ML20236D332

Insp Repts 50-348/87-11 & 50-364/87-11 on 870511-22 & 0601-05.Major Areas Inspected:Implementation of Licensee/ Vendor Interface Program,Procurement Program & Specific vendor-identified Technical Issues for Applicability

ML20236D332
Person / Time
Site:	Farley
Issue date:	07/24/1987
From:	Mcintyre R, Merschoff E Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236D276	List: ML20236D273 ML20236D332
References
50-348-87-11, 50-364-87-11, IEIN-83-11, IEIN-84-83, IEIN-85-074, IEIN-85-74, NUDOCS 8707300412
Download: ML20236D332 (28)

See also: IR 05000348/1987011

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it' Report.ho.~:

60-348/87-11 and 50-364/87-11

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Licensee:

Alabama Power Company.

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Post Office Box 2641.

Birmingham,. Alabama.'35291-0400

Docket Nos.:

50-348 and.50-364

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License Nos.:

NPF-2 and NPF-8.:

Facility Name:

Joseph M. Farley:huclear' Plant

Units 1 and 2

Inspection Conducted:

'May 11-22 and June 1-5, 1987'

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Lead Inspector:

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f,*. Richard P. McIntyre

'm Leader,.VIB, DRIS

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. Inspectors:

J. B. Jacobson, Electrical. Engineer

P. J. Prescott, Reactor Engineer

J. J.:Petrosino, Quality Assurance Specialist-

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D. R. Lasher, Electrical Engineer

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Consultant:

Paul Farron, Nuclear Engi ers and Consultants, Incorporated'

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Approved:

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Ellis W. Merschoff,

ng Branch Chief, Division

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of Reactor Inspe

n and Safeguards, Vendor?

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Inspection Branc

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G707300412 870727

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SUPhARY

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SJco e: This was an announced inspection that'was conducted at the Farley Nuclear

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Plant (FNP) Units 1 and 2, to' verify the implementation of the Licensee / Vendor

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' Interface Program, to review FNP's Procurement Program, and to review specific-

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vendor identified technical issues for applicability at FhP.

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Results: The results of the inspection show considerable weakness in the areas.

of procurement and vendor interface. The Alabama Power Company vendor interface

program appears to lack the rigor and formality necessary to achieve its

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' intent. Several examples are cited in this report where, although Alabama-

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Power Company had been made aware of'a problem by a vendor, complete, effective,

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and timely corrective action was not taken.

In addition, significant deficiencies

were found in Alabama Power Company's procurement of both safety-related and

commercial: grade' components, resulting-in hardware being installed in safety-

related. applications which may not have been capable of performing its intended-

function. These findings, when considered along with the improper installation

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of the service' water battery rack and the failure to report to the NRC the

inoperability of 2 control room fire dampers and 15 cracked battery cells in

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both trains of the auxiliary building batteries inc'icate a lack of systematic

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attention to detail. While no instances were found where Alabama Power Company.

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failed to receive information as a result of its lack of a formal process to

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periodically contact key vendors, a number of cases were identified where the

information had not been obtained from the vendor or VETIP but was obtained

fortuitously from other sources.

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REPORT DETAILS

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Persons' Contacted':

Alabama Power Company

• J. D. Woodard, Plant Manager

• W.'B. Shipman, Asst.. Plant' Manager, Support

• L. W. Enfinger, Admin. Manager

• L. A._. Ward, Maintenance Manager

• J. K. Osterholtz, SAER Supervisor.

• C. D. Nesbitt, Technical Manager

D. N. Morey, Asst. Gen. Manager, Operations

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• L. M. Stinson, Modifications' Manager

• T._-W. Cherry, I&C Supervisor

• M. C. Carstensen, QC Engineer

• R. M. Coleman, Systems Performance Supervisor

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• E. L. Stephenson, SEE-IN Coordinator'

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• B.:R. Yance, Electrical Maint. Supervisor

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• J. T. Brantley, GPE Supervisor

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• H. R. Garland, Mechanical Maint. Supervisor

• R. D. Hill, Operations Manager

L. S. Williams, Training Manager

B. L. Moore, Operations Unit Supervisor-

F. V. McKinney, Switchborad Operator

D. Mansfield, Birmingham

'C. Buck, Dis. Eng. Supervisor

G. J. Terry, Section Supervisor

J. Garlington, Birmingham

G. Grove, Procurement / Birmingham

R. H. Marlow Technical Supervisor

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R. G. Berryhill, Systems Performance Manager

R. Yance, Electrical Maintenance Supervisor

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R. Harding, Electrical Maintenance Forman

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'M. Firestone, Warehouseman

D. Canady, Shift Supervisor

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W. Cumbee,_ Shift Supervisor

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J. Upchurch, Shift Supervisor

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K. Jones, Material Supervisor

C. L. Buck, Disc. Eng. Supervisor - PMD

R. B. Smith, PMD Engineer:

L. D. Huey, S.P. Engineer

W. M. White, S.P. Engineer

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The inspectors also contacted or interviewed other licensee personnel from

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operations, maintenance and I&C, and the technical staff.

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• Attended exit meeting.

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Nuclear Regulatory Commission

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W. H. Bradford, Senior' Resident: Inspector 1

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.*H.:C. Dance,' Chief, Reactor ProjectsfSectionL1B,!RII

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s*L.LP. Modenos, Project: Engineer, RII:

L*B;'K. Grimes, Deputy Director, Division of Reactor Inspection.and:

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Safeguards <

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• E. W. Merschoff,' Chief, Vendor Inspection Branch

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E.-A.. Reeves' Project Manager, NRR '

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• G. Requa TProject Manager, NRR

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• Attended? exit meeting.

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2.

Exit Interview

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The inspection scope and findings were summarized and discussed on

June 5, 1987 with those individuals identified in Section 1 above.

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inspectors described the areas inspected and discussed the inspection

findings described below. The licensee did not identify 3s proprietary

any.of the materials provided.to or reviewed by the inspectors during

this inspection.

3.

Licensee Action on Previous Enforcement Matters

This subject was not addressed in this inspection.

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Unresolved Item 50-348, 364/87-11-05

Unresolved Issues

One unresolved issue was identified concerning the use of two replacement

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circuit breakers procured commercial grade and installed into environmentally

qualified Motor Control Centers (MCC) 1U and 20 with no analysis or

documentation provided to establish similarity to the original MCC breakers.

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The equipment qualification (EQ) aspect of these circuit breakers will be

reviewed during a future EQ inspection.

5.

Licensee / Vendor Interface

A.

Vendor Technica1'Information

The inspectors reviewed the Alabama Power Company (APCO)/FNP vendor

information evaluation and tracking system with respect to the recei

and processing of technical information provided by Westinghouse (W)pt

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General Electric (GE), Colt Industries, the Institute of huclear -

Power Operations (INPO), the NRC, and vendors of safety-related

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equipment and components.

APCO, the licensee, has developed a Vendor Equi 3 ment Technical

Information Program (VETIP) structured around tie Nuclear Plant

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Reliability Data System (NPRDS) and the Significant Event Evaluation ~

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and Information Network (SEE-IN) programs. APC0 stated that this

program, in addition to the formal contact programs established by

APC0 with W (NSSS supplier), Colt Industries (emergency diesel

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generator supplier), and GE, is an efficient and realistic approach

to ensure that vendor equipment problems are recognized and evaluated

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and corrective actions are taken. APC0 has not established a contact

program with other vendors of key components other than the three

mentioned above, nor does it maintain a list of key components.

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Procedure Review

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FNP Administrative Procedure FNP-0-AP-65, Revision 4, "FNP Operating-

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. Experience Evaluation Program," assigns plant staff responsibilities

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and identifies functions performed to ensure compliance with operating

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experience requirements described by. Generic Letter 83-28, Section'2.2.2.

This procedure also defines what vendor information falls under the

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scope.of.this program, how it is acted on, and by whom.-

The FNP "SEE-IN Procedures Manual," FNP-0-M-028, Revision 3, provides

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instructions for processing and communicating operating experience

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information required to implement the FNP. Operating Experience-

Evaluation Program described in FNP-0-AP-65. These two documents

' describe the FNP Operating Experience Evaluat on Program, what it

consists of, and how it is accomplished.

Tne program provides for

formal review and processing for both industry and in-house events

and the information related to these events.

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This program is implemented at both APC0's headquarters in Birmingham,

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Alabama and at the FNP. The huclear Support Group in the Birmingham

office receives regulatory and industry information and. coordinates

the evaluation and disposition of NRC bulletins, NRC generic letters,

and Westinghouse Owner's Group information. The Nuclear Sup) ort Group

also performs the initial screening of controlled vendor tec1nical

information and forwards all applicable information to the FNP.

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site.

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Site activities are primarily coordinated through the Systems

Performance Group and the Technical Group. The Systems Performance

Group has prime responsibility for. coordinating and acting on.

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industry communications, and the Technical Group handles correspondence

relating to regulatory issues. The vendor interface programs and

industry equipment and component issues are primarily the responsibility

of.the Systems Performance Group.

The vendor and equipment issues that fall under the purview of the

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System Performance Group are addressed through the FNP SEE-IN program,

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The SEE-IN program, managed by INPO, screens, evaluates, and

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disseminates pertinent information concerning problems of the nuclear

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industry to utilities who are INPO members.. The SEE-IN coordinator

at FNP oversees and directs all SEE-IN related activities, including

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the Operating Experience Evaluation Program, Nuclear Network, NPRDS,

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and VETIP. The Coordinator also receives controlled and unsolicited

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vendor technical information.

Industry events are defined as those occurrences or problems that are

reported to FNP from outside sources. These sources include'INP0

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(significant operating experience reports [SOERs], and significant

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event reports SERs), Westinghouse (letters and technical bulletins),

GE (letters and service advisories), Colt (vendor bulletins), various

vendors.(bulletins and notices), and the NRC (information notices,

bulletins, and generic letters).

NRC bulletins and generic letters

are processed by the Nuclear Support Group at the Birmingham office;

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NRC information notices are processed by the Technical Group at FNP.

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Information received from the remaining services mentioned above is

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processed by the Systems Performance Group at the FNP site..

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The Systems Performance Group has overall responsibility for the

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disposition and status tracking of vendor information which it

assigns as action items. This includes what is called controlled

vendor technical information at FNP, that is, information from the

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three vendors (W), GE, and Colt) with whom formal interface )rograms

have been established, as well as any unsolicited vendor tecmical

.information (UVTI).

UVTI consists of technical information received

from vendors with whom no formal contact programs have been

established.

UVTI has no designated recipient within the utility.

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Besides processing information from INP0, controlled vendors, and

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unsolicited vendors, the' Systems Performance Group also reviews and

processes operating experience from in-house events, that is, those

that occur at FNP.

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The processing of this information consists of (1) receipt of the

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information from the various sources, (2) screening of the informa-

tion for applicability at FNP, (3) evaluation and routing to the

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appropriate personnel when input is required, and (4) completing,

and tracking the required corrective action to completion.

While reviewing FNP-0-AP-65 the inspectors noted that there was no

mention of reports of defects submitted by vendors pursuant to

10 CFR 21.

Incoming 10 CFR 21 (Part 21) notifications from vendors

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are not identified any differently than any other vendor-related

correspondence and are not tracked separately'at FNP. The inspectors

also reviewed G0-NG-22, Revision 3, " Procedure for Nuclear Maintenance

Support Conduct of Operations." This procedure sets the guidelines

used in handling the vendor technical information received by the

Nuclear Support Group in Birmingham. This includes incoming Part 21

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notifications that go through an initial screening process and then

are transmitted to the Systems Performance Group at FhP. Just as at

FHP, these Part 21 notifications are treated no differently than any

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other vendor technical information. The inspectors noted that since

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vendor Part 21 notifications indicate a potential for a substantial

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safety hazard to exist, it has been their experience that incoming

vendor Part 21 notifications were identified and tracked separately

from other vendor technical information.

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The inspectors also reviewed FNP-0-AP-18, Revision 4. " Conduct of

Operations - Technical Group." This is the procedure used by the

Technical Group for processing NRC IE information notices. Section

5.2.1 states, " Maintain a tracking system and track written commit-

ments relating to NRC requirements," and Section 5.2.10 states,

" Process I and E Notices and coordinate plant actions required by

these documents." This is the extent of the guidelines given the

Licensing.Section of the Technical Group for accomplishing this task.

The Technical Group was reviewing and tracking NRC IE notices, but

there was no documented guidance on how to perform these tasks.

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~T'e.F P'institided temporary procedure change,1TCN 4A to FNP-0-AP-18

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on June 2,i1987. This change providedl additional guidance on the-

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preparation of. responses _to IE notices to ensure consistency. FNP.

personnelt stated.this temporary change =would.become. permanent when

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the.next.revisionLwas issued.

APC0 has developed ties to otiher . vendors,-as will be described:later

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in'other: sections of the report,-because of potential hardware problems

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that the SEE-IN program has not. addressed. As a result of this

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inspection :APC0.. contacted Terry Turbine, Anchor / Darling Valve Co.

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' Henry Pratt Co., Amerace Corp. (Agastat relays), GNB Batteries,.Inc.,

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Satin American Co.,rColt Industries, Bechtel-Corp.,'Telemecanique.Inc.,.

Siemens Allis, Inc., Limitorque Corp., Namco Control Inc.,-and:

Target Rock Corp. to investigate; potential hardware deficiencies.

Many of'these problems could have been resolved at an earlier date

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(if.a more. rigorous vendor interface program had been established.

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Ths'NRC inspectors reviewed the. receipt, processing,and evaluation

of W Technical Bulletins (WTBs) at FNP since the licensee began

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.doclimenting this process after the issuance of Generic Letter 83-28.'

The inspectors' verified that past WTBs had been received'at.FNP. which

was stipulated when formal contact'was set up with W in11 ate 1983.

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Thel inspectors reviewed the disposition of.14 WTBs from.'1977 to the"

present to confirm that evaluations at FNP had'been performed land;

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documented by the Systems Performance Group.

The WTBs requested'

by the~NRC inspectors had all been evaluated and' acted on properly.

It appears that the APC0" interaction with W is adequate

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Interface With'Other Vendors

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.The NRC inspectors reviewed the1 vendor technical information received

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from sources other than W'.

This included -information from the

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-othercontro11ed: vendors 7GEand' Colt,aswellasnumerousexamples

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categorized as UVTI.

ThisLincluded :10 GE Service Advice-Letters, 6

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Colt Service' Information Letters,16 documents pertaining to specific'.

vendor issues:(including NRC IE information notices and INPO

'significant event reports (SERs), and 11 Part 21 notifications from-

vendors. Selected vendor it, sues and the action taken at FNP are

described below:

(1)' Henry Pratt Valves

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On May 30, 1985, Henry Pratt Co. issued a. letter to APC0

detailing problems with Henry Pratt valves using Limitorque

operators. The letter also stated that the NRC had received a

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Part 21 report on this problem; that is keys within the keyways'

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slipped on valves with operators located below the horizontal

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axis.'-As a result,. actuators became disengaged from the valve

shafts.

Pratt records indicated that 119 valves with Limitorque

motor operators were furnished to APC0 for use at-FNP. Similar

occurrences were identified in IE Circular 80-12.

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FNP personnel reviewed the 1985 Henry Pratt letter in conjunction

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with their response and actions related to IE Circular 80-12.

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This IE circular identified problems with Henry Pratt butterfly-

valves using Bettis Robotarm actuators that, when mounted below

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the horizontal, had the potential for the actuator-keys to fall.

out. The IE circular suggested that licensees inspect their

31 ants for similar mounting problems with the Henry Pratt

autterfly. valves using Bettis Robotarm actuators. Additionally,

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for those valves with this configuration the key / keyway was to

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be modified to prevent slippage. . In 1980 FNP personnel performed

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an inspection to locate all Henry Pratt butterfly valves located

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below the horizontal regardless of the actuator type. The plant

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personnel identified a total of seven Henry Pratt butterfly

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valves with this arrangement at Units 1 and 2.

Work requests

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were written to. inspect and stake the keys on the Unit 1 valves.

Because of these actions taken in 1980, the licensee elected to

take no immediate action on the 1985 notification and to act on

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this potential failure mechanism as part of the site Motor

Operator Valve Task Force.

Until the time of this NRC inspection,

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no actions had been taken.

During the review, the NRC inspectors were notified by the

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licensee that the original work requests in 1980 had been voided

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because it was assumed that three of these valves were of a

design that did not have a key and the remainder were designed so

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that the key could not fall out. The NRC inspectors requested

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that the licensee show them the valves during the final week

of the inspection.

Before the final week, maintenance personnel obtained a spare

Henry Pratt butterfly valve with a Limitorque H0BC operator to

determine how the operator was attached to the valve stem. The

arrangement of the spare valve was the same as that of three of

the valves in the plant. When the operator was disassembled,

-it was found to have a splined adapter that was keyed to the

valve stem.

Both the key and the splined adapter could fall

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out and lie on the top of the indicator plate and render the valve

inoperable. The four remaining valves with Limitorque H0BC

operators also were keyed but the arrangement was such that the

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key could not slip all the way out.

Plant personnel immediately inspected these seven valves in the

field and discovered that the spline adapter on one of the

Henry Pratt valves with an H0BC operator had already slipped

about three-quarters of an inch. The four remaining H0BC operated

valves had the keys rusted in place and showed no signs of

slippage. All seven valves are in safety-related systems, and

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the valves with H0BC operators are automatic isolation valves

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in the control room ventilation system.

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The licensee's response to.this issue was inadequate for the

'following reasons:

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There was not a timely disposition of the 1985 Henry Pratt

letter (no action in 2 years).

The licensee's perception that review and investigation in

1980 satisfied the immediate concerns was in error because

the investigation at that time was timited to butterfly

valves.

The work requests for corrective actions in 1980 were voided.

No changes have been made to maintenance procedures to modify.

key / keyways following maintenance.

This vendor issue is included in Potential Enforcement Finding

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50-348, 364/87-11-01.

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-(2) Anchor / Darling Check Valves

On June 11, 1985 Anchor / Darling Valve (A/DV) Company notified

the hRC, in accordance with 10 CFR 21, about problems with A/DV

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tilting disc check valves caused by failures of tack welded

hinge. pin bushings that can render the valve inoperable. APC0

was notified by a letter dated August 15, 1985 about these

problems and the recommended corrective actions. Similar problems

were identified in an FNP Licensee Event Report (LER) concerning

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the auxiliary feedwater system in 1983, and corrective action was

taken for the auxiliary feedwater system only.

Following receipt of the A/DV letter in August 1985, the FNP

Systems Performance Group recommended that the check valves

identified in this letter be inspected and modified in the same

way as the check valves in the auxiliary feedwater system.

The response sheet dated February 5, 1986 ctated that the

recommendations were implemented.

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When copies of the work requests were requested by the NRC

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inspectors, they discovered that the work had never been

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completed. Maintenance personnel promptly issued a memorandum

dated May 13, 1987 to reopen this issue and take corrective

action.

The licensee's response to this issue was inadequate for the

f011owing reasons:

The licensee failed to inspect the Anchor / Darling check

valves in other safety-related systems in 1983 when the

first problems were identified in the auxiliary feedwater

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system and failed to properly inspect the valves in 1984

following notification from Anchor / Darling of problems with

the hinge pin bushings.

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The licensee installed new bushings for the check ,alves

which were procured Code C (non-safety related) rather than

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safety related eventhough the licensee's LER in 1983

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identified the bushings as the cause of failure of the

safety-related valves.

.This vendor issue is included in Potential Enforcement Finding

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50-348,'364/87-11-01.

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.(3) Anchor / Darling Globe Valves

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APC0 was informed by Anchor / Darling by letter dated January 27,

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1984 of a potential problem with stem collar setscrews. APC0

contacted Anchor / Darling and determined that four valves of

this design were purchased for use at FHP. The NRC inspectors

verified that plant maintenance personnel performed corrective

action - setscrew locking - in accordance with the Anchor / Darling.

procedures and that the FNP Systems Performance Group Problem

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Report No. 7-025 documented the recommended actions and implemen-

tations. The licensee's response to this issue is considered

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adequate.

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(4) Pacific Valve

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Pacific Valve notified APC0 about a potential performance

problem with swing check valves in a service bulletin dated

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March 31, 1986. APC0 evaluated the problem and reviewed the

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FNP master valve list to determine if any of these valves were

in use at the site. No Pacific' Valve check valves were

identified at the site, and the screening of this issue was

completed on April 10, 1986.

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The NRC inspectors independently reviewed the 31 ant inventory

reports on Pacific Valve and determined that t1ese valves were

not in use at the site. The licensee's response'to this issue

is considered adequate.

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(5) Atwood-Morrill Valves

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On September 17, 1953 while securing steam to the Unit 2 turbine

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building as part of a normal shutdown, two main steam isolation

valves (MSIVs) initially failed to close under no-flow conditions.

The MSIVs were later closed, and two unrelated causes for the

failures were determined to be binding in the valve packing on

one valve and separation of the valve disc from the disc arm on

another valve.

The licensee contacted Atwood-Morrill, the vendor, and worked

with them in testing experimental packing arrangements and

modifications to the valves to prevent disc separation. FNP

Specific Event Evaluation 83-10 documents the causes of the

problems and corrective action taken by FNP personnel.

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licensee's response to this issue is considered adequate.

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D) Terry Turbinee

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The NRC inspectors reviewed Terry Turbine, APCO, and.

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correspondence and dispositions to determine the adequacy of

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(the utility's interface..with key vendors-in maintaining the

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Lauxiliary feedwater' system turbines and-associated pum

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Jturbines in~use at FNP are Terry turbines, Model'GS-2

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to Ingersoll-Rand pumps.,

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The' review of vendoricorrespondence received at thh FNP sit

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primary supplier (Terry Turbine).:- All:av

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ence:and APCO dispositions related to these issues were;also.

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reviewed.-~Most:INP0 issues were categorized as 'not bein

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applicable, as being received before;the development-of'APC

Because of the NRC. concerns with the

-!

from. Terry, APC0 contacted Terry and requested a211 st

~

applicable correspondence previously supplied-by Terry and

a letter:to Terry for confirmation of this listing.c_APC0;gav

the.NRC inspection team a copy of an Intra-company Cor

1

.

that' included a listing.of Terry Turbine letters received and

applicable APC0 dispositions.

issues previously~ unidentified at the site but later d

to have been received by the corporate office.

_

,

'Between the second and third. week of the inspection, the NR

'

inspectors met.with Terry service personnel in Windsor,.

m,

.Conne'ticut to identify all corres

c

-notifications and. product alerts) pondence (i.e., Part 21

L

that pertain to.the Terry

aturbines at FNP.

,

The Terry service personnel reviewed their

records'and verified that APC0 had'been sent'all appitcable.

correspondence.

. Terry personnel stated that in'1983 they and

developed a. list of all-nuclear plants utilizing Terry, turbin

including model and-. serial numbers'of the turbines.-

this listing for issuing service information.

,

Terry uses

' e

.Once they returned to FhP, the NRC inspectors reviewed

-dispositions as well as the completion of work.

revealed that all applicable. Terry correspondence was received

and APC0 has evaluated or is in the process of evaluating the

issues. The NRC inspection resulted in APC0 contacting T

!

Turbine and confirming that all applicable correspondence was

received.

the evaluation or taken actions 'concerning g

tack weld cracks as described in a Terry letter to APC0 dated

September 9, 1966.

,

'

The licensee's difficulties in determining what-changes affecte

,

I

of the problems which can arise from a les)

interface system.

.

,

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(7) Colt PC-2 Series Emergency Diesel Generator

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The NRC inspectors reviewcd APCO's deportability evaluation and

corrective action related to Colt Industries' Part 21 report

dated February 4, 1986, which identified a potential overspeed

q

trip problem associated with the Colt PC-2 series emergency

i

I

diesel generators. The Part 21 report'was initiated by Colt

after Public Service of New Hampshire (the licensee for Seabrook

Station) reported that one of its diesel engines had tripped

I

out on overspeed while it was being started for test purposes.

i

The overspeed trip seemed to involve the rack boost cylinder on

the control system.

To prevent further occurrences, Colt Industries recommended that

all Colt PC-2 series engines in nuclear service be modified to

positively vent the air from the rack boost cylinder, and its

associated shuttle valves, by making the source of that air supply

the pilot air lines that control the main air start admission

-

valves. The pilot air lines are controlled by solenoid valves

'

that receive the start signal from the control system. These

are three-way valves that positively vent the pilot air signal to

'

the atmosphere when the control system senses that the engine is

!

started.

!

On February 20, 1986 the FNP initiated a Systems Performance

Group problem report that showed that three of the emergency

diesel generators (EDGs) (1B, 28, and 1-2A) were affected by

the problem. The problem report also recommended that

-

maintenance personnel implement the EDG modifications as

recommended by Colt in the Part 21 report. On March 3, 1986,

the Maintenance Department issued three FNP production change

requests (PCRs) to modify the EDG air start p ping systems.

The PCRs had to be revised as a result of a d esel inspec-

tion and document review performed at FNP, which revealed that

the piping modification had already been completed per Work

Request No. 4572 on October 16, 1977. However, the associated

documentation that reflected the piping modification (i.e.,

'

service manuals, piping and instrumentation diagrams, and the

i

Final Safety Analysis Report were not revised by FNP until

October 1986 per Production Change Notices S-86-1-3647 and

S-86-2-3649. The NRC inspectors reviewed the master control

copy of FhP's Colt Service Manual No. U-184852F to verify that

'

the correct piping modifications had been incorporated. The

NRC inspectors reviewed Drawing No. P12609336 dated January 12,

1978 entitled " Air Start Control Piping Modification" and Drawing

No. 11868007, Revision 7, dated August 27, 1986 entitled " Starting

Air and Control Air Schematic" and noted that although both

drawings reflected the same piping system, discrepancies were

found between the two piping configuration drawings.

In an

,

interview with FNP maintenance personnel, the NRC inspectors

i

asked which control drawing.(if either) correctly depicted the

actual as-built condition existing in the plant.

In response,

FNP personnel performed a walkdown inspection of all three EDGs

13

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.

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and determined that Drawing No. 11868007 depicted the correct

as-built piping configuration. As a result of the walkdown,

.- -

FNP personnel also discovered an additional line, but were

unable to determine if it too was associated with the air start

control piping and requested assistance from Colt.

On May 29, 1987 Colt sent a letter to FHP that stated, in part,

that the line in question was a lube oil line that assists in

performing an interlock function for the EDG barring gear

device. Colt also stated that there were no drawings or

instructions explaining the operation of the interlock in the

vendor service manuals issued to FNP at the present time, but

the oil supply for the barring device was illustrated on page 3

of Drawing No. 008-134A (Section G-G).

The NRC inspectors reviewed FNP's controlled Service Manuals 6.

U184852F, which is used at FNP for the utility's PV-2 EDGs 18

and 1-2A, and No. U21622F, which is used for PV-2 EDG 28.

In an

interview with FNP personnel, the NRC ins)ectors asked why two

-

separate manuals are used at FNP if all t1ree PV-2 EDGs are the

same. The FNP personnel stated that hanual No. U184852F was

issued for use at FNP during the construction of Unit 1 for

EDGs 1B and 1-2A and Manual No. U21622F was issued at a later

date during the construction of Unit 2.

The FNP personnel also

stated that to the best of their knowledge, all three PV-2 EDCs

were the same and the information in the manuals (i.e., drawings

and service information) was controlled and should not vary in

!

.the two manuals.

-

During a review of the manuals the NRC inspectors examined

Drawing No. 008-134A (Section G-G) (which Colt stated in its

correspondence would illustrate the oil supply for the barring

l

device) and noted that Section G-G in Manual No. U184852F

.

.I

displayed totally different details of the PV-2 EDG than did

Section G-G in Manual No. U21622F. The NRC inspectors also

noted a number of illustration and numbering differences between

1

the two drawings.

,

As a result of this review, FNP personnel compared the two

~

f

manuals page by ange before the conclusion of the inspection

to ensure that t1e information in the manuals was similar. The

i

problems with the vendor manual described above indicate a

j

potential weakness in the licensee's ability to provide current

{

technical information on its equipment. The licensee recognized

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,

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the general problems with its diesel manuals prior to this

4

inspection and has been actively seeking to correct the problem.

f

1

(8) Colt Service Information Letter A-2

{

The NRC inspectors reviewed a number of Colt Industries service

information letters (SILs) which Colt uses as a means of

l-

conveying vital service information to its customers.

SIL

)

.

A-2, dated February 18, 1985, entitled " Blower Installation"

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dealt with certain precautions that should be observed after the

-

installation of a new or rebuilt blower for Colt emergency

.

,

diesel generator models 38D8-1/8 and 38TD8-1/8. FNP's Systems

Performance Department evaluated SIL A-2 and recomraended the

following actions in Problem Report Ho. 7-103:

Administration personnel should attach a copy of SIL A-2

to controlled (FNP) vendor Service Manual No. U-184804.

Operations personnel should review and revise as necessary

all procedures for model 38T08 diesel generators.

Maintenance personnel should review and revise as necessary

all procedures for model 38TDB diesel generators.

-

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The NRC inspectors reviewed controlled vendor Service Manual

.,

No. U-184804 and the actions taken by the Operations and

'

Maintenance Departments. As a result of the review, the

-

inspection determined that the Operations and Maintenance

'

Departments performed the appropriate actions as recommended by

the Systems Performance Department. However, the inspectors

were unable to locate an attached copy of SIL A-2 in controlled

vendor Service Manual No. U-184804 as required. FNP personnel

rectified this problem by placing a copy of SIL A-2 into the

applicable controlled vendor service manuals before the conclusion ,

of the inspection.

!

This vendor issue is included as part of Potential Enforcement

"

Finding 50-348, 364/87-11-01.

(9) Foxboro Company Letters

The NRC inspectors reviewed the following four Foxboro Company

letters:

June 1984 advisory letter - Model E transmitter wire

insulator problem

,

June 1984advisoryletter-aluminumelectrolyticcapacitok

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aging

l

July 1982 advisory letter - potential deficiencies in

potentiometers

l

October 1986 advisory letter - potential transmitter damage

~

during handling

Each letter was evaluated by the FNP reviewer and the appropriate

action was taken.

Specifically, the first letter was found to

be nonapplicable to FNP; the second letter was applicable, and

an aluminum electrolytic capacitor changeout program was esta-

blished to coincide with scheduled maintenance; the third letter

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was found to be nonapplicable to FNP; and the last letter was

-

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applicabic, and the appropriate Foxboro vendor manuals were

revised to incor

,

.

preclude damage.porate the required precautionary advice to

The' licensee's response to this issue is

considered adequate.

(10) INP0 SER 7-85

The NRC inspectors reviewed the FNP screening evaluation proi

for INPO SER 7-85, " Battery Problems Caused by Terminal Post

Design."

The main issue of ti,e SER concerned specific

hardware problems at the Vermont Yankee (VY) nuclear plant

identified to the NRC in a June 29, 1984 potential Part 21

letter.

The problems included cover distortion, jar te cover

seal cracking, co

post seal damage.pper contamination of the negative strap, and

involving battery cracks had been reported since 1981

Information Notices 84-83, and 83-11 and INPO 0&MR-150 were

NRC

'

icentified in the SER as having delineated "other types of

buttery cracks." Futhermore, the SER specifically stated that

"a preventive maintenance program that includes inspections for

,

distortion, cracks, leakage and corrosion should be implemented

for batteries.

IEEE-450/1980

.!

battery inspections."

provides additional guidance for

i

The FNP reviewer of SER 7-85 deemed that the inform

applicable to the facility and based this conclusion on the

~

contents of NRC Information Notice (IN) 83-11, " Premature Batte

Aging."

A review of the evaluation package by the NRC inspector

revealed that a copy of IN 83-11 was the only technical informa-

i

tion document in the package.- SER 7-85 was not in the packag

Discussions with FNP personnel determined that the conclusion of

nonapplicability was based on IN 83-11.

Following the NRC

inspector's identification of FNP's incomplete review of SER 7-85.

FNP personnel implemented actions to perform another review of

i

SER 7-85 that would include all applicable references.

,

Furthermore, it should be noted that the referenced technical

information within SER 7-85 identified "other types" of battery .

5

'

cell cases that were identified by FNP personnel

125-v auxiliary battery rooms in April 1986.

On tnc basis of the data presented during the inspection, the

licensee's review of this issue was not based on sufficient

technical information to accomplish its intent.

,

(11)ljRCInformationNotice's84-83and85-74

1

The NRC inspectors attempted to review FNP's evaluation of

IN 84-83, "Various Battery Problems." However, the review

revealed that FNP personnel had not performed a separate

evaluation of IN 84-83.

The NRC inspectors reviewed a

1

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. preliminary evaluation'of IN_85-74 that had'been routed to'FNP:

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' . J management for comment. - -This evaluation addressed IN .85-74,

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" Station Battery Problems," and the-laststwo paragraphs of the

[

evaluation addressed IN.64-83.. The FNP policy in regard to the

t'

evaluation of;information notices-was to route the preliminary

e"

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draftJto management lfor comments beforecits-disposition. There--

s'>

fore,ithe;NRCxinspectors reviewed the' draft evaluation. ;A'-

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handwritten note on the evaluation stated.that 15 safety-related:

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battery cells had been,fourid;to have cracks during an April 1986

,

battery; cell inspection. A followup review of the cracked-cell

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issue and corrective actions by FNP personne1 to preclude

',

recurrence was performed by the NRC inspectors.

IN 84-83' discusses various' battery problems;that include battery

case cracking _ induced by; hydrocarbon-based materials and commonly ,

used solvents.: The information notice states'that. tests have

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shown that some commonly used solvents will induce almost

,

instantaneous cracking of battery cases. _The Maintenance

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Department revised!two of its three electrical procedures to-

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include a~ precautionary note to limit solvents and hydrocarbon-

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ba' sed _ components from coming.into contact with the batteries.

(

The. followup review of the cracked cell revealed that FNP

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ersonnel had id et Vied 12 cracked cells of the auxiliary

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uiloing 125v Clar 7d batteries in battery room unit 2-A and 3-

in. battery room unit 2-B. 'The cracked cells were found in

9

April 1986. The licensee...to date, has not determined the root

2

cause of.the cracked battery cells. However, the inspector

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noted after.an inspection of the cracked battery cell _s that.

t'

each cell exhibited signs of paint and that the paint had been

.i

aartially removed from some of the. cells. This could possibly'

t

lave'been a source of hydrocarbon based solvent: contact with

'"

the batteries.

+

The inspectors'. concerns.during'this review 1ere primarily

..

-focused on the FNP corrective' action to prec"ude recurrence.

'Two out of three electrical procedures had precautionary notes-

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'adaed, but no other steps.or' precautions had been implemented.

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Even though personnel other than electrical, such as painters

.

andilaborers, performed work actions in safety-related battery

1. '

rooms, FNP personnel did not.take adequate' corrective action to

preclude recurrence. However, before the exit meeting, FNP

n'

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management committed to~ expand its precautions and personnel

L,a

, notifications.

The 15 cracked. battery cells in Unit 2 discovered in April 1986

m

y-

represented both train B redundant sources, and had they gone

i

undiscovered, the c ..dition could have resulted in a DC power

_

source that, following a. seismic event .might not have supplied

5

DC power for its design assumption rated time period as used in'

j

FNP's safety analysis. The cracked battery condition is con-

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sidered an unanalyzed condition as discussed in 10 CFR 50.73,

.

,

that could have significantly :ompromised the Unit 2 redundant

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train.E power source that is used for instrumentation and

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control systems that monitor and maintain ~the plant's status.

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-Additionally, the degraded battery condition could have prevented

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the fulfillment of the Unit 2 DC power distribution safety

j

function.

The' battery vendor, GNB Batteries, Inc., formerly Gould, stated

.l

to FNP in an' April 18, 1986 letter that the batteries cculd be-

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operated if the two worst-case cells were replaced immediately

.j

and the remaining cells were replaced within 4 weeks. This GNB

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statement was based on no apparent leakage, an adequate 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

j

cell performance test, and daily cell inspections to ensure

that the cracks did not propagate.

$

Failure to report this condition under 10 CFR 50.73 is included

as part of Potential Enforcement Finding 50-348, 364/87-011-04,

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y

and lack of appropriate corrective action on this vendor issue

q

is also part of Potential Enforcement Finding 50-348, 364/87-11-01.

.

(12) Ruskin Manufacturing Fire Dampers

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During.their review of the evaluation by FNP personnel of.a

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November 1984 Part 21 letter from Ruskin manufacturing, the NRC

l

of the control. room recirculating air conditioning (A/C)pply side.

inspectors found that both of the fire dampers in the su

a

and

'

emergency filtration systems were found to be inoperable by the

licensee in 1982, but had never been fixed. The dampers had

failed to close completely during an air flow test performed in

1982 by FNP personnel.

)

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Appendix A of NRC Inspection Report No. 50-348/81-06 listed as

)

4

a deviation several inadequate fire damper installations.

It

was discovered that some dampers were not installed in.accordance

!

with either the manufacturer's recommendation or the applicable

fire codes, or both. As a result of the report, the-licensee

implemented a program to inssect and evaluate all of the fire

dampers in Units 1 and 2.

T1e-scope of the licensee's inspection

,

efforts included the testing of the fire dampers in place under

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actual system air flow conditions to ensure that the danpers

'

would function as required by their system design. Several

~

dampers failed to operate within their system air flow design

j

parameters.. The failures were limited to three general areas,

'

and the licensee established a plant change notice (PCN) document

for each area as follows:

containment purge system - PCN B-83-1-1402, damper numbers

120-14, 120-15, 119-19, and 119-20

control rod drive mechanism switchgear room - PCN B-83-1-1403,

damper number 110-18

control room recirculation ventilation system - PCN

B-82-1236, damper numbers QSV49XV2782AC and QSV49XV2782BC

Each of the three PCNs contained the same electrical / mechanical

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system design modification, which included the addition of a

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circuit that simultaneously deenergized both the fan motor and

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air conditioning compressor upon receiving a signal from the

applicable heat sensor device. The first two of the above PCN

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packages were acted on, the work was performed, anc the items

J

were closed. However, PCN B-82-1236 for the control room fire

dampers was neither acted on nor was the work performed. Co ns t.-

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quently, the subject control room fire dampers have been in a

condition that hcs rendered them unable to perform their system

design function since the original installation, as determined

by the licensee in 1982.

l

Section 3/4.7.12 of the FNP Technical Specifications requires

that if one or more fire barriers or dampers are not functional,

the licensee shall, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, either establish a continuous

fire watch and restore the nonfunctional fire dampers to a.

,

functional status within 7 days or prepai,e and submit a special

report to the NRC pursuant to Specification 6.9.2 within 30 days

outlining the action taken, the cause of the non functional

penetration, and plans and a schedule for restorirg the fire

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damper to functional status. The licensee failed to

establish a continuous fire watch within the req.' red time

restore the nonfunctional fire dampers to functional status

within 7 days, or

prepare and submit a report to the NRC in accordance with

FNP Specification 6.9.2 within 30 days.

"

The licensee stated that since the dampers are in the control

room ceiling and the control roor.: is manned at all times, the

fire watch obligation has been met. However, two main issues

concerning the licensee's statement indicate that the control

room personnel may not have been able to respond before the fire

dampers were damaged during a closure attempt under system air

flow conditions. First, laboratory .'.esting of heating, ventila-

tion, and air conditioning has shown that fire damper deflection

,

end damage can occur during high-velocity closure attempts that '_

render the damper inoperable within the first few seconds of the

closure attempt. Second, the control room personnel were

not aware of any fire damper closure problems under system air

flow conditions until June 2, 1987, and might not have been able

,

1

to determine the problem and respond before damage would occur.

Additionally, subsequent to this inspection, the licensee

informed the NRC that FNP personnel had discovered additional

deviations in the control room fire dampers not previously

known.

The licensee failed to complete 48439 and 67875

Maintenance Work Requests which would implement corrective

,

actions on the four control room fire damper electrical circuits

{

to ensure that the circuits had been completed and that the

'

electrical components of the fire dampers would function as

designed.

This issue will be further defined in NRC Resident

Report 87-14.

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This area is included in Potential Enforcement Finding 50-348,

.

364/87-011-04 and also as part of Potential Enforcement Finding

50-348, 364/87-11-01.

(13) W Solid State Protection System Heat Sink Adhesive Failures

A Part 21 notification issued on June 1, 1983 to APC0 stated

that the adhesive used to secure heat sinks to the W 7300

Series nuclear loop power supply cards was failing In service

causing transistors to overheat and fail. This initial notifica-

tion was followed by Technical Bulletin 83-04 issued on Jur.e 15,

'

.1983, which elaborated on the initial notification and provided

suggestions for resolving the concern. This item was entered

in the FNP system and was tracked. The affected cards at FNP

were examined and found not to be subject to the concern, and

the issue was closed out. There is a discrepancy in dhtes

between the evaluation cover sheet and the letter presenting

,

the disposition, but this was caused by the backlog of work

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resulting from the initiation of the tracking program.

However,

.

the Part 21 notification and the subsequent technical bulletin

were classified by the system as "not significant" and received

no expedited or special handling nor was there any indication

on the action package that this was a Part 21 issue.

We believe

this lack of safety discrimination to be a serious problem with

the operation of the event classification system, since all

Part 21 notifications are by definition considered to be

significant safety concerns.

,

(14) Eberline Radiation Monitor

A Part 21 notification from Eberline Instruments issued on

December 21, 1981, involved a design defect in the Central

Processing Unit (CPU) board (CPU-III) of their radiation

monitoring equipment. The fix was a " piggy back" board that

could be installed on the CPU board.

Because this type of

equipment was used at FNP, the notification was applicable.

The NRC inspectors found that the documentation of this item

'

,

was very poor. They were able to establish that the recommended-

parts were purchased from Eberline, but no documentation existed

verifying installation of these replacement boards in 1982.

This notification was issued before the establishment of the

current documentation and tracking system; however, it does

point out the necessity for systematic documentation of receipt,

evaluation, anc remedial actions taken.

During the inspection, the licensee declared a limiting condition

for operation (LCO) and physically removed the CPU board to

verify the installed component was in fact the " piggy back"

board recommended by Eberline in 1981.

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(15) GNB Inc., Industrial Battery Division Letter

.

.

The NRC inspectors reviewed the evaluation by FNP personnel of

a January 18, 1984 GNB battery rack letter. GNB also had

transmitted a March 27, 1984 letter to the NRC and subsequently

l

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had issued a January 22, 1985 letter to all affected nuclear

i

plants.

Each letter addressed the' subject of excessive space

between individual battery cells installed in certain GNB battery

l

cacks. The NRC inspectors visually inspected the auxiliary

l

building GNB battery racks and observed that the required spacers

1

h M been installed in the 1A (room 214), 1B (room 212), 2A

(room 2214), and 2B (room 2212) safety-related station batteries.

,

Additionally, the NRC inspectors reviewed the FHP/GNB battery

rack design drawings and seismic test report for the battery

racks. The licensee's response to this issue is considered

adequate.

(16) Pacific Scientific Mechanical Snubbers

,

I

On September 14, 1983, Pacific Scientific Company filed a Part 21

report with the NRC concerning mechanical shock arrestors (PSA-1

and PSA-3) with cracked capstan spring tangs. The failure of

the tang on certain series snubbers could lead to overstress

in the piping system, adjacent pipe supports, and structural

j

steel during a thermal transient or seismic event.

i

APC0 never received this Part 21 notification from Pacific

'

Scientific or ITT Grinnell, supplier of many of FNP's snubbers.

i

APC0 did receive notification of this capstan spring problem on

j

November 4, 1983 from Wyle Laboratories, which was marketing its

1

inspection, repair, and snubber testing services as part of

Pacific Scientific Service Bulletin 1801-01, " Removal and

Inspection of Capstan Spring."

APC0 did not contact Pacific Scientif n or ITT Grinnell, but

did request from Wyle a complete listing of the serial numbers

for the affected snubbers. Using this list, FNP personnel

,

conducted their evaluation and determined that none of the

'

sffected PSA-1 and PSA-3 snubbers were in service at FNP. This

is another example of APC0 receiving vendor technical informa-

tion from a source other than the applicable vendor.

E.

Vendor Interface Summary

The results cf this area of the inspection show considerable weakness

in the area of vendor interface. Specifically, the receipt of vendor

i

technical information, other than tirough the formal contact programs

established with W, GE, and Colt, is informal.

Other vendors of key

j

components are noT contacted regularly, but on a need-to-know basis

j

as evidenced by FNP personnel contacting several vendors during this

.

inspection to receive specific technical information to answer

i

inspector's questions regarding vendor issues, including Part 21

notifications.

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Terry Turbine and Pacific Scientific are two examples of APC0

receiving Part 21 notifications from second-hand sources.. /ilthough

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the FNP personnel did have all the vendor information requested

by the inspectors, they had to rely on sources other than the

original vendor to receive some of the information with no

apparent action by FNP personnel to verify completeness.

The evaluation of' vendor information is' weak and in some cases

untimely as evidenced by the less-then-rigorous evaluations

]erformed on the Henry Pratt Valve, Anchor / Darling Valve,

hydrocarbon-based cleaner / cracked battery cell, and Colt diesel

generator issues. The weak evaluations contributed to subsequent

problems in these areas.

The implementation of the corrective actions recommended in the

FNP evaluations, in general, was poor. The failure of FNP personnel

to carry out rec. commendations and perform additional work by means

of maintenance work requests, was evident in relation to the

~

Henry Pratt Valve, Anchor / Darling Valve, Ruskin fire damper,

,

Eberline radiation monitor and Colt diesel generator issues.

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This problem may have been aggravated by the lack of formal

identification of incoming Part 21 notifications and detailed

documented instructions for evaluating NRC information notices.

In the instances noted above, the FNP personnel failed to follow

through to completion their own recommendations or to implement

vendor recommendations and suggested maintenance.

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The inspectors reviewed in detail the Colt Industries Vendor

Manual, which is used by FNP personnel as guidance when performing

preventive and corrective maintenance. The control of the manual

was lacking, and in several cases the manual did not reflect

11 ant configuration. The licensee realizes this fact and has

ontracted with Colt to review and revise the vendor manuals to

correct all deficiencies.

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6.

Procurement of Material

' A.

Procedure Review

The NRC inspectors reviewed F,iP procedures for the procurement of

materials. Procedure FNP-0-A!>-9 is the administrative procedure

used at FNP for procurement and procurement document control.

Basically,itemsprocuredat;NPareassignedoneofthreequality

assurance (QA)reviewcodes(/)kismeanttobeusedforprocurement

C, or D) based on the items' safety

significance. QA review code

of all parts that perform a stJety-related function.

Parts for non-

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safety-related systems or parts for safety-related systems that

perform no safety function mag be procured as commercial grade parts,

either QA code C or D.

No spesific guidelines for determining whether

a part performs a safety function were contained in this procedure;

however, a review of parts obtained in this manner showed that

evaluations as to a part's safety significance were generally being

done correr,tly, but documentation was lacking. This determination

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and evaluation were'found to be applicable only when parts were

ordered for'a specific application.. When parts were ordered for

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general stock or for non-safety-related systems, there was no

procedure that required a similar safety evaluation if the parts

=could be drawn for a safety-related system.

Specifically, parts

obtained as commercial grade and stocked in the warehouse could.be

drawn by craftsmen and installed in safety-related systems without

the benefit of any review as to the acceptability.of using these

commercial grade parts in a safety system. 'During the inspection

numerots examples were cited where commercial grade parts were-

)

installed in safety-related systems without any safety evaluation or

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material. dedication. Procedure FNP-0-AP-21 requires warehouse personnel

to fill out a material-issue form before issuing any material from

stock. The material issue form contains the QA review code, Total

Plant Numbering System'(TPNS) number, and maintenance work request

number but does not prohibit issuing QA review code C or D material

for safety-related systems.

This problem 11s further aggravated by the licensee's decision not to

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fully implement Section 2.2.1 of Generic Letter 83-28, which requires

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the identification of all safety-related equipment on information

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systems in use. FNP's system of TPNS numbers where "Q" designators

are used for safety-related and "H" designators for non-safety-related

equipment is ineffective because many exceptions exist for both Q and

N-designated ecuipment (N-designated equipment that is really safety

related and Q-cesignated equipment that,is really non-safety related.)

The fact that'no definitive system exists for easily determining the

classification of equipment can cause confusion at the working level.

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Receipt inspection at Farley is done in accordance with one of two.

procedures. FNP-0-AP-20 is the procedure for receipt inspection

of material purchased as either QA review code A (safety-related) or

QA review code D (commercial grade with QA criteria). This procedure

delineates the general items to be inspected for all QA review code

A and D materials. Additionally, characteristics such as dimensions,

weld preparation, workmanship, electrical insulation, and lubricants

are verified as being acceptable and documented on material receipt ~

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inspection reports.

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liaterial purchased as code C (commercial grade) is inspected on receipt

in accordance with Procedure FNP-0-SRP-9, which requires a check for

shipping damage and correct part number only.

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B.

Maintenance Work Request and Purchase Order Review

The NRC inspectors reviewed a computer printout generated from maintenance

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work requests (MWRs) issued from January 1982 to December 1986 for

work performed on the auxiliary feedwater, cheminal and volume control /

high pressure safety injection, residual heat removal / low pressure

safety injection, feedwater control, auxiliary feedwater control,

and reactor protection systeus. From this printout the inspectors

chose 11WRs for review to identify any work being performed utilizing

replacement parts with safety-reicted functions.

On the basis of the

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review'of this'information, purchasing and maintenance packages

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.involvingLthese replacement. parts with safety-related functions were

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requested so that > implementation of procurement practices 'could be

reviewed.

The: inspectors' performed a detailed revi.ew of 54 procurement packages.

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The )rocurement packages consisted of maintenance work requests,

purciase orders, material issue forms, certificates of compliance /

conformance, and other related documentation. Several problems were

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identified concerning the use of components procured as commercial'

grade' code C and placed in safety-related applications.without

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adequately evaluating their suitability for such applications.

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.Also, a' problem with a major. safety-related procurement of circuit'

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breakers was identified and is~ discussed further in'C. below.

C.-

Safety-Related Procurement

The NRC . inspectors reviewed a procurement of 200 safety-related Class

'1E molded case circuit breakers. The: breakers, which were certified-

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as being in,accordance with seismic and' quality assurance specifications,

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Were purchased from Satin American Corp. Satin American is'not the

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manufacturer of these breakers but acquired a number of commercials

grade breakers which they-then' certified as being' seismically quali-.

fied and acceptable for use~in FNP's safety-related 600-VAC motor

control centers. A sample of these breakers was shown to the inspec-

-tors who observed that a. number of the breakers had a paper. label

Laffixed indicating that they were acceptable ~for use in applications

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up to 600 VAC. This label, apparently affixed by Satin American, was

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in addition to the 480-VAC.UL-certified. label-that had been put-on the

breakers by the original manufacturer, ITE.

No basis to show'the-

acceptability of using these.480-VAC UL-rated breakers in 600-VAC

systems was provided by Satin American. 'No testing of these breakers

to determine the acceptability of useLin 600 VAC systems was. performed

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by Satin American or upon arrival at FNP. Further,' Alabama Power

Company approved Satin American as a source based on a review of

their quality assurance manual which had been received through the.

mail. At no time' prior to this inspection had Alabama Power Company'

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conducted an audit or survey at the vendor's facility to assure that ?

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the vendor had appropriate facilities to perform the contracted work

or to verify the validity of the vendor supplied certificates of

conformance. During a subsequent NRC inspection of Satin American,.it was

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determined that only meager checks and trip tests on a sample basis were

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performed by the vendor, rather than the overload test at rated

voltage, the overcurrent trip test, the rated load test and the

endurance test required by UL for 600 VAC breakers.

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Additionally, it appears the entire basis for establishing seismic

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qualification, 600-VAC acceptability, and safety-related quality

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assurancs criteria was derived from statements of the breakers'

similarity to breakers that were manufactured at a different location,

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underwent different testing, and were qualified many years ago. No

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testing, auditing, or inspection was performed by either Satin American

or FNP to determine this similarity or to determine what effect manu-

facturing changes that may have occurred over the years could have

had on the breakers.

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'During the-inspection FNP personnel: revealed that.nine'of these

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breakers had.already been installed into safety-related 600-v motor

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control; centers (HCCs). Because questions as to the acceptability

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ufor use of these: breakers could.not be resolved ithe~ breakers were:

1either removed or disconnected from service during the'latter,part<

Lof the inspection..~The. breakers had been installed-in the following.

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locations:

'MCC 1B'

NCC 1C

FBD2L.

FCLO3

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FSM4L'

'MCC 2A

MCC 2B

MCC 2E

MCC 20-

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FAK4L

.FBD6

FEE 3

FMH2

FB03

FBH3

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Installation of these breakers into safety-related motor contFoi .

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benterr is.' considered in Potential Enforcement Finding.50-348,=364/

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87-11-02.

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D.

l Comercial Grade' Procurement

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The NRCLinspectors reviewed a number of MWRs for material replacement.

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data. ;For MWRs thateindicated replacement parts were used; supplemental-

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documents such as material ~ issue' forms and aurchase orders were

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requested. .Bysreviewing these documents, tie inspectors could iden-

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tify instances where commercial grade parts were installed into safety-

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related systems. For these applications,; additional supporting data

that would be necessary to support the.use of these commercial grade

parts was requested.- In a. number of' cases' acceptable. supporting. data.

such as testing, analysis, or inspection,date did'not exist or had

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,not been properly documented. :This supporting documentation is'

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required to ensure'the commercial grade items are suitable for thec

intended applications.: Specific instances where this documentation-

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did not exist or.was insufficient are given in the following examplest

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(1) .A' commercial. grade circuit breaker procured as'QA review code C

was. installed:into an environmentally qualified motor control

center-(MCC) IU under MWR 71930. sNo material analysis or docu-

mentation that would-show it was similar:to the. original HCC-

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breakers was'available. This breaker fed the Unit 1 accumulator

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2C discharge' valve and was removed by the licensee during.the

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course of-the inspection,

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(2) . A similar circuit breaker, also procured ~as' comercial grade, was

installed into environmentally qualified MCC 20. The breaker

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.was withdrawn from the warehouse under MIF 82-7177; however, no

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record that this breaker was installed in the plant could be

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located. -It is believed.to have'been installed under MWR 56671._

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Thesfact?that its installation was not properly recorded is a

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violation of FNP procedures. Additionally, no records were

.available.to show-that this breaker was tested before it was.

installed, nor were there any records available to prove that

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it-was similar to'the original MCC breakers.

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.(3) 7A Namco limit' switch ordered: commercial grade code C was installed

ion March 26, 1986 as a replacement for an environmentally' qual 1-

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fied switch on the accumulator tank-isolation valve. Although

.it had the.same part number (17045S02) as the original switch,

.no-certification as to its environmental qualification-was-

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available,until'a vendor certification was:obtained durin

course of the. inspection. Additionally, a review of the g.the

qualification file:for these switches uncovered the fact that

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the specified environment:on the~ system component. evaluation

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work sheet was in error. The environment specified was for.

inside the containment, not for the outside containment locations.

where these: switches were installed. This model Namco switch-

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.is.not. qualified for the harsh environments postulated.for

~inside the containment.

(4) .ALtorque switch ~ purchased as_ commercial grade QA review cod' C'

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was installed into a Limitorque actuator connected to'a valve

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in'the service water linetto the motor-driven auxiliary feed pump.

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The switch installed.under NWR 89573 was purchased from Amertap.

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Corporation via-Bishop' Sales Company.

Limitorque,has indicated

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-that had the' switch been ordered from them as safety related,

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~ dditional QA' checks'would have been made.

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.No documentation was available to show the QA checks that would

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have been performed by Limitorque were ever performed by FNP

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personnel.

A. valve stroke time test and part' number (P/N).

verification for the switch, however, were completed.

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(5) Replacement hinge pin bushings on~the Anchor / Darling tilting

disk check valvescin the auxiliary feedwater system were procured-

-as code C, non-safety related.. Production Change Request

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84-1-2988/2-2985 outlined the corrective action to be taken.

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The bushing failures were the cause (LER-83-084) of-the inopera-.

bility of one train-of the auxiliary feedwater system at Unit 1-

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and could potentially affect the operability of.the other trains.

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The new bushings for these safety-related valves were procured

as non-safety related with no QA.from the vendor. 'In addition,

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no safety-related receipt inspections or installation inspections-

were performed.

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-During the inspection, APC0 contacted Anchor / Darling and received

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a' letter dated May 29, 1987 which stated that the new bushings-

were handled as safety'related by Anchor / Darling and 10 CFR'21'

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was applicabic. However, FNP'persennel had treated the parts

as non-safety related once they were received on site.

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(6)

'A commercial grade Agastat relay, model #7012PA, serial #83191275,

was found to~be installed in a safety-related 600-v load center

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(equipment #Q2R16B007-D, device #62.1, procured by FNP Record

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1. 10148). A review of the procurement documents and discussions

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with the manufacturer indicated that the above relay was procured

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as commercial grade. The vendor manufactures two distinct models

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for each Agastat relay.

One model is strictly for commercial

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grade application and the other is designated as nuclear grade.

{

The nuclear grade relay has been demonstrated as complying with

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the applicable regulations and is qualified for Class 1E applica-

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tions. Further observations by the NRC inspectors determined

that the following Agastat relays were commercial grade relays

in a safety-related application:

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DG Load Shed Sequencer (Q2R43E501B-B)

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Agastat model 7014PCC774, serial #79091380, device unknown

Agastat model 7012PD, serial #78312249, device 2AJ

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DG Relay Terminal Box (Q1R43G506-B)

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Agastat model 7012PC, serial #4362625, device T2A

Agastat model 7012PC, serial #4362631, device T2B

In response to the questions raised regarding the suitability

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for use of these Agastat relays, the licensee either removed

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or disconnected from service the affected relays prior to the

end of the inspection.

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The above examples constitute the basis for Potential Enforcement

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Finding 50-348, 364/87-11-03,

7.

Service Water Battery Rack Installation

The NRC inspectors toured the service water (SW) building to inspect

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recently procured and installed safety-related batteries and battery racks.

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, The recent installation was a result of a DC distribution system plant

modification. During the inspection of the two SW battery rooms, a few

inconsistencies were noted. The most significant involved a nontypical

battery rack floor attachment configuration that was noted on SW battery

racks 3 and 4.

The licensee had used standard concrete expansion anchor

bolts that were typically Si inches long to faston the angle iron frame

to the floor in train A and train B battery rooms.

However, the concrete

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anchor bolt nuts on all train B battery rack anchors were backed off and

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used as leveling nuts for the rack, thus providing no preload on the

concrete anchors.

As discussed in Section 3/4.8 of the FNP Technical Specifications, the

design bases concerning DC power sources and associated distribution

systems used during shutdown ensured that (1) the facility can be maintained

in the shutdown condition for extended time periods and (2) sufficient

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instrumentation and control capability is available for monitoring and

maintaining the unit status. Additionally, Section 3/4.3.8.2.5 states

that one battery in each train of the SW DC distribution system shall

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be operable. _ Consequently, if one battery of a particular train is

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inoperable (without backup), the licensee is; required to implement

its specific limiting conditions for operation.

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However, the'NRC inspector-identified that both of the redundant batteries

in train B of the SW safety-related DC distribution system were installed

in an unanalyzed configuration and therefore'were indeterminate as to their

operability.

This incorrect installation has existed for approximately

1 year.

This ar'ea of review is included in Potential Enforcement Finding 50-348,

364/87-11-01.

Additional. items that were noted to the licensee include:

Pressurized steel. emergency eye wash bottles.were found to be stored

in each service water battery room. The steel tanks were not-

restrained or fastened in'any manner. _The service water. batteries

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are low profile in that the cell connections are approximately 18

inches from.the floor. The steel eye wash tank was approximately

40-48 inches high.

Several nonplated_ carbon steel fastener nuts were observed as being

used to attach service water battery racks 1 and:2 to their concrete

expansion anchor attachment studs. This was observed because of the

excessive corrosion noted on some and no corrosion on the other

attachment fastener nuts.

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lionseismically installed-metal storage boxes, approximately 12 inches x

18 inches x 10 inches, were found installed over service water batteries

1, 2, 3, and 4 (i.e., seismic category II installed over seismic

Category 1 components). These boxes were used to store battery

maintenance. tools and material.

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