IR 05000382/1988010

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Insp Rept 50-382/88-10 on 880418-22.Violations Noted.Major Areas Inspected:Licensee Corrective Action Program Effectiveness
ML20195J487
Person / Time
Site: Waterford Entergy icon.png
Issue date: 06/01/1988
From: Boardman J, Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195J436 List:
References
50-382-88-10, IEIN-87-066, IEIN-87-66, NUDOCS 8806290141
Download: ML20195J487 (7)


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APPENDIX B U.S. NUCLFAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-382/88-10 Operating License:

NPF-38

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Docket:

50-302 Licer,see:

Louisiana Power & Light Company (LP&L)

317 Baronne. Street New Orleans, Louisiana 70160 Facility Name: WaterfdrdSteamElectricStation, Unit 3(Wat-3)

Inspection At: Wat-3, Taft, Louisiana Inspection Conducted:

April 18-22, 1988 Inspector:

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. Boardman, Reactor Inspector, Operational Date G

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grams Section, Division of Reactor Safety

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E. 7(gliardo, Chief, Operational Programs Date Sectt6n, Division of Reactor Safety Inspection Summary Inspection Conducted April 18-22, 1988 (Report 50-382/88-10)

Area Inspected:

Routine, unannounced inspection of licensee corrective action program effectiveness.

Results: Within the area inspected, one violation was identified (failure to have documentation of qualification as required by 10 CFR 50.49(j),

paragraph 2).

8806290141 880617 PDR ADOCK 05000382 G

PDR

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DETAILS 1.

Persons Contacted LP&L

  • N. S. Carns, Plant Manager
  • S. A. Alleman, Quality Assurance Manager
  • J. R. McGaha, Nuclear Operations Engineering ai.d Construction (N0E&C)

Manager

  • T. F. Gerrets, Nuclear Services Manager
  • R. G. Azzorello, Manager, Electrical / Controls
  • D. W. Vinci, Maintenance Superintendent
  • L. L. Bass, Technical Support Supervisor
  • M.

Meyer, N0E&C

  • C. R. Gaines, Event Analysis and Reporting (EA&R)
  • J.

E. Howard, EA&R

  • D. Gallodoro, N0E Procurement
  • G. W. Robin, N0E Inservice Inspection
  • G. E. Wuller, Operational Licensing Supervisor
  • L. Laughlin, Licensing NRC
  • I. Barnes, Chief, Materials & Quality Programs Section, RIV
  • D. D. Chamberlain, Chief, Reactor Project Section A, RIV
  • W. F. Smith, Senior Resident Ir.spector, RIV
  • E. Tomlinson, NRR, PDIV
  • K.

C mpsey, NRR/EMEB

  • R. C. Stewart, Reactor Inspector, RIV The NRC inspector also interviewed additional i nensee personnel during the inspection period.
  • Denotes those persons that attended the exit interview conducted on April 22, 1988.

2.

Licensee's Corrective Action System (92720)

This inspection involved a performance oriented review of the licensee's corrective action program to identify, follow, and provide an effective solution to problems.

The findings discussed in report Sections 2.a through 2.c below were selected examples of licensee corrective actions to problems previously identified by the NRC, and a licensee action in response to an NRC Inspection and Enforcement Information Notice (IEN).

The examples were used to determine the effectiveness of the licensee's corrective action program.

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a.

Effectiveness of Licensee Response to Violation 382/8425-01 - Dealing with Licensee Control of Vendor Manuals Violation 382/8425-01 cited the licensee for failure to have procedures to assure proper control of vendor manuals and to assure that vendor manuals are properly implemented in maintenance activities. An example in the inspection report related to this violation was failure to use grease for lubrication of containment fan motors as specified in the applicable vendor manual.

Licensee letter W3P85-1237 dated April 29, 1985, which responded to Violation 382/8425-01, stated:

"An ongoing program to verify adequate documentation of decisions concerning preventive maintenance with respect to any deviations from vendor recommendations, as prescribed in vendor manuals, has been implemented at Waterford 3.

To date, LP&L has performed a technical review of environmentally.

qualified / safety-related vendor technical manuals, extracted individual vendor recommendations applicable to Waterford 3 from those manuals, and is in the process of identifying deviations from those vendor recommendations.

"LP&L requires additional time to achieve full compliance regarding the insrection item commitment. The initiation of corrective actior, or other appropriate resolution for deviations identified durir.9 this initial effort is rescheduled for August 1, 1985."

This inspectior. revealed that lubrication of the Waterford 3 containment cooling fans was accomplished using lubricant other than that specified by the motor manufacturer's technical manual without adequate documentation to support the grease substitution.

It was determined that lubrication of these motors was accomplished using Mobil Temp SHC-32.

The containment cooling fan equipment qualification report, Joy Manufacturing Company Report X-604, dated April 6, 1977, and the licensee's EQ Maintenance Input Report No. LPL-EQMI-4.1, Revision 2, approved May 22, 1987, require the use of Chevron SRI-2 grease.

The use of Mobil Temp SHC-32 grease was based on Project Evaluation /

Information Request (PEIR) 70023, which was approved October 11, 1984.

This PEIR does not contain empirical test data to support the substitution, and predates LPL-EQMI-4.1, Revision 2.

10 CFR 50.49 requires a record of equipment qualification based upon temperature and pressure, humidity, chemical efrects, radiation, aging, and synergistic effects, including safety margins.

The licensee had no available documentation of the environmental qualification of the subject motors using Mobil Temp SHC-32 grease, or an admixture

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of Mobil Grease and SRI-2 grease.

Subsequent review by the NRC indicated that Mobil Temp SHC-32 grease was probably acceptable because it contained the same gelling agents and exposure data as Mobil 28 grease. Mobil 28 is an allowable substitution for SRI-2 as documented in EPRI-NP-4916. However, an admixture of the two greases would require additional evaluation.

Failure to have the required documentation of environmental qualification is an apparent violation (382/8810-01) of the above 10 CFR 50.49 requirement.

b.

Effectiveness of Licensee Response to IE Information Notice (IEN)

87-66, Dated December 31, 1987, "Inappropriate Application of Comercial Grade Components" This information notice dealt with the fact that commercial grade Agastat relays (7000 series) were not manufactured with design change and configuration controls. As a result, qualified life expectancy was not projected beyond 2 years for these relays.

The NRC inspector found that there were 111 commercial grade Agastat relays, over 2 years old, installed in safety-related applications.

Of these, 54 had been scheduled for replacement during the current outage. Many of the installed relays had been manufactured during the second quarter of 1978.

All relays were scheduled for replacement, but none had been scheduled specifically in response to IEN 87-66.

The licensee considered the commercial grade relays still qualified based on the following documented facts and logic:

The 7000 series Agastat relays were originally purchased and

qualified Class 1E as part of the relay control panels. The specifications associated with the referenced purchase orders required this equipment to meet Institute of Electrical and Electronic Engineer (IEEE)-323-71 and IEEE-344-75 and other standards.

In addition, a Quality Assurance program (10 CFR 50, Appendix B) was imposed on the vendor by these specifications.

The specifications also required equipment to be qualified to

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l harsher environmental condition than the presently installed l

conditions fi.e., lower temperatures, radiation, and relative l

humidity).

It should be noted that the above equipment is i

located in a mild environment.

A review of the 7000 series Agastat relay (without "E" prefix)

l failures since 1982 (the inception of startup testing)

l identified only nine failures.

The failures were all the l

inability of the relays to meet timing calibration.

The licensee concluded that the failure of nine relays to be

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calibrated over a period of 6 years was acceptable.

On April 21, 1988, an LP&L telephone conversation with Amerace Corporation (manufacturer of Agastat relays), clarified the

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position on the 2-year life of the series 7000 Agastat relay (without the "E" prefix).

The 2 years does not apply to qualified life, but to relay warranty. This 2-year warranty is based on a lack of pedigree or material traceability.

Based on the above stated facts and logic and on operational history of the Agastat relays installed in safety-related panels at Waterford 3, the licensee had concluded that the installed relays did not present a problem and would perform their intended function throughout the outage.

The licensee committed to replacing all comercial grade Agastat relays in IE applications with nuclear grade (E-7000 series) relays prior to entering Mode 4.

The licensee did not interpret IEN 87-66 as stating that, because of the lack of design and configuration control, commercial grade Agastat relays could not be dedicated for 1E applications for longer than a 2-year design life, even though the relays were qualified to NRC accepted IEEE standards, c.

Effectiveness of Licensee Responses Identified in Letter W3P86-2806, Dated January 26, 1987, Providing Additional Information on Violations 382/84-42, 382/85-01, and 382/85-05 The subject responses described the licensee's program for reestablishing the acceptability of safety-related replacement parts and components utilizing forms entitled, "Spare Parts Equivalency Evaluation Reports (SPEERs)," and, "Part Quality Determination (PQDs)."

The inspection reviewed a sample of licensee SPEERs and PQDs identified in the licensee's response as being used to dedicate commercial grade items for safety-related applications.

SPEER 84-078, covering commercial grade anti-friction (ball)

bearings, was reviewed.

Included in this SPEER were a number of double shielded bearings. These bearings must be lubricated with the correct, equipment-specific grease by the bearing manufacturer prior to installing the shields. Licensees cannot remove a shield to repack the bearings with the correct, equipment-specific grease without changing bearing design characteristics.

The SPEER did not

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Specify correct lubricant when purchasing double-shielded (or

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double-sealed) bearings.

Control bearings by installed grease type.

  • l No replacement bearing and use data was reviewed during this inspection. This will remain an open item (382/8810-02) pending review during a subsequent inspection of end use of replacement bearings.

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3.

Preliminary Review of the Failure of Main Steam Isolation Valve MS-1248 (92720)

Waterford 3 experienced a mechanical failure of the downstream (closing)

disc guide bars on main steam isolation valve (MSIV) designated MS-1248.

Inspection of the upstream (opening) disc guide bar assembly revealed the following condition of the nine 5/8-inch diameter hexagon socket flat countersunk head capscrews used to secure each of the two guides:

For one guide, five of the nine capscrews were missing or broken as

follows:

one missing

three apparently failed at, or near, the head-to-body junction

one apparently failed above the threads in the body area

For the other guide, two capscrews were broken as follows:

one apparently failed at the 1st thread

one apparently failed above the threads in the body area

All capscrew failures appeared to be nonductile failures.

  • All capscrews were staked (punch marks of varying depths) at four places.

No rotation was apparent, one capscrew had its hexagon socket distorted as if a high torque were used in an attempt to remove it.

The capscrews exhibited rough machining (nonprecision).

The hex-sockets varied in depth and appeared crudely machined.

The following factors which can significantly affect bolt failure in this type joint had not been evaluated by the licensee:

Poor thread engagement (not class 3, improper tolerances)

Lack of hardness of the parts Conical joint makeup (such as a countersunk head capscrew)

High temperature creep

~ 1.25 diameter Thread engagement

l Improper torque and tightening methodology

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Improper preload inadequate radius of thread roots Tool marks, and poor surface finish

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Magnitude of load excursion l

Poor bolt / joint stiffness ratios l

Improper thread runout Inadequate fillet size and shape (head-to-body)

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Another factor affecting joint integrity was the question of whether or not the bar stock from which the fasteners were fabricated met the

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following design parameters applicable for the operating environment:

ASTME21(elevatedtemperaturetensiontests)

rupture, and stress-rupture tests).

ASTME139(creep, creep-(charpyimpacttests)

A320, Sections 6 and 7

i Followup activities with respect to MSIV repair and operability determination will be addressed in the resident inspector inspection report.

This preliminary review did not identffy any violations or deviations.

4.

Exit Interview An exit interview was conducted on April 22, 1988, with the licensee's representatives.(identified in paragraph 1). During this interview, the NRC inspector reviewed the scope.and findings of the inspection. None of the information discussed at the exit was identified by the licensee as being proprietory.

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