IR 05000321/1986035
| ML20210V530 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/07/1987 |
| From: | Potapovs U, Wilson R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20210V468 | List: |
| References | |
| 50-321-86-35, 50-366-86-35, IEIN-86-003, IEIN-86-071, NUDOCS 8702190044 | |
| Download: ML20210V530 (17) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report No.:
50-321/86-35 and 50-366/86-35 Docket No.:
50-321 and 50-366 Licensee:
Georgia Power Company Post Office Box 4545 Atlanta, Georgia 30302 Facility Name:
Plant E. I. Hatch, Units 1 and 2 Inspection Conducted:
November 3 to 7, 1986 2. b87 Inspector:
R. C. Wilson, Equipment Qualification and Date Test Engineer Also participating in the inspection and contributing to the report were:
U. Potapovs, Chief, Equipment Qualification Inspection Section, 18E 0. P. Gormley, Inspecter, I&E A. B. Ruff, Reactor Inspector, Region II J. M. Fehringer, Engineering Specialist, Idaho National Engineering Laboratory D. E. Jackson, Censultant Engineer, Idche National Engineering Laboratory M. J. Jacobus, Member of Technical Staff, Sandia Natinral Laboratories A. C. Sugarman, ENRAC, Consultant to Sandia National Laboratories I
i Approved By:
( 2 d, O La& to 2-b-ff7 U. Potapovs Chief, Equipment Cualification Date Inspection Section, Vendor Program Branch
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INSPECTION SUMMARY Inspection on November 3 to 7, 1986 (Inspection Reports Nos. 50-321/86-35 and 50-366/86-35 Areas Inspected: Special, announced inspection to review the licensee's implementation of a program per the requirements of 10 CFR 50.49 for estab-lishing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.49.
Results: The inspection determined that the licensee has implemerted a
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program to meet the requirements of 10 CFR 50.49, except for certain deficiencies listed below.
Name Report Paragraph Item Number Potential Enforcement / Unresolved Items 1.
Limitorque operators 4.F(1)
50-366/86-35-01 2.
Okonite cable and splices 4.F(2)
50-321/86-35-01; 50-366/86-35-02 3.
States terminal blocks 4.F(3)
50-321/86-35-02; 50-366/86-35-03
Rosercunt transmitters 4.F(4)
50-321/86-35-03; 50-366/86-35-0a 5.
Target Rock solenoid valves 4.F(5)
50-321/86-35-04;
50-366/86-35-05 Open Items 1.
HPCI turbine controller 4.F(6)
50-321/86-35-05; 50-366/86-35-06 2.
Walkdown deficiencies 4.G 50-321/86-35-06; 50-366/86-35-07
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DETAILS
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1.
Persons Contacted 1.1 Georgia Power Company (GPC)
- J. T. Beckham, Jr., Vice President Nuclear Power
- H. C. Nix, Jr., Plant Manager
- D. Read, Plant Support Manager
- A. Fraser, Acting Site QA Manager
- T. R. Powers, Engineering Manager
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- P. R. Bemis, Engineering Liaison Manager C. T. Jones, Engineering Liaison
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G. Barker, I&C Maintenance Supervisor R. Glisson, Maintenance J. Newton, Maintenance Supervisor, Work Planning Group G. Goode, Engineering Services D. McCusker, Quality Control G. Sorrell, Document Control S. J. Bethay, Regulatory Compliance Supervisor
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- K. W. Whitt, Safety and Licensing
- S. H. Chesnut. Nuclear Generating Engineering
- A. Domby, Attorney T. Moore, Training Manager S. Tipps, Regulatory Compliance J. Price, Maintenance Training Supervisor J. Dixson, Methods and Training Specialist for Program Development R. Moxley, QA 1.2 Southern Company Services (Architect Engineer)
- D. R. Madison, Site Engineering (onsite.E0 coordinator)
- C, R. Pierce, NSF (offsite E0 coordinator)
- J. K. Branum, Engineering Liaison L. Long, NSF L. Mensie 1.3 Contractors to GPC/SCS
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- D. Dismukes, Mechanical Supervisor, Bechtel
- S. Pauly, Impell
- G. MacDonald, impell 1.4 U.S. NRC
- G. M. Nejfelt, Resident inspector
- Denotes those present at exit meeting at Plant Hatch on Nivenber 7, 1986
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2.
PURPOSE The purpose of this inspection was to review the licensee's implementation of a program to meet the requirements of 10 CFR 50.49, 3.
BACKGROUND The NRC held a meeting with GPC on February 14, 1984, to discuss GPC's proposed methods to resolve the EQ deficiencies identified in the Safeev
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Evaluation Report dated March 31, 1983 for Plant Hatch and in the FRC TERs dated January 21, 1983 for Unit 1 and February 8, 1983 for Unit 2.
Discus-sion also included GPC's general methodology for compliance with 10 CFR 50.49 and justification for continued operation (JCO) for those equipment items for which environmental qualification was not completed. The minutes of the meeting and proposed method of resolution for each of the EQ deft-ciencies were docunented in GPC's submittals dated March 30 and June 4, 1984.
The final SER transmitted August 29, 1985 identified that certain equipment in both units was still under JCO. At the tine of the inspection, no JCOs or extensions applied. An NRC letter dated July 30, 1985 stated that the staff finds acceptable the post-accident monitoring instrumentation for complying with Reg. Guide 1.97 that was described in GPC submittals dated February 21, 1984 and April 29, 1985; this equipment was covered in the inspection.
4.
FINDINGS The NRC inspectors examined the licensee's progran for establishing the qualification of electric equipment within the scope of 10 CFR 50.49. The program was evaluated by examination of the licensee's qualification documentation files, review of procedures for controlling the licensee's E0 efforts, verification of adequacy and accuracy of the licensee's 10 CFR 50.49 equipment list, and examination of the licensee's prooram for maintaining the qualified status of the covered electrical equipment.
Based on the inspection findings, which are discussed in more detail below, the inspection team determined that the licensee has implemented a program to meet the requirements of 10 CFR 50.49, although some deficiencies were identified.
A.
E0 Program Procedures During the entrance meeting GPC provided an overview of the Plant Hatch EQ program and procedures. The program was evaluated by interviews and discussions with GPC representatives and by review-ing the licensen's onsite procedure for controlling and maintaining the qualified status of 10 CFR 50.a9 equipment. The following
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procedures were reviewed.
40AC-REG-005-05, Environmenal Qualifications Surveillance Program 50AC-MNT-001-05, Mainterance Program 40AC-REG-001-05, Technical Specifications Survefilance Program 50AC-MTL-001-05, Control of Purchased Material 50AC-MTL-002-0S, Identification and Control of Material and Equ4pment
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50AC-MTL-004-0S, Procurement of Material and Services 10AC-MGR-04-05, Deficiency Control System 10AC-MGR-005-0S, Corrective Action, Trending and Tracking 40AC-ENG-003-0S, Design Control 55MC-MTL-003-05, Material Identification and Issue Control 42EN-ENG-005-05, Identification and Control of 10 CFR 50.49, Work Activities Various Electrical and Instrumentation and Control Procedures for General, Corrective, and Preventive Maintenance, Surveillance, and Calibration such as 52-GM-MEL-02?S, 57 CP-CAL-103-2S, 57CP-CAL-104-IS The licensee's program was reviewed to verify that adequate procedures.'
and controls had been established to meet the requirements of 10 CFR 50.49. Areas of the program reviewed included methods and their effectiveness for:
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Requiring all equipment that is located in harsh environments and is within the scope of 10 CFR 50.49 to be included on the Master List of equipment requiring qualificatinn.
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Controlling the generation, maintenance, and distribution of the EQ Master List.
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Defining and differentiating between mild and harsh environments.
Establishina harsh environmental conditions at the location of
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equipment through engineering analysis and evaluation.
Establishing, evaluating, and maintaining EQ documentation.
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Training personnel in the environmental qualification of
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equipment.
Controlling plant modifications including installation of
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new and replacement equipment, and providing for updating replacement equipment to 10 CFR 50.49 criteria.
Review of the above procedures and interviews with GPC representatives confirm that an E0 progran has been established for Plant Hatch. The procedures define the scope of the EQ prore and responsibilities of varinus organizations for implementing F.
'ie licensee's program included methods and their effectivene i fo- :entrol of activities on EQ components in that:
All repairs, maintenance, and surveillance for safety related or e.
environmentally qualified electrical corponents are specified by procedures and are authorized for performance by Maintenance Work Orders (M0).
b.
MW0s can be initiated by any person who identifies a need for repair or maintenance.
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c.
The MW0s identify the components to be worked by MPL numbers,
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d.
The MWO is reviewed by an appropriate department representative in the Work Planning Grcup (WPG) which includes Operations Department for special operating instructions, clearance and tagging; Engineering Department for an EQ review, if the component is envirorsentally qualified; and a QC review for component classification (safety /non-safety) and for hold points.
All completed MW0s relating to 10 CFR 50.49 components are reviewed e.
by the Engineering Department.
f.
An E0 surveillance program for scheduling and tracking has been implemented.
g.
Trending of equipment failures is performed.
h.
00R Guidelines equipment upgrade review is performed annually.
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Replacement of components identified on the EQ Master List, except for exact-kind components qualified to NUREG 0588/10 CFR 50.49, reouires completion of a 10 CFR 50.49 check list which includes justification.
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Electrical equipment environmental qualification trainirg for
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personnel is conducted.
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Response, tracking, evaluation and corrective action, if applicable, are performed for significant nuclear industry events including IEBs and IENs.
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Annual EQ audits are conducted by on-site QA department.
Monthly system surveillance is performed by on-site QA department.
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As part of the program review, the inspectors exanined records and met with licensee representatives of the following grcups:
a.
Engineering Section b.
Quality control c.
Training d.
Electrical and I&C Maintenance e.
Work Planning Group f.
Quality Assurance g.
Regulatory Compliance The inspectors examined the extent of cc-site QA, involvement to verify the licensee's compliance with 10 CFR 50.49 and the QA program require-ments.
During 1986 the QA organization conducted an audit of the site EQ program. This audit was performed in July and is documented by GPC
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Audit Report No. 86-EQ-A.
In addition, surveillance is perforned on a different system each month by QA. EQ issues are included as part of these monthly surveillances.
Review of the Audit Report and inter-views with OA staff shows a significant QA involvement in the EQ Several audit items were identified and are being tracked program.
for resolution. One of the audit findings indicate a deficiency in an ongoing EQ Awareness Program in the training section. An interview with training section personnel indicated that a video tape on Environmental Qualification was shown to a large number of GPC person-nel during late 1985. This was confirmed by a review of attendance records. Also an Environmental Qualification Awareness training plan has been developed and is in the approval circuit. This training plan consists of a slide / tape presentation and a self study module. A portion of this plan is presented to all QA, engineering, maintenance, and material personnel. A periodic presentation of this plan including the self study module will be required for selected groups such as Electrical and I&C maintenance personnel. This plan is scheduled for implementation early in 1987. Additional discussion of training is provided in Section 4.D below.
The inspectors interviewed the supervisor and a procurement engineer in the Materials and Procurement Section of the General Support Department. This section procures items for the warehouse stock.
The material is received and controlled through the warehouse even if the material was specially ordered for a specific job. Procurements for individual items involved in plant changes of significance are usually handled by off-site procurenent, e.g., an A-E.
The EQ inter-face is primarily covered by Procedure 42 EN-ENG-010-0S Rev. 2 Requisition Review for Quality Requirements, which covers assurance that qualified parts are provided and recuires that the upgrade from D0R Guidelines be addressed.
When identical items cannot be procured, Procedure 42 EN-ENG-09-0 Equivalency Review of Replacement Parts or Materials provides the required guidance for the equivalency review.
The persons interviewed were able to accurately describe the process without reference to the procedures.
B.
EQ Master List The licensee is required to maintain an up-to-date list of the equipment that must be qualified under 10 CFR 50.49. This list is entitled " Master Parts List." Considered in the preparation of this
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were the environmental effects resulting from all of the postuleted design-basis accidents documented in the Final Safety Analysis Report, l
the Technical Specifications, the Energency Operating Procedures, and
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the Piping and Instrumentation Diagrams.
Circuits were traced from l
cable block diagrams, where available, and some equipment was walked down for location, tag number, name plate information and circuit confirmation. Equipment in harsh environments was segregated and listed by system.
Next, General Physics Corp. was brought in to work with the plant operating department and check the list for complete-The integrity of the list is maintained bf procedures which ness.
govern plant changes.
Consideration of E0 is achieved by routing and by check list. Both changes to the equipment and to the environment
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are considered. SCS provided an example of equipment that was not affected by a plant change except that its environment was made harsher. The documentaction showed that the impact on the qualified equipment caused by the change in the environment was considered.
C.
Maintenance EQ maintenance is tracked and scheduled by a computer program. When maintenance is required, the work is initiated by a Maintenance Work Order (MW0). The component number of the MWO is cross checked with component numbers on the.EQ master list. All EQ related MW0s require engineering and QC review.
The inspectors reviewed maintenance procedures listed in Section 4.A above. The inspectors interviewed the Manager of Maintenance, an electrical foreman and an electrician with respect to maintaining the required environmental qualification of equipment, training of GPC personnel, training and supervision of contractor personnel and naintenance backlog.
All persons interviewed were aware of the GPC commitment to an EQ program and were familiar with the details to be followed not only in and by the maintenance organization but in inter-facing organizations as well. The EQ status is preserved by the procedure which requires that the maintenance liason engineer in the Work Planning Group check whether the component to be replaced is on the EQ Master List. He also checks to see if the action required is indeed a simple replacement or whether it constitutes a change.
In the latter case a MW0 is not allowed, and the change must be handled as a Field Change Request with the attendant checks on EQ impact.
If the work to be performed is a simple replacement the MWO is so marked, and is routed to the EQ coordinator after the work is ccmpleted. The latter determines if additional work is required to comply with the requirement to upgrade components meeting 00R guide-lines to meeting 10 CFR 50.49 requirements.
If so, he develops any required evaluations and justifications and initiates action to have the upgrade performed. The warehouse also uses the EQ Master List to ensure that the appropriate part is furnished in response to the parts requisition.
Training on hardware is based on a particular piece of identifiable plant equipment which is duplicated in the training lab. The piece of equipment selected as the training vehicle is an E0 item whenever possible, so the training is received on an EQ item. Contractor personnel do not often receive EQ training, but they rarely work on EQ items and in any event are always under the supervision of a GPC foreman.
In addition, the GPC electrician interviewed noted that the detailed work procedures are so complete and specific that training is not necessary. There is no backlog of EQ items since a missed surveillance or PM action, or a component failure, puts the plant in a limiting condition for operation (LC0). This in turn results in preemptive priority being assigned tn the requiced
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maintenance action.
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MWO 2-85-4686 was reviewed for components 2E32-N061B, F, K, P that
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were previously chosen for a Qualification Data Package (QDP) file review and walkdown inspection. The review of the MWO indicated i
that EQ maintenance work was performed and signed off satisfactorily.
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D.
Training
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The inspectors interviewed the manager of training, the mechanieel and electrical lead instructors, and' the superdsor of training document-ation,' and inspected the training laboratories.
In addition, the inspector questioned the' personnel interviewed in Maintenance, Procurement, and Work Scheduling and Planning about training received.
The manager of training explained that Plant Hatch had three maintenance programs ready for INP0 accreditation and that during the period of getting people certified most personnel were receiving about 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />
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per year of training.
EQ training was given separately in the 1979-1980 time frame and most
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employees who were there at that time, down to the craft level,
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remembered that training. Early in 1986 a three hour taped present-
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ation on EQ was given to managers down to the foreman level.
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names of foreman were selected from employee records for a check.
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Records of tape viewing were available for three of the four.
Records and interviews with other personnel generally confirmed 80 to 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> per year training. Although the examinations inspected did not contain questions on EQ issues, EQ did appear to be integrated into training. This was done by using EQ items as aids for generic training.
For example, an EQ Limitorque operator was used for training on all Limitorque operators and the-trainees were shown
how to recognize wire, terminal blocks and switches and other EQ
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Interviewees in other departments were able to recognize and cite this as EQ training.
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i In addition to the regular training outlined above the Training Manager provided documentation showing that special requirements for l
training for infrequent activities which will arise during the present i
Unit 2 outage were recognized and provided for.
E.
Inspection and Enforcement Bulletins (IEBs) and Notices (IENs)
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The Regulatory Compliance Section of Plant Hatch assigns responsibi-
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lity for evaluation of all IEBs and IENs including those that are related to EQ of electrical equipment. An action tracking system is used to insure that evaluations are performed and corrective actions, when applicable, are complete.
IEB and IEN evaluatics and support-ing document files are maintained by the Regulatory Compliance Section.
Presently, there is no discussion or reference to EQ related IEBs or IENs in the QDPs. The licensee is studying the problems and benefits cf placing the resolution of EQ related-IEBs and IENs in j
the correspondence section, or a separate IEN/IEB section, in the
l epplicable QDP.
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F.
EQ Documentation Files
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GPC maintains separate, similar EQ documentation files for Units 1 and 2 of Plant Hatch. Infomation necessary to document qualifi-cation of equipment is contained in or referenced by the files.
The Plant Hatch EQ files are arranged as follows:
Section A - Introduction (includes sumnary of harsh environ-
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ment parameters and references).
Section B - Master List (includes plant identification; generic
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name; in/out drywell location; SCEW sheet; QDP; qualification criterion;andqualificationstatus).
Section C - System Component Evaluation Worksheets (SCEWs).
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Section D - Qualification Data Packages (QDPs)
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Table of Contents 2.
Revision History 3.
Status (includes a sunmary evaluation and certification of qualification)
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Environmental Oualification Report Evaluation (EQRE)
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Environmental Qualification Reports (for large reports referenced in nore than one QDP, reference is made to Section G of the files)
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List of Applicable Components 7.
Correspondence (infrequent reference to file Section G)
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Installation / Maintenance Requirements (serves as basis for detailed plant maintenance procedures)
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Calculations Section E - Replacement Component Evaluation Sheets (RCEs)
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The NRC inspectors examined files for 26 equipment items, where an item is defined as a specific type of electrical equipment, designated by manufacturer and model, which is representative of all identical equipment in a plant area exposed to the same environmental service conditions. The items were selected in advance by the inspection team and identified to the licensee during the entrance meeting.
The files were examined to verify the qualified status of equipment within the scope of 10 CFR 50.49.
In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selectively reviewed areas such as required post-accident operating time compared to the duration of time the equipment has been demonstrated to be qualified; similarity of tested equipment to that installed in the plant (e.g.,
insulation class, materials of components of the equipment, test configuration compared to installed configuratio3, and documentation of both); evaluation of adequacy of test conditions; aging calculations for qualified life and replacement interval determination; effects of decreases in insulation resistance on equipment perfornance; adequacy
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of demonstrated accuracy; evaluation of test anomalies; and applica-biHty of EQ problems reported in IEBs/ ins and their resolution.
The files were well organized and clearly documented qualification of the equipment except as described below.
(1) Limitorque operators - Review of files covering Limitorque valve motor operators revealed no deficiencies except with regard to the generic concerns addressed below. The inspectors particularly addressed in-containment operator E51-MOV F007, which.is covered by QDP-55 for operators with no T-drains (T-drains are generally required for operators located inside containment).
In this specific case, the qualification test report 600198 (F-C2232-01) specimen did not have "T-drains" installed and was mounted vertically.
The installed operator is mounted in the most conservative position (horizontal limit switch and motor).
In addition, the only conduit penetrations are in the bottom of the installed operator, thus minimizing the possibility of moisture instrusion; the unsealed conduit entry also provides a drain path.
(Although this operator was not accessible for physical inspection, the installed orientation was verified from photographs provided by thelicensee.) Therefore, this operator is considered qualified for its application with respect to T-drains.
a.
Information Notice 86-03: Potential Deficiencies in Environmental Qualification of Linitorque Motor Valve Operator Wiring.
Selected valve motor operators for Plant Hatch, Unit 1, were inspected by GPC prior to March 21, 1986, to deter-mine the applicability of IN 86-03, and unqualified
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internal wiring was identified. All operators that were identified as inaccessible or critical to power operation were inspected and upgraded to assure compliance to IN 86-03 prior to the Unit 1 startup following the November 1985 through May 1986 outage.
All additional EQ operators for Unit I had JCOs in place on May 2,1986, prior to the Unit 1 startup.
All necessary upgrading was completed by July 1986.
Unit 2 operated from before November 30, 1985 until the mid-September 1986 refueling outage shutdown.
During this period, the qualification of internal wire was in an unknown status. The Unit 1 JCOs were determined to be generically applicable to Unit 2 on June 2, 1986. The GPC Unit 2 inspection to address the concerns of IN 86-03 commenced on July 7, 1986.
Internal wiring for which qualificatio3 could not be established was identified. The JCOs unique to Unit 2 were not in place until July 24, 1986.
GPC stated that
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upgrade work to address the concerns of IN 86-03 for
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Unit 2 was completed on 32 of the 66 accessible operators by August 14, 1986, and that all EQ-related operators would be upgraded prior to Unit 2 startup. GPC submitted a detailed status report on Limitorque internal wiring to the NRC Region II office on August 22, 1986.
b.
Limitorque Recommended 6 Month Cycling Interval.
Limitorque test report B0058, Section 10.1, recommends that Limitorque operators be cycled at least once every 6 nonths to assure proper grease mixing and part coating.
By letter dated November 6, 1986, from Limitorque to Plant Hatch, Limitorque stated that the intent of Section 10.1 of B00058 is to establish the actual cycling frequency based on historical data for the installed equipment.
The licensee for Plant Hatch, Units 1 and 2, provided a list of all EQ operators that are not stroked at least once every 6 months due to plant procedures and operating restrictions. A search of naintenance records for Unit I and 2 operators over the life of the plant reveeled no failures that could be attributed to the condition of the grease or the condition of the actuators due to failure to perform the 6 month stroking. Therefore, an 18 month stroking frequency appears to be acceptable.
During the Plant Hatch Unit 1 outage from November 1985 through May 1986, all EQ operators either had actuator replacement to address 10 CFR 50.49 concerns or had a full grease replace-ment. During the Unit 2 outage which commenced mid-September 1986, all 122 operators were scheduled for inspection in accordance with the 18 nonth and/or 36 month maintenance requirements as appropriate.
c.
Information Notice 86-71: Recent Identified Problems with Limitorque Motor Operators, Burn Damage to Limit Switch Area Wiring and Cracked Limit Switch Rotors.
The concerns addressed in IN 86-71 apply to 98 Linitorque operators in Plant Hatch Unit 1 and 122 in Unit 2.
As of November 6,1986, the status of licensee inspection and repair was as follows:
Unit 1 Unit 2 Valves inspected 94 of 98 117 of 122 Cracked Rotors found
5 Cracked Rotors replaced
5 Burnt Wires found
1 Burnt Wires replaced
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Only one burnt wire was found during the inspection. The
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wiring insulation was damaged but had not burred through to the conductor. The wiring was replaced and routed away from the space heater. The cracked rotors exhibited only minor cracking, and appear to have operated over a long period of time with these cracks.
Failure of Linitorque operators due to rotor cracking does not appear to be a significant concern at Plant Hatch at present, and continued surveillance under existing plant procedures will monitor any degradation.
d.
Other Limitorque concerns.
In addition to the above areas, the inspe-tors reviewed the action taken by Plant Hatch to address Limitorque concerns idertified in Inspection and Enforcement Manual Temporary Instructions 2515/75 and 2525/76 and in Infomation Notice 86-02, " Failure of Valve Operator Motor (Magnesium Rotor)
During Environmental Qualification Testing," as well as the timely completion of Limitorque operator upgrading from the requirements of the D0R Guidelines to the requirements of 10 CFR 50.49 in accordance with Regulatory Guide 1.89.
No deficiencies were found in these areas.
e.
Summary.
Although the licensee was performing acceptable inspections and corrective actions with regard to internal wiring, the inspectors concluded that the timeliness of those activities was inadequate to ensure ongoing operator qualification for Plant Hatch, Unit 2.
Adequate actions were taken for Unit 1 prior to its first restart after November 30, 1985. But Unit 2 operated after November 30, 1985 with the following 00R Guidelines qualificatien deficiencies:
(i) Plant specific JCOs for internal wiring were not in place until July 24, 1986, although Unit 1 JCOs were declared generically applicable on June 2,1986.
(ii) Physical inspection to identify unqualified internal wiring in Unit 2 did not commence until July 7, 1986, and replacement of unqualified wiring was completed for only 32 of 66 Unit 2 operators by August 14, 1986.
Linitorque operator wiring constitute for Plant Hatch Unit 2 Potential Enforcement / Unresolved Item 50-366/86-35-01.
(2) Okonite cable (0koguard EPR, Okolon EPR, Okozel tefzel, and Okonite FMR), QDP 14, AND Okonite splice tape (T-95 insulating tape and T-35 jacketing tape), ODP 29 - The files contained no data reflecting cable performance (e.g., in,sulation resistance)
during the LOCA test, and no plant performance requirenents were identified. Appropriate test data were obtained by GPC
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during the inspection, after the problem was identified by the
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Review of plant requirements for terminal blocks and transmitters indicated that these data were sufficient to permit correction of the QDP deficiencies and demonstrate the claimed qualification to 10 CFR 50.49. Okonite cable and splices constitutes Potential Enforcement / Unresolved Item 50-321/86-35-01; 50-366/86-35-02.
(3) States terminal blocks (ZWM and NT), ODP 4 - The files did not compare errors determined during type testing with plant application performance criteria to establish acceptability under the 00R Guidelines. Before the end of the inspection the licensee stated that in-containment terminal blocks are not used in transmitter circuits at Plant Hatch (transnitter appli-cations outside containment are addressed in the next section of this report). Accordingly, the most limiting in-containment use of terminal blocks is with resistance temperature detectors (RTDs). The licensee provided an error calculation for an RTD used for temperature compensation of the reactor vessel level measurement. A terminal block error of 0.59 F, based on GE report 24A1206BD, led to an RTD loop error of 0.72F. At the close of the inspection the licensee had not identified the allowable error, so the acceptability of the terminal block in that circuit could not be determined. States terminal blocks comprise Potential Enforcement / Unresolved Item 50-321/86-35-02; 50-366/86-35-03.
(4) Rosemount 1153B transmitters, QDP 26 - The files did not address the impact of terminal blocks on transmitter circuit accuracy for harsh environments. As described in the previous section of this report, the licensee stated that in-containment terminal blocks are not used in transmitter circuits.
In response to ouestioning by the NRC inspectors, the licensee performed an error analysis for T48-DPT N210, a 0 to 30 inch water column differential pressure transmitter in the primary containment purge and inerting system.
Plant Hatch uses States and Buchanan terminal blocks in non-sealed enclosures. Available test data showed that both types maintained insulation resistances of 180,000 to 190,000 ohms in unsealed enclosures during LOCA testing that erveloped all HELB conditions outside containment at Plant Hatch. Using the methodology of NUREG/CR-3691, the licensee showed that the terminal block error increased the HELB error due to the trans-mitter alone from 2.63 to 2.64 inches, still within the allowable value of 2.7 inches.
Neither the QDP files, any calculations referenced in it, or plant setpoint analysis PI-10.6 contain the analysis of terminal block error that was perfomed during the inspection in response to questioning. The licensee stated during the exit meeting that the analysis need not be placed in the ODP itself; this is correct, but the EQ files Pfdst either contain l
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or reference appropriate analysis to show qualification to the
- 00R Guidelines. Rosemount transmitters constitutes Potential Enforcement / Unresolved Item 50-321/86-35-03; 50-366/86-35-04.
(5) Target Rock solenoid valves, QDP 10 - The file information stated that no aging analysis had been performed because the valves will fail to a safe condition.
It also stated that a life of 20 years was available for all components of the valves and their operators at 120F ambient. The files did not contain a sufficient des-cription of the model 73K003 valves to support an evaluation of whether the valve wculd indeed close and shut off flow in the event that electrical power was removed from the coil (i.e.,
" fail safe") during or after exposure to a harsh environment.
Neither did the files contain a sufficient description of the model 73K003 valves, nor the model 76HH002 valves which were cualification tested, to determine whether the two models of the valves were similar as claimed.
The files did not specifically address the more severe operating environment actually experienced by the D11-SVF050 and 52 valves as opposed to that experienced by the 76HH002 valves in the deenergized condition as reported in Target Rock Test Report 2302 Revision B.
The more severe operating environment results from self heating when the normally deenergized valves are used energized to achieve a " fail safe" state, and from use on 135 F process. fluid. Coil generated heat and heat transferred from the process ccmbine to increase the operating environment of the normally deenergized valve internals to above the 100 F name plate environment and the 120 F system component evaluation worksheet value. While the chortened lifetime was not evaluated in the files, GPC was able to produce work packages showing that the internal rubber parts had been replaced in 1986 in recogni-tion of a Target Rock letter stating that normally deenergized design valves which are used normally energized should have their internal rubber parts replaced every 5 years.
In addition, prior to the end of the inspection the licensee produced suffi-cient information to show that (1) there are no elastomers to hinder closing of the valves when the power is removed, and (2)
the resilient disk and other internal rubber parts can be expected to have a lifetime of over 5 years.
Thus, although the files did not support qualification to 10 CFR 50.49 information
obtained during the inspection in response to questioning contained the basis for a satisfactory revision of the files to meet 10 CFR 50.49.
Target Rock solenoid valves constitute Potential Enforcement / Unresolved Item 50-321/86-35-04; 50-366/86-35-05.
(6) HPCI turhine hydraulic controller (Terry, General Electric, Square D, Namco, Woodward), QDP 51 and 56 - Qualification of this equipment was simplified because Plant Hatch does not take credit for this system in the event of an HELB in the HPCI 00R Guidelines qualification deficieficies were observed room.
with respect to the de auxiliary lube oil pump motor.
Neither the file nor the Terry Corporation Installation and Maintenance
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manual define motor maintenance requirements, and records could
- not be located for monthly maintenance after June 1986 and for one semiannual maintenance. A future NRC inspection will verify that these deficiencies are corrected. HPCI turbine controller constitutes Open Item 50-321/86-35-05; 50-366/86-35-06.
G.
Plant Physical Inspection The NRC inspectors, with component accessibility input from licensee personnel, established a list of eleven component types in both units for physical inspection. Multiple specimens of most types were inspected. Local radiation levels and plant operational concerns with respect to equipment tagout, even in the shutdown unit, limited access to certain components such as General Electric F01 containment penetrations and specific Limitorque operators, but a representative walkdown selected was obtained. The inspectors examined characteristics such as mounting configuration, orientation, interfaces, cable seals and splices, model number, ambient environment, and physical condition.
The inspectors observed the concerns listed below.
(1) The actuator arm was loose on Namco limit switch 2E41-F029 (0 pen). GPC immediately issued a corrective Maintenance Work Order, MWO 2-86-6674, which was closed out before the end of the inspection. The jam screw (threaded expansion plug) in the hub was found to be loose.
(2) During the walkdown inspection the NRC inspectors examined General Electric pressure switches 2B21-PS N301A, G, H, K, L, and M.
The flex conduit from one switch was broken loose from its junction box connection. The metal identification tag for one switch was missing, and two others were illegibly damaged (these switches were identified from tags on nearby isolationvalves).
(3) The flex conduit for one beed temperature element 2T47-N001J was broken loose from its junction box connection. MWO 2-86-6580 had been written two days before the NRC inspection to correct this deficiency.
(4) The conduit for one Victoreen high range radiation fronitor, 2011 N003A or B, was not properly connected.
(5)
For Rosemount differential pressure transmitter T48-DPT N210 the junction box gasketing was not intact; a mounting screw was missing for the metal plate to which the terminal block is attached; and a small amount of loose debris lay in the bottom of the box. Prompt corrective action was initiated.
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All of these deficiencies except the transmitter junction box were found in Unit 2, which was shutdown at the time. The licensee stated that they probably would have been discovered and corrected during pre-startup system walkdowns. Nevertheless the number of walkdown deficiencies at Plant Hatch was higher than for most 10 CFR 50.49 inspections to date, even though access constraints slightly restricted the number of walkdown samples. The NRC will verify that all of the identified deficiencies are corrected during a future inspection.
Walkdown deficiencies constitute Open Item 50-321/86-35-06; 50-366/
86-35-07.
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H.
Cable Trace The inspectors obtained wiring block diagrams for control and power wiring to 11 items inspected during the walkdown. The wire and terminal box identification numbers were then checked against infor-nation recorded by the inspectors perfonning the walkdown. Complete agreement was found in five cases. On three items one or more wires were unlabeled, and in two cases the wiring block diagrams had not yet been revised to reflect field changes implemented three years earlier.
This three year backlog had been identified on earlier inspections.
In one of the two cases the request for the wiring block diagram produced an out of date drawing from document control. This was not recognized until after the walkdown revealed that the drawing infor-mation was not correct.
In the other case, no information could be produced prior to the walkdown. When it was realized that the missing information was part of the backleg, the licensee was able to produce documentation of field changes which did accurately portray the infor-mation obtained during the walkdown.
The foreman and the electrician in the maintenance department were asked about the significant number of untagged leads on equipment in the plant. They replied that the untagged leads are left over from plant construction. A current procedure requires that wires must be identified end tagged before any leads are lifted for maintenance.
GPC personnel could not recall any instance where the large number of untagged leads, the three year backlog of drawing updating and the availability of misinformation from document control had combined to cause problems where unidentified wires were subsequently misidentified.
The inspectors noted that an earlier problen involving wire and cable identification at Plant Hatch was reported in LER 84-005 and Inspection Report 50-321/84-31;50-366/84-31. That problem involved unidentified cables entering safety-related panels, and was resolved by licensee inspection and tagging of leads under Procedure HNP 2-10280,
" Identification, Control, and Resolution of Problems with Class IE Electrical Panels." The recurring nature of this problem suggests that GPC may wish to consider stronger remedial action for the cables ex'.ernal to panels.
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