IR 05000382/1988027

Insp Rept 50-382/88-27 on 881017-27 & 881101-07.Violations Noted.Major Areas Inspected:Licensee Actions on Previously Identified Items Re Equipment Documented in NRC Insp Rept 50-382/86-32 on 870416

ML20206K650
Person / Time
Site:	Waterford
Issue date:	11/22/1988
From:	Andrea Johnson, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206K640	List: IR 05000382/1988027 ML20206K636 ML20206K645
References
50-382-88-27, NUDOCS 8811290477
Download: ML20206K650 (7)

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APPENDIX B

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U.S. NUCLEAR REGULAT0T/ COMMISSION .

> REGION IV l

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NRC Inspection Report: 50-382/88-27 Operating License: NFF-38 1

i j Docket: 50-382 l I

Licensee: Louisiana Power & Light Company (LP&L)  ;

! 317 Baronne Stree.

New Orleans, Louis'ana 70160 Facility Name

Wat erforJ 9* .c Electric Station, Unit 3

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{ Inspection At: Reg,on IV Office j Inspection Conductsa: October 17-27 and November 1-7, 1988  ;

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Inspector: '. R. John r ??D 4*/

n, Reac' tor Inspector, Plant System, Date 66 '

ction Division of Reactor Safety L

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i Approved: 4f // 2!M T. F. Stetka, Chief, Plant Systems Section Date r Division of Reactor Safety i

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} Inspection Summary l

1 Inspection Conducted October 17-27 and Novreber 1-7, 1988 (Report 50-382/88-27) {

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j Areas Inspected: Licensee actions on previously identified items regarding

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equipment (EQ) as documented in NRC Inspec*, ion Report 50-382/86-32 April 16,

1987. These actions were outlined in a response letter from LP&L to NRC [

Region IV, October 18, 1988, at the NRC Region IV offic ;

Results: Two apparent violations were identified with regards to: (1)ITT  !

Barton Model 763 and 764 .nressure transmitters; and (2) electrical cable .

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conduit seals to Roserrount 1153 Series A transmitter l Three unresolved items are closed out requiring no further action based on the  ;

licensee's response dated October 18, 1988, to NRC Region IV, one unresolved item remains open, and one unre. solved item is reclassified as a  ;

violation, t I

Of the two open items reviewed, one itev has been closed out based on the I licensee's response letter, and the other item has been reclassified as a i violatio l

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8811290477 881123 .

i PDR ADOCK 050003S2 O PDC

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DETAILS Persons Contacted LPAL J. Dewease Senior Vice President. Nuclear Operations

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R. Barkhurst, Vice President, Nuclear Operations R. Burski, Nuclear Safety and Regulatory Affairs Manager J. McGaha, Nuclear Operations Engineering and Construction Manager J. Howard, Procurement and Programs Engineering Manager /EQ Coordinator NRC/ Region IV J. Milhoan, Director, Division of Reactor Safety A. Beach, Deputy Director, Division of Reactor Piojects G. Sanborn, Enforcement Officer T. Sletka, Chief. Plant Systeins Section D. Chamberlain, Chief, Project Section A A. Johnsen, Reactor Inspector Division of Reactor Safety R. Ireland, Technical Assistant, Division of Reactor Safety W. Smith, Senior Resident inspector, Waterford 3

Note: All individuals listed above attended the enforcement conference

, held in the Region IV office on October 4, 1988.

Licensee Actions on Previously identified items (NRC Inspection Report 50-382/86-32)

, (Closed) Unresolved item (382/8632-01): During the NRC EQ inspection the electrical equipment qualification documentation (EEQD) No. 42.3 for Barg Warner pneumatic-hydraulic operators, Model 39400, established qualification based on a similarity between the tested and installed configuration. The EEQD, however, required a station modification to upgrade the operators prior to the November 30, 1985 deadline, to demonstrate this similarit The qualification testing of the operators commenced in early 1983 with the testing initially to be completed by July 1983. However, the test was postponed due to a hydrolization reaction during aging tests experienced with the Fyrquel 220 Hydraulic fluid. The Fyrquel hydraulic fluid was changed to a synthetic hydrocarbon hydraulic fluid (SHHF) and new thermal aging tests of the actuator were rescheduled for completion in February 1984 After successfully completing the thermal aging tests, several failures occurred during the LOCA simulation which were attributed to the seal materials which were incompatible with this hydraulic flui The SHHF was then replaced with a silicon based fluid which was compatible with the seal materials, and the qualification test program was completely rerun and scheduled for completion in August 1985. During this qualification testing for the loss of coolant accident / main steam line break (LOCA/MSLB),

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severai anomalies occurred. LP&L reported to the NRC that the anomalies resulted because (1) there were problems with the test specimen configuration.i (2) simulaticos went beyond Waterford 3 requirements; and (3) the.c w t- improper test procedures. LP&L also reported that some anomalies 'a crved for the test specimen were not applicable to the actuators im tiled at Wts "ford *

LP&L submit 6.* & W ttgff a justification for continued operation (Js v k j 16, l5. The JC0 concluded that the anomalies were attributo h 4 tk. test program and were not applicable to the installed ope > W bt Wterford 3 and that the affect of these anomalies on the equipm * '. ,W ' on would be provided to the NRC by November 1, 1965. The jct, , ioM t able assurance of cperability while the anomalies were .3 res e .

In a letter to the .: ' d,aed November 1, 1985, LP&L provided the

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equipment qualification information. In this letter, LP&L described six modifications to the motor operators. Of these six, three were implemented, one was determined to be unnecessery (pump / motor coupling),

and two were deferred entil the next refueling outage (0-ring sealing and larger filter installation). The licensee determined that these two '

deferred upgrades were enhancements and did not affect the qualification of the equipment. These upgrades were completed under a station modification order during the refueling outage of December 198 The NRC considers the licensee's action on this item to be acceptable and this item is close .2 (Closed) Unresolved Item (382/8632-02): Examination of equipment qualification assessment (EQA) file LPL-EQA-8.2A identified a problem concerning submergence for ITT Barton Model 763 and 764 pressure transmitters. The EQA file did not contain at y documentation to show that a type test was conducted for the equipment in a subraerged environment. LP&L's position is that the equipment is qualified based on an ITT Barton type test (Report No. R3-764-9)

which subjected an identical model transmitter to a 100-day steam test at ,

7R 319, which is equivalent to a submergence in 30 feet of water. The  !

EQA file included ITT Barton's analysis of these steam conditions to l correlate them to the submergence equivalents. The NRC does not concur with this positio It is the NRC's position that the licensee clearly should not have known that Model 763 and 764 pressure transmitters were not qualified for submergence because a detailed review of the ITT Barton test report and analysis was not required. However, the licensee was not in compliance with the requirements of 10 CFR 50.49 and NUREG-0588 in that a submergence test was not performe For record purposes, this unresolved item is considered closeo, and this item is now considered to be a violatio ._

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-4-l 1 Violation (382/8827-01): Failure to comply with the requirements of 10 CFR 50.49 with respect to demnstrating qualification for submergence during DBA and post DBA condition .3 (Closed) Unresolved Iter (382/8632-03': The space heater and connecting Okonite T95 (insulation)/35 (Jacket) bolted tape splices on the General Electric (GE) motors for charging pumps A and B were removed as requirementi, of the EQ programs as the result of the LP&L/Ebasco engineering evaluation performed in September 1986. The GE motors still remain on the EQ master list (EQML-E) and are qualified to meet the 10 CFR 50.49 requirements for

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harsh environment. The heaters ware subsequently disconnectett in February 1987.

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The Ebasco evaluation included the requirements of 10 CFR 50.49 regarding nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety-related equipment functiens. Consequently, the de-entrgized space heaters within the GE motor housings pres n t no adverse affects to the motor qualification status. Also, because the bolted tape splices are contained in an electrical box outside the motor housing, no adverse

affects to motor functions were postulate With regards to other applications of the Okonite T95/35 bolted tape splices used in EQ applications at Waterford 3, LP&L maintains that the splices are qualified as documented in NQRN-3, Revision 0 (June 23,1980)

and Patel Engineering Test Report PEI-TR-840704-1. When this issue was

! raised during the December 1986 NRC inspection LP&L i m ediately contacted Okonite to confirm LP&L's interpretation of bolted splice qualificatio In a letter to LP&L dated December 11, 1986, Okonite stated that these test reports qualified materials used for various splices and termination assemblies installed in accordance with Okonite instructions.

l The NRC considers the licensee's action on this item to be acceptable and

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considers this item to be closed.

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1 2.4 (Closed) Unresolved Item (382/8632-04): At the time of the 1986 NRC EQ

! inspection, the NRC inspector reviewed the timeliness of LP&L actions to

, correct deficient conditions in Limitorque motor operators in accordance I with the guidance given in NRC Information Notice (IN) 86-03. During the i NRC walkdown of Limitorque motor operators, it was observed that pigtail connections in dual voltage operator EWF-HVAAA-220-A had been spliced I using blind barrel crimp splices. LP&L later identified 11 out of a total of 38 dual voltage motor operators (outside containment) which used this type crimp connector splice. These splices were later identiffed as j

Thomas & Betts (T&B) RB-4 and RC-6 nylon crimp connectur splice The

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Limitorque test reports did not identify these nylon crimp connector splices as part of the qualification tests. The NRC inspection team f observed that inadequate documentation existed in the EEQD 3.1.A file to j

j establish qualification by testing, and the insufficient evidence of

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testing was interpreted by the NRC as a lack of qualification.

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. . i-5-The nuclear industry, including utility owner groups, have reported that the manufacturer has subjected the dual voltage motor design using these

nylon crimp connector splices to environmental qualification testing on four separate occasions. Limitorque has tested dual voltage motors with Reliance Class H. Type RH insulation (Test Report No. 600376A) and with Reliance Class B insulation (Test Report Nos. B0003 and F-C3271). ,

Limitorque has also tested dual voltage motors with Class H, Type Rad H insulation (Test Report No. 600198). Documentation to substantiate that the RB-4 and RC-6 series connector splices were used in the above testing '

is not availabl Recently, another utility has sponsored a qualification test for the -

T&B RB-4 and RC-6 nylon crimp connector splices used in dual voltage Limitorque operators, at Wyle Laboratories. An 8-year screen  !

{ qualification test was completed successfully in late October 1987.

t A 40-year qualification test has been conducted and completed in  !

early 19E8. As a result of this testing, these nylon crimp tunnectors

failed part way into the accident test which indicates restrictive '

use of the T&B RB-4 and RC-6 connector splices, and demonstrates a shorter qualified life of 9.9 year Consequently, the NPC issued IN 88-81 to all licensees with regards to the use and application of T&B nylon crimp connector splices. IN 88-81 highlights the need for  ;

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licensees to identify all degradable components in 10 CFR 50.49 designated equipment and to verify that they have been properly i environmentally teste ;

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LP&L, through its association with a utility owners group, is aware that more recent testing has concluded that the qualified life of the connectors may be limite In light of this information, LP&L will

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l I replace the connectors by the end of the third refueling outage  !

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(September 1989) which will occur before the end of qualified life as reflected on recent testin ;

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! It is the staff's position that the licensee clearly should not have

! known that the T&B crimped type splices were not qualified because a

! review of the Limitorque testing reports was not required to that  !

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i Based on this position, this potential enforcement / unresolved item

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has been reclassified as an open item. This item remains open

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pending completion of the connector splice replacements before .he I qualified life ends. For record purposes, this unresolved item is t j considered to be closed, t Open Item (382/88?7-03): Review final EQ test results for qualifying ,

l T&B RB-4 and RC-6 nylon crimp connector splices used in dual voltage

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limitorque motor operators to verify qualified life and verify  ;

i replacements accordingl ?

2.5 (Closed) Unresolved Item (382/8632-06): LP&L at the time of the 1986 NRC t EQ inspection had the infonnation available to establish qualification in I

the EQ file (EQF) for the Boston Insulated Wire (BIW) cable assembl l

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Contained in EEQD 14.1/52.1 was: (1) Isomedix test report on radiation l aging performed for Litton Precision Products; (2) an Ebasco memorandum describing the thermal lag analysis done on the assembly - Appendix 2 of the EEQD; and (3) a degradation equivalency analysis (Arrenhius

calculation) - Appendix 4 of the EEQD. These documents demonstrate that the actual temperature profile was enveloped by that tested. The NRC i inspector had not reviewed the Appendix 4 analysis during the 1986 NRC inspection. The additional test report No. 558-1654 by National Technical Systems, which also demonstrates the test accident profile envelop; the MSLB temperature peak, also confirms qualification of the RIW cable assembly. The NRC concludes that information contained in the EQF as of November 30, 1985, and at the time of the 1986 NRC inspection was adequate l to support NUREG-0588, Category II qualification. This item is close .6 (Closed) Unresolved Item (382/8632-07)

The BIW cable assembly aging i

concerns were adequately addressed in EEQD 14.1/52.1 in the EQF. The NRC l concern focused on a statement in the EEQD that the ambient temperature in the reactor vessel head area could reach 250*F. The nominal temperature

referenced in the EEQD was 120'F. As of November 30, 1985, LP&L did not have indications that its 120*F nominal temperature value had exceeded

] this value, in that the plant had not operated for a substantial period.

4 Therefore, LP&L perfoned its EQ analysis based on the 120*F value. Since the 120 F nominal temperature qualified the components to greater than a i j 40-year life, no replacement schedule was required.

i LP&L has had an ongoing inside containment ambient temperature monitoring i program. This program monitors and trends containment temperature on a

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continuous basis. LP&L again reviewed its nominal temperature values and  ;

I concluded that additional conservatism could be added without nullifying I qualification. Specifically, LP&L has raised the nominal temperature to a i j very conservative level which results in a decrease in qualified lif ~,

! Now that a less than 40-year life has been documented, a replacement

schedule has been develope This item is close ,

2.7 (Closed) Open Item (382/8632-10): There is no requirement that Okonite Okoguard SKY insulated cables and Okonite T95/35 tape splices include the  ;

use of a cable tray system for thermal shielding. This issue was '

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l misunderstood by the NRC during the 1986 EQ inspection. LP&L has not

taken credit for the cable tray system as thermal shielding for contained  :

cables. The cable tray system provides support, physical protection, and 'i

, some beta dose shielding for contained cables. The Waterford 3 EQ Program l

incorporates an Environmental Qualification Maintenance Input (EQMI)  ;

document which identifies to the maintenance department, maintenance-related  !

actions that are required to maintain equipment qualificatio Initial i l issuances of EQMIs contained action items for operations, engineering, and  ;

l maintenance groups. As the program developed, items that w re not specifically

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maintenance department actions required for qualification were removed ,

from the EQMIs. The EQMI statement which required verification that the  ;

! installed cable service temperature, including internal heat rise, remain  !

j belew 90*C was originally intended to be a reminder to engineering groups l 1 that future design changes should incorporate initial design parameter l i .

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-7-Therefore, consistent with other non-maintenance-related deletions, this type of a requirement should have also been deleted. Engineering requirements for cable design (including consideration for maintaining contiajous conductor temperature below 90'C) are contained in Waterford 3 Electrical Design Criteria, Criterion No. 8 "Power Cable Ampacities."

Only the addition of cables to closed top trays would require the designer to revisit these calculations to ensure proper conservatism and thus preserve the 90'C temperature limit. Otherwise, there is no requirement for maintenance personnel to perform any verification function regarding Okonite SKV cables and splices, and therefore no need for the verification statement in the E0MI. This item is close .8 (Closed) Open Item (382/8632-14): The Rosemount 1153 Series A pressure transmitter file (EEQD 8.1/8.1A), did not contain qualification docu.Lentation regarding the use of GE RTV silicone rubber sealant, (type 106/116/8262) in lieu of electrical cable seal assemblies (ECSAs),

during the NRC 1986 EQ inspectio LP&L during equipment walkdowns conducted prior to November 30, 1985, iden'ified the need to provide ECSA's in electrical conduit connections to Rosemount 1153A transmitters. LP&L experienced difficulty in the timely procurement of ECSAs. To resolve this issue, LP&L elected to seal the conduit cable entrance with RTV sealant and reinstall the appropriate ECSAs during the first refueling outage scheduled for December 198 LP&L evaluated the use of RTV as a sealant in a Spare Parts Equivalercy Evaluation Report (SPEER) dated February 21, 1985, and concluded that it was qualified. GE has determined that RTV 106/116/8262 has excellent temperature and radiation resistan'c. RTV 106/116 was tested in Rosemount resistance temperature detectors (RTDs) under accident simulation RTV 8262 was tested by BIW as a potting compound for thermocouples under accident simulations. RTV 8262 was also tested by litton Precision Products /Isomedix under a simulated LOCA/DBE by sequential exposure to environments of thennal aging, radiation, containment pressurization, steam, and chemical spray. However, the above industry testing of RTV 106/116/8262 did not include accident simulated temperatures above 340*F to a required 414*F for the 120-day duration required at the Waterford 3 plant. An Ebasco thennal lag analysis is now known to establish oualification at the highe temperature level LP&L, during the NRC 1980 inspection did not have/or reference these qualification documents in the Rosemount EQF. The failure to maintain the necessary qualification information in the EQF is considered to be a violation. Fe -

record purposes, this open item is considered closed, and this item has been reclassified as a violatio Violation (382/8827-02): Failure to comply with requirements of 10 CFR 50.49 with respect to establishing a record of the qualification.