IR 05000413/1989020

Insp Repts 50-413/89-20 & 50-414/89-20 on 890717-21.No Violations or Deviations Noted.Major Areas Inspected:Environ Qualification of Electrical Equipment,Generic Ltr 83-28 & NRC Bulletins 88-001 & 88-003

ML20245K414
Person / Time
Site:	Catawba
Issue date:	08/11/1989
From:	Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245K411	List: IR 05000413/1989020 ML20245K405
References
50-413-89-20, 50-414-89-20, GL-83-28, IEB-88-001, IEB-88-003, IEB-88-1, IEB-88-3, NUDOCS 8908210002
Download: ML20245K414 (12)

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\ .R8-T f UNITED STATES NUCLEAR REGULATORY COMMISslON

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of REGION 11

.[ 3 d j 101 MARIETTA STREET, Si e ATLANTA, GEORGl A 30323 t

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Report Nos.: 50-413/89-20 and 50-414/89-20 Licensee: Duke Power Company 422' South Church Street Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414' License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2

. Inspection Conducted: July 17-21, 1989

Inspector:' Lyywd- b M~ 8f N. Merriweather Date Signed Approved'by: #av cP79 __

b //- ff T. E. Conlon, Chief

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P1 ant Systems.Section ,

Engineering Branch Division of Reactor Safety SUMMARY Scope:

This routine, . announced inspection was conducted to review, what actions, if any, the licensee had taken in response to previous inspection findings. The items inspected involved environmental qualification (EQ) of electrical equipment, Generic Letter 83-28, and NRC Bulletins 88-01 and 88-0 Results:

In the areas inspected, violations or deviations were not identifie The actions taken by the licensee in response to previous inspection findings were in most cases timely and complete. Two exceptions to the above were a noted deficiency in the EQ file for the Hydrogen Recombiner tape splice analysis and failure to install breather drains on the Hydrogen Skimmer Fan Motors in a timely fashion to meet an NRC commitment. The latter problem j highlights a possible weakness in the licensee's handling and closeout of NRC  !

commitment l

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A chronology of the event clearly indicates that the Hydrogen Skimmer Fan ,

Motors breather drains could have been installed much earlier had the licensee  !

'done a better job tracking the status of the ite Extenuating circumstances ]

did exist which caused a delay in installation while a design fix 8908210002 890811 PDR ADOCK 05000413 p PDC

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l l was investigated with the vendor The fix was approved by the vendor in

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November 1988. Yet, no further action was taken until the licensee was informed of the impending NRC followup inspectio Prior to the inspection, Variation Notices were issued for Units 1 and 2 authorizing the design change to allow stainless steel threaded pipe extensions-to be used to install the breather drains. The pipe extensions were ordered on July 11, 1989 and the breather drains were finally installed on July 23, 198 Another area that appeared to be weak, although it was not previously identified as an open item, was the lack of EQ training provided to certain Construction Maintenance Department staff. This appears to be the result of a failure by the licensee to clearly identify which persor.nel must be cognizant of EQ issues and special consideration i i

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REPORT DETAILS

~ Persons Conta'cted Licensee Employees-

• R.~L~. Dobson,; Engineering Manager, General Office

• • R.7M. Glover, Catawba Compliance Engineer, Catawba Site

• T. P.' Harrall, Design Engineering, Catawba' Site Office Manager

,  :*R. J. Smith, Design Engineer,' General Office

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-*R.: G. Sokal, Design Engineer, General Office Other licensee employees ' contacted during this inspection : include craftsmen, engineers, and administrative personne NRC Resident Inspectors W. Orders,-Senior Resident M. Lesser,. Resident

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• Attended exit interview

' ** Participated in exit interview by Telephone Conference Call

/scronyms and initialisms used throughout this report are listed in

paragraph- . - Action.on' Previous Inspection Findings (92701 and 92702) (Closed) IFI 50-413/86-26-01, Review-Work Requests / Purchase Documente te Assess Equipment Classification Program For. All Safety-Related Components The HRC inspector had a concern regarding the adequacy of Duke's

. implementation of a program to properly classify work activities L considering the lack of' detail provided in the QSMSSC. At the time of the first inspection the licensee's procedure (Station Directive 3.3.1).

required QA Checklists be completed where conflicts existed between the QA conditions shown in the manual list (QSMSSC) and design documents. During that inspection, the planners did not appear to be very knowledgeable of how to use the QA checklist and some E confusion existed regarding the classification of work requests relating to maintenance of the CPOMs. Also it was observed that the QA Checklists were not always forwarded to manual holders by the Licensing Section to be incorporated into the manual. Thus, 3 information developed from previous evaluations was not being L distribute At that time, it was determined that a draft revision to the subject procedure would no longer require that the checklists be forwarded to the manual holders. Since that inspection SD 3.3.1 was revised (dated L - _ _ - _ _ _ _

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I ' July 3, 1986) to require that " the Compliance Engineer..will ensure

. the . equipment identified in the checklists issincorporated in the L-Manual at . its next revision."' The ' QSMSSC was last revised July 1, 1989 .to incorporate the most'recent.QA Checklist' dat L Recently, there have been several- discussions within DPC, based on review of internal memorandum, regarding the format and. content of information to be included in the QSMSSC. Discussions with representa--

.tives-in the General Office, Licensing Section for Catawba Station, revealed that recent QA Checklists were provided containing informa-tion on specific parts and work request number The General'0ffice Licensing staff believes that this clearly was not -

the intent of7the QSMSSC. It was -intended to aid the plant in classifying the safety function of major. structures, systems and component . Proposed . changes to the procedure are to require that when a QA -

Condition Checklist is filled out to determine the QA condition'of a piece.of equipment,:an Editorial SPR should be initiated to preserve

- for futurc reference the previous determination made. The SPR would

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also be reviewed by Desig .

The original, concern is now considered closed because the planners appear.to be very knowledgeable of SD 3.3.1 and the QSMSSC. This was

' confirmed by;' interviewing personnel in the I&E' Planning and

- Scheduling Sectio The recent revisions to the QSMSCC have insured that appropriate information has been incorporated from QA Check-list ' Although the licensee identified what appears to be a deficiency in their program for performing parts evaluations, the recent changes

. proposed would provide a method for performing these evaluations and resolve all questions regarding what information will be included in the QSMSS (Closed) IFI .50-413/86-26-02 and 414/86-29-02, Resolution of

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Deficiencies in Reactor Trip Breaker Maintenance Procedure MP/0/A/2001/05 Duke committed to make certain changes to the above procedure which

, would both improve the procedure and make it more clear. The. items committed by the licensee to be incorporated into the procedure were 1) add a list of tools required to perform the procedure, 2) make provisions to record UVTA trip force data, 3) add UVTA dropout voltao add *... %test ion requirement, resistance test4) add low-voltag)e (megger shunt test . Additional trip test, changes and 5)

made to'the procedure were to add sign-offs for QC inspection verification steps and incorporate references to. the latest vendor manual (CNM-1399.40-0016-010) and Drawings (693C350 and 588C785) for 05-416 Breaker _ - -

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The procedure was revised - on June- 28, 1988. The comment made

to the' licensee regarding this procedure was that there were three typographical -errors 'noted (see procedure steps 11.5, 11.16.5, and 11.17;8). The ' licensee ' representative frcm the Transmission

- Department committed to have the errors corrected as soon as-

.possible. This. issue was also discussed in the exit and' the licensee reafirmed that errors would.be corrected. Based.on the above this'

item is now considered close c.' -(Closed)' Unresolved Item 50-413/ 86-26-03 and 414/86-29-03 ' Tracking

_ and Closecut of Vendor Technical ~ Bulletins and Information Letters

Implementation of the 0EP program, as it related to vendor technical information, was considered weak. The_ licensee failed to escalate items that were not evaluated in a timely ~ manner to management for -

resolution. DukeL at that time indicated that 'a planned revision to the procedure would address the timeliness requirements for evaluating and closecut' of vendor technical bulletins' and letter DPC Nuclear- Production . Department Directive No. 4.8.1, Operating

Experience Program Description, dated January 9,1989 (on page 15

. step 5.1)_now requires a response due date be assigned to documents distributed ~ under ' the OEP program. Response due dates will be assigned s as "Immediate. Attention" or " Normal Attention" items

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requiring a -response within 30 days or_90 days, respectively. The program allows for extension of. due dates under certain' conditions which may require written justification.-

Fifteen working days after a due date is exceeded ONSA'will issue _a letter to the responsible manager of the section identifying the overdue document number, title, individual responsible, original due date, and a summary of the outstanding commitment or recommendatio A reply- to this '1etter is required within 10 days. If no response is received within 10 days a letter of escalation of. overdue OEP Item

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will be ' forwarded to the General Manager leve1 ~ for assistance in obtaining a resolution. Based on the above this item is close (Closed) Violation 50-413/88-07-01, Inadequate Documentation For Qualification of Splices on Hf rogend Recombiners The licensee ' responded to the violaticn in a letter to NRC dated November 23, 1988. In this letter the licensee admits the violation and states that the documentation to qualify the tape splice K configuration was available. However, the documentation was in I different files and not in an auditable form as required by 50.4 The corrective actions taken by the licensee were to assemble and place in the proper file documentation which demonstrates the qualification of the tape splice. Duke Vendor Manua'. CNM-1354.00-0080-001, Environmental Qualification Package for Termination Method of Main Power Cables of the Westinghouse Model B Electric Hydrogen Reccmbiner is the EQ file which demonstrates qualification for the 4-to-1 tape

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splice based on similarity to a V-type tape splice configuration and a shrink tubing configuratio In addition the licensee obtained information from Westinghouse which indicated that some type of tape splice configuration was used to qualify the recombiners. The splice was made with a silicone tape l

in a 4-to-1 configuration. However, this information alone is clearly not sufficient to support qualification .for the tape splice in that the vendor information does not describe the configuration used in the LOCA test. Furthermore there was no information on radiation conditioning and pre-aging. Therefore, to establish qualification for the splices the licensee obtained additional test data to support their claim that the 4-to-1 splice was qualifie Based on review of the qualification analysis the inspector considered the analysis to be acceptable except the licensee did not indicate a qualified life for the tape splice configuration. The inspector informed the licensee and they committed to include an aging analysis into the file. The inspector reviewed a preliminary analysis which shows the splice materials are conservatively qualified for 40 years. Based on the above this iten is considered close (Closed) Violation 50-413,414/88-07-02, RCS Wide Range RTDs Installed in an Unqualified configuration The violation occured because the RCS wide range (hot and cold leg)

resistance temperature detectors (RTDs) (model RdF) were not installed similar to the tested configuration. The bellows or hydrostatic hose assembly which protected the RTD pigtail lead wires from moisture egress was removed during installation. Also the junction box where the RTD pigtail wires terminated could become submerged during a LOCA event and was not qualified for submergence operatio ,

i The licensee acknowledged the notice of violation in a letter dhted November 23, 1988. In this letter the licensee indicated that the violation cccurred because of a misinterpretation of notes on l drawings during initial installatio The corrective action taken by tha licensee was to replace the RTDs on Unit 1 and completely fill the termination junction boxes with S:otchcast 9 Epox The Unit 2 R1Ds were replaced by Station Work Request 11736 NSM using procedure TN/2/A/16.29/CE/AL The work on '

Unit I was completed and reviewed during inspection 88-07. The work on Unit 2 was completed on February 14, 198 Considering the above, in conjunction with information previously reviewed and accepted during inspection 88-07, this item is considered close l

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The inspector noted one concern while reviewing the work request that. replaced the RTDs on Unit 2. The work request had not been properly identified as "EQ Related" as required by station procedures. The "EQ Related" block on the form had not been checke This could have been the result of an oversight or the maintenance planner may not have clearly understood the EQ ramifications of the work required. This work request was '.'11tated to put the RCS Wide Range RTDs in their tested configuratio In order to determine which was the most probable cause for the  ;

omission, the inspector interviewed the planner identified on the work request and his immediate supervisor. The individual involved in planning the work could not recall the reason for leaving the space blank. His supervisor indicated that in late 1987 or early 1988 the j

procedure was revised to require the EQ Related designation. He indicated.that there was confusion at that time regarding the proper 1 use for this block by the CMD Planner Further review of this item as it related to EQ training revealed that the planner and the supervisory had not attended the last EQ training. At this point, it seemed evident that the licensee did not provide EQ training to all personnel that could have an effect on EQ equipment. The licensee agreed with this concern and agreed to provide better coordination between departments to identify those people required to have knowledge of the EQ progra (Closed) Violation 50-413/88-07-03, Use of Unqualified Limitorque Motor Operated Valves Inside Unit 1 Containment The violation occurred because the licensee had used unqualified limitorque motor operated valves in the Containmer.t Air Return and l Hydrogen Skimmer System (valve nos. IVXiA, IVX2B, 2VX1A, and 2VX28). t The Itcensee had previously claimed that these valves were qualified J for outside containment. However, at the tirte of the inspection the licensee could not support qualification for these valve operators for either inside or outside containmen ;

The licen3ee responded to the violation in a letter to NRC dated l November 23, 1988. The licensee indicates in this letter that the j subject valve operators were replaced with qualified valves.. The l valves operators on Unit 1 (IVX1A and IVX2B) were replaced in February j of 1986 and the Unit 2 valves were replaced prior to Unit 2 initial )

riticality. The violation only applied to Unit 1. The Unit i valve i operators were replaced by Mechanical Work Request Nos. 2889 MNT and 2890 MNT. The valves were rewired in accordance with Design Drawing CN-1735-01.02 by I&E under approved work requests and variation notices. Based on the above this item is considered close = ~ _ _ _ - - ._

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j, m 6 1 L(Closed) Violation 50-414/88-07-04, Joy / Reliance Fan Motors Not

~ Installed In Accordance with the Tested Configuration

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The issue relates to' the fact that the Hydrogen Skimmer Fan motors

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y did not have' breather drains installed. The violation was written K against Unit.2, however, it also applies to Unit 1. At the time of

.the inspection the violation was believed to be isolated to Unit 2 only because the motors on Unit 2 had been replace The.. licensee. responded.to the notice of violation -in a letter dated November 23, 1988. In this letter the licensee identifies the cause for the violation as due to vendor maintenance error and a lack o adequate inspection by Duke. upon receiving.the spare motors from the vendo The. interim corrective action taken by the licensee after identifica-tion of-.the problem was to. remove one condensate plug on each motor. Subsequently, Variation Notices CE-1748 and CE-1749 were issued to install the breather drains on both units. At or around the same time ~ purchase orders were issued to the vendor to supply  !

the~ drain plugs. As discussed earlier in this report, the breather drains were not replaced until July 23, 1989 (Work Request Nos 2831 HSM and 2832 NSM) shortly after this inspection ended. The chronology of the events point out a weakness in the . licensee's handling and closeout of NRC commitments, although technical' problems existed which required the licensee to obtain ; additional information  :

from the vendor. These ' concerns were resolved in November 198 l However, the proposed fix was not documented in a revision to the  ;

' Variation- Notices- (CE-1748 and CE-1749) until July 1989, shortly af ter the licensee was informed of the NRC followup inspectio Although the corrective action was not as timely as it possibly could have been, the licensee has met the commf tment stated in their letter. Based on the above this item is considned close (Closed) Violation 50-413/88-07-05, Inadequate Documentation For ,

Qualification of Minco RTDs l In response to this item the licensee has assembled data and reports  ;

in a file (CNM 1399.03-V357-002, RVLIS Equipment, RTD Submergence Qualification) which demonstrates qualification for the Hinco RTD installations at Catawba. The proprietary file us reviewed and

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found to be acceptable. Based on this review this item is close , (Closed) Violation 50 A14/88-07-06, Unqualified Namco Limit Snitch j

The cover gasket on a Namco Limit Switch (tag No. 2NCLLO251) was '

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found folded under at one end of the Namco cover. The licensee initiated Problem Investion Report 2-C88-0054 which evaluated the

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unqualified limit switch for operability and deportabilit The :

i cover gasket was replaced by Work Rec,uest 8889 and the installation procedure (IP/0/A/3820/20) was revised to include a visual inspection of cover gaskets for proper seatin This action was taken to

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' prevent further : recurrence of the y problem. The licensee ' also .

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W performed visual inspections of all' Namco Limit switches listed. on

! .the -EQRI.'to verify proper cover gasket seating, screws, and washer 2 installation. This-item is now considered closedy i . .j.- (Closed) Violation' 50-413,414/88-07-07.. Plugged or Missing T-Drains

'on Limitorque Valve. Motor Operators

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The violation . involved Limitorque valves on Unit 2 that were

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- observed to have'.their T-Drains painted over and plugged 'Two out off the three' Limitorques. inspected exhibited 'some kind of obstructio A walkdown by the-licensee identified further examples of T-Drains

' obstructed or their abi11ty.'to properly drain was - uncertain. In addition, some limitorque operators. located inside containment on i Units 1 and.2 were discovered.without any T-Drains installe The licensee . response to the above violation is dated November 23,.

.1988. In this-response the licensee admits'the violation occurred as stated 1and -discussed the reasons for the violation. The licensee

., attributed the violation to inadequate installation and painting procedures. . All Limitorque ' valve operators requiring T-Drains were inspected. and.the required T-Drains were installed or unplugged. The inspections and repairs were documented E Station Work Requests (see Nos. 8903 thru 8906 IAL and 8890 thru 883/ IAE). 'To prevent furthe recurrences, the licensee revised the. Licitorque maintenance'

procedures (IP/0/A/3820/01 and 04, 'and MP/0/A/7300/61) 'and coatings procedure (MP/0/A/7650/95) to clarify . T-Drain installation r64uirements. Additionally, Duke provided training for painters and

. technicians on the proper T-Draiti maintenance and installation requirements. This item is now closed, j (Closed) Unrosolved Item 50-414/88-07-08, T-Drain on Limitorque -

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Operator hot Installed-at Luw Point :

Thd concern was that T-Drains on Limitorque valve No. 2NI-122B were not installed at the low point . The licensee tddressed this concern in a letter to the NRC dated June 15, 1988. The licensee reviewed this concern and concluded that the installation was bounded by the vendor test report B0058 and was consistent with guidance provided by the Nuclear Utility Group regarding installation of T-Drains on motors when the principal axis is -vertical. The licensee further states in I the letter that Limitorque has no restrictions on operator -

orientation other - than to minimile motor down positions. The l'

licensee indicated that valve operator 2NI-122B met all of tne required guidelines to De qualified. Bised on the above this item it considered closed.

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. o 3. Followup on NRC Bulletins 88-01'and 88-03 (92703)

a.-. (Closed)LIEB88-01,DefectsinWestinghouseCircuit. Breakers.

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Duke L Power responded to .the bulletin in a letter to NRC dated April 5,1988. In tiisLletter l Duke stated that the pole shafts were 1: replaced on' all- four. of the main Reactor Trip Breakers at- Catawb The-licensee also stated that'the.four bypass breakers were inspected

~per the. Westinghouse. Technical Bulletin and NRC Bulletin ~88-01, resulting in the' pole shaft being replaced on. Unit l' Bypass Reacto Trip. Breaker No..B (Work Request 0050 TRD). The~ licensee also commits in the. letter to ' revise the. breaker maintenance procedure by July.1, 1988 to ; include . the weld and mechanism alignment verification inspections contained in. the NRC Bulletin 88-01 and Westinghous < ' Technical Bulletin 87-11. ' The work records associated with the . main

~ Reactor, Trip . Breakers pole . replacements and. Bypass Breakers .

inspections were reviewed and' found acceptable. A list of records reviewed are contained in pragraph 5 below. The maintenance procedure for ' the ~' Reactor Trip Breakers (MP/0/A/2001/05) was revised June.28,1988 to require weld and alignment inspections. Based on the above. this item is now considered close ' . (Closed) IEB 88-03, Inadequate Latch Engagement in HFA TYPE Latching Relays Manufactured by General Electric (GE) Company The< licensee responded to the bulletin in a letter to NRC dated

' July 13, 1988. The licensee .determincd ' that the subject GE HFA relays with latching mechanisms are not used in any safety-related applications. at McGuire, Catawba or Oconee Nuclear Stations. Based on the above this item is closed.

t Exit Interview-The inspection scope and results were summarized on July 21, 1989, with those persons indicated in paragraph 1. The inspector described the areas r inspected and discussed in detail the inspectior, results as described in

. paragraphs E are 3 above. Although reviewed during this inspection, proprietary information is not contained in this reper Dissenting

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comments were not received from the liccase . In reviewing the above items, the following documents were reviewed: Procedure Nc. MP/0/A/7650/96, approved August 31, 1988, titled Administrative Control of Applied Coatings Procedure No. IP/0/A/3820/01, approved November 30, 1982, titled Limitorque Operator Preventive Maintenance Procedure No. IP/0/A/3820/04, approved December 3, 1986 titled Operating Checkout of Limitorque and Rotork Valve Actuators Procedure No. MP/0/A/2001/05, approved June 29,1988 titled Westinghouse DS-416 Air Circuit Breaker Inspection and Maintenance

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Nuclear Production Department Directive No. 4.8.1, approved January 9,1989 titled Operating Experience Program Description a Procedure No. IP/0/A/3820/20, approved September 7,1985 titled Namco 1E Limit Switch Installation Requirements Procedure No. TN/2/A/1629/CE/AL1, approved February 5,1988 titled Procedure for Implementation of Variation Notice CE-1629 Work Request Hos.11736 NSM, 8903 I AE, 8904 I AE, 8905 I AE, 8906 I AE, 8890 IAE, 8891 IAE, 8892 IAE, 8893 IAE, 8894 IAE, 8895 IAE, 8897 IAE, 0048 TRD, 0050 TRD, 0051 TRD, 005195 SWR, 005196 SWR, 0025 TRD, 0013 TRD, 0014 TRD, 8889'IAE, 2890 MNT, 2889 MNT, 1591 NSM, and 2890-MNT- Variation Notice CE-0499 (dated January 24, 1986) for Actuator changeout of Limitorque valve operator IVX001 Connection Diagram CN-1735-01.02, Containment Air Return and Hydrogen Skimmer System (VX) Valves and Dampers, Revision Problem Investigation Reports 1-C88-0207 and 2-C88-005 . NRC Inspection Reports: 50-413/86-26 and 414/86-29; and 50-413 and 414/ 88-0 Catawba Nuclear Station Directive No. 3.3.1, approved July 3,1986 titled, Determination of QA Condition For Structures. Systoms and Components Duke Power letter to NRC dated November 23, 1988 responding to the Notice of Viclation, Duke letter to NRC dated April 5,1938, regarding NRC Bulletin 88-0 Duke letter to NRC dated July 13, 1988, regarding NRC Bulletin 88-0 Duke letter to NRC dated June 15, 1988, providing additional information regarding NRC Unresolved Item 50-414/88-J7-0 Vendor Manual CNM-13E4.00 - 0030-001. Environmental Qualification Package for Ter.pination mathed of Main Power Cnbles of the Westinghouse Mocel 8 Electric Hydrogen R? combiner Vendor. Manual CNM-1399.03 - G357 - 002, RVLTS Equipmer.t, RTD Submegence Qualification

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'6. Acronyms and Initialisms CMD Construction Maintenance Department

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CRDM- Control Rod Drive Mechanism DPC Duke Power Company EQ Environmental Qualification GE . General Electric Company I&E Instrumentation and Electrical IP Inspection Procedure MP' Maintenance Procedure NRC Nuclear Regulatory Commission NSM Nuclear Station Modification OEP Operating Experience Program 0NSA Operational Nuclear Safety QA Quality Assurance QC Quality Control QSMSSC Quality Standards Manual for Structures, Systems and Components SPR Special Problem Report TRD Transmission Department UVTA Undervoltage Trip Attachement

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