ML20137R314

Insp Repts 50-348/85-40 & 50-364/85-40 on 850930-1004. Violation Noted:Failure to Follow Procedures for Continuity Checks of CRD Mechanism Cables & Coils

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: IR 05000348/1985040 ML20137R149 ML20137R295 ML20137R314
References
50-348-85-40, 50-364-85-40, NUDOCS 8512050473
Download: ML20137R314 (9)

See also: IR 05000348/1985040

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UNITED STATES

, .pjke Rf!g'o NUCLEAR REIULATORY COMMISSION

[ ~, REGION 11

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.j 101 MARIETTA STREET.N.W.

ATL ANT A, GEORGI A 30323

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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.: NPF-2 and NPF-8

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

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./- Date Signed

Approved by:

B.

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T.' Debs, Acting Section Chief

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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

PDR ADOCK 05000348

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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

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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

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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~ FCV-479, FCV-489 and FCV-499. FNP-1-STP-256.~15 is utilized to obtain

the stroke times of the feedwater flow control valves necessary to

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

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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

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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

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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

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' 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

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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.

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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).

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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),

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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.

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c. Additional MWR Reviews

The following MWRs were reviewed with no further discrepancies noted:

WR 114489 control room emergency pressurization units (common) I

WR 115624 "A" feed regulating valve (Unit 2)

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.- WR'114483 "A" steam generator LI-476 (Unit 1)

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MWR 112043 MSIV limit switches (Unit 1)

MWR 94322 on replacement of FCV122 and associated piping (Unit 1)

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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

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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.

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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

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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  !

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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.

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