IR 05000348/1987025

Insp Repts 50-348/87-25 & 50-364/87-25 on 870914-18.No Violations or Deviations Noted.Major Areas Inspected: Equipment Qualification Deficiencies Identified by Licensee on Solenoid Valves & motor-operated Valves

ML20236B772
Person / Time
Site:	Farley
Issue date:	10/16/1987
From:	Conlon T, Levis W, Merriweather N, Paulk C, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236B697	List: IR 05000348/1987025 ML20236B694
References
50-348-87-25, 50-364-87-25, GL-85-15, GL-86-15, NUDOCS 8710260343
Download: ML20236B772 (7)

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Report Nos.: .50-348/87-25 a'd n 501364/87-25l

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           .y Licensee: Alabama Power.'. Company-      y  '

600 North!18th Street .. ]h Birmingham,eAL 35291-0400- J L . Docket Nos.: 50-348, 50'-364 License'Nos.:.LNPF-2, NPF-81 y Facility Name: Farley 1 and 2 Inspection Conducted: -September 14-18,~1987' q Inspection:at Farley si e ear Dotha'n,' Alabama Inspectors: N. Merriweather 4<+ r /d' II75 Date-Signe , w f , }. ,- /0 -/6 - f 7 * C.'Pa lk * Date Signed

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C. Smith m hf h ~ ~ /0 04 - f ') Date Signed 1 f W. Levis k,r y fr- .

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Approved by: /[> //2/a/8 M// /6 h?f -D '

            :1 T. E. Conlon, Sectio vChief    Date Signed'   d Division of Reactor Safety        -!

SUMMARY Scope: This special, announced inspection was performed.to followup.on the EQ- j L , deficiencies identified by the licensee on solenoid valves, motor operated-L valves-and inside containment fan motors.

L ' Results: No violations or deviations were identifie i H i 8710260343 871016 PDR ADOCK 05000348 f?? ' l G PDR ,

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i REPORT DETAILS Persons Contacted-Licensee Etployees ]

 *J. D. Woodard, General Manager
 *W. B. Shipman, Assistant General Manager - Technical Support
 *D. N. Morey, Assistant General Manager - Operations
 *C. D Nesbitt,' Technical Manager
 *D. H. Jones, Supervisor, Design Support
 *L. A. Ward, Maintenance Manager
 *B. R. Yonce, Electrical Maintenance Supervisor-   6
 *W. G. Ware, QC Engineer R. G. Berryhill, Systems Performance- (SP) Manager -  ,
 *L. S. Williams, Training Manager
 *L. M. Shinson, PMD Manager
 *L. M. Enfinger, Administration Manager   1
 *J. J. Thomas, SP Engineer
 *E. W. Carmack, Unit Supervisor G. Dykes, Lead Electrical Engineer C. Buck, Discipline Engineering Supervisor   b Other licensee employees contacted included craftsmen, engineers, technicians, security force ' members, storekeepers, and office personnel in the warehouse, l

Other Organizations

 *J. E. Love, Bechtel Engineering
 *C. R. Foltz, Bechtel Engineering
 *C, J. Vaz, Bechtel Site
 *E. A. Raves, Farley Project Manager, NRC NRC Resident Inspectors
 * Bradford, Senior Resident Inspector
 * Miller, Resident Inspector
 * Attended exit interview Exit Inte'rview The inspection scope and findings were summarized on September 18, 1987, with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in' detail the inspection findings. The following new items were identified during this inspection: Unresolved Items 50-348,364/87-25-01, Unqualified Splice on Hydrogen-Recombiners, paragraph .
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1 Unresolved Items : 50-348, 364/87-25-02.a. Procurement o'f Commercial-f

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Grade Components for EQ Applicat; ions, paragrr.ph: .

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    ' Unresolved Items' 50-348,364/87-25-02.b].InadequateUpgrade: Program-for   c EQ Components, paragraph 5-b;
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       ,r o Unresolved Items 50-348,364/87.-25-03,' Inadequate" Peer Review Program,.   *

paragraph. ~

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. Unresolved Items 50-348,.364/87-25-04, Use of UnqualifiedLGrease' on;   .

MOVs, paragraph 5.d.- Unresolv'ed Items '50 348, 364/87-25-05,: Unqualified Lubricants,t para- - ~ ' graph '

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The licensee did'not identify as p'roprietary any of. the; materials provided to or reviewed by the inspectors during .this? inspectio '

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Subsequent to the' inspection,' telephone conversation.ns and,a meeting wer T held with licensee management.' to . discuss. the . inspection- findings y and - corrective actions to be taken for resolution of the identified?defi - ciencie . Licensee Action on Previous Enforcement Matters-See paragraph 5 for more information on previously identified enforcement matter ' d Unresolved Items . Unresolved items are matters about which more information .is required ) to determine whether they are acceptable ortmay involve. violations:o H deviations. Five unresolved'. items identified during- this inspection 'are-discussed in paragraph , Followup On Licensee Identified EQ Splice Problems During the weeks of May 11-22, 1987, and Jun'e 1-5, 1987, a Procurement and: Vendor Technical . Interface Program Inspection was performed by :NRC. In order to address concerns expressed:by the NRC inspection. team and.recent-EQ maintenance problems experienced by other utilities -(such as Calvert Cliffs), Farley management formed an Environmentally 2Qualified Equipmen J o Document Verification task team on June 15, 1987, to' review-maintenance-  ! records to verify that EQ equipment had been maintained in a qualified-status.

l l On July 16, 1987, the licensee's task team noted a potential problem with the electrical connection between the solenoid ' pigtails and. the field wires. Plant inspection of a sample solenoid. valve on July.20,,1987, y confirmed that the connection was not in accordance with design and the

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l licensee subsequently notified NR A JCO.was' prepared for the solenoid valves to a'llow for continued operation based on the operability require.- ments of the solenoid valve Further review by the licensee's task team indicated that the potential problem also existed with' M0V motor lead splices and other 600V motor terminations. A JC0 was prepared for the MOVs on July 30, 1987. Three . , MOVs in each containment were not capable of justification for continue " operation and required immediate configuration verification._ These valves were inspected and subsequently repaired :on July 31, 1987 and August 1, 1987.

l On August 4, 1987, the licensee's task team identif.ied the same potential splice problem with containment fan motors. There were ten fans involved per unit, which affected several systems. Instead of preparing a JC0 for these fans as recommended by Generic' Letter'86-15 and as done previously with the S0Vs and M0Vs, the licensee chose to. inspect the' motor termina-l tions one train at a time and correct deficiencies as they were foun l In this manner, the train was declared inoperable during the inspection and repair and later declared oparable upon completion of repairs. All 1 splices / terminations for the containment fan motcrs were found to be . deficient and required replacemen The work was accomplished for i Unit 1 from August 7-13, 1987, and for Unit 2 from August 13-19, 198 ' During the week of September 14-18, 1987, NBC Region II performed a Reactive Inspection to followup on the EQ splice deficiencies identified by the licensee on solenoid valves, motor operated valves,. and inside l containment fan motors. The inspection concluded that .there was 'not I sufficient documentation to establish qualification of the installed 1 splices. The splices were determined to be unqualified as defined b Generic Letter 85-15. The unqualified configuration is a . type V-stub connection splice using T95 tape for insulation and T35 tape for jacket material. This configuration is not covered by design drawings or engineering instructions and has not been environmentally tested for Design Basis Accidents (DBA) (e.g., Loss of Coolant Accident (LOCA), High Energy Line Break (HELB)) by ApCO. This type of splice is not completely sealed. It can allow moisture to travel along the cables to the V-stub connectio The root cause of these unqualified . configurations was determined to be due to incomplete design drawings / engineering work instructions and misinterpretation of electrical notes and details by craf It should be noted that the drawing did not address the V-type stub ' connection but indicated that the Raychem splice kit for in-line splices should have been used in the above application The splice issue for SOVs, M0Vs, and the containment fans were previously identified as Unresolved Items 50-348, 364/87-17-01, 02, and 03, respec-tively, and will remain ope Additionally, potentially unqualified splices may exist in electrical penetrations and instrumentation circuits inside containment. The licensee did not perform adequate walkdowns prior to November 30, 1985, to ensure compliance with 10 CFR 50.4 r

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Other specific concerns expressed by the inspection team and left as unresolved items at-the exit meeting include: The licensee has not established qualification for the in-line splice configuration used on the hydrogen recombiner on both trains iri both units. The assumed configuration.as described 'in the licensee's JC0 dated September 17,1987 (letter No.13525), identified a one-to-five splice configuration. The team's concern is that.this configuration will allow moisture egress into the' unsealed splice region along'the heater lead cables causing potential fault paths. The EQ central l . files only address a SKV'in-line one-to-one splice configuration and l do not provide adequate information to establish reasonable assurance 3 o that the 'five-to-one- splice will perform its intended function. It' should be noted that the licensee also took credit for. operability =of l the hydrogen recombiners in their JC0 on motor operated valves dated July 30,1987 (letter No. NS-87-0241). This item is identified as-Unresolved Item 50-348, 364/87-25-01, Unqualified Spl. ice Ani Hydrogen Recombiners.

The tapes procured for these splices (i .e. .. V-type or in-line)

are procured as commercial grade (Code C), and have been since construction. No program existed to dedicate Code C components for safety-related and/or EQ applications. ~ The current program allows for the foreman or above supervision to substitute commercial grade (Code C) parts or components into safety-related and/or EQ applica- , I tions (Code A). The licensee acknowledged a deficiency in their l procurement program for Code C items and are undertaking corrective  ! action In addition similar deficiencies concerning use of  ; commercial grade items in EQ applications was identified by the l Vendor Program Branch Inspection -Report (50-348, 364/87-11). This I item is identified as Unresolved Item 50-348, 364/87-25-0 Procurement of Commercial Grade Components for EQ Applications.

I i ! Additionally, the licensee's EQ Administrative Program does not ' address upgrade requirements as specified in 10 CFR 50.49(L). The licensee does not agree with this finding. However, contrary to the requirements of 10 CFR 50.49(L) procedural controls have not been established to document reasons to the contrary for not upgrading replacement equipment. The licensee considers that their program meets their commitments as specified in their letter dated February 29, 1984, which states in part that "if identical components cannot be obtained", the exiting equipment is required to be replaced with new components procured to meet provisions of test reports that have been reviewed and accepted by APC0 to the requirements of-10 CFR 50.4 This item will be submitted to NRR for further review and is identified as Unresolved Item 50-348, 364/87-25-02.b, Inadequate Upgrade Program for EQ Component Peer inspections of splice configurations on the ~ containment mixing fan motors were inadequate and did not reflect drawing requirement Recent walkdown inspections of the fan motors showed only the use of I _ _ _ - - - ~ - _ _ . _ ~ _ -

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T95 tape in V-configuration which areinot in' accordance withl desig , 3 and are not environmentally qual.ified. ' Maintenance Work' Requests 3

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used ~ to determinate and determinate splices. during -the previous -  ; outages. on ' each unit.~ indicated.- that the splices were . documented as' ; being in accordance with -design by .an inspection performed by 'the -

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i forema Spec 1tically,: MWR .'147889, .' completed November- 13, 1986,- on 'Uniti11 .

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documented that. the. splices on containment (Mixing; Fan Motors 11B and' IC were in accordance with design. < However, during .the recent walkdowns on Unit.1,'it was found that.these . fan motorL splicesFonly had T95 ' tape in a- V-configuration.which is not in accordance .with design (reference MWRs 159078.and 159079), indicatin'g:an inadequate peer review. In addition, other deficiencies were identified'by

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l the Vendor Program Branch and are documented in Inspection. Report 'j No. 50-348, 364/87-11, which are . indicative. of- generic problems ~-in . 1 the area of " Peer Reviews ~." This is Unresolved Item'50-348,: 364/ t l 87-25-03, Inadequate Peer Review Progra , d. The Limitorque Motor Operated Valves '(MOVs)' used by FNP inside containment were supplied by. the vendor with Exxon _ Nebula; EPO..or EP1 j grease in the main gear boxes. The potential'o/ having incompatible .! greases inside the main gear. box exists' as -a result of maintenance

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performed with Texaco MARFAK AP grease, which is a. lithium soap-base 'l versus Nebula which is a calcium soap base..'The lubrication checks -{ as specified by the FNP Lubrication Manual. (R12) are performed every.- J 548 days and MARFAK AP is added as .necessary to ensure sufficient 1 grease level . There is no requirement to completely change .the greas Limitorque specifically states' that greases of different soap bases should not be mixed. In addition, this problem wa detailed further in INP0 SOER 7-84. The team:noted that the plant-response to this 50ER was to be included in that of.IEB 85-03 which is not yet complete Another item of concern to the team was the fact that no documenta- 1 tion was presented to the team to establish the environmental I qualification of the MARFAK AP grease for inside: containment applications or SUN SOEP grease for outside containment application The licensee stated that they had information addressing MARFAK. AP but it was still under review and was not yet approved. Subsequent-to the inspection, the licensee provided :the' team a copy of. a- JCO for mixed grease used in MOVs. This is identified as Unresolved: Item 50-348, 364/87-25-04, Use of Unqualified Grease on MOV . e. No documentation was presented to the inspection team which supported: the use of Premium RB grease on fan motors inside containment- and ~ room coolers outside containment.- The root cause isithat lubricants

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were not included on the EQ Master list of EQ ' equipment and component Subsequent to the inspection, the licensee documented.a JC0 to allow - continued operation with this - deficienc This is identified as - Unresolved Item 50-348, 364/87-25-05, Unqualified Lubricant a

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Additionally, the inspection team was concerned with the installation and qualification of other EQ equipnent, such as electrical penetra-j 4

tions and instruments inside the containment.- The licensee did not 1 have adequate justification or documentation to accurately verify.the i installation configuration in order to assure that the additional ] equipment was qualifie Such . documentation should have been l available had the licensee performed adequate walkdowns to ensure j compliance with 10 CFR 50.4 j l On September 22, 1987, a conference call was held between NRC staff and APC0 to. discuss the inspection team findings and actions taken by .] APC0 to resolve deficiencies previously identified by themselve { Numerous questions were _ posed by the staf f; however, the. answers ; provided by APC0 were not sufficient to satisfy NRC concerns at that- j time. These issues will be examined further during the planned EQ l inspection in November 198 l l

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