ML20137R314
| ML20137R314 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/13/1985 |
| From: | Brooks C, Debs B, Falconer D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137R153 | List: |
| References | |
| 50-348-85-40, 50-364-85-40, NUDOCS 8512050473 | |
| Download: ML20137R314 (9) | |
See also: IR 05000348/1985040
Text
r:
-
.
UNITED STATES
jke Rf!g'o
NUCLEAR REIULATORY COMMISSION
.p
,
[
~,
REGION 11
j
.j
101 MARIETTA STREET.N.W.
ATL ANT A, GEORGI A 30323
s'
l
.....
Report No.: 50-348/85-40 and 50-364/85-40
Licensee: Alabama Power Company
600 North 18th Street
' Birmingham, AL 35291
l
Docket Nos.: 50-348 and-50-364
License Nos.:
Facility Name: 'Farley 1 and 2
Inspection Co acted:
September 30 -~ October 4, 1985
Inspectors:
N-
2e
I I - 13 - 87
l
D. Falponer
Date Signed
_h
11- 1% "T
.
l
C. Brooks
./-
Date Signed
'
Approved by:
-
_// /3
B. T.' Debs, Acting Section Chief
Date Signed
Operational Programs Section
Division of Reactor Safety
SUMMARY
Scope: This routine, unannounced inspection entailed 76 inspector-hours on site
in the area of maintenance program implementation.
Results: One violation was identified:
348/85-40-01 - Failure to Follow Procedures (multiple examples).
8512050473 851115
ADOCK 05000348
G
y
.
..
,
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- D. N. Morey, Assistant General Manager,.0perations
- L. A. Ward, Maintenance Superintendent
- W. G. Ware, SAER Supervisor
- T._W. Cherry, I&C Supervisor
- H. Garland, Maintenance Supervisor
- B. R. Yance, Sector Supervisor
NRC Resident Inspectors
W. H. Bradford,~ Senior Resident Inspector
B. Bonser, Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on October 4,1985, with
those persons indicated in paragraph I above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
In addition to the enforcement items, the following inspector followup items
were identified during the exit.
348, 364/85-40-03 - Calibration of. Instrument Air System Pressure
Switches.
348, 364/85-40-04 - Cleanliness Checks and Circuit Breaker Checks of
the 5 KVA and 7.5 KVA Inverters.
The licensee did not identify as proprietary any of the materials provided
to or_ reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
' determine whether they are acceptable or may involve violations or
deviations.
One unresolved item identified during this inspection con-
cerning the establishment of criteria to determine when print revisions are
L
.
.
-
-
.
,.
__
.
__ _ _ _ _ _ _ _ _ _
_
____ -.
<
. *?
.
2
I
!
necessary during the implementation of a Minor Departure From Design -
L
Temporary (URI 348,364/85-40-02) is discussed in paragraph 5.
5.
~ Corrective Maintenance
<
The inspector reviewed selected portions of the licensee's corrective
maintenance program to verify that the program is being implemented in
accordance with
regulatory requirements.
The following corrective
maintenance activities were included.
- -
a.
Feedwater Flow Control Valves
L
l
During an evaluation of test results from the performance of
FNP-1-STP-256.15, Loss of Offsite Power Response Time Test on April 21,
1985, the licensee identified extremely fast stroke times for the
Unit 1 feedwater flow control valves FCV-478, FCV-488, FCV-498,
,
l~
the stroke times of the feedwater flow control valves necessary to
FCV-479, FCV-489 and FCV-499.
FNP-1-STP-256.~15 is utilized to obtain
determine emergency safeguards features- (ESF) feedwater isolation
response times pursuant to Technical Specification (TS) Surveillance
i
Requirement 4.3.2.3.
This is accomplished by connecting a recorder to
l
selected terminals at the Main Control Board (MCB) Auxiliary Panel and
measuring the time between valve stroke limit switch actuations.
l
On April 25, 1985, suspecting that wiring errors in the limit switches,
l
limit switch function boxes, and main ' control board indication lights
l
of the six feedwater flow control valves as causing the selected
terminals in FNP-1-STP-256.15 to indicate incorrect stroke times
..
although correct valve indication was available at the MCB; the
licensee originated maintenance work requects (MWR) 111728, MWR 111729,
MWR 111730, MWR 111731, MWR 111732 and MWR 111733 to verify and correct
,
!
valve operation and indication for the six feedwater flow control
valves.
l
On May 15, 1985, the licensee implemented a temporary procedure change
l
number (TCN) 68 to FNP-1-STP-256.15 to utilize test point connections
necessary to obtain correct stroke time measurements of the six
i
feedwater flow control valves.
test results demonstrated that each
'
valve was within the feedwate
olation response time acceptance
criteria. On May 18,1985, elect ical maintenance personnel completed
maintenance activities pursuant to the above MWRs.
Only MWR 111728
(FCV-478) indicated that wiring in the limit switch junction box and to
the MCB indication was not in accordance with specified wiring drawings
and that corrective action had been taken to correct these
deficiencies. The other five MWRs indicated that the electrician had
checked wiring at the junction box and limit switch and found it to be
satisfactory. The electricians failed to identify that wiring at the
limit switch junction box was not terminated in accordance with
specified wiring drawings.
During subsequent dise"ssion between I&C
and electrical maintenance, it was revealed that wiring errors were not
w
-
_
>
-
.
3
corrected for five of the six feedwater flow control valves.
On
May 31, 1985, the licensee originated MWR 113930, MWR '13931, MWR
113932, MWR 113933 and MWR 113934 to correct wiring errors on the five
feedwater flow control valves on which maintenance activities completed
on May 18, 1985, failed to identify and correct the deficiency.
10 CFR 50 Appendix B, Criterion V, states that activities affecting
quality shall be prescribed by documented instructions, procedures, or
drawings of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures or
drawings.
The failure of the licensee to wire the limit switch junction box and
the indication lights at the MCB for FCV-478, FCV-479, FCV-488,
FCV-489, FCV-498 and FCV-499 pursuant to prescribed wiring drawings is
a violation of 10 CFR 50, Appendix B, Criterion V (348/85-40-01).
The second set of MWRs on the five feedwater flow control valves with
uncorrected wiring errors were placed into the outage maintenance file
to be completed during the Unit 1 1986 refueling outage. A review of
these MWRs by the inspector revanled that item 8, Deficiency Tags, was
checked "N0"
indicating that Deficiency Tags were not placed to
identify the deficiency. In that this abnormal plant configuration was
not subject to minor departure from design requirements, the inspector
considers the placement of deficiency tags to be
required.
FNP-0-AP-52, Equipment Status Control and Maintenance Authorization,
states that if the reported condition on the work request requires
corrective maintenance, the reviewing authority will ensure that a
deficiency tag is placed at a location to best identify the fact that
the deficiency has been reported.
The licensee's failure to place
deficiency tags pursuant to FNP-0-AP-52 will be identified as another
example of violation (348/85-40-01).
A review of previous FNP-1-STP-256.15 test results revealed that
extremely fast stroke times (approximately 1 second) for the feedwater
flow control valves first occurred during the 1984 refueling outage. A
procedure change had been developed from approved wiring drawings to
connect the time recorder to the incorrectly wired terminals prior to
the 1984 refueling outage.
Utilization of this procedure resulted in
nonconservatively incorrect stroke times for the six feedwater flow
control valves. These stroke times were subsequently considered in the
feedwater isolation response time verification as required by TS 4.3.2.3.
Post test evaluation of the 1984 test data by the licensee
failed to reveal that the stroke times for the six feedwater flow
control valves were incorrect and provided non-conservative data for
determining feedwater response times pursuant to TS 4.3.2.3.
A review
of FNP-1-STP-46.0, Main Feedwater Valves In-Service Test, conducted on
April 20, 1984, verified that the actual stroke times for the six
feedwater flow control valves were within the acceptance criteria of 5
seconds.
.
.
-
.
_
-
._- _ _
-
-.
._
_ _ _ - _ _ _ _
_ __
I
'
...
,
4
b.
Electrical Penetration Maintenance
Records associated with maintenance on safety-related electrical
penetration QIT528037-N which was performed on June 23, 1985, and
June 24, 1985, were reviewed. On June 23, 1985, the penetration failed
causing a rod drop event and subsequent reactor trip on Unit
1.
Maintenance Work request (MWR) No.114481 and Minor Departure from
Design No. 85-1163 were written to document the maintenance activities.
The problem was indicated by blown fuses on shutdown bank "B" rods E-11
and L-11.
Appropriate plant procedures were included in the work
sequence steps of the MWR for troubleshooting to determine the cause of
failure, including FNP-0-MP-67.0, Continuity Check for CRDM Cables and
Coils, and FNP-0-MP-28.191 for replace,ent of the fuses.
Work sequence step 5 was vague in that once the troubleshooting efforts
determined the failure cause, the instruction was simply to repair as
necessary.
The maintenance performed was documented in blocks 37 and
39 of the MWR. The problem was determined to be due to a short in the
wires for rods E-11 and L-11 in penetration 5037. The repair consisted
of moving the E-11 wires to spare conductors in module A of penetration
B037 (this is the module in which the four conductors for rods E-11 and
L-11 were found shorted together) and moving the L-11 wires to spare
conductors in module C of penetration B037. The MWR did not document
the use of approved procedures, technical manuals or drawings, or the
determination and retermination of the wires. Discussion with plant
personnel indicated that drawing A-172398, Cable Termination Detail,
Farle/ Nuclear Plant, Units 1 & 2, contained the instruction details
for this work and was used by maintenance personnel.
FNP-0-AP-52,
Equipment Status Control and Maintenance Authorization, requires that
the work sequence include delineation of the activities to be performed
either by reference to approved procedures or by inclusion of steps
written into the work sequence which incorporates the use of approved
procedures, technical manuals, or drawings. Three~ additional failures
to adhere to FNP-0-AP-52 associated with MWR No. 114481 were
identified.
The failure description, block 18, was not completed in
accordance with paragraph 7.5.1 of ' AP-52 which specifies that a
description of the failure shall be entered in block 18 for work
requests which are generated as a result of equipment failures.
This
entry is used for trending and failure analysis. Block 25 was not
annotated to indicate if any inspections were required during
performance of maintenance in accordance with paragraph 7.5.6.4 of
AP-52.
Block 30 was not annotated to indicate if the MWR was
associated with NPRD reportable equipment failure per~ paragraph 7.5.10
of AP-52. These items were discussed with plant management during an
exit meeting on October 4,1985.
These items will be included as an
additional example of violation (348/85-40-01).
.
I
_ . . _ _ . _ _ . _ _ . _ _ - _ _ _ _ _ _ _ _ . _ _
..
,
5
,
Following retermination of the CRDM stationary coil wires, FNP-0-67.0,
Continuity Check of CRDM Cables and Coils, was performed.
Coil
resistance was recorded on the MWR to be 11.7 ohms for rod E-11 and
11.6 ohms for rod L-11. The MWR indicates that the coils were returned
to - service following this check, although the acceptance criteria
provided in MP-67.0 requires that coil resistance readings must fall
within the range of 8 to 11 ohms. Discussions with plant personnel
indicated that the manufacturer's instruction book U-213116A-
CRDM-0-106A was used for the acceptance criteria in this case.
This
!
instruction book indicates that the stationary. gripper coil resistance
is a function of coil temperature and varies between 8.92 ohm at 25*C
and 14.9 ohms at 200 C.
FNP-0-MP-67.0 prerequisites do not place
restrictions on coil temperatures. Coil temperatures are not measured
or recorded during the procedure nor does the acceptance criteria
indicate that it is applicable to coils at ambient temperature only.
The inadequate acceptance criteria in MP-67.0 is anather example of a
violation against 10 CFR 50, Appendix B, Criterion V (348/85-40-01).
The wiring change in penetration 8037 was documented on Temporary Minor
Departure from Design No. 85-1163.
FNP-0-AP-8, Design Modification
Control, establishes the requirements for this program.
Section 16.1
of AP-8 states that the four criteria must be evaluated to determine if
a change can be implemented as a Minor Departure from Design
-
Temporary.
The second criteria is that the work complies with
recognized industry standards and good engineering practice. There was
no indication of what good practice the wiring change complied with.
Furthermr.,re, the description of the change on the minor departure form
indicated that two wires were moved by jumpers to a different module
within penetration 8037. Plant maintenance personnel indicated that no
jumpers were used, the wires were determinated and redeterminated to a
different module. Section 16.2.7 of AP-8 requires that the description
of the change must provide a complete and through description of the
change with attached sketches and marked up drawings as necessary for
illustration. This was identified to plant management as an additional
example of a violation for failure to adhere to plant instructions
(348/85-40-01).
AP-8, Design Modification Control, Section 17.1 requires that drawings
shall be revised whenever the need is identified, and that typically,
site prepared revisions shall be used to input changes to drawings
. which will correct them - to the as-built condition of the plant.
Drawings D-181931 and D-181932, Power Penetration QIT528037-N, were not
revised to reflect the as-built- condition following the wiring change
performed under MWR 11481. Although this wiring change was expected to
remain until the next Unit 1 outage in the fall of 1986, plant
personnel do not routinely update drawings when a Minor Departure from
Design - Temporary is in effect. This was identified as an unresolved
item pending clarification of the terminology "when the need is
identified" (348/85-40-02),
f
.--
- -
. .
- . .
- .
-
- - - - - - - . - - - - - -
. - . . - - - - -
,.
_
-
-
-
.
i
6
10 CFR 50, Appendix B, Criterion XVI requires that the cause of
significant conditions: adverse to quality be determined and corrective
action taken to preclude repetition. Although the cause of the rod
drop event on June 23, 1985, has been attributed to an insulation
breakdown between conductors in the A module of penetration 8037 due to
natural end of life, the licensee failed to investigate the full extent
of insulation breakdown in the penetration. The limited investigation
during troubleshooting determined that conductors A9, A10, A13 and A14
were shorted together
The insulation integrity between the remaining
conductors was not determined prior to returning the penetration module
to service.
The licensee has experienced many failures of control
penetrations and has, on a limited number of these, experienced an
apparent propagation of the insulation breakdown to adjacent conductors
-within the penetration. Since power to stationary and movable gripper
coils for four control rods continue . to be supplied through the
degraded penetration, repetition of the rod drop event is considered
possible without additional testing and/or evaluation.
Corporate
levels of management were aware that the rod drop event could recur and
- that engineering judgement was used to delay corrective action until
the next refueling outage when the penetration module is scheduled to
be replaced.
Licensee representatives stated that the probability of
another rod drop event would not decrease if the remaining wires in
module A were re-routed to spare conductors in undamaged modules. They
based this on experience with previous penetration failures which
indicated that the failures were due to a complete rapid breakdown of
insulation ar.d not a progressive insulation degradation that could be
trended to predict failure.
Discussion with regional personnel concerning the propriety of
restarting the unit without checking conductors adjacent to those which
had failed indicates that sufficient technical basis existed.
With respect to MWR 114481, the following areas were inspected with
satisfactory results.
Qualification and training of maintenance personnel
Maintenance history records
Measuring and Test Equipment (M&TE) program implementation
Parts and materials identification
Consideration
for radiological,
temperature,
pressure
and:
electrical hazards
Provisions for fire protection, cleanliness and housekeeping
-Reportability in accordance with 10 CFR 50.73
LER 85-12 was reviewed for completeness regarding the rod drop event.
The LER was misleading in that it stated that the wires to the dropped
rods were re wired to a different module whereas one of the rods was
actually re-wired to spare conductors in the same faulted module. The
LER also did not address the corrective action taken to preclude
recurrence of the event.
- - .
- .
--
.
--
.
,.
_
__ . _ _ _ _
-
_ _ _ _ - _ _ _
.
_ _ _ _ _ _ _ _ _ - _ - _ _
_ - _ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ _
_
r
'
...
,
7
i
c.
Additional MWR Reviews
The following MWRs were reviewed with no further discrepancies noted:
I
WR 114489 control room emergency pressurization units (common)
WR 115624 "A" feed regulating valve (Unit 2)
WR'114483 "A" steam generator LI-476 (Unit 1)
- ~
.-
MWR 112043 MSIV limit switches (Unit 1)
- -
MWR 94322 on replacement of FCV122 and associated piping (Unit 1)
E
'
- WR 111823 containment auxiliary hatch (Unit 1)
WR 114703 Loop 3 Tavg (Unit 1)
.MWR 114562 pressurizer level (Unit 2)
WR 114473 RCS loop Delta-T (Unit 1)
d.
Machinery' History Records
Maintenance history records for the equipment indicated above was
.
reviewed and verified to be properly stored as quality assurance
records. Document retrieval is . facilitated by use of the computerized
data management system which can be searched by the equipments TPNS
number. This TPNS number is entered in block 2 of the MWR. The plant
performance group is tasked with detection of repetitive equipment
failures, however this area was not inspected due to time limitations.
,
6.
Preventative Maintenance
The inspector reviewed the implementation of the preventive maintenance
f
program for selected c.xponcats in the Compressed Air System and the 120
volt Vital Instrumen'. . Power System.
Vendor manuals and plant maintenance
procedures were rev ewed to verify. that critical components within each
system were' provided periodic preventive maintenance pursuant to vendor
'
recommendations. Within the areas inspected, the inspector identified the
following concerns:
a.
Compressed Air System Pressure Switches
'
FSAR section 9.3.1.5 states that the following . pressure . switches
located in the system allow for an order of priority in removal of
various compressed air loads in the event of a system failure:
Actuation
Point
Function
80 psig decreasing manual reset
Closes N1P19V901; isolates
service air' header
70 psig decreasing manual reset
' Opens N1P19V902; bypasses'
f
air dryers and filters
55 psig decreasing manual reset
Closes N1P19V904; isolates
~
nonessential air header
!
Y
. ..
--
-
-
2
. . . - - . -
- - -
.
,
_
_
_
_____ _
. _ _ _ _
,
..
,
8
45 psig decreasing manual reset
Closes N1P19V903; isolates
essential air header
The .FSAR does not commit to a periodic calibration of these pressure
switches nor does the licensee provide periodic calibrations of the
switches.
The inspector noted that due to the functions of pressure
switches being referenced in the FSAR, periodic calibration should be
provided.
The
licensee = concurred.
Incorporation of periodic
calibration checks of the above pressure switches will be an inspector
followup item (348, 364/85-40-03).
,
b.
5 KVA and 7.5 KVA" Inverters
The- 5 KVA and the 7.5 KVA inverters contain four breakers within the
inverter cabinet. These breakers are the AC input breaker, the AC
output breaker, the battery disconnect breaker, and the DC input
breaker. The inspector noted that the licensee's periodic maintenance
program did not address the functional checking of these breakers. The
' -
licensee concurred.
The vendor mantal on the inverters strongly recommends the establish-
ment of a periodic cleaning schedule of the inverter's rectifier
assembly and transformer to remove accumulated grime and dust to
prevent these parts from operating -at excessive temperatures.
Currently, the licensee's preventive maintenance program on these
inverters does not specify periodic cleaning of these components.
Pending the incorporation of the above items into the preventive
maintenance program, this will be identified as an inspector followup
item (348, 364/85-40-04).
Within the area of preventive maintenance program implementation, no
violations or deviations were identified.
,
-
.
.
.
.
.
.
.