IR 05000461/1987026

Safety Insp Rept 50-461/87-26 on 870817-1013.Violation & Deficiencies Noted.Major Areas Inspected:Environ Qualification (EQ) of safety-related Equipment within Scope of 10CFR50.49,including Adequacy of EQ Documentation

ML20236K267
Person / Time
Site:	Clinton
Issue date:	11/05/1987
From:	Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236K255	List: IR 05000461/1987026 ML20236K252 ML20236K263
References
50-461-87-26, IEB-79-01, IEB-79-1, NUDOCS 8711090172
Download: ML20236K267 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

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TjfGT)NIII Report No. 50-461/87026(DRS)

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Docket No. 50-461 License No. NPF-62-l Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 4 l

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Facility Name: Clintan Nuclear Station

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Inspection At: Clinton Site, Morris, Illinois Glen Ellyn, Illinois ,

i Inspection Conducted: August 17 through October 13, 1987 Inspector: Anil S. Gautam f Iff'-

Reactor Inspector, Region IU llf5l$l '

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Also participating in the inspection and cc,ntdibuting to the report were:

i M. Kopp, RIII / j J. Jacobson, NRR ,

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H. Stromberg, Idaho National Engineering Labs (INEL) .j

M. Trojovsky, INEL K. Iepson, Schneider Associates ' -'

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M. Jacobus, Sandia National Labs l E. Claiborne, Sandia >-

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Approved By: Ronald N Gardner, Chief 016 M Plarat Systems Section, Region III Date l

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i Inspection Summary l Inspection on August 17 through October _13, 1987 (Report No. 50-461/87026(DRS))

Areas Inspected: Special announced safety inspection of the environmental qualification (EQ) of electric equipment within the scope of 10 CFR 50.4 The inspection included licensee action on SER/TER commitments; EQ program comoliance to 10 CFR S0.49; adequacy of EQ documentation, and a plant physical inspection of EQ equipment (Modules No. 30703, No. 25576, and No. 25587).

Results: The licensee has implemented a program to meet the regJirements of 10 CFR 50,4 Deficiencies in the areas inspected are summarized below:

O172 B71106 hA0l DOCKPDR05000461 G

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VIOLATION ~ l

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50-461/87026-03- 10 CFR 5049 designated ASCO

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6c(1)(2)(3)(4)

[a,b,c,d](DRS) solenoid valve ~, junction box,

'LPCS motor, fuel pool' cooling pump-installed in an unqualifie configuratio POTENTIALLY ENFORCEABLE / UNRESOLVED ITEMS Item N Description Report Section L 50-461/87026 201(DRS) Unqualified nylon wire. cap '6a.- ~on Limitorque 480V power ;1ead /87026-02(DRS). Unqualified KYNAR AMP _ electrica b butt splices in power,' control'

.and instrument circuit ..

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Item N Description Report Section-

50-461/87026-04(DRS) Failure analysis to justify 6d: ,3 unqualified T drain location-on_Limitorque actuator'1SX095 ~q

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DETAILS ,

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- Persons Contacted .] Illinois Power Company (IP)

W. C. Gerstner, Executive Vice, President ,

, , * P. Hall, Vice President  :{

• J. G. Cook, Assistant Plant Manager

• J. D. Weaver, Director, Licensin jl

• A. Till, Director,' Nuclear" Training . l

• R. T. Kerestes,: Director, NSED

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A. L. Ruwe, Director, Outage Maintenance Support G. 'W. ' Miller, Director, Fiscal Management '

• D. L. Holtzscher, Director, Nuclear Safety-

• J. A. Miller, Manager, Scheduling /0utage Maintenance l

• R. E. Campbell, Manager, Quality Assurance

• W. Conner, Manager, Nuclear Planning and Suppor *R. Freeman, Manager l

• J. S. Perri,-Manager, Nuclear. Program Coordination-

• J. Greenwood, Manager,-Power Supply F. A. Spangenburg, Manager, Licensing and Safety

• T. J. Camiller, Assistant Manager.. Maintenance

• S. E. Rasor, Project Manager, Maintenance

+*M. E. D' Haem, Supervising Specialist,.EQ

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'*S. Clary,' Supervisor, Procurement

• J. R. Dodson,-Supervisor, Nuclear Communications- ;l'

• D. W. Wilson, Supervisor, Licensing Administration Consultants to the Licensee ,

• D. K. Schopfer, Project Manager, Sar. gent &:Lundy (S&L). U.S. Nuclear Regulatory Commission (USNRC)

• Hiland, Senior Resident Inspector, RIII S. Ray, Resident Inspector, RIII

• B. L. Siegel, Project Manager, NRR

• A. Wang, Enforcement' Coordinator, NRR .{

• Denotes those attending the interim site exit meeting on August 21, 198 + Denotes those participating'in the telephone exit. interview on October 13, 1987, at the conclusion of the inspectio . Licensee Action on SER/TER Commitments .

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The NRC inspection . team evaluated the implementation of .the licensee's:

.EQ corrective action commitments made as:a result of.EQ deficiencies,. ,

.l identified by the NRC during.a limited site. inspection on March'11-14,_ 1 1985=and noted in Section 3.11.4 of SSER 5,;(January.1986) to the Clinton- ,

FSAR.-

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l The majority of.the deficiencies identified in the SG addressed j documentation, similarity, aging, qualified life, and replacement schedules. All open items identified in the SER were discussed with the NRC staff, and the licensee's proposed resolutions to these items were found acceptable by the NRC, as stated in Section 3.11'of SSER (March 1987), included in the plant FSAR. The primary objective of the Region III EQ Audit in this area was to verify that appropriate analyses '

and necessary documentation to support the licensee's proposed and accepted resolutions to NRR issues were contained in the licensee's EQ I files, and that appropriate modifications or replacements of equipment {

had been implemente J l

During this review, the NRC. inspection team selectively reviewed EQ

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j documentation and examined equipment in the plant relevant to prior .!

discrepancies identified in the SER. The-licensee was found to have 1 implemented their SSER commitments. Exceptions in documentation and ]

equipment inspected are noted in appropriate sections of this repor l 3. (Closed - TI 2515/87) Review of Licensee Implementation of Regulatory i Guide 1.97 l The inspectors reviewed the licensee's effort in qualifying Regulatory Guide 1.97 equipment within the scope of 10 CFR 50.59 Paragraph (b)(3).

During this review, the inspectors observed that the licensee had submitted i their Regulatory Guide 1.97 responses on September 9, 1983 and December 11, 1984 to NRR, and that the NRC addressed the licensee's responses in SSER 5, dated January 1986 and SSER 8, dated March 198 The inspectors performed a Regulatory Guide:1.97 review in accordance with the requirements of NRC Temporary Instruction 2515/87. Areas reviewed included verifying the adequacy of the licensee's Regulatory Guide 1.97 ;

lists; inclusion of the Regulatory Guide 1.97 Category I and II items in the licensee's 10 CFR 50.49 list; verification that selected Regulatory Guide 1.97 items had redundancy, physical separation, isolation, and uncompromised independent power supplies; field examination of selected Regulatory Guide 1.97 items; and verification of maintenance and surveillance activities performed on Regulatory Guide 1.97 items installed in the plan The following variables were selected for the Regulatory Guide 1.97 audi * Reactor Water Level, Category 1, Types A'and B

• Reactor Pressure, Category 1, Types A, B, and C ,

• Status of Standby Power Supplies, Category 2,. Type D t

• Drywell Pressure, Category 1, Types A, B, C, and D

• SRV Position Indication, Category 2, Type D

• Suppression Pool Water Temperature, Categcry 1, Types A and D The power supplies for each of the Category 1 variables selected for the audit were verified to either be powered from their respective divisional

. Class.1E diesel generator buses or from their respective divisional

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i Class 1E uninterruptible power supplies.(NSPS system). The inspector' ')

confirmed that those instrument loops powered from the NSPS system do not lose power on a loss of offsite power where as those powered from their respective divisional diesel generator buses lose power for approximately 12 seconds. The instruments that do suffer a momentary power loss are not shed from their respective power supplies (i.e., they are "0" sequenced).

Table 4.3.7.5-1 of the licensee's Technical Specification which specifies the calibration and channel check frequencies, was reviewed to ensure that a testing program was in place to ensure the proper operation of the RG 1.97 Category 1 instrumentation. The calibration data sheets that resulted from loop calibrations and the results of the loop calibrations performed on Category 1 instruments'were reviewed to ensure that the instrumentation was tested to the required range Physical separation of the sensors in redundant instrument loops was-verified during the walkdown along with verifying-instrument manufacturer, -'

make and model (were possible). In circumstances where it was not possible to verify pertinent name plate data during the walkdown (such as the Weed RTDs used to monitor the suppression pool water temperature) additional installation documentation was reviewed to verify identification of the installed equipment. A visual inspection of the indicators in the main control room was performed to ensure that the indicators were properly ,

identified as required by RG 1.97. The licensee has incorporated a silver triangle on the meter housings of their RG 1.97 indicators to address this requirement. Each of the Category 1 variables selected for the audit was' reviewed to ensure that the licensee had met the minimum recording requirements of RG 1.9 The Clinton Station Regulatory Guide 1.97 SER was reviewed to identify any outstanding deficiencies and to ensure-that licensee commitments j were being implemente As a result of this review, it was found that i the licensee deviated from the RG 1.97 requirements in regard to th !

neutron flux detectors and the Reactor Pressure . Vessel (RPV) water level (fuel zone range only) indicators. The inspectors observed that in an Illinois Power Company (IPC) letter dated December 11, 1984, from i F. A. Spangenberg to A. Schwencer, the licensee had committed to upgrade !

their neutron flux detectors when replacements were available to the industry; and to provide Class 1E power to the fuel zone RPV water-level indicators before startup after the first refueling outage scheduled for January 198 The licensee will inform Region III in regard to their Implementation of these commitments and appropriate activities will be reviewed by the NRC during a followup inspectio No violations of NRC requirements were identifie . EQ Program Compliance to 10 CFR 50.49 The inspector reviewed selected areas of the licensee's EQ program to verify compliance to 10 CFR 50.49. The licensee's EQ program was found to identify methods of equipment qualification; provide for evaluation

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and maintenance of EQ documentation in an auditable form, including maintenance records; provide for updating of replacement equipment, and control of plant modification Based on their. review, the inspectors determined that the licensee had established an adequate EQ program in compliance with the requirements of 10 CFR 50.49. The licensee's' methods for establishing and maintaining the environmental qualification of electrical equipment were reviewed in the following areas: EQ Program Procedures  !

The inspectors examined the adequacy of the licensee's policies and procedures for establishing and maintaining the environmental qualification of equipment within the scope of 10 CFR 50.49. The licensee's EQ program was reviewed-for procurement of qualified i equipment; maintenance of qualified equipment; modification to the plant that could affect qualified equipment; updating of the EQ master list; and review and approval of EQ documentatio l'

Procedures reviewed included the following documents:

• Station Preventative Maintenance, CPS 1034.01, Revision 10,~

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• Maintenance Procedure, CPS 8801,04, Revision 9, 5/15/87 l

• Maintenance Procedure, CPS 8801.14, Revision 6, 5/27/87

• Surveillance Procedure, ECCS Rx Vessel Water Level, CPS'9433, l Revision 21, 7/11/84

• HPCS Pump Motor Maintenance, CPS 8513, Revision 1, 7/8/86

• LPCS Pump Motor Maintenance, CPS 8515, Revision 1, 7/8/86

• Preparation and Routing MWRs, CPS 1029-01, Revision 17, 4/14/87

• Preparation, Review, Approval, and Issuance of P.O./ Contracts, N P&S 5.05, Revision 2, 1/5/87 i

• RHR Pump Motor Maintenance, CPS 8522-01, Revision 1, 2/8/86 ,

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• Initiating and Processing Requisition, Procedure P.O., i Revision 7, 7/18/86-l >

• Product Acceptance, QAP 107.01, Revision 8, 1/28/87 I l

• Quality Verification Plan, QAP 110.02, Revision 3 )

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• Development of Performance Based Training, Procedure 5.3,  ;

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Specific areas reviewed in these procedures included definition of harsh and mild. environments,-equipment qualified, service conditions, periodic testing, maintenance and surveil. lance, and upgrading of replacemer,t equipment purchased after February 22, 198 No violations of NRC requirements were identified, b. 10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment IE Bulletin No.79-018 required licensees of all power reacto'r facilities with an operating license to ' provide a MEL that identified each Class 1E electrical equipment item relied upon to perform a-safety function durirg a design basis even CFR 50.49, Paragraph (d), requires licensees to prepare a. list of electrical equipment important to safety and within the ' scope of the ' rul The NRC inspectors reviewed the licensee's MEL for compliance to 10 CFR 50.49. Areas reviewed included adequacy of the MEL, technical justifications for removal'of items from the MEL, and licensee reviews of the MEL for changes due to field modification The inspectors verified the completeness / adequacy of the lists in terms of equipment needed during accident conditions, through review of piping and instrumentation drawings (P& ids), emergency procedures, technical specifications, and FSAR i No violations of NRC requirements were identifie .!

c. EQ Maintenance and Surveillance Program The inspector reviewed specific maintenance, replacement, surveillance tests, and inspections necessary to preserve the i environmental qualification of EQ equipment identified on the ME EQ requirements in the licensee's maintenance procedures and EQ binders were reviewed against maintenance records of i selected equipment to verify performance of maintenance and surveillance activities at prescribed intervals, including gasket inspection, lubrication, torquing of housing covers and installation of replacement parts. The following exception was identified:

The EQ documentation for PYC0 thermocouple requires that the PYC0 housing covers be torqued to 50 ft-lbs. This requirement was not found to be implemented. Subsequent to this finding the licensee initiated Maintenance Request C-52705, dated 8/20/87, to ensure that the housing covers were torqued to 50-ft-lbs. The licensee also demonstrated that the PYC0 thermocouple in question were being removed from the EQ list with adequate technical justificatio No violations of NRC requirements were identifie .

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. Plant Procurement and Upgrading of Replacement Equipment ]j Procurement procedures and documents were found to adequately address appropriate quality and regulatory. requirements regarding the environmental qualification of equipment within the scope of 10 CFR 50.4 !

For example, Purchase Order P.O. No. 501219 was reviewed by the inspectors for evidence of incitsion of EQ requirements. This purchase order was for the refurbishment of three Limitorque motor The procurement document was found to have invoked all appropriate environmental standard No violations of NRC requirements were identifie Quality Assurance (QA) and Training Program During this review, the inspectors determined that the licensee had implemented a program to monitor the quality of EQ activities through surveillance, audits, and reviews of the records and files for plant modifications and equipment procurement. NRC inspectors !

reviewed the licensee's QA audits including Audit Nos. Q 38-87-22, Q 38-87-09, and Q 38-87-3 The inspectors found the methodology, results, and followup corrective action relative to the audit acceptabl No NRC concerns were identifie i The NRC inspectors also reviewed the licensee's staff training program and associated records relative to the performance of EQ 4 activitie The training records indicated that the licensee had I implemented a training program for key personnel, including management, i operations and maintenance personnel responsible for EQ activitie I The training program was found to adequately address key aspects of 10 CFR 50.49 requirements and the licensee has incorporated EQ i training into an ongoing training program for appropriate' plant personne i No violations of NRC requirements were identifie . Detailed Review of Qualification Files The licensee qualified their 10 CFR 50.49 designatec EQ equipment to the requirements of the NUREG-0588 Category 1 (10 CFR 50.49, Paragraph K).

The inspectors reviewed over 50 equipment qualification files ior evidence-of the environmental qualification of equipment within the scope of 10 CFR 50.49 and evidence of equipment qualification to NUREG-0588' ;

Category I. Files were found to include a full description of the equipment; similarity analysis of tested equipment to_that installed in the plant; allowed mounting methods and orientation; qualification of interfaces (conduit housings, seal, etc.); evaluation of aging effects on equipment; description of test sequence and methodology; environmental l

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condi' . tons for the equipment during an accident;; qualification for

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subme.gerce of' applicable equipment;. resolution of; test anomalies; and p4 maintenance / surveillance criteria for the preservation of thel qual _ified-

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The inspectors selectively reviewed the above. areas as applicable,-

i including special reviews.for the~ required duration of_ operability of equipment; licensee evaluation of tested materials 'and ~ configurations relative to actual plant installations; adequacy of test conditions; . i aging' calculations for qualified life and replacement intervals; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy of equipment and. interfaces during an accident; and licensee evaluations of discrepancies, identified in IE_ Notices.an N Bulletin EQ ' files were reviewed for electrical cables, cable. splices, terminations,.

terminal. blocks, electric motors,' solenoid valves, electrical penetrations, ,

seals, lubricants,. transmitters, temperature elements, radiation monitors, control and position switches, switch gear, control panels, and'

miscellaneous electrical devices. The inspectors found that in almost all cases the files allowed verification of. equipment qualification for-accident conditions. In.some instances', the inspectors questioned the

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adequacy of the'EQ documentation; however, thellicensee provided actual-

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test data and references to mitigate concerns ~. q

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a Details are noted below: j i Instrument Accuracy and Setpoint Calculations 1

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During review of qualification documentation forLvarious instruments, 1 the inspector:s observed that in many. cases the accuracy stated on- i the SCEW sheets was not adequately supported by the' test documentation

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on which they were based. Adequate discussions had.not'been provided ~ 1 in the files to address such discrepancies. Subsequent:to this NRC concern the licensee provided additional. calculations'and references' 1 to mitigate the concerns. The licensee agreed to enhance their. files: . I to make them auditable in regard to the adequacy of'the demonstrated-accuracy of the EQ instruments. . The"following examples were noced: ,

(1) WEED Resistance Temperature Detectorsi(RTDs)

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The licensee did not monitor the accuracy of the.RTDs duringL the LOCA test' exposure. The licensee ~ enhanced their file to include information regarding the accuracy.of the RTDS.during; the LOCA' exposure. No further concerns were identified.- ,

(2) Rosemount Model 1153 and 1154 Transmitters During,the review of the EQ files, the inspectors note'd tha the.specified accuracy.of the transmitters-was 0.25% of calibrated span, however, the demonstrated. accident accuracy-was within 8%Jof the U.R.L. This.' discrepancy was.not addressed in the.EQ Binde .

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The licensee stated that the specified accuracy of 0.25% of span was a nominal accuracy only and that actual accuracies i from the report were used in the setpoint calculations done ,

per Regulatory Guide 1.105. The licensee was informed that i the specified accuracy shown on the SCEW sheet.should reflect l the device specific requirements.ar.d demonstrated values. The licensee revised their files to provide these clarification No further concerns were identifie n (3) MCC Powers Temperature Detector (MINCo RTD No. 555-722/Kulka Terminal Block No. 600)

File: EQ-CLO33 ,

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During review of the EQ files, the inspectors noted that no !

functional data from the RTO during the radiation and LOCA-test phases was presented despite statements made in the. report that the devices were " monitored." The licensee stated that although the performance of the RTDs was monitored during 1 irradiation and DBA testing, the readings were not recorde j The licensee stated that since the accident duration for these ;

RTDs lasted only 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and the steady state temperature ;

during the accident was only 150 F their functional adequacy was i demonstrated during the LOC To mitigate NRC concerns the licensee obtained additional j relevant data to document the functional capability of the 1 equipment and enhance their EQ file No further concerns !

were identifie j i PYC0 Temperature Elements f

During review of the EQ files, the inspectors noted that the test' I specimens had covers retorqued after thermal aging and prior to the- ;

LOCA aging. The inspectors considered this action a repair made i during the test and were concerned that this may have invalidated-

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test result The licensee reviewed their files and stated the the PYC0 temperature elements were not within the scope of 10 CFR 50.49 and would be removed )

from their EQ program. These instruments are also discussed in Section 4c of this repor No further concerns were identifie i l

6. Plant Physical Inspection {

I The NRC inspectors selected over 40 items on the MEL for examination in !

the plant. The EQ file of each item had been reviewed, and information j regarding the location, manufacturer, model/ serial number, mounting, i i

orientation, environment, and interfaces had been note The inspectors examined the selected items in the field, as accessibie, and verified q that the method of installation of each item was not in conflict with j its environmental qualificatio Specific areas reviewed included *

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traceability of installed items of EQ equipment, ambient environmental conditions, qualification of interfaces (connectors, wires, seals, insulation, lubricants, etc.), evidence of significant temperature I rise due to process, drainage, mounting methods, physical conditions and )

housekeepin In almost all cases, items examined in the field during this walkdown were found to meet their appropriate EQ requirements with the following exception: Nylon Wire Caps in Limitorque Actuators l

Limitorque Actuator ICC072 was examined by the inspectors in the l auxiliary buildin The inspectors noted the use.of three nylon l wire caps to terminate six of the nine 480V motor leads. The licensee j confirmed that nylon wire caps had been installed in approximately ninety dual voltage 10 CFR 50.49 designated Limitorque actuators in i the auxiliary and fuel building These actuators see.the following profiles: i l

Normal Accident Temperature 150"F .

285 F  ;

Pressure -1 to 0.1" l 9 psig j Relative Humidity 90% l 100%/ Steam Radiation 1 x 104 Rads l 1.1 x 107 Rads Spray N/A l None j The licensee stated that Limitorque Test Reports No. 600376A and No. B003 demonstrated equipment qualification, and that a Limitorque ,

letter dated August 20, 1987, confirmed that these wire caps were I used during these tests. The inspectors, however, found no evidence in the reports that the wire caps were tested and required the licensee to demonstrate through additional test data records, )

the type / size, configuration and application in which the nylon '

wire caps were tested. The licensee could not provide additional information. The inspectors informed the licensee that Limitorque actuators containing these wire caps were unqualified based on <

inadequate qualification documentation. The inspectors also informed the licensee that they were required to immediately prepare a Justification for Continued Operation (JCO) for review by the NR The licensee took immediate corrective action and submitted a JC0 to Region III on August 28, 1987. This JC0 took credit for a Wyle Test, Report No. 17943-1 dated August 21, 1987, conducted by the licensee subsequent to the NRC finding but during this EQ inspectio In the Wyle Test, the licensee subjected an SMB-0 Limitorque actuator-to a 100% steam environment at elevated temperatures and pressure with nylon wire caps in an appropriate configuration. No failures were noted in that the actuator cycled, however, the nylon wire caps'were not therma'lly or radiation aged. The licensee has committed to conduct an additional test at Wyle in. full compliance to 10 CFR 50.49,

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NUREG-0588 Category I, and to submit a final report by February 12, 1988. The inspectors considered the licensee's prompt action in conducting this test very responsible, in regard to ensuring.the safety of the plan In the JCO, the licensee also evaluated the operability of 90 actuators with dual voltage motor Eighty-three were identified _3 by the licensee to be operable in the event of a postulated accident despite the wire caps. Seven actuators were identified to be compromised, and the licensee immediately replaced.the wire caps in these. actuators with Raychem splices. The JC0 took credit for

location, redundancy, duration, application, and the position'of the-actuators if a failure occurre No immediate NRC safety concerns were identifie !

Pending review of additional testing at Wyle by the licensee to demonstrate the qualification of the nylon wire caps, this is a Potentially Enforceable / Unresolved Item (50-461/87026-01(DRS)).

b. AMP KYNAR Splices in Limitorque Actuators During examination of Limitorque Actuator E51-F010 in the auxiliary building, the inspectors observed the use of AMP KYNAR (Polyvinylidene l Fluoride) butt splices on 480V motor leads. The licensee confirmed that these splices had been used in various instances inside and ,

outside the containment in instrument, control, and power circuits, j and that- plant specification K-2999 allowed the use of these . splices l when leads were found too short to terminate. The licensee's EQ files, however, did not have adequate documentation to qualify these j splices, in that plant spcific configurations were not tested in I postulated accident environment The inspectors informed the licensee that actuators containing these splices'were unqualified based on inadequate documentation and'.that thc licensee was required to immediately prepare a JC0 for review by the NR The KYNAR Splices are exposed to the following profiles: I Normal l- Accident-Temperature 104 -150 F l 345 F Radiation 5 x 107 Rads l 2 x 108 Raos Pressure 12" of water) 33 psig Relative Humidity 90% RH l 100% RH/ Steam Spray N/A l Demineralized I water spray The licensee took immediate corrective action ar.d submitted a JC0 to Region III on August 28, 1987. This JC0 took credit for'a Wyle test conducted by the licensee on-August 21, 1987,-subsequent to the NR finding, but during the EQ inspection. In the Wyle test (Report No. 17943-2) AMP KYNAR butt splices were: exposed to a 100% steam ;

and water spray environment at elevated temperature and pressure while monitoring circuit integrity. No failures were.noted,

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however, these splices were not thermally or radiation aged nor given the radiation exposure postulated during an accident. The licensee has committed to conduct an additional test at Wyle in full compliance. to 10 CFR 50.49, NUREG-0588 Category I and to submit a final report by February 12, 198 ,

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In their JCO, the licensee stated that based on their review,  ;

information on specific locations of AMP splices in instrument and 1 control circuits was not immediately availabl The licensee j stated, however, that the Wyle test provided an adequate basis for j the qualification of these circuit The licensee did identify ten l actuators where the AMP splices were used in power circuits, and submitted an operability analysis for these actuators assuming splice failure during accident condition The operability analysis took j credit for location, duration, redundancy, application, and.the position of the actuators during an accident. No immediate NRC safety j

I concerns were identified in regard to the JCO. Pending review of_the i results of the additional testing of these splices at Wyle, this is a l Potentially Enforceable / Unresolved Item (50-461/87026-02(DRS)).

c. The following deficiencies were considered in violation of f 10 CFR 50.4 I i

(3) ASCO Solenoid Valves, ORA 027 1 q

During the plant walkdown, two concerns were identifie I l

The first concern involved Valve ORA 027. Based on their file 1 review the inspectors had determined that this valve was used {

for " breathing air isolation" and that it was qualified based on

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it being Energized for less than one hour each_ mont During the field examination, the inspectors noted that'this valve was continuously energized for much longer periods. The inspectors were concerned that such operation would affect the qualified life of the solenoid valve. The licensee took immediate corrective action and recalculated the qualified life of this valve to be 9.13 year The licensee also established a new replacement schedule (50-461/87026-03a(DRS)).

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(2) Junction Box 1JB673 This junction box had a top conduit entry and contained a l Marathon terminal block, however, there were no provisions for i moisture removal during an accident (no weep holes). .The j licensee confirmed the box was in a HELB environment and issue Condition Report No. 1-87-08-081 to install weep holes in the j box (50-461/87026-03b(DRS)).

The licensee also stated that ASCO Solenoid Valve 1E12-F0658, )

which is: energized from this terminal block, would have failed i to an accident safe position if the terminal block was

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(3) Low Pressure Core Spray Motor (IE21-C001)

i During the plant walkdown, the inspectors identified an oil leak from the upper motor bearing drain plug onto the motor ,

case. The licensee committed to correct the leakage and j issued MWR No. C40312 (50-461/87026-03c(DRS)).

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(4) Fuel Pool Cooling Pump (1FC02PA)

During the plant walkdown, the following discrepancies were noted:

(a) One bolt on this motor connection box was missin '!

(b) There was rust on the motor connection box sealing j surfac {

i (c) The thermocouple connection box cover was broken and there was no gaske (d) The pump inboard bearing had little or no oil in it.

l i (e) There was a pool of oil on the floor under the pump  !

outboard hearing.

l l The licensee took immediate corrective action 'and generated work orders to make repairs- The licensee also stated that

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this pump would not be needed until after the first fuel 1 l outage, and that Modification FC-12 had been issued to replace i the existing unqualified pump motors prior to the first refueling j outage. The licensee issued MWR C37556 to address the oil {

1eakage (50-461/87026-03d(DRS)).

]i 10 CFR 50.49, Paragraph (f), requires licensees to environmentally J quslify equipment important to safety by-testing and analysi <

The licensee was informed that deficiencies described in i Sections 6c(1), (2), (3), and (4) were considered examples of i a violation of 10 CFR 50.49 Paragraph (f), failure to qualify l

, equipment in their installed conditio This is a Severity l Level V violation (Supplement IE) (50-461/87026-03[a,b.c,d](DRS)).

d. T Drain on Limitorque Actuators 1SXO95A and IE51F045 Limitorque Actuator 1SX095A (inside the containment) was found installed in a position such that the.T drain could not provide drainage for condensate during an acciden The licensee stated that they could provide a failure analysis to demonstrate that this ,

actuator was not within the scope of 10 CFR 50.49 and that its failure would not affect other. safety equipment or mislead the operato The inspectors had no immediate safety concerns regarding i this actuator. Pending review of the licensee's failure analysis, l this is an Open Item (50-461/87026-04(DRS)).

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Limitorque Actuator 1E51F045 was found installed without a T drain !

outside the containment. The licensee's EQ File CL-009 which contained Limitorque Reports No. 600376A and B0009,. qualified -l

actuators with T drains installed. The licensee demonstrated that i this actuator could also be qualified by Limitorque Reports No. B0003 -l and B0058 which did not require T drains on the tested actuator No I further concerns were identifie pamper 1"R034V Blocked by Cables 1 During the plant walkdown, a compartment damper between the General Containment Area and the Steam Tunnel was found blocked open to facilitate routing of some temporary cables. The routing was such that the cables prevented the damper from closing. The licensee was requested to provide documentation demonstrating that this installation had received a 50.59 safety revie The licensee stated " . . . Damper IVR034Y, per K-2903, is classified ,

as non safety-relate It is normally open to allow air from the l general area to the steam pipe tunnel. In the event of a High Energy l Line Break in the steam tunnel, it would fail open. The consequences of this failure were addressed when worst case environmental conditions {

for adjoining areas were established. The cable routed through i Damper IVR034Y therefore does not impact equipment environmental !

quali fication. " No further NRC concerns were identifie KULKA Terminal Block i During examination of Resistance Temperature Detector (RTD) ITE-VY001 in the field, the inspectors noted a KULKA terminal block installed in the RTD to have broken / cracked barrier The licensee demonstrated j that this deficiency did not affect plant safety based on the 1 application of this RT The licensee issued MWR No. C40298 to j correct the problem and agreed to review six other RTDs for a  ;

similar problem. No further concerns were identifie I 1 Valcor Solenoid Valve IPSO 44b j During tne inspection, the inspectors observed that Check Valve 1E12F0318 i was leaking water onto the valve section oi' the solenoid valve assembl '

The solenoid valve was scaled for water intrusion, however, the licensee took immediate corrective action and issued maintenance request MWR No. C40311 to stop the leakage. No further concerns were identifie . Open Items Open Item 3 are matters which have been discussed with the licensee, which f will be reviewed further by the inspector, and which involve some action

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on the part of the NRC or licensee or bot An Open Item disclosed during this inspectien is discussed in Paragraph 6d.

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8. Potentially Enforceable / Unresolved Item An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violatio Potentially Enforceable / Unresolved Items-are unresolved items, which if ascertained to be a violation may be followed up with enforcement action in accordance with NRC enforcement guidance on environmental qualificatio Potentially Enforceable / Unresolved Items are discussed in Paragraphs 6a and 6 . Exit Interview The Region III inspectors met with the licensee's representatives (denoted under Paragraph 1) during an interim exit on August 21, 1987, and discussed t their findings by phone at the conclusion of the inspection on October 13, 1087. The inspectors summarized the purpost and findings of the inspection and the licensee acknowledged this information. The licensee did not identify any documents / processes reviewed during the' inspection as proprietar ,

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