessary to fully verify qualifica-

l tion. Therefore, pending a more in-depth review by NRC, the qualif-

l

'

ication of the subject terminal block for its use at Oyster Creek is

unresolved (219/85-39-02).

2. Additional Concerns

t

A. The licensee had established environmental qualification files and

l system component evaluation work (SCEW) sheets for the important to

safety electric equipment. Although this has been accomplished, the

licensee did not have a SCEW sheet for the Stanwick Electric terminal

block, nor was the terminal block listed on the Master EQ List. - 10

CFR 50.49 and GPUN Technical Functions procedure 5000-ADM-7317.01

require, in part, that the licensee prepare a record of the qualifica-

tion of electric equipment important to safety to permit verification l

that each item is qualified for its application and meets its specified

performance requirements when it must perform its safety function.

l'

,

!

L

. . - - . .- _ _ - . . _ _ _

_

- - _ . . -. . - _ . _ .

. *

1 . . . .

t

6

,

a

The licensee first determined the presence of Stanwick Electric

terminal blocks during the course of this inspection and later.per-

i formed an analysis to environmentally qualify these components for

l use at Oyster Creek. The licensee had no previously established

1

record of Stanwick terminal blocks for Oyster Creek. Failure to

~ adequately identify electrical equipment important to safety and

j prepare a record of qualification is a violation. (219/85-39-03)

8. Another area of concern was -the inability of the EQ audit group to

f appropriately identify this EQ discrepancy. The licensee estabifshed

an EQ program in accordance with the requirements of 10 CFR 50.49 and

promulgated Technical Functions Procedure 5000-ADM-7317.01 (EP-31),

i Revision No. 0-01, " Equipment Environmental Qualification," to assure

compliance with applicable regulations. EP-31 requires nuclear assur-

, ance to audit records and files required to implement and sustain

i systems, procedures, and programs established to ensure the proper

i control of environmentally qualified equipment. The audit group did

not identify the presence of Stanwick Electric terminal blocks at

~ '

i Oyster Creek. The adequacy of EQ audits is an unresolved item pending

j NRC review of GPUN Environmental Qualification Program. (219/85-39-04)

'

3. Unresolved Items

Unresolved items are items about which more information is required in

.

order to ascertain whether they are acceptable, violations, or deviations.

l Unresolved items identified during this inspection are df:Jussed in para-

graphs 1.A, 1.B, and 2.B above.

,

4. Exit Interview

.

l Prior to the issuance of this special inspection report, a telephone con-

! '

ference was held with licensee management to discuss the findings discussed

herein. The licensee stated that of the subjects discussed at the exit

interview, no proprietary information was included,

i

5

i

1

I

!

1

4

I

_ _ _ _ _ _ - _ . .