ML20237D974

Insp Repts 50-338/87-32 & 50-339/87-32 on 871005-09. Violations Noted.Major Areas Inspected:Environ Qualification of Electrical Equipment,Including Review of 10CFR50.49 Requirements Implementation

ML20237D974
Person / Time
Site:	North Anna
Issue date:	11/25/1987
From:	Alexander S, Conlon T, Levis B, Paulk C, Ruff A, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237D976	List: IR 05000338/1987032 ML20237D974
References
50-338-87-32, 50-339-87-32, NUDOCS 8712280068
Download: ML20237D974 (14)

See also: IR 05000338/1987032

Text

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3 A UNITED STATES

g g NUCLEAR REGULATORY COMMISSION-

o e REGION 11

[ 101 MARIETTA ST., N.W. ]

4,,,, ATLANTA, GEORGIA 30323  !

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Report Nos.: 50-338/87-32 and 50-339/87-32 l

Licensee: Virginia Electric and Power Company

Richmond, VA 23261

Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 '

Facility Name: North Anna 1 and 2

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Inspection Conducted: October 5-9, 1987 1

Inspectors: /k/[#I /2#

A. Ruff,'RIE

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Consultants: T. ilumphrey, Idaho National Engineering Laboratory (INEL) i

J. Stoffell, INEL

V. Nicolette, Sandia National Laboratories

Approved by C ff / // - fP P[

T. E. Conlo1, Chief Date Signed '

Plant Systems Section

Division of Reactor Safety

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SUMMARY

Scope: This special, announced inspection was in the area of Environmental

Qualification (EQ) of Electrical Equipment and included a review of Virginia

Power Company's implementation of the requirements of 10 CFR 50.49 for North

Anna and an inspection of electrical _ equipment within the scope of

10 CFR 50.49.

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8712200068 8712 l

PDR ADOCK 0 '

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Electrical Equipment requiring Environmental Qualification at North Anna Unit 1

and Unit 2 are qualified to the requirements of IEB 79-01B and NUREG-0588,

Category II, respectively. The NRC inspectors examined Virginia Power

Company's program for establishing the qualification of equipment within the

scope of 10 CFR 50.49. The program was evaluated by examination of Virginia

Power Company's qualification documentation files, review of procedures for

controlling the EQ efforts, and verification of adequacy and accuracy of the

program for maintaining the qualified status of the applicable equipment at

North Anna.

Based on the inspection findings, which are discussed in more detail in

paragraphs 5 through 13, the inspection team determined that Virginia Power Co.

has implem nted a program to meet the requirements of 10 CFR 50.49 for North ,

Anna although some deficiencies were identified. '

Results: Four violations were identified: (1) EQ Station Maintenance Program

Procedures, paragraph 12; (2) Limitorque Motor Operators, paragraph 13.c.(3);

(3) Performance Characteristics, paragraph 13.c.(4); and (4) Raychem Splice

Sleeves in Unqualified Configurations, paragraph 13.c.(11).

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• W. L. Stewart, V. P. Nuclear Operations

• J. L. Wilson, Manager, Nuclear Operations Support

• E. W. Harrell, Station Manager, Nuclear (North Anna)

• M. L. Bowling, Assistant Station Manager, Nuclear Safety and Licensing

• N. E. Hardwick, Manager, Nuclear Programs and Licensing

• R. W. Calder, Manager, Nuclear Engineering

• R. F. Driscoll, Manager, Quality Assurance North Anna

• G. L. Pannell, Director Safety Evaluation and Control

• H. L. Sutton, Nuclear Specialist

• D. B. Roth, Nuclear Specialist

• H. V. Le, Station EQ Coordinator

• P. T. Knutsen, Supervisor Nuclear Engineering

• M. G. Pinion, Engineering EQ Coordinator

• P. E. Conner, Electrical Engineering

• W. F. Murray, Nuclear Engineering

• B. L. Ingraham, Nuclear Engineering

• J. W. Shim, Nuclear Engineering

• M. E. McClendon, Nuclear Engineering

Other licensee employees contacted included craftsmen, engineers,

technicians, operators, mechanics, security force members, and office

personnel.

Other Organizations

• L. P. Gradin, Director of Engineering, Ecotech, Inc.

NRC Personnel and Resident Inspectors

• E. Merschoff, Chief, Vendor Inspection Branch, Division of Reactor

Inspection and Safeguards, NRR

• A. Herdt, Chief, Engineering Branch, Division of Reactor Safety, RII

J. Caldwell, Senior Resident Inspector

L. King, Resident Inspector

• Attended exit interview

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2. Exit Interview

The inspection scope and findings were summarized on October 5, 1987, with

those persons indicated in paragraph 1 above. The inspectors described

the areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The following new

items were identified during this inspection:

a. Violation 50-338, 339/87-32-01, EQ Maintenance Requirements in

Qualification Document Review (QDR) Files not adequately

addressed in the Station Maintenance Program Procedures,

paragraph 12.

b. Violation 50-338, 339/87-32-02, Unqualified Limitorque

Operators, paragraph 13.c.(3).

c. Violation 50-338, 339/87-32-03, Performance Characteristics not

Adequately Addressed in the QDR File, paragraph 13.c.(4).

d. Unresolved Item 50-338, 339/87-32-04, Test Anomalies from

Victoreen Test Report not Adequately Addressed in the QDR File,

paragraph 13.c.(5).

e. Violation 50-338, 339/87-32-05, Raychem Splice Sleeves in

Unqualified Configuration, paragraph 13.c.(11).

The licensee did identify some material as proprietary during this

inspection, but this material is not included in this inspection report.

3. Licensee Action on Previous Enforcement Matters

NRC's unresolved item 50-338, 339/87-01v05 concerning Raychem splices is

closed with this report. Raychem splices are discussed in paragraph

13.c(11).

4. Unresolved Items

Unresolved items are matters about with more information is required to-

determine whether they are acceptable or may involve violations or

deviations. One unresolved item identified during this inspection is

discussed in paragraph 13.c.(5).

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5. Electrical Equipment Environmental Qualification

a. EQ Program and Procedure Review

The inspectors reviewed Virginia Power Co./ North Anna EQ program

directives to verify establishment of an EQ program in compliance

with 10 CFR 50.49 including the following:

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Nuclear Operations Department Policy Statement N0DPS-SP-01,

Environmental Qualification Program

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- Nuclear Operations Departmer,t Policy Statement, N0DPS-M-02,

Preventive Maintenance Program

- Nuclear Operations Department Standard, N0DS-M-02, Station

Maintenance Program

- Nuclear Operations Department Standard N0DS-SP-01, The Standard

for the Environmental Qualification Program, dated November 26,

1985

- Virginia Power General Engineering Standard, STD-GN-0025,

Equipment Qualification Standard

- North Anna Administrative procedure ADM-3.10, Environmental

Qualification Program

- North Anna Administrative procedure ADM-3.7, Engineering Work

Requests

- North Anna Administrative procedure ADM-16.4, Maintenance

Program

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North Anna Administrative procedure ADM-16.9, Maintenance

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North Anna Administrative procedure ADM-16.16, Nuclear Plant

Reliability Data System c9d Equipment Failure Evaluation and

Trending

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General Engineering Nuclear Standard STD-GN-0023, Electrical

Procurement Standard

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General Engineering Nuclear Standard, STD-GN-0001, Instructions

for DCP Preparation

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Engineering and Construction Nuclear Design Control Manual I

Procedure No. 3.5, Design Document Preparation and Revision

The above procedures along with procedures discussed elsewhere in the

report confirm that an EQ program has been established for North

Anna. The procedures define the scope of the EQ Program and

responsibilities of various organizations for implementing it. The

procedures assign the Engineering and Construction Department (E & C)

responsibility to maintain the EQ Master List as a controlled.

document and to assemble and control documentation to support

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qualification of equipment identified in the EQ Master List. E&C

also maintains the environmental zone descriptions, j

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6. Environmental Qualification Master List (EQML)

The licensee is required to maintain an up to date list of the equipment

that must be qualified under 10 CFR 50.49. This list is entitled

Environmental Qualification Master List (EQML) and was prepared as

described in the licensee's Equipment Qualification Design Standard

STD-GN-0025, Rev. 3, Appendix B. The list was based on a review of the

Final Safety Analysis Report (FSAR), Technical Specifications, Emergency

Operating Procedures, and flow / electrical diagrams for Class 1E electrical

equipment that can be exposed to the harsh environmental effects of Design

Basis Accidents and which are required to function to bring the plant to a

safe shutdown condition. Other equipment evaluated included certain Post

Accident Monitoring (PAM) equipment and nonsafety related electrical

equipment whose failure under postulated harsh environmental conditions

could prevent the satisfactory accomplishment of safety functions.

i The licensee's first EQML was submitted in response to IEB 79-01B. It was

l reviewed and accepted by NRC on May 20, 1981. Subsequent and revised

l EQML's were also submitted to NRR for review. This review is detailed in

the Safety Evaluation Report, dated December 11, 1984.  ;

l Equipment Qualification Standard, STD-GN-0025, Rev. 3, Section 4.2, is

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used to maintain the list in an updated condition. This standard was

reviewed and determined to be adequate for establishing the methodology

for the preparation and maintenance of the EQML. To assess the

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completeness of the current EQML, the Safety Injection System was selected

as the system for review. Associated flow diagrams (11715-FM-0958,

11715-FM-096A and 11715-FM-096B) and electrical elementary diagrams

(11715-ESK-6EQ, 11715-ESK-6ER) were reviewed to determine the system

components, such as; Motor Operated Valves (M0V's), Solenoid Valves

(S0V's), motors, and instrumentation that are required to bring the plant

to a safe shutdown condition. All items required to be on the EQML were

identified on the EQML. An item of concern was noted when reviewing the

Station's Emergency Operating Procedures. Step 7 of 1-EP-0, Reactor Trip

or Safety Injection, Rev.1.00, dated June 12, 1987, required the operator

to verify Charging /SI Flow by checking Flow Indicators, FI-1961,1962,

1963, 1943 or 1943-1. Flow Transmitters FT-1943 and 1943-1 provide

redundant indication of total system flow and were on the EQML. Flow

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Transmitters 1961, 1962 and 1963, which provide individual SI flow to each

cold leg, were not on the EQML. The team's concern was that an

unqualified transmitter could provide inaccurate flow determination during

Design Basis Accidents and potentially mislead the operator. To alleviate

this concern Virginia Power committed to reviewing all their Emergency

Operating Procedures and delete references to unqualified instrumentation.

7. IE Information Notices (IENs) and Bulletins (IEBs)

The NRC inspectors reviewed and evaluated the licensee's activities

concerning the review of EQ-related IENs and Bulletins. The inspector's

review included examination of procedures and EQ documentation packages

relative to Information Notices and Bulletins. The procedure review

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determined that the licensee does have a system for distributing,

reviewing, and evaluating IENs and Bulletins relative to equipment within

the scope of 10 CFR 50.49, and that IENs and Bulletins are addressed in

appropriate component EQ files. During the review of individual component

qualification files, the inspectors did not identify any concerns with

respect to Information Notices and/or Bulletins.

8. EQ Equipment Replacement and Spare Parts Procurement

General Engineering Nuclear Standard procedure STD-GN-0025, Equipment

Qualification Standard, defines the methodology used by the licensee to

ensure compliance with 10 CFR 50.49, and identifies actions to be taken to

maintain the qualification of equipment throughout its installed life.

This procedure delineates the requirements for procurement of new

equipment, i.e., first time purchase, replacement-in-kind equipment,

upgraded replacements, modules, and parts. Requirements: have been

established for upgrade of replacement equipment in accordance with 10 CFR

50.49(1); and sound reasons to the contrary have been documented for not

upgrading replacement equipment to this rule.

Administrative controls applicable to the preparation, review, approval,

document control, and change control of procurement documents are

described in the Nuclear Operations Department Standards and their

supporting procedures. Nuclear Operations Department standard number

NODS-MM01, Procurement Process, delineate the specific responsibilities of

personnel involved in the procurement process. It also defines the

equipment quality classification to be used in the procurement process,

and describes the various modes that may be employed in the procurement of

new or replacement equipment and spare parts. Applicable regulatory

requirements, design bases, and other requirements necessary to assure

adequate quality are delineated in the following lower tier implementing -

procedures:

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ADM-4.0, Procurement Document Control, dated May 21, 1987

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Engineering and Construction Nuclear Design Control Manual

No. 4.1, Procurement, Revision 2

- STD-GN-0011, Guidelines for Procurement Reviews, Revision 2

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Nuclear Design Control Program Procedure No. 3.6, Procurement

Document Preparation, Revision 2.

Addendum No. 2 to ADM-4.0 provides specific guidance in the procurement of

electrical equipment. It requires procurement of new equipment, within

the scope of 10 CFR 50.49, to- be accomplished via an Engineering- Work

Request (EWR) or a Design Change Package (DCP). Additionally,-purchase

requisitions prepared for replacement equipment that are not required to be

upgraded are required to stipulate compliance with the equipment

qualification test report, and requires the vendor to supply a Certificate

of Conformance (C of C). Direct replacement of modules or spare parts are

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required to be procured from the original vendor who provides a C'of C

that their qualification report number is applicable to the replacement

module or part. The vendor is also required to identify any material

changes to the module or part since the qualification test was performed.

For situations where the vendor will not certify that the qualification

test report is applicable or; will not identify material changes or;

cannot be placed on the approved vendors list, an EWR is prepared and

forwarded to the engineering department for resolution. Engineering then

determines the item's critical attributes, its ability to perform its

safety related function, and the acceptable parameters for verification of

these attributes.

The adequacy of the implementation of the procurement procedural controls

was assessed by review of EWR Nos.86-012, 86-047,86-165, 85-829 and

related procurement documents. No violations or deviations were

identified in this area.

9. Control of EQ Related Modifications

Licensee design control program provides controls that ensure applicable

regulatory requirements and design bases are correctly translated into

specifications, drawings, procedures, and instructions to form a Design

Change Package (DCP). The following procedures delineate the design

controls applicable to plant modifications that impact electrical

equipment within the scope of 10 CFR 50.49:

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STD-GN-0001, Instructions for DCP Preparation, Revision 8

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STD-GN-0025, Equipment Qualification Standard, Revision 3

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Engineering and Construction Nuclear Design Control Manual

Procedure No. 3.2, Design Change Package Preparation,

Revision 14

Procedure No. 3.5, Design Document Preparation and

Revision, Revision 2

Procedure STD-GN-0001 requires that an EQ review be performed on proposed

plant modifications to determine if material and/or equipment used or

affected by the modification are listed or should be listed on the

Environmental Qualification Master List (EQML). This review is intended

to ensure that affected equipment on the EQML or new equipment to be added

to the EQML has been reviewed, procured, and documented to meet the

requirements of 10 CFR 50.49. Changes to the EQML are included as an

Appendix to the DCP, and these changes are further documented on a EQML

Change form. Requirements have also been established for review of the

Environmental Zone Descriptions (EZDs) and updated FSAR to ensure that

equipment located in areas subject to submergence are qualified for this

type of service. Specific guidance for the preparation and revision of

the EQML, Qualification Data Review (QDR) packages, and EZDs are further

delineated in procedure number 3.5

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The inspector reviewed three design change packages involving EQ related

modifications to determine the adequacy of the design controls regarding

EQ requirements. Acceptable procedural interface requirements were

identified with respect to personnel, training and knowledge of licensee's

employees involved with the DCPs preparation. Additionally, no EQ

deficiencies were identified in the DCPs reviewed.

10. EQ Training

Procedure ADM-3.10 delineates the requirements for the development and

implementation of a training program for personnel involved in various i

aspects of the EQ program. Responsibility has been assigned to the

Superintendent of Training for training of station personnel in the

requirements of the program, and the retention of training records which

provides objective evidence of completed training. The Environmental

Qualification Coordinator has also been assigned responsibility for

coordination and overview of the EQ training program with the Training

Department. He ensures that appropriate personnel are scheduled for EQ ,

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training classes, and provides EQ related information for incorporation in

the lesson plans.

The inspector conducted interviews with licensee personnel to ascertain I

the scope and depth of the EQ training provided. Additionally, objective

evidence in the form of completed training records was requested for

selected members of the engineering staff, (both on-site and off-site).

The licensee presented completed "Envi ronmental Qualification

Certification of Training / Orientation" forms for nine staff members

involved in various EQ related activities. Review of the completed

training forms revealed that a mandatory reading list raouirement had been

established. This list dealing with EQ requirements consisteo cf IE

Circulars, Information Notices, and Bulletins, NUREGs, Franklin Research

Center (FRC) Technical Evaluation Reports, NRC correspondence, and

applicable industry codes and standards. No violations or deviations were  ;

identified in this area.  !

11. QA/QC Interface

The Manager of Quality Assurance and his staff has been assigned

responsibility for monitoring compliance with the QA Program for the

operational phase of the nuclear power stations. He also provides

technical support of quality related efforts associated with plant

modifications, operation and maintenance activities. The inspector

determined that u audit of the EQ Program was performed on October 10,

1984 with the audit findings documented in Audit Report No. N-84-34. The

scope of the audit covered a review of station activities to verify

compliance with the EQ program contained in the 1981 Safety Evaluation

Report (SER) and associated commitments.

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The inspector reviewed the corrective actions fnr selected audit findings

to assess the adequacy of the corrective actions. No inadequacies were

identified during this effort. He also conducted interviews with licensee

site QA department personnel to determine the degree of involvement of the

site QA organization with ongoing EQ activities. The inspector was

informed that various performance areas involving EQ related activities

are audited on a schedule basis as determined by the Technical Specifica-

tion schedule for auditing of the 10 CFR 50 Appendix B program. No

violations or deviations were identified in this area.

12. EQ Maintenance Program

A computer program had been developed by Virginia Power Company to help

monitor EQ related maintenance and to avoid overdue maintenance problems.

This system was explained to the inspectors and it appeared to be a

signficant enhancement to EQ and general plant maintenance management.

The QDR files contain a maintenance / surveillance section. This section

covers the maintenance requirements that are necessary to ensure continued

environmental qualification of the specific equipment. The station is

responsible for maintaining this equipment in a qualified condition by

incorporating EQ maintenance practices into station maintenance programs.

Review of the procedures listed in paragraph 5.a. Indicated that these

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requirements have been, in general, properly incorporated into site and

department procedures. However, during this review three items were

identified in which the QDR EQ maintenance requirements were not

adequately addressed in station maintenance programs. These are as

follows.

a. Procedure MMP-C-S0V-1 is used to troubleshoot, repair, replace and/or

test solenoid valves. When this procedure is used there are actions

that can disturb or partially disassemble the electrical conductor

seal assembly (ECSA). The ECSA should be torqued to manufacture's

specifications as called for in the ECSA QDR file when it is

disturbed or partially disassembled. After the ECSA has been

disturbed or partially disassembled, there was no retorquing of

the ECSA in procedure MMP-C-S0V-1 before returning it to operability

status,

b. The low head safety injection (LHSI) motors are to have their

bearings replaced after operating a specified number of hours. There

was no procedure to track and record the number of operating hours and

no procedure to replace the bearings after the specified number of

operating hours.

c. The safeguard vent fans' QDR has an EQ maintenance- requirement to

change out the bearing grease or to sample it to ensure it is

satisfactory. This is to be accomplished..every refueling outage.

This requirement was not addressed in the station maintenance

program.

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The above items are identified as violation 50-338, 339/87-32-01, EQ

Maintenance Requirements listed in the QDR Files are not adequately

addressed in Station Maintenance Programs.

13. Environmental Qualification Document Files and Plant Physical Inspection

a. Qualification Document Review (QDR) Files

Virginia Power Co.'s EQ documentation files are established within

the corporate office engineering data and configuration control

system with duplicate files to be maintained at the site. The files

are called " Qualification Documentation Reviews" (QDR) and consist of

QDR Summary Sections, component evaluation worksheets (CEW),

Environmental Zone Description (EZD) sheets, reference lists,

parameter evaluations, accident profiles, installation and

maintenance requirements, NRC IENs and IEBs reconciliations, and

references including EQ test reports and supporting analyses, and

related correspondence.

A QDR is prepared for each specific type of qualified component

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designated by manufacturer and model in a plant area exposed to the

same environmental service conditions.

The NRC inspectors examined QDR's for 25 selected equipment types.

In addition to comparing plant service conditions with qualification

test conditinns and verifying the bases for these conditions, the

inspectors selectively reviewed areas such as required post-accident

operating time compared to the duration of time the equipment has

been demonstrated to be qualified, similarity of tested equipment to

that installed in the plant (e.g., insulation class, materials of

components of the equipment, tested configuration compared to

installed configuration, and documentation of both), evaluation of

adequacy of test conditions, aging calculations for qualified life

and replacement interval determination, effects of decrease in

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insulation resistance on equipment performance, adequacy of

demonstrated accuracy, evaluation of test anomalies, and

applicability of EQ problems reported in NRC IE Information Notices

and Bulletins and their resolutions. The more significant QDR

comments are discussed in the following Section c. Most of these

and other comments were resolved and/or corrected during the

inspection.

b. In Plant Physical Inspection

l The NRC inspection team physically inspected 32 qualified components

l and selected field run cables. This inspection was on both of the

North Anna units. The inspection team examined characteristics such

as mounting configurations, orientation, interfaces, name plate data,

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ambient temperature, conductor seals and instrument moisture seals,

splices, terminal blocks, internal wiring and physical conditions.

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c. Specific Comments

The QDR and plant walkdown items discussed below were considered to

be the more significant findings:

(1) QDR 8.5, Rosemount Transmitters -. It was noted during the file

review that the _ test reports - to which . qualification. was -

established 'are dated 1983. The file showed . installation of

many of the transmitters in 1982. Thu licensee was asked to

show traceability to-the test reports. The licensee responded

by stating that the 1153D Rosemount transmitters installed in

1982 were installed per Design Change 81 S08. . The Design Change

(DC) states that the qualification of .the transmitters was in

process at the. time the DC was issued. Virginia Power was a

member of a Westinghouse Owner's Group that worked with

Rosemount to produce this type of , transmitter. The EQ tests

results were available for utility review in 1982, but' the

formal- report was not issued until 1983. The licensee orde. red'

, the transmitters and specified that they be qualified in'

accordance with the Rosemount Design Report and IEEE 323/1974.-

The transmitters are considered qualified and this explains the

date discrepancy.

(2) QDR 4.4, General Electric Notor, Model SK6319X51D - The motors

qualified using this file are located in containment at Zone

RC2168. These motors are used as inside recirculation spray

, pump motors and have' component . identification . numbers of

1-RS-P-1A, 1-RS-P-1B, 2-RS-P-1A, and 2-RS-P-1B.

l The licensee was questioned as to the location of the motors 'in

regard to submergence level. The QDR shows the motors to be at

the 216 foot level while the submergence level is_225 feet 11

inches. It was concluded after the plant walkdewn and

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discussions with plant personnel that by virtue'.of.the pump

height and its vertical installation, the main body of the pump

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and the motors are above the submergence level.

(3) QDR 3.1 - Limitorque Valve Actuators - The files showed the

actuators to be qualified to the requirements.of IEB 79-01B (D0R:

Guidelines)

The NRC hasfor unit-1

issued and NUREG~

several Information0588, category

Notices 83-72,(II- 86-02, for unit 2.

86-03, 86-71 and 87-08) that. apply to Limitorque = actuators.

Based on the' above, this inspection, and the licensee's

documentation', some of the actuators were considered unqualified

-after November 30, 1985. The large majorityLof the '

qualification concerns. involved internal wiring as discussed in

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IEN 86-03. The ' licensee's ' documentation indicated that nine-

motors were' _ installed for which qualification documentation

could not be substantiated. These motors were listed as being

-qualified to - Limitorque test report B0003; however, the

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licensee's QDR review indicated that I.D. numbers on the motors

did not match the normal numbering sequence used by the

manufacturers. Limitorque was advi_ sed of this finding and they

informed the licensee that qualification to the above test

report could not, in fact, be definitively applied to the motors -

in question. The foregoing is discussed in the licensee's

Deviation Report on Limitorque Outside Containment .MOV

Actuators, dated February 27, 1987. The questionable

i qualification conditions were properly evaluated and analyzed,

and justification for continued operation in the questionable

configuration was performed by the ' licensee.- These items were

reported and have subsequently been corrected.

The above indicates that unqualified equipment was installed in'

the plant as of November 30, 1985 as defined by G/L 85-15 and

l 10 CFR 50.49(j) and is a violation. Since the wiring issue has

been considered generic, it is excluded from this violation

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based on SECY 87-32. This violation is identified as 50-338,

339/87-32-02, Unqualified Limitorque Operators.

l (4) Performance characteristic - The functional performance

l characteristic as specified in 10 CFR 50.49(d)(1) and (2), NUREG

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0588, section 2.2(7)(10) and IEEE 323-74 Section 6.3.2(3)' for

equipment was not adequately addressed in the QDR Files. This

includes the accumulated effect of leakage currents, IR drops,

t and instrument accuracy on the. total loop accuracy for

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instrumentation circuits along with the voltage, current, and

frequency variations'that could-affect satisfactory _ operation of-

the equipment during a potential . accident. Before the end of

the inspection the licensee prepared and presented partial

information which indicated that the performance specifications-

requirements had been considered, and that leakage currents were-

thought to be acceptable. The above constitute a violation to

10 CFR 50.49(j) and is identified as 50-338, 339/87-32-03,

l Performance Characteristic not adequately addressed in the QDR-

files.

(5) QDR 8.10 - Victoreen Radiation Monitor and Connector - This item 1

was included in the walkdown inspection and it was verified that

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the installed unit is.the same as the EQ test unit. The cable

was completely sealed' in steel _ conduit as reconinended by

Victoreen. There were two concerns that were identified by the

file review. The first was that the ' accuracy of the monitor

( 36% demonstrated) was not discussed in regard to North Anna's.

requirements'. This is considered an example that falls under

discussion. of (4) above. The second. is that several: test

anomalies were encountered during the. test of the EQ unit.

These were considered not -to~ be adequately resolved by the

licensee. This is identified as an unresolved item 50-338,.

339/87-32-03, Test Anomalies . fron Victoreen Test Report not

adequately resolved in the QDR file.

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(6) QDR 6.11 - Raychem Flamtrol Cable - This cable is 300V

instrument cable used inside and outside containment and

consists of XLPE insulation and XLPE jacket. The test used to

support qualification was performed by Franklin Research

Laboratory and involved simultaneous heat, steam, and radiation.

The two cable specimens which are similar to the installed

cables both failed the post-LOCA dielectric withstand test.

Post-test inspection revealed the cable insulation to be damaged

near the point of chamber penetration for these two specimens.

This appeared to be a reasonable explanation of the cause of the

anomaly. Low irs were also recorded for these specimens during

the LOCA test. The cables were considered qualified when the

concern regarding the effects of these low irs on instrumentation

was resolved. The only instrumentation connected to this type

of cable was outside of containment and the low irs were

considered to be due to the damage near the penetration.

l (7) QDR 6.2 - Rockbestos Cable - The Rockbestos cable (Firewall III

and Pyrotrol III) qualification basis was 00R Guidelines and

NUREG 0588 Category II. The file contained Rockbestoes reports

1806, 1807, 5804, and 5805, as well as Franklin reports

F-C2404-01, F-C2750, F-C2857, F-C2927, and F-C3050. The file

also contained NUREG 3588/ SAND 83-2406, which was used as a basis

l

for qualification (via similarity) of the Pyrotrol III and also

for " worst-case" insulation resistance values. The plants

contain the KXL-760, -A, B, -C, -D formulations as well as

KXL-510. However, the utility indicated that none of the

l KXL-510 is presently used in instrumentation circuits. The file

contained a generic assessment of leakage current effects, but

did not specifically analyze these effects for their

acceptability at North Anna. This is another example that falls

under the discussion of (4) above.

(8) QDR 8.8 - Ganma Metrics Neutron Flux Monitor - The qualification

basis for this file was NUREG-0588 Category I. The files

contained Gamma Metrics test reports #010 and #012, as well as

1. 104 for the junction box 0-ring. The test conditions enveloped

the North Anna LOCA environment, with the exception of the

radiation dose. The test radiation dose of 3E09 rads is lower

than the expected 40 year dose of 4.8E09 rads. Thus, the file

contained notices that the monitor has a qualified lifetime of

. 26.5 years before replacement is necessary. The file also

l

contained a letter from Gamma Metrics indicating that a new

0-ring was being manufactured, superseding the original 0-ring.

.

'

The n6w 0-ring replacement schedule is once every 10 years,

whereas the old 0-ring was to be replaced once every 5 years.

The file contained references to both replacement schedules and

was somewhat confusing as to what schedule currently applied,

and whether the 5 or 10 year replacement schedule should be used

in the future. The utility agreed to nodify the file to remove

this confusion.

i

L_____- _ _ _ _ _ __ _ _ _ _ _ . _ __ ______-.__A._._.__ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ . _ _ _ ___-___-_.mm_ ___._... _.___a

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(9) QDR 6.13 - Brand Rex 300V and 600V Cable - The qualification

basis for this cable was D0R Guidelines and NUREG-0588 Category

II. Franklin reports F-C5120 (-1 and 3) were used to qualify

the power and control cable, and Franklin' report F-C5120-4 was -

used to qualify the instrumentation cable. These cables have

XLPE (cross-linked polyethylene) insulation and CSPE (hypalon)'

jackets. The test environment enveloped the North Anna LOCA

environment. While the file did contain an error analysis (due

to insulation resistance effects), it did not demonstrate that

the calculated errors were acceptable for North Anna. This is

another example that falls under the discussion of (4) above.

(10) QDR file 171 - Connectron Terminal Blocks - This file was

I reviewed and found to be auditable. A minor administrative

deficiency existed in that the referenced test report was

included in its entirety at the end of Section G in the QDR

package, and a portion of the report was also included at the

beginning of Section G. 'The licensee committed to remove the

partial report and leave the : complete report at the end of

Section G. The test report had some anomalies that the licensee

had evaluated and determined that they were acceptable, however,

the licensee did not clearly state how the evaluation was

performed or what the basis was for accepting and/or resolving

these anomalies. The licensee committed to provide additional

clarification to address the anomalies. No violations were

identified.

(11) QDR 16.2 - Raychem Splices - The NRC inspector reviewed Virginia

Electric and Power Company's (now Virginia Power) (VEPC0's)

actions in response to IE Information Notice 86-53, " Improper-

Installation of Heatshrink Tubing." Temporary Instruction

(TI) 2500/17 was used as a guide for this inspection. As a

result of this review, including plant physical inspection of

l. splices, the inspector found that VEPC0 had conducted walkdowns

inspections of all heatshrink insulated splices in both units ,

at North Anna Power Station (NAPS) and detennined that many did

not conform to the configurations originally tested and qualified

l by the manufacturer. (Raychem). Accordingly, VEPC0 initiated a-

design change package to replace. all deficient slices using

procedures that were verified to be consistent with current

Raychem installation specifications. This effort was almost ,

complete at the. time of the inspection and VEPC0 had committed

to completion on both units. prior to startup of Unit 2 from the

outage in progress. The replacement of splices already

accomplished was confirmed by the inspector's review of related

maintenance documents and by plant physical inspection. No

incorrectly installed splices were identified that were not 3

already scheduled for replacement. All the splices installed by '

the VEPC0 Design Change Package (DCP) that were inspected during

this inspection were satisfactory.

I

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14

VEPC0's inspection results indicated that they had operated NAPS

after November 30, 1985 with splices not in a qualified

configuration. This constitutes a violation of paragraphs (f)

and (k) of 10 CFR 50.49 as follows:

Contrary to sections 5.2.2 and 5.2.6 of the D0R Guidelines,

for Unit 1, and contrary to section 5(1) of. NUREG 0588,

Category II, for Unit 2, qualification documentation for

Raychem splice insulation sleeves did not, establish similarity

between installed splices and those tested. VEPC0 failed to

ensure that Raychem splice insulation sleeves were installed

in a configuration similar to that in which they were tested.

Subsequent to discovering these deficiencies, VEPC0 had

developed information [ based on testing of Raychem splice.

configurations that deviated in various ways from the Raychem

specifications (information also known to the inspector)]that

indicated considerable deviation from Raychem specifications

could be accepted for harsh environmental performance. The

result of VEPCO's inspections indicated that many of their

splices deviated from Raychem installation guidelines. A large

majority of these fell within the constraints of the industry's

test for nonstandard Raychem configurations and were acceptable

based on the results of those test programs. VEPC0 concluded by

their evaluations and JC0's for the other nonstandard Raychem

splices that the equipment in question was operable. As indicated

above, all deficient (nonstandard) Raychem splice configurations

were replaced and up-graded to meet current Raychem specification.

Based on the above, unresolved item 50-338, 339/87-01-05 is closed

and up-graded to a violation identified as 50-338, 339/87-32-05,

Raychem Splice Sleeves in Unqualified Configurations.

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