IR 05000155/1986013

Safety Insp Rept 50-155/86-13 on 860915-19.Deficiencies Noted.Major Areas Inspected:Environ Qualification of Electrical Equipment within Scope of 10CFR50.49 & Licensee Action on SER Commitments

ML20215N847
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/04/1986
From:	Gautam A, Muffett J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215N842	List: IR 05000155/1986013 ML20215N841
References
50-155-86-13-01, 50-155-86-13-1, NUDOCS 8611070338
Download: ML20215N847 (17)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/86013(DRS)

Docket No.~50-135 License No. OPR-06 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, Michigan.49201 Facility Name: Big Rock Point Nuclear Plant-Inspection At: Charlevoix, MI Inspection Conducted: September 15 through 19, 1986 Inspector: A. S. Gautam, *

Reactor Inspector, RIII Date Also participating in the inspection and contributing to the report were:

J. W. Muffett, Section Chief, RIII R. J. Smeenge, Reactor Inspector, RIII R. Lasky, Engineer, I&E M. Jacobus, Technical Staff Engineer, Sandia National Laboratories M. Yost, Consultant Engineer, Idaho National Engineering Laboratory D. Jackson, Consultant Engineer, Idaho National Engineering Laboratory Approved By: J. W. Muffett, Section Chief ~

H!4!Ob Plant Systems Section Date Inspection Summary Inspection on September 15 through 19, 1986 (Report No. 50-155/86013(DRS)

Areas Inspected: Special announced safety inspection of the environmental qualification of electrical equipment within the scope of 10 CFR 50.4 The inspection included licensee action on SER/TER commitments; environmental qualification (EQ) program compliance to 10 CFR 50.49; adequacy of equipment EQ files; and a plant physical inspection of EQ equipment (Mo~dule Nos. 30703 and 25176). ~

Results: The licensee has implemented a program to meet the~ requirements'of 10 CFR 50.4 Certain deficiencies were identified in the areas inspected and are listed belo PDR ADOCK 05000155 G PDR

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POTENTIAL ENFORCEMENT / UNRESOLVED ITEMS Item Numbers Description Report Section

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50-155/86013-01(DRS) Inadequate implementation of 2

- SER/TER commitment regarding the-qualification of Polyethylene and

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! Butyl Rubber insulated cables 50-155/86013-05(DRS) Limitorque Actuator M0-7068 not 4a qualified to D0R Guidelines-for operation in a Design Basis Accident

(DBA) due to unqualified materials 50-155/86013-06(DRS) Rotork Actuator MO-7072 not 4b qualified to D0R Guidelines for operation in a DBA due to unqualified materials 50-155/86013-07(DRS) Flow Transmitter FT-2162 not 4c

qualified for intended function,

! past the November 30,1985,EQ j deadline

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50-155/86013-12(DRS) Limitorque Actuator M0-7080 found Sa unqualified to D0R guidelines due to broken terminal block barriers

OPEN IlEMS Item Numbers Description Report Section '

50-155/86013-02(DRS) Items removed from.the MEL 3b(1)

still relied on in the Emergency Procedures

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50-155/86013-03(DRS) Use of inaccurate dates in the 3c(1)  ;

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PACS master file listing of  ;

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I maintenance and surveillance activities

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50-155/86013-04(DRS) Inadequate program to train key 3e(1)

personnel for EQ activities

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Item Numbers Description Report Section 50-155/86013-08(DRS) ' Deficiencies in the EQ. file d(1)(2)(3)

for various power and control cables 50-155/86013-09(DRS) Qualification for 30 day 4e-operability after a DBA has not been established in fil /86013-10(DRS) Missing sections in EQ file 4f

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for STATES terminal blocks 50-155/86013-11(DRS) Lack of licensee response to 4g concerns in IE 83-72 for Limitorque

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DETAILS Persons Contacted Consumers Power Company (CPCo)

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'*F. W.'Buckman, Vice President

• D.-P. Hoffman, Plant Superintendent ~

• C. Withrow, Engineering and Maintenance Superintendent

• C. R. Abel, Production and Performance Superintendent

• J. L. Beer, C/HP Superintendent

• E. MacInnis, Director, Public Affairs

• E.,M. Evans, Senior Engineer K. A. Toner, Palisades Engineering Supervisor

• R..R. Frisch, Licensing Analyst, Corporate

• J. Alexander, Technical Engineer L. Darran,: Acting Operation Supervisor

• R..L.'Krchmar, Quality Assurance Engineer

• E. Raiciborski, Outage Planner Consultants

• P. A. DiBenedetto,' DiBenedetto Associates, In E.' J. Olfier, Staff Engineer, Jackson Associates U.'S. NRC

• S. Guthrie, Senior Resident Inspector

• Denotes those attending the exit interviews on September 19, 198 . Licensee Action on'SER/TER Commitments The NRC inspection team evaluated the implementation of the licensee's EQ corrective action commitments made as a result of EQ deficiencies identified by the NRC--in the February 18,'1983, FRC/TER; April 26, 1983, SER;' June-5 thru 7, 1984, NRR audit; and October 3, 1985, final SE During the June 5 thru 7, 1984,-audit the NRC st'aff had observed that the licensee had not demonstrated an EQ program meeting the requirements of'

10 CFR 50.4 Consequently, the Nr,C staff had recommended large scale efforts for EQ program compliance.in the areas of file maintenance; file auditibility; qualification of equipment for peak temperature; installation and location of equipment; assignment of key EQ personnel; and increased management commitment in the. area of E In particular the staff identified outstanding file deficiencies-for-

- Motor Operators'; Cables with Polyvinyl Chloride ~ (PVC), Polyethylene (PE)

and Butyl rubber insulations; Static-0-Ring Pressure Switches; Yarway Level Switches; Westinghouse Terminal Blocks; General Electric Terminal Blocks; and Target Rock Solenoid Valve .

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The licensee initiated efforts to take corrective action relative to the above deficiencies and submitted evidence of this effort, including Justifications for Continued Operation (JCO's) in their letters of August 27 and October 31, 1984, January 7 and 28, 1985 and February 7 and 2_1, 1985. The NRC staff accepted these JCO's as well as the licensee's approach to the resolution of these deficiencies in.their October 3, 1985, SE The majority of the deficiencies identified above involved files not being adequate to demonstrate qualification. During this current review the NRC inspection team determined that in most cases EQ files on equipment previously reviewed had been updated and corrected to contain appropriate qualification documentation; details of the files reviewed are referenced in Section 4 of this report. Based on a review of the licensee's implementation of the SER/TER conrnitments, the NRC inspection team identified the following deficiency:

In their August 8, 1984, audit report of the June 5-7, 1984, EQ audit the NRC audit team had concluded that "the electrical cables reviewed in Appendix B (of the report) should be tested as originally planned, or a more positive effort to show qualification through testing already completed should be initiated." Appendix B of this August 8, 1984 report had referenced three unqualified electrical cables having PVC insulation, Butyl rubber insulation, and PE insulation respectively, for Class IE circuits inside the containment. Appendix B had also recommended that the once scheduled testing by the licensee be resume During this review the NRC audit team observed that the licensee had not performed testing of similar or identical kinds of PE or Butyl rubber insulated cables, but had attempted to qualify them through reference to an analysis of generic industry tests of PE and Butyl Rubber Cables. The licensee stated that tests of identical cables could not be performed due to a lack of sufficient plant records needed to locate and obtain identical samples from their plant. The licensee also stated that such tests would not be cost effective. The NRC inspectors reviewed the licensee's generic qualification of these cables and determined that the PE and Butyl cables were unqualified due to the failure of the licensee to establish adequate similarity between the tested cables in the generic reports and the plant cables. Review of these cable files is discussed in Sections 4d(4) and 4d(5) of this report. The NRC inspectors also concluded that the licensee had not implemented their SER/TER conunitment for cables, in that they had not made a more positive effort to show the qualification of these cables through testing of identical or similar cables. Pending further review of this issue with NRR, this is a Potentially Enforceable / Unresolved Item (50-155/86013-01(DRS)). EQ Program Compliance ton 10 CFR 50.49 The inspectors reviewed selected areas of the licensee's EQ program to verify compliance to 10 CFR 50.49. The licensee's methods for establishing and maintaining the environmental qualification of electrical equipment were reviewed in the following areas:

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> 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 equipment; maintenance of qualified equipment; modifications to plant that could affect qualified .

-equipment; updating of the EQ master. list; and review an .

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approval of EQ documentatio Procedures reviewed included the *

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• BRP-EQ-NPS-1, " Upgrade of Big Rock Point Plant Environmental Qualification Files,"~ Revision 0, dated-September.20, 1984 e' BLP-EQ-NPS-2, " Upgrade'of Big Rock Point Plant EQ List,"

i Revision 0,. dated September 19, 1984 -

• Procedure 3.1.1, " Plant Modifications," Revision 0, dated July 30, 1986

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• Procedure 3.1.1.1, " Facility Change, Minor," Revision 0, dated August 1, 1986

• Procedure 3.1.1.5, " Facility . Change, Major," Revision 0,

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• . Procedure 3.2.1, " Maintenance-Order Processing,"

Revision 1,. dated September 12, 1986 i

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• Procedure 4.2.4, " Procurement of Materials," Revision 0,

! dated September 18, 1986

• . " Periodic' Activities Control System Master File Listing,"

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dated. August 27, 1986 i Specific areas reviewed in these procedures included definitions of harsh and mild environments,' equipment qualified life, service conditions, periodic testing,. maintenance and. surveillance, and o upgrading of replacement equipment purchased after February 22, 1983.

The licensee's EQ program was found to identify methods for

equipment qualification; provide for evaluation and maintenance J

of auditable EQ documentation, including maintenance records; 1

provide for updating of replacement equipment and control of

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plant modifications. Based on the above review the inspectors-

determined that the licensee had established an adequate EQ

. program in compliance with the requirements of 10 CFR 50.4 No violations or deviations were: identified.

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b. 10 CFR 50.49 Master Equipment List (MEL)

IE Bulletin 79-01B required licensees of all power reactor facilities with an operating license to provide a master list that identified each Class IE electrical equipment item relied upon to perform a safety function during a design basis even CFR 50.49 Paragraph (d) required licensee's to prepare a list of electric equipment important to safety and within the scope of the rule. The NRC inspectors reviewed the Big Rock MEL titled " Environmental Equipment Qualification Program Equipment List", Revision 5, dated February 19, 1985, 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 list in terms of equipment needed under accident conditions through review of Piping and Instrumentation Drawings, Emergency Procedures, Technical Specifications'and FSAR's. The. inspectors reviewed the five revisions made to the MEL since December 1984, Revision 0, through March 1985, Revision 5, and found adequate technical justifications for the. items removed from the lis Items removed were verified to not initiate any automatic spray functions or require any subsequent safety actions by the operator. Additions or deletions to the list due to field modifications were found acceptable and acceptable reviews had been performe The inspectors reviewed equipment needed to function under accident conditions including equipment used during natural recirculation after an accident and Post Accident Samplin Accidents reviewed included a Minor LOCA inside the containment, Major LOCA inside the containment, Major LOCA outside the containment, and a LOCA in conjunction with a loss of off-site power. Equipment needed for the above accidents ~

was identified in the Plant Emergency Procedure EMP 3.3-Loss of Reactor Coolant, Revision 138. All applicable equipment in this-procedure was reviewed for applicability and inclusion in the ME The MEL was found accurate for all items sampled with the exception of the following discrepanc (1) During review of the Big Rock Emergency Procedures EMP 3.3-LOCA, Revision 138, the inspector observed that indications-from one instrument removed from the EQ list was still relied upon in the EMP by the operator during an accident. For example, PT-IA07C had been removed from the EQ l_ist in February 1985, however, EMP 3.3 page 5 reflected the Pressure Indicator PI-1A05 for transmitter PT-IA07C as having symptomatic information relative to a Major Loss of Reactor Coolant inside the containmen The licensee agreed to put in cautionary

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i statements in-EMP's as appropriate', to prevent inadvertent misleading of operators during an accident due to the malfunctioning of any unqualified instruments removed from the MEL.~ Pending further review of licensee- ,

corrective action in this a'rea, this is an Open Item (50-155/86013-02(DRS)). EQ Maintenance Program The inspectors reviewed specific maintenance,-replacement, surveillance tests, and inspections necessary to preserve the environmental qualification of EQ equipment on the ME The NRC inspectors found no deficiencies in the licensee's methods for scheduling maintenance and surveillance, with the' exception of the following:

(1) The inspectors' observed that the licensee was using inaccurate dates in theirinew " Periodic Actieities Control System". (PACS) Master-File listing. This computerized listing identifies all preventive maintenance and surveillance requirements, but had certain inaccurat ' dummy' dates entered temporarily to facilitate the'use of a computer program. The licensee stated that the correct dates would be identified in the PACS listing upon completion of the-January 1987 scheduled plant refueling outage. The inspectors had no immediate concer o regarding the. qualification of relevant equipment since no maintenance deficiencies were identified in regard to the use of these dates. Pending a verification of the correction of these dates and a verification of the completion of appropriate maintenance' activities, this is an Open: Item (50-155/86013-03(DRS)). Plant Procurement and Upgrading of Replacement Equipment

~ Licensee procedures were found to adequately address upgrading of replacement equipment purchased after February 22, 198 Procurement procedures and documents were found to adequately address appropriate quality and regulatory requirements -

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regarding the environmental qualification of equipment within

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the scope of 10 CFR 50.49. Checklists were observed to have been used to provide' evidence of' reviews and approvals. For

! example, procurement packages for replacement level transmitters and position switches were found to properly address upgrading of replacement equipment to requirements of IEEE 323-197 No violations or deviations were identified.

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. Quality Assurance (QA) and Training Program During this review the inspectors determined that the licensee had implemented a significant effort in. monitoring the quality of EQ activities through surveillance and review of plant-modification records and files. The inspectors noted that the plant. QA personnel had conducted detailed EQ reviews during the 1985 refueling outage and performed another QA audit in May 1986. The inspectors found the methodology and results of these QA audits very acceptable. The following ~xception e

was identifie (1) Based on NRC interviews of licensee personnel responsible for EQ activities, the inspectors determined that the licensee had not implemented an adequate training program to support their EQ activitie In particular, plant maintenance personnel were observed to have a low level of awareness of the significance of the environment qualification of critical equipment in the plant. This was also evidenced by broken terminal block barriers found in the EQ Limitorque actuator M0 7080, discussed in Section 5(1) of this repor The licensee personnel acknowledged a lack of formal EQ training, but were-aware of the special requirements applying to EQ equipment within the scope of 10 CFR 50.49. Pending further review of licensee actions in this area, this is an Open Item (50-155/86013-04(DRS)).

4. Detailed Review of Qualification Files IE Bulletin 79-01B required licensees of all power reactor facilities with an operating license to provide written evidence of the environmental qualification.of each piece of electrical equipment listed on their MEL. 10 CFR 50.49 Paragraph (f) requires records of qualification of equipment on the MEL to be maintained in an auditable form for the entire period during which the equipment is installed in the plant or stored for future use, to permit verification of qualification

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and specified performance for accident condition The licensee qualified their EQ equipment to the requirements of the D0R Guidelines (10 CFR 50.49 Paragraph K). .The inspectors reviewed 52 equip-ment qualification files for evidence of the environmental qualification of equipment within the scope of 10 CFR 50.49 and evidence of-equipment qualification to the 00R Guidelines. Files were found to include a full description of the equipment; similarity analysis of tested equipment to that installed in the plant; allowed monitoring methods and orientation; qualification of interfaces (conduit housing, seal etc.); evaluation of aging effects on equipment; performance / acceptance criteria for the qualification of equipment; description of test sequence and methology; environmental conditions for the equipment during an accident; qualification for submergence of equipment; resolution of test anomalies; and maintenance / surveillance criteria for the preservation of the qualified status of the equipment. The inspectors selectively reviewed

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the above areas, as applicable, 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; aging calculations for qualified life and replacement' intervals;~ effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy; and licensee evaluation of discrepancies identified in IE Information Notices and Bulletin EQ files were reviewed for Electrical Cables, Cables Splices, Level Switches, Level and Flow Transmitters, Pressure Switches, Pressure Transmitters, Radiation Monitors, Electrical Motors, Motor Operated Valve Actuators, Solenoid Valves, Terminal Blocks, Electrical Penetrations and Position Switches. During this review the inspectors found the files well organized and very auditable. In almost all cases the files allowed verification of equipment qualification to a specified performance for DBA conditions. Exceptions are noted below: Limitorque Actuator M0-70_6_8 Limitorque Actuator M0-7068 was reviewed for qualification to the 00R Guidelines in EQ File No. 3.80. This actuator was procured under Limitorque Order No. 50744, Serial No. 95921 and is mounted inside the containmen In early 1975, Valve Actuator M0-7068 was removed from service after 13 years of operation and shipped to the Franklin Laboratories for LOCA testing (referenced in Franklin Report F-C4124). On April 23, 1975, a LOCA test which included a steam environment, was performed on M0-7068 for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The-valve actuator was then shipped to the Limitorque Corporation plant in King of Prussia, Pennsylvania, where Limitorque inspected the actuators and greased it. Limitorque then shipped the actuator back to the Big Rock Plant, where it was placed back in service in the containment spray system. The EQ file, however, did not evidence any refurbishmen't of degradable materials prior to M0-7068 being placed back in servic During this review the licensee reported that they could not retrieve documentation necessary to confirm any refurbishment ;

of materials. EQ File No. 3.80 did not address the effects of the Franklin LOCA test on the qualified life of the installed actuator nor did it provide evidence that the valve actuator could sustain another DB In addition to the above, the inspectors could not inspect the materials in the valve actuator in the field as this action would have placed the operating plant in a Limiting Condition of Operation (LCO).

During this inspection the licensee provided a thermal degradation evaluation of materials postulated to be in the actuator, as well as a letter from Limitorque Corporation describing their inspection of M0-7068 after it_had undergone the Franklin LOCA test. The licensee was informed that this evaluation was inadequate because of the following:

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-(1) No detailed evaluation was provided for degradation due to the-E steam environment experienced by materials during the LOCA testing.

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(2) LOCA testing,(including steam) for the purpose of thermal degradation has not been justified as an acceptable method of calculating qualified lif Further, such a methodology may apply only to newly installed equipment, not a test

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specimen that has already experienced aging degradation-t due to'a LOCA environment, and required to survive a second LOCA at the end of its qualified life, and maintain post LOCA operabilit '

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(3) The evaluation assumed that Buna N was the weakest link material in the.Limitorque actuator M0-7068. Due to the lack of documentation of the types and condition ~of materials in the actuator after the:LOCA test, and due to the inability of the inspectors to perform a physical inspection in the field, this assumption was not considered justifie The licensee was informed that the Limitorque Actuat'or M0-7068 was

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-considered unqualified for operation during a DBA.- The licensee then provided an interim JC0 regarding the operability of M0-706 The JC0 has been accepted by the NRC. In the JC0 the licensee indicated that M0-7068 was actuated only during a Main Steam Line Break to initiate containment spray if the principal valve M0-7064 failed to open. The inspectors deteriiiined that in view of the relatively less harsh accident environments in the containment L .at Big Rock, manual initiation of M0-7068 during a MSLB would be accomplished in a relatively mild environment early into the

accident. Based on a review of this JCO, the inspectors had no

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immediate concerns regarding the actuation of-the valve and the l- operability of the plan ~

The-licensee agreed to replace the Limitorque Actuator M0-7068 with

. an environmentally' qualified replacement at the earliest opportunity, f

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but no later than the January 2, 1987, outagee In addition to the above, the licensee has modified EMP 3.3 to no longer require the i . secondary use of'M0-7068 in washing down iodine released to the containment during a LOCA or.MSLB. The licensee was informed that in accordance with the guidance in Generic Letter 85-15 enforcement

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action may be taken, in that the licensee clearly should have known i that Limitorque M0-7068 was unqualified past the EQ deadline of l' November 30, 1985. Pending further review, this is a Potentially l- Enforceable / Unresolved Item (50-155/86013-05(DRS)).

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l Rotork Actuator M0-7072 was reviewed for. qualification to the D0R L guidelines in EQ File No. 3.90. This valve was part of the Franklin LOCA testing for M0-7068 described in paragraph 4a of this report, I and was also put back in service without adequate documentation or

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record of any refurbishment of degraded materials. The EQ file did not address the effects of the Franklin LOCA test on the qualified life of the installed actuator nor did it provide evidence that the valve actuator could sustain another DB The licensee was informed that the Rotork Actuator M0-7072 was considered unqualified for operation during a DBA. Subsequent to the audit on September 26, 1986, the licensee submitted a response to Region III (No.- AT0986-0162-NLO2), which included an adequate technical evaluation to justify removal of this actuator from the ME This evaluation indicated that M0-7072 was a third source of water to the core and containment spray systems which already had redundant paths to achieve their safety functions. Based on a review of appropriate plant drawings, the NRC inspectors accepted this technical evaluation; however, the licensee was informed that in accordance with guidance in Generic Letter 85-15 enforcement action in regards to this programmatic problem may be taken, in that the licensee clearly should have known that unqualified actuator MO- m72 was on their MEL past the November 30, 1985, EQ deadlin Thi tem was removed from the MEL, only after being identified as unqu lified by the NRC inspectors. Pending further review this is a Potentially Enforceable / Unresolved Item (50-155/86013-06 (DRS)).

c. Flow Transmitter FT-2162 Rosemount Model 1153, Series D, transmitters, including Flow Transmitter FT-2362, were examined in EQ File Nr 2.120. .The inspector noted that FT-2162 was located below tne containment flood level, but that the Rosemount test report in the file did not qualify this transmitter for submergence. The licensee was informed that this transmitter was unqualified for performing its stated safety function during a DB Subsequent to this finding in their September 26, 1986, response to RIII the licensee stated that the time during the accident sequence at which this flow transmitter becomes submerged varies as a function of the break size and location. The licensee stated that since it was impossible for the transmitter to escape submergence, they had revised the EQ file to indicate that FT-2162 was qualified up to the point of submergence, and that a cautionary statement had been added in the EMP to advise operators not to rely on FT-2162 for core spray flow indications once FT-2162 was- submerge References to adequate redundant core spray flow indications were provided by the license The inspectors reviewed this response and were concerned that operators could be misled if they did not know when the transmitter was submerged; however, the inspectors determined that due to available redundant indications and corrective action taken, the lack of qualification of this transmitter for submergence would not affect the safety of the plan The licensee was informed that their failure to qualify this transmitter for its stated function was a programmatic deficienc The NRC staff informed the licensee

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that in accordance with guidanc'e in Generic Lette'r 85-15, enforcement action may be taken, in that the licensee clearly should have known that Flow Transmitter FT-2162 was unqualified for its stated safety function past the November 30, 1985, deadline. This is a Potentially Enforceable / Unresolved Item (50-155/86013-07(DRS)).

d. Control Cables The inspectors reviewed tne following files for Control Cable Exceptions are noted below:

(1) File No. 2.10-Raychem Control Cable No performance criteria relative to IR characteristics was addressed in the file, however, results of testing included in the file indicated reasonably high IR values to mitigate inspector concern The licensee agreed to add appropriate data to the fil (2) File No. 2.16-Rockbestos Control Cable No performance criteria relative to IR characteristics was addressed in the file. In addition to the above, the latest tes. reports from Rockbestos on cross linked Polyethylene

~Cabie, which would justify the qualification of this cable to 10 CFR 50.49, had.not yet been included in the fil The inspectors determined that sufficient information existed in the file to mitigate concerns, and the licensee agreed to update their file (3) File No. 2.25-Kerite Control Cable ~

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No performance criteria relative to IR characteristics.was addressed in the file, consequently effects of IR's on circuits during an accident had not been considered in the files. In addition to the above, the System Component Evaluation Work (SCEW) sheet stated a qualification for 30 days while the test documentation qualified the cable for 7 days and 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> The inspectors determined that sufficient information existed in the file to mitigate concerns, in that the test profile used could qualify the cable for 30 days based on the significant margins used in the test. The licensee agreed to update their fil Pending review of licensee corrective action for deficiencies identified in Paragraphs 4d(1), (2), and (3), this is an Open.

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Item (50-155/86013-08(DRS)).

(4) Files 2.45, 2.50 and 2.51-General Electric and Anaconda Power and Control Cable The inspectors reviewed the GE Anaconda Butyl rubber insulated

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cable for qualification to the D0R Guidelines. File No. 2.45 cited a IEEE Transactions paper of ' April 1986 as a basis for the qualification of these cables. This paper contained limited test data on one styrene-butadiene synthetic rubber based insulation, per 7 CEA 5-19-81 Sections 3.15 and 3.1 Since this paper did not establish adequate similarity in accordance with the 00R Guidelines to'the cables installed in the plant, generic qualification for the cable installed inside the~ containment was not accepted by the iaspector The licensee was informed that further testing and analysis of identical or similar specimens of plant installed cable was necessary to complete their fil (5) File No. 2.55-General Cable, GE and Anaconda Power and Control Cables The inspectors reviewed the above three types of Polyethylene (PE) power and control cables for qualification to the D0R Guidelines. The file cited a test done by Wyle Laboratories on a PE cable from Plastics Wire and Cable Company as a basis for qualification of the cable installed at Big Rock. The above test had been performed by Wyle for the Tennessee Valley Authority (TVA), for cable installed at the TVA plant. The inspectors concluded that the generic qualification in the EQ file did not establish similarity in accordance with the 00R Guidelines, and that similarity of the tested cable of a different manufacturer to cables installed in the plant had not been demonstrated. The licensee was informed that further testing and analysis of identical or similar specimens of plant installed cable was necessary to complete their fil Pending NRC review of further qualification testing or analysis for Butyl rubber and PE insulated cables, the deficiencies identified in Paragraph 4d(4), and (5) are considered part of Unresolved Item (50-155/86013-01(DRS)). File No. 3.50 3M Electrical Splice Table 3M Electrical Splice Tape was reviewed for qualification to the 00R Guideline No performance criteria in terms of IR characteristics was addressed in the file. The inspector also observed that the test conditions noted in the file did not envelope the plant profile for either titre or temperature. The SCEW sheet in the EQ file identified a required operability of 30 days, while the testing qualified the tape for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An analysis was presented and accepted during the audit for justifying a lower peak temperature; however, corrections need to be made to the EQ documents for a 30 day qualificatio Pending review of licensee corrective action this is an 0?en Item (50-155/86013-09(DRS)). STATES Terminal Blocks STATES terminal blocks used for 120VAC and 125VOC control circuits were reviewed in EQ File No. 4.60 for qualification to the 00R Guideline EQ documentation in the file documented a Wyle report

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.for qualification, but the inspectors observed that the Wyle report in the_ file was missing certain sections of the LOCA_ test. The licensee stated that these sections would be retrieved from their

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document center in Jackson,-Michigan as.soon as possible. No problems are anticipated once the available information is replaced in the file. .Pending verification of corrective action this is an

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Open Item (50-155/86013-10(DRS)). Response to EQ Notices and Bulletins During review of Limitorque Actuator files for responses to IE-Notices and Bulletins concerning EQ, the inspectors observed that the licensee has not adequately. addressed IE Notice 83-72 which had-identified various generic concerns regarding the operability of Limitorque valve actuators. In a letter to.their Safety Review

' Committee dated December 27, 1983, the-licensee stated, "Limitorque operators are still.an Open Item in the Big Rock Point EEQ program and are- st_ill being evaluated for adequacy. Deficiencies, if found will~be resolved at a later.date." The inspectors informed the licensee that a walkdown was necessary to verify that Limitorque actuators on their MEL were not affected by deficiencies identified in IE 83-7 . Based on their review of Limitorque and Franklin tests . included in the EQ. files, the inspectors had no concerns relative to Actuators M0-7050,-7051,'7061 and 7066. The remaining two Limitorque Actuators M0-7068 and 7080 are addressed in. Sections 4a and Sa of this repor The licensee agreed to perform a complete walkdown of all (6) Limitor-que Actuators for review to'IE 83-72. Pending verification of this review, this is an Open Item (50-155/86013-11(DRS)).' Plant Physical Inspection The NRC inspectors selected 50 items on the MEL for examination in the

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plant. The EQ file of each item had been reviewed, and information regarding the location, manufacturers, model/ serial number, mounting, orientation,~ environment, and. interfaces had been noted. The inspectors examined the selected items, where accessible, and verified that the method'of installation of each-item had not affected its environmental qualificatio Specific. areas reviewed included traceability of. installed items.to EQ files, ambient environmental conditions, qualification of interfaces (connectors, wires, seals,' insulation, lubricants etc.),

evidence of significant temperature rise from process, drainage, mounting-methods, physical conditions and housekeeping. In almost all cases items examined in the' field were found to meet their appropriate EQ requiremsnt One exception is noted below: Limitorque~ Valve Actuator M0-7080 Valve actuator M0-7080, Model SMB 005, Serial No. 321750, was examined by the inspectors in the core spray room,. elevation 586 f Mounting, orientation, housing seals and ambient environmental

= conditions were found adequate. On removal of the housing cover the inspectors observed that all the barriers between the lugs of

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the terminal block had been completely severe Since no pieces of the barriers were visible, the inspectors determined that this damage had occurred prior to their inspection. QA/QC documents for this installation indicated no record of this deficiency. In addition to the above, certain wires attached to the limit switch terminals were bent back 180 , thereby exceeding an allowable bend radiu The licensee was informed that the Limitorque Valve actuator M0-7080 was potentially unqualified for a DBA, in that it was installed in a configuration other than tested during its qualificatio The licensee took immediate corrective action and issued Deviation Report No. D-BRP-86-32 to process repairs. The inspectors determined that the valve currently functioned properly and that it would not.see a harsh environment till it was opened during the recirculation mode. Since the core spray room was in a separate enclosure outside the containment, the actuator would not be exposed to excessive moisture that could cause shorting between the terminal Based on the above review the inspectors determined that valve actuator M0-7080 in its current state viould not affect the safety of the plant during accident conditions. The licensee was informed that the identified damage to M0-7080 indicated a failur to preserve the qualified status of this Limitorque actuator. The licensee was also informed that in accordance with guidance in Generic Letter 85-15, enforcement action may be taken, in that the licensee should have clearly. known that valve actuator M0-7080 was unqualified. Pending further review, this is a Potentially Enforceable / Unresolved Item (50-155/86013-12(DRS)).

6. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during this inspection are discussed in Paragraphs 3b(1), 3c(1), 3e(1), 4d, 4e, 4f, and 4 . 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 will be followed up with enforcement action in accordance with NRC enforcement guidance on environmental qualification. Potentially Enforceable Unresolved Items are discussed in Paragraphs 2, 4a, 4b, 4c, and S (_ .

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t . Exit Interview The Region III inspectors met with the licensee representatives (denoted under Paragraph 1) .at-the conclusion of the inspection on September 19, 1986. The inspectors sunmarized the purpose and findings of the inspection and the licensee acknowledged this information. The licensee did not identify any documents / processes reviewed during the inspection as pro;irietary.

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