ML20011D346
| ML20011D346 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/20/1989 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hall D HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8912270008 | |
| Download: ML20011D346 (4) | |
See also: IR 05000498/1989034
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In Reply Refer To:
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' Dockets:' 50-498/89-34
50-499/89-34
Houston Lighting & Power Company
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ATTN: Donald P. Hall, Group
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~Vice President, Nuclear
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.P.O. Box 289
Wadsworth Texas 77483
Gentlemen:
p
Thank you for your letter of November 24, 1989, in response to our letter and
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Notice of Violation (Notice) dated Or:tober 18, 1989. We have reviewed your
response and note your denial of Violation A.
Our position with respect to
these violations was discussed with tir. M. A. McDurnett of your staff during
a: telephone' conversation held on December 18, 1989.
As the result of our review of your response to Violation A, we concur that the
wrong. valve was indicated in the Notice and that the correct valve number is as
indicated in your response. We do not concur with your position that the
indicated examples were not in violation of 10 CFR 50.49.
In Example 1 of this violation, HL&P was cited for not demonstrating
submergence for components associated with motor operated valves. To
demonstrate such qualification,10 CFR 50.49 requires the qualification files
to contain sufficient information to address all necessary aspects of the
qualification. During this inspection, the files p esented to the inspectors
for review did not contain the necessary information to demonstrate
. submergence qualification. Failure to have the necessary qualification
information in the file at the time of the inspection is contrary to the
requirements of 10 CFR 50.49. This example is indicative of the concern
raised in the. inspection report regarding the maintenance of your EQ files.
The second example of this violation involved the failure to maintain a
motor-operatedvalveinatested(qualified) condition. The tested motor-
' operator did not have any corrosion present at the time of testing. As a
result of the gasket failure on the valve at STP, the limit switch housing
experienced moisture intrusion, during normal operating conditions, which
resulted in the start of the corrosion process. The EQ rule, 10 CFR 50.49,
requires that the component be qualified based on testing of similar equipment
with a supporting analysis to explain why the differences would not affect the
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qualification of the component. At the time of the inspection, the inspectors
were not provided any analysis to indicate that the corrosion present, and any
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additional corrosion that may occur, would not jeopardize the qualification of
the valve.
We have concluded, therefore, that HL&P was in violation of
10 CFR 50.49 and this violation stands as cited.
RIV:RI:PSS *
C:PSS *
D:DRS *
D:DRP *
CPaulk/cjg
TStetka
LJCallan
SJCollins
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8912270008 891220
ADOCK 05000498
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Houston Lighting & Power Company
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' With respect to Violation B, we note your contention that Example B.1 should
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'not.be an example of this Violation. Upon further review, we concur with your
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assessment; however, at the time of the inspection, the inspectors were not-
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made aware by your representatives that the subject wire was a spare. Had
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they been cognizant of this fact, the example would not have been cited.
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We have reviewed your corrective actions for both violations and find them to
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be responsive to our concerns raised in the Notice. Therefore, no additional-
response is necessary. We will review implementation of your corrective
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actions during a future inspection to determine that full compliance has been
achieved and will be maintained.
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Sincerely,
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Samuel J. Collins, Director
Division of Reactor Projects
n
cc:
Brian Berwick, Esq.
Assistant Attorney General
Environmental Protection Division
P.O. Box 12548
Capitol Station
,
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Houston Lighting & Power Company
' ATTN: .J. T. Westermeier, General Manager
South Texas Project
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P.O. Box 289
Houston, Texas 77001
Houston Lighting & Power Company
ATTN:
M. A. McBurnett, Manager
Operations Support Licensing
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P.O.. Box'289
,D
Wadsworth, Texas 77483
City of Austin Electric. Utility
ATTN:
R. J. Miner, Chief Operating
Officer (2 copies)
721 Barton Springs. Road
City Public Service Board
ATTH:
'R.' J. Costello/M. T. Hardt
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P'.0. Box 1771
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San Antonio, Texas 78296
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Houston Lighting & Power Company
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Bechtel Corporation
ATTN:
E. T. Molnar/L. W. Hurst
R. ,
P.O. Box 2166
Houston, Texas 77252-2166
Newman & Holtzinger
P. C.
ATTN: Jack R. Newman, Esq.
1615 L Street, NW
Washington, D.C.
20036
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Central Power and Light Company
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.ATTH:
R. P. Verret/R. L. Range
P.O. Box 2121
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Corpus Christi, Texas 78403
Baker &-Botts
ATTN:- Melbert Schwartz, Jr., Esq.
One Shell Plaza
Houston, Texas 77002
Doub, Huntzing and Glasgow
-Attorneys at Law
Suite 400
808 Seventeenth Street, N.W.
Washington, D.C.
20006
INPO-
Records Center
i
1100 Circle 75 Parkway-
Atlanta, Georgia 30339-3064
Ms. Iris J. Jones
.
Acting City Attorney
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City of Austin
P.O. Box 1088
Houston Lighting & Power Company
ATTH:
S. L. Rosen, Vice President
Nuclear Engineering and
Construction
-P.O. Box ?89
Wadsworth, Texas 77483
Houston Lighting & Power Company
ATTH:
R. W. Chewning, Vice President
Nuclear Operations
P.O.-Box 289
Wadsworth,. Texas 77483
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Houston-Lighting & Power Company
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Mr. Joseph M. !!endrie
50 Bellport Lane
Bellport, New York 11713
Bureau of-Radiation Control
State of Texas
<
1101 West 49th Street
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Judge, Matagorda County
, Matagorda County Courthouse,
1700 Seventh Street
' Bay City, Texas 77414.
Licensing Representative
Houston Lighting.& Power Company
Suite 610
'
'Three Metro Center
Bethesda, Maryland 20814
Houston Lighting & Power Company
' ATTN: Rufus S. Scott, Associate
General Counsel
- P.O. Box 1700l
Houston, Texas 77001
U.S. Nuclear Regulatory Commission
- ATTN: Resident Inspector-
P.O. Box'910
Bay City, Texas. 77414
U.S. r.uclear Regulatory Commission
,
- ATTN: Regional Administrator, Region IV
- 611 Ryan Plaza Drive, Suite 1000
' Arlington, Texas 76011
.
bec_to DMB (IE01) - DRP and DRS
bec'distrib. by RIV:
R. D. Martin-
Resident Inspector
SectionChief(DRP/D)
' DRS
MIS System
DRSS-FRPS
Lisa Shea, RM/ALF
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RIV File
R. Bachmann, 0GC
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RSTS Operator
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13-D-18)jectEngineer(DRP/0)
Pro
G. Dick, NRR Project Manager (MS:
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T. Stetka
C. Paulk
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P. Wagner
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NOV 3 0 089
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The Light
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South Texas Prcject Electric Generating Station
P.O. Box 289 Wadsworth,1 emas 77483
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November 24, 1989
ST-HL-AE-3286
File No. I G2.4, 426
G2. 2, G4. 02, G112. 4 03
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U.S. Nuclear Regulatory Commission
Attention: Document control Desk
20555
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South Texas Project Electric Generating Station
Units 1 & 2
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Docket Nos. STN 50-498,-
STN 50-499
Response to Notices of Violation 8934-03 and 8934-04
Reference: Letter ST-HL-AE-3299 from S.
L. Rosen, HL&P
to U. S. NRC Document Control
Desk, dated
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November 24, 1989
By this letter Houston Lighting & Power Company submits
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Attachment 1 and Attachment 2.in response to Notices of Violation
8934-03 and 8934-04 dated October 18, 1989, pursuant to 10CFR2.201.
These Notices of Violation were identified in an NRC inspection
conducted during the period Geptember 18-22, 1989.
An extension
of the original 30 day responsa time was granted November 17, 1989
by Mr. E. J. Holler of NRC Region IV.
,
,
In addition to the response to the Notices of Violation,
Attnrfument 3 is included which addresses observations identified
during the inspection.
It is of particular concern to HL&P_that
the inspection report notes (page 12) a perceived " hesitancy" on
,
the part of EQ and . contractor personnel
in determining the
operability of components relative to the operating unit when
qualification of a component was in question.
Our personnel have
been trained to consider operability promptly when conditions are
identified.
An example of this is the HL&P response to the splice
issue of NOV 8934-04.
Our evaluation of this condition identified
operability
concerns
for
Regulatory
Guide
1.97
Category
2
instrumentation, which HL&P promptly addressed. Consequently, Unit
2.was not allowed to restart from the September 21, 1989 reactor
trip until the affected splices were reworked, and rework of the
Unit 1 splices was made a restraint to restart of Unit 1 subsequent
to the completion
of its first refueling outage.
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A Subsidiary of Houston Industries incorporated
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Houston Lighting & Power Company
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South Texas Project Electric Generating Station
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The case above is an example of the prompt and thorough
investigative actions undertaken when potential
problems
are
identified at STPEGS.
We believe these actions continue to
demonstrate the strong sensitivity employed by STPEGS personnel in
determining the actual condition of components when qualification
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or operability is in question and in the verification that
requirements are met. However, we have used this inspection report
as a medium to reemphasize to our staff the need to ensure that
operability determinations are communicated promptly and clearly
to NRC personnel.
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If you should have any questions on this matter, or the
attachments, please contact Mr. A. W. Harrison at (512) 972-7298
or myself at (512) 972-7138.
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S.
. Rosen
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Vice President,
Nuclear Engineering & Construction
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SLR/SDP
Attachments:
1.
Response to Notice of Violation 8934-03
2.
Response to Notice of Violation 8934-04
3.
Response to other observations made during NRC
Inspection Report 89-34
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A1/032.NL9
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ST HL AE 3286
Houston Lighting & Power Company
South Texas Project Electric Generating Station
File No.: C2.4
Page 3
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cc:
Regicnal Administrator, Region IV
Rufus T. Scott
Nuclear Regulatory Commission
Associate General Counsel
611 Ryan Plaza Drive, Suite 1000
Houston Lighting & Power Company
Arlington, TX 76011
P. O. Box 1700
Houston, TX 77001
Coorge Dick, Project Manager
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Records Center
1100 circle 75 Parkway
J. I. Tapia
Atlanta, CA 30339 3064
Senior Resident Inspector
c/o U. S. Nuclear Regulatory
Dr. Joseph M. Hendrie
Commission
50 Be11 port Lane
P. O. Box 910
Be11 port, NY 11713
Bay City. TX 77414
D. K. Lacker
J. R. Newman, Esquire
Bureau of Radiation Control
Newman & Holtzinger, P.C.
Texas Department of Health
1615 L Street, N.W.
1100 West 49th Street
Washington, DC 20036
Austin, TX 78704
R. L. Range /R. P. Verret
Central Power & Light Company
P. O. Box 2121
Corpus Christi, TX 78403
J. C. Lanier
Director of Generations
City of Austin Electric Utility
721 Barton Springs Road
Austin, TX 78704
R. J. Costello/M. T. Hardt
City Public Service Board
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P. O. Box 1771
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San Antonio, TX 78296
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Revised 11/15/89
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L4/NRC/
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Attachment 1
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ST-HL-AE-3286
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File No. G2.4
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G26, G2.2, G4.02
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Gil2.403
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Page 1 of 5
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South Texas Project Electric Generating Station
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Units 1 and 2
Docket Nos. STN 50-498, STN 50-499
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Resnonse to Notice pf Violation 8934-03
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STATEMENT OF VIOLATION
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A.
Failure t2 Ensure Qualification
Paragraph (a) of 10 CFR 50.49, " Environmental
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Qualification of Electrical Equipment Important to
safety for Nuclear Power Plants," requires licensees to
establish a program for qualifying certain electrical
equipment.
Paragraph (e) of 10 CFR 50.49 requires the program to
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include submergence considerations if the equipment is
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subject to being submerged.
Paragraph (f) of 10 CFR 50.49 requires that
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(environmental) qualification of each component must be
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based on testing or experience with identical
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equipment, or with similar equipment with a supporting
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analysis, to r.how that the equipment to be qualified is
acceptable.
Contrary to the above:
1.
A motor operated valve (B1SI-MOV-0039B, ECCS
Accumulator Outlet), which could be required to be
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repositioned following an accident, had electrical
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cabling for power and indication which was subject
to submergence.
This cabling had not been
qualified for post accident submergence.
2.
A failed gasket existed on motor operated valve
DlAF-MOV-0514 as evidenced by the existence of
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moisture intrusion. In addition, the grease relief
on this motor operated valve actuator was broken
off.
These conditions resulted in the actuator
being in an unqualified condition.
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ST-HL-AE-3286
File No. G2.4
G26, G2.2, G4.02
Gil2.403
Page 2 of 5
II.
HOUSTON LIGNTING & POWER POSITION
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A1.
HL&P does not concur with the cited violation as
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written; however, deficiencies exist in the EQ
documentation.
A2.
HL&P does not concur with the cited violation.
III.
REASON FOR VIOLATIONS
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A1.
A preliminary review of the location of the subject
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valves and appurtenances against the calculated flood
levels identified a junction box containing spliced
cables for Namco position indication limit switches
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(associated with BlSI-MOV-0039B), which were subject to
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submergence following an accident.
Design
documentation did not specify that these spliced cables
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needed to be located above the calculated flood level,
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and EQ documentation did not indicate the splices were
qualified for submergence.
The submergence qualification of the electrical power
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and control cabling associated with the motor actuator
B1SI-MOV-0039B is contained in STP EQ documentation as
part of the EQ Calculation E-4046-1 dated September 2,
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1987, which bases qualification on the ICEA long term
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water immersion test.
Through an oversight on the part
of HL&P, uhis documentation was not reviewed at the
time of the audit.
However, it was reviewed in g
previous NRC audit on January 27-30, 1987.
A2.
The actuator inspected by the NRC inspector is
incorrectly identified in the Notice of Violation as
motor operated valve D1AF-MOV-0514.
The valve
inspected was A1AF-MOV-0048 as stated on page 14 of
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inspection report 89-034.
The limit switch compartment
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gasket of valve A1AF-MOV-0048 was damaged which
resulted in moisture intrusion as evidenced by traces
of oxidation.
In addition, a grease "zirc" fitting
(not a grease relief fitting) was damaged.
However,
neither of these parts are required to meet
qualification criteria.
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ST-HL-AE-3286
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File No. G2.4
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G26, G2.2, G4.02
Gil2.403
Page 3 of 5
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IV.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED
A1.
The power and control circuits for Trains
"A",
"B" and
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"C" of the Accumulator Discharge valves in both Units 1
& 2 have been evaluated to determine their operability
and the availability of requisite Control Room
indication following an accident where flooding and
cable submergence are calculated to occur.
Based on the measurements of the actual locations of
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sach valve, including the appurtenances for both Units
1&2
it was determined that the following components
could,be submerged.
1.
The junction box for the Namco limit switches
BlSI-ZSO-000393 and BlSI-ZSC-0003&B d'ich provide
indication to the Control Room of valve position
.
(associated with B1SI-MOV-0039B) contained control
cable spliced with Raychem material in Unit 1,
2.
The special raceway box (B1XCIAKHPO5-BLUE) for
Unit 1 contain power and control cables for
actuator B1SI-MOV-0039B and Namco switches
BlSI-ZSO-0039B and BlSI-ZSC-0039B, and
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3.
The special raceway box (B2XCIAKHPO5-BLUE) for
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Unit 2 contain power and control cables for
actuator B2SI-MOV-0039B and Namco switches
B2SI-ZSO-0039B and B2SI-ZSC-0039B.
The junction box identified in item 1 above contained
cables spliced with Raychem material which did not meet
the existing submergence qualification criteria.
However, adequate valve indication was available in the
Control Room since the motor actuator limit switch
indication would have been available once power was
restored to the motor operated valve.
(The valve is
normally open with power locked out to preclude
spurious operation.)
Immediate action was taken to
relocate the control wiring contained in this junction
box above the flood. level.
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Attachment 1
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ST-HL-AE-3286
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File No. G2.4,
G26, G2.2, G4.02
G112.403
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Page 4 of 5
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The special raceway boxes identified in items 2 & 3
above were used as pull boxes and contain pcwer and
control cables.
There are no splices inside these
boxes.
The submergence qualification for these power
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and control cables is documented in EQ Calculation
E-4046-1 and meets the requirements of 10 CFR 50.49.
HL&P subsequently re-evaluated the existing STP
qualification documentation for cables and Raychem
splices in more detail and believes them to be
,
qualified for submergence.
The subject cables and
splices are qualified based on the test reports
included in the EQ files.
These aret
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Full LOCA Tests (NUREG 0588)
o
High Pot Test (IEEE 383)
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Long Term Water Immersion Test (ICEA)
HL&Pis review of the test data concludes that the
cables and splices can survive a LOCA and separate
,
submergence since critical cable / splice characteristics
are not adversely impacted by the relevant test
parameters.
In addition, the test parameters
. adequately bound expected submergence conditions at
STP.
Therefore, HL&P concluded that the subject cables
and splices are qualified for submerged applications
based on the existing test documentation.
A
documentation deficiency does exist in that the files
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did not include an analysis to show how the test data
addressed submergence.
HL&P will enhance the existing
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submergence documentation to show how the test data
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addresses submergence by February 28, 1990.
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A2.
An inspection of the limit switch compartment ( valve
A1AF-MOV-0048) for effects of the moisture intrusion
revealed no evidence of corrosion on the terminal block
contact points in use although corrosion was noted on a
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spare terminal.
The Limitorque Qualification Report
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B0058 does not take any credit for the cover
gasket / seal for its actuator qualification.
Therefore,
the valve would have performed its intended safety
function.
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Attachment 1
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ST-ML-AE-3286
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File No. G2.4,
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G26, G2.2, G4.02
Gil2.403
Page 5 of 5
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The function of the damaged grease "zirc" fitting was
investigated. It was determined that it would not be
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possible to use this-fitting during preventive
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maintenance, but it would not impact the environmental
qualification of the actuator.
The damaged grease
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fitting would have been identified during preventive
mbintenance and replaced.
A Maintenance Work Request
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has been initiated to correct the failed gasket and
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damaged grease "zirc" fitting.
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V.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE
A1.
No recurrence control is necessary based on the
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qualification of the cables / splices.
A2.
An investigation was performed to reaffirm that the
Preventive. Maintenance (PM) Program ensures that
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equipment qualification is maintained.
The results of
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the investigation demonstrated that the regularly
scheduled PM would have detected and corrected the
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identified conditions.
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VI.
DATE OF FULL COMPLIANCE
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A1.
STP is in full compliance at this time.
The
documentation deficiency will be corrected by February
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28, 1990.
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A2.
STP is in full compliance at this time.
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Attachment 2
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ST-HL-AE-3286
File No.: G2.4, G26,
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G2.2, G4.02,
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G112.403
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Page 1 of 4
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South Texas Project Electric Generating Station
Units 1 and 2
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Docket Nos. STN 50-498, STN 50-499
Resnonse to Notice of Violation 8934-04
[
I.
STATEMEMT OF VIOLATION
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B.
Failure to Follow Procedure
Criteria V of Appendix B to 10 CFR 50 Part B requires
activities affecting quality to be prescribed by
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documented instructions, procedures, or drawings, of a
type appropriate to the circumstances and be accomplished
in accordance with those instructions, procedures, or
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drawings.
Paragraph 6.1 of the " Specification for Cable Splicing,
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Termination, and Supports," 5E189ES1004, Revision 10,
dated April 26, 1988, lists the requirements for forming
and supporting cables and conductors, including the
minimum band radius allowable;
Paragraph 8.2 of the above specification lists methods of ~
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electrical connection to be utilized inside the reactor
,
containment building in lieu of terminal blocks (tbs),
but allows the use of tbs in vendor supplied equipment if
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supplied by the vendor for-the specific equipment and
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utilized in a manner approved or qualified by the vendor.
The vendor (Limitorque Test Report B0009) qualified
certain equipment utilizing alternate TB connection
points; and
Section 6.5 of Station Procedure OPMP02-NZ-0053, "Raychem
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Insulation Application," Revision 1, dated January 12,
1988, provides the requirements for the proper selection
of shims and insulating sleeves for making bolted
connection splices.
Contrary to the abovet
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1.
Miras connected to the TB inside the motor operated
val.ve A1SI-MOV-0039A were found to be bent greater
than the minimum bend radius allowable.
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Attachment 2
ST-HL-AE-3286
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File No.
G2.4, G26,
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G2.2, G4.02,
G112.403
Page 2 of 4
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2.
Wires were connected to adjacent TB points inside
.i
the motor operated valve DIAF-MOV-0514 instead of
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alternate points specified in the vendor's test
report.
In addition, post installation inspections
.:
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incorrectly documented that the wires were connected
in accordance with the vendor's requirements.
3.
The splice connections for Flow Transmitter
i
N1SI-FT-0901 were not installed using the shims
necessary to provide a properly qcalified
configuration.
.
II.
HQHSTON LIGHTING & POWER POSIT 1QH
.;
.
Bl . . HL&P does not concur with the cited violation.
,
B2.
HL&P concurs with the cited violation.
B3.
HL&P concurs with the cited violation.
III.
REASON FOR THE VIOLATIONS
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Bl.
The wire with the unacceptable bend radius was determined
to be a spara for which band radius criteria do not
i
apply.
STP engineers reviewed the remaining wiring in
the motor opedator and found no non-conforming
,
,
conditions.
Both the vendor and field wiring were found
to have an neceptable bend radius.
All #12 AWG wires inside the limit switch compartment
which were connected to terminals had a band radius of
-
greater than 5/8".
The minimum band radius for the #12-
I
AWG wire is 3/8" as specified in installation procedures.
MOV AISI-MOV-0039A contains a spare wire in the limit
switch compartment (Wire No. A1SI14ClWK-SB)is listed in
that does
exceed the minimum bend radius.
This wire
the EE 580 cable codputer program as a spare to which
i
minimum band radius criteria do not apply.
The operator
.is in accordance with design requirements and would have
performed its safety function.
B2.
The reason . tor the violation is failure to follow
!
installation procedures.
The personnel performing the
!
post installation inspection failed to properly document
the justification for use of adjacent terminals in the
Construction and Inspection Planning (CIP) document.
The
use of adjacent terminals for the subject 125 VDC
actuator is acceptable because the qualification is based
,
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Attachment 2
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ST-HL-AE-3286
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File No.: G2.4, G26,
G2.2, G4.02,
i
G112.403
Page 3 of 4
on. documentation included in the EQ files for Marathon
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300 terminal blocks (Limitorque Test Report 50119).
I
However, this justification was not attached or referred
to in the CIP, except for a partial handwritten
annotation that the actuator is 125 VDC.
,
The HL&P investigation has determined that this error was
limited to the 125 VDC actuators.
,
,
B3.
See voluntary LER 89-18 transmitted by letter
ST-HL-AE-3299, S. L. Rosen (HL&P) to U.S. NRC Document
Control Desk, dated November 24, 1989.
i
IV.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED
'
Bl.
No violation of minimum band radius requirements was
'
found.
Therefore, no corrective action is necessary.
,
B2.
Based on investigation of the existing documentation, a
non-conformance report (NCR) was issued to address the
i
inadequate CIP documentation.
,
B3.
See voluntary LER 89-18 transmitted by letter
>
ST-HL-AE-3299, S. L. Rosen (HL&P) to U.S. NRC Document
Control Desk, dated November 24, 1989.
1
V.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE
Bl.
Investigations and walkdowns have confirmed that the
i
wiring in the subject motor operated valve is in
accordance with design requirements.
Valve operability
'
was not compromised.
Therefore, no measures are,
necessary to prevent recurrence.
B2.
The Limitorque vendor's manual will be revised by
December 15, 1989 to clarify that the use of adjacent
terminals for the 125 VDC actuators is acceptable.
Limitorque Motor Inspection procedure (OPMP05-ZE-0300)
will be revised by January 16, 1990 to address the use of
adjacent termination points.
B3.
See voluntary LER 89-18 transmitted by letter
ST-HL-AE-3299, S. L. Rosen (HL&P) to U.S. NRC Document
Control Desk, dated November 24, 1989.
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Attachment 2
ST-HL-AE-3286
File No.: G2.4, G26,
G2.2, G4.02,
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G112.403
Page 4 of 4
VI.
DATE OF FULL COMPLIANCE
Bl.
STP is in full compliance at this time.
,
B2.
STP is in full compliance at this time.
The
documentation revisions will be completed by
January 16, 1990.
B3.
STP is in full compliance at this time.
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Attoch::nt 3
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ST-HL-AE-3286
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File No.
G2.4, G26,
G2.2, G4.02,
G112.403
Page 1 of 5
South Texas Project Electric Generating Station
Units 1 and 2
Docket Nos. STN 50-498, STN 50-499
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Resnonse to Observations / concerns Identified in NRC Insnection
Raport 50-498/89-34 and 50-499/89-34
A.
EO PROGRAM REVIEW
The following items were identified as observations and/or
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concerns as a result of the EQ Program inspections
CONCERN
Al
The EQ Master List (EQML) is difficult to use and
understand.
The EQML contained certain items
J
which are not required to be on the list.
RESPONSE Al
HL&P acknowledges the concern and actions are
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being initiated to review the EQML and delete
those items which do not need to be on the list.
These actions will be completed as part of the
on-going maintenance of EQ documentation.
OBSERVATION A2
The inspector indicated that there is confusion
on the use of the last column on the EQML which
states "yes" or "no" for EQ related maintenance
requirements.
Equipment qualified life should be
based on the lifetime of the limiting parts,
c
RESPONSE A2
The qualified life identified in the EQML P.nd on
the SCEW sheets represents the qualified life of
'
the major non-replaceable part of that component.
The Special EQ column in the EQML denotes if EQ
related maintenance is required to maintain the
.
qualified life of the component which is in
i
addition to the regular maintenance specified by
the original equipment manufacturer.
I
Special EQ "Y" denotes that'EQ related
,
maintenance (replacement of short life parts,
installation of sealing devices, etc.) is
required to maintain the qualified life of the
component.
The details of the EQ related
maintenance for each tag number are provided in
the Special Equipment Qualification Maintenance
Book (SEQMB) .
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Attochment 3
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ST-HL-AE-3286
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File No.:
G2.4, G26,
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G2.2, G4.02,
G112.403
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Page 2 of 5
Special EQ "N" danctes that no EQ related
maintenance is required to maintain the qualified
life of the component.
However, to further enhance our program and to
i
reduce confusion, the STP EQ procedure (CEP-
i
3.11Q)-and EQML are being revised to further
clarif
the meaning of EQ related maintenance
identi ied as "Y" or "N".
OBSERVATION A3
The inspector noted that HL&P relies heavily on
contractors, thereby weakening the corporate
knowledge base, and appearing to now have little
overall experience in the EQ area.
,
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RESPONSE A3
The subject contractors are regarded as an
extension of the HL&P organization and work under
direct HL&P supervision.
Since the time of this
audit, we have added one permanent employee with
more than six (6) years of STP specific EQ
,
experience in the EQ engineering discipline.
'B.
MAINTENANCE PROGRAM REVIEW
j
CONCERN
B1
The inspectors noted separate tracking of total
equipment maintenance requirements and were
concerned that any change in the STP philosophy
'
relating to the inclusion of " vendor recommended
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maintenanc?" in the PM index could result in
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omission of a required maintenance action.
RESPONSE B1
Based on the present Preventive Maintenance (PM)
program in place at STP, HL&P does not agree with
the NRC's concern.
The present PM program
requires an integration of (1) the EQ maintenance
requirements identified in the SEQMB and (2) the
maintenance recommendations included in the
vendor manuals.
Any change to the SEQMB
"
requirements is controlled by the EQ engineering
discipline and transmitted to the Maintenance
Department in the SEQMB.
Changes to vendor
,
manual recommendations are justified by
'
documented technical evaluations.
In addition,
the vendor manuals are kept updated by the Vendor
,
Equipment Technical Information Program (VETIP)
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Group.
CONCERN
B2
There were instances of poor maintenance
practices attributed to a lack of attention to
detail by some craftsman.
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Attacha2nt 3
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ST-HL-AE-3286
File No.t
G2.4, G26,
' ' '
G2.2, G4.02,
G112.403
Page 3 of 5
RESPONSE B2
HL&P believes that the STP programs and
procedures resulted in a quality plant with
reliable components.
Although the discrepancies
found were not safety significant, HL&P agrees
that they should not have existed.
The STP
maintenance program is set up so that it will
identify and correct conditions such as'those
found by the inspectors.
HL&P will also
reinforce with maintenance personnel the
importance of identifying and correcting these
types of discrepancies.
RECORD REVIEW
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OBSERVATION Cl
The existing Purchase Order based EQ filing
system being utilized could lead to future
difficulties in maintaining auditable records to
ensure proof of component qualification.
q
RESPONSE
C1
The qualification documentation maintained for
STP Units 1 & 2 is organized in an auditable form
I
and meets the requirements of 10 CFR 50.49.
However, we do agree with the NRC's
recommendation and will develop an enhancement to
the EQ Master List software that will sort the
purchase order based files by original equipment
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manufacturer (OEM).
CONCERN
C2
An Inspector Follow-up Item (498/8934-01) was
initiated to: Review the results of the
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licensee's temperature survey when the results
have been documented.
RESPONSE
C2
A plan of action and procedure to takJ a
temperature survey in the Reactor Containment
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Building (RCB) have been developed, and the
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survey is in progress.
RCB temperature data will
be retrieved during the Unit 1 second refueling
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outage (tentatively Spring 1990) and then
continued throughout the summer months to obtain
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values during the hottest time of the year.-
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CONCERN C3
Westinghouse EQ documentation (EQCP) did not
contain environmental qualification checklists.
RESPONSE C3
We agree with the NRC's concern.
The Equipment
Qualification Procedure No. OEP-3.11Q and
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Engineering Instruction No. EI-7.03 have
been revised to include preparation of an
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Attochm:nt 3
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ST-HL-AE-3286
File No.
G2.4, G26,
G2.2, G4.02,
Gil2.403
Page 4 of 5
Environmental Equipment Qualification
Chacklist (EEQC) for any future changes (any
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made after September 25, 1989) to the NSSS
EQCPs.
CONCERN C4
An Unresolved Item (498/8934-02; 499/8934-02) was
initiated to: Evaluate the qualified lifetime of
ASCO solenoid valves to ensure that they remain
RESPONSE C4
A plan of action has been developed to
re-evaluate the qualified lives of ASCO solenoid
valves.
This plan is now in progress and the
actions will be completed by December 28, 1989.
The preliminary calculations have indicated that
no solenoid valve would exceed its qualified
lifetime prior to the next refueling outage
scheduled for Spring 1990.
CONCERN C5
The MOV A1AF-FV-7525 did not have T-drains nor
the grease relief that were implied by the System
Component Evaluation Worksheet (SCEW).
The SCEW
sheet was misleading and the licenses stated that
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a clarification would be made.
RESPONSE C5
The SCEW sheet for the subject motor operated
valve has been corrected to clarify that this
valve is not required during a HELB environment.
Therefore, a T-drain and grease relief is not
required for equipment qualification. If during
normal on-going maintenance of the EQ
documentation other sheets are identified that
provide misleading information, they will be
corrected.
CONCERN C6
Solenoid valve with tag no. B1CC-FY-4548 did not
have a vendor plate attached to verify that it
was the proper model number for the solenoid.
Not having the name tag would present problems
with field walkdown and verification.-
RESPONSE C6
Valve identification is not performed by using
the vendor nameplate.
Components are numbered
and tagged with STP equipment tags numbers (TPNS
numbers) which are traceable to design
documentation. These tags are used for field
walkdown verification.
CONCERN C7
Solenoid valve A1AF-FY-7517 coil assembly was
loosely mounted.
RESPONSE C7
A Work Request was initiated to tighten the
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Attcchm:nt 3
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ST-HL-AE-3286
File No.:
G2.4, G26,
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G2.2, G4.02,
Gil2.403
Page 5 of 5
solenoid valve body jam nut to prevent the
housing from rotating loosely around the valve
body.
Work was completed on October 8, 1989.
CONCERN C8
Solenoid valve A1AF-FY-7517 did not have an
i
electrical conduit seal assembly (ECSA) that
.
would have prevented noisture intrusion if it was
1
required to operate in HELB scenario.
,
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RESPONSE C8
The SCEW sheet for this solenoid valve has been
J
corrected to clarify that the valve is not
required to operate in a HELB environment.
Therefore an ECSA is not required for equipment
j
qualification.
!
CONCERN C9A'
Two screws were found in the bottom of the switch
compartment on one of the valves (BISI-HV-0899-
!
01).
RESPONSE C9A
A Work Request was initiated to remove the loose
screws.
Work was completed on September 30,
1989.
CONCERN C9B
On valve (AlSI-PV-3928-01) , separation barriers
'
between adjacent terminals on the TB had been
broken by apparently using a screwdriver that was
too large and terminal screws were missing
resulting in the placing of two wires on the same
'
screw.
RESPONSE C9B
A Work Request was initiated to replace the
.
terminal block and correct the two wires on the
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same screw.
Work was completed on September 24,
1989.
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