ML20198P973

Ack Receipt of Expressing Concern Re Role Products Occupy in Safety Sys of Domestic Nuclear Power Facilities,Per IE Info Notice 86-003, Potential Deficiencies in Environ.... Position Clarified

ML20198P973
Person / Time
Issue date:	06/02/1986
From:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Denham F LIMITORQUE CORP.
References
REF-QA-99900100 IEIN-86-003, IEIN-86-3, NUDOCS 8606090028
Download: ML20198P973 (4)

Text

i

• $ f' o

g UNITED STATES e o NUCLEAR REGULATORY COMMISSION t j WASHINGTON. D. C. 20555

\...../ June 2, 1986 D:cket No. 99900100 Limitorque Corporation ATTN: Mr. F. K. Denham Executive Vice President 5114 Woodall Road Lynchburg, Virginia 24502 Gentlemen: 4

References:

a. Letter from F. K. Denham, Limitorque, to E. L. Jordan, NRC,

Subject:

Information Notice No. 86-03 (January 14, 1986) Potential Deficiencies in Environmental Qualification of Limitorque Motor Valve Operator Wiring, dated February 13, 1986. -

b. IE Information Notice 86-03: Potential Deficiencies in Environmental Qualification of Limitorque Motor Valve Operator Wiring, dated January 14, 1986.

We have received your letter of reference a. and appreciate your cancern with regard to the role your products occupy in the safety systems of domestic nuclear power facilities. We have reviewed the comments provided in your letter and the discussions in the following paragraphs provide our position on them.

As you know the purpose of information notices (ins) is to inform the nuclear industry of safety or potential safety problems of a generic nature to the industry. The information included in ins is obtained from many different sources, which include inspections at licensed nuclear facilities, inspections at vendor facilities, 10 CFR 21 reports, 10 CFR 50.55(e) reports, and various other sources as appropriate. In this case, information in the IN was based on data gathered ouring an inspection at your facility as well as information from NRC inspections at several different licensed facilities. i Based on the information we had at the time the IN was issued, it was evident i that while there was the possibility that some Limitorque operators might not i have the internal wiring qualification problem as described in the IN there '

were sufficient data to question the qualification of the internal wiring of all Limitorque operators in nuclear plant safety systems. We still have the same concerns and have seen no evidence which indicates we should change our position. In fact data obtained since the issuance of the IN appears to reinforce our concerns. Further, this is a repeat of an earlier concern expressed in Information Notice 83-72. I am troubled that NRC licensees and your company have failed to resolve this issue since it was brought to your attention three years ago.

8606090028 860602 PDR GA999 EMVLMIT 999900100 PDR

Limitorque Corporation June 2, 1986 During the visit to your facility in November 1985, the inspector was given the impression that the only wire you considered qualified for nuclear safety systems operators was either Raychem Flametrol or Rockbestos Firewall SIS wire.

Additionally, he was informed that the qualification of these two wires was supported by separate cable qualification reports and not by the Limitorque operator qualification reports. While there is no problem with this approach to establish qualification of your operators, your nuclear power plant customers should have these separate reports available for their qualification files.

Our inspector was also informed that valve manufacturers, licensees, or others may have added additional wires to Limitorque operators after the operators left your plant. We understand this and recognize such additions and changes are outside Limitorque's responsibility. When this occurs, unless these wires i were either Raychem Flametrol or Rockbestos Firewall SIS, qualification of .

these wires would have to be supported by other data in licensee _ qualification I

files.

2 Since the in.pection at your facility, we have learned that there are other wires installed by you in safety related applications of your operators which are not covered by the qualification reports discussed above due to change in application since purchase or equipment purchased many years ago without qualification requirements. Licensees have a requirement to qualify these operators to appropriate qualification standards depending on their application.

Since the inspector was not made aware that wires other than Raychem Flametrol or Rockbestos Firewall SIS had been installed by Limitorque, he could not discuss any problems associated with their qualification. He did, however, discuss briefly by telephone some concerns with the qualification of these wires with P. McQuillen on December 18, 1985.

l With regard to your comment concerning the fact that some wires are too short to identify and establish qualification, we have issued guidance in IE Temporary Instruction 2515/75, " Inspection of Limitorque Motor Valve Operator Wiring to l Determine if Wiring is Environmentally Qualified," dated March 27, 1986, to  :

address this concern. Basically this guidance tells an inspector that if short l wires cannot be identified but are similar in appearance to wires that can be l identified in an operator, the unidentified wires can reasonably be considered  !

the same as the identified wires. If similarity is not established, the wires 4 may also be identified by establishing traceability to the manufacturer through a controlled procurement / installation process.

It is unfortunate that you feel the IN unreasonably identified the wiring defi-l ciencies soley to Limitorque; however, we have not identified similar problems with other environmentally qualified equipment at this time. For this reason, the IN only referenced Limitorque operators. If future information, including findings from our 10 CFR 50.49 inspections of licensees, identify similar problems with other equipment they will be evaluated for generic application and action will be taken as deemed appropriate to the issue.

/

- . - . . _ . . _ , _ _ _ . - - _ , . _ . . . . - _ , _ _ _ . _ _ _ , _ . . , . . , _ , . _ . _ , _ , , , _ _ ,,__m, , , . , , , ,

Limitorque Corporation June 2, 1986 We acknowledge that a comment opportunity on this IN was discussed during the inspection in early November 1985; however, we did not feel that it was necessary in this case. Our position was and still is that the IN accurately describes this qualification issue. The NRC reserves the right to make determinations on coordination of Information Notices as well as Bulletins on a case-by-case basis.

NRC's objective is to present facts in an objective manner that is beneficial to the health and safety of the public. In future reporting of events concerning Limitorque equipment or any other manufacturers' equipment we will continue to seek, as we have in the past, input from the affected manufacturers, as considered appropriate.

With regard to your request that your letter become a part of the IE Notice No.

86-03 file in the public document room, we have sent a copy of your letter and a copy of this reply to the public document room for inclusion in the file.

If you have further questions concerning this matter contact G. Zech (301/492-9663) or U. Potapovs (301/492-8030).

Sincerely, dw d dan, Director Divisi of Emergency Preparedness and Engi ering Response

, Office of Inspection and Enforcement

Enclosure:

Information Notice 83-72 i

i Limitorque Corporation June 2, 1986 We acknowledge that a comment opportunity on this IN was discussed during the inspection in early November 1985; however, we did not feel that it was necessary in this case. Our position was and still is that the IN accurately describes this qualification issue. The NRC reserves the right to make determinations on coordination of Information~ Notices as well as Bulletins on a case-by-case basis.

NRC's objective is to present facts in an objective manner that is beneficial to the health and safety of the public. In future reporting of events concerning Limitorque equipment or any other manufacturers' equipment we will continue to seek, as we have in the past, input from the affected manufacturers, as considered appropriate.

With regard to your request that your letter become a part of the IE Notice No.

86-03 file in the public document room, we have sent a copy of your letter and a copy of this reply to the public document room for inclusion in the file.

If you have further questions concerning this matter contact G. Zech (301/492-9663) or U. Potapovs (301/492-8030).

Sincerely, Original Signed By:

E. 0 Jor~ dan Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement

Enclosure:

Information Notice 83-72 DISTRIBUTION:

DFB:IE:09; VPB Reading DQAVT Reading DEPER Reading JTaylor RVollmer BGrimes HMiller GZech UPotapovs GHubbard

. EPER:IE

• SEE PREVIOUS CONCURRENCE ELJordan 5/Jf/86 1

• VPB:DQAVT *SC/VPB:DQAVT *BC/VPB:DQAVT D/DIR:DQAVT *DIR: DQAVT *D/DIR:DEPER )

GHubbard: sam UPotapovs GGZech HMil1er BKGrimes SSchwartz 4/22/86 4/23/86 4/24/86 4/ /86 4/24/86 4/29/86

,, , & R b*f 6 / C J ' YS

// ,7 SSINS No.: 883s

( I IN 83-72 UNITED STATES  !

NUCLEAR REGULATORY COPWISSION l 0FFICE OF INSPECTION AND ENFORCEMENT l WASHINGTON, D.C. 20555 0CTOBER 28, 1983 IE INFORMATION NOTICE 83-72: ENVIRONMENTAL QUALIFICATION TESTING EXPERIENCE Addressees:

All holders of a nuclear power reactor operating license (OL) or construction permit (CP).

Purpose:

This information notice is provided to inform the licensees of environmental qualification test failures. These test failures are based on (1) Construction Deficiency Reports and 10 CFR Part 21 Reports submitted to the NRC, and (2) results from the NRC-sponsored environmental qualification methodology research program. This information notice also serves to inform the licensees of findings that resulted from inspections conducted by the licensee or its -

agent of equipment that has been environmentally qualified and is being delivered or installed at the sites.

Because of the potential safety significance and related generic implications of these test failures and inspection findings, addressees are expected to review the information for applicability to their facilities. No specific

• response to this information notice is required.

Description of Circumstances:

The NRC has received a number of Construction Deficiency Reports and 10 CFR Part 21 Reports from licensees and vendors of safety-related equipment. These reports describe a number of test failures and the circumstances under which the equipment failed to function during environmental qualification testing.

These reports also indicate that there are a number of instances in which delivered equipment and components contained material that did not conforra to standards for safety, thus rendering the qualified equipment and components unqualified. 'In addition to the monitoring and assessing of environmental qualification information received from the industry, the NRC has also spon-sored a number of qualification tests of certain safety-related equipment under its environmental qualification methodology research program, which has resulted in a number of adverse test results. This information notice is published with the following objectives:

1. To disseminate the information on matters rela'ed to the environmental qualification of equipment and on test results, as received from the licensees and equipment vendors.

N p3N

83-72 Octcb2r 28, 1983 Page 2 of 2

2. To disseminate the results of NRC-sponsored environmental qualification tests which have been completed.

The enclosed continuing series of Equipment Environmental Qualification Notices (Attachment 1) describes the circumstances of each failure, failure mode, and qualification concerns as described in various reports and sources indicated.

Please note that for items in Qualification Notices No. 14 through 19 the vendors have issued service instructions to the affected users regarding corrective action to be taken.

Questions regarding the details of tests described in Attachment 1 should be directed either to the equipment manufacturer or the cognizant design / test agency. If you have other questions regarding this information notice, please contact the Regional Administrator of the appropriate NRC Regional Offigg, or .

this office.

dward L - irector Divisio6 (/To dan, Preparedness and f Emergency Engin ping Response '

Office (oT Inspection and Enforcement Attachments:

1. Series of Equipment Environmental Qualification Notices

2. List of Recently Issued IE Information Notices 4

Technical

Contact:

N. B. Le, IE (301) 492-9673 l

l l

l

s

\ , .tichment 1

.~* IN 83-72 October 28, 1983 4 Page 14 of 16 Equipment Environmental Qualification Notice No. 24 Equipment: Limitorque valve operators

Reference:

Construction Deficiency Report - Part 50.55(e)

Facilities: 50-329, -330 Description of Circumstances:

The Bechtel Associates Professional Corporation, A/E for Consumers Power Company's Midland Plant Units 1 and 2, has recently reported to the NRC the following deficiencies related to the Limitorque valve operators at the Midland plants: ,

1. The use of underrated terminal blocks in Limitorque operators

2. The use of terminal blocks without proper environmental qualification in Limitorque operators "

3. Additionalconcernsregardingqualifica[ionofvariousLimitorque operator components

- These concerns are detailed below.

A. Underrated Terminal Blocks

• While replacing a damaged terminal block on a Limitorque operator, Bechtel determined that some of the terminal blocks used for the termination of the leads from the 460-volt motor were rated less than 460-volt. These Limitorque operators when used on saf ty-related valves, must function on an emergency core coo, ling actuation signal (ECCAS). In addition to being a personnel safety hazard, the potential exists for short circuit /flashover, which could render the valves inoperative.

B. Environmental Qualification During random inspection for underrated terminal blocks, it was discovered that, in some cases, terminal blocks were used from manufacturers not covered by existing qualification reports.

Limitorque provided the following information on environmental qualifi-cation of terminal blocks in its July 31, 1981, letter to Bechtel.

The Buchanan 0524 has been qualified by analysis. To supple-ment the qualification by analysis, Limitorque is currently running a type test on the Buchanan 0524 terminal block. The Buchanan 0824 terminal blocks are not qualified and must be replaced.

otachment 1 IN 83-72 October 28, 1983 Page 14 of 16 l EquipmentEnvironmentalQualificationNoticeNo.[4 '

GENERIC QA PROBLEMS IN THE EQUIPMENT QUALIFICATION INDUSTRY The NRC has performed several QA programmatic reviews of companies and labora-tory facilities that perform tests to environmentally qualify safety-related electrical equipment used in the harsh environment. This effort was started in late August 1982 to assess the testing organization's establishment and imple-mentation of the QA program based on 10 CFR Part 50, Appendix B criteria.

During these QA programmatic reviews, several generic problems related to the testing industry were identified. They are as follows:

1. Organizations (architect engineers (AEs), manufacturers, suppliers ,and testing laboratories) have failed to include 10 CFR Part 50, Appendix 8 or equivalent quality requirements and 10 CFR Part 21 requirements in purchase orders or contracts. In one case a testing laboratory was performing environmental qualification testing without knowing it was testing safety-related electrical equipment, because the purchase order of contract did not include quality control or 10 CFR Part 21 requirements.

NRC inspectors have identified many similar failures to pass on require- ~

ments between involved organizations. The NRC considers this to be a serious problem because testing without knowing the criticality of the equipment being tested would likely result in less caution during testing and little concern relative to deviation or defect reporting in accordance with 10 CFR Part 21.

o 2. A few testing facilities failed to establish and implement a QA program.

Other testing facilities failed to properly implement 10 CFR Part 21.

3. The majority of the manufacturing test facilities and testing organizations inspected had QA programs that were deficient or nonconforming. The serious-ness of these nonconformances ranged from no QA program to less serious nonconformances such as failing to follow procedures.

4. The generic problems described above have in most cases, been caused by the test organization's customers (manufacturer, AE, or licensee). That is, these upline customers have failed to pass on NRC requirements in procurement documents, failing to ensure that QA programs were established and properly implemented. It is apparent that the audit process (licensee to lowest subcontract tier) is not working properly. A vecent example was identified in which three utilities and five AEs had performed audits of the vendor's QA program for manufacturing but had not audited the EQ test program to ensure proper establishment / implementation of the QA program.

J, f '

\ ..ctachment 1 IN 83-72 October 28, 1983 Page 15 of 16 Equipment Environmental Qualification Notice No. 25 (Cont.)

Description of Circumstances (Cont.):

Some of the Limitorque operators having Buchanan 0824 type terminal blocks have been used on safety-related valves located inside containment. These operators must function on an ECCAS. The potential exists for a terminal block to fail during its intended service life because of aging and radiation effects, which would render the valve inoperable and prevent proper operation of the safety-related system.

C. Additional Qualification Concerns

~

During the month of June 1982, a random inspection was made of safety-1, related Limitorque valve operators supplied through various valve manu-facturers and installed inside the reactor building. This inspection resulted in various potential concerns regarding qual'.'ication of these Limitorque operators.

These concerns are:

1. The motor nameplate ambient temperature rating on various motors installed on some Limitorque operators is 40*C. Limitorque has

! verbally stated that the Class B insulation motors rated for a 40*C ambient temperature have not undergone qualification testing in accordance with IEEE Std 382-1972 for the specified normal, accident, and postaccident environment. Class H insulation motors o

are rated for 50 C ambient temperature, but the qualification testing

' in accordance with IEEE Std 382-1972 for these motors is presently unknown.

2. No identification was evident on certain materials internal to the Limitorque operators (e.g., wiring, insulation, etc.). It is not presently known whether these types are qualified for the service conditions, j 3. Various orientations of installed operators were observed. It is

not presently known whether the operators are qualified for all installed orientations.

4. Drain plugs on operators were observed to be both in place and removed. Orientation of the operators did not always result in the drain holes being at the lowest point of the installed operator. It is not presently known whether the existence of the drain plug or j the orientation of the drain hole is essential to proper operation of the operator or is in conformance with the qualification tests for the operator.

l i

S. Various Limitorque operator limit switch gear frames were observed to be made of a white metal. It is not presently known whether these gear frames are qualified for the service conditions.

- - , - - . .+3-,-- _%,m-.,yy---y-.-y---. _ ,,-mm ..-_w-%_., e, ,. ,yy,. ,--,y,- ,w,,.-%.--.._,-.y y --

,,...yo.-._.,w.py-w.4-

y.

(

\ .tachment 1 e ,

IN 83-72 October 28, 1983 Page 16 of 16 Equipment Environmental Qualification Notice No. 25 (Cont.)

. Description of Circumstances: (Cont.)

6. Information obtained from purchase order files and qualification files does not agree with the installed components.

7. It is presently not known whether space heaters are qualified or required to be qualified.

8. Various 0 rings are located throughout the actuator. It is not presently known whether these components are qualified for the service conditions. . .

9. Unidentifiable terminal blocks (nonpower lead connectors inside the operators) were observed in other Limitorque operators. It is not presently known whether these components are qualified for the service conditions. '

O

. . . . . - - .-