ML20141F378
| ML20141F378 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/04/1986 |
| From: | Christensen H, Debs B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20141F370 | List: |
| References | |
| 50-413-86-05, 50-413-86-5, 50-414-86-07, 50-414-86-7, NUDOCS 8604220535 | |
| Download: ML20141F378 (16) | |
See also: IR 05000413/1986005
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET N.W.
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ATL ANTA. GEORGI A 30323
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Report Nos.: 50-413/86-05 and 50-414/86-07
Licensee: Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.:
50-413 and 50-414
License Nos.: NPF-35 and CPPR-117
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Facility Name:
Catawba 1 and 2
Inspection Conducted: January 6-10, 1986
Inspectors:
N
R. Christensen, Team Leader
- at'e Signed
C. Brooks
R. Pierson
C. Caldwell
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P. Moore
Approved by:
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h/E N
B. Debs, A6 ting Section Chief /j/
Date< Signed
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Operational Programs Section g
Division of Reactor Safety
SUMMARY
-Scope: This routine, announced inspection entailed 175 inspector-hours on site
in ~ the areas of Surveillance -Testing, Maintenance Activities, and Operational
Activities for unit two, and the close out of-selected open inspection items for
unit one.
Results:
Two violations were identified.
The Violation (413/86-05-05), on
Hydrogen Skimmer Fan Isolation Valves not being environmentally qualified in
accordance with 10 CFR 50.49 is not being sited in the Notice of Violation.
It
is under consideration for proposed enforcement policy and will be sited in
separate correspondence.
8604220535 860407
ADOCK 05000413
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
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- J. W. Hampton, Station Manager
- L. N. Adams, Quality Assurance
- H. B. Barron, Superintendent of Operations
- W. F. Beaver, Performance
- T. B. Bright, Engineering Manager, Construction and Maintenance Department
- B. F. Caldwell, Superintendent Station Services
- E. M. Couch, Manager, Construction and Maintenance Department
- J. W. Cox, Superintendent Technical Services
- C. L. Hartzell, Compliance Engineer
- R. A. Jones, Test Engineer
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- J. Knuti, Operations Engineer
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- P. G. LeRoy, Licensing Engineer
- W. W. McCollough, Mechanical Maintenance
- W. R. McCollum, Integrated Scheduling
- J. F. McKcown, Mechanical Maintenance
- D. B. O'Brien, Construction Technical Services
- A. Pauly, Mechanical Maintenance
- C. L. Ray, Principal Engineer
- D. Rogers, IAE Maintenance
- F. P. Schiffley, Compliance, Licensing Engineer
- G. Smith, Superintendent Maintenance
- J. M. Stackley, IAE Maintenance
- J. W. Willis, Quality Assurance
,
Other licensee employees contacted included engineers, technicians,
operators, mechanics, and office personnel.
NRC Resident Inspectors
- K. VanDoorn, Senior Resident Inspector
P. Skinner, Senior Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on January 10, 1986, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings listed
below. No dissenting comments were received from the licensee.
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Inspector Followup Item 413/86-05-01; Station Directive 3.2.2, Develop-
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ment and Conduct of the Periodic Testing Program, the procedure will be
revised to require notification of the Shift Supervisor when surveil-
lance tests are not completed within the allowed Technical Specifica-
tion interval.
(pcragraph 3)
Inspector Followup Item 413/86-05-02, 414/86-07-01; Discrepancies noted
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between the Catawba Periodic Test (CPT) Program data base and Technical
Specification
required
surveillance
frequencies
requirements.
(paragraph 6)
Inspector Followup Item 413/86-05-03,414/86-07-02, Various maintenance
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procedure deficiencies.
(paragraph 8a, 8b)
Violation 413/86-05-04; Two examples of inadequate maintenance
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procedures; (1) IP/0/A/3820/01, Limitorque Valve Operator Corrective
Maintenance, incorrectly required the use of Unirex N2 grease.
(2) The
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Catawba Lubrication Manual failed to specify what type of lubricant is
required for Limitorque valve operator Models SMB-00 and SMB-000, with
serial numbers below 295810 and Models SMB-0, SMB1, SMB2, SMB3, and
SMB4 with serial numbers below #302262.
(paragraph 8a)
Violation 413/86-05-05, Hydrogen Skimmer Fan Isolation Valves IVX1A and
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IVX2B not environmentally cualified in accordance with 10 CFR 50.49.
(paragraph 8a)
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Inspector Followup Item 413/86-05-06, 414/86-07-03; Design Engineering
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Review and Implementation of Environmental Qualification Maintenance
Program.
(paragraph 8a).
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Inspector Followup Item 413/86-05-07, 414/86-07-04; Concerns satellite
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document control station updating.
(paragraph 8b)
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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
a.
Unresolved Item (URI) 413/85-12-01; Concerns the lack of full adherence
to Station Directive (SD) 3.2.2 - Closed - Catawba Performance and
Compliance now receive attachments showing tests were not performed
within the time allotted by the program and the surveillance tracking
mechanism has been revised to handle specialized areas such as mode
change and surveillances dependent on Effective Full Power Days.
Additionally, the licensee stated that SD 3.2.2 would be revised to
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require notification of the Shif t Supervisor when a test is not
completed within the allowed Technical Specification (TS) interval, if
exceeding the TS interval makes the system inoperable.
The licensee
was informed that the procedure revision will be an Inspector Followup
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Item (413/86-05-01).
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URI 413/85-12-03, Concerns the lack of formal feed back of operational
experience training and documentation to maintenance personnel -
Closed - By memorandum dated April 5,1985, the Maintenance Engineer
developed a required reading routing form which documents the feedback
of operational experience training. The Maintenance Engineer maintains
a log of all routing packages sent out to the department and all
packages are required to be reviewed and returned within sixty (60)
days.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Operating Procedures (42450)
The inspector reviewed the controlling documents for writing, reviewing,
implementing, and changing procedures. Additionally, the inspector reviewed
selected procedures, drawings., and logs to determine if they were being kept
in accordance with the controlling documents and also observed operations
personnel in their use of these procedures.
The following operating
procedures were reviewed.
OP/2/A/6100/01, Controlling Procedure for Unit Startup, Revision 0.
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OP/2/A/6350/01, Diesel Generator Operations, Revision 11.
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OP/2/A/6100/06, Establishing System Operability During Initial Unit
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Startup, Revision 0
The inspector noted that tha procedures followed the recommended format, the
change records were updated as required, and the procedure had the
appropriate review and approval signatures.
The inspector observed a Unit 2 nuclear equipment operator perform
OP/2/A/6350/01, Diesel Generator Operations, enclosure 4.6, D/G 2A Checklist
for ESF Actuation, enclosure 4.10, local Diesel Startup and Shutdown and
enclosure 4.18, Diesel Generator Cylinder Head Leak Detection.
The
inspector noted the following:
The operator was very familiar with the procedure and had no problem
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using it.
Additionally, the operator's use of the procedure was in
accordance with Catawba Nuclear Station Directive 4.2.1, Development,
Approval and Use of Station Procedures.
Enclosure 4.6, step 8.,
states, Check D/G Engine Jacket Water Standpipe
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Water Level to be greater than or equal to 1 on level indication (as
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indicated by gauge located on standpipe). The gauge is located at the
top of the standpipe, approximately 40 feet above the operators
location.
The operator had to climb up a temporary ladder which was
not very secure to verify the reading. This is considered a personnel
safety hazard and should be evaluated.
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Enclosure 4.18, Initial Conditions Section 1, is lacking step 1.3,
which is the step used by the operator to document which Diesel
Generator is having the Cylinder Head Leak Detection Test performed.
Unit one enclosure 4.18 has this documentation requirement.
The operator referred to the Diesel Generator logbook as required by
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the Diesel Generator Operating Procedure.
This logbook appeared to be
used and maintained in accordance with OMP 2-28, Diesel Generator
Logbook.
6.
Surveillance Requirements
a.
The inspector reviewed section 3/4.3, Instrumentation of the Catawba
Draf t Technical Specifications (TS) for Units 1 and 2.
This section of
the draft was compared to the Unit 1 Technical Specifications and no
discrepancies were found. The inspector also compared the Instrumenta-
tion section of the draft with the surveillance requirements listed in
the Catawba Nuclear Station Unit 2 Surveillance Report.
This is a
computerized printout of all surveillance requirements.
Included on
this report is the frequency, applicable procedure number, responsible
section, and Standing Work Request (SWR) for each surveillance
requirement.
The inspector identified several discrepancies between
the Draft Technical Specifications surveillance requirements and the
Surveillance Report. These discrepancies are as follows:
4.3.1.1.16A - The Surveillance Report requires a weekly surveil-
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lance for the Operations section which is not required by the TS.
This discrepancy is also applicable to Unit 1.
4. 3. 2.1.10A -
The TS have an 18 month surveillance for the
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Transmission section that is not contained in the Surveillance
Report. This discrepancy is also applicable to Unit 1.
4.3.2.1.10B -
The TS have an 18 month surveillance for the
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Transmission section that is not contained in the Surveillance
Report. This discrepancy is also applicable to Unit 1.
4.3.2.1.11B -
The Surveillance Report requires a monthly
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surveillance for the Transmission section which is not required by
the TS.
4.3.2.1.15C -
The TS have a monthly and an eighteen month
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surveillance for the Transmission section.
However, the
Surveillance Report only lists two monthly surveillances.
This
discrepancy is also applicable to Unit 1.
4.3.3.1B through 4.3.3.15 - No titles or descriptions are listed
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in the Surveillance Report for the applicable surveillance
requirements.
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The TS have a monthly surveillance for the
4.3.3.3.1B
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Operations section that is not included in the Surveillance
Report. This discrepancy is also applicable to Unit 1.
4.3.3.9A - The TS have a daily and a weekly surveillance for the
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Operations section.
However, the Surveillance Report only lists
an "as required" surveillance.
This discrepancy is also
applicable to Unit 1.
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4.3.3.3.1 through 4.3.3.3.4 -
The TS have an eighteen month
surveillance that is not included in the Surveillance Report.
This discrepancy is also applicable to Unit 1.
The inspector noted that, even though these discrepancies exist, the
licensee has all TS surveillance requirements included in a procedure
for Units 1 and 2.
In addition, these procedures specify the proper
frequency given in the TS.
Thus, the licensee has provisions to
conduct all Instrumentation Surveillance Requirements although their
Surveillance Report has some administrative discrepancies.
These
discrepancies were identified to the Performance section which is
responsible for the Surveillance Report.
Followup of corrective actions for the discrepancies identified above
is Inspector Followup Items (413/86-05-02, 414/86-07-01)
b.
The inspector reviewed implementation of the requirements of Technical Specification 4.3.2.1 from Catawba Unit 2 Draft Technical Specifica-
tions which states, in part, that each ESFAS instrumentation channel and
interlock and the automatic actuation logic and relays shall be
demonstrated OPERABLE by performance of the Engineered Safety Features
Actuation System Instrumentation Surveillance Requirements specified in
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Table 4.3.2 of Technical Specifications.
These surveillance require-
ments were compared to the Catawba Nuclear Station Unit 2 Surveillance
Report to determine if required surveillances were scheduled and
performed as required.
A sampling of these procedures was reviewed to
determine if necessary requirements to perform the Technical
Specification Surveillances were incorporated.
Of the procedures reviewed, necessary requirements appeared to be
adequately implemented.
In addition, these procedures, as well as some
others, were reviewed for administrative sufficiency and technical
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validity.
This review consisted of in-office analysis of procedures
discussion of procedure content with licensee personnel, and procedure
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walk-through with licensee personnel.
Mode 1 Periodic Surveillance Items, PT/2/A/4600/02A, was reviewed, in
part, with the licensee. Control Room operators appeared knowledgeable
about the procedure and its requirements.
No discrepancies were noted.
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Routine Test Procedure, Type ITE 27H Relay, PT/0/A/4971/06/R, was
reviewed with a licensee technician.
The technician appeared
knowledgeable concerning the procedure.
The Test Data Sheet could be
improved by ordering the sign-off's in the order that the procedure is
done.
Engineered Safeguards Features Functional Test, TP/2/A/1200/03A, was
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reviewed in part.
No discrepancies were noted.
The Upper Head
Injection System Functional Test, TP/2/A/1200/03B, was reviewed in part
and appeared to be adequate.
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In conjunction with this review it was determined that the test method
should preclude the occurrence of an incorrectly connected pressure
transmitter such as the incident at McGuire Nuclear Station in 1984.
In conjunction with the procedural evaluation of the Upper Head
Injection System, performance of Work Request No. 004229 SWR was
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partially observed.
This work request which was to perform channel
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calibration using IP/2/B/3222/10, Upper Head Injection Surge Tank Level
for 2NILT5700, could not be completed because of apparent air in the
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calibration lines.
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Performance Procedure (42450)
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PT 0/A/4971/10/R Revision 0, Routine Test
Procedure:
ITE 270 Relays
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PT 0/A/4971/06/R Revision 0, Routine Test
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Procedure: Type ITE 27H Relay
PT/0/A/4600/12 Revision 3, Chemistry Periodic Surveillance items
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PT/2/A/4250/02C Revision 0, Turbine Control Valve Movement
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PT/2/A/4600/02A Revision 0, Mode 1 Periodic Surveillance Items
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PT/2/A/4600/03A Revision 0, Monthly Surveillance Items
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The following performance procedures were walked through with licensee.
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PT/2/A/4250/02F Revision 0, Turbine Startup Pressure Switch Alarm Test
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PT/2/A/4250/02B Revision 0. Weekly Main Turbine Valve Movement
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On procedures reviewed and walked through, no deficiencies were noted.
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However, the inspector did note some program enhancements that could improve
the use and understanding of these procedures.
These general notes are as
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follows:
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The inspector found that there is no uniformity in inclusion of the
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Technical Specification Surveillance Requirement Number in the
reference section of the applicable procedures.
Approximately 50% of
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the procedures reviewed referenced a particular surveillance require-
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ment.
The inspector considers that addition of the Surveillance
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Requirement Number will aid licensee personnel in identifying Technical
Specification items and should be included in all procedures if
applicable.
Discussions with the Transmission Section indicated that these
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personnel are knowledgeable of their procedures as evidenced by
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procedure walkthroughs.
However, the inspector noted that the section
personnel were weak in dealing with the Technical Specifications and
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applicable surveillance requirements.
In fact, the inspector had to
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explain where the surveillance requirements originated and how they
are included in the Surveillance Report.
The inspector considers
that the section should receive more training with regards to the
meaning and importance of surveillance requirements and the Technical
Specifications.
The inspector considers that this increased training
would aid the Transmission Section personnel in understanding the
reascris for developing procedures to implement surveillance require-
ments(and the significance of test data that falls outside of Technical
Specification limits.
8.
Maintenance Programs (42451, 35743)
a.
Maintenance Procedures
Maintenance procedures used to comply with Technical Specification 6.8.1 and Regulatory Guide 1.33, Revision 2, February 1978 were
reviewed for format, administrative controls, technical adequacy and
completeness.
Specifically, Appendix A of Regulatory Guide 1.33
requires that maintenance that can affect the performance of safety-
related equipment and should be properly pre-planned and performed in
accordance with written procedures, documented instructions, or
drawings appropriate to the circumatances.
(1) MP/0/A/7150/36, Pressurizer Power Operated Relief Valve Corrective
Maintenance:
Problems were found in this procedure which were
later determined to be generic to all plant maintenance
procedures.
The licensee was aware of these problems and was
correcting them in the periodic 2-year procedure reviews.
These
problems related to a lack of detail in the parts list section of
procedures and on the use of cleaners and lubricants.
Many
procedures specify the use of " approved lubricants" or " approved
cleaners" and problems have developed when attempting to determine
which cleaner or lubricant is approved.
The revised procedures
will clearly specify approved materials.
Although the parts lists
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contained in the procedures are very general, lack part numbers,
and are incomplete, this is compensated for by the work request.
Planners provide a complete computer printout of parts and part
numbers and attach this to the work request.
(2) MP/0/A/7150-38, Pressurizer Safety Valve Corrective Maintenance:
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This procedure specifies the disassembly and reassembly steps for
the Pressurizer Safety Valves. Section 12, Restoration, calls for
resetting and checking of the relief valve setpoint to be
performed in accordance with MP/0/A/7650/37.
MP/0/A/7650/37,
Relief Valve Set Pressure Testing and Adjustment, specifically
prohibits the use of this procedure on Main Steam and Pressurizer
Safety Valves.
Licensee representatives stated that these
procedures were not used since safety valve work is contracted out
to a test laboratory.
After the exit meeting, licensee
representatives stated that this error had been detected by them
during a procedure review, and a draf t revision of the procedure
deleted the inappropriate procedure.
This was not verified and
will remain a follow-up item to assure correction (413/86-05-03,
414/86-07-02).
(3) MP/0/A/7600/55, Limitorque Actuators Type SMB-000 Corrective
Maintenance and MP/0/A/7600/58 Limitorque Actuator Type SMB-00
Corrective Maintenance:
Various problems with these procedures
were noted.
Licensee representatives provided a draft copy of a
revision to these procedures which were in the review and approval
chain which correctly addressed the inspector's concerns.
The
inspector requested a copy of the maintenance procedure for
Limitorque Actuator Type SMB 0 through 5 and found that no
procedure is available.
The licensee reviewed its list of
safety-related valve actuators and found that SMB-1 actuators were
installed in the Nuclear Service Water System, and SMB 3 actuators
were installed in the Safety Injection System. The licensee noted
that the procedure is only required prior to maintenance being
performed on these actuators and speculated that the reason a
procedura does not exist is that these actuators have never been
worked on.
They indicated that a procedure would be developed.
This will be left as another example of inspector followup item
(413/86-05-03,414/86-07-02).
(4) MP/0/A/7150/04, Component Cooling Water Pump Corrective Mainte-
nance: An apparent typographical error was located in step 11.5.6
of this procedure.
The torque values specified for the coupling
bolts are given as 20 ft-lbs on the second pass but are also
provided in a second location.
This second location, on Data
Sheet page 6, gives the second pass torque values as 190 ft-lbs.
This will be left as an Inspector Followup Item pending the
licensee's determination of toe correct torque values (413/
86-05-03,414/86-07-02).
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(5)
IP/0/A/3820/01, Limitorque Valve Operator Corrective Maintenance:
This procedure is for instrumentation and electrical maintenance
work on Limitorque actuators.
IE Information Notice No. 85-22,
Failure of Limitorque Motor-0perated Valves Resulting from
Incorrect Installation of Pinion Gear, was closed out by the
licensee with no action based upon IP/0/A/3820/01 which requires
correct installation of the motor pinion gear.
The invector
reviewed IP/0/A/3820/01 and verified that step 10.1.6 required the
pinion gear to be installed in the correct position; however,
there was no further guidance in the procedure to aid maintenance
personnel i n the determination of the correct orientation.
Drawings that were contained in the procedure did not depict the motor
pinion gear and the referenced Limitorque Maintenance Manual,
Bulletin SMBI-170 also contained inadequate precautions.
A more
recent Limitorque manual, Bulletin SMBI-82A, provides an accurate
detail of the pinion orientation and a caution statement in the
reassembly instructions; however, this procedure was not
referenced in IP/0/A/3820/01 even though it is a controlled
reference manual on site.
Since the type SMB-0 actuator requires
the most caution on pinion gear orientation, the inspector
requested a listing of safety-related SMB-0 actuators.
Licensee
representation stated that although they use SMB-0 actuators in
non-safety-related applications, they do not have any in safety
related use.
The licensee stated that the procedure would, none
the less, be revised to more clearly depict the correct pinion gear
orientation.
This will be left as another example of Inspector
Followup Item (413/86-05-03, 414/86-07-02).
An additional problem was found with IP/0/A/3820/01 in that it
specifies the use of Unirex N2 grease in the main gearcase of
actuators (Steps 10.1.4 and 10.1.11).
This is contrary to the
rrechanical maintenance procedures (MP/0/A/7600/55 and MP/0/A/
7600/58) and the Station Lubrication Manual. Unirex N2 grease has
not been evaluated for compatibility with the greases approved by
the Station or Limitorque Corporation.
The licensee was unable to
determine the source of this error.
This is an example of a
violation against Technical Specification 6.8.1 for inadequate
maintenance procedures
(413/86-05-04).
An additional example of
this violation was found in the Catawba Lubrication Manual.
The
Station Lube Sheet (page 11 of the Valves System) contains the
lubrication type requirements for Limitorque operators.
The lube
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sheet requires Nebula EP0 to be used in Limitorque operators
Models SMB-00 and SMB-000 serial numbers 295810 and higher and
Models SM80, SMB1, SMB2, SMB3 and SMB4 serial numbers 302262 and
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higher.
The lubrication manual does not specify the lubricant
type to be used in operators with serial numbers below those
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specified.
This is critical since Limitorque has stated in
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Bulletin SMBI-82A that the standard lubricant shipped with
actuators below serial number 295810 for SMB-00 and SMB-000 was
Sun Oil Co.
SOEP and that Sun SOEP cannot be mixed with Nebula
EP-0.
Although this information was known by the licensee and a
memorandum from Preoperational Projects to the Manager, Catawba
Nuclear Station dated September 17, 1981 indicated that Catawba
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Maintenance was to use administrative controls to prevent improper
lubrication, the Station Lube Sheet remained inadequate. This is
the second example of Violation 413/85-05-04.
Since various documents indicate that up to three different
greases (Unirex N2, Nebula EP0 and SUN SOEP) may have been used
in Limitorque Valve Actuators, the licensee initiated a review
of maintenance records to determine the potential for mixed,
incompatible grease being installed in safety-related actuators.
An additional review is to be conducted in order to document which
actuators are required to use only Nebula EP0 as a result of the
10 CFR 50.49 environmental qualification requirements and to
substantiate that this qualified grease is indeed installed in
the required actuators.
On the completion of this review, the
inspector was provided an intrastation letter for the Maintenance
Superintendent to the Compliance Engineer, dated January 13, 1986,
stating, no mixing of lubricants was found in safety-related
limitorque actuators.
To avoid the possibility of mixed
lubricants in the future:
(a) procedures will be revised to
reference the Catawba lubrication manual prior to addition of any
lubricant in limitorque actuators, (b) the Catawba lubrication
manual will be revised to reflect the correct lubricant in
limitorque actuators by their serial number.
Additionally, the
inspector was provided a letter dated January 14, 1986, Catawba
Nuclear Station Limitorque Valve Motor Actuators Approved Gearcase
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lubricants, Duke File: CN-1205.19.
This letter stated, it should
be noted here that Limitorque manufactures two levels of environ-
mentally qualified actuators in their SMB/SB/SBD line:
" containment chamber" and "outside containment" actuators.
" Containment chamber" actuator have been applied at Catawba both
inside and outside containment.
"Outside containment" actuators
are applied only outside containment, with the following excep-
tion:
IVX1A, IVX28, 2VX1A, and 2VX2B (These applications have
been justified; reference SNM-1205.02-614).
1,2VX1A and 1,2VX2B
are isolation valves for the Hydrogen Skimmer Fans located inside
containment.
The isolation valve operator is actuated coincident
with the startup of the hydrogen skimer fans, which are started
by the containment spray actuation signal ten minutes after the
containment pressure reaches 3.0 psig on a postulated loss-of-
coolant accident.
CNM-1205.02-614, Duke Power Company Design
Engineering - Mechanical Systems and Equipment Section Engineering
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Justification Report, dated June 15, 1984, based the continued use
of an outside containment actuator inside containment on Design
Basis Event environmental conditions of temperature and radiation
exposure to the motor insulation only.
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10 CFR 50.49, Environmental Qualification of Electric Equipment
Important to Safety for Nuclear Power Plant, section (d), states
in part, the applicant or licensee shall include the following
information for this electric equipment important to safety in a
qualification file:
(1) The performance specifications under conditions existing
during and following design basis accidents.
(2) The voltage, frequency, load, and other electrical
characteristics for which the performance specified in
accordance with paragraph (d)(1) of this section can be
ensured.
(3) The environmental conditions including temperature, pressure,
humidity, radiation, chemicals, and submergence at the
location where the equipment must perform as specified in
accordance with paragraphs (d)(1) and (2) of this section.
Section (e), states in part, the electric equipment qualification
program must include and be based on the following:
(1) Tempera-
ture and pressure,
(2) Humidity,
(3) Chemical
effects,
(4) Radiation,
(5) Aging,
(6) Submergence,
(7) Synergistic
effects,and(8) Margins.
On January 17, 1986, the inspector was provided with additional
information, a letter from Chief Engineer, Mechanical and Nuclear
Division to Manager, Catawba Nuclear Station dated January 17,
1986, the letter addressed the other environmental conditions for
the valve actuators including SUN SOEP grease and the licensee
stated that the information is sufficient to demonstrate that
IVX1A and IVX2B are environmentally qualified in accordance
with 10 CFR 50.49.
The inspector informed the licensee that lack of proper
documentation of the environmental qualification of IVX1A and
IVX2B motor operator, from November 30, 1985, until January 17,
1986, is a violation of 10 CFR 50.49 (VIO 413/86-05-05).
(6) Maintenance of Environmental Qualification of Electrical Equipment
Important to Safety (10 CFR 50.49):
10 CFR 50.49 requires that a
record of the environmental qualification of electric equipment
important to safety must be maintained to permit verification that
each item meets its specified performance requirements when it
must perform its safety function up to the end of its qualified
life.
Implicit in this requirement is that records must be kept
to substantiate that periodic maintenance activities required to
maintain a piece of equipment in its qualified condition have been
performed.
The licensee specifies these periodic maintenance
requirements in the Catawba Nuclear Station Equipment Qualifica-
tion Reference INDEX (EQRI).
Station groups responsible for
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performance of EQRI mandated maintenar,ce have identified
outstanding maintenance activities and alternate actions which
they believe have satisfied the intent of the EQAI.
The station
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requested a Design Engineering Review of these actions on
March 27,1985.
As of January 9,1986, the Design Engineering
Review is incomplete. Although an in-depth review and revision of
the EQRI is in progress by Design Engineering, the potential
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exists that the qualifications of some equipment may have been
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compromised or invalidated due to a failure to maintain the
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equipment in its qualified condition through periodic maintenance
activities.
This item will be left as an Inspector Followup Item
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pending completion of the Design Engineering review and
implementation of corrective actions if necessary (413/86-05-06,
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414/86-07-03).
b.
Preventive Maintenance
The inspector reviewed procedures associated with maintenance
activities on equipment and components employed during plant
operations.
Particular attention was given to the Preventive
Maintenance Department and their program.
This, in turn, led to
procedure reviews in the Instrumentation and Electronics Department as
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well as the Maintenance Department.
Procedure No. PM/IG-048 is the preventive maintenance program for
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the instrument air system dryers.
This is an annual maintenance
program for the refrigerated air dryers. The procedure references
CNM 1213.00-0135 as its technical manual.
This manual was not
available in document control and was found to be superseded by a
drawing, CNM 1210.03-0095, on 8/25/83.
The procedure did not
reflect this change.
The referenced manual, CNM 1213.00-0135 was
found in a satellite document control in the Maintenance Depart-
ment.
Upon review of the manual it was revealed that the drawing
that superseded the manual was derived from the manual itself.
These inconsistencies indicate two possible deficiencies.
First is that of a procedural discrepancy in that PM/IG-048
referenced a superseded document for a technical manual. This is
identified as another example of Inspector Followup Item (50-413/
86-05-03 and 50-414/86-07-02).
Secondly, the satellite document
control station in the Maintenance Department not being up to date
with the central document control indicates a lack of adequate
document control.
This is identified as Inspector Followup Item
(413/86-05-07,414/86-07-04).
Additionally, the inspector questions why a technical manual that
has comprehensive maintenance instructions and a troubleshooting
section would be superseded by
only a drawing.
This is an
inspector concern.
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Procedure No. PM/IG-049 addresses preventive maintenance on the
station air system on a semi-annual or refueling basis.
The
procedure was clear and comprehensive. The inspector also reviewed the
referenced technical manual, CNM 1213.00-089 and found that the
maintenance procedure matched the suggested maintenance in the
technical manual with the exception of the flow control valve,
which had no maintenance specified in the procedure.
The
inspector did not have the opportunity to determine whether this
was an intentional or inadvertent omission.
This is an inspector
Concern.
The following procedures and their referenced technical manuals
were reviewed for completeness, clarity, and proper control. All
were judged adequate.
PM/IG-023 Nitrogen System. Maintenance on a yearly basis. Vendor
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Manuals:
CNM-1340.00-0020, Indeeco Gas Preheater; CNM 1205.06-267
and 268, Fisher Technical Manual; CNM 1210.03-10, Moore Technical
Manaal.
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rM/IG-047 Instrument Air Compressors and Associated Equipment.
Maintenance on a quarterly and semi-annual basis.
Vendor manuals:
CNM 1213.00-41, Gardner-Denver Air Compressor Service Manual; CNM
1213.00-43, Gardner-Denver Air Compressor Parts Manual; CNM
1320.00-1, Reliance Electric Air Compressor Motors.
PM/IG-084 Auxiliary Feedwater Turbine / Pumps.
Maintenance on a
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semi-annual and annual basis.
Vendor Manuals:
CNM 1201/05-179,
Bingham Pumps; CNM 1201.05-269, Terry Turbines Technical Manual.
PM/IG-085 Auxiliary Feedwater Motor Driven Pumps. Maintenance on
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a yearly basis.
Vendor manuals: CNM-1201.05-0360, Bingham Pumps
Technical Manual; CNM 1318.16-14 We-tinghouse Motor Technical
Manual.
The inspector noted that there was no scheduled preventive maintenance
un Limitorque valve operators. The present policy is to trend failures
first to see if preventive maintenance is needed. This is accomplished
three ways:
(1) a quarterly review of frequent failures (three or
more) in a s
(2) a yearly review of all systems and their
failures; (3)ystem;all work requests are processed through the Preventive
Maintenance Department and a pattern of failure may or may not be
noticed this way.
The lack of preventive maintenance on Limitorque
valve operators is an inspector concern.
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The inspector also reviewed maintenance procedures.
Procedure No. MP/0/A/2001/05 Westinghouse DS-416 Air Circuit
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Breakers.
Maintenance on a semi-annual basis.
The procedure
appeared to be complete and clear.
The Associated Technical
Manual (CNM 1399.40-0011) was in document control.
The inspector
also tracked down the lubrication kit specified on a work request
that used this procedure and found it to be the proper type
specified in the vendor's Technical Manual.
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Procedure No. MP/0/A/7400/16 Diesel
Engine Cylinder Head
Corrective Maintenance. Maintenance every refueling outage. This
procedure adequately addressed the maintenance requirements and
was well organized.
However, the referenced technical manual was
listed as CNM 1302.00-237, Delaval Instruction Manual Vols. I &
II., and it was not found in Document Control under that number.
Instead it was found as CNM 1301.00-237.
This could have been
just a typographical error, but it is another example of
procedural discrepancies identified as Inspector Followup Item
(50-413/86-05-03) and (50-414/86-07-02).
The inspector reviewed the following Instrumentation and Electronics
procedures. All were found to be adequately written and controlled.
IP/0/A/3200/08A Train A Reactor Trip Breaker Trip Device Monthly
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Functional Test.
IP/0/A/3230/06 Procedure for Disconnection and Connection of
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Incore Thermocouple Cables.
IP/0/A/3240/13 Excore Nuclear Instrumentation System - Detector
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Plateau Curve Plotting.
In all of these maintenance procedures, there were clear instructions
as to tagging out the equipment being worked on, notifying operations
that work was being done, and subsequently removing the tags when the
equipment was put back in service.
9.
Operating Staff Training (41301)
A training assessment was performed for Catawba Unit 1 and 2 under
inspection report nos. 50-413/84-93 and 50-414/84-42.
This inspection
satisfies the objectives of Inspection Procedure 41301, Inspection of
Operating Staff Training.
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10.
Followup on Previously Identified Items
IFI 413/85-12-04; The licensee stould take action to provide a management
review to ensure that when steps are deleted from procedures that they are
deleted in an appropriate fashion.
CLOSED - The licensee stated that the
Shift Supervisor is the appropriate final reviewer of completed procedures
and no required post review is needed or desired.
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