ML20198P529
| ML20198P529 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/12/1997 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20198P464 | List: |
| References | |
| FOIA-99-32 EA-96-354, ESR-97-00087, ESR-97-00087-R01, ESR-97-87, ESR-97-87-R1, NUDOCS 9901070073 | |
| Download: ML20198P529 (17) | |
Text
{{#Wiki_filter:N C2 1 Page 1 sf _ pm j ENOlNEERKJG SERVICE REQUEST san e eroooer n ,e $ wwwoe over Doownenm ten, oss, ses.) Pnmery system a pienery ro M None m sup **'*8'"' l 8041 GENERIO ENVIRONMENTAL QUALIFICATION Pitt POR O A"ffected fles OHginatorWPhone SG Type JC0 for improperty configures ceneust Seele STYRON. WIWAM C /060 31De Plant Customere (PvtntNente, Sign Does) EngineeringfPlant Programe (Psint Neme. Sgn, Does) EQ
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is a 10CFM 90.55 Safety Review roodred per (plant speems m _ _t? NA$ Sofore Approvel/implomontotin O Setety Evolustion revoed (Pried Name, Sign. Dets) NAS Beh Claesout E ESR Rev does not effect provteue Safety AneWWee) or USQ f :%Me). PNSC Before Approvellt.U :T c.sw NRC Befog implementeelen 1st OSR: Date: pient General uenneer 2nd Q$R: D,ete: neopenesw Enginese wiwAu c sTYRON ) [g d / ' k Reeponettes esenecer (Print Nemo. Biys, Dele) Plant General teenneer (Print Neme. Sign, Date) Pfecesure: Form EOR-MOGC 00061-3 DCMD1h2 12/10/96 9901070073 981221
- PDR FOIA PAYNE99-32 PDR 4ei o \ o '?oG ) 7 A. - - _ .
GS/20/8@94, G8:30 9104573014 .PAGE 03
>39 _ Cf Form 1 ENGINEERING SERVICE REQUEST son a mov a 78es 9700007 1 EQ Type JCO for improperty ConMputed Condu6t Seele Roguest Develop an 1;Q-ty;a JCO for the ASCO Tripoint Pressure switenes found witti tlie conduit seal located at the terminal -box and of the flex conduit, refer to CR 97-00508. The concern is that the "as installed" flex concuit non-metallic ma'erials may compromise the environmental sealing of the switches. This JC0 will consist of a comparision af the ASCO tested configuration to the HNP installed configuration, evaluaticn of the switches.during the BNP MELB environment, and an evaluation of the various materials used in flex conduit, ne.eense An EO-Type JC0 addressing the flex conduit and seal configuration for the ASCO Tripoint Pressure Switches requiring conduit seals is attached. It is concluded that there is a high level of confidence that the subject switches will perform their required safety functions following a HELB in the reactor building.
Minea the flaxible conduit is net environmentally qualified in accordance with 10CFR50.49, one of the following option must be taken to provice a fully rInalifiad installation: A. Modify the evieing inneallations such that a conduit seal (ODP-74 or QDP-75) is connected direcly to the pressure switch.
- 8. Perform envirennental qualification testing ot the existing Anaconda fiwx conduit ficx, including conduits with the jacket removed.
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01/28/1934 03:30 9104573024 }P5GE~04" ESR 97-00087
- PAGE 1, Rev.1 .
l LIST OFEFFECTIVE PAGES i-BEL PACE NO. 1 15 1
- Al-A3 1 B-1 1 C1 1 D1-D2 1 El 1 I F1 1 G191 1 H1 H3 1 11-17 1
! J-1 1 4 4 TABLE OF CONTENTS 1 SEC'IlON DE5fJt.IET10N PAGE LIST OF EFFECTIVE PAGES / TABLE OF CONTENTS . . . . . . . . . . . . . . . . 1 1.0 PROBLEM IDENTIFICAT10N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.0 ESR DESIGN SPECIFICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.1 ESR Functional Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.2 Design inputs . . . . . . . . . . . . . . . . ... ...................... 2 2.3 Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.5 Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . 5 3.0 DOCUMENT UPDATE FORM (DUF) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4.0 SELF ASSESSMENT RECORDS . . . . . . . . . . . . . . . . . . . . . . .... 15 A!TACHMENT A (Unit 1 & 2 EDBS List) . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 ATTACHMENT B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1 ATfACHMENT C (Ref. 2.4.27) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1 ATTACHMENT D (Figurcs 5.1 1 & 5.1-2, Ref. 2.4.8) . . . . . . . . . . . . . . . . . D-1 ATTACHMENT E (Photographs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1 ATTACHMENT F (Conduit walkdown data) . . . . . . . . . . . . . . . . . . . . . . . . . . F-1 ATTACHMENT G (System 1000 data) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . G 1 ATTACHMENT H (Ref. 2.4.25) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H-1 ATTACHMENTI(Ref 2.4.26) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 ATTACHMENT J (List of Contacts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J 1
- $NNFS PAGE 05 ~
ESR 97-00087 I PAGE 2. Rev. I 1.0 ProblemIdentincation During a walkdown of the ASCO Tri-Point pressure switches, denoted at EQ in EDBS (EQ pressure switches),it was determined that pressure switches 1-E21 PS-N008B, l-E21-PS-N0098,2-E21 PS N008B, and 2-E21 PS-N009B had been installa1 with i Anaconda liquidtight flex conduits between the switch and the conduit seal (see l Attachment E). Used in this manner the flex conduit becomes an extention of the conduit scal. De Anaconda liquidtight ficx conduit was not used in the qualibation of the ASCO switches (Ref. 2.4.10 and 2.4.11). The concem is that the as installed flex conduit ' non-metallic materials may compromise the environmental sealing of the switches. Condition Report 97-0050R, Ref. 2.4.1, was issued to document this problem. Moisture intrusion for equipment located in the Reactor Building is a concem following a High Energy Line Break outside of primary containment (there are no ASCO Pressure Switches in the Drywell that require environmental qualification, see Attachment A). Since the condition identified in CR 97-00508 has been verified to exist for all EQ ASCO pressure switches in the Reactor Building which require conduit neals, this JCO applies to all of the switches listed on Attachment A. - 2.0 ESR DESIGN SPECIFICATION 2.1 ESR Funedanal Requirannents This ESR is an "EQ" type Justification for Continued Operation (per POM Procedures Ref. 2.4.4, and 2.4.5), performed in response to CR 97-00508. His JCO will provide a reasonable level of assurance that the installed flex conduit will not prevent the ASCO Tri Point switches from performing, their required safety functions during the worst case HELB environmental conditions postulated at their installed location. 2.2 Design lapata ne design inputs used to suppon this ESR are listed as references under Section 2.4. l 2+3 MN l None i e
l ESR 97 00087 l PAGE 3, Rev.1 .
- 2.4 Rafaremmes l 2.4.1 Condition Report CR 97 00508. " Improperly Sealed EQ Press. Sw."
2.4.2 DBD 100, Rev. O, " Equipment Qualification" . 1 2.4.3 National Electrical Code,1993 Edition 2.4.4 POM Procedure OPLP-02, Rev. 4 " Program Document for Compliance with 10CFR50.49 (Envirunnmatal Qualification of Safety-Related Electrical Equipment)"
- 2.4.5 POM Procedure OENP 34.1, Rev. 4C " Design Control of Environmentally Qualified l Equipment"
! 4 2.4.6 Deleted" 2.4.7 QDP-77 Rev.1. ASCO Tri-Point Pressure Switches j 2.4.8 UEAC Report No. 9527-058-S-MS-001, Rev. 5, " Reactor Building Environmental Report" l 2.4.9 Deleted
- 2.4.10 ASCO Test Report No. AQR-101083/ Rev. I " Automatic Switch Co. (ASCO) Tri Point
! Pressure Switches for Safety-Related Non-Containment Applications in Nuclear Power Plants". DR-77.1 ! 2.4.11 ASCO test report No. AQR-51785/Rev.1," Report on Qualification of Automatic Switch l Company (ASCO) Tri-Point Pressure Switches to an Altemate Environmental Design i Basis Event Simulation" DR-77.2 2.4.12 Steam Tables, Combustion Engineering, Inc., Thirteenth printing, i 2.4.13 Specification forInstallation of the Electrical Raceway System, Specification 048-001, Rev.18 l 2.4.14 Plant Modification 84-175,"Repl HPCI Press Sw" 2.4.15 Plant Modification 84-182,'CS Pressure Switch E21-PS-N008B&9B" 2.4.16 Plant Modification 84183,"CS Pressure Switch E21-PS-N008B&9B" 2.4.17 Plant Modification 84-184,RCIC Pressure Switch R: placement"
G8 m v m 4 @):8G M4WMM PAGE 07
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ESR 97-00087 ! PAGE 4, Rev.1 J j 2.4.18 Plant Modification 84-185,"RHR Pressure Switch Replacement Loop A" i 2.4.19 Plant Modification 84-186. "RHR Pressure Switch Replacement Loop B" 2.4.20 Calculation 9527-058-6-VAR-51F, Rev.1, " Essential Equipment. Environmental Requirements for the Primary Containment and the Reactor Bldg." 2.4.21 Wyle Laboratories Test report No. 45307 1, dated 12/23/81, "Quali5 cation Test Report on InJhtaia-t Cables for CP&L", SHNPP EQDP 3.3C 2.4.22 Radiation Effects on Organic Materials in Nuclear Plants, NP.2129, Research Project 1707-3, Final Report, November 1981 2.4.23 Lang's Handbcok of Chemistry, Eighth edition 2.4.24 A Review of Equipment Aging Theory and Technology,NP-1558, Research Project 890- ! 1, Final Report, September 1980 2.4.25 Quality Classification Analysis, CNDT-002, Rev. 0,1,2, and 3. 2.4.26 Handbook of Thermoplastic Elastomers, Second Edition, Benjamin M. Walker and Charles P. Rader(excerpt) 2.4.27 Fax from ASCO to Richard Williams from Rich Maryskiel dated 2-6-97 2.4.28 QDP-74. Rev. 3. Patel Conduit Seals 2.4.29 QDP 75, Rev.1, Dow Coming 3110 Sealant
01/20/1994 03:10 9104573014 PAGE 08 ESR 97-00087 PAGE 5, Rev. I 2.5 Evaluation 2.5.1 Comparison of the ASCO tested connguration with the BNP instaBed configuration. ASCO Tri-Point switches with Electri flex Liquatite flex conduits providing a seal ber;.c a the switches and the pressure vessel electrical connections were subjected to HELB testing, references 2.4.10 and 2.4.11. ASCO states that the connections were dry connections (no sealant), Attachment C. There were no other environmental sealing devices used at either end of the flex conduit connection. The BNP installed configumtion uses A=mada Sealtite or possibly Electri-flex Liquatite flex conduit (See section 2.5.3 and Attachment F concerning the type of conduit). The flex conduit away from the switch is sealed with a qualified moisture anal. This forms a closed but not sealed enclosure dunng a HELB environment. This installed arrangement 1 is similar to the ASCO tested configuration. Liquatite and Sealtite are the manufacturers brand names for Electri ficx and Anaconda respectively. Both conduits are designated liquidtight as described by the National Electric Code Article 351 (Ref. 2.4.3). Requirements of NEC, Article 351 include:"an outer liquidtight, nonmetallic, sunlight-resistant jacket over an inner flexible metal core, with associated couplings..." Liquidtight conduits are not considered steam tight and they are not generally used as an environmental seal. However, in the ASCO HELB testing the conduit was used to prcycat moisture ingress into the Tri-point switch housing. Conclusion from the above evaluation is that the BNP installed configuration of the ASCO Tri-Point switches with the liquidtight flex conduits is the same as the original tested configuration, except for possible differences in nonmetallic materials used by Anaconda vs Electri-ficx, newfore if the Anaconda flex conduit non metallic materials are compatible with the BNP environmental service conditions, the Anaconda flex conduit should provide the same level of environmental protection against moisture intrusion as the Electri-flex conduit. 2.5.2 Evaluation of the ASCO Tri-Point switches during the BNP HELB profile.
'Ihe most severe HELB condition in the areas where the ASCO Tri-Point Pressure ,
Switches are located is the HPCI line break in the HPCI toom. The peak temperature and pressure in the HPCI roorn are 295'F and 1.6 psig , as shown in Figures 5.1-1 and 5.1-2 of the Reactor Building Environmental Report, Ref. 2.4.8 (see Anachment D). I
@RO$@414 PAGE 09 ESR 97-00087 PAGE 6, Rev.1 Pressure is the primary concem since it is the main driving force for transporting the moisture into the conduit, ne HPCI room pressure retums to normal following the HET.B in appmximately 60 seconds which is much less than th: 7.5 psig, seventy second duration pressure applied in the ASCO HELB environment test. Since the differential pressure between the Inside and outside of the ficxible conduit is small, approximately 1.6 psig, and lasts for a short period of time, approximately 60 seconds, no significant moisture intrusion is expected during this period. ASCO Tri-Foint switches are mounted in a vertical upright position De flex conduit connection to the switch is from above.
'Ihe conduit entrance is at the low point, the wiring goes up from the conduit entrance to the microswitch terminals, see Attachment E. Since the body of the switch and the inside rnetal core of the flex conduit are cooler than the outside HELB W=e any moisture leakage past the flex conduit would condense at the entrance to the switch. Assuming the jacketing material does not provide a moisture seal, the metal core of the flex conduit presents a tortuous path to any moisture intrusion. Therefore the short duration 1.6 psig pressure would not be able to drive any moisture up to the microswitch housing.
I ne rnaximum HELB ambient temperature for the switches of 295'F (Attachment D) is due to low pressure superheated steam. Since the switches and conduits are et normal ambient temperature (104'F) prior to the accident, th steam will condense on them. De maximum surface temperature of the condensed steam and therefore the conduit surface, l is determined by converting the 295'F.1.6 psig superheat temperature to an equivalent I saturated steam ternperature of 217'F by the use of the steam tables, reference 2.4.12. Due to the thermal man of the ASCO Tri-Point switch and the internal metal core of the associated flex conduit and couplings, the conduit jacket overall temperature will not increase significantly from an initial ambient temperature of 104*F du:ing the 60 seconds the steam temperature is at 295'F and the surface temperature is at 217'F. However, even peak temperatures of 286'F will not adversly affect the ability of the flex materiac perform their intended function as shown by the material evaluations in Section 2.5.3 of this ESR. After 60 seconds the pressure returns to O psig and the air temperature decreases rapidly to 250'F in 2 minutes and to 215 *F in the next 5 minutes. Therefore, it is expected that this short duration temperature increase will not result in damaging the ' flex conduit jacketing or result in any appreciable moisture intrusion into the switch housing.
t43T2Wrpfgf~~wR st4 71WO/)Jt4TB P/4lE 10 ESR 97-00087 c PAGE 7. Rev.1 l 2.5J Fles Condelt Non Metallic Jacketing Materials Evaluations. Reed on reviews of the current and past revisions (Revision 6 dated 02/13/76 through Revision 19 dated 01/31/97) of BNP Specification No. 048-001 the only flex conduit allowed for used in reactor building applications has been "Sealtite" or"Liquatite". In two (2) of the past revisions the "Liquatite" flex was specified as " Liquid-Tight", this is judged to be a typographical error, since in some instances the Electri-Flex catalog defines their "Liquatite" flex as " Liquid-Tight" All EQ precure switches were installed l in the 1984 time frame, based on reviews on the following pressure switch installation modifications and the EQ Maintanance Data Base: l 84 175 84-182 84-183 84-184 84-185 84 186 Per discussions with document services specification revisions pdor to 1976 are not maintained on file here at BNP. These records would have to be obtained from United l Engineers. Since the specification revisions, as of 1976, required the use of"Sealtite" or l "Liquatite" and the pressure switches were installed sometune nAer January 1984 it is reasonable to annume that all flex conduit is in fact "Sealtite" or "Liquatite". Additionally, based on the consistent requirements in the specifications, as far back as ! 1976, it in reasonable to believe all flex conduit used during installation of the EO l pressure switches is "Sealtite" or "Liquatite. The manufacturers of these types of Jacketed flex uv Anaconda and Electri-flex, respectively. Further assurance is obtained, since the BNP Supply Inventory System (SIS) does not show any otherjacketed flex conduit as ever being procurred. During the walkdown of all flex conduit associated with the subject pressure switches, it was noticed that some of the BNP installed flex has been painted with a black oil based paint. Therefore, it was not possible to identify all the different 1%Das of"Sealtite" or "Liquatite" currently installed (i.e., E.F., U.A., O.R., Z.H.C., L.A., LOR, etc.) It should be noted that the BNP Supply Inventory System (SIS) indicates that only two (2) types of "Sealtite" or "Liquatite" have ever been stocked at BNP (i.e. "E.F." and "U.A."), which would verify the non metallic jacketing material is either Polyvinly Chloride or Thermoplastic. However, for conservatism all different types of Anaconda "Sealtite" and Electri-Flex "Liquatite" will be included in this JCO Materials Evaluation. Evaluating cach different type will provide assurance that jacketing materials are acceptable for the BNP environmental conditions. It was verified during the walkdown that all associated flex isjacketed with a non-metallic sheath. Extensive research has been p4vis.4, including discussions with Anaconda and Electri flex; review of vendor catalogs; and l ' discussions with utilities and testing laboratories,in order to identify flex materials and i environraental testing data. Information obtaincd from industry wurces was used to provide additional assurance conceming non-metallic jacket materials types and their
- acceptability when used in the BNP specific environments (See Attachment J).
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es/2871994 03:10~ ~ie'573ei4 ~~ f d 13 ESR 97 00087 PAGE 8. Rev.1 j l Based on the results of tids research it has been determined that the following non- I metallic materials could potentially have been used by Anaconda and Electri-flex during i the manufactudng of the different types of"Sealtite" or "Liquatite" jacketed flex conduit: Anaconda (Sealtita) Flectri.Fler (Ummtitel Polyvinyl Chloride (PVC) Nylon l Polyolefin (Zem Halogen Cover) Polyvinyl Chloride fPVC) j Chlorin =W Polyethylene Polyolefin (Zero Halogen Cover) l Thermoplastic Rubber (ELEXAR) Thermoplastic Rubber (SANTOPRENE) Polyethylene / Ethyl Acrylate ne postulated BNP environmental conditions are =n===rized below: (Reference BNP Calculation 9527-058-6-VAR-SI-F)(2.4.20) Normal Service Temperature: 104'F Peak DBA Temperature / Pressure: 217'F (Max. Sat. Temp.) . - ! Normal Radiation: 1.0E3 Rads DBA Radiation: 1.0E7 Rad = 1.0E7 Rads (TID) The following discussion will evaluate the above listed materials in order to detsanine their acceptability when used in the BNP speci6c application. Polyvlayl Chloride (PVC): Normal Temrwrature (104'F1 The Digital System 1000 Database (Materials Radiation / Aging Database) was used to calculate the expected life of PVC. De results of these calculations indicate that at BNP specific normal temperatures (i.e.,104'F) the PVC meteeint life is greater than 40 years for all formulations, as calculated t. sing Arrhenius methodology, ne longest operating time for either BNP unit is approaching 23 years. Le calculated life, which greatly exceeds 40 years provides reasonable usurunce this material will perform its intended safety function (i.e. maintain a moisture barrier, in the event of a HELB). DBA Temnerature 017'Fh The worsth peak HELB tempe'mture, based on the saturation temperature (217*F) defined above, has been enveloped by quali$ cation testing of PVC by Wyle Laboratories (Report No. 45307-1, dated 12/23/81," Qualification Test Report on In-Containment Cables foe CPAL",
Reference:
SHNPP EQDP 3.3C) indicates the subject material maintained its integrity subsequent to:
r t4372W7TWr$-~WJR@ FN65Y3LW 4 PAGE 12 4 ESR 97-00087 PAGE 9. Rev.1
'Ihermal Aging @ 212T for 382 Hours Peak LOCA Simulation @ 2867 for 3 Hours Subsequent Temperature Soaks at 2197 for 21 Hours & 1527 for 29 Days Therefore, it isjudged that DBA temperatures postulated to occur at BNP (217'F) will l
not adversely affect the ability of flex to provide a moisture barrier. Normal / DBA Radiatlan (10F7 Radah PVC materials undergo sission or cross linking, dermiing on t+ sare and oxidizing conditions. Actual tesdng on a 4 mil sampic of PVC has shown that PVC lost only 20% l of original tensile strength after 7.0E6 Rads and still maintained 50% ofits tensile l strength aAer 1.0E8 Rads. Test results on a 20 mil sample indice'.e that the PVC material lost only 20% of the original tensile strength at 1.0ER Rads and 7.0E7 Rads was required to change the elongation of the 20 mil sample by 20% (Ref. EPRI NP-2129, dated 11/81, page 310). Based on the specific BNP application of this PVC material (i.e., mechanical / static application) a 20% loss in the original material property would not result in the inability of the material to perform its intended safety function (i.e., maintain a moisture barrier). Therefom, the PVC matenal is judged to be capable of maintaining its safety function when used in this application. 4 4 I
4 ESR 97-00087 PAGE 10, Rev.1 Polyolena (Zero Halogen Cable): Nonnal Temnerature (104Th . The Digital System 1000 Database (Materials Radiation Aging Database) was used to calculate the expected life of polyolefin. The results of these calculations indicate that at the BNP worst case normal temperature the subject material life is greater than 40 years, as calculated using Arrhenius methodology. the calculated life, which greatly exceeds 40 years pmvides reasonable assurance this material will perform its i* Mad safety function (i.e. maintain a moisture barrier, in the event of a HELB). DBA Tm- ._ rare (217T) / Preneure (1.6 naleh he Digital System 1000 Database indicated the polyolefin materials are acceptable for continuous used at temperatures ranging fmm 2577 through 302*F. BNP's worst-case peak is 2177 for 60 seconds; therefore, the polyolefin material is judged to be capable of withstanding peak temperature conditions. Normal / DRA R=Aiation (1.0E7 Radeh EPRI NP-2129, dated 11/91 indicates that Polyolefins are aliphatic alkene polymers (i.e., ethylene, propylene, isobutylene). Additionally, EPRI hT 2129, dated 11/91, indicates that ethylene materials reach a threshold at 3.0E5 Rads. However, this threshold value does not indicate damage, but rather, an improvement of original properties. Additionally, EPRI NP-2129 states that at 4.4E7 Rads the ethylene materials lost only 33% of the original tensile strength. The EPRI NP-2129 recommended service limit is 1.0E8 Rads for the ethylene materials. The damage timeshold of propylene matetials is 1.0E7 Rads, per EPRI NP-2129. The isobutylene materials have radiation thresholds of approximately 1.0E7 Rads, which tensile strength increases above the threshold, but decreases after about 2.0E8 Rads. Herefore, based on the BNP specific application of this polyolefin material (i.e., mechanical / wtatic application) and the discussion presented above. the material is judged to be capable of maintaining its safety function.
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Oi/28/5994 03:10 9i04573054 PAGE 14 ESR 97 00087 PAGE I1, Rev.1 Chlorinated Polythylene: Normal Tauw (104'Fh The Digital System 1000 Database (Material Radiation / Aging Database) was used to calculated the expected life of chlorinated polyethylene. The results ofthese calculations indicated that at BNP speci6c normal temperatures the material life is greater than 40 years. De calculated life, which greatly exceeds 40 years provides reasonable assurance I this material will perform its intended safety ftmetion (i.e. maintain a moisture barrier, in the event of a HELB). l t nR A Temrwenture (212"Eh The subject material has successfully withstood thermal aging at a temperature of 325'F i (
Reference:
Arrhenius Library Code 022-83B, Digital System 1000). Therefore, this material is judged to be capable of performing its intended safety function in the BNP, DBA environment (i.e., maintain a moisture seal). Normal / DBA R=Atation (1.0E7 RmA* This material ha a radiation threshold of 1.9E7 Rads (
Reference:
Library Code 261-83 A, Digital System 1000). Therefore, the material is judged to be capable of maintaining its safety functions,the BNP worst-case radiation environment. Anaconda Thermoplastic Rubber (ELEXAR): This specific material we identifled in the Digital System 1000 Database as " polyolefin". Therefore, for a discussion concerning the abilities of this material see " polyolefin" discussed above. Polyethylece / Ethyl acrylate: Keview of"Langs Handbook of Chemistry, Table 10.3" the maximum use temperature of polyethylene is 160*C, while the maxirnum use temperature of Ethyl Acrylate is 121'C. Therefore, for the purpose of this discussion the weak link material will be Ethyl Acrylats, and verification of the ability of this material to function in the BNP environment will also envelop the polyethylene material. It should be noted, that the polyethylene material has been evaluated above as one of the polyolefin materials and was shown to be acceptable when used in BNP postulated environmental conditions. Ethyl acrylate was not found in the Digital System 1000 Database. However, review of published data (i.e., Merck Index, 8th Edition, printed time 1975) verified, based on boiling points that the ethyl groups (2 carbon atoms) physical properties exceed methyl group (1 carbon atom) physical properties. Therefore, acceptability of Methyl acrylate as s a flex jacket material will envelope Ethyl acrylate as a flex jacket material.
su cEaWJ~WWEC4 CECM S M fik PAGE 15 1 ESR 97-00087 PAGE 12, Rev.1 I Normal Temnerature (104% The Digital System 1000 Database was used to calculate the expected life of Methyl acrylate. The results of these calculations indicate that at BNP specific normal temperatures, this material life is gmater than 40 years, as calculated using Arrhenius methodology. The calculated life, which greatly exceeds 40 years provides reasonable assurance thle material will perform its intended safety function (i.e. maintain a moisture barrier,in the event of a HELB). DBA Tw.n. :. m (217%
'Ibe Digital System 1000 Database indicates this material is acceptable at a continuous temperature of 300*F. Thettfore, this material is judged to be capable of performing its intended safety function in the BNP DBA envimnment.
Nnamal / DBA Radi=Han (1 OR7 R=A=h ' lhis material has a radiation threshold of 2.0E7 Rads (
Reference:
Library Code 069 83C,
, { Digital System 1000). 'Iherefore, this material is judged to be capable of maintaining its safety functions in the BNP worst case radiation environment.
Nylon (Polynsmide): Normal T===+n.e (10d%- The Digital System 1000 Database was used to calculate the expected life of nylon. The results of these calculations indicate that at BNP specific nonna! temperature the material life is greater than 40 years, based on the Arrhenius Methodology. The calculated life, which greatly exceeds 40 years provides reasonable assumace this material will perform its intended safety fbaction (i.e. maintain a moinure banier, in the event of a HELB). DBA Temner=rure (217P: Actual test data verified the nylon material was acceptable subsequent to thermal aging at 296'F (
Reference:
Library Code 039 83E, Digital System 1000). Therefore, this matenal is judged to be capable of performing its intended safety function in the BNP DBA environment. Normal / BRA RaAladnei (1.OE7 R adeh Based on review of EPPJ NP-1558, Page 7-41; nylon has limited use after exposure to 1.0E7 Rads. However, nylon fiben showed little change in tensile strength and 1.5 times original elongation after 1.7E7 Rads when irradiated in air. Therefore, based on the static application of this material, it is judged that nylon flex jacket material will cor.tinue to maintain a moish:re harrier after exposure to the worst-case BNP adiation environment.
01/20/1994 03:10 9104573014 ' PAGE 16 4 ESR 97-00087 PAGE 13, Rev.1 Electr6 Flex Thermoplastic Rubber (SANTOPRENE): Discussions with Electri-Flex indicated the specific thermoplastic rubber used is rnanufactured by Monsanto. Discussions with Monsanto indicated the material defined as SANTOPRENE is EPDM rubber and Polypropylene plastic. ne following evaluation willjustify the ability of SANTOPRLHE to withstand BNP postulated environmental conditions. m.m.iT - -.n04*m. De Digital System 1000 Database (Materials Radiation / Aging Database) was used to calculate the expected lives of EPDM and Polypropylene. & cxpected lives of all EPDM / Polypropylene materials greatly exceeded 40 years (Ref. At" meat I) with the exception of one (1) EPDM material (i.e. Nordel 1700) and one (1) Polypropylene material (i.e. Profax 6523). Discussions with the material manufacturer (Monsanto Chemical Corp., Dr. Charles P. Rader, phone 216 849-5180) verified the specific composition of SANTOPRENE was superior to the Nordel 1700 and Profax 6523 compositions that have expected lives of less than 40 years. The manufacturer stated that SANTOPRENE is acceptable for use in a continuous 194 *F environment. Therefore, based on the expected life calculations and discussions with the material manufacturer, this material is judged to be uuwptable for the BNP normal temperature environment for the entire 40 year life of the plant. DBA Temnernmee d17'Fh The EPDM materials identified in the Digital System 1000 Database have been thermally aged at temperatures ranging from 194"F to 347'F without failure. The Polypropylene materials are rated for continuous use at temperatures ranging from 149'F to 248'F. De Polypropylene material compositions rated for continuous use at 149'F were thermally aged at 31l'F without failun. The material manufacturcr (Monsanto) indicated the SANTOPRENE material, potentially used at BNP is acceptable for use at temperatures of 275'F for several hours, nerefore, based on the Digital System 1000 and discussions with the material manufacturer, this material is judSed to be acceptable for the BNP DBA temperature conditions. Normal /nR A Radiation (1 OE7 radh Elongation of EPDM was not significantly changed after 5.0E6 rads, but was reduced to 48% of the initial value after 5.0E7 rads and 37% aAer 1.0E8 rade. Also, additional I; @ 1esdag indicated EPDM retained 79% of the original tensile strength after 1.0E8 rads (Ref. EPRI NP-2129, dated 11/81, page 3-24). 7M ed EPRI NP-1558, dated 9/80, page 7-41, indicates polypropylene is often satisfactory for l use aher exposure to 1.0E7 rads. g bD f7. Y ,bwtx., u g- , ist"
01/28/1994 03:10 9104573014 PFE 17 ESR 97-00087 PAGE 14, Rev.1 Therefore, based on the mechanical / static application of the subject flex, losses in material properties as stated above will not prevent the matcrial from perfonning it intended safety fbaction (i.e. moisture barrier). Mex Conduit End Connectors: Review of Quality Classification Analysis (CNDT-002, Rev's 0,1,2,3) in addition to the Supply Inventory System (SIS), provided reasonable assurance that all flex conduit end connectors, used on the subject flex conduits are procwed from Thomas & Betts (Ref. Attachment H). Discussions with homas & Betts (phone 1 800-786-23RR, ext. 3671, Kim) verified, based on teview of applicable connector design drawings, that the non. metallic connector materials ar- the sealing ring and the insulator. De Thoma A Betts design drawings require thest aon metallic materials to be Nylon (Polyamide). This Polyamide material has been discussed above, and was determined to be acceptable for the BNP postulated environments. CONCLUSION The above evaluation is based on the worst-case environmental conditions of the subject pnnmure switches. The temperature and pressure transients in other areas when the ASCO Tri-Point Pressure Switches are located are less severe than the HPCI room conditions described above. Therefore, there is a high level of confidence that the configustion identified in CR 97 0050A would prevent any significant amount of moisture intrusion into the pressure switch assemblies following the HELB events for which the pressure switches are requimi to function. THE ABOVE RFEFARCH PROVIDES A HICH f FVFt OF CONFIDENCE THAT Tstr DEVICFE 1 IETrn IN ATTACHMENT A WOUI.D PERFORMJHE REOUIRFn SAFETY FUNCTIONS FOI LOWING A HFI R IN THE REACTOR 31TILDING. Since the flexible conduit is not environmentally qualified in accordance with 10CFR50.49, one of the following option must be taken to provide a fully qualified installation: A Modify the existing installations such that a conduit seal (QDP 74 or QDP-75) is connected directly to the pressure switch. B. Perform environmental qualification testing of the existing Anaconda flex conduit flex, including conduits with the jacket removed. These actions will be tracked using CR 97 00508.
y . - . - . - . ...-. . ,o l , ESR 97-00087 PAGE 15, Rev.1 l 3.0 DOCUMENT UPD ATE FORM (DUF) h are no plant documents (e.g. POM, drawings, calculations, etc) requiring update as l a result of this ESR. 4.0 SELF ASSESSMENT RECORDS i l None. \ t l 1 l l I
Environmental Qualification Issues
~
i l e Task Force Structure sTechnical lasues , 6
+ Reporting Relationships + PASS System
+ In-House Resources + Associated Circuits
+ External Expertise + Thread Sealants e Plan and Schedule + MCC's
+ Short term o Programmatic issues
+ Long Term + QDP's Requiring Review
+1ncorporate Documentation References
+ Reactor Building Environmental Report
+ Re-verification of the EQ Master--
Equipment List gCP&L x
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'****d PRESTICE l- Tim 3 Nie : 28Jun96 001 Pr:Jtct s ENVIRONMENT GUALIFICATION RES0 '
Fsesezet End: 30sep96 17: 10 a.gi it, o,n, e i . LUTION AND UPGRADE TASKFDRCE 30 c,iting ,,,, a l Ytestant 00 WleresoFL Project:16Ju!96 Required End: o g, g y,,,,, , Terests: Showins Forecent Detes (Ju!96 lAug Sep 130 l07 lt4 124 128 104 lit lie 125 Of 108 115 l22 l 11 Perform review 6 evaluation or 25 ODPs/I 0$Jul96 0 r:00 - : 30Sep96 17:00 45-R10 100-Ril 354-R3 380-R5 56-R6 >> 12 Pursue resolution or EG-related condit!r 23Ju!96 a6:00I i l 13 Provide support to 24-Month Cycle end Po i 22Jul96 07:00 EE5 25Jul96 17:00 l- 40-R3 [ 14 Perform review or outstonding EO-related 9Jul96- 16:00 C:323Ju!96 16:00. 20-Rl0 20-R2 20-R9 17 Determine BNP Licensing' Bests 6 Commitme
' =09Jul96 12:00 l 120-R15 40-R3 i
- 29 CR Review I)Jul96 12.00: 1 30Sep96 17:00 235-R10 120-Ril 50-R17 100-R5 40-R6 >>
3 Re-esteb!!sh the correct EQ Environmente ! 2BJun96 07:00 -
'10Jul96 17:00 t 80-R3 4 Re-Ver!Fv BNP ED Master Equipment List 2BJun96'07:00 - :23Sep96 08:00 360-R10 324-R13 150-Rl9 40-R3 576-R4 >>
6 Perform detailed evolustion or EQ proced 02Sep96 07:00i '26 Sep96 12:00 l 20-R10 40-Ril 80-It3 60-R4 40-R6 20-R7 >> l 7Est ab!!sh technical position and procedu 23Sep96 08:00: : 30Sep96 17:00 50-R1 8 16-R3 , 8 Review or UFSAR For EQ and HELB l 12Sep96 12:00: ' 30Sep96 17:00 24-R3 36-R5 9 Review Associated Circuits issue . 2BJun96 07:00 ' '30Jul96 16:00 l 40-R10 40-Ril 100 RIB 40-R4 40-R6 40-R7 I [ 4 f 130 107 184 126 128 l04 Ill lie 125 01 108 115 122 l lJu!96 lAug Sep i
ENVIRONMENTAL QUALIFICATION (EQ) ISSUE RESOLUTION AND UPGRADE TASK FORCE ACTION PLAN i l
- I rios l ales l s, s l
ID Task Name Duration Start Finish Team Membe Work 6/16 l 6/30 l 7/14 l 7/28- l 8/11 l 8/25 l IWB l 9/22 1 Long Term Action Plan 132.4d 6/21/96 3/31/97 5554h 2 Revise Environmental Qualification DBD 69.6d 9/2/96 12/31M KJi 120h i 3 Determine if a HELB/MELB Topical DBD exist 162.4d 6/21/96 3/31/97 240h 4 Perfonn review of selected Vendor Technical 30d 10/7/96 11/27/96 300h manuals , 6 Continue reviews of a5 QDPs 128.8d 6/21/96 1/31/97 KJi/RTB/ET/A 1288h j
. . e j
~ '
t implement sRe-wlde EQ training 129.6d 6/21/96 2/2/97 1296h , f 7 Perform selected review of EQ-related 69.6d 9/2/96 12/31/96 100h f maintenance work orders l ,i j [ s Evaluate various operating versus 76d 6/21/96 10/31/96 KJi 40h [ t l l r
. i i
l r i I t 1 b Task Summary Roled Up Progress m Project. Progress M RoHed Up Task i Date: 7/24/96 L Milestone $ Roged Up Milestone h Page 1 l I i l
ENVIRONMENTAL QUALIFICATION (EQ) ISSUE RESOLUTION AND UPGRADE TASK FORCE ACTION PLAN woe l Ins las wr mr ur I I I l 4mr I ser er i mr 10/6 l 10/20 l 11/3 l 11/17 12/1 l 12/15 l 12/29 l 1/12 l 1/26 l 2/9 l - Of23 l 3/9 l 3/23 l 4/6 l 4/20 l S/4 l S/18 6/1 l 6/15 l 6/29 l 7/13 RESO1 RESO1 I RESO1 RESO1 1
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RESO1 RES01 RESO1 Task Summary RosedUpProgress m at M Progress m Rotied Up Task Milestone $ RoHed Up Maestone Q Page 2
Environmental Parameter Re-Construction i e Only Major Issue is We Are Lacking A Total BETA Dose
+ Still Searching
+ Power Uprate Study Does Not Provide This Data Either
+ Power Uprate Project is Aware
. Conference Call Scheduled l t
i t i [ CP&L i r
Thread Sealant URI
-a e QDP Complete Today e Maintenance Procedures Scheduled August 8
+ This Will Close-Out URI CP&L
Licensing Basis & Commitments i i e Research Complete e Investigating R.G.1.97 commitment
+ Pass System Over Committed l 6
t I CP&L
1 QDP Review f l t . e 110 Total QDP's . o 25 Which Had Never Been Reviewed Are Now 4 Reviewed
+ No Significant Problems At This Time i
+ No Hardware issues At This Time CP&L
- Master List Reverification e U1 Database Created t e U2 Database Completing Today i
e item By item Review Begins Tomorrow r i i i CP&L .
E.Q. Procedures i I i i i e in Review .
?
I e Will Adopt Harris / Robinson Procedures ;
+ EDBS Procedure in Review To Tighten-Up Control Of E.Q.
Program ! 1 t t i l t 4 CP&L
Associated Circuits e Similar Devices Have Been Qualified Elsewhere e We Are Pursuing Qualification Testing Of Breakers AT E&E Center t i CP&L 1
e Pass Technical issues e Overcommitted To R.G.1.97
+ Must Be Seismic
+ Must Be E.Q.
+ Support Systems Also
. RBCCW is Main Concern
~~ '
e Reg Affairs is Writing Letter To Change ' Commitment e JCO is Being Formulated CP&L
l-FAX TRANSMITTAL - ONE PAGE ONLY TO: P FROM: U<-
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(301) 415-l- OE UNDERSTANDING AND EA REQUEST FORM rr. Conf.reng.: <r Post Conference: _ EATS Date Entry Information l Date of Request: Region: CaseType: b Reg.
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Lacensee: 4 45W # IM tb8 Facility (Unit)/Locetton: b**' Docket No. bY M Last Day of Insp.: 3 Date of O! Ref. I E O! Rpt No. O! Apt Date! Conference Open ?: l Sumery of Tacts: E * * $ 6 4 6 4141/ L- 6O t SCu6,5 4
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3- Enforcement Conference Needed? O No Yes Corrnent s : N . . e Discretaon or Order Needed? Q No Y Yes F WGr$ && f"4.r b Coment s : A _ . . gy -- - a f wh M g gv Action? D Submit to CE D Regicnsi Action c Choace Letter D DEDO Review 0 Coma s s a on C Dasagreement C Other.
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- 5. Conferenes Reeded? D No Yes E.rplain:
- 6. CF7 O Bo CF 0 Base CF D couble Base CP i Other: 0 4v1244-4** b( v'" .l- 14 W J /1 J
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- 7. oiscretion or Order Reeded? O Yes Esplain: k (t db [M e #F7 8 W111 fulness involved? O Wo O Yes O 01 Coordinated: O Beeds 01 Coordination
- 9. Progran Office Represented? O Bo MYes: 10. 00C Represented?
- 11. Action? O Bo violation O Re panel YConference Letter a Choice Letter O SL 17 NOV O Re-Caucus O Region Issues Esc. Action
- O Sutumit to OE for QalcA Review Q Sukumit to OE for full Fockage Rgview Q DEDO Review 0 Consmission Disagre t Other: IM 4- C#4A. M h h f"O c.ur w a ~7 O ! Q(,
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~ " Co enta: Mtut N N erw.ud/w/'Av M N&M 1s ? App o,od: %M A~- ""m wuS La # as ' " m _. ..-. 9/t3/96, **** NOT FOR PUBLIC DISCLOSURE WITHOUT APPROVAL OF THE-DIRECT i NUREG/BR-0195 C-7 Rev. 6/96 FAX TRANSMITTAL - ONE PAGE ONLY- . . . i TO: bas O FROM: 47 ark SWom s (k/) sis :;2.fC EA REQUEST & ENFORCEMENT STRATEGY FORM an.t: , R..Panet: Post Caucus- / t Re-Caucus: _ . _ _ EATS Data Entry Informatico EA % -3 54 Date of Request: IO !7.N % Region:I Case Type: b Reg. Contact Nd Y[_ Licensee: 0 b % L- Facility (Unit MLocation: SRU/JSw / c K Dock et No. : 60-37 5 [sM r.-t Der of Ins,. F /v'J/96 rD Date: 8/za /% Date of O! Ref.: A/A CI Rpt No. A)4 OI Ept Date: Conference Open 7: OW h A.4/J1, k ct M 'c8 m (dkau Oz M L"MJ ~ dol w asa b u DG .% ula , or nL Es: /h s SL Supp f . Det.a ts : L && . Y w L/Y.t * . 02 &b w/2D &', r o c ee so .<A uV ' u r () Supp f , L ... skis: ,[r 13A W ? :=A '& ~ .w ce & w 4'm- 4 ' & s/ zh da bO ,rurf g 1 te . OL. o e Sz-- E F A .-.- S1 Supp , Ditsil M 7 A [A/ M 7 n xAs 'L ML M M dut ese<dL, d>A O O ad/n S cruf CM & L/ cGe I dM & /Li' w Sl4
- 2. Prior Escalated Action? O o EA: b[# */ [ Date: '7 / /~2 -[ T G .
,3, Lic.1D [No Yes O c. Credit O No Credit 0 Inad. Info O MA T.rplein : k C- J. & h1 I VIOM2 U 4 Corrective Action? KLic. Credit u No Credit D Inad. Inic Explain: /.h b ,, S. Conference Needed? O Mo yYes Explain: ID ['1A gQpod _ . . ,6. CP? O No CP yBaseCP D Double Base CP O Other: h OOb ' [84- h 2- O Cod i ret. ion or Order Needed? 0 No %Yes Explain M 4 RML7 M U M % o&v fo 7 p/d
- 8. W111tv.iness involved? yNo O Yes a OI Coordinated: a Meeds .01 Coordinataon
- 9. Progrann Office Represented? D No Yes: OS.brNM Ib 10. DOC Represented? O No
{Yes
- 11. Action? Q Ne violation D Re panel O Conference Letter O Choice Letter Re-Caucus o Region Issues Esc. Action 0 Sulunit t.o OE for Quick Review 0 Sutemit to OE for Full Package Review DED6 Review 0 Comenission C Dasagreement
} Q Other: / Comments: OI M M' b 13. Approved-() ~ ' I l Tmhl AMnsur i Date: In f 4%-{4[ < \ ' ~i / l .yJ .o_* * *- NOT. . E0 &-d8 TIC-DISCLO$URE WITHOUT M OVAL OF THE T liECTO 4 4 7 4 mi_-.4 p .p ,4__3,a .et -,6ajA.*+"s-a,,_A %4& A 46 Ai 4_ %.A.4a a isA..J4,=._16 ,%,._m.. 4,.d.J__A. 4 & Aa fas ,.m_.m O e * % 354 ef/g 1 4 - A-Y D A /~ d. , 1 { ~ ' ~ ~ ^ ~~ \ & . A) q g _ J. I h ~ t t ! as r / , . _ - - . . . _ - . . - - - =~ -- - I* CP&L Corolino Power & Light Company PO Box 10429-William it. Campbell ' Southport NC 28461 0429 Vice President Brunswick Nuclear Plant December 19,1996 I-SERIAL: BSEP 96-00476 i 10 CFR 2.201 James Lieberman Director, Office of Enforcement U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 BRUNSWlCK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-71 AND DPR-62 REPLY TO NOTICE OF VIOLATION Gentlemen: On November 19,1996, the Nuclear Regulatory Commission (NRC) issued a Notice of Violation for the Brunswick Steam Electric Plant, Units 1 and 2. The basis for the violation is provided in NRC inspection Report 50-325/96-14 and 50-324/96-14. Carolina Power & Light Company admits the violations occurred as described in NRC inspection Report 50-325/96-14 and 50-324/96-14. Enclosure 1 provides Carolina Power & Light Company's response to the violations in accordance with the provisions of 10 CFR 2.201. Carolina Power & Light Company finds the inspection does not contain information of a proprietary nature. Please refer any questions regarding this submittal to Mr. M. A. Turkal at (910) 457-3066. Sincerely, !$d 4 William R. Campbell JFMijfm - Enclosures
- 1. Reply to Notice of Violations
- - 2. List of Commitments Tel 910 457 2496 Fox 910 457 2803
- Tho7vi6A jypje ~' ~~ ' ~ ~ ~ ~ ^ ~ ~ ~ ^ BSE# 96-0476 / Pag) 2 ,. Mr. J:mes Li: berm:n
- c. -
cc: Mr. S. D. Ebneter, Regional Administrator, Region 11 ~ Mr. D. C. Trimble, Jr., NRR Project Manager- Brunswick Units 1 and 2 Mr. C. A. Patterson, Brunswick NRC Senior Resident inspector - The Honorable H. Wells, Chairman - North Carolina Utilities Commission Document Control Desk, U.S. Nuclear Regulatory Commission t s . l e i - - . . ~- . - . .- - . . . . . - . . . . - . ENCLOSURE 1 [- BRUNSWICK STEAM ELECTRIC PLANT, UNITG 1 and 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATIONS VIOLATIONS: During an NRC inspection conducted between June 24,1996 and September 17,1996, two violations of NRC requirements were identified. In accordance with the " General Statement of
- Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the NRC proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U. S. C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
Violation A: 10 CFR 50.49 (d) requires, in part, the licensee to prepare a list of electric equipment important l to safety covered by 10 CFR 50.49 (b), and include information conceming performance specifications, electrical characteristics and environmental conditions for this electric equipment in a qualification file; and, keep the list and information in the file current and retain the file in auditable form for the entire period during which the covered item is installed in the plant or is stored for future use, 10 CFR 50.49 (f) requires, in part, that each item of electric equipment important to safety be ! qualified by testing of, or experience with, identical or similar equipment, and that such qualification shallinclude a supporting analysis to show that the equipment to be qualified is i acceptable. ! 10 CFR 50.49 (j) requires, in part, a record of the qualification in auditable form to permit l verification that each item is qualified and meets its specified performance requirements under predicted environmental conditions. i ! I 10 CFR 50.49 (k) states that electnc equipment important to safety which was previously I required to be qualified in accordance with NRC's " Guidelines for Evaluating Environmental
- Qualification of Class 1E Electrical Equipment in Operating Reactors." November 1979 (Division of Operating Reactors (DOR) Guidelines), need not be requalified to 10 CFR 50.49. However, DOR Guidelines require that the radiation service condition include the sum of the gamma and
. beta doses unless it can be shown by assuming a conservative unshielded surface beta dose of l 2.0 X 10E8 RADS and considering shielding factors, that the beta dose to radiation sensitive l equipment internals would be less than or equal to 10 percent of the total gamma dose to which an item of equipment has been qualified. The DOR Guidelines further require that qualification records be complete and auditable for qualification to be considered valid. ! 1 of 9 I l I l Contr:ry to ths cbova, as of Juna 14,1996, environm:ntal qualification requirsmsnts wsra not mnt, es cvidsncsd by the following examples: .
- 1. The licensee failed to: (1) include the R.G. Laurence solenoid valves in the post-accident sampling system (PASS) and residual heat removal system of Units 1 and 2, identified by p! ant tag numbers 1(2)-RXS-SV-4180,4181,4193,4194, and 1(2)-E11-SV F079A, F0798, F080A, and F0808 on the list of electric equipment important to safety required to be qualified under 10 CFR 50.49, (2) test or demonstrate that the subject Laurence solenoid valves were identical or similar to an appropriately tested configuration, and (3) document the qualification of the subject Laurence solenoid valves in the auditable form.
- 2. The license.e failed to: (1) include the Target Rock solenoid valves in the PASS of Units 1 and 2, identified by plant tag numbers 1(2)-RXS-SV-4182,4183,4184,4185 and 4192, on the list of electric equipment important to safety requ; red to be qualified under 10 CFR 50.49, (2) provide an analysis demonstrating that the subject Target Rock solenoid valves were acceptable, and (3) document the qualification of the subject Target Rock solenoid valves in the auditable form.
- 3. The licensee failed to: (1) include Target Rock open and close limit switches for PASS Valves 1(2)-RXS-SV-4182,4183,4184, and 4185, on the list of electric equipment important to safety required to be qualified under 10 CFR 50.49, (2) provide an analysis demonstrating that the subject Target Rock solenoid valves were acceptable, and (3) document the qualification of the subject Target Rock solenoid valves in the auditable form.
- 4. The licensee failed to maintain the Environmental Qualification (EQ) equipment list and 50 files current and in an auditable form, in that: (1) the EQ equipment list was not being maintained current as demonstrated by hundreds of items identified on the list as environmentally qualified without a reference to a qualification data package (QDP), the document utilized to establish environmental qualification; (2) several QDPs had been in revision for over two years; (3) several QDPs had never been issued; (4) Enertech/Herion solenoid valve 2-B32-SV F019 was installed and declared operational without a QDP being issued and placed in the EQ File: (5) the QDPs did not include the latest Reactor Building environmental profiles which are required to establish predicted environmental conditions; (6) Hydrogen Water Chemistry modifications changed the radiation profiles and they had not been addressed in the EQ files; and (7) Beta radiation effects were not addressed in the EQ files.
- 5. The licensee failed to provide documentation in the auditable form to verify qualification of the safety-related Motor Control Centers 1(2)XA,1(2)XB,1(2)XC,1(2)XD,1(2)XE, 1(2)XF,1(2)XH,1(2)XM,1(2)XA-2,1(2)XB-2,1(2)XDA, and 1(2)XDB which are located in the Reactor Building in that the heat transfer analysis included in the file to demonstrate qualification was not based on the most severe ' design basis accident conditions that had been postulated based on the licensee's Reactor Building Environmental Report, Revision 4.
I 2 of 9 i l
- 6. The lic3ns;e failId 10: (1) includa the following cquipment important to safety on ths EQ
~ squipment list r: quired to ba qurlifird to 10 CFR 50.49: 120/208 AC distributio,n panels l i such as but not limited to Panels 1(2)A-RX,1(2)B-RX,1(2)C-RX,1(2)D-RX, and 1(2)AB- l RX; Potentiometers 1-1XE-EBO-POT,1 1XF-EE2-POT,2-2XE-EBO-POT,2-2XF-EE2-POT; various types of fuses identified as FRN-R, RNA, NOS, RES, NON, and SC; and Thread Sealants; (2) test or demonstrate that the equipment listed in (1) above, was i similar to a tested configuration; and (3) document qualification of the equipment listed in I (1) above, in an auditable form. l l
- 7. The licensee failed to maintain the EQ equipment list current by deleting the 300 EQ components listed in CP&L Great idea numbers NED-326 and NED-327 without adequate justification and management review. Specifically, subsequent review of these EQ data changes in 1995 and 1996 disclosed that more than 50 of the 300 components had been i downgraded, i.e., removed from the licensee's EQ Program incorrectly. (01013) I This is a Severity Level lli violation (Supplement 1).
Civil Penalty - $50,000. l l RESPONSE TO VIOLATION A-Admission or Denial of Violation: Carolina Power & Light admits this violation. Reason for Violation: By late 1995, Brunswick Engineering recognized a trend in discre ' ancies related to EQ documentation and accuracy of the EQ master equipment list. Increased management assessment of the EQ Program discrepancies confirmed that a programmatic problem existed. On April 12,1996 Brunswick Engineering initiated a Condition Report (CR 96-01277) to document this concern. A root cause investigation was initiated to determine the cause of the program discrepancies. Additionally, an EQ Program self assessment (96-00271) was initiated to identify any EQ Program weaknesses. Investigation into the cause of the EQ Program discrepancies determined that; 1) personnel responsible for control of the Brunswick Nuclear Plant (BNP) EQ Program failed to implement the program effectively, and failed to take appropriate action to resolve known deficiencies and 2) management oversight of the BNP EQ Program was inadequate and did not identify the deficiencies in the implementation of the program. l Corrective Actions Which Have Been Taken and Results Achieved: l l 3 of 9 l A Short Tcrm Corr:ctiva Action Plan was devslop d to identify tha scope end significance of tha , EQ issues. The goal of the short term plan was to establish the appropriate EQ design base I l requirements. This provided the basis for ensuring that the electrical equipment at BNP which is l required to be environmentally qualified will perform its intended function, and provided the basis I for properly reconstructing the program. The following actions have been completed. 1 Actions were taken to increase skill sets of EQ engineers, ensure technology transfer l and provide a heightened awareness, sitewide, of EQ related issues. This was l accomplished by establishing a dedicated team of CP&L personnel augmented with ! contract EQ experts and led by a program manager to implement the EQ Program Short l Term Corrective Action Plan. Additionally, near-term EQ training for appropriate engineering personnelincluding engineering supervisors and selected maintenance l personnel was implemented. In order to establish a sound foundation for reconstructing the EQ Program, a new EQ master equipment list was independently developed. This was then further validated by comparison to the existing equipment list. This action was necessary in order to ensure the electrical equipment required to be environmentally qualified was documented and understood. In order to ensure that the equipment identified above is capable of l performing its safety function, and that no unreviewed safety questions exist, the environmental design conditions for each plant area and event were re-evaluated and corrected as necessary. These established and documented environmental conditions l were reviewed to ensure that they were enveloped by the existing qualification testing. l Revisions to site documents such as the Updated Final Safety Analysis Report and Reactor Building Environmental Report have been initiated to document Qanges as described. Justification for Continued Operation (JCO) evaluations were completed as required for equipment whose qualification documentation did not use environmental conditions V ich bounded the newly reconstructeci environmental conditions, or for which no qualification documentation existed. l independent assessments were initiated and performed to provide continued program improvement through self identification and prompt resolution of program weaknesses. These assessments include; 1) a Maintenance assessment of the EQ Maintenance l Program assiste i by the Nuclear Assessment Section (NAS),2) a NAS assessmen' of l EQ JCO evaluations, and 3) an assessment of the EQ Program Corrective Action Plan conducted by the Chief Engineering Section. Results from the assessments have been incorporated into the EQ Program Corrective Action Plan. l This Short Term Corrective Action Plan has been successfulin identifying the sec+pe and significance of EQ issues which must be correcMd. Many discrepancies have been evaluated l and captured through the Corrective Action Program and resolutions have been implemented. To l date it has been determined that the issues are primarily documentation related with no impact on equipment operability. Except in the cases described in the JCOs referenced above, the equipment qualification documentation packages (QDPs) demonstrate the equipment had been tested to environmental profiles which envelope the actual environmental conditions for which I ! 4 of 9 l thsy will b3 exposed. Corrective Steos Which Will Be Taken to Avoid Further Violations: A Long Term Corrective Action Plan has been developed and is being implemented. The goal of the Long Term Corrective Action Plan is to implement actions which will establish comprehensive program procedures and develop upgraded ODPs which will provide the auditable documented evidence which validates program compliance. Upon completion of the Long Term Corrective Action Plan, the BNP EQ Program will fully meet the requirements set forth in 10 CFR 50.49. The plan includes the following actions. All QDPs will be updated to ensure accuracy, and formatted to support future equipment maintenance activities. This QDP upgrade process willinclude walkdowns of installed EQ equipment to verify that the as-installed configuration of the equipment is consistent with the qualification documentation. Discrepancies identified as a result of these walkdowns will be assessed for operability and resolutions will be implemented. Development of improved EQ Program procedures and revisions to the EQ Design Basis Document will ensure that the proper guidance is in place to support program implementation. Procurement specifications will be reviewed to ensure that a sound basis exists for maintaining configuration control of the installed equipment. Development and implementation of long-term training needs will support maintenance of the knowledge base required to ensure continued improvement of the EQ Program at BNP. Resolution of remaining CR action items will ensure closure of outstanding issues. This will be the final step in the reconstruction of the BNP EQ Program. Ownership and self critical assessment is necessary to maintain and build the EQ Program to the highest standards. EQ Program ownership will be clearly identified in program procedures. Specific expectations and accountability for maintaining the EQ Program in compliance will be established for the owner (s). To ensure that program oversight deficiencies, as evident by the EQ Program, do not exist or surface in other site technical programs, the following initiatives are being implemented by BESS: Identification of BNP engineering technical programs and program owners Establishment and clear communication of management expectations with regard to perfermance standards for each technical program engineer / owner incorporation of a series of self-assessments into the 1997 BESS Self-Assessment Plan which are targeted at evaluation of significant engineering programs 5 of 9 I i l i l . 1 1 Date When Full Comoliance Will Be Achieved: 1 i l Carolina Power & Light believes that all electrical equipment that falls under the scope of 10 CFR 50.49 will function in the environments in which they are located. Updates to the qualification j l documentation packages will be completed by December 31,1997. Field validation of ' component configuration and resolution of any identified discrepancies will be completed by July l 31,1998, following the next Unit 1 refueling outage. Violation B: 1 10 CFR 50, Appendix B, Criterion XVI, requires that measures shall be established to assurc that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures, and shall be accomplished b accordance with these instructions or procedures. i Carolina Power & Light Company Plant Program Procedure PLP-4, Corrective Action Management, implements the requirements of 10 CFR 50, Appendix B, Criterion XVI, at the Brunswick Nuclear Plant. Contrary to the above, as of the dates indicated, the licensee failed to assure that conditions adverse to quality were promptly identified and corrected and failed to follow Procedure PLP-4 as described in the examples below:
- 1. CP&L Prccedure PLP-4, Revisions 4 through 17, dated December 26,1990 through May 31,1996, requires managers to assure that assigned corrective actions are implemented.
- a. Corrective actions associated with Adverse Condition Report (ACR) 91-181 which was identified in April,1991 regarding maintenance of the EQ program required by 10 CFR 50.49 were not implemented as of June 14,1996.
- b. Corrective actions identified on ACR number N93-0101 which was identified in August 1993 and subsequently reissued as ACR number 94-00980 in June 1994 regarding associated circuits were not implemented as of June 14,1996.
- 2. Paragraph 6.0 of CP&L Procedure PLP-4, Revision 14, dated March 24,1995, requires individuals identifying a condition to consult with their supervisors and initiate a Condition Report (CR). A condition is defined in paragraph 4.5 of PLP-4 as an adverse condition or a condition not meeting expectations.
Condition Reports (CRs) were not initiated to document and correct the following conditions not meeting expectations: 6 of 9 . _ _ _ _ m . _ . __ . . _ _ . . _ . _ _ _ _ . _ . _ . . _ . . _ _ _ _ _ . _ _ . _ _ _ _ . . O. The finding that EQ related QDPs had not been updated to account for.the impact of hydrogen water chemistry increased radiation levels on EQ equipment, as . documented in Engineering Service Request (ESR) 9400752, dated May 11, ,' 1995.
- b. The finding that QDPs potentially impacted by engineering changes may require revision, as documented in ESR 9400742, dated May 11,1995.
- c. The fiading that procedures covering application of thread sealants for EQ 6
oquipenentkquired revision and that unqualified thread sealants may have been usedia FQ equipment applications, as documented in ESR 9400743, dated W... a 7.,1" 35 i A Pa.agraph i e . vi t.,iO.i. l'eccedese PLP-4, Revirion 15, dated June 7,1995, requires l onniam u. und per;or.nel fo emano CRs are initiated when they become aware ofadverse o y .,liron.. v.'..o;.ui n. in iho I L n in u.ohcq Group in ihn Bsunswick Engineeiing Site Support .g . . , : . :ri. . '; > . . ,; . a. y . re. CES " cre inithted to docorneat and correct nuinerous
- ..i, .,J '. 5
; e : , G ns. yam whi.M v.eie doc >mented in on ur.pitb!ished. .,;... :.s une i I. W d ; O phi .bse ;we*:t Ahen it was discuswd 'with tharn in .n: . .Mn Sc 'oc'ividin! who ident fied the conditions also ;!:- i l *: n , ., . , , . a ,. _i , . . ".P 6, ;?.wiom,14 iiiivugh 1/, .latait March 24 ; .e ; , -
- i- ,, ..n .3...s to c,i< oin th.M assignorf conoctivo
, I .. -r .- .w ,, uw GD;13 softei> c%s:fii aiion for EQ y .o q ni . ; w .e. e4 %bresry 22 1995 wrere not effective .' .t !.. m t v;gn l . , , ,n.4 .IJ ' 4 troni.i ns 17 and 10, . hied %y 13,1996 and ,. n- ' . e , n 'n . q. .s -ni i und r,.. :Wvarr.e i'oi dlians and ... 1 . m ficd ih.a i r ;;< had not Won initiated to o(. n ;m mono! vo .luty nt 3 00 P.M. on hily 18 i !, .c. d i. gar r ig i. mipun atvi'/ . tin:.Hi:ro . Ici potoittis . m, i. c 9 a., ,-ic:,.ot S;torpling Syr, tern. ,. .u ., .: . .to, .de. '.imJ tlwt a CR had not been ;nitiated to i 1 a .- .
- ..... ~ ui;.3 Rv. k opun .301 ctcsc lirnit switches for the PASS valves e - 1* t " 11: .' 4184, and d1M were not EQ qualif.ed (02013)
I 7 of 9 l l m - -vp..- - r y -- ~q .a , This is a Sev;rity LsvIl lli violation (Supplement I). , Civil Penalty - $100,000. RESPONSE TO VIOLATION B: Admission or Denial of Violation: Carolina Power & Light admits this violation. Reason for Violation: Ouring investigations initiated in conjunction with BNP CR 96-01277, referenced in the reason for Violation A, it was discovered that many of the BNP EQ Program inconsistencies being identified had been previously recognized by BNP EQ Program personnel. Many of these issues were identified in accordance with CP&L Corrective Action and Self-Assessment Programs. Actions to resolve these problems were either closed prior to fu!!y resolving the issue or not tracked adequately through the Corrective Action Program to ensure the issue was dealt with adequately and in a timely manner, Consequently, the problems remained uncorrected. Failure to implement effective corrective actions to resolve known deficiencies associated with the BNP EQ Program, resulted from causes similar to those described as the reason for Violation A in that; 1) personnel failed to take timely action to document and resolve known deficiencies and 2) management's lack of intrusiveness failed to recognize the extent of the deficiencies and the ineffectiveness of the actions which were taken, ineffective issue tracking due to weaknesses in the Corrective Action and Self-Assessment processes allowed the deficient modTons to persist. CarrachveAdions Which Have Been Taken and Results Achieved: %,ng Jia past several years BNP has continued to strive to improve its Corrective Action Program Actions taken during 1995 and continuing through 1996 have addressed the Co nsct.v : Action Program weaknesses evident in our response to the EQ Program deficiencies. These act ins are described below. .o Marci. of 695, BNP implemented aggressive changes to the site Corrective Action Program. Oce of the major changes was the training of designated plant personnelin the performance of arganizal:vnal and human perfurmance root cause analysis. Additionally, Revision 14 of procedure OPLP-04 " Corrective Action Management" introduced program changes which were designed to; !) lower the threshold for performing root cause analysis,2) stress self identification of conditions, and 3) increase line management ownership of the program. Revision 17 of OPLP-04 introduced the Event Review Team concept. Section 8.0 of the 8 of 9 l
- j proc: dura d2scrib2s this concept which w:s establish:d for inv:stigrting significant sita ev:nts.
This conc pt providas an integrated approach to incident investigation which is desigrled to quickly identify issues, determine causes of these events, and establish immediate corrective actions. In May 1996, additional Corrective Action Program enhancement was initiated. This enhancement consisted of training for appropriate Engineering and Regulatory Affairs personnel, and Corrective Action Program subprogram coordinators to ensure they are sensitized to the l level ofintrusiveness required during reviews of action item closure. This includes validation that action item closure ensures full resolution of the problem, or follow-up action items are initiated for tracking resolution. This requirement was added to Revision 3 of OPLP-04.1," Site Action item ' Management", section 5.3 in May 1996. These expectations were further reinforced by site management in a series of memorandums issued in July of 1996. Additionally, Revision 18 of , OPLP-04, which was issued in July 1996, deleted the ability to track corrective actions by any ' other means than the Corrective Action Program database. A site assessment was performed at BNP in mid 1996 which also identified the need to improve the effectiveness of the site Corrective Action Program. This site initiative was developed to provide a self criticallook at BNP organizational and programmatic activities. Based on the results of thin assessment, several action plans were introduced to the site which were designed to improve arrective Action and Self-Assessment effectiveness. Additional actions were initiated as a result of ti,e 1996 site assessment to improve the effectiveness of the Corrective Action Program. These actions, which were specified in Revision 19 of OPLP-04, include; 1) increased management involvement in program implementation as defined in section 4.2, and 2) a requirement to add a corrective action item to all root cause analysis which requires a follow-up effectiveness review of corrective actions implementei, as stated in paragraph 6.10.2.4. A Self-Assessment improvement Team was formed to develop and implement the site assessment action plan to improve self-assessment effectiveness. As a result, procedure OPLP-25 "Self-Assessment" was revised. New procedural requirements include; 1) a requirement to initiate CRs to track resolution of all findings as stated in paragraph 6.2.3.9, 2) increased management oversight which involves management review and approval of self assessment outlines and completed reports is required as defined in paragraph 4.2.2, and 3) documented disposition of items for management consideration by managers is required as defined in paragraph 6.2.3.10. Lead Assessors and management have been trained on effective methods and management expectations with respect to development of self-assessment outlines, conducting self-assessments and reporting assessment results. Lead Assessors are required to be trained as stated in section 4.5 of OPLP-25. Each of these programs (Corrective Action and Self-Assessments) procedurally enhance management involvement in program execution, including verification of the effectiveness of corrective actions. 9 of 9 Brunswick EnginIcring Supp;rt S:cti:n (BESS) m:nagsmint support of thise progrcms is , evident. . During 3rd Quarter 1996 ESP Continuing Training, a session was provided which reinforced the reason for and the importance of maintaining an effcctive Corrective Action Program. Management continues to stress the importance of self critical assessments and
- effective dispositioning of problems. Weekly management meetings (Section Manager and i
! Superintendents) are held to review completed root cause analyses and self assessments with 4 the responsible individuals to critique the reports and ensure corrective actions are appropriate. Additional Corrective Steos Which Will Be Taken: ] l An assessment will be performed by the Nuclear Assessment Section in 1997 of the Corrective l Action Program and Self Assessment Program to evaluate the effectiveness of the improvements ; made. I I Date When Full Comoliance Will Be Achieved: Carolina Power and Light believes that it is in full compliance with the requirements of 10 CFR 50, Appendix B. I i ! i l i l l l l l 100f9 . 1
- Enclosure 2
,. List of Regulatory Commitments - The following table identifies those actions committed to by Carolina Power & Light Company in this document. Any other actions discussed in the submittal represent intended or planned actions by Carolina Power & Light Company. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Manager-Regulatory Affairs at the Brunswick Nuclear Plant of any questions regarding this document or any associated regulatory commitments. Commitment * *
- date or outage
- 1. All QDPs will be reviewed and updated as necessary to ensure accuracy, and formatted to support future equipment maintenance 12/31/97 activities.
- 2. Field validation of component configuration and resolution of any identified discrepancies will be completed following the next Unit 1 07/31/98 l refueling outage.
- 3. Develop improved EQ Program procedures and revisions to the EQ design basis documents to ensure that the proper guidance is in 07/ %/97 place to support program implementation.
- 4. Procurement specifications will be reviewed to ensure that a sound basis exists for maintaining configuration control of the installed 12/31/97 equipment. .
- 5. Develop and implement long-term training to establish the l
knowledge base required to ensure development and continued 11/30/97 j improvement of the EQ Program at BNP. i
- 6. EQ Program ownership will be clearly identified in program procedures. Specific expectations and acccuntability for maintaining 07/14/97 i the EQ Program in compliance will be established for the owner (s). '
- 7. Identify engineering technical programs and program owners for 02/28/97 BNP.
j - . - . . - . . . - . . . . . . . .. - .. . - . . . - - . . . ~ . . - . . . - . . . . - . . - _ . . ~ - - _. _~. , - 7,' . i -s Committed . ! mmd. ment date or outage
- 8. Establish and provide clear communication of management .
expectations with regard to performance standards for each 02/28/97 I technical program engineer / owner
- 9. -Incorporate a series of self assessments into the 1997 BESS Self-Assessment Plan which are targeted at evaluation of significant 02/28/97
. engineering programs .s.
- 10. An assessment will be performed by the Nuclear Assessment -
Section in 1997 of the Corrective Action Program and Self- 08/31/97 Assessment Program to evaluate the effectiveness of the improvements made. l l 4 ,' N c FonM 3se ' 19[3 U.S. NUCLEAR REGULATORY COMMISSION invoice NuMat: I ' ' INVOICE 4 M'at cwicas PAv A81.E To TME U s NUCLE AR mEGut AfoRY CoMM:ssioN. REFERENCE THE INvotCE NUMBER oN REMsTT ANcE. AND invoice DATE
- U.S. NUCLE AR REGULATORY COMMISSION OlVISION OF ACCOUNTING AND FINANCE
, OFFICE OF THE CONTROLLER December 23, 1996 WASHINGTON, DC 20555 UCENsE NUMBER ut asums ?! REFERENCE NUMBER uf apatows Carolina Power & Light Company co"'^c' P.O. Box 10429 N^u' Southport, NC 28461-0429 TELEPHONE AREA NUMBER CODE _ 301 1 oE sCRlPTioN AMoVNT Received full payment for EA 96-354, dated November 19, 1996, 5150,000 Docket Nos. 50-324 and 50-325. AMOUNT DUE <s 7- 5150,000 TERMS. Interest will accrue f rom the envcice date at the annual rate of %. Payment is due immediately. However, interest will be waived if payment is received within 30 days from the invoice date. Penalty and administrative cha<ges will be essessed on a delingvent invoice. Additional terms and con-ditions are attached, d applicable. NOTE. If there are any cuestions about the eurstence or amount of the debt, contact the individual named above. For NAC debt collection procedu es. in-ciuding interest and penalty provisions. see 31 U.S.C. 3717. 4 CFR 101 105, and 10 CFR 15 s I I l N2C somu se ises. / " e . i CP&L Cudh Pmd Usht Comm Raleigh NC 27602 . Dog 12-10-96 Ched nvar 040163; Ol Vendor number K0072 Y t PAY EXACTLY $~4AA ;;.;;4150,000 DORARS AND 00 CENTS $****150.000.00 Pay to the crder of: . i TREASURER OF THE U S
- C/0 JAMES LIEBERMAN
- DIR OFF OF ENF-USNRC '
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