ML20213G420
| ML20213G420 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/08/1987 |
| From: | Boardman J, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20213G411 | List: |
| References | |
| 50-285-87-05, 50-285-87-5, NUDOCS 8705180280 | |
| Download: ML20213G420 (19) | |
See also: IR 05000285/1987005
Text
,,
- .. .
_,g
,
~ ,
"
< -
(~
.
_
,,
,
-
e
,
_
,
,
>
.
' APPENDIX'
-*
,U.S. NUCL' EAR REG LATORY.. COMMISSION
~
REGION IV-
-T
,
.
-NRCLInspection Report ~ 50-285/87-05:
License: DPR-40
Docket: 50-285
Licensee: Omaha Public Power District (0 PPD)
,
1623 Harney Street
' Omaha, Nebraska. 68102
Facility Name:
FortCalhounStation(FCS)
Inspection At:
Fort Calhoun Station, Blair, Nebraska
Inspection Conducted: April 6-10,1987
7
/!
[ 7 J'
h/-
-Inspector:
I
). R. Ebardman, Reactor Inspector
Date[
'
Operations Section, Reactor Safety Branch
Consultant:
H. S romberg, EGG Idaho, Inc./INEL-
f p ,3
I
O'
Approved:
/'
N
. M. &
inicutt, Chief, Operations Section
Date /
Reactoi
afety Branch
4
4
Inspection Summary
t
Inspection Co'nducted April 6-10, 1987 (Report 50-285/87-05)
Areas Inspected: Licensee maintenance program, maintenance program
'
. implementation, electrical maintenance, and instrumentation and control systems
-maintenance.
l
Results: Within the four areas inspected, five potential violations were
identified.as follows:
. Failure to include in p' ocedures the criteria to' permit determination of
1.
r
,
acceptability (paragraphs- 3.b.1, 3.b.5, 4.c, 4.d, 5.c, and 5.q).
.2.
Failure to. identify and retrieve records (paragraphs 3.b.2, 3.c.2, and
3.d.3.a).
'
8705180200 870508
DR
ADOCK 050
5
-. .
,
-.f
2-
3.
-Failure to perform design review (paragraphs 3.b.4, 3.b.5, 3.c.3,'and
3.d.3.b).
4 .~
Failure to implement procedures (paragraphs 4.a and 4.e.1).
5.
Failure to use required lubricant in Electrical Equipment Qualified (EEQ)
Limitorque valve operators (paragraph 4.1).
,
+ .
.
3
DETAILS
l
1.
Persons Contacted
'*R.-Andrews, Division Manager, Nuclear Production
'W. Gates, Plant Manager-
- R. Mehaffey, Supervisor, General Station Engineering Electrical
- M. Core,. Supervisor, Maintenance
J. Fisicaro, Supervisor,' Nuclear Regulatory and Industry Affairs
J. Foley, Supervisor, I&C and Electrical Field Maintenance
- J. Gasper, Manager, Administrative and Training Services
- R. Jaworski, Section Manager, Technical Services
- K. Miller, Supervisor Mechanical Maintenance
- L. Kusek,'-Supervisor, Op'erations
.
- J. Tucker, GSE Electrical Engineer
- D. Munderloh, Plant Licensing Engineer
- T. McIvor, Supervisor, Technical.
- R.'Mueller, Plant Engineer
- A. Richard, Manager, Quality Assurance
T. McIvor, Supervisor Technical
- R. Drahota, Maintenance Engineer
J.-Folley, Electrical and I&C Supervisor
M. Ellis, I&C Supervisor.
R. Grimes, QC Supervisor
D. Golden, Maintenance Engineer
D. Burns, Electrical Foreman
NRC Personnel
- P. Harrell, Senior Resident Inspector
- Denotes attendance at the exit interview on April 10, 1987.
2.
Licensee Maintenance Program
The NRC inspector reviewed the following procedures relating to the
maintenance program:
Procedure
Revision /
Number
Title
Date
Comments
G-17
Maintenance Order
R40/10-15-86
G-62
Control of Vendor Technical
R2/10-30-86
See Note 1
Information
M-2
Preventive Maintenance Program
R8/4-16-85
}
r
'
.
,
4
A-0-30
Testing of Safety-Related
R3/9-30-80
Equipment
M-1
Maintenance Procedures
R7/10-10-84
0-25
Electrical and Mechanical
R19/8-18-86
Jumpers and Blocks Controls
G-23
Surveillance Test Program
R20/9-10-86
G-17A
Electrical Equipment in a Harsh
R2/2-12-86
Environment
0-20
Equipment Tagging Procedure
R17/9-20-85
Note 2
G-26
Maintenance Quality Control
R16/10-16-85
Note 3
Program
G-56
Qualified Life Program (QLP)
R6/2-12-86
SP-Vendor-1
Vendor Manual Indexing
R1/10-31-85
SP-Vendor-2
Safety-Related Vendor Technical
R2/1-30-87
Information Indexing and
Review
Notes:
1.
Reference 3.2 of G-62 includes ANSI N45.2.9-1979 which is
not accepted by NRC.
The correct revision of N45.2.9, which
is 1974, is identified in the body of G-62.
2.
Sections 4.2.1.c, 4.1.8, and 4.2.1.a contains "should"
actions that appear to require "shall" instead.
3.
Reference 2.5 is the 1976 transmittal of the QA Program
which is not the latest revision.
No violations or deviations were identified.
3.
Maintenance Program Implementation
a.
Background
i
The NRC inspector reviewed the licensee's implementation of its
maintenance program.
On Tuesday, April 7, 1987, during a tour with
'
!
the NRC Senior Resident Inspector (SRI), the NRC inspector noted
l
licensee maintenance on the main feedwater system flow nozzles. The
NRC inspector reviewed the maintenance order (MO), which indicated
that retorquing of the line flange bolting would be by " slugging"
(use of a slug wrench) until the joints were tight.
The NRC
inspector was concerned because this practice could result in bolt
stresses that did not meet design values.
Allowable values would
f
3
m
,
5
range from approximately 27,700 psi to 31,800 psi based on ASME
design stress intensity values for bolting materials in the 1965,
1968,-and 1980 (with addenda) ASME Boiler and Pressure Vessel Code
Revisions. The NRC inspector selected twn critical safety-related
applications for review. The main steam safety relief valve (MS SRV)
and pressurizer SRV line flange bolt design stress values and
resultant torque values.
b.
Uncontrolled Stressing of MS SRV Line-Flange Bolts
(1) Governing Procedures
The NRC inspector requested the licensee procedure which covered
reinstallation of the MS SRVs. The licensee Procedure MP-MS-1,
Revision 13, dated March 19, 1987, " Main Steam Safety Valve
Inspection and Repair." This procedure covered torquing of the
MS SRV with the following steps:
"5.39 After offsite testing, reinstall valves with new
Q.C. to closeout inspect piping."
No torque values were provided in Procedure MP-MS-1 to assure
that design bolt stress was achieved.
10 CFR Part 50, Criterion V, states that activities affecting
quality shall be prescribed by documented instructions and
procedures which shall include appropriate quantitative
acceptance criteria. The failure of licensee Procedure MP-MS-1,
-Revision 13, to include torque values to achieve appropriate
design bolt stress levels is a potential violation of 10 CFR Part 50, Appendix B, Criterion V (285/8705-01). Other examples
of this potential violation are identified in Sections 3.b.5,
4.c, 4.d, 5.c, and 5.a of this report.
(2) Original Design and Installation Records
The NRC inspector requested the original design base calculation
and original installation records (" code data package") for the
MS safety relief valve line flange joint bolt stress level. The
licensee was unable to retrieve these records.
10 CFR Part 50, Criterion XVII, requires the maintenance of
sufficient records to furnish evidence of activities affecting
quality; it further requires that records be identifiable and
retrieveable.
Failure to identify and retrieve the records is a
potential violation of 10 CFR Part 50, Appendix B,
Criterion XVII (285/8705-02).
Other examples of this potential
violation are identified in Sections 3.c.2 and 3.d.3.a of this
report.
-_
- _ - _ - _ _ _
_ _ _ _ _ _ _
_ _ _ .
"^
.
'
6
-(3) Applicable Code and Specification Revisions for Piping .,ystem
Design
Fort Calhoun Station piping systems were initially designed to
USAS (now ANSI) 831.7 and ASA/USAS/ ANSI B31.1.
Since Nebraska
is a code state, later piping design should have been to the
ASME Boiler and Pressure Vessel Code (BPV Code), when the BPV
Code was extended to piping systems.
Licensee plant engineering
personnel were unable to identify to the NRC inspector which
revision of the code was being used by Fort Calhoun Station or,
during previous periods of time, which revisions were
i
I
applicable. This is an unresolved item (285/8705-03) pending
further review by the NRC inspector.
.
(4) MO 16275 for Reiastallation of MS SRVs and Lack of Design
Control
The NRC inspector requested licensee M0s covering reinstallation
of the MS SRVs.
The licensee was unable to retrieve any such
M0s prior to the NRC inspector leaving the site on April 10,
1987.
This is another example of the licensee's inability to
retrieve records.
On April 15, 1987, via the NRC SRI, the licensee provided the
NRC inspector with a copy of MO 16275 accomplished in
March 1983, covering reinsta11ation of SRVs MS-275, 276, 277,
278, 280, 281, 282, 291, and 292.
This M0 contained instructions to torque the subject valve
in-line flange bolts 'to 750 foot pounds.
The NRC inspector
questioned the basis for that torque value, but licensee
personnel did not provide it.
Since design stress calculations
l,
for these bolts was not available, the licensee was performing a
design function in determining these stress values.
10 CFR Part 50, Criterion III, requires design control,
including performance of design review.
The licensee is been
committed to WASH 1283 in its Quality Assurance Program
Description.
WASH 1283 contains ANSI N45.2.11 " Quality
Assurance Requirements for the Design of Nuclear Power Plants,"
(Draft 2, Revision 2, May 1973).
The licensee, in his latest approved Quality Assurance Program
Description (QAPD), Section A.4, is committed to Regulatory
Guide 1.64 and ANSI N45.2.11-1974 which specifies (Section 6)
that design verification is to be performed by individuals or
groups other than those who performed the original design.
There was no licensee documentation that such a design review
had been performed in determining the torque value for the MS
SRV line flange bolt stress valve.
_ _ - _ _ _ _
o
.
7
f
Failure to meet the requirements of ANSI N45.2.11 is a potential
violation of 10 CFR Part 50, Appendix B, Criterion III
.(285/8705-04). Other examples of this potential violation are
identified in Sections 3.b.5, 3.c.3, and 3.d.3.b of this
report.
(5) Deletion of a Design Requirement Without Proper Review
The torque valve provided on H0 16275 was a piping system design
parameter necessary to prevent poteritial failure of the joint
under design base (not necessarily operating) conditions.
The torque valves were marked through with the comment "cannot
be torqued." Based on licensee conversations with the NRC SRI,
the bolts were stressed in an uncontrolled manner, to an unknown
stress level, by the common plant procedure of using a slugging
wrench. Later M0s did not show torque values.
Deletion of the torque values constitutes another example of
potential violation (285/8705-01), failure to provide
appropriate acceptance criteria required by 10 CFR 50,
Appendix B, Criterion V; and potential violation (285/8705-04),
failure to meet the requirements of 10 CFR 50, Appendix B,
Criterion III, Regulatory Guide 1.64, and ANSI N45.2.11-1974,
Section 6.
c.
Over Torquing of Pressurizer SRV Flanged Pipe Joints (Reactor Coolant
Pressure Boundary Integrity Joints)
(1) Findings
The NRC inspector reviewed the approved licensee
Procedure MP-PSV-1-3, Revision 15, dated February 6,1986,
" Pressurizer Safety Valve Installation." This procedure
contained detailed instructions for tightening (torquing) the
valve line flange bolts, including the required lubrication and
tightening sequence.
The NRC inspector reviewed the vendor technical manual for the
pressurizer SRVs RC-141 and RC-142. This manual contained the
same data as the licensee procedure. The manual had not had a
technical review to comply with Generic Letter 83-28 and was
classified as an uncontrolled manual by the licensee. The valve
manual procedure, A-1519-1, which contained the data apparently
used by the licensee, gave torque values for generic
applications covering different sizes of bolts and different
levels of bolt stress. The torque value used by the licensee
resulted in bolt stresses of 45,000 psi. As stated in
Section 3.A of this report, allowable stress values would be in
the range of 27,700 psi to 31,800 psi (nominal 30,000 psi),
based on the licensee identified bolting material used for this
_ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _
,.
8
application (ASTM A193, Grade 87 or B16). This results in an
- overstress on the bolts of 150 percent of design values.
(2) Original Design and Installation Records
The NRC inspector requested original design base calculations
and installation records for the pressurizer SRV line flange
joint bolt stress level and bolt torque.
~
For a second time, the licensee was. unable to retrieve these
records. This is another example of potential violation
(285/8705-02) with regard to-10 CFR 50, Appendix B,
Criterion XVII, identification and ' retrieval of records.
(3) Lack of Design Control in Determination of Pressurizer SRV Line
Flange Joint Design Strer.s Values and Bolt Torque
The licensee was unable to provide the NRC inspector with
' documentation of their compliance with Regulatory Guide 1.64,
-ANSI N45.2.11-1974 (as discussed in Section 3.b.4) for the
determination by OPPD personnel of design bolt stress values and
resulting bolt torque for the pressurizer SRV line flange
joints. This is another example of potential violation
(285/8705-04) with regard to 10 CFR 50, Appendix B,
Criterion III, Regulatory Guide 1.64, and ANSI N45.2.11-1974,
Section 6.
,
d.
Reactor Containment Building Ventilation and Cooling Fan Units
The NRC inspector also reviewed the blade angles and bolt torque for
reactor containment building ventilation and cooling fan units.
(1). Review of the Vendor Technical' Manual (NRC Generic Ltr 83-28,
paragraph 2.2.2)
The NRC inspector reviewed the licensee vendor technical manual
for American Air Filter / Joy Manufacturing Company reactor
containment building ventilation and cooling fans and auxiliary
equipment. This manual is identified as "NUS-044."
Documentation of the NUS Corporation Technical Manual review
states that the manual requires lubrication of Fan Units VA-2A
and VA-28 at a 6- to 12-month' periodicity; and Units VA-12A and
VA 12-B at a 3-month periodicity. The NUS review identified
several other differences between the vendor technical manual
and the licensee preventive maintenance program, lhe licensee
has not reviewed this manual for resolution of differences, and
does not consider it a controlled manual. This will remain an
unresolveditem(285/8705-05) pending further review during a
subsequent inspection.
,
_
-__ _ _.
'O
9
(2) Findings Related to Safety-Related Fan Units VA-3A, VA-3B,
E
VA-7C, and VA-7D
The section of the ir.anual containing data for Fan Units VA-3A,
VA-3B, VA-7C, and VA-7D, on page 11 states:
"During normal and emergency operation, this angle will be
degrees,' but if the fan must be tested at conditions other.
than spec values, this angle may have to be changed ta prevent
overworking of the motor with resulting burnout."
As noted above, the blade angles are not given in the technical
manual. Licensee Procedure HP-VA-7, Revision 6, dated
October 28, 1985, "VA-7C/7D Fan Blade Checks / Adjustment," shows
the blade angle as 26.5 degrees for Fan Units VA-7C and VA-70.
Licensee engineers could not provide the NRC inspector with
documentation of the design calculations or justification for
using a blade angle of 26.5 degrees. The licensee could not
retrieve construction phase design calculations and
installation / test records substantiating that this angle was
correct or any 0 PPD design review documenting the acceptability
of this angle.
Similarly, the licensee was torquing the bolts which prevent a
change in blade angle-to 450 foot-pounds, though no value was
given in the vendor technical manual. The licensee could not
retrieve construction phase design records approving this torque
or a design review showing its acceptance.
In addition, the method of adjusting blade angle in the
procedure differed from that described in the vendor technical
manual'. The method in the procedure was subject to two
interpretations that would result in different blade angles.
Two licensee engineering personnel were unable to explain to the
NRC inspector the proper blade adjustment using the procedure.
Licensee Procedure PM-VA-2, Revision 5, dated December 22, 1986,
"VA-3A-3A/3B Fan Blade Checks / Adjustment," contains the same
differences from the vendor technical manual, except that the
licensee was using a blade angle of 21 degrees.
No construction records or design reviews were retrievable to
substantiate the blade angle and torque values being used by the
licensee for this procedure.
(3) Summary
a)
Failure to Identify and Retrieve Design Calculations for
Blade Angles and Bolt Torque for Safety-Reldted Fan
4
--
.
,
10
Units VA-3A, VA-38, VA-7C, and VA-70
The failure of the licensee to identify and retrieve
original design calculations for blade angles on
Fans VA-3A, VA-3B, VA-7C, and VA-70 is another example of
potential violation (285/8705-02), failure to meet
10 CFR 50, Appendix B, Criterion XVII.
b)
Failure to Have Documentation Substantiating Design Reviews
of Procedures Specifying Blade Angles and Bolt Torque for
Safety-Related Fan Units VA-3A, VA-3B, VA-7C, and VA-7D
Without the availability of original design calculations
for fan blade angles and bolt torques for Fans VA-3A,
VA-3B, VA-7C, and VA-70, determination of blade angles and
bolt torques was a design review.
The failure of the
licensee to provide documentation of required design
reviews for blade angles and bolt torques is another
example of potential violation (285/8705-04), failure to
perform a design review as required by 10 CFR 50,
Appendix B, Criterion III, and ANSI N45.2.11-1974.
e.
Vendor Technical Manuals
(1) Background
The NRC inspector reviewed licensee copies of vendor technical
manuals for the following significant safety related equipment
to determine the design maintenance base for maintenance of
these components, and review / updating in response to NRC Generic Letter 83-28.
Turbine driven auxiliary feed pump.
Electric auxiliary feed pump.
High pressure safety injection pump.
Raw water pump.
Pressurizer safety relief valves.
Reactor containment building ventilation and cooling fan
units.
(2) NUS Review
The above manuals, except for the pressurizer safety relief
valves manual, had been reviewed recently by the NUS Corporation
for OPPD as part of the licensee's response to Generic Letter 83-28.
The NRC inspector determined that no
. _ _ _ _ _ _ _ _ _ _
_
__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ - - - _ _ _
-
,
..
t
.
11
documentation existed that NUS identified:
(1) the vendor
recommendation for annual disassembly and inspection of the the
raw water pumps, and (2) that the manual for the reactor
containment building ventilation and cooling fan units did not
apparently contain the blade angles or bolt torque values for
the adjustable fan unit blades.
Further, the NUS review did not
identify components, such as sleeve bearings in the HPSI and
auxiliary feed water pumps, or antifriction bearings in
containment building ventilation and cooling fan unit motors
that have predictable design life cycles which are less than
plant design life; and hence, need to be evaluated for periodic
bearing replacement based on plant life-cycle component
operation, including required postaccident operation.
Containment building ventilation and cooling fan units were
required to operate for approximately 1 year following a design
base event (DBE).
This will remain an unresolved item
(285/8705-06) pending further review.
(3) NSSS Supplied Manuals, Lack of Review
The pressurizer safety relief valve manual did not contain
documentation that it had been reviewed in response to Generic Letter 83-28.
Licensee personnel stated that the original
program plan was for Combustion Engineering (CE) to perform the
review of vendor manuals that were in CE's original scope of
supply.
Economic considerations, apparently precluded this
action, and the licensee identified no other approved,
implemented, program plan for the review and approval of vendor
manuals originally supplied by CE.
(4) Controlled Vendor Technical Manuals and Licensee Technical
Manual Review
Licensee personnel stated that a vendor technical manual could
not become a " controlled" manual until it had a technical review
by 0 PPD engineering technical service personnel.
The licensee
estimated that there were approximately 600 technical manuals
for safety related equipment and components.
An estimated
540 (approximately 90 percent) had been reviewed by NUS.
The
remaining 10 percent were supplied by CE or were not available.
The licensee stated that no manuals had been reviewed by OPPD;
hence, there were no controlled vendor technical manuals.
(5) Licensee Position Status on Generic Letter 83-28 Regarding
Maintenance / Design Life
The licensee stated that the potential requirement for
replacement of component parts with a design life less than that
of the plant life had not been considered in their original
response to clarify Generic Letter 83-28.
Additionally,
safety related preventive type maintenance activities specified
'
.
12
in the vendor technical manuals, which were not presently
accomplished by Fort Calhoun Station, were not identified.
(6) Upgrading of Licensee Maintenance Practices and Procedures
The licensee could not identify a schedule, or a projected
target date, for upgrading plant safety-related maintenance
procedures and activities to meet either (1) equipment
manufacturer's specified maintenance, or (2) identifiable
required component replacement such as anticipation bearings and
electrolytic capacities, necessary to maintain the
safety-related design bases for Fort Calhoun Station, after
completion of commitments to Generic Letter 83-28.
This will
remain an unresolved item (285/8705-07) pending further review
during a subsequent inspection.
4.
Instrumentation Maintenance
Maintenance history, calibration records, qualification records,
procedures, work item tracking forms, and maintenance work request forms
were reviewed.
Four work activities in progress were witnessed to determine if the
technicians were following the appropriate maintenance procedures.
The
activities were:
Calibration Procedure CP-B/911; SG A Wide Range Level (Revision 10).
Calibration Procedure CP-B/912; SG B Wide Range Level (Revision 4).
Calibration Procedure CP-C/112C; Reactor Coolant Loop Cold Leg
Temperature (Revision 6).
Calibration Procedure CP-C/112H; Reactor Coolant Loop Hot Leg
Temperature (Revision 6).
A number of apparent discrepancies were noted during the performance of
these activities.
a.
Failure to Follow Procedures
The first discrepancy noted was that during the performance of
Calibration Procedure CP-B/911 and 912, the technicians turned a
bypass switch (RC2B) to the bypass position, which was a step that
was not provided for in the procedure. Questioning of the
technicians determined that this step was done as an extra precaution
on their part.
They felt that due to the close proximity of this
module to another module having the same appearance and function
(just a different transmitter), it would be too easy to work on the
wrong module.
Therefore, to ensure that no incorrect signals or
alarms resulted, they turned the controls for the second module to
_
_
^
.
p
-
13
bypass, even though it was not in an approved procedure, nor had it
been reviewed as an unresolved safety issue.
The fact that steps were being performed that had not been reviewed
by the cognizant engineering group was questioned.
Since the switch
repositioning had not been reviewed and approved as an authorized
change, the safety implications had not been assessed. The
technician's actions indicated that step-by-step procedural
implementation was not strictly adhered to.
Failure to-implement
procedures as written is a potential violation of Fort Calhoun
Station Technical Specification 5.8.1 (285/8705-08).
b.
Use'of A Defective Instrument
The second concern identified by the~ inspector was that one of the
instruments used for the performance of CP-B/911 and CP-B/912 did not
appear to be working properly in that one leg of the digital readout
was faint, or nonexistent.
The technician took readings using the
seemingly defective meter without paying any apparent attention to
the malfunction.
Only after questioning by the NRC inspector was the
, meter changed for one that worked properly. The technician indicated
- that since the meter did not appear to be working properly, its
calibration and operation wouid be verified.
As followup to the use
of the meter, the NRC inspector questioned the technical group about
the sequence to be followed should the instrument be found defective.
It was demonstrated that a methodology existed where a record of
procedures on which this instrument was used was in place.
Should
the instrument be identified as being defective the calibrations in
question could be repeated as required.
c.
Lack of Specified Instrument Accuracy
The third concern was how the I&C staff had established that the
accuracy of instruments used for calibration was within the accuracy
constraints of the system on which it was being used.
Questioning of
the technical and engineering staff determined that system accuracy
and calibration instrument accuracies had not been considered.
Failure to assure that instrument accuracy is adequate to meet
Technical Specification values is another example of potential
violation (285/8705-01), failure to provide criteria to permit
determination of acceptability in violation of 10 CFR 50, Appendix B,
Criterion V.
d.
Failure to Control Test Connection Points
The fourth concern was that the procedures identified voltage and
current readings to be obtained but did not indicate how or where
they would be takee
This practice did not assure uniformity, or
acceptability of the readings.
This is an example of potential
violation (285/8705-01), failure to provide criteria to permit
- ..
.
s
14
determination of acceptability in violation of 10 CFR 50, Appendix B,
Criterion V.
e.
Training of Plant Personnel in Electrical Equipment Qualification (EEQ)
The fifth concern was that the personnel (electrical, I&C, and QC)
whose responsibility was.to maintain equipment qualification did not
appear to understand the requirements of EEQ.
This concern was
discussed with a number of personnel from each of the applicable
organizations and.the general impression was that the people whose
responsibility was to maintain qualification had not received all of
the training necessary on qualification, how the requirements were
identified and what steps had to be performed to ensure qualification
was maintained.
The NRC inspector's concern of personnel training
was discussed with the training department personnel and it was found
that the training program was under development.
This will remain an
unresolved item pending further review.
(287/8705-09)
f.
Control of Safety-Related Requirement Parts
The sixth concern identified involved the control of qualified
replacement parts.
The concern was with the method used by the
licensee for control of CQE (Critical Quality Equipment) qualified
replacement parts.
The current method for storing CQE materials is
that each department (Electrical and I&C) maintains a CQE storage
area. When during the performance of a task, replacement parts are
needed, the craftperson goes to the storage area and obtains the
parts believed to be necessary and then signed in a log that the
parts were removed.
The storage area was not manned constantly.
The
concern included the return of parts that were removed for a job and
then found to be unnecessary.
The craftpersons were questioned as to
what procedure would be followed in this case.
The response in
general was that it was not clear what should be done.
Discussions
with plant management indicated that a procedure existed for the
return of equipment.
The procedure was not reviewed; however, it
appeared that personnel had not been adequately trained in the
control of qualified spare parts, technical approval of parts was not
specified, and shelf life controls were not identified.
This will
remain an unresolved item (287/8705-10) pending further review during
a subsequent inspection.
g.
Re.tew of I&C Maintenance Orders (M0s)
Eleven completed safety-related M0s were reviewed to ensure they were
completed, reviewed, stored as quality documents, all discrepancies
resolved, and the appropriate work performed.
During the completed M0 review, a concern was identified which
involved the maintenance performed on M0 No. 41 861204.
This
maintenance was for replacing a potentiometer and and amplifier
module for AI-31C-CW15-B1 and then performing a Surveillance Test
_
' *
.
15
Procedure ST-RPS-7.
The concern was that the procedure was not clear
yet the procedure had been completed.
The licensee researched the
,
'
files and located a signed off copy of the procedure and provided it
for review, which satisfied the NRC inspector's concern.
5.
Electrical Maintenance
a.
In-Process Review of Electrical Maintenance
Two maintenance action items in progress were witnessed to ensure
that the electricians performing the maintenance tasks followed the
appropriate maintenance procedures.
These tasks were performance of
D. C. transfer switch surveillance testing and A. C. circuit breaker
testing. Testing was performed in accordance with the following
procedures:
CP-Tie Breaker, Tie Breaker Calibration Procedure (Revision 3).
ST-DC-3, D. C. Transfer Switch (Revision 10).
(1) Tie Breaker Calibration
During the performance of "CP-Tie Breaker" maintenance, two
concerns were identified.
(a) Use of Incorrect Procedure
The first concern involved the procedure that was used to
perform the testing. When the testing was started, it was
begun by using a " Procedure CP-Main." This procedure was
for testing main breakers instead of tie breakers.
The
main breaker procedure was used until overcurrent testing
was performed, at which time the trip settings were found
to be set almost 100 seconds early on all three phases.
The electricians performing the test adjusted the setting
en one phase, when it was decided that something w s wrong.
An electrical supervisor was contacted who in turn
determined that the incorrect procedure was being used.
The correct procedure was obtained, and implemented, and
the testing was completed.
Failure to implement the proper
procedure is another example of potential violation of
Fort Calhoun Station Technical Specification 5.8.1
(285/8705-08).
The licensee indicated that the appropriate
procedures would be reviewed to prevent recurrence of this
problem.
(b) Use of Incorrect Vendor Technical Manual
During the performance of CP-Tie Breaker maintenance, it
was noticed that the secondary contacts on the tie breaker
had some uneven arcing marks.
It was not clear that such
arcing was in accordance with the vendor's technical
.__
_
.
_ . . -
. - . - - . .
_.
_ -
,
t
'
16
manual.
Licensee personnel were requested by the NRC
inspector to provide a copy of the technical manual to
verify the requirements.
Licensee personnel provided a
copy of a technical manual which was generic and not
specific to the breaker being tested.
The generic manual
did not discuss the contacts and the adjustment
requirements in detail.
The NRC inspector reviewed the
generic technical manual and referred the licensee
personnel to another manual which was the applicable
manual.
The electricians then found the correct manual.
The contact requirements'were determined to be in
compliance.
The licensee does not appear to have adequate
control of the technical manuals.
This finding was
corroborated when crafts personnel (I&C and Electrical)
were questioned about the control of technical manuals.
They indicated that at times the technical manuals may not
be up-to-date, correct, or locatable.
This will remain an
unresolved item (285/8705-11) pending further review during
a subsequent inspection,
b.
Review of Completed M0s
Eleven completed M0s were reviewed to ersure they were completed,
reviewed, stored as quality documents, all discrepancies resolved and
the appropriate work performed.
During the review, several concerns
were identified.
One concern involved the review of maintenance
records that were completed during or before 1984.
The review of the
completed maintenance found that in some packages the work
description was not detailed enough to determine the work performed,
not all applicable documents were included in the package, EQ
tracking documents could not be located (see M0 No. 840858), and it
was not clear that required inspections had been performed.
This
concern was discussed with licensee management.
The discussion
determined that the MO control procedures had been modified to
prevent these type of concerns.
A number of M0s dated 1986 and 1987
were reviewed to verify that the modified procedure was adequate
enough to prevent similar types of anomalies. The review of later
M0s did not identify any further concerns,
c.
Accomplishment of Meggering
Additional concerns were identified concerning meggering of
electrical equipment as follows:
A number of procedures (examples are PM-EE-VA3/7, Revision 0 and
PM-MOV-1, Revision 3) indicated that meggering was to be
accomplished; however, the instrument and/or the voltage of the
instrument was not provided.
- -
-
-
.
.
- -
.
.,
,
t
17
A number of procedures (examples are PM-EE-VA-3/7, Revision 0;
i
PM-EE-1-13, Revision 5; and PM-EE-3.0, Revision 0) do not
specify meggering acceptance criteria.
A procedure for meggering reactor containment ventilation and
cooling fan unit motors was not identified during the
q
inspection.
Failure to identify meggering equipment required to
f
provide acceptance criteria and to megger containment
ventilation and cooling unit fan motors is an example of
potential violation (285/8705-01), failure to provide criteria
to permit determination of acceptability in violation of
10 CFR 50, Appendix B, Criterion V.
d.
Replacement of Safety-Related Agastat Relays
The licensee was questioned by the NRC inspector about replacing
relays at the end of their qualified life.
A replacement schedule
had not been identified.
The licensee is to discuss this issue with
,
Agastat and resolve it in accordance with the vendor's~
<
recommendations. This will remain an open item pending further
review during a subsequent inspection.
(285/8705-12)
e.
Maintenance of ASCO Solenoid Valve HEV-386-20
One concern was a task description for preventive maintenance for
maintaining qualified life on ASCO Solenoid Valve HCV-386-20.
The
task description indicated that the work was to refurbish the
solenoid valve; however, the procedure that was referenced (SP-50V-1)
did not discuss refurbishing the valve but discussed exercising it.
The licensee was questioned about this discrepancy.
The response
indicated that the requirement was to exercise the valve and not.
refurbish it.
The refurbish description was in error.
The licensee
further stated to indicate that this valve had been removed from the
o
equipment qualification program.
f.
Calibration of Safety-Related Relays
Relays were calibrated by System Protection, an offsite group from
0 PPD.
No concerns were identified from this review.
g.
Electrical Maintenance Procedures Lacking Acceptance Criteria
The NRC inspector reviewed the following electrical maintenance
procedures which did not include acceptance criteria, for the
'
tightening, or verification of tightness of threaded electrical
connections such as tie bolts, terminal bounds, and mounting bolts,
and in some cases voltages for meggering.
MS-EE-4.1, Revision 1, January 1,1980, " Maintenance Standard
for 480 Motor Control Center Draw-Out Unit."
_-
--
_ _ _ _ _ _ _ _ _ .
..
,
18
,
PM-EE-1.1, Revision 2, March 12, 1987, " Type AM-4.16-250
Magne-Blast Circuit Breaker."
PM-EE-3.0, Revision 0, October 13, 1978, "AKD-5 Low Voltage
Swi tchgear. "
PM-EE-3.2, Revision 1, dated October 27, 1978, " Types AK-2-25
and AK-2-50 Circuit Breaker."
Failare to provide acceptance criteria is another example of
potentiai violation (285/8705-01) regarding 10 CFR 50, Appendix B,
Criterion V.
h.
Lubrication of Containment Cooling Fan Motors and Limitorque Operators
The licensee was lubricating Reliance Motors in containment on an
18-month (refueling outage) in lieu of 3-6 month periodicity, and had
used MARFAK lubrication in lieu of Nebula EP-0 in Limitorque
operators in containment.
This will remain an unresolved item
pending further review during a subsequent inspection.
(285/8705-13)
1.
Unapproved Use of Mixed Greases in Electrical Equipment
Qualified (EEQ) Limitorque Operators for Safety-Related Valves in
the Reactor Containment Building
The NRC inspector reviewed the Fort Calhoun 1987 Outage Working
Schedule of maintenance activities.
Included on the schedule was the
maintenance activity " change out grease to Nebula EP-0" for the
following EEQ valves in containment:
L
HCV-383-4-0
F
HCV-347-0
'
HCV-348-0
HCV-331-0
'
HCV-383-3-0
HCV-333-0
The licensee indicated that these Limitorque operators contained a
mixture of Nabula EP-1 and Marfak greases which they considered
qualified even though such practice contradicted the specific
requirements of the applicable Limitorque Type SMB Instruction and
Maintenance Manual, Bulletin SM81-828.
The document used as
'
justification was Bolt and Associates letter dated June 17, 1986,
11 ring Marfak with Nebula EB or (Sun Oil Company) Prestige 50 EP."
i
The letter basically referenced a 1961 Rock Island Arsenal Laboratory
lorhnical Report, "Compatability of Lubricating Grease." This report
covered tests of unnamed, generic type greases and concluded that:
Compatibility was determined by the extent of hardening or
softening exhibited by the binary mixture after a 10,000 stroke
..
. .
.
.
.
,
- _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _
_ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . - - -
e.
.
19
6
worker test as compared to the extent of hardening or softening
exhibited by the components when subjected to the same test.
Incompatibility can occur when greases of the same type are
mixed together. A grease made by one manufacturer may behave
differently from the same type of grease made by another
manufacturer.
It was found that grease compatibility could not be predicted
accurately from a mere knowledge of tile thickener and fluid
type, and the safest procedure to follow is to avoid mixing
greases of different types.
The letter begins with a statement that no problem exists with
Limitorque operators because of mixing, since incompatibility is
likely to result in " softening" (a de-hydrolyzation or
de-saponification'of the grease increasing its fluidity).
The letter
states that this would be no problem since the grease is contained in
the gear box.
Adverse chemical reactions (bearing corrosion, etc.),
reduction or loss of extreme pressure (EP) characteristics, or
separation of oil from the mixture, all of which may result from
incompatibility of the greases, were not addressed.
The letter summarizes with a paragraph which states:
"I do not wish my comments on mixing greases to be construed as
endorsing such a practice.
I agree with Limitorque
(Bulletin SMBL-80) that this should not be done as a matter of
policy.
It is not a good idea, particularly if the greases
mixed involve different gelling agents, as is true with the
situation at hand. The best practice is to pick an approved
grease (Nebula is the only one approved for everything) and stay
with this product down the road.
If more than one supplier is
desired or as, other products are qualified, I would keep with
materials containing at least the same gelling agents."
Marfak and Nebula EP greases have different gelling agents.
Limitorque has stated that qualification of their operators in
containment is contingent upon the sole use of Exxon Nebula EP
greases.
Failure to use the required grease is a potential violation of
10 CFR 50.49 (285/8705-14).
5.
Exit Interview
The NRC inspector met with licensee representatives (denoted in
paragraph 1) on April 10, 1987, and summarized the scope and findings of
inspection activities.
The NRC senior resident inspector was present.
.-
_ _ .
-
-
.
..