ML20138J475
| ML20138J475 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/07/1985 |
| From: | Architzel R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8512170530 | |
| Download: ML20138J475 (11) | |
Text
-
t ,'
T&ll j.
o
}/ - I
~
/
Docket No. 50-245-M8b NOV 7 1985 MEMORANDUM FOR: File
- c. FROM: Ralph E. Architzel, Senior Inspection Specialist Licensing Section Quality Assurance Branch Division of Quality Assurance, Vendor, and Technical Training Center Programs
./ Office of Inspection and Enforcement
SUBJECT:
LICENSEE NOTES FOR FORT CALHOUN OUTAGE DESIGN INSPECTION INTERIM STATUS BRIEFING On October 17, 1985, following a telephone conversation with DI end DQAVT, the licensee sent the attached notes to IE for review. The stated .urpose f was to ensure that Omaha Public Power District (0 PPD) had correctly u1derstood the issues presented to them during the interim status briefing for the outage dasign inspection, held on October 8.1985. The licensee wanted a review of these notes by the NRC due to the large number of items involved and a concern regarding the delay involved in waiting to receive the official inspection report from the NRC. The licensee did not want to delay initiation of corrective actions pending receipt of the official report.
DQAVT reviewed the notes and informed OPPD in a telephone call initiated by the licensee on October 22,1985 (J. Fisicaro to R. Architzel) that the notes were a fairly accurate representation of the status briefing. The licensee was inforded that for unresolved item A.6, error in the Technical Specification
. basis, concerning the addition of RCP component cooling water heat load to the CCW system post-LOCA, the more significant concern was the capability of the CCW system to remove sufficient heat being supplied by the containment coolers and the licensee's approved solution of having the operators secure one of the four coolers if all start following a LOCA.
j Ra ph E. Architzel
, Licensing Section Quality Assurance Branch Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement
Enclosure:
l ,, Interim Status Briefing l
l 8512170530 851107
!~
, . _ . - ,- ~ "
Distribution:
QAB Reading JLMilhoan, IE '
RArchitzel, IE PDR LPDR Resident Inspector ETourigni, ORB 3, NRR EButcher, ORB 3, NRR MPhillips, RIV ,
t gat +8 )
S N
($
/
QAB:)QAVT:IE QAB: QAVT:IE 0A :IE :
'DQAVT:IE RArchitzel JLMi can GT krum BKGrimes 10/J'//85 10p /85 10 85 10/'5//85 R B: :IE RC :D .IE :I :I s RHe an JPa ow R 11 e J aylor 4 1 1 1/ 85 0/ 85
/ 402 402 536 4466
., 2,0/17/85 10:51 OPPD JONIS ST. NO.006 001
<< . r ,
b y h 4. r s
&A 99 A/0/h L1C.85-462 Interim Status Briefing Attendees:
NRC J' . E. Konklin, Chief. Special Programs Section t Brian Grimes, Director Division of Q.A., Vendor and Technical Training Office of Inspection and Enforement J. L. M11hoan, Chief, Licensing Section, Q.A. Branch J. L. Barker, Tem Leader, outage Inspections M. E. Murphy, Pro,fect Inspector, Region IV R. Architzel, Tem Leader A. H. Saunders, Reactor Engineer R. L. Lloyd, Reactor Engineer G. Overbeck, Mechanical System A. V. DuBouchet, Mechanical Components L. Stanley, Instrument and Controls ,
G. Morris, Electrical W. K. Shin. Observer, Nuclear Safety Center, Korea OPP _D W. C. Jones, Y. P. Production !
D. D. Wittke, V. P. Engineering R. L. Andrews, Division Manager, Nuclear Production J. K. Gasper, Manager, Admin'straive Services K. J. Morris, Manager. Quality Assurance W. G. Gates Manager, Fort Calhoun Station R. L. Jaworski, Section Manager, Technical Services P. M. Surber, Section Manager, GSE J. J. Fisicaro, Supervisor, Nuclear Regulator and Industrial Affairs M. E. Eidem, Manager, GSE Mechantal Engineering S. K. Gambhir, Manager, GSE Electrical & Nuclear Engineering T. L. Patterson, Manager, Technical Support Mr. Architzel introduced the summary of findings by the discipline inspectors by, stating three classification of findings.
- 1. A number of design problems were identified.
, 2. 10 CFR 50-59 review discrepancies of a programatic type.
- 3. Discrepancies in meeting commitments.
He said that sthe tem did not anticipate that original design basis domments would not be available. The search for documents during the inspection caused additional impact on the GSE Staff.
P i
L
/f
mrtrwt-e; wezr-- a;9t# MaM-$wit.
' ~ ~
NO.006
. 002 A. Mechanical Systes - G. Overbeck, NRC Inspector.
The inspection addressed modifications planned for installation during the outage. Review of capleted modifications were added to identify if the problens observed were pervasive or generic. The fbliowf ng concerns were identified:
- 1. Engineering input into post installation testing was inadequate. '
The following are examples of inadequate test procedures. l t
NRC Concern
\
- a. MR-83-158. Testing did not verify the function of the check l valve or the capability of the accumulator to close the ;
val ve.
NRC Concern
- b. MR-81-218. Installation and test procedures did not test the function of the check valve. HCV-438B A 438D.
- 2. Seisnic requirments are not adequately addressed in design pack-ages.
MRC Concern
- a. ML-83-158. The design documents do not reference the generic routing and spacing procedures for seismic analysis.
N_RC_ Concern
- b. m-83-158. purchase Orders do not require sef smic analysis of valves.
NRC Concern
- 3. Design verificatian is required at site acceptance and not at design completion. GSE procedures B-2 requires design verification at design cepletion. Procedure G-21 does not address design verifi-cation delaying design verification until site acceptance. This is not consistent with good design practice.
- 4. Design verification is not conducted in a complete and detailed manner.
NRC Concern
- a. E-83-158. Third Party Review of design did not discover items ta a 2b. The failure to find the above problems is prooted by an over reliance on check lists. '
l
emse) wbs tww mEs sT. NO.006 003' j
WRC Concern
- b. m-81-215. Third Party Review of design did not address the following: The procurement specification for the check valves did not indicate that Third Party Review wa s pe r-formed. Di screpancies in calculations. Inadequate post installation testin; was not detected by checks and verifica-tion. Seismic qua'ification of the new valve operator was not done in accordance with 10 CFR 50, Appendix B.
NRC Concern
- 5. Incorrect or inapproptrate documents were used for design input.
OPPD procedures do not require that the source of design input be identified or controlled. The plant systen descriptions are not maintained current but are used for design i nput. The USAR is controlled but updates can lag for a ye ar. Engineers are not informed of impending changes to the USAR. The USAR is not suffi-cient as the sole source for design i np uts. Calculations are nnt maintained as living design documents. Calculations are prepared and filed with the modt fication packages. As such, thqy are not readily retrievable.
NRC Concer_n
- 6. Unresolved iten. Safety Analysis.relded to MR-81-218.
The RC pump seal cooling loads was added to the component cooling water systen. This apparently: reduced the margin of safety. The matter was not considered an unraviewed safety question.
- 8. Mechanical Components - Dr. A. V. DuBouchet, NRC Inspector Dr. DuBouchet's inspection resulted in the identification of eleven defielencies in three categories. The categories were 1) lack of reference to the design basis, 2) u:e of uncontrolled design data, 3) deficiencies in the initial design basis.
- 1. The following are examples of inadequate reference to design basis !
documents. I NRC Concern
- a. % 83-158. The de sign did not reference the generic l analysis for support of 3/8" diameter air tubi ng. Hilti l bolt spacing for accumulator support us not adequa tely '
specified. Does not conform to USAR, Appendix F.
NRC Concern
- b. *-84-162. Thermal loads we re not considered in stress calculations although the DBA temperature is 288F. The conbination of the vertical and horizontal sef snic forces in the transverse direction of the horizontal angle was not considered. The duct may be inadequately designed. The new support is to be painted instead of galvanized like the existing supports.
3
7 asun%> mW3 EMORf3 @T. NO.006 004 l NRC Concern
- c. 4 092. The nozzle dams were identified as CQE but the speciffcation did not require seismic analysis. This wes ;
not in accordance with USAR Appendix F.
1 NRC Concern
- d. During a site visit it was observed that junction box for YCV-10458 had a unistrut support connected to condui t.
4 Seimic analysis was not available to verify the present configuration. This was not in accordance with USAR,
- Appendix F.
NRC Concern
- e. E-81-127. A walkdown of the auxiliary feedwater systa by Gilbert Commonwealth revealed that YCV-10458 appeared to be
-, unstable. Thqy recommended that the existing rod restraint be replaced by a strut and that e detailed analysf s of the AFV systs be performed. GSE performed the analysis. As built drawings did not show the operator or the rod res traint. Vendor drwings of YCV-1045B could not be found.
The restraint was not modeled. There are no records of pipe stress of loads; no reactions of loads. The supports appear to be overloaded. The OPPD computer runs are not referenced and therefo re not audi table. The valve integrfiy is questionable. The valve is not seismically qualified.
NRC _C_o_ncern
. f. m 83. The sef snic analysis to qualify the supports for the containment pressure switches did not reference the drmings where the physical characteristics of the switch are specified. The Hoffman Junction Box was not included in the calculations and, therefore, was not qualified.
- 2. The following are examples of the use of uncontrolled design data.
WRC Concern
- a. 79-14 piping analysis.
The original design taperature data could not be found to use in the piping analysis. Technical Services transmitted a set of P&ID's to GSE wi th tesperatures and pressires
- marked on the drawings. The temperature data was provided to the A/E for use in the piping analysis. The tenperatures furnished the A/E by GSE are not contained in a controlled document. This is a violation of ANSI 45-2.11 and the QA manual.
10/17/85 10:55 OPPD JOtES ST. NO.006 005 i .
M C Concern
- b. . piping specification.
The balance of plant piping was procured and installed under Contract 763. The contract is not controlled or auditable.
Howeve r, specification H-1 fran Contract 763 is referenced on design documents (PSID's) as the design specification for pf pt ng. In the absence of technical speci fications, 763 remains the defining uncontrolled design document dich violates the QA manual .
- 3. The following are exmples of deficiencies in the original design ba si s.
NRC Concern
- a. Small bore piping was installed in accordance wtth a '
- t procedure developed by the installation contractor. The '
criteria is based on 6 Hz horizontal and 18 Hz vertical .
The USAR, Appendix F sets the criteria fbr any piping penetrating the contaf tsment or supported from the contair>. ,
i ment at 12 Hz horizontal and 18 Hz vertical. WPD should confirm that all small bore piping confonns to USAR, Appendix F.
NRC Concern
- b. Seimic qualification of valves in Class I piping. Contract 763 procured the bulk of valves in Class I pipi ng. No sefsnic requirments were stated in the contract. The USAR requires that all equipment associated with Class I piping be qualified.
C. Electrical - G. Morris, RC Inspector The electrical inspection examt ned m-FC-84-119, 2-FC-85-25. Only final design packages were reviewed. m-FC-85-125 and The construction packages for these jobs were not complete.
- 1. E-84-119.
NRC Concern
- a. The inverters were not sized by analysis but by a review of operating records. The size needs to be verified. Because of the non-safety related loads which are being reoved fran safety related inverters the size may be adequate.
NRC Concern '
- b. 200 amp ba ttery chargers were being replaced by 400 enp cha rgers. The current is 1 fatted at 125% of design load which requires bigger cables. Because of (OPPD) checker's comments, three cables were rerouted and two othe rs increased in size. The team is concerned that no OPPD guide is available for cable sizing.
1047/85 10:56 OPPD JOES ST. NO.006 006
. NRC Concern
- c. Two battery cells are being reoved to reduce battery voltage. The battery size has been recal:ulated using the US AR load profiles developed in 1979. Neither the checker nor the reviewer questioned the use of 1979 load profiles which may have changed. Also, in the 1979 load profiles no justification was included in the calculations for excluding some of the loads, such as trip currents for 4160V and 480V breakers.
NRC Concern
- d. 1979 battery size calculations were not checked by 0 PPD nor was a Third Party Review of the design package completed per GSE's current procedures.
NRC Concern i
- e. The battery charger circuit breaker is sized to trip at 400 amps. If the chargers are connected to a completely di scharged ba ttery, the chargers will go to current limit and supply a maximum of 500 amp. This in turn may trip the 400 amp breaker; both breakers need to be coordinated.
NRC Concern
- 2. m-85-25, Fire wraping of electrical cables.
The cable derating factor used by 0 PPD was calculated by the vendor using an unve rified conputer progra. Empirical results do not substantiate the computer in forination. OPPD did not attempt to verify the conputer progran.
- D. Instrument and Controls - L. Stanley, NRC Inspector The instrument and control inspection reviewed fourteen design packages.
The findings identiff e'd two general themes. 1) inadequate recoptition and identification of technical requirments end. 2) failure to follow procedural requirements.
- 1. The following are examples of inadequate recognition and identifica-tion of technical requirements.
NRC Concern
- a. M-84-074A, limit Swi tch Fuse Coordi na tion. Some solenoid valves have unqualified limit switches. The solution to use a smaller fuse in series with a larger fuse ~ was based on t
assumptions that were not adequately document'ed. A letter received from the vendor has confinned that the design is adequa te. The vendor has also committed to vertfy this by testing .
6 /
-,-,r r ,-,- , - , ,,-,a ~ ,.------,,,,,,---n-- ---,,--,,,_-_,,,m--- -
,,-rn.,w,_,,,,,,,,,,_nm,,,_-w,,-vma,w,---._,,-m,,v-n,, ,,w_am_-
._ g . _ . _ . _ _ _ _ ,
I . .
. i NRC Concern
- b. E-77-40, Undervoltage Relays. During a field visit it was i
observed that the installation of the under voltage relays ;
modification did not maintain pysical separation of 6" '
inside panels. This does not conform to USAR Section 7.3.
NRC Concern,
- c. E-81-102, ESF Bypass Switches.
No justification was provided for the lack of separation between Cla ss 1E and non-Class 1E wiring in the design package. The design package did not include an analysts to support the assurr.; tion that brafded wire would be sufficient to provide the separation. This does not confom to USAR Section 7.3.
NRC Concern
- d. 2 102, Keylock Switch.
The design package did not address the type of keys to be used wi th the keylock swi tches provided modification.
'o r this NRC Concern _
- e. E-84-46, High Power Rate of Change Trip Alarm.
Conflicting requirements pertaininfi to the trip bypass annun-ciation were not addressed by eng neering. The requirenents
! of IEEE 279 conflicts with the requirements of NUREG 3217
! but there was no justification in the design package regard-ing which requirement should prevail. A solution to this problem was identified by GSE Electrical on October 7,1985, which may eliminate thfs problem.
NRC Concern
- f. MR-83-109, ERF Computer.
4 Requirment to apply 125 AC/DC on the output tenninals of the electrical isolators was not specified in the purchase documents. Florida Power and Light has performed testing to confim that the isolators do comply with this requirement.
2.
The following are examples of failure to follow procedural require-monts.
NRC Concern ,
- s. M-82-17 8. DPI's were added to the filters in the Auxiliary
< Building heating and ventilation system and the nuclear detector well cooling un i t. The engineer did not request ;
sepias of drawings M-1 and M-2. This was not in accordance wi th GSE Procedure A-9.
w ar a;#srwasrwr. KsR's m NRC Concern
- b.64-104, Delta T Power Loop Analysis.
050R 85-83 did not identify whether safety related or CQE.
The fomuula used was not identified. The calculations were not third party reviewed.
NRC Concern
- c. The battery roon fire hazard analysis did not include the masonite fuse block enclosure in the combustible natorial totals . The Ofstrict should confirm that this is not a l significant fire hazard.
E. Compliance with 10 CFR 50.59. R. Archtitel & A. Saunders, NRC Inspectors !
NRC Concern
- 1. m-83-158, An emergency modification to YCV-1045 A 4 8 performed in l 1980 changed the failure mode of the valves from failed close to failed open. The safety evaluation detemined that the modification l resulted in an unresolved safety issue. Technical Services !
recognized that the requirenents were not satisfied. Procedures '
were changed to require manual closure of the valves. The change was not identified in the FSAR. The unresolved safety issue wa s closed based on work that was not completed.
NRC Concern
- 2. E-84-119 The unresolved safety issue that the irwerter modifica-tion may change the Technical Specifications has not been addressed.
10 CFR 50.59 Paragraph 1, requires that for the modi fications involving changes to Technical Specifications WRC approval is required prior to implementing the modi fication. For this modification the safety evaluation performed by the District concluded that in order ot maintain consistency with tbs existing USAR and Technical Specification. the bypass mode must be defined as inverter failure per Technical Specification 2-7 (g). In tesn's l opinion, this requires a Technical Specification change. 1 NOTE: No bypass provisions were available earlier.
NRC Concern
- 3. In all cases a safety analysis in accordance with 10 CFR 50.59 had I not been completed for non-CQE. Examples are: ,
2 175 Feedwater Regulator MR-85-008 Boric Acid Addition M-748-57 ~ Power Systen Stabilizer '
m-83-90 L.P. Feedwater Heater Replacement l I
1 17 i
- e e>#srmAssnsnr. 0@.6% 009 NRC Concern
- 4. In all cases a safety analysis in accordance wtth 10 CFR 50.59 had not been completed prfor to emergency modifications. For example:
MR-84-84 D.C. Ground for CQE Valves M-83-129 Diesel Generator
' M-83-152 Speed Sensing Power Supply M-83-07 Load Cell Replacement, HF-1 l
Construction safety evaluations are not considered an adequate substitute for engineering safety evaluations.
NRC Concern
- 5. After-the-fact de sign packages to document closecut of emergeny modifications are not completed in a timely manner. One design package was coupleted 50 months af ter the energency modification.
The shortest time for completion was eleven months. Four modifica-tions with coupletions ranging from 11 to 33 months still do not have final design packages. The tracking system for the emergency modi fications is satisfactory but the problem requires management attention.
NRC Concern
- 6. There is a lack of documentation of the design input used for modification packages. It is not clear what design input was used for engineering. The overall lack of detail incorporated in the design package results in insufficient information for the check and verification process.
F. Overall Comments - R. Architrel, NRC Inspector WRC Concern i 1.
10 CFR 50.59 is not always followed in acconplishing safety evalua-tions.
[
WRC Concern l 2. Design input is lacking in the design packages, i
- NRC Co_ncern i 3. There is no original design documentation.
NRC Concern l
- 4. GSE procedures are adequate but the implementation of the procedures is loosely controlled.
i NRC_ Concern
! 5. There is a failure to address seismic analysis.
_ __ . . ___ . . .