IR 05000443/1989004

Insp Rept 50-443/89-04 on 890327-31.No Violations Noted. Major Areas Inspected:Licensee Activities Re Info Notice 86-053,previously Identified Electrical Items & Program to Maintain Emergency Diesel Generator Fuel Oil

ML20247L751
Person / Time
Site:	Seabrook
Issue date:	05/11/1989
From:	Anderson C, Della Greda A, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247L747	List: IR 05000443/1989004 ML20247L740
References
50-443-89-04, 50-443-89-4, IEIN-86-053, IEIN-86-53, NUDOCS 8906020246
Download: ML20247L751 (12)

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[ U.S. NUCLEAR REGULATORY COMMISSION L REGION I Report No. _50-443/89-04 i Docket N I License N NPF-56- Category 1 u Licensee: Public Service of New Hampshire P. O. Box 330

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Manchester, New Hampshire 03105 Facility Name: Seabrook Inspection At: Seabrook, New Hampshire Inspection Conducted: March 27-31, 1989 Inspectors: k // /$ M br C. H.~Woodard, Reactor Engineer, Plant Sf/89

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Systems Section, Engineering Branch

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LIE Aux fl PQ" A. L. Della Greca,~ Reacror Engineer, Plant 'date Systems Sec on Engineering Branch i Approved by: . e 5/d C. J. #nderson, Chief, Plant Systems date Section, Engineering Branch Inspection Summary: ' Routine Unannounced Inspection March 27-31, 1989~

(Inspection Report No. 50-443/89-04)

Areas Inspected: Inspection of the licensee's activities relating to Information Notice 86-53 (Raychem Splices), previously identified electricci items and the licensee's program to maintain adequate quality of emergency diesel generator fuel oi Results: The inspection determined that, except for in-line and 3-wire splice deficiencies discusscd herein, Public Service of New Hampshire has implemented a program to meet the requirements of 10 CFR 50.49 relative to Heat Shrinkable Tubing (Raychem Splices). In addition, several previously identified electrical items were resolved. The Emergency Diesel Generator (EDG) fuel oil TI2515/100 inspection was completed with fuel program improvement evaluation commitments from the licensee. No violations were identified in ary of the areas inspecte k G

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Details 1.0 Persons Contacted 1.1. New Hampshire Yankee S. Barraclough, Technical Projects Engineer R. Belamger, Lead. Engineer, Compliance S. P. Buchwald, QA Supervisor R. Cooney, Maintenance Department Supervisor-R. E. Cyr, Maintenance Manager -

W. A. DiProfio, Assistant Station Manager

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J.'Grillo, 0oerations Manager G..A. Kann, Program Support Manager M. Kenney, Technical Support Engineer

G. J. Kline, Technical Support Manager G. A. Kotknwski,~ Electrical Engineering Supervisor W. B. Leland, Chemical /HP Manager J. T. Linville,' Chemical Department Supervisor M. McNamara, Maintenance Supervisor D. Moody, Station Manager V. J. Pascucci, Q.C. Inspection Supervisor D. W. Perkins, Operational Programs Supervisor  !

J. M. Peschel, Operational Programs Manager i J. ' L. Peterson, A.O. Manager N. - A. Pillsbury, IRT- Manager C. W. Roberts, Sec. & Computer Systems Manager W. J. Temple, NRC Coordinator P. J. Tutinas, Engineering Programs Supervisor, EQ .

J. M. Vargas, Engineering Manager '

J. Warnock, Nuclear Quality Manager i W. Yingling, Technical Support Engineer ' U.S. Nuclear Regulatory Commission U. Ruscitto, Senior Resident Inspector 2.0 Licensee Actien on Previous Inspection Findings (92701)

2.1 (Closed) Unresolved Item 86-45-01 - Containment Electrical Penetration Assemblies This item was opened to cover apparent inadequacies in the licensee's disposition of a Non-Conformance Report (NCR) related to electrical penetrations whose internal pressure had dropped below the 15 psig required by the licensee's procedure !

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The inspector reviewed licensee actions-taken which included

, licensee evaluations for a permanently installed penetration-pressurization system and an engineering evaluation / analysis made by .

the penetration supplier to show that the penetrations do not require -l

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internal pressurization in order to perform their containmerit' (

integrity function Based uoan these evaluations, the . licensee

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concluded that'the penetration internal pressurization was required only. during the 10 CFP. 50, Appendix J 1eak rate testing and not at other times. As a consequence, the licensee's procedures have been revised to delete the requirements for maintaining the penetration

. internal pressure except during leak rate tests. No deficiencies were observed in the licensee's evaluations and findings. This item is close .2 (Closed) Unresolved Item 86-45-02 - Electrical Equipment Heaters This item originated from the inspection of Emergency Diesel Generator (EDG) 'and Auxiliary Feedwater Pump motor (AFP) heater There weia questions as to the adequacy of surveillance to-detect damaged (burned-out) heaters in the EDG generator and as to the adequacy of the sizing of the heaters in the Westinghouse supplied AFP moto The inspector reviewed the licensee's evaluation of the EDG generator heaters including concurrence from the EDG manufacturer to change the heaters from a delta to wye connection in. order to reduce the heater wattage thereby prolonging heater and connecting wiring life. The analysis of the adequacy of heater sizing for the AFP motor was reviewed. There were no outstanding questions in the resolution of the. heaters for either the EDG or AFP units. However, there were questions regarding the surveillance for all safety-related motor and generator heaters and the adequacy of sizing of heaters for other motors and generator A review was made of the licensee's general specifications for all motors which includes the requirements for properly sizing the electrical heaters. In addition, IEEE Standard 43 and Westinghouse criteria for sizing electric motor heaters were reviewe No deficiencies in heater sizing were noted from this revie The licensee's motor / generator electrical heater surveillance program was reviewed. All motors and generators with heaters are included in a scheduled maintenance program which includes surveillance of heater operability on an annual basis. Heaters which are de-energized (because the motor or generator is i

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. running) are checked by electrical continuity' tests. Energized

heaters are checked by monitoring the current to.the heaters. The heatersifunction to prevent moisture intrusion into electrical

, windings which could cause damage. By performing electrical megger D tests of motor / generator windings on an annual scheduled basis, the licensee ensures equipment (motor /ge'nerator/ heater) operabilit The inspector questioned the needlfor. routine periodic operator '

surveillance of motors / generators to ' determine the operability of-heaters since the maintenance program frequency for determining j operability-is only once per year. Operations.does not now include i motor / generator heater operability in their surv'eillance progra A commitment was made by the licensee to assess the need for a more frequent. assessment of heater operabilit Based upon the inspection. findings, licensee actions taken and commitments made, this item is close ~ (Closed) Unresolved Item 86-45-03'- Restoration of Station 345KV System-This item originated as a result of a problem encountered during-hot functional Loss of Offsite Power (LOOP) tests. The 345KV circuit breakers in the switchyard are enclosed in a sodium hexaflouride

(SF6 ) insulating base medium. The SF6 is maintained as a gas by electric heaters which are powered by onsites 480 volt non-safety power. During the LOOP test when the heaters were de-energized, the SF6 cooled sufficiently to begin condensing thereby initiating breaker. opening. Since the normal non-safety feed was not available, the heaters could not provide the heat needed to permit circuit breaker re-closur Temporary power wiring was then used to provide power to the heaters to permit 345KV breakers reclosur '

Since this event, the licensee has installed a class 1E feed from  ;

the 1A Emergency Diesel Generator (EDG) 480 volt bus by means of a dedicated normally-open circuit breaker which can be closed in the event of LOOP to permit 345KV breaker reclosure when the 345KV offsite power source is regained. In order to provide further backup heater power in the event of LOOP and also loss of the A EDG, the licensee has provided a dedicated pre-cut coil of cable in a convenient location and an operating procedure for connecting the cable to obtain heater power from the other EDG 480 volt suppl The inspector reviewed the licensee's actions taken including the analysis for connecting non-class 1E loads to class IE buses (with coordination and test requirements) and the procedures which are used to accomplish the temporary connections. Following this review g the only outstanding question was the training of operators to l

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ensure their proficiency in the use of the procedure. Accordingly, 1 the licensee has scheduled training with the first session to begin 1 June 5, 1989. Based upon the inspection findings and license actions taken, this item is close .0 Emergency Diesel Generator Inspections 3.1 Emergency Diesel Generator Fuel Oil (TI 2515/100)

This inspection was performed to verify the licensee's program to

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maintain adequate quality of the emergency diesel generator (EDG)

fuel oil (FO). NRC Inspection Manual Temporary Instruction (TI)

2515/100 formed the basis and was used as a guide for this inspection. The inspection findings for each TI inspection item are the following:

• The licensee has adequately reviewed and evaluated IE Information Notice 87-04 relative to EDG F0 starvation. This review and its findings are included in Intra-Company Business Memo SPP#870139 dated February 2,1987. No systems or procedural changes were required as a consequence of this revie *

The licensee does not have an installed permanent F0 recircula-tion system for complete F0 inventory cleaning by filtering each refueling outage to remove accumulated particulate. However; the licensee does have a portable F0 recirculation / filtration system which can be used whenever plant chemistry determines (based upon routine EDG F0 sampling) that the particulate level requires reduction. The inspector reviewed sampling procedures CS 924.04 and CS 924.06 which establish the requirements for sampling and particulate. The review also included a review of the most recent occasion when the particulate level was high and the portable recirculation / filter system was used to remove the excess particulate (Work Request 89 WOO 1075 dated March 20,1989).

The portable system accomplished the excess particulate removal objectives in thirty-two hour This system provides adequate F0 filtratio * The license's technical specifications require that the F0 storage tanks be cleaned and inspected at a minimum of ten year intervals in accordance with Regulatory Guide 1.137. This cleaning and inspection is required by licensee procedure CX0901.2 Initial cleaning is due in August 199 =

The licensee's FO program includes regular analysis of F0 samples and bottom testing for accumulated water at the lowest point in the F0 day tanks and F0 storage tanks each 31 days in accordance with procedure CSO924.0 In addition, the day tanks are checked for water each time the EDG is operated for

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one hour or more. However, accumulated water has never been a problem at Seabrook. All of the fuel tanks are inside at a controlled temperature. They are maintained in a near-full condition. There are provisions for draining accumulated water from the tanks if require *

The licensee performs F0 sampling and analysis to detect high particulate concentrations in the F0 tanks which can occur over long-term storage due to the effects of oxidation and biological contamination in accordance with ASTM D270-197 Sampling and analysis are performed each 31 days in accordance with procedure CS0924.06. The licensee uses BioBar J as a F0 additive to prevent fuel oxidation and biological growt Thi s additive was approved by the EDG manufacturer (Colt) as being compatible with the engine fuel system. Sampling, testing, and analysis for BioBar concentration, addition and control are performed quarterly in accordance with procedures CD0924.08 and .0 *

The licensee performs sampling and analysis for clear, bright, viscosity and API gravity for incoming fuel prior to offloading the F0 into the EDG F0 storage tanks. Incoming F0 samples are then sent to offsite laboratories to complete the ASTM D 975 analysis which is necessary to verify that the material is the correct F0. However; current turn-around time for this analysis is a minimum of fourteer, days after the .:iatertal is offloaded into the EDG F0 tanks. The EDG F0 tanks are filled through a common FO filler pipe which than splits and goes to each of the EDG FO tanks. Each EDG tank fill line has a normally closed fill valve which would permit alternate or simultaneous filling of the tank Currently, the licensee's procedures do not direct that a tanker delivery be made to only one of the EDG tanks rather than to both. As a consequence, there is a possibi-lity for contaminating both EDG fuel tanks until the F0 is confirmed to be the correct EDG FO by later analysis. This could result in a common mode failure of both EDG unit Technical Specifications would require declaring the EDG units inoperable if the F0 was determined to be "out of spec."

The licensee has no installed provisions for replacing unacceptable F0 in the EDG tanks. Although unacceptable F0 replacement has not been necessary to date, a procedure reflecting prior planning for F0 tank draining / replacement could reduce the associated EDG inoperability time period in the event that it were require *

F0 components which may be prone to fouling are routinely monitored for indications of fouling. When the EDG units are operating the F0 pressure and differential pressures are

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normaloperationalsurveilla0ceparameters. . Local indiv' dual i ~-

indications / alarm are.provided on the local EDG panels for pressures and differential pressures. Fuel oil alarms are annunciated on a common trcuble alarm in the control- roo When the EDG units are not operating, Procedure MS0539.04 requires starting F0 pumps on a quarterly basis to monitor-F0 strainers / filters for evidence of fouling. The F0' system-utilizes. duplex strainers and duplex filters which permit switch over and, filter replacement during EDG operation. .This, work is performed by the licensee under a Repetitive Task System

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.(RTS) work order basis. Under this RTS EDG duplex F0 filters are routinely replaced each 26 week * . Instruments that perform F0 control and alarm functions are seismically qualifie The licensee committed to study improvements in the EDG fuel program as follows:

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Develop prxedural' changes which.would require off-loading FO-'on an alternate basis to each EDG FO tank. These changes would ensure that at least one of the tanks is known to-contain "in spec" FO. When the "in spec" analysis for one tank is received the other tank could be fille *

Establish a procedure to drain / replace "off-spec" F0 in .the EDG storage tank * Investigate methods to obtain ASTMD975 F0 analysis in a shorter period of tim Conclusion: The licensee has a' program which can maintain adequate EDG fuel oil quality. The licensee plans to conduct evaluations to enhance this progra .2 Emergency Diesel Generator Lube Oil This inspection was performed to determine if the licensee has a maintenance program for the sampling / analysis of EDG lube oil as a predictive indicator of engine components (bearings, etc.)

excessive wea The inspector determined that the licensee has implemented an EDG oil sampling / analysis program for EDG lube oil utilizing their RTS work order system. Oil samples are taken each thirteen weeks and analyzed for oil contaminants including metallic The iron, copper, tin,-lead, aluminum, and chromium content are measured and trended to provide early evidence of potential engine problems. The procedure and sample analysis dated January 5,1989 were reviewe l No deficiencies were identifie j

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3.3. Emergency Diesel Generator Jacket Water This inspection was performed 'to determine if the' licensee has a program for maintaining the quality of the EDG jackee wate The inspector confirmed that the licensee maintains jacket water chemistry in accordance with the EDG manufacturer's recommendations-utilizing appropriate corrosion inhibitor Samples of Jacket water

- are analyzed quarterly. ' Jacket water is filtered on a regular schedule to remove particulate utilizing a temporarily installed filtration system in accordance with procedure MS0539.16. . Whenever

engine components-exposed to jacket water (such as the turbo-charger)

are disassembled,.the coolant contact surfaces are' routinely examir;ed for corrosion and scale bu'ild-up with appropriate follow-up action No deficiencies were identified 4.0 Heat Shrinkable Tubing (RAYCHEM) Inspection (TI 2500/17) Introduction Several. licensees discovered in 1986 that a substantial number of Raychem cable splices, previously installed at their facilities, did not conform to the vendor's installation requirements in one or more of the following ways:

. Improper diameters (size)

Improper overlap length or wire insulation Use of tubing directly over the fabric cover of the wire Improper bending of tubing / wires inside junction boxes On June 26, 1986 Information Notice (IN) 86-53 was issued to alert the licensees of this potential generic safety problem and to urge them to review the information and consider appropriate actions, if applicable, to prevent or correct similar problems at their facilitie This. inspection was made to review the licensee's Raychem splice program and to inspect splices for IN 86-53 type problem .2 Corrective Action By Licensee In response to IN 86-53, the licensee undertook a re-inspection p program aimed at a complete walkdown and review of all plant splices.

L In addition, the licensee prepared Low Voltage Raychem Installation Procedure MS0514.09 to address present and future electrical instal-lations. Prior to the issuance of this procedure, splices were installed in accordance with licensee's drawing 1-NHY-30023 _ - _ _ _ - _ .

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The licensee's first formal reinspection was performed by the use of a checklist. However, pursuant to recommendations by the licensee's Nuclear Quality Group, the licensee prepared a procedure.(ES87-1-12)

to address the program objectives. lThe reinspection program uncovered many: splices which did not comply witn installation requirements '

specified.by Raychem. The unsatisfactory. installations were indivi-dually analyzed by.the licensee and, where necessary, replaced by new splices that were installed in accordance with the new procedur .3 Program Evaluation

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This NRC inspection consisted of a. program evaluation and a physical examination of several low voltage splices. The documents reviewed are listed in Attachment 1. Following are the results of the program evaluation:

E Paragraph 8.1.3.3.5 of the licensee's Raychem in:;ta11ation procedure MS0514.09 addresses the use of heat shriak tubing in cases where more then two wires are part of an in-line splice. The paragraph clearly expresses preference for breakou type splices which are especially designed by Raychem for.this-application. However, when breakout type splices are not available, the procedure allows the use of heat shrink tubing-which is typically used for in-line splices involving only two wires. The procedure provides ro details relative to specific installation requirements and drawing No. 1-NHY-300230, SH. 53, Rev. 5, also supplied by the licensee, requires only that " voids between adjacent wires be filled with B/M No. 13BM sealant."

Therefore, neither document assures consistent installation for the purpose of maintaining an environmentally qualified produc With regards to qualification, the package supplied by the licensee (File No. 600-01-09, Rev. 2) primarily addresses quali-fication of the components, i.e., the splice itself and the sealant. The analysis, however, does not clearly address the qualification of the assembly. Also, the additional analysis prepared by the licensee at the time of this inspection is inadequate to substantiate qualification in that it is neither supported by test data, nor by concrete evidence that the instal-lation, regardless of the methods used, will prevent moisture from entering the splice and thus, short the conductor to ground. This issue is an unresolved item (89-04-01) pending further evaluation by the license Qualification Report DCR No. 87-0137 includes the licensee's analysis to justify qualification of the Raychem splices to the Seabrook specific LOCA and MSLB temperatures which are nut enveloped by the qualification test profile. The analysis l did not specify margins. The licensee confirmed that the LOCA and MSLB profiles contained in the report did not include

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4.4 Physical Inspection

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The'NRC. inspector conducted.a physical. examination of several Raychem splices, including new and.old installations, from both control and instrumentation circuits. The installations were found

. generally acceptable except for..the following deficiencie An inline splice associated with solenoid valve ISB-FY-3 was found to use tubing directly over the fabric cover of the wire

. insulation. This installation, performed prior to the issuance of Information Notice 86-53, does not meet the manufacturer's -

installation criteria. Within the same enclosure a similar splice' performed with the current procedure was inst,alled correctly. The licensee was questioned as to the: reason why the splice had not been. redone. The licensee explained that during the construction phase of the plant it was common practice'to pull back the braid material for the installation of the splice

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and then to restretch the braid a short distance under the outer sleeve to prevent fraying. The practice was confirmed with

, Mr. V. Paseucci, the licensee's QC supervisor. However, no specific documentation exists which addresses the issue. The reinspection program did not consider this a necessary attribute for the acceptance / rejection of the splice. This issue is-an unresolved item (89-04-02) pending the licensee establishing the validity of this practic Inspection of splices contained in a 12 x 12 x 6 junction box associated with MOV No. SIV003, node V39, cable H36-V-39-1 revehled a 3-wire splice with shims that are shorter than the required 2 inch length (1 1/4 to 1.3/8 inches). Based upon Paragraphs 7.0 and 8.0 c.f DCR No. 87-0137 the splice should have been replaced. The licensee agreed that the splice should have been replaced. As a result, the DCR was reviewed to determin if the checklist prepared at the time of the walkdown had ' oeen dispositioned by engineering. It was found that the checklist, for some unknown reason, had never been sent to engineering for review. A copy of the checklist was furnished prior to the exit meetin Further evaluation of the checklist indicates that the splice, although found to be unsatisfactory as a "3-way in-line splice" by the QC inspector, was considered satisfactory with regards to attribute 3 (minimum shim length of 2 inches maintained).

This deficiency raises a question regarding the adequacy of the walkdown performed and the adherence to the requirements of the procedure. This issue is an unresolved item (89-04-03) pending further evaluation by the licensee to establish the adequacy of the walkdown considering the deficiencies note _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ -

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- 4.5 Training The NRC inspector examined personnel. training records to determine-the adequacy of licensee's' splice training. Prior to-January 1985, the licensee provided no formal training for installing splice 'This was primarily the responsibility of.the Architect Engineer who also provided the manpower for installation. After establishing a training program, the first class was held January 2,1985. The training lesson plan No. S17.078 indicates that the program includes hands-on training complete with a written exam at the end of the

. lesson. The course is provided for. engineering, electrical, I&C and QA/QC personnel. No deficiencies were identifie .0 Unresolved Item Unresolved items are matters for which information is required in order to ascertain whether'they are acceptable, violations, or deviation Unresolved items are discussed in Section 2 and 4 of this repor .0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance interview on March 27,-1989. The findings of the inspection were discussed with licensee representatives during the course of the' inspection and presented to licensee management at the March 31,'1989 exit interview (see paragraph.1-for attendees).

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ATTACHMENT 1 Documents Reviewe d Station Operating Procedure No. MS0514.09, Rev. 01, Low Voltage i Raychem Installatio )

I Electrical Equipment Qualification File No. 600-01-09, Rev. 2, {

Electrical Splice l Design Coordination Report (DCR) No. 87-0137, CA 0 Station Operating Procedure No. ES-87-1-12, Rev. 01, Raychem i Splice Inspection Progra {

i Drawing No.1-NHY-300230, SH. 33, Rev. 5, Wiring Systems Nutes  ;

and Typical Details, Lesson Plan No. S17.078, Form No. NT-6001-1, Rev. O, Raychem Heat Shrink Tubin Computer Printout, dated March 28, 1989, Training Attendees by Class Display, Course S17.078, Rev. O, Heat Shrink Termination ;

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