ML20038B652

First Interim Deficiency Rept Re Equipment Judged Unqualified for safety-related Use During Investigation of NUREG-0588 Requirements,Initially Reported 811015.Equipment Identified to Be Replaced or Modified

ML20038B652
Person / Time
Site:	Grand Gulf
Issue date:	12/01/1981
From:	Mcgaughy J MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
RTR-NUREG-0588, RTR-NUREG-588 10CFR-050.55E, 10CFR-50.55E, AECM-81-473, NUDOCS 8112080465
Download: ML20038B652 (16)

Text

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] MISSISSIPHelping PI PBuild O\hNh[lississippi'CGRT, A ~ CO M P. O. B OX 16 4 0, J AC K S O N, MIS SIS SIP PI 3 9 2 0 5 3l DEC 3 ^8 35 JAMES P. McGAUGHY. JR.

assisr4~r vice mser December 1, 1981 Office of Inspection & Enforcement M U. S. Nuclear Regulatory Commission p 4 3

<N Region II N // '1 101 Marietta Street, N.W. /jM  :

Suite 3100 2 Atlanta, Georgia 30303 D ,'(l re /

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Attention: Mr. J. P. O'Reilly, Regional Administrator 6s  %

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Dear Mr. O'Reilly:

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416/417 File 0260/15525/15526 PRD-81/42, Interim Report No. 1, NUREG-0588 AECM-81/473 On October 15, 1981, Mississippi Power & Light Company notified Mr. P. A.

Taylor, of your of fice, of a Potentially Reportable Deficiency (PRD) at the Grand Gulf Nuclear Station (GGNS) construction site. The deficiency concerns equipment determined to be unqualified during the investigation of the NUREG-0588 Requirements In a previous telephone conversation with your Mr. F. S. Cantrell on August 3, 1981, MP&L agreed to the following:

1. Reporting, under 10CFR50.55(e), the first piece of equipment reviewed under the qualification plan which were it "to have remained uncorrected could have adversely affected the safety of operations of the nuclear power plant".

2. Submitting interim reports approximately every three months after the first report, adding additional equipment found not to be qualified and which also "could adversely affect safety".

3. Submitting a final report on completion of the qualification work, referencing previous interim reports.

This report was originally due your office on November 16, 1981, but a two week extension was requested and granted by Mr. P. A. Taylcg on November 17, 1981.

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DR ADOCK Member Middle South Utilities System fg i

Mr. J. P. O'Reilly AECM-81/473 NRC Page 2 Attached is our Interim Report No. 1 identifying that equipment previously reported and since determined to be ' reportable within the meaning of 10CFR50.55(e) and that equipment previously reported and since determined not to be reportable within the meaning of 10CFR50.55(e).

We expect to submit our next Interim Report b.y March 1,19.82.

Yours truly, ftlJ. P. licJaughy, Jr.

ATR:dr ATTACHMENT cc: Mr. N. L. Stampley Mr. R. B. McGehee Mr. T. B. Conner Mr. Richard C. DeYoung, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D-C. 20555 Mr. G. B. Taylor South Miss. Electric Power Association P. O. Box 1589 Hattiesburg, MS 39,401 l

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Attscheent A to AECM-81/473 Page 1 of I INTERIM REPORT. #1 TO PRD-81/42 I 1. Description of Deficiency As a result of NUREG-0588, " Environmental Qualification Requirements",

MP&L initiated a review to determine the acceptability of _ the specified equipment. The initial review has revealed that certain equipment is not qualified for its ir. tended safety-related use. The equipment

- identified, to date, is as follows:

A. NSSS Scope of Supply 1

1. MS1V Limit' Switches, NAMCO Model EA740

2. HPCS Motor Operated Valve, Limitorque, Model SB-3-100

3. Schutte &'Koerting (S&K) Flow Meter B. BOP Scope of Supply

1. Butterfly Valve Position Switches, NAMCO Model EA170

2. Gould Handswitch M-009B

2. Safety Implications Each item will be discussed in the enclosures to this . attachment.

Enclosures:

, 1. NAMCO EA740

2. HPCS Motor Operated Valve ,

3. S&K Flow Meter

4. NAMCO EA170 Position Switches

5. Gould Handswitch M-009B i

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Enclosure 1 to Atttchment A to AECM-81/473 Page 1 of 1 Component: MSIV Limit Switches Manufacturer: NAMCO - Model EA 740

1. Description The limit switches for the MSIV's were manufactured in 1975. They were NAMCO Model EA-740 Limit Switches. These were never environmentally qualified (no test report) for their intended application.

The MSIV Limit Switches are used in the MSIV-Leakage Control System (MSIV-LCS) to isolate or interlock the LCS , depending on the in-board MSIV position indication. The LCS is used following a Design Basis Accident (DBA) recirculation line break to collect MSIV seat leakage and direct it to the Standby Gas Treatment System in Auxiliary Building for processing.

Since the limit switches had not been environmentally qualified for their intended use, their failure could adversely af fect the safety of operations of the plant and is, therefore, reportable within the meaning of 10CFR50.55(e).

2. Approach to Resolution of the Problem NAMCO has, since 1975, modified and qualified the EA-740 switches to meet IEEE 323-1974. These new switches will be purchased and used to replace the existing switches. Additionally, the new switches will be tested to obtain a five (5) year qualified life.

3. Status of Proposed Resolution The new switches are expected to be installed by December 31, 1981, a nd the additional testing is expected to be completed by June, 1982.

4. Reason Why A Final Report Will Be Delayed As noted in the letter of transmittal.

5. Date When A Final Report Will Be Submitted As noted in the letter of transmittal.

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Enclorura 2 to Atttchment A to AECM-81/473 Page 1 of 1 Component: HPCS Motor Operated _ Valve Manufacturer: Limitorque Model SB-3-100

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1. De scription Adequate test data does not exist to support the qualification of the Limitorque Model SB-3-100 valve actuator used on valve (E22-F004) in the High Pressure Core Spray System (HPCS).

This valve is the HPCS injection valve and is required to open during the first minute of an accident to initiate HPCS flow to the core.

Subsequently, the valve serves as an isolation valve to terminate HPCS flow on high reactor water level or by operator action.

F/.llure of the valve to perform its intended safety f unction could adversely af fect the safety of operations of the plant and is, therefore, reportable within the meaning of 10CFR50.55(e).

2. Approach to Resolution of the Problem The actustor components are to be replaced by components which have been extensively type tested for abnormal environmental conditions. The

aging tests, however, are considered inadequate to meet the requirements of NUREG-0588. Therefore, additional testing will be accomplished by 2

June 1982 to obtain a fully qualified actuator.

3. Status of Proposed Resolution The unqualified components in the Unit i valve actuator will. be replaced by December 31, 1981 and additional testing is being undertaken with a projected completion of June 1982. ,

4. Reason Why A Final Report Will Be Delayed As noted in the letter of transmittal.

5. Date When A Final Report Will Be Submitted As noted in the letter of transmittal.

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Enclosure 3 to Attachment A to AECM-81/473 Page 1 of 1 Component: Flow Meter Manufacturer: Schutte & Koerting (S&K) Model 20-9651-8550

1. _ Description The S&K flow meter is subject to only radiation as a harsh environment.

Pressure, temperature, and humidity are non-harsh for this device. The radiation environment will af fect the function of the Teflon washer located in the flow meter.

The flow meter is used in the MSIV - Leakage Control System (MSIV-LCS). The MSIV-LCS, including instrumentation and circuits necessary for the functioning of the system, are designed in accordance with standards applicable to an engineered safety feature.

2. Analysis of Safety Implications The flow meter measures leakage flow in a 1" pipeline toward the low pressure manifold. The flow meter can act as a flow rate regulating check valve in both directions. If the Teflon washer is deformed due to radiation, then the alignment of LVRT coil can be af fected. However, the flow meter will continue to perform the necessary function of physically limiting the leakage flow to the Low Pressure Manifold. The flow sensor is a fail-safe design and it activates an alarm under high leakage flow conditions. This alarm is used for initiation of isolation of the in-board LCS system. If the failure of the Teflon washer ef fects a misalignment of the LVRT coil, an erroneous flow signal can be generated.

This failure, however, will not adversely af fect the safety of operations of the plant because the flow meter will continue to perform its limiting function and an erroneous high-leakage flow signal will cause the initiation of measures to isolate the in-board LCS system.

This deficiency, therefore, is not reportable within the meaning of 10CFR50.55(e).

3. Corrective Actions Taken Even thmith the failure of the flow meter would not adversely af fect safety, it does not meet the NUREG-0588, Category 11 requirements. To meet these requirements, the Teflon washer will be replaced with a brass washer and the flow meter will be recalibrated.

It is expected that the flow meter will be modified by June, 1982.

Enclorura 4 to Atttchment A to AECM-81/473 Page 1 of 1 Component: Position Switches EA-170 Manufacturer: NAMCO Controls

1. Description The NAMCO Model "4-170 Position Switches are installed on 24 valves both inside and outside containment. The affected systens are: Standby Liquid Control, Combustible Gas Control, Fuel Fool Cooling & Cleanup,

' Containment Cooling, Condensate & Ref ueling Water Transfer & Storage, Plant Service Water, Auxiliary Building Ventilation, and Fuel Handling _

Area Ventilation.

There are either no environmental qualification test reports available or the material used in these switches has a maximum service temperature of only 225 F. Therefore, the switches would not remain functional in the elevated temperatures during a Loss of Coolant Accident (LOCA) or Hight Energy Line Break (HELB).

This deficiency is, therefore, reportable within the meaning of 10CFR50.55(e).

2. Approacn to Resolution of the Problem The switches will be replaced with qualified NAMCO EA-740 switches prior to fuel load.

3. Status of Proposed Resolution Procurement action has been initiated to obtain the NAMCO Model EA-740 switches. It is expected that it will require 10 weeks for delivery and io;tallation of the switches.

4. Reason Why A Final Report Will Be Delayed As noted in the letter of transmittal.

5. Date When A Final Report Will Be Submitted As noted in the letter transmittal.

s= i Enclosura 5 to Attachment A to AECM-81/473 Page 1 of 1 Component: Handswitch Manufacturer: Gould, Inc. M0098~

1. Description ,

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The handswitch is not qualified to withstand the radiation levels in its present location. The handswitch is used in the Standby Service Water System which removes heat from plant auxiliaries during an emergency shutdown of the plant.

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2. Analysis of Safety Implications The specific application of the handswitch is in relation to the Residual Heat Removal (RHR', Loop B Heat Exchangers. When the RHR Heat Exchangers are not in operation, the tube side piping is flushed with l desineralized water supplied by the makeup water system'to purge the heat exchanger of impurities and minimize corrosion and fouling. The demineralized water is brought in through a supply valve which is operated with local handswitch HS-M009B.

. The failure of the handswitch will not adversely affect the function of the RHR Heat Exchangers to perform their intended safety function. The handswitch only controls water to flush piping when the Heat Exchangers are not in operation.

This deficiency,1therefore, is not reportable within the meaning of 10CFR50.55(e).

3. Corrective Actions Taken Even though the failure of the handswitch would .not adversely affect safety, it does not meet the NUREG-0588 requirements. To meet these

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requirements the handswitch will be relocated to reduce the radiation exposure of the handswitch to acceptable limits.

It is expected the handswitch will be relocated prior to fuel load.

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) MISSISSIPPI POWER & LIGHT COMPANY

]a Helping Build Missi_ssippi Edhhilhildd5 P. O. B O X 164 0, J AC K S O N, MIS SIS SIP PI 3 9 2 05 JAMES P. McGAUGHY. JR assinan vicmesioe" December 1, 1981 Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission @

Region II g g 'g 101 Marietta Street, N.W. '

( N eQ2 Suite 3100 Atlanta, Georgia 30303 Y

7 /g f Attention: Mr. J. P. O'Reilly, Regional Administrator  %

Dear Mr. O'Reilly:

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SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2

&cket Nos. 50-416/417 File 0260/15525/15526 PPD-Si/42, Interim Report No. 1, NUREC-C388 AECM-81/473 On October 15, 1981, Mississippi Power & Light Company notified Mr. P. A.

Taylor, of your of fice, of a Potentially Reportable Deficiency (PRD) at the Grand Gulf Nuclear Station (GGNS) construction site. The deficiency concerns equipment determined to be unqualified during the investigation of the NUREG-  ;.

0588 Requirements In a previous telephone conversation with your Mr. F. S. Cantrell on August 3, 1981, MP&L agreed to the following:

1. Reporting, under 10CFR50.55(e), the first piece of equipment reviewed under the qualification plan which were it "to have remained uncorrected could have adversely affected the safety of operations of the nuclear power plant".

2. Submitting interim reports approximately every three months af ter the first report, adding additional equipment found not to be qualified and which also "could adversely affect safety".

3. Submitting a final report on completion of the qualification work, referencing previous interim reports.

This report was originally due your of fice on November 16, 1981, but a two week extension was requested and granted by Mr. P. A. Taylor on November 17, 1981.

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Member Middle South Utilities System T e .;L 7SI;,;i

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Mr. J. P. O'Reilly AECM-81/473 -

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NRC Page 2 Attached is our Interim Report No. 1 identifying that equipment previously reported and since determined to be reportable within the meaning of 10CFR50.55(e) and that equipment previously reported and since determined not to be reportable within the meaning of 10CFR50.55(e).

We expect to submit our next Interim Report by March 1, 1982.

Yours truly, i

ftlJ.P.McCaughy,Jr.

ATR:dr i ATTACHMENT cc: Mr. N. L. Stampley Mr. R. B. McGehee Mr. T. B. Conner Mr. Richard C. DeYoung, Director

, Office of Inspection & Enforcement i U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. C. B. Taylor South Miss. Electric Power Association P. O. Box 1589 Hattiesburg, MS 39,401

Atts:chsent A to AECM-81/473 Page 1 of 1 INTERIM REPORT #1 T0_PRD-81/42

1. Description of Deficiency As a result of NUREG-0588, " Environmental Qualification Requirements",

MP&L initiated a review to determine the acceptability of the specified equipment. The initial review has revealed that certain equipment is not qualified for its intended safety-related use. The equipment identified, to date, is as follows:

s A. NSSS Scope of Supply

1. MSIV Limit Switches, NAMCO Model EA740

2. HPCS Motor Operated Valve, Limitorque, Model SB-3-100

3. Schutte & Koerting (S&K) Flow Meter B. BOP Scope of Supply

1. Butterfly Valve Position Switches, NAMCO Model EA170

2. Gould Handswitch M-009B

2. Safety Implications Each item will be discussed in the enclosures to this attachment.

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Enclosures:

1. NAMCO EA740

2. HPCS Motor Operated Valve ,

3. S&K Flow Meter

4. NAMCO EA170 Position Switches

5. Gould Handswitch M-009B De

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Enclosure 1 to Attachment A to AECM-81/473  ;

Pags 1 of 1 a

j Component: MSIV Limit Switches ,

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.' Manufacturer: N4MCO - Model EA 740 4

1. Descriptieg j The limit switches for the MSIV's were manufactured in 1975. They were NAMCO Model EA-740 Limit Switches. These were never environmentally 1

qualified (no test report) for their intended application. <

The MSIV Limit Switches are used in the MSIV-Leakage Control System I

(MSIV-LCS) to isolate or interlock the LCS ' depending on the in-board .

MSIV position indication. The LCS is used following a Design Basis Accident (DBA) recirculation line break to collect MSIV seat leakage and ,

direct it to.the Standby Gas Treatment System in Auxiliary Building for

processing.

Since the limit switches had not been environmentally qualified for

their intended use, their failure could adversely af fect the safety of j

operations of the plant and is, therefore, reportable within the meaning of 10CFR50.55(e).

2. Approach to Resolution of the Problem NAMCO has, since 1975, modified and qealified the EA-740 switches to meet IEEE 323-1974. These new switches vill be purchased and used to replace the existing switches. Additionally, the new switches will be tested to obtain a five (5) year qualified life.

3. Status of Proposed Resolution 1 b 4

The new switches are expected to be installed by December 31,1981, and

the additional testing is expected to be completed by June, 1982.

l 4 .' Reason Why A Final Report Will Be Delayed ,

i As noted in the letter of transmittal. <

5. Date When A Final Report Will Be Submitted As noted in the letter of transsir.tal.

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Enclo:urs 2 to Attachment A to AECM-81/473 Page 1 of 1 Ccaponent: HPCS Motor Operated Valve Manufacturer: Limitorque Model SB-3-100

1. Description Adequate test data does not exist to support the qualification of the Limitorque Model SB-3-100 valve actuator used on valve (E22-F004) in the High Pressure Core Spray System (HPCS).

This valve is the HPCS injection valve and is required to open during the first minute of an accident to , initiate HPCS flow to the core.

Subsequently, the valve serves as an isolation valve to terminate HPCS flow on high reactor water level or by operator action.

Failure of the valve to perform its intended safety function could adversely affect the safety of operations of the plant and is, therefore, reportable within the meaning of 10CFR50.55(e).

2. Approach to Resolution of the Problem The actuator components are to be replaced by components which have been extensively type tested for abnormal environmental conditions. The aging tests, however, are considered inadequate to meet the requirements of NUREG-0588. Therefore, additional testing will be accomplished by June 1982 to obtain a fully qualified actuator.

3. Status of Proposed Resolution The unqualified components in the Unit i valve actuator will be replaced i by December 31, 1981 and additional testing is being undertaken with a projected completion of J2ne 1982.

4. Reason Why A Final Report Will Be Delayed As noted in the letter of transmittal.

5. Date Khen A Final Report Will Be Submitted As noted in the letter of transmittal.

Enclosura 3 to Attcchment A to AECM-81/473 Page 1 of 1 Component: Flow Meter .

Manufacturer: Schutte & Koerting (S&K) Model 20-9651-8550

1. Description The S&K flow meter is subject to only radiation as a harsh environment.

~

Pressure, temperature, and humidity are non-harsh for this device. The radiation environment will affect the function of the Teflon washer located in the flow meter.

The flow meter is used in the MSIV.- Leakage Control System (MSIV-LCS). The MSIV-LCS, including instrumentation and circuits necessary for the functioning of the system, are designed in accordance with standards applicable to an engineered safety feature.

2. Analysis of Safety Implications The flow meter measures leakage flow in a 1" pipeline toward the low pressure manifold. The flow meter can act as a flow rate regulating check valve in both directions. If the Teflon washer is deformed due to radiation, then the alignment of LVRT coil can be affected. However, the flow meter will continue to perform the necessary function of physically limiting the leakage flow to the Low Pressure Manifold. The flow sensor is a fail-safe design and it activates an alarm under high leakage flow conditions. This alarm is used for initiation of isolation of the in-board LCS system. If the failure of the Teflon washer effects a misalignment of the LVRT coil, an erroneous flow signal can be generated.

L This failure, however, will not adversely affect the safety of operations of the plant because the flow meter will continue to perform its limiting function and an erroneous high-leakage flow signal ' !1 cause the initiation of measures to isolate the in-board LCS system.

This deficiency, therefore, is not reportable within the meaning of 10CFR50.55(e).

3. Corrective Actions Taken Even though the failure of the flow meter would not adversely af fect safety, it does not meet the NUREG-0588, Category II requirements. To meet these requirements, the Teflon washer will be replaced with a brass washer and the flow meter will be recalibrated.

It is expected that the flow meter will be modified by June,1982.

Enclosura 4 to Attrchment A to AECM-81/473 Page 1 of 1 Component: Position Switches EA-170 Manufacturer: NAMCO Controls

1. Description The NAMCO Model EA-170 Position Switches are installed on 24 valves both inside and outside containment. The affected systems are: Standby Liquid Control, Combustible Cas Control _, Fuel Pool Cooling & Cleanup, Containment Cooling, Condensate & Refueling Water Transfer & Storage, Plant Service Water, Auxiliary Building Ventilation, and Fuel Handling Area Ventilation.

There are either no environmental qualification test reports available or the material used in these switches has a maximum service temperature of only 225" F. Therefore, the switches would not remain functional in the elevated temperatures during a Loss of Coolant Accident (LOCA) or Hight Energy Line Break (HELB).

This deficiency is, therefore, reportable within the meaning of 100FR50.55(e).

2. Approach to Resoletion of the Problem The switches will be replaced with qualified MAMCO EA-740 switches prior to fuel load.

3. Status of Proposed Resolution Procurement action has been initiated to obtain the NAMCO Model EA-740 b switches. It is expected that it will require 10 weeks for delivery and installation of the switches.

4. Reason Why A Final Report Will Be Delayed As noted in the letter of transmittal.

5. Date When A Final Report Will Be Submitted As noted in the letter transmittal.

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/. Encloruro5to.AttachmentAto.AECM-81'/k731 1 Y '

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• b Component: Handswitch i,

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Manufacturer: Gould, Inc. M009B I _

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1. Description * '

u,p s , , A The handswitch is not qualified to withstand the radiation' levels in ils k present location. The handswitch is used in the Standby Service Water,

• P System which removes heat from plant auxiliaries during an emergency ,

' , Wy shutdown of the plant.  ? , q

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2. Analysis of Safety Implications '

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The specific application of the handswitch is in relation to tha sg y '

Residual Heat Removal (RHR) Loop B Heat Exchangers. When the'RHR., Meat [ ,

Exchangers are not in operation, the tube side piping is flushed with Q ,N, demineralized water supplied by the makeup water system to purge the d heat exchanger of impurities and minimize corrosion and fouling.-The g _f , ' ,,,, .

demineralized water is brought in through a supply valve which is -C

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operated with local.handswitch HS-M009B. N " , i The failure of the handswitch will not adversely af fect the function of the RHR Heat Exchangers to perform their intended safety function. The ,

handswitch only controls water to flush piping when the Heat Exchangers (.f g are not in operation. +

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This deficiency, therefore, is not' reportable with'in the meaning of 10CFR50.55(e).

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3. Corrective Actions Taken

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Even though the failure of the handswitch would not advdrsely affect t a

safety, it does not meet the NUREG-0588 requirements.-oTo ineet e th'se i h /, f P!

requirements the handswitch will' be relocated to reduce the radiation' , [d W$

exposure of the handswitch to acceptable limits.

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It is expected the handswitch will be relocated prior to' fuel load. 6 7y N y T. , 'c i ,

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