ML20151F257

Insp Repts 50-313/88-05 & 50-368/88-05 on 880229-0610. Violations Noted.Major Areas Inspected:Followup to Insp Repts 50-313/87-23 & 50-368/87-23 & Licensee Response to Generic Ltr 83-28

ML20151F257
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/06/1988
From:	Boardman J, Gagliardo J, Ireland R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151F248	List: ML20151F245 ML20151F250 ML20151F257
References
50-313-88-05, 50-313-88-5, 50-368-88-05, 50-368-88-5, GL-83-28, NUDOCS 8807270005
Download: ML20151F257 (22)

See also: IR 05000313/1988005

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-313/88-05 Operating Licenses: DPR-51

50-368/88-05 NPF-6

Dockets: 50-313

50-368

Licensee: Arkansas Power & Light Company (AP&L)

P.O. Box 551

Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One (ANO), Units 1 and 2

Inspection At: ANO, Russellville, Arkansas

Inspection Conducted: February 29 through March 4; March 21-25; April 4-8;

and June 6-10, 1988

Inspector:

J. R'.

,

Boa'rdman, Reactor Inspector, Operational

IU

Date

regrams Section Division of Reactor Safety

Approved: .c6 __

J. E. Gagliardo, Chie'f, Operational Programs Date ' "

Section, Division of Reactor. Safety

$$. C\ln/

R. E. Ireland, Acting Chief, Plant Systems

7/4

D'te

a

/W

Section, Division of Reactor Safety

Inspection Sumary

Inspection Conducted February 29 through March 4; March 21-25; April 4-8;

and June 6-11 1988 (Report 50-313/88-05; 50-368/88-05)

Areas Inspected: Routine, announced inspection of followup to issues

identified in NRC Inspection Report 50-313/87-23 and 50-368/87-23 and the

licensee's response to NRC Generic Letter 83-28.

8007270005

DR

880713

ADOCK 05000313

PDC

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Res'ults:: Within the areas inspected, two violations (failure to maintain

design control.of installed. seismic bolting and failure to'take prompt-

corrective action for an Emergency Diesel Generator fuel -line leak,-

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paragraph 2.b.), and one-potential violation (failure ~to have records of

' equipment qualification, paragraph 3.a.).were identified.

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DETAILS

1. Persons Contacted'

Licensee

• J. Levine, Executive Director Nuclear Operations

+L.-Humphrey, General Manager, Nuclear Quality

+*D. Lomax, Plant Licensing Supervisor.

+*D. Howard, Special Projects Manager

+*P. Michalk, Plant Licensing Engineer.

• B. Baker, Plant Modifications Manager

+*R. Lane, Engineering Manager Superintendent

+*J. Taylor-Brown, Quality Control Superintendent

• B. Converse, Operations Assessment Superintendent

+H. Greene, Quality Assurance Superintendent

'+*J. McWilliams, Manager, Maintenance-

• R. Wewers, Work Control Center Manager

• B. Durst, Project Engineering Superintendent

• M. Snow, Licensing Engineer

• M. Tull, Licensing Specialist

E. Ewing, General Manager, Plant Support

'S. Quennoz, General Manager, Plant

'R. Gillespie, Technical Analysis Superintendent

D. Eichenberger, Maintenance Coordinator

• R. Turner, Plant Projects

'K. Wire, Plant Projects

• 1'. Baker, Technical Support Manager

• R. Tucker. Electrical Maintenance Superintendent

C. Halbert, Engineering Supervisor  ;

D. Provencher, Quality Assurance Supervisor l

C. Shively, Plant Engineeing Superintendent

B. McCord, Quality Control Supervisor

J. C. Garrett, Materials Management Superintendent

NRC

+*W. D. Johnson, Senior Resident Inspector

'+*C. C. Harbuck, NRR Project Manager, ANO

• I. Barnes, Section Chief i

• R. Haag, Regional Inspector i

• L. Gilbert, Regional Inspector l

• R. Taylor, Regional Inspector

• J. Gagliardo, Section Chief

• Denotes attendance at exit interview on March 4,1988.

+ Denotes attendance at exit interview on March 25, 1988.

• Denotes attendance at exit interview on June 10, 1988..

The NRC inspector also contacted other station and corporate personnel, j

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2. Followup of NRC Inspecticn Report 50-313/87-23; 50-368/87-23 (25578)

The subject inspection reviewed the licensee's quality verification

activities. The quality wrification organizations involved included

Quality Assurance, Quality Control, and independent review groups such as

the Independent Safety Evaluation-Group. The purpose of the inspection

.was (a) to provide assurance.that licensee quality verification

organizations were effectively contributing to the identification,

solution, and prevention of safety significant technical problems and

deficiencies, and (b) to measure line management response to identified

quality deficiencies. The subject inspection did not contain violations

or deviations, but identified NRC inspector concerns and other findings.

This followup inspection address (s the specific NRC inspector concerns and

findings in the four areas (Plant Modifications, Maintenance, Plant

Operations, and Corrective Actions) covered by the subject inspection.

a. Plant Modifications -(two concerns)

The first concern related to the licensee's evaluation of a inminar

indication in reactor coolant hot leg piping base metal as dctected

by ultrasonic inspection. This concern was resolved during the

subject inspection, and no further followup was required.

The second concern related to a design calculation for the seismic

support bracket of a high pressure injection pump recirculation line

valve and motor operator. The concern was that one specified

fastener could not be obtained. A substitution was made which .

deviated from the design calculation.

The original design calculation required mechanical properties

(190,000 170,000 psi minimum yield

strength) which

psi minimum

are nottensile strength /

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available, or practical, for seismic bolting l

applications. The design agent (Vogt) had modified a previous i

calculation, but had failed to modify the fastener mechanical

properties.

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The NRC inspector reviewed both the original and corrected ,

calculations. The latter calculation specified equal to, or better l

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than, ASTM A193, Grade B7. ASTM A193, Grade B7, in the subject size

(1/4"-21/2"), specifies mechanical properties of 125,000 psi minimum

tensile strength and 105,000 psi minimum yield strength, 16 percent

minimum elongation, and 50 percent minimum reduction in area.  ;

The licensee had installed "high strength" hexagon socket head cap

screws (1960 series). The Industrial Fastener Institute book,  ;

Fastener Standards, Fifth Edition specifies (Page G-5, Note 17),  !

surface hardness values of Rockwell C37 to C45 for the mechanical i

properties of the subject capscrews. The NRC inspector was not i

provided adequate data to datermine the acceptability of these

fasteners for this seismic design application. The equivalent

tensile strengths for the above specified hardness values are 170,000 l

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to 217,000 psi. Alloy steel materials of this range of mechanical

properties are relatively nonductile. They would not meet the

ASTM A193 Grade B7 requirements of 16 percent minimum elongation and

50 percent. minimum reduction in area. The design mechanical

properties (ASTM A193, Grade B7) should assure'that the cap-screws

can meet required dynamic seismic loads.

The licensee stated that these installed capscrews were too small to

be tested for mechanical properties. Failure to insure that

installed socket head capscrews met the design requirements of

ASTM A-193, Grade B7, is an apparent violation of 10 CFR Part' 50,

Appendix B, Criterion III, for design control, which requires

licensees to establish measures to select and review for suitability

of application materials, parts, and equipment that are essential to

the safety-related functions of structures, systems, and components

(313/8805-01).

b. Maintenance (two concerns)

(1) Concerns

The first maintenance concern related to the effectiveness of

the licensee's corrective actions to prevent recurrence of

Errergency Diesel Generator

LicenseeEventReport(LER)(No.EDG) fuel degradation reported by'

50-368/86-014-00.

The licensee's corrective actions were effective to prevent

. recurrence of the e-act failure mechanism. The NRC inspector

identified, however, other related potential problems as

follows:

The Technical Specification (TS) for EDG fuel quality

requirements does not address significant potential fuel

degradation factors such as gum and oxidation products

related to the duration of fuel storage.

ANO Unit 1 EDGs each had a s - lex (single in-line) filter,

in lieu of dup' ax (double) fi .cers. With duplex filters,

either filter could be placed in service if one became

clogged. This helps assure continuing EDG operability.

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Site fuel quality was not related to filter capacity to

assure EDG operability. Specifically, the licensee could l

not provide data that site fuel quality would assure that

Unit 1 EDGs could accomplish a design base run without

clogging each unit's simplex filter. This could cause both

units to stop. Failure of both EDGs is an unanalyzed

<

condition.

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The licensee had instituted an enhanced EDG fuel testing

and a periodic refiltering program. Southwest Laboratory

had completed a study of EDG fuel for the licensee.

This will remain an open item (50-313;368/8805-02) pending

review of the licensee's final EDG fuel quality program and

analysis of the Unit 1 simplex filter installation for its

affect on EDG operability. ,

The generic aspects of the EDG fuel concern are included in

a Memorandum from J. H. Milhoan to D. M. Crutchfield dated

April 8, 1988; Subject: EMERGENCY DIESEL GENERATOR FUEL

DEGRADATION DURING EXTENDED STORAGE.

The second maintenance concern related to a review of the

licensee's corrective action in response to LER

No. 50-368/86-012. This LER reported-an inoperable Unit 2

pressurizer code safety valve which was found to have a set

point considerably above the value permitted by TS.

Incident to the review, the NRC inspector identified that

the code safety valves' body-to-bonnet stud bolt design was

of a type previously identified as prone to failures during

dynamic loading. Additionally the installed stud bolts

were not in accordance with ANSI standard B16.5, "Stud

Bolts for Pressure-Temperature Piping." The ap

American Society of Mechanical Engineers (ASME)plicable

Boiler and

Pressure "essel Code revision did not require analysis of

this joint according to licensee personnel. This~ item is '

closed based on the Memorandum from J. W. Roe to C. E.

Ross, dated December 2, 1987, that requested an NRR review

of this concern as a generic issue. l

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(2) A_dditional Findings i

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In addition, the Maintenance Section of the report contained I

findings related to licensee actions with regard to Licensee

Event Report (LER) No. 50-368/87-003 (Pressurizer Heater i

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Rupture),

turbo-charger QA-Audit designated

bolts), Reports QAP-11-86

of Abnormal (Loose

Conditions (RACsand missing)EDG

2-85-315 and 2-85-316 (EDG fuel line leak), and RAC 2-86-043

(stripped EDG fuel drain line fitting). Followup on these

findings were as follows:

(a) Pressurizer Heater Rupture

As stated in Inspection Report 50-313;368/87-23, the root

cause of the rupture was determined to be an apparent

weakness in the licensee's vendor audit and surveillance

program. The NRC inspector reviewed the 1988 printout of

actual and scheduled vendor audits and surveillances, as

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well as 1987 and 1988 manpower allocation.for vendor audits

and'surveillances.

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Site involvement has increased from 0.25. equivalent ,

man-years to 3.1 equivalent' man-years (4.1 by July 1988)..

Overall manning.in 1987 and 1988 for vendor activities was

identified-to be as follows:

, 1987 1988

AP&L personnel .2.75 7.1

Contract personnel 3.5 1.?

Total 6.25 8.3

During a subsequent inspection, the effectiveness of the

licensee's vendor audit and surveillance will be reviewed.

This review will include an analysis of licensee identified

root causes of vendor responsible problems, and the root

causes of receipt in~pection rejections to verify that

licensee vendor controls are effective.

(b) Loose or Missing EDG Turbo Charger Bolts

This finding related to loose or missing bolts. Based on

interviews with licensee personnel, the NRC inspector found

that only one bolt was affected. This finding is

considered closed.

(c) EDG Fuel Line Leak ,

This finding related to licensee RAC Nos. 2-85-314 and

2-85-316, which identified a leak in a copper fuel oil ,

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supply line for EDG 2K4B. - The leak was ~a potential fire

hazard and an operability concern. The NRC inspector

obtained the licensee's documentation of corrective actions

taken.

The RACs had been closed without a determination of root

cause, or actions to preclude recurrence. The silver braze

repair of the hole through the tube wall base tretal had no

docurrentation of acceptability. Specifically, there was no

brazing procedure, no brazer qualification, no approved

brazing rod or documentation of the type rod used, and no

acceptance criteria (except that the repair not leak).

Licensee proposed corrective actions at the time of the

initial NRC inspection included replacing the repaired line

with a new line supplied by the original manufacturer, or

m iacing it with a flexible line.

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During the present inspection, licensee personnel confirmed

that no additional action on this condition had apparently

been accomplished.since the August 1987 NRC inspection.

The repaired line was still-installed without docurented

acceptability, including seismic evaluation. The root

, cause of this metallurgical' problem, its generic

implications,-and actions to prevent recurrence had not

.been~ determined. Failure to take prompt corrective action

is an apparent violation of 10 CFR Part 50, Criterion XVI,

which requires a. licensee to establish measures to assure

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that significant conditions adverse to quality are not only

promptly corrected, but that the cause of the condition is

identified and that action is taken.to preclude repetition

~(368/8805-03).

Stripped EDG Fuel Drain Line Fitting

This finding involved a reportedly stripped fuel drain line

fitting that was a possible fire hazard. Licensee

person'el stated that the subject fitting did not have

stripped threads, but slightly damaged threads. These were

repaired by use of a thread chaser. This finding is

closed,

c. Plant Operations

No significant concerns were identified. The two findings which were

related to Unit 2 Plant Protection System Cabinets'and the Nuclear

Quality (NQ) organization operational oversight observation program,

were reviewed and the following findings were noted:

Unit 2 Plant Protection System (PPS) Cabinets

The May 12, 1987, NQ Surveillance Finding Report.(SFR) No. 461

identified that the PPS cabinet power supply cover was only secured

by 1 of 14 screws. Several screws were missing and the remainder

were loose. Plant Engineering Action Request (PEAR) 87-1857, dated

June 10, 1987, requested determination of the minimum number of

screws required to maintain seismic qualification. The screws that ,

were in place, but loosened, were tightened on-or-about June 5, 1987. l

At the time of NRC Inspection 87-23, on August 20, 1978, the missing  ;

screws had not been replaced. PEAR 87-1857 response had not been '

completed (determination of seismic qualification), and reportability

had not been determined. NRC Inspection Report 87-27 updated.the

status of this finding as follows: Temporary replacements for the

missing screws were installed on August 24, 1987. Remaining actions ,

(corrpletion of PEAR 87-1987 and reportability determination) were l

madeanunresolveditem(368/8727-01). This item still remained open j

at the time of inspection.

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NQJperations0_versightObservationProgram

The report included only favorable comments about the NQ operations

observation program, except for an a aparent reduction in. frequency.

Licensee personnel stated that the o)servation program had been

restructured to meld the NQ Surveillance Program into the audit

program. Audits of this type increased from 1 in 1986 (program

initiation) to 25 in 1987, and 28 from January .1,1988 to the date of

this-inspection. This finding is considered closed.

d. Corrective Actions

During NRC inspection 50-313;368/87-23, clesures of corrective

actions were examined to assess their effectiveness. No significant

concerns were identified in the area of corrective actions. The

inspection findings included:

In certain cases root causes were not identified

In certain cases there was a lack of timeliness of determination

of reportability

In some cases there was a lack of timeliness in completion of

actions to prevent recurrence.

The above general areas were generically covered in NRC Inspection

Report 50-313;368/87-26 and in the licensee's response thereto. This

finding is considered closed.

Another finding was lack of identified effective corrective action in

Nonconformance Reports (NCRs) dealing with inadequate material

control. The licensee in February 1988 initiated a Standing Order on

Material End Use Authorization (3000.004). This Standing Order

presently has an indefinite expiration date. It is intended to

assure that all issued safety-related components, parts, and material

meet plant design and quality requirements. This finding is

considered closed. The Material End Use Authorization Program will

be reviewed for effectiveness during a subsequent inspection.

3. Near-Term Followup to NRC Generic Letter (GL) 83-28, Temporary

Instruction (TI) 2515/64, Revision 1 - Licensee. Response to the Generic

Implications _of ATWS Events at the Salem Nuclear Power Plant (25564B)

The purpose of TI 2515/64 is to provide guidance for performing near-term

inspection follow-up to NRC Generic Letter (GL) 83-28 "Required Actions

Based on Generic Implications of Salem ATWS Events," July 8, 1983. The

objective of this TI is to provide near-term inspection of the equipment

classification, vendor interface, and maintenance programs for selected

safety-related components within safety-related systems.

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The NRC inspector began a performance oriented review of the licensee's

response to GL 83-28. When the inspection began, the' licensee could not

provide a definitive status of their overall responses to this generic

letter.

The NRC inspector selected the following three safety-related components

to sample the licensee's response to the generic letter:

Reactor Containment Building Cooling Unit Fan Motors (containment

cooling fan Reliance motors)

Reactor Trip Breakers

Limitorque Valve Operators

These components were selected because of their safety significance, wide

use in the plant, potential generic implications, and their potential

failure modes. The findings are detailed below:

a. Reactor Containment Building Cooling Fan Reliance Motors and other

Te'liance Yotors QiialTfied_ by Joy Man _ufacturinglompany Report X-604

_

The inspection covered both ANO-1 and -2 cooling fan motors. The NRC

inspector reviewed the supplier's (Joy Manufacturing Co.)

Environmental

manufacturerReliance

(Qualification (EQ)

Electric) Documentation,

maintenance the motor

instructions, selected

licensee maintenance procedures and maintenance history, selected

licensee material control and issue documentation, selected AN0 Plant.

Engineering Action Requests (PEARS), and other licensee procedures

and documentation. This included'all applicable environmental

qualification docuaentation for Reliance motors which was so

identified in the licensee's document control system.

(1) Background of En_vironmental Qualification Requirements for  :

Containment 700 ling Fan Motors, andll other Reliar.ce Motors, ~

Except Motors Qualified by Limitorque

10 CFR 50.49(e) requires that environmental qualification for

components such as the ANO-1 and -2 reactor containment building

cooling fan motors include and be based on temperature,  ;

pressure, humidity, chemical effects, radiation, aging, and '

synergistic effects, j

10 CFR 50.49(f) requires that equipment such as the subject fan

motors ". . . be qualified by one of the following methods:

"(1) Testing an identical item of equipment under identical

conditions or under similar conditions with a supporting

analysis to show that the equipment to be qualified is  ;

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"(2) Testing a similar. item of equipment with' a supporting-

analysis;to.show that the equipment to be qualified is.

acceptable.

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"(3)'Experiencewithidenticalor_similarequipmentunder

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similar conditions with a supporting analysis to show that

--the equipment to be qualified is acceptable.

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"(4) Analysis in'~ combination with partial type test data that

supports the analytical. assumptions and conclusions."

10 CFR 50.49(k) requires that equipment such as the -subject

motors further be qualified ". . . in accordance with

"Guidelines for Evaluating Environmental Qualification'of

Class IE Electrical Equipment in Operating Reactors," dated- '

November 1979(00RGuidelines),orNUREG-0588(ForComment

- version), "Interim Staff Position on Environmental Qualification

of Safety-Related Elec.trical Equipment."

00R Guidelines, Section 8,' require that complete ar.d auditable

records must be available for qualification. These records

should describe the qualification method in sufficient detail to

verify that all of the guidelines have been satisfied. A simple ,

vendor certification of compliance with a design specification ~

should not be considered adequate.

The licensee identified Joy Manufacturing Company Environmental

Qualification (EQ) Report No. X-604 . "Qualification Testing .of

Joy Axivane Fan and Reliance Electric Motor for Class I-Service

for Nuclear Containment per IEEE 334-1974," dated April 6, 1977,

as being the basis for environmental qualification of the

subject containment cooling fan motors. There is a 1980

Revision of X-604 which was basically a format change.

(2) Equipment Qualification Concerns With-ANO Units 1 and 2,

Containment Cooling Fan (Reliance) Motors

The NRC inspector identified the following areas of i

significant concerns relating to equipment-qualification of

the subject fan motors:

Undocumented modification of the motor insulation

system

Unapproved bearing replacement

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Use of modified bearings

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Details of these concerns are provided in the'following

paragraphs:

a) Lack of Documentation of Licensee Modification of the

Electrical Insulation System of Qualified Motors

Joy Manufacturing EQ Report X-604 states for the

electrical insulation system of the qualified motor,

that the specific definition of materials used in the

insulation system is considered proprietary. This

data is on file at both Joy Manufacturing and Reliance

Electric Companies, and is available for audit at

these facilities.on request. Page 4 of Report X-604

further indicated that Dow Corning Type DC 997 varnish.

was a component of the subject insulation system.

Licensee procedures have permitted tne repair

(modification)-of the insulation varnish with

unspecified varnish without documentation and without'

QA/QC verification. Licensee personnel stated that

repairs had been made using GE Glyptol 1201 varnish.

The licensee identified no documentation meeting the

requirements of 10'CFR 50.49 for the maintenance of

motor qualification using GE Glyptol 1201 to repair

the qualified insulation systems for ANO-1 and -2 fan

motors. Further, the NRC inspector in comunication

with Joy Manufacturing Company personnel identified

the following concerns:

The Joy Manufacturing Company representative

stated that he was not aware of the practice of

accomplishing insulation system repairs to

Reliance Motors, and that Reliance Electric

indicated that Glyptol 1201 might not be suitable

for high radiation environments.

The Joy representative stated that Reliance

indicated that they knew of no data, based on

tests, showing the compatibility of their

proprietary insulation system and Glyptol 1201.

The Joy representative further stated that

Reliance indicated there were no generic criteria

for adequate evaluation of damage to the

insulation of their qualified motors, that

Reliance approved personnel must make this

determination; and that, basically, proprietary

warranted repairs required to maintain

qualification using Report X-604 could only be

made at the Reliance factory.

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b) Lack of Documentation of Approval of Licensee Bearing

Replacement For_EQ 1 Reliance) Motors

Joy EQ Report X-604 identified a bearing failure-

during the-EQ qualificatior, test because of an

lacement. The

unauthorized

report stated field

that repair / bearing

no field . rep (bearing

repairs-

replacement) were to be undertaken on the subject

motors. The licensee had subsequently disassembled

and reassembled all but one of the subject motors for

both Units 1 and 2, for bearing replacement.

Licensee maintenance procedures for Units 1 and 2

containment cooling fan (Reliance) motor bearing

replacement were based on a Reliance Motor Bearing

Assembly Procedure obtained in February 1979 from Joy

Mai.ufacturing Company. Neither the procedure, nor

accompanying documentation, indicated that this

procedure was applicable for EQ, or safety-related,

Reliance motors.

The NRC inspector contacted a Joy Manufacturing

Company representative concerning the acceptability of

this

Joy (procedure for bearing replacement onReliance) containme

motors covered by Report X-604. The Joy

representative responded that the subject procedure

used by ANO was a comercial procedure and did not

contain the requirements for EQ fan motors.

A licensee telecon dated October 24, 1984, with a Joy

Manufacturing representative stated (with. reference to

motor disassembly and required bolt torques for

reassembly) "The reliance motors are qualified

equipment and they [ Joy] do not recontrend disassembly,

since any disassembly in the field will void the

equipment qualification."

c) Lack of Documentation of Qualification of Gulf High

Temp Grease for Ej'TT@liance) Fan Motor Lubrication

Joy Report X-604 documents that the subject fan motors

were environmentally qualified using Chevron SRI-2

grease. Licensee procedures such as 1403.08,

Revision 0, Change 2, "Reactor Building Cooling Fan

Motor Inspection," have permitted the use of "High-

Temp Grease (Gulf)" as an alternate to SRI-2, and

admixed with SRI-2. The licensee could not document 1

that SRI-2 grease was onsite at AN0 prior to 1984,

except for one 35 pound pail. The licensee did not

identify that this pail would have met lubrication

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. quantity requirements, or that grease gun control

(including any gun-filling pump system used with the

pail)werecontrolledtoprecludeadmixturewithother

greases used onsite.

The licensee identified no documentation meeting

10 CFR 50.49 substantiating maintenance of Reliance

motor qualification using'either Gulf High. Temp

_ grease, or an admixture of Gulf and SRI-2 greases,

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d) Lack of Documentation for_ Qualification of Site

Installed Bearings in EO (Reliance) Motors i

Background

Joy EQ Report X-604 identified the qualified -

(Reliance) motor opposite drive end bearing as being a

95BC0ZXPP3H bearing. The symbols "PP" designate a

double shielded bearing.-

Licensee Design Control of Bearing Lubrication

The NRL inspector requested a printout of all ANO

warehouse stock ball bearings. A review of this

printout, and discussions'with ANO personnel,

-identified that AN0 had-not specified, or controlled,

bearing manufacturer lubrication of double sealed or

double shielded bearings until February 1988 when

PEAR 88-036 was issued for bearing Baseline

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QualificationRequirements(BQR). This PEAR was the

result of the End Use Authorization Program (see

report paragraph 2.d) identifying this problem.

Previous BQR PEARS for bearings, such as generic

PEAR 83-1905, failed-to-discuss lubrication.

_ Lack of Documentation of Bearing Manufacturer

Installed Grease

As a resul't, the licensee could not document the

lubricant packed by bearing manufacturers in double

sealed / double shielded bearings at ANO. These

bearings had been manufactured in several countries

and by various manufacturers based on the NRC

inspector's review of bearings in warehouse stock at

ANO. .Most safety-related replacement bearings-at ANO

appeared to have been purchased as comercial grade

items from~a distributor who was not in the licensee's

supplier quality audit program.

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Licensee Modification of Bearings

Licensee personnel stated that replacement opposite

drive end bearings for EQ (Reliance) motors were

modified on site prior to installation by removal of 4

one shield and relubrication with SRI-2 grease.

Licensee Proced_u_r_es for_ B_ef rino ReDlacement

A review of the following' ANO procedures for EQ

(Reliance):motorbearingreplacementwasaccomplished:

1403.08, Revision 2, dated January 09, 1985,

"Reactor. Building Cooling Fan Motor

~1 403.008, Revision 4, dated December 18, 1987,

Unit 1 Containment Cooling Fan Inspection and

Repair

2403.005, Revision 4, dcted June 4, 1988, Unit II

Containment Cooling Fans

These procedures:

Did not require the use of bearings having any

shields. (Bearing desigrations in

not include the shield designator.) procedures do

Did not require steel bearing retainers for EQ

applications. (The retainer designator was

missing.)

Did not specify motor bearing tolerance. (The

tolerance designator was missing.)

Did not require (1) determination of the

lubricant in "as received" replacement bearings,

(2) shield removal if lubricant is not SRI 2, or

(3) specify how to degrease bearings of other

than SRI 2 grease.

Did not identify which bearing shield to remove,

or how to remove the permanent shield without j

damage to the bearing. Shield removal modifies

flow of grease in the motor lubrication system,  !

and grease retention by the bearing assembly.

The licensee document "Evaluation of L9bricants Used'

in Safety-Related Equipment Installed at ANO Units 1

and II" states:

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If the soap bases of the two greases are not'the

same, they MUST NOT BE MIXED TOGETHER IN THE

EQUIPMENT. The original grease must be

completely removed from all lubricated surfaces

using the manufacturer's recommended practices

[there were none,provided or identified to the

inspector] before the' substitute grease is

applied."'

Licensee Technical Ju_s_tif_ica_t_ ion for Bearing

Nodifications

Thelicensee_documentcontrolsystem-(reel 3682,

frame 4878) contained a lecter to the licensee from

Schneider Engineers dated March 23, 1988. This letter

states (in part):

"Discussion: The ANO Units 1 and 2 Containment Fan

Cooler Motor Environmental

Qualification is based on the tests

reported in Reference 1 [ Joy

Report X-604]. The NRC has reviewed

and accepted this document as evidence

of qualification for plants licensed to

both 10 CFR 50.49 and IE

Bulletin 79-01B, of which AN0 Units 1

and 2 are the latter.

"Attachment 1, Appendix E of

Reference 1 provides a detailed

description of the test motor including

the bearings AFBMA designation:

DRIVEEND(INBOARD): 95RU02M3B

OPPOSITEEND(0UTBOARD): 95BC02XPP3H

"Per Reference 2 [ Anti Friction Bearing

Manufacturers Association (AFBMA)

Standard 20-1977], the AFBMA

translation of each identification

number is as follows:

"Drive End: 95mm bore; cylindrical

roller bearing, a single row,

non-locating type, inner ring without

ribs, double ribbed outer ring, inner

ring separable; dimension series 02,

32mm width; cage, bronze or brass not

in sheet strip or wire form, centered

by rolling elements; internal clearance

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greater than normal; special lubricant

.(e.g.,ChevronSRI#2).

"Opposite End: 95m bore; single row radial contact

ball bearing, non-fillirg slot

assembly; dimension series 02, 32m

width; any type cage acceptable, spacer

when a bearing requires supplementary

coding of special cage; permanently

fastened double shield; internal

clearance greater than normal; special

lubricant (e.g.,ChevronSRIf2).

"The qualified configuration, therefore, consisted of

both an unshielded thrust bearing and a double

shielded radial bearing. The post-test inspection

documented in Reference 1 showed that despite the

shields the chemical spray entered the bearing, but

did not affect its operation. The shield is not

intended to seal the bearing. The reported bearing

failure was attributed to over tightening of the

locknut. AP&L EQ evaluations caution maintenance

personnel to this problem.

"The installed bearings differ slightly from the

tested bearings due to the size differences between

the tested and installed motors. However, the vendor

has certified

installed that the Reference

equipment. test is app3 [licable to the

a Reliance document

on 1983 series motor design] indicates that the

qualified series of motors supplied by Reliance use

conservatively rated bearings in an open system

(unshielded). Also, Reliance utilizes a "grease  ;

channeling passage" with minimum grease path entry  :

("metering plate") and two means of preventing over

greasing - grease reliefs and relief along the shaft.

Reliance provides additional information regarding l

bearings in References 7 and 8 [ Reliance Sumary l

Reports].

"According to Reference 4 [a Scheidner Engineering I

report],whichevaluatedtheinstalledbearingsand

lubricants for suitability to their potential

environment due to postulated accident conditions, the

bearing lubrication combination in the AN0 Containment

Cooling Fan Motors is qualified. Use of the ANO

maintenance procedures and Chevron SRI #2 grease will

maintain the bearings in "like-new" condition.

"Based upon the EQ test, motor and bearing vendor data

and industry standard information, the use of bearings

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with zero, one or two shields is considered acceptable

in the CCF Motor application provided that maintenance

procedures for inspection and lubrication, in place at

the current time, are strictly enforced.- As such, the

current bearing configuration is considered

environmentally qualified in accordance with

IE Bulletin 79-01B and 10 CFR 50.49."

Concerns Relating t_o Licensee Bearing Modification

The NRC inspector confirmed with a Joy Manufacturing

Company representative'that the different bearing

configurations (oneshield,twoshields,noshields)

are based on overall motor lubrication system design,

and analysis has not been'made to support

substitutions. The Joy representative stated that use

of single shielded bearing'in lieu of a double

shielded bearing, depending upon which shield was

removed, might have negative affects on bearing i

lubrication, and relubrication periodicity. l

The NRC inspector determined from Joy Manufacturing

Company personnel that there have been three different

lubrication systems for EQ Reliance motors (which

includes the configuration of the motor frame and

housing). This fact was apparently ignored in the

Schneider Engineering Letter.  ;

The latest (open) Lubrication system, design ,

(reference 3 of the Schneider Engineering letter)  ;

apparently post-dates the ANO motors, and uses l

unshielded bearings. The open system allows

unlimited addition of grease without unacceptable

introduction of grease into the motor cavity by .

migration down the motor shaft. Reference 3 l

states: "This bulletin is not intended to  !

provide operational instructions. Appropriate

Reliance Electric Instruction Manuals and warning i

tags attached to the apparatus should be read ,

carefully prior to installation.~ operation and/or '

maintenance of equipment." Appropriate Reliance

Electric instruction manuals do not support the

conclusions of the Schneider Engineering letter

for the motors reviewed by the NRC inspector. l

The second system, apparently applicable to ANO

motors, was designed to use double shielded

opposite drive end bearings. Relubrication is

specified by appropriate Reliance manuals as a

few cubic centimeters (or ounces) of grease.

This is required to prevent over-lubrication.

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The earliest identified lubrication system design

consisting of one shield and a metering plate, is

found in "General Specifications for Nuclear-

Motors used with Joy Axial Fans in Cor.tainment

Areas," FF-12642 (Sheet 1) Revision NBN 883,

dated March 27,'1971, (this specification was

provided to the:NRC inspector by licensee

personnel) which states in Sections (4) and (5):

"4) Bearings shall be anti-friction ball bearing

regreasabletype,singleshielded(inside)

with metering plate for each bearing.

[ Note that the required' shield (on

which side it is installed) is identified.]

Bearings to operate in a nuclear environment

and under emergency conditions. See motor

bill of material for bearing loads and 8-10

Life.

"5) Grease to.be' Chevron BRB#2 [ Predecessor of

SRI-2] or equivalent (radiation resistant).

Grease entry and relief openings shall be

located on Frame 0.D., 180' apart, with

removable pipe plugs."

Lack of Documentation ~of Design Control of

Licensee Instafled Bearings

For replacement bearings purchased as double

shielded and installed in EQ (Reliance)

motors, The licensee had no documentation to

show:

That the "as received" bearings with

unknown grease were not installed in

some cases.

That shields were removed without

distortion or damage.

Which shield was removed.

That all as-received grease was removed

after shield removal.

That the bearings, after shield <

removal, were properly relubricated

with SRI-2 grease. l

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Sumary of EQ Concerns

In the examples detailed above (lack of

docum:ntation of qualification ~ of Glyptol 1201,

acceptability'of bearing replacement procedures

to maintain qualification; qualification of Gulf

High Temp Grease, and qualification of

replacement bearings), the licensee apparently

did not meet the requirement of 10 CFR 50.49(j)

for records of the qualification of ANO Units 1

and 2 Reactor Containment Building Cooling unit

fan (Reliance) motors and other Reliance motors

at ANO whose qualification is based on

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Report X-604. Failure to meet 10 CFR 50.49(j) is.

anapparentviolation(50-313;368/8805-04).

This apparent violation is not addressed in the g

Notice of Violation issued with this report. The

licensee is requested to be prepared to discuss

all aspects of this violation, including all

affected equipment and corrective actions taken,

during a subsequent meeting with Region' IV staff

covering the Equipment Qualification Inspection

of ANO performed July 14-18, 1986 (NRC Inspection

Report 50-313;368/86-24),

b. Reactor Trip Breakers

The inspection covered a review of the licensee's Reactor Trip

Breaker In-Service Inspection and Maintenance Instructions (1405.18,

Revision 2; and 2405.18, Revision 2). The procedures were well

written and contained many helpful illustrations. -The NRC inspector

witnessed the performance of the maintenance procedure for Unit 1 on

a spare breaker used for training. The licensee had been involved in

the efforts of the B&W owners' group to improve the trip breaker

maintenance procedure. Presently recommended improvements were

scheduled for incorporation prior to the next accomplishment of

breaker maintenance.

c. Limitorque Motor-0perated Valve Operators

The NRC inspector reviewed licensee procedures for disassembly,

assembly, and maintenance of Limitorque Valve operators,

Models SMB-000 through SMB-4. This included review of licensee

procedures as 1403.160, Revision 8; 1403.161, Revision 5; and

1403.162, Revision 7. The procedures were detailed and had many

meaningful illustrations. These procedures contain approximately

60 pages of instructions, (compared to 2 pages of instructions in the

Limitorque Type SMB Instruction and Maintenance Manuel,

BulletinSMB/-828). These licensee procedures were developed from

those used by Limitorque field engineers (Babcock and Wilcox).

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The NRC inspector reviewed the licenset.. training facility for

Limitorque maintenance and the initial training film on Limitorque

maintenance. Both the facility and the film appeared to be-

effective.

The NRC inspector reviewed the licensee's actions related to NRC IE

Notice (IEN) 81-08 on' failed Limitorque keys. The replacement keys

were in the licensee's storeroom, but had never been installed.

There was no site procedure controlling keys for any SMB models.

This concern will be reviewed further during a subsequent inspection.

4. Seismic Qualification of ANO Unit One Containment Cooling Fan and Motor

Units

During his search of the ANO document control system, the NRC inspector

was unable to identify documentation of seismic qualification of the

installed Unit 1 containment cooling fan motor assemblies. ' Based on the q

extent of.the search, which could not be completed because of time, this

isanunresolveditem(50-313/8805-05) pending completion of this review

during a subsequent inspection.

5. Potential Irtproper Lubrication of Qualified Safety-Related and

EnvironmentalEQualified__(EQlylianceMotors

_

The NRC inspector reviewed selected archive records of corrective

maintenance for Reliance safety-related and environmentally qualified

motors. Among these was Job Order (J0) #00755814 for Unit 2 containment

cooling fan motor for 2VSF-1B.

i

The

versuswork description

green) discussed

and the purging installation

of motors of proper

with the the wrong (grease

green) SRI-2 (brown

grease. Licensee Report of Abnormal Condition (RAC) 0-88-008(not

reviewed by the NRC inspector) and nonconformance report (NCR) 88-076-2

addressed this anomaly. Based on discussions with licensee personnel,

apparently the brown grease was nonconforming SRI-2, which was

subsequently recalled by the grease manufacturer.

The grease purging procedure identified on Licensee Job

Order (J0)00755814 failed to comply with Reliance lubrication procedures

of ANO safety-related motors (see ANO manual TO R165.0120, Reliance

Manual B-3645-4, dated February 1985, page 7. Table 3).

The licensee's practice of purging can result in overgreasing the Reliance

Safety-Related Electric motors at ANO. NRC Information Notice No. 88-12

discusses this generic concern and cites examples of failures of

containment cooling fan motors from overgreasing.

Pending further review by the NRC inspector during a subsequent inspection

of the generic implications of nonconforming SRI-2 grease and of the use

of grease purges for Reliance motors, this will remain an unresolved item

(313;368/8805-06).

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6. Unresolved Item

. Unresolved items _are matters about which more infonnation is required in

order to ascertain whether or not the items are ' acceptable, violations, or

deviations. The following unresolved items were' discussed in this report:

Paragraph Item Subject

4 '313/8805-05 Seismic qualification of ANO

Unit 1 containment-cooling fan-

motor units

5 313;368/8805-06 Lubrication practices for

safety-related Reliance motors.

7. Exit Interviews

$

The NRC inspector met with licensee representatives (denoted in

paragraph 1) on March 4 and 25 and June 10, 1988, to sunnarize the scope

and findings of the inspection activities.

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