IR 05000445/1989064
| ML20248A679 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/26/1989 |
| From: | Latta R, Livermore H Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20248A653 | List: |
| References | |
| 50-445-89-64, 50-446-89-64, NUDOCS 8910020284 | |
| Download: ML20248A679 (21) | |
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APPENDIX C U..S.
NUCLEAR REGULATORY COMMISSION
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OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report:
50-445/89-64 Permits: CPPR-126 50-446/89-64 CPPR-127 Dockets: 50-445 Construction Permit 50-446 Expiration Dates:
Unit 1: August 1, 1991 Unit 2: August 1, 1992
' Applicant:
TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201
' Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2
. Inspection At:
Comanche Peak Site, Glen Rose, Texas Inspection Conducted:
August 2 through September 5, 1989 A/G9
"7 Inspector:
c R. M.
Latta, Resident Inspector Date (Electrical) (paragraphs 2, 3, 4,
6, 7, 8, 9, and 10)
Consultant:
W. D. Richins - Parameter (paragraphs 2 and 9)
J. L. Taylor - Parameter (paragraphs 2, 4,
5, 7, and 8)
Reviewed by:
M
H. H. Livermore, Lead Senior Inspector
/Date 1 89100g,y,kfk.
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Inspection Summary:
Inspection Conducted:
August 2 through September 5, 1989 (Report 50-445/89-64; 50-446/89-64)-
Areas Inspected: Unannounced, resident safety inspection of the-applicant's actions.on previous inspection findings, follow-up on violations / deviations, action on.10 CFR 50.55(e) deficiencies identified by the applicant, electrical components, instrumentation components, general plant' areas-(tours), allegation follow-up, and-safety-related mechanical components.
i Results:
Within the areas. inspected, a relative strength'was i
identified in.that. plant cleanliness concerns were quickly addressed by the' Unit 1 construction manager (pa ragraph 7).
During the inspection period, one violation was identified concerning the
' bypassing of a QC hold point by craft personnel while performing work evolutions on a safety-related cable tray (paragraph 5).
Additionally, one. deviation was identified pertaining to the applicant's failure to-replace-the Unit 1 emergency diesel generator wattmeters prior to hot functional testing as committed to in TU-Electric's letter TXX-88294 dated March 25, 1988,
'(paragraph 2.b).
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DETAILS 1.
Persons Contacted
- J.
L. Barker, Manager, ISEG, TU Electric
- D.
P. Barry, Director, CECO
- J. W. Beck, Vice President, Nuclear Engineering, TU Electric
- O.
Bhatty, Issue Interface Coordinator, TU Electric
- M. R. Blevins, Manager of Nuclear Operations Support, TU Electric
- H.
D. Bruner, Senior Vice President, TU Electric
- W.
J. Cahill,. Executive Vice President, Nuclear, TU Electric
- H.
M. Carmichael,. Senior QA Program Manager, CECO
- J.
T.
Conly,' APE-Licensing, SWEC
- W.
G. Counsil, Vice Chairman, Nuclear, TU Electric
- C.
G.
Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric
- B.
S. Dacko, Licensing Engineer, TU Electric
- R.
J. Daly, Manager,,Startup, TU Electric
- D.
E. Deviney, Deputy Director, Quality Assurance.(QA),
TU Electric
- S.
L.
Ellis, Performance and Test Manager, TU Electric
- J.
C.
Finneran, Jr., Manager, Civil Engineering, TU Electric
- C. A. Fonseca, Deputy Director, CECO
- J.
L.
French, Independent Advisory Group
- B.
P. Garde, Attorney, CASE
- J.
Greene, Site Licensing, TU Electric
- W.
G. Guldemond, Manager of Site Licensing, TU Electric
- T.
L. Heatherly, Licensing Compliance Engineer, TU Electric
- J.
C. Hicks, Licensing Compliance Manager, TU Electric
- C.
B. Hogg, Chief Engineer, TU Electric
- D.
L. Hubbard, Technical Training Manager, TU Electric
- A.
Husain, Director, Reactor Engineering, TU Electric
- J.
J. Kelley, Manager, Plant Operations, TU Electric
- J.
E. Krechting, Director of Technical Interface, TU Electric M. L. Lucas, Electrical Production Supervisor, TU Electric
- S.
G. McBee, NRC Interface, TU Electric
- J. W. Muffett, Manager of Engineering, TU Electric
- E.
F. Ottney, Program Manager, CASE
- S.
S. Palmer, Project Manager, TU Electric
- P.
Raysircar, Deputy Director / Senior Engineering Manager, CECO
- J.
D. Redding, Executive Assistant, TU Electric
- D.
M. Reynerson, Director of Construction, TU Electric
- M.
J. Riggs, Plant Evaluation Manager, Operations, TU Electric
- A.
B. Scott, Vice President, Nuclear Operations, TU Electric
- R.
L.
Spence, TU/QA Senior Advisor, IU Electric
- J.
F.
Streeter, Director, QA, TU Electric
- C.
L. Terry, Unit 1 Project Manager, TU Electric
- O.
L. Thero, QTC Consultant to CASE
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- T.
G. Tyler, Director of Management Services, TU Electric
- R.
G. Withrow, EA Manager, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection period.
- Denotes personnel present at the September 5, 1989, exit meeting..
2.
Applicant's Action on previous Inspection Findings (92701)
a.
(Closed) Open Items (445/8603-0-05 '.nd 445/8603-0-06):
Cable tray welding inspection discrepancies.
These open items concerned Evaluation Research Corporation (ERC)
deviation reports (EDRs) R-E-CATY-04 and R-E-CATY-24, respectively.
These DRs referred to the lack of documentation, including weld filler material logs for cable trays T140CDJ17 and TBORCJ28.
Specifically, the closure of these items was dependent on the satisfactory completion of nonconformance report (NCR) E85-101525SX which addressed the above DRs as well as one additional DR.
The NRC inspector reviewed the documentation associated with these open items and determined that the subject NCR had been transferred to NCR 89-01574 which resolved these issues by removing the existing welds and rewelding T140CDJ17.
Additionally, the NRC inspector examined the applicant's supporting engineering analysis, the results of the applicant's inspections for welds at T130RCJ17 and T130RCJ28, and the completed actions associated with cable tray T130RCJ17 contained in Design Change Authorization (DCA) 58483.
Based on the above reviews, the NRC inspector determined that the engineering analysis, the applicant's inspections, and the referenced DCA provided sufficient justification to insure that the welds were adequate.
Therefore, these open items are closed.
b.
(Closed) Open Item (445/8845-0-01):
Replacement of Unit 1 emergency diesel generator (EDG) wattmeters.
(Note:
This item was previously closed in NRC Inspection Report 50-445/89-53; 50-446/89-53).
As documented in the closure of Allegation OSp 84-A-0022 in NRC Inspection Report 50-445/88-45; 50-446/88-41, this open item was identified to track the replacement of the Unit 1 EDG wattmeters with qualified components.
The NRC inspector determined that the Unit 1 EDG wattmeters had been replaced with qualified meters from Unit 2; however, this activity was accomplished following the completion of hot functional testing (HFT) on Unit 2.
This is a deviation from the applicant's commitment to replace the wattmeters in TU Electric's letter TXX-88294, prior to HFT on Unit 1 (50-445/89-64-D-01).
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Subsequent to the NRC inspector's identification of this issue, the applicant provided a response by letter TXX-89509.
This letter acknowledged the fact that the commitment to replace the Unit 1 EDG wattmeters prior to HFT had not occurred and provided the justification that there was no safety significance associated with this oversight.
Although the inspector agrees that there was no safety significance associated with this particular failure to abide by a commitment, the inspector is concerned with the commitment tracking process that allowed this failure.
The NRC, in good faith, uses applicant commitments to determine if reasonable assurance exists that adequate corrective actions will be taken.
In many cases the failure to abide by a commitment would result in a violation of NRC requirements.
The failure that occurred, therefore, places the applicant's commitment tracking process in question.
The response provided by TU letter TXX-89509 does not alleviate the inspector's concern.
The response to this deviation should include an explanation of why the deviation occurred and the action taken to prevent recurrence.
In addition, a determination should be made concerning the possibility that other commitments have not been met.
c.
(Closed) Open Item (445/8952-0-01):
This item addressed a reassembly procedure for Borg-Warner check valves that required modification to allow for more precise rotational alignment between the bonnet-disk assembly and the seat.
Initially, the applicant planned to use the studs on the bonnet as a reference for the axial location of the valve disk.
The NRC inspector questioned the adequacy of using the studs as the reference datum.
The applicant is currently using procedure MSM-CO-8801, Revision 1, "Borg-Warner Check Valve Maintenance" and Attachment 2 to the Work Order for each valve.
These documents specify a method to be used for scribing match marks on the bonnet and valve body to insure adequate alignment of the disc and seat during valve assembly.
This method uses the valve clevis, rather than the studs on the bonnet, as the reference.
The axial relationship between the valve disk and the clevis is a controlled
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The NRC inspector reviewed the valve installation L
procedures and witnessed the installation of
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valves 1FW-195 and 1FW-196 (see details in this report paragraph 9).
The NRC inspector concluded that the current procedures are adequate and address previous NRC l
concerns.
This item is closed.
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(Closed) Open Item (445/8952-0-02):
This item addressed the adequacy of procedure EGT-328A, " Reverse Flow Operability Testing for Auxiliary Feedwater Check Valves."
The NRC inspector had identified the following concerns during review of EGT-328A, Revision 0:
(1) acceptance criteria were not defined, (2) the pressure of the test source was not recorded, and (3) the test results were not documented.
Revision 1 of EGT-328A r.
was issued primarily to address these concerns.
The NRC inspector reviewed EGT-328A, Revision 1, and determined that the procedure adequately provides steps to test and document the results for the auxiliary feedwater supply line check valves and that the NRC inspector's concerns had been addressed.
This item is closed.
3.
Follow-up on Violations / Deviations (92702)
(closed) violation (445/8730-V-06):
Capacitors in diesel generator circuit not shown on drawings.
As previously identified in NRC Inspection Report 50-445/8952; 50-446/8952, this violation was technically closed, however, additional clarification was requested relative to supplemental corrective actions initiated by the applicant.
The NRC inspector reviewed the applicant's revised response to this item as contained in letter TXX-89591 dated August 21, 1989.
This revised response accurately documented the results of the functional tests which had been performed on the Unit 1 EDC control panels to establish the function of the subject capacitors.
Additionally, the applicant's letter described the results and the supplementary actions which had been taken relative to the EDC control panel modifications.
Based on the review of this revised response, it was determined that the applicant had provided adequate clarification regarding corrective actions associated with the EDG control panel modification implementation.
4.
Action on 10 CFR Part 50.55(e) Deficiencies Identified by the Applicant (92700)
a.
(Closed) Construction Deficiency (Cp-87-136):
" Motor Control Center Space Heaters."
This reportable deficiency involved the use of space heaters for Class lE motor control centers (MCCs) which were determined to be unqualified Class lE components, but were connected to a class lE power source in the MCCs.
Additionally, the Class 1E shunt trips for the MCCs at the service water intake structure were connected as part of the non-Class 1E space heater circuit.
As stated in the applicant's final report on this issue, contained in letter TXX-88065, the above described configurations resulted in the wiring of these space heaters and shunt trip devices being in disagreement with the separation
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l requirements described in the CPSES Final Safety Analysis Report.. The applicant's final report also identified.
that this deficiency resulted because the vendor did not provide qualified space heaters and the shunt trip wiring for the MCCs were incorrectly wired as part of the heater circuitry.
The absence of qualified space heaters or isolation devices between the space heaters and the associated shunt trip could have permitted a fault in the non-Class lE equipment / circuits to degrade the safety-related MCC circuits.
The NRC inspector reviewed the applicant's corrective actions which included a design change which would trip.
the space-heater supply breakers on receipt of a safety injection (SI) signal.
This modification would serve to isolate the Class 1E MCCs from the space heaters and, therefore, satisfy the requirements of Regulatory Guide 1.75.
Also, the shunt trip circuits would be rewired to provide a direct power supply from the Class 1E source, The NRC inspector also reviewed the-design change authorizations associated with the previously described corrective actions and performed inspections of selected MCCs and confirmed.that the stipulated corrective actions had been accomplished for the affected Unit 1 components and that these modifications appeared adequate.
However, no hardware changes had been implemented for Unit 2, therefore, this item is closed for Unit 1 only.
b.
(Open) Construction Deficiency (SDAR Cp-88-08):
" Battery Room Heaters."
This reportable deficiency involved the determination that the Class 1E battery room heaters were not powered from redundant Class 1E power supplies and that they were not seismically qualified.
As determined by the NRC inspector the applicant's proposed corrective actions included the replacement of the Class lE battery room heaters and controls with seismically qualified units powered from redundant Class 1E power supplies.
In order to accomplish these modifications the applicant issued DCAs 59920, 80180, and 38075 for Unit 1 and DCA 66141 for Unit 2.
The NRC inspector reviewed the subject DCA1 and examined the associated power supply breakers.
Based on these reviews and inspection activities, the NRC inspector determined that the Unit 1 work was incomplete and that Unit 2 may require additional DCAs in order to complete the specified modifications.
Therefore, this item will remain open pending the implementation of the identified corrective actions.
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c.
(Closed) Construction Deficiency (SDAR CP-88-37):
" Defective Solenoid Coil Leads."
This deficiency involved two concerns pertaining to Automatic. Switch Company (ASCO) solenoid val >e coil leads.
Specifically, the applicable Electrica3 Engineering Specification ES-100 requires a minimum bend radius of four times the outer cable diameter for the installation and routing of ASCO solenoid valve coil leads.
However, the applicant's inspections revealed that the subject coil leads had been packaged by the vendor with a minimum bend radius as low as two times the outer cable diameter.
The second concern involved solenoid valve coil leads.
which exhibited uneven tinning and discoloration.
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The NRC inspector reviewed the documentation associated with this reportable deficiency including the applicant's final report submitted on July 28, 1989, by letter TXX-89514.
Based on these reviews, the NRC inspector determined.that the concerns relative to the minimum bend radius requirements had been effectively resolved in that vendor practices allow for reinstallation (e.g., storage, shipping, etc.) minimum bend radius of one conductor outside diameter.
Therefore, no additional corrective action relative to this issue was required.
Resolution of the second issue of uneven tining and discoloration resulted in the replacement of all of the subject solenoid valve coils received on Purchase order 655-70352 and the scrapping of these components in
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accordance with NCR 88-15048.
The NRC inspector reviewed the technical disposition of this NCR and determined that the applicant's corrective actions appeared adequate.
Therefore, this construction deficiency is closed.
d.
(Closed) Construction Deficiency (SDAR CP-89-012):
" Brown Boveri HK Circuit Breakers."
This deficiency was reported by the applicant subsequent to their receipt of a 10 CFR Part 21 notification involving the failure of two breakers to operate due to contaminated and hardened.
lubricant at another facility.
This issue was determined to be.nonreportable in that the applicant's maintenance procedures which were in effect since December 1984 specified the lubrication of parts when replaced or when the old grease became contaminated.
Additionally, the applicant's documentation indicated that all of the Class lE breakers had been reworked as a result of the corrective action associated with SDAR CP-86-14, titled
"6.9kV breaker jackshaft weld failure."
The NRC inspector reviewed the subject SDAR and determined that it had been closed in NRC Inspection Report 50-445/87-35; 50-446/87-27.
The NRC inspector also reviewed the
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following documentation associated with this issue; Electrical Maintenance Instruction EMI-301, Electrical.
Maintenance Surveillance Test MSE-SO-6301, Work order C87-05909 and the applicable Brown Boveri breaker manual.~ Based on the above reviews, the NRC inspector concluded that the applicant's determination of nonreportability was acceptable and that the existing programmatic controls are adequate to address the identified Brown Boveri HK circuit breaker operability issues.
This item is closed for both Unit 1 and Unit 2.
5.
Electrical Components and Systems (51051, 51053, 51055, 51061, and 51063)
During this reporting period, the NRC inspectors performed-direct inspections of work performance to determine if the
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technical requirements contained in the applicant's Final Safety Analysis Report, for safety-related electrical systems and components had been adequately translated into applicable drawings, procedures, and instructions.
Additionally, the NRC inspectors evaluated the applicant's work control program to determine if the specified documents and procedures were of sufficient detail to provide adequate work performance and control.
In particular, the NRC inspector observed the activities associated with Work Order P890001896 which included the applicant's inspections for closure of NCR 89-01847 and the performance of Maintenance procedure MSE-SO-6301.
The NRC inspectot: determined that NCR 89-01847 had been issued to address the failure of 6.9kv breaker S1APSl-02 to operate.
The failure of this breaker to operate was attributed to a charging motor linkage pin which fell out.
The NRC inspector also observed similar work activities in progress on breaker 1APCH1 per Work Order P89-01878.
The NRC inspector observed that the maintenance personnel involved were knowledgeable, that the applicable procedures and documentation were present at the job site, that QC personnel were present, and that no deficiencies were identified.
Additionally, the NFC inspector observed portions of the work activities associated with traveler T140 EDA 42-T-01.
In particular, this work package involved the modification of existing cable tray installations in accordance with DCA 83551.
The NRC inspector reviewed the subject work package which specified the lifting and protection of the cables in tray T140 EDA 42 prior to the welding of replacement tray fittings.
This review revealed that the required quality control (QC) hold point for this step had been bypassed.
This failure to follow procedures is identified as a violation (445/8964-V-01).
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Within this area one violation was identified.
6.
-Instrumentation Components and System (52053, 52055)
During this reporting period, the NRC inspectors performed.
direct observations and independent evaluations of work performance, work in progress, and completed work to determine if these activities. relative to safety-related instrument components and systems were accomplished in accordance with NRC requirements, FSAR commitments, and appropriate applicant procedures.
In particular, the NRC inspector evaluated the use of Teflon tape (thread sealant) in the plant after learning that the applicant had identified some unapproved applications during an audit.
As part of this review, the NRC inspector researched the available historical documentation associated with this issue the Electric Power Research Institute Report NP-2129, " Radiation Effects on Organic Materials in Nuclear Plants," which peripherally addressed the radiation degradation of Teflon.
The NRC inspector also reviewed CPE documentation contained in CARS87-007, Revision 1 and CAR 87-043, Revision 0, which also addressed the issue of unauthorized thread sealant use.
CAR 87-043, Revision 0, was closed for Unit 1 and common on June 5, 1989, and included a revision of Instrument Installation Specification I-1018 and the implementation of Field Verification Method (FVM)-IC-069.
Review of FVM-069, Revision 3, revealed that its scope included Class 1E instrumentation, non-Class 1E related instruments connected to ASME Class III fluid systems, and the instruments attached to ANSI safety Class 1, II, and III heating, ventilation, and air-conditioning (HVAC)
installations for Units 1, 2, and common.
However, the sampling system and radiation monitoring system instrumentation as well as bolting materials specifications were excluded from the above described programmatic controls.
The NRC inspector reviewed Attachment 3 of FVM 069, Step 5.E.9.f.2 which directed that the presence of Teflon at connections with visible thread sealant would require justification.
As identified in the applicant's audit, of the measuring and test equipment (M&TE) program (TUG 89-15)
selected examples involving the incorrect use of Teflon in M&TE were documented.
As a result of these identified deficiencies a Stop Work Order (SWO)89-002 was issued on June 30, 1989, which halted the use of Teflon tape on site.
Subsequently, CAR 89-008 was issued on July 2, 1989, which identified the use of teflon tape on both the primary and secondary sampling systems, on the condensate polishing system, and on an auxiliary feedwater (AFW) system pressure instrument.
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The NRC inspector also determined that on August 2, 1989, SWO-002, Revision 1, was issued and that procedure STA-608, Revision 14 had been modified to allow the use of Teflon on M&TE with certain provisions which-included no direct contact-with plant hardware.
Further changes in Teflon tape usage were described.on the applicant's Memorandum TIM-891753, dated August 7, 1989.
On August 24, 1989, members of the NRC staff met with representatives of the applicant to discuss the findings of Audit Report TUG 89-15.-
Based on the inspection results and reviews conducted in this area as well as information provided during the above mentioned meeting, the NRC inspector determined that the applicant's program for the use and control of Teflon tape appeared adequate.
The NRC inspector also observed portions of the work in progress relative to the rerouting of the pressure indicator
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tubing for 2 pI-0108 and -0109 in auxiliary building Room 206.
Three work packages involving Room 206, 2PI-0108 and 2PI-0109 were=also reviewed with no discrepancies identified.
During the observance of these activities, the NRC inspector determined that the instrument technicians involved wete adept and that a copy of the installation specification, I-2002, was available.
No violations or deviations were identified within this area.
7.
Plant Tours (51061, 51063)
The NRC inspectors conducted routine plant tours during this inspection period wh?
included evaluation of work in l
progress as well as completed work to determine if activities involving safety-related electrical systems and components including electrical cable were being controlled and accomplished in accordance with regulatory requirements, industry standards, and the applicant's procedures.
The NRC inspectors also evaluated the general cleanliness of plant equipment and systems.
During these inspections it was determined that housekeeping and cleanliness in specific rooms
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and areas were very poor.
In particular, the NRC inspector observed grinding wheels, tubes of sealing compound, rags, poly bottles, welding equipment, and other discarded debris in and around HVAC ducting.
These conditions were identified to the applicant's construction manager who took immediate action l
to address the identified conditions.
This responsiveness to an NRC identified concern is commendable and is identified as a strength.
The NRC inspectors reviewed the applicant's implementation of
Corrective Action Request (CAR)99-009 involving deficiencies
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associated with thermolag installed on cable trays and l
conduits.
Specifically, this issue concerned site fabricated thermolag panels which were identified by the applicant as I
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being below minimum wall thickness.
The NRC inspector l
discussed this issue with representatives af TU Electric's staff and conducted inspections of cable trays and conduits in
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the safeguards building which were insulated with thermolag material.' Based on these inspections, it was determined that the applicant had aggressively pursued this issue in that all potentially unacceptable installations had been marked for replacement with thermolag purchased from an approved supplier
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and.that all suspect (site fabricated) thermolag material, currently on hand but not installed, will be evaluated.
No violations or deviations were identified within this area.
8.
Allegation Follow-up (99014)
a.
(Open) Allegation (OSP-89-A-0066):
During this reporting period, the NRC inspector evaluated the portions of Allegation OSP-89-A-0066 which pertained to deficiency number one of QA Audit TCP-86-09.
In particular, this deficiency involved the potential use of improperly sized cable grips which resulted from the utilization of uncontrolled vendor documents for grip sizing information.
The corrective actions that were implemented by the applicant subsequent to the closure of this issue included the incorporation of cable grip specifications into ES-100 electrical installation specification; the implementation of CAR-055, which included control of vendor manuals; and the implementation of FVM-EE-089 which encompassed inspection and documentation requirements for all installed cable grips as well as inaccessible areas where grips may have been required.
FVM-EE-089 activities have been documented in other NRC inspection reports, including the i
final reconciliation of the Post-Construction Hardware Verification Program, and have been found acceptable.
The allegation also contended that some grips were used on Kapton wiring as well as shielded cables.
As previously documented in NRC Inspection l
Report 50-445/89-04; 50-446/89-04 only six usages of Kapton have been identified in the plant including primarily its application on pigtails connecting field cable and other equipment.
These usages would not require cable grips on the pigtails.
Additionally, shielded cable, such as triax and coax may have utilized cable grips, however, these cables are normally jacketed and shields would not have contacted the grips.
I Therefore, this particular item of the allegation could l
not be substantiated.
b.
(Open) Allegation (OSP-89-A-0061):
This allegation involved a former worker's concerns relative to safety l
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issues which were identified to members of~the NRC resident staff at. comanche Peak on July 13, 1989.
.It is noted that the following evaluations address only those portions of the alleger's concerns which apply to plant electrical components and systems.
The remaining aspects of t'ds allegation will be evaluated in a subsequent ins]
Jion report.
'(1)
The first concern-identified by the alleger was that during the installation of plant lighting,' the
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wiring polarity was not identified on the individual conductors.
The alleger went on to state that initially the work practice was to leave the breakers closed ~which supplied power to the lighting fixtures in order to verify continufty; however, the alleger indicated that this practice changed and that the associated breakers were opened and left open during the termination process.
The alleger stated that.he had not previously identified this item to SAFETEAM but that he was concerned that the applicant's lighting termination practices regarding standard color coding and polarity verification were not being accomplished in accordance with national electrical standards.
The NRC inspector asked the alleger if the plant lighting systems involved were safety-related components (i.e.,
lighting required for safe shutdown of the plant).
The alleger responded that he thought they were safety related in that they concerned worker safety.
Subsequent to independent inspections and evaluations conducted by the NRC inspector of installation practices utilized by electrical craft personnel, it was determined that the lighting systems involved in the alleger's concerns were not the emergency lighting systems required for safe shutdown.
The NRC inspector determined that the current policy regarding termination of plant lighting is to label the associated wires.
The implementation of this labeling program was confirmed by the NRC inspector based on examination of selected plant lightfne system terminations throughout the plant.
cased on these inspections, this portion of the allegation could not be substantiated; however, it is noted that the identified condition could have existed in the past.
No further action is recommended regarding this issue.
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(2)- The alleger's second concern involved the applicant's use of incandescent lighu bu3bs in enclosed plant illumination systems which were identified as "not for use in enclosed fixtures."
In particular, the alleger expressed concern over the use of 300 watt bulbs.in these enclosed fixtures which generated " excessive heat" and created the potential for heat related degradation of the light fixture.
The NRC inspector reviewed the applicant's response to this issue which was addressed in allegation SAFETEAM file No. 1105.
The applicant's actions appeared responsive in that, for these areas where enclosed fixtures were required, the applicant's engineering evaluations supported the continued use
.of the enclosed fixtures.
Additionally, the applicant modified their replacement practices concerning these enclosed plant illumination
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fixtures and they currently utilize industrial service incandescent lamps.
Also, in areas where enclosed fixture' replacement was feasible the'
applicant is utilizing high pressure sodium type fixtures.
As documented in the applicant's response to this concern, these high intensity discharge fixtures are more efficient, have greater longevity, and provide equivalent illumination.
Based on the above reviews and inspection activities, it was determined that the applicant's actions to evaluate and correct the alleger's identified concerns appeared adequate and that their response to this nonsafety-related issue was appropriate.
No further action is recommended regarding this issue.
(3)
A third concern expressed by the alleger involved the proposed addition of local light switches in areas and rooms such that when not required, the affected lighting components could be " turned off."
This modification would prolong the service life of the light bulb and reduce the heat load on the subject fixtures.
The NRC inspector determined that this concern had also been identified to SAFETEAM and that a response had been provided to the alleger.
The NRC inspector reviewed the response and determined that additional local light switches had been installed in several areas of the auxiliary building and in the safeguards building in accordance with DCA 21,441.
Based on the engineering reviews documented in this
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response, local light switches in other areas were
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not recommended.
The-NRC. inspector determined that this item did not involve a regulatory issue; however, the actions ~of the-applicant" appeared adequate in-that the allegers e
concern was evaluated and corrective' steps, where-p applicable,,were~ accomplished.
No further action is recommended regarding this issue.
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(4)
The fourth concern identified by the alleger pertained to exterior lighting on the turbine deck.
Specifically, the issue involved the applicant's utilization of 150 watt flood lamp fixtures on the turbine deck in lieu of the 250 watt flood light fixtures specified on the turbine deck. drawing for permanent plant lighting.
The NRC' inspector reviewed the applicant's response to this concern and examined the applicable design drawings.
The applicant's response to this issue appeared to confirm the alleger's position in that the installed fixtures were not in conformance with the specified components.
Subsequent to this determination, the applicant generated problem Report PR-86-491 which directed the replacement of the existing 150 watt high pressure sodium (HPS)
flood lights with HPS' fixtures rated for 250 watts as specified on the' turbine deck permanent plant lighting system drawing.
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The NRC inspector verified the implementation of this nonsafety-related modification and determined that the plicant had adequately addressed the identifiet concern.
No further action is recommended regarding this issue.
(5)
The fifth concern expressed by the alleger involved e potential operational problem with the installed lighting system in the containment dome and refueling pool high bay.
These lights utilize 1000 watt bulbs which " burn out" quickly (approximately every 6 weeks).
The alleger stated that these could shatter and pose a personnel hazard.
The alleger also expressed concern over the potential radiation exposure that would be incurred by workers during future maintenance activities and that the lack of lighting due to burnt out lights might cause operational (access) difficulties.
Additionally, the alleger stated that during the
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maintenance process (changing of bulbs) that the
fixture cover could fall, resulting in possible personnel injury and or equipment damage.
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The NRC inspector determined that this issue had also been identified to the applicant's SAFETEAM and.
that a response had been provided to the alleger.
The NRC inspector reviewed the applicant's response-and. conducted independent inspections of the-installed lighting systems in the containment and in the spent fuel pool area.
These reviews and inspection activities revealed that the subject lighting fixtures were installed in accordance with the applicable primary plant electrical schedule and L
that these fixtures appear to be suitable for their intended function.
In particular, these fixtures
.are restrained by seismic (cable) supports and that the lens covers are fabricated from tempered glass which is mounted securely to the fixture.
In the event that an installed bulb shattered, it would be
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contained by the lighting fixture and the lens cover which encapsulates the bulb.
Relative to the radiation exposure which would be incurred by personnel during maintenance activities on the subject fixtures, the NRC requires that applicant's monitor and control radiation exposure to plant personnel as defined in the Code of Federal Regulations - 10 CFR Part 20.
These standards for the protection against radiation hazards as implemented by the applicant's radiation protection and contamination programs would limit the exposure of plant personnel to acceptable levels during operation and refueling modes.
With respect tc the hazards associated with lighting fixture covers falling during bulb replacement activities and potentially injuring personnel or damaging equipment, the NRC inspector examined the applicable plant drawings and maintenance instructions for the installed Sturdilite, Model E64-1000 floodlights.
These reviews established that the subject fixtures have hinged covers which securely attach the lens cover to the housing thus precluding the inadvertent dropping of the glass covers.
Based on these reviews and evaluations, the NRC inspector determined that this portion of the alleger's concerns could not be substantiated.
No further action is recommended regarding this issue.
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The sixth' concern identified by the alleger involved the utility's apparently. erratic preventative maintenance practice regarding the cleaning'and preservation of lighting and switch gear panels.
The alleger stated that his experiences were that some panels were cleaned / dusted regularly while others were not maintained.
This concern was general in nature in that the alleger could not identify any specific electrical panele in the plant that were affected by this practice.
The NRC inspector reviewed the applicant's response to this concern which defined the preventive maintenance program and preservation schedule for lighting and switchgear panels including electrical breakers.
At the conclusion of this reporting period, certain aspects of this issue remained outstanding.
Therefore, this item will remain open pending.further evaluations which will be documented in subsequent inspections.
(7)
The alleger also stated that because of his personal knowledge of a specific utility employee involved with station battery maintenance, he was concerned with that-individuals qualifications and ability to perform his job on safety-related equipment.
An associated issue involved concerns over the applicant's procedural controls and usage (depletion) of required battery cells.
Specifically, the alleger felt that the existing procedures did not provide notification to the individual responsible for battery maintenance of potentially degraded batteries subsequent to their use on the weekend.
The alleger was also concerned with the applicant's battery maintenance program and questioned the adequacy of all cells.
At the conclusion of this reporting period, certain aspects of this issue remained outstanding.
Therefore, this item will remain open pending further evaluations which will be documented in subsequent inspections.
(8)
Subsequent to the alleger's meeting with members of the NRC staff on July 13, 1909, an additional concern was identified which pertained to electrical systems and components. 'This issue involved alleged leaks in the fire protection sprinkler system which allowed water to drip into cable trays.
The alleger l
stated that on various occasions personnel received l
shocks while attempting to cleanup the residual water.
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i This allegation s general ir, nature and the NRC inspector was u.
le to estab'ish if the stated conditions existed in safety-related or nonsafety-related cable trays.
In order to evaluate this allegation, the NRC inspector reviewed Section 9.5 of the FSAR which addresses the applicant's. implementation of the fire protection program including the deluge sprinkler suppression system.
In particular, this section establishes
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that the installed cables are designed to allow wetting down without experiencing electrical faulting.
Consequently, electrical faults detected during testing or operations would have been documented on test deficiency reports or on deficiency. reports and corrected in accordance with the resultant technical disposition.
The NRC inspector determined that examples of leaking fire suppression sprinkler heads have been identified and subsequently corrected-
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however, the NRC inspector was unable to substantiate the allegation that reported personnel electrical shocks had resulted from this condition.
No further action is recommended regarding this issue.
9.
Sp#ety-Related Components, Mechanical (50071, 50073)
NDE and Reinstallation of Borg-Warner Check Valves
<0n May 31, 1989, a 4-inch Borg-Warner bolted bonnet check valve in'the service water system, Valve 1SW-048, exhibited excessive backleakage.
This event was first documented in NRC Inspection Report 50-445/89-30; 50-446/89-30.
The applicant disassembled Valve'1SW-048 and the swing arm was determined to have failed with the valve disk completely separated from the i
swing arm at a point roughly parallel to the ball / disk assembly.
The swing arm for valve 1SW-048 and two additional swing arms l
from Unit 2 which had not failed were evaluated by Stone and Webster Engineering Company (SWEC).
The evaluation determined, in part, that:
The swing arm failure in Valve 1SW-048 initiated from
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surface defects formed during the casting process.
Normal nondestructive inspection techniques may not
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reveal these defects.
The swing arm did not receive an adequate heat-treatment.
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Weld repairs to the casting did not directly' contribute
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to the failure.
The casting quality is poor.
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The susceptibility of these castings to failure may be
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reduced by 100% inspection to assure absence of surface flaws and then reheat-treated.
Subsequently, Aptech Engineering Services, Inc., consultant to the applicant, evaluated the swing arms to determine the root cause of the failure.
Preliminary conclusions from Aptech indicate that the swing arm for Valve 1SW-048 failed due to a combination of:
Material condition / casting defects
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Residual and applied stress
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Aggressive eu.vironment (corrosion)
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Aptech recommended nondestructive examination (NDE) be performed on Borg-Warner check valve swing arms to investigate the surface conditions.
Aptech developed procedures for replication * of a minimum of two areas (approximately 0.5 square inches in each) on each swing arm to establish casting quality by looking for hot cracks.
In addition, a 10X visual examination and a liquid penetrant test of all accessible surfaces'on the swing arms was required to look for surface cracks, voids, etc.
The NDE examination of 80 Unit 1 and common Borg-Warner check valves is currently being conducted per NCR 89-7476, Revision 12.
The two areas on each valve swing arm where replications are taken are ground and polished to a mirror finish and acid etched.
A minimum of 0.025 inches of material
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is removed due to the presence of microshrinkage cracks (small intergranular cracklike discontinuities) near the surface of the casting.
These microshrinkage cracks are not relevant to the examination for hot cracking.
Ultrasonic testing is used both before and after preparing these areas for replication to insure that minimum wall thickness are maintained for each swing arm.
The NRC inspector attended a training session for the metallographic technique and microstructural etching required to produce replications per NCR 89-7476, Revision 10.
The training was given to TU Electric NDE QC personnel by an Aptech' metallurgical engineer.
The training included:
(1) grinding and polishing techniques, (2) cleanliness,
- A process of recording the three dimensional surface I
topography of a sample using cellulose acetate.
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(3) acid. etching, (4) replication, and (5) documentation.
The NRC inspector also revieued training records and lesson plans for previous and current revisions of the replication techniques detailed in NCR 89-7476.- The NRC inspector
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concluded that the training was sufficient to allow the personnel to produce adequate replications and that the training was completed before the replication work began.
The NRC inspector witnessed NDE activities including replications per NCR 89-7476 for the following Borg-Warner check valves:
1AF-086 1CC-0651'
1CC-0693 1CC-0697 1DD-0006 1FW-014 1SW-388 The NRC inspector also discussed the results of various replications with the Aptech metallurgical engineer who examined each replication under a microscope for the presence of hot cracks.
No NRC concerns ware identified.
The NRC inspector witnessed the removal of the valve internals for check valves XSF-003, XSF-160, and XSF-180.
This activity was completed in a controlled and careful manner and no NRC concerns were identified.
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The NRC inspector reviewed the applicant's methods for reassembling the Borg-Warner check valves.
procedure MSM-CD-88D1, Revision 1, "Borg-Warner Check Valve Maintenance" contains the steps used for valve reassembly.
In addition, Attachment 2 to each work order for valve reassembly provides details for scribing match marks on the bonnet and valve body to insure adequate alignment of the disc and valve seat.
The NRC inspector reviewed the valve installation procedures, work orders, and witnessed the reassembly of valves 1FW-195 and 1FW-196.
No concerns were identified.
To date (September 6, 1989), the applicant has removed 55 of the 80 valves identified on NCR 89-7476 and completed inspection of 48 of these valves.
Three valves were unsatisfactory due to the failure of the swing arms to pass the NDE tests.
A total of 43 valves have been reinstalled.
To replace the defective swing arms, the applicant has ordered spare parts from Borg-Warner.
Il addition, the applicant has stated that some swing arms from Unit 2 may be used to replace the defective parts.
The adequacy of the applicant's program to examine and evaluate the Borg-Warner check valve swing arms
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evaluated in a subsequent NRC inspcction report.
10.
Exit Meeting (30703)
An exit meeting was conducted September 5, 1989, with the applicant's representatives identified in paragraph 1 of this report.
No written material was provided to the applicant by the inspectors during this reporting period.
The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
During this meeting, the NRC inspectors summarized the scope and findings of the inspection.
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