U-600427, Final Deficiency Rept 55-85-14 Re Torquing of Cover Plate Screws on Namco EA170 & EA180 Limit Switches.Initially Reported on 851227.Field Engineering Change Notices 13714 & 13715 Issued to Provide Addl Engineering Instructions

Final Deficiency Rept 55-85-14 Re Torquing of Cover Plate Screws on Namco EA170 & EA180 Limit Switches.Initially Reported on 851227.Field Engineering Change Notices 13714 & 13715 Issued to Provide Addl Engineering Instructions

ML20151U004
Person / Time
Site:	Clinton
Issue date:	01/25/1986
From:	Hall D ILLINOIS POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
55-85-14, U-600427, NUDOCS 8602100431
Download: ML20151U004 (5)

Text

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_. ; e hpg U-600427 1A.120 y_ ~ L14-86( 01-25 )-L lllLINOl8 POWER COMPANY IP CLINTON POWER STATION. P.O. BOM 678, CLINTON. ILLINOIS 61727 -

January 25,-1986 Docket No. 50-461 Mr'. James G. -Keppler

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? Regional Administrator:

_ Region III- .

U.S. Nuclear Regulatory Commission 799-Roosevelt Road 1 Glen Ellyn, Illinois' 60137 Subj ect : . Reportable 10CFR50.55(e) Deficiency 55-85-14: Torquing of Cover Screws for EA170 and EA180 Limit Switches

Dear.Mr. Keppler:

.On December 27,.1985, Illinois Power (IP) verbally notified Mr. Gouldemond, U.S. NRC Region III (Ref:-IP Record of Coordination Y-32699, dated December 27, 1985) of~a potentially reportable condition under the provisions of 10CFR50.55(e) concerning the torquing of cover plate screws on NAMCO EA170 and EA180 limit switches. Torquing of the

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cover plate. screws associated with these' limit switches had not.been performed during-installation, terminations, or

-start-up testing. Illinois Power has reviewed and evaluated:

the findings associated with this investigation and has determined that the failure to torque the cover plate screws on-the NAMCO limit switches would invalidate the NAMCO limit switch environmental qualification. 'An extensive engineer-ing evaluation would be' required to determine the effect of i' the identified deficiency and the adequacy of these limit switches to perform their required safety function in their presently installed condition. On this basis the issue is considered to be reportable under the provisions of

,, 10CFR50.55(e).

Our investigation of this matter is complete. This

. letter represents a final report in'accordance with'the k requirements of 10CFR50.55(e). ~ Attachment A provides the details of.our~fnvestigation.

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U-600427 1A.120 L14-86( 01-25 )-L We trust that this final report.provides you sufficient' background information to perform a general assessment of this reportable deficiency and adequately describes our overall approach to resolve-this issue.

Sincerely yours, D. P. Hall Vice President RLC/jky -

Attachment cc: NRC Resident Office.

Director, Office of I&E, US NRC, Washington, DC 20555 Illinois Department of Nuclear Safety INPO Records Center

i U-600427

-1A.120 L14 -86 ( 01 ; ' 25) -L Attachment'A Illinois Power _ Company Clinton Power Station-Docket No. 50-461 Reportable 10CFR50.55(e)~ Deficiency 55-85-14:

Torquing of Cover Screws for EA-170 and EA-180 Limit Switches-Final Report Statement of Reportable Deficiency / Background

' Illinois Power-Quality-Assurance' Department (IPQA) identi-

fied a potentially reportable condition under the provisions of 10CFR50.55(e).concerning the torquing of cover plate screws on NAMCO EA170 and EA180' limit switches. The torquing require-ments for NAMCO limit switches are traceable to IP-Equipment Qualification Package EQ-CL008. Package EQ-CL008 contains Installation Instruction drawings EA189~90006, EA189 90008, and' EA189 90009, which require twenty (20) inch-pounds of torque be.

applied to-the top cover screws in a staggered pattern.

Torquing of the cover plate screws has not been performed

'during installation, terminations, or start-up testing.

Investigation Results A review was performed of the Final Safety Analysis Report (FSAR) Table 3.11-1 and the Equipment Qualification Coordinator's data base (SQWK.DBF) to identify those NAMCO limit switches requiring torquing of the cover screws. During the course of this review it was determined that the~ torquing deficiency applies only to NAMCO EA180 and EA740 limit switches, since the EA170 limit switches are used only in mild environmental zones and do not require environmental qualification. Therefore, the torquing requirements contained within qualification' package EQ-CL008 do not apply'to NAMCO EA170 limit switches.-

A review-was performed to identify procurement specifi-cations and vendor Installation and Operation Manuals (IOMs) associated with NAMCO limit switches qualified for harsh-environments. Of-the IOMs identified and reviewed, none contained information regarding the torquing requirements associated with.the NAMCO limit switch cover screws. Although the torquing requirements were not contained in the 10Ms, all NAMCO EA180 and EA740 limit switches are supplied with an adhesive tag containing installation instructions which include

. torquing requirements. These tags are required to be removed upon " final installation" for equipment qualification purposes.

The installation instructions contained on these tags were not incorporated into construction, start-up or maintenance procedures.

Page 1 of 3

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K' _ g U-600427-1A.120 L14-86( 01-25 )-L Attachment A

,v (continued)

Further review' identified that although Sargent &-Lundy

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(S&L) had reviewed the NAMCO equipment.for engineering require-ments to support equipment environmental qualification, no

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engineering; instructions had been issued, nor had any request

- been documented for the required engineering instructions.

Illinois Power Nuclear Station Engineering Department

(NSED)

conducted a sample review of other Equipment

. Qualification Reports 1(EQRs), .IOMs, maintenance manuals, engineering-instructions and:other on-site documentation, to

. determine.if the subject deficiency was an isolated occurrence.

This review did not identify any similar concerns.

Corrective Action On January 14, 1986, Sargent & Lundy. issued-Field

-Engineering Change Notices (FECNs)lNos. 13714 and 13715.which

provide'the required engineering instructions regarding torquing and installation instructions for NAMCO limit switches.

'as specified in the Environmental Qualification-packages ~for EA180 and EA740 limit switches. For remedial corrective

-action, NSED issued 173 Maintenance Work Requests (MWRs)?to implement the engineering instructions set.forth in FECNs'13714 and.13715. To preclude recurrence of this deficiency, FECNs 13714 and 13715 have been posted against the installation specification / contract (K-2999) and the associated vendor manuals. The corrective action associated with this matter is i

scheduled for completion by January 31, 1986.

4 i Root Cause

' Illinois Power's investigation into this matter has determined that the root cause of the identified deficiency was that instructions regarding the' torquing requirements for NAMCO EA180 and EA740 limit switches were not issued by NAMCO in a manner consistent with normal industry practice. Instead of listing torque requirements in published installation /oper-

.ation/ maintenance instructions, NAMCO issues torque

_ requirements on. temporary stickers adhesively ~ attached to the

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j i' limit 1 switches in a non-qualified manner. .Sargent & Lundy's program which governed the review of the NAMCO technical V

information for these limit switches was not developed for detecting this type of departure from normal industry practice.

As'a result, S&L did not issue engineering instructions regarding the torquing requirements contained in the environmental qualification package for NAMCO EA180 and EA740 F limit switches.

i Page 2 of 3

r i; N U-600427 1A.120 Ll4-86( 01-25 )-L Safety Implications / Significance Illinois Power's-investigation of-this matter is complete'.

Illinois Power.has' reviewed and evaluated the findings

• associated.with this investigation and has determined.that the failure 1to: torque the cover plate screws on the NAMCO limit switches would invalidate-the' NAMCO limit switch environmental qualification.. An extensive engineering evaluation would be required to determine the effect.of the identified deficiency; and the adequacy of these limit switches to perform their .

required safety function in their presently installed condi--

tion. On'this basis, the issue is considered to be reportable runder the provisions:of 10CFR50.55(e).

Page 3 of 3