ML20050C266

First Interim Deficiency Rept Re Unqualified Namco Limit Switches,Initially Reported 820225.Unqualified Switches That Perform safety-related Function Will Be Replaced.Next Rept by 820419.Also Reported Per Part 21

ML20050C266
Person / Time
Site:	Grand Gulf
Issue date:	03/26/1982
From:	Mcgaughy J MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
REF-PT21-82 10CFR-050.55E, AECM-82-108, NUDOCS 8204080346
Download: ML20050C266 (10)

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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi --

P. O . B O X 16 4 0, J A C K S O N , M I S S I S S I P P I 3 9 2 0,5

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JAMES P. McGAUGHY, JR. March 26,1982 y AS$1STANT VICE PRESIDENT Office of Inspection & Enforcement #

U. S. Nuclear Regulatory Commission -

Region II 101 Marietta Street, N.W.

Suite 3100 y-Atlanta, Georgia 30303 Attention: Mr. J. P. O'Reilly, Regional Administrator

Dear Mr. O'Reilly:

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SUBJECT:

Grand Gulf Nuclear Station d ""

a&D _g Units 1 and 2 Op7 .

Docke t Nos. 50-416/417

• File 0260/15525/15526 s[i

'\ r:tr j' / PRD-82/07, Interim Report #1,

/ '- Unqualified NAMCO Limit CS^ Switches 7]T[h AECM-82/108 On February 25, 1982, Mississippi Power & Light Company notified Mr. R.

Butcher, of your of fice, of a Potentially Reportable Deficiency (PRD) at the Grand Gulf Nuclear Station (GCNS) construction site. The deficiency conccens unqualified NAMCO limit switches.

Bechtel Power Corporation and MP&L have both determined that this deficiency is a substantial safety hazard and meets the reporting requirements of 10CFR21 for both Bechtel and MP&L. Mr. F. S. Cantrell was notified by phone of this determination on March 23, 1982.

Our original notification stated that Models EA740 and EA180 may not be qualified for their intended safety functions. At this time, only the model EA740 switches, none of the model EA180 switches, have been identified as being safety-related. However, investigations are continuing by MP&L.

Bechtel's Part 21 report is included as Attachment B to this letter.

MP&L's Interim Report is included as Attachment A. We expect to submit our Final Report by April 19, 1982.

Yours truly, F204080346 G20326 k

PDR ADOCK 05000416 . P. cGaughy, Jr.

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OFFICIAL COPY __ .

cc: See page 2 lb dy Member Middle South Utilities System /

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- Mr. J. P. 0'Reilly

. AECM-82/108 NRC Page 2 cc: .Mr. N. L. Stampley <

Mr. R. B. McGehee

. Mr. T. B. Conner Mr. Richard C. DeYoung, Director Office of Inspectfon & Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 2055s

Mr. G. B. Taylor-South Miss.-Electric Power Association P. O. Box 1589 -

Hattiesburg, MS 39401 L

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Attac' amsnt "A" to AECH-82/108 Pagn 1 of.3 INTERIM REPORT NO. 1 FOR PRD-82/07

1. Name and address of the individual . . . informing the commission:

J. P. McGaughy, Jr.

Assistant Vice-President, Nuclear Production P.O. Box 1640 Jackson, Mississippi 39205 Notification of Part 21 applicability made to Mr. F. S. Cantrell, NRC, Region II by phone on March 23, 1982.

2. Identification of the facility ... which ... contains a deficiency:

Grand Gulf Nuclear Station (CGNS) Unit 1 Port Gibson, Mississippi 39150 Investigations are underway to determine if this deficiency applies to Unit 2.'

3. Identification of the firm ... supplying the basic component which ...

contains a deficiency:

Supplied to Grand Gulf by Bechtel Power Corporation, Gaithersburg, Maryland. Investigations are underway to see if any unqualified safety-related NAMCO switches were supplied by General Electric in the NSSS Scope of Supply.

4. Nature of the deficiency .. . and the safety hazard which . .. could be created by such a deficiency ...:

A. Description of the Deficiency According to NAMCO's test report " Qualification of NAMCO Control Limit Switches Model EA740", Revision 1, 2/22/79 Model EA740 and EA180 limit switches were qualified for - '. lear containment service.- However, it was later discov- that the applicability of the report depends upon the materials unca in construction of the limit switches. The materials can be identified by certain manufacturing codes stamped on each limit switch. The absence of the proper code on any limit switch indicates that it is unqualified since the materials used in the construction of the switch cannot be l identified.

Uncoded switches at GGNS on Unit 1 are known to be on valves in the following systems: Suppression Pool Cleanup (P60), Domestic Water (P66), Floor and Equipment Drains (P45), Residual Heat Removal I (E12), Reactor Water Cleanup Filter /Demineralizer (G36), Containment '

Cooling (M41), Condensate / Refueling Water (Pil)' and Standby Liquid Control (C41)

Attachannt "A" to AECH-82/108 Pags 2 of 3 During the investigation of NUREG-0588 requirements, EA740 limit switches on Main Steam Isolation Valves in the Nuclear Boiler System

. (B12) were also determined to be unqualified because of the manufac-turing date. These have previously been reported by MP&L under PRD-81/42.

' Applicability of the deficiency to Unit 2 and to the NSSS vendor is currently under investigation.

B. Analysis of Safety Implications The majority of the valves identified are used for containment and auxiliary building isolation. The limit switches are used to indicate the position (open/close) of safety-related valves. Failure of the limit switches during degraded plant conditions could cause erroneous indications of the status of the building isolation. This could further degrade plant conditions if inappropriate corrective actions were taken utilizing the erroneoue indications. This is a substantial safety hazard and reportable under the provisions of 10CFR21.

5. The date on which the information of such daficiency ... was obtained.

Mississippi Power and Light received information of the deficiency on Februa ry 24, 1982. We reported the deficiency to Mr. R. Butcher, of your office, as a Potentially Reportable Deficiency under 10CFR50.55(e) on that date. .We notified Mr. F. Cantrell of your office on March 23, 1982, that this deficiency was also reportabl3 under the provisions of 10CFR21 for Bechtel Power Corporation and Mississippi Power & Light. The MP&L-

" Responsible Officer," Mr. J. P. McGaughy, Jr. , will be notified of the Part 21 reporting requirement when he returns to his office.

6. In the case of the basic component ... the number and location of all such components.

- A total of ninety three (93) NAMCO type EA740 limit switches that perform a safety function have been identified on Unit 1 in eight (8) systems.

Two (2) type EA180 limit switches have been identified on Unit 1 but these do not perform a safety' function. Investigations are currently underway to locate any additional affected switches on Unit 2.

We do not have knowledge of the location of defective equipment located other than at GGNS. i 1

-7. The corrective action which has been taken . . . the name of the individual '

... reponsible for the action; and the length of time that has been ...

taken to complete the action.

A. Corrective Actions Taken -l l

All unqualified switches that perform a safety related function will

. be replaced with correct switches that have the necessary '

qualifications for nuclear service. '

w Atttchannt "A" to AECM-82/108 Pags 3 of 3 B. . Responsible Individual G. B. Rogers, Jr.

Site Manager Mississippi. Power and Light Company C. - Length of Time to Complete Actions Since it is not positively known at this time if all affected switches-have been located, a definite date cannot be determined for completion of. corrective actions.

8. Any advice related to the deficiency ... that has been, is being, or will be given to purchasers or licensees:

hi the deficiency did not originate with MP&L, we have no advice to offer.

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bec: Dr. D. C. Gibbs Mr. J. N. Ward .

Mr. J. P. McGaughy, Jr.

Mr. J. D. Hbaton Mr. R. S. Trickovic Mr. J. W. Yelverton

'Mr. L. F. Dale Mr. C. K. McCoy Mr. T. H. Cloninger Mr. R. A. Ambrosino Mr. J ". Pinto Mr. G. T Rogers

Mr- '.

, H. Hobbs Mr. L. E. Ruhland Mr. C. C. Hayes Mr. A. G. Wagner Mr. R. F. Phares PRD File Manual File File-

-Mr. D. M. Houston

U. S. Nuclear Regulatory Commission Division of Licensing Washington, D.' C. 20555 s

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. Attachment "B" to AECM-82/108 Page 1 of 4 ATIACF2ET "A" 'IO PRD 82/07 (I* CAR-132)

NAFCO LI!!IT SNI'lGES PARr 21 REPORP

1. Name and address of the individmis ... infonning the ccmnission:

J. R. Valdez Quality Assurance Supervisor Bechtel Power Corporation Post Office Eox 41 Port Gibson, Mississippi 39150 K. D. Shelton -

Quality Assurance Mississippi Power & Light Capany City Center North 210 South Lamar Street suite 320 Jackson, Mississippi 39201 Per telephone call on March 23, 1982 with !!r. F. Cantrell, Region II, NBC, it was confirmed that the 10 CFR 50.55 (e) tia2 requirements for the written report could be applied and, as such, MP&L was requested to include this report with their 50.55(e) report. -

2. Identification of the facility ... which contains a defect:

Grand Gulf Nuclear Station (GGNS)

Unit I and Unit II Port Gibson,flississippi 39150

3. Identification of the firm constructing the facility ... contains a defect:

Installed at the CGIS by:

Bechtel Power Corporation 15740 Shady Grove Pcad Gaithersburg,11aryland 20S77 m

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' Atitachment "B" to AECM-82/103

.Page 2 of 4

14. . Nature of the defect ... and the safety hazard which could be created by such defect:

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a. NXX) Controls letter to Bechtel dated August 27, 1982,. stated that all EA180 and EA740 limit switches listed in its attachment were qualified for nuclear containment service.

Based an this infortration, Bechtel Project Engineering for I

GGNS utilized the W ICO Controls test report " Qualification of

' MICO Controls Linit Switches, Model EA740, Revision 1, dated February 22, 1979" for justifying the use of 200 limit switches EA180 and EA740 on the safety related valves in Unit i I. However, subsequent discussions with NANCO Controls revealed that the applicability of this test report depends upon the caterials used in the construction of limit switches.

L These mate. rials can be identified by certain manufacturing

,! codes stanped on each limit switch, as explained in NAtro

' letter to Bechtel, dated December 15, 1981. Limit switches which do not have the proper codes may have materials which are indeterminate and, therefore, they cannot be covered by the above referenced test report. It should be noted that the nodel numbers remained unchanged even thcugh materials of construction are different.

b.

' The ambiguity in the NMKD letter dated August 27, 1981, resulted in this deficiency. Since the materials are indeterminate, there is a possibility that these limit switches may fail during normal operation or under post-ICCA conditions. These limit switches are used to-indicate the-position (open/close) of safety related valves. Failure of the limit switches could result'in erroneous indications.

This could confuse the operator, as the operator is required 4 to verify the position of sane of these valves (e.g., --

containment isolation valves) under the Off tbrreal Event Procedure. This confusion could cause.the operator to take improper corrective action..

The failure of the limit switches could also cause erroneous control signals to be generated which could initiate further T

indeterminate plant conditi6ns.

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The date on which the information of such a defect was obtained.

4 An evaluation of.the applicability under the provisions of 10 CFR 21 was made on !! arch 23, 1982 by Bechtel Pcwer Corporatien.

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-Attachment "B" to AECM-82/108 to: v. Page 3 of 4

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In the case of basic cwguent ... the number and location of all such.ccraponents:

The letter frcm NM 00 Controls, dated August 27, 1981, to Bechtel Grand Gulf Project Engineering resulted in the incorrect use of the subject test re:crt for the qualification of limit switch Models

.EA740 and FA180 at GGNS.

Note that for GGNS Unit I, none of the Model FA180 switches are

. utilized in a mode that could create a substantial hazard. I A total of ninety-three (93) Mcdel FA740 limit switches without proper identification code were found on various safety related valves located in the Containment and Auxiliary Buildings.

NAt00 Controls is being notified that Bechtel Project Engineering has filed a Part 21 Report. NM00 Controls is also being requested to be~ aware of the potential error that can occur in use of the test report " Qualification of NMKD Controls Limit Switches, Model EA740, Revision 1, dated February 22, 1979," as this report does not refer to any manufacturing codes.

'Information concerning this defect is being furnished to the other Bechtel Power Corporation divisions for review. should it be determined that basic canponents which contain this defect are in use at, have been supplied for, or are being supplied for one or more other Bechtel projects, this will be reported by the cognizant division directly to the cognizant director (s) of the NBC Pegicnal Office of Inspection and Enforcement.

7.

The corrective action which has been taken ... the name of the "

organization responsible for the action, and the length of time that has been ... or will be taken to ccznplete the action:

For Unit I, all the affected lbnit switch Models EA740 and EA180 en safety related valves have been physically inspected for the-manutacturing codes.

It has been determined that the lirit switches on certain valves do not'have proper manufacturing ccdes.

'Ihey are, therefore, not covered by the subject test report. .

Bechtel Field Engineering has placed an order for procurement of new limit switches which are qualified for nuclear service.

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Attachment "B" to AECM-82/108 l e

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Mississippi Power & Light Ccmpany has been notified of the deficiency by Bechtel letter dated February 5, 1982. The replacement of the switches will be scheduled by MP&L.

For Unit II, there is a possibility that a similar deficiency may exist in the limit switches Modals FA180 and EA740 installed on the safety related valves of Urit II. These limit switches will be physically inspected, end all those models which do not meet the criteria of the manufacturing ccdes will be replaced with new switches. These actions will be ccrcpleted, by Bechtel, prior to fuel load of Unit II.

8. Any advice related to the defect that has been, is being, or will be given to purchasers of licensees.

None e-t 9

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