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Insp Repts 50-413/86-05 & 50-414/86-07 on 860106-10. Violations Noted:Hydrogen Skimmer Fan Isolation Valves 1VX1A & 1VX1B Not Environmentally Qualified in Accordance w/10CFR50.49
	ML20141F378
Person / Time
Site:	Catawba
Issue date:	04/04/1986
From:	Christensen H, Debs B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20141F370	List: ML20141F366; ML20141F372; ML20141F378;
References
	50-413-86-05, 50-413-86-5, 50-414-86-07, 50-414-86-7, NUDOCS 8604220535
	Download: ML20141F378 (16)
	v • d • e

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UNITED STATES

[pm Etcoq*e NUCLEAR REGULATORY COMMISSION

.[" 3 REGION 11

g,_ j 101 MARIETTA STREET N.W.

" *2 ATL ANTA. GEORGI A 30323

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.....

Report Nos.: 50-413/86-05 and 50-414/86-07

Licensee: Duke Power Company

422 South Church Street

Charlotte, NC 28242

Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and CPPR-117

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Facility Name: Catawba 1 and 2

Inspection Conducted: January 6-10, 1986

Inspectors: N

R. Christensen, Team Leader - at'e Signed

C. Brooks

R. Pierson

C. Caldwell !

P. Moore

Approved by: .- 7 . ~M h/E N

Date< Signed

B. Debs, A6 ting Section Chiefj /j/

Operational Programs Section g

Division of Reactor Safety

SUMMARY

-Scope: This routine, announced inspection entailed 175 inspector-hours on site

in ~ the areas of Surveillance -Testing, Maintenance Activities, and Operational

Activities for unit two, and the close out of-selected open inspection items for

unit one.

Results: Two violations were identified. The Violation (413/86-05-05), on

Hydrogen Skimmer Fan Isolation Valves not being environmentally qualified in

accordance with 10 CFR 50.49 is not being sited in the Notice of Violation. It

is under consideration for proposed enforcement policy and will be sited in

separate correspondence.

8604220535 860407

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REPORT DETAILS

1. Persons Contacted

Licensee Employees ,

J. W. Hampton, Station Manager

L. N. Adams, Quality Assurance

H. B. Barron, Superintendent of Operations

W. F. Beaver, Performance

T. B. Bright, Engineering Manager, Construction and Maintenance Department

B. F. Caldwell, Superintendent Station Services

E. M. Couch, Manager, Construction and Maintenance Department

J. W. Cox, Superintendent Technical Services

C. L. Hartzell, Compliance Engineer

R. A. Jones, Test Engineer

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J. Knuti, Operations Engineer

P. G. LeRoy, Licensing Engineer

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W. W. McCollough, Mechanical Maintenance

W. R. McCollum, Integrated Scheduling

J. F. McKcown, Mechanical Maintenance

D. B. O'Brien, Construction Technical Services

A. Pauly, Mechanical Maintenance

C. L. Ray, Principal Engineer

D. Rogers, IAE Maintenance

F. P. Schiffley, Compliance, Licensing Engineer

G. Smith, Superintendent Maintenance

J. M. Stackley, IAE Maintenance

J. W. Willis, Quality Assurance

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Other licensee employees contacted included engineers, technicians,

operators, mechanics, and office personnel.

NRC Resident Inspectors

K. VanDoorn, Senior Resident Inspector

P. Skinner, Senior Resident Inspector

Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on January 10, 1986, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

below. No dissenting comments were received from the licensee.

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Inspector Followup Item 413/86-05-01; Station Directive 3.2.2, Develop-

ment and Conduct of the Periodic Testing Program, the procedure will be

revised to require notification of the Shift Supervisor when surveil-

lance tests are not completed within the allowed Technical Specifica-

tion interval. (pcragraph 3)

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Inspector Followup Item 413/86-05-02, 414/86-07-01; Discrepancies noted

between the Catawba Periodic Test (CPT) Program data base and Technical

Specification required surveillance frequencies requirements.

(paragraph 6)

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Inspector Followup Item 413/86-05-03,414/86-07-02, Various maintenance

procedure deficiencies. (paragraph 8a, 8b)

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Violation 413/86-05-04; Two examples of inadequate maintenance

procedures; (1) IP/0/A/3820/01, Limitorque Valve Operator Corrective

Maintenance, incorrectly required the use of Unirex N2 grease. (2) The .

Catawba Lubrication Manual failed to specify what type of lubricant is

required for Limitorque valve operator Models SMB-00 and SMB-000, with

serial numbers below 295810 and Models SMB-0, SMB1, SMB2, SMB3, and

SMB4 with serial numbers below #302262. (paragraph 8a)

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Violation 413/86-05-05, Hydrogen Skimmer Fan Isolation Valves IVX1A and

IVX2B not environmentally cualified in accordance with 10 CFR 50.49.

(paragraph 8a)

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Inspector Followup Item 413/86-05-06, 414/86-07-03; Design Engineering .

Review and Implementation of Environmental Qualification Maintenance

Program. (paragraph 8a).

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Inspector Followup Item 413/86-05-07, 414/86-07-04; Concerns satellite

j document control station updating. (paragraph 8b)

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters

a. Unresolved Item (URI) 413/85-12-01; Concerns the lack of full adherence

to Station Directive (SD) 3.2.2 - Closed - Catawba Performance and

Compliance now receive attachments showing tests were not performed

within the time allotted by the program and the surveillance tracking

mechanism has been revised to handle specialized areas such as mode

change and surveillances dependent on Effective Full Power Days.

, Additionally, the licensee stated that SD 3.2.2 would be revised to

require notification of the Shif t Supervisor when a test is not

completed within the allowed Technical Specification (TS) interval, if

exceeding the TS interval makes the system inoperable. The licensee

was informed that the procedure revision will be an Inspector Followup

i Item (413/86-05-01).

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b. URI 413/85-12-03, Concerns the lack of formal feed back of operational

experience training and documentation to maintenance personnel -

Closed - By memorandum dated April 5,1985, the Maintenance Engineer

developed a required reading routing form which documents the feedback

of operational experience training. The Maintenance Engineer maintains

a log of all routing packages sent out to the department and all

packages are required to be reviewed and returned within sixty (60)

days.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Operating Procedures (42450)

The inspector reviewed the controlling documents for writing, reviewing,

implementing, and changing procedures. Additionally, the inspector reviewed

selected procedures, drawings., and logs to determine if they were being kept

in accordance with the controlling documents and also observed operations

personnel in their use of these procedures. The following operating

procedures were reviewed.

- OP/2/A/6100/01, Controlling Procedure for Unit Startup, Revision 0.

- OP/2/A/6350/01, Diesel Generator Operations, Revision 11.

- OP/2/A/6100/06, Establishing System Operability During Initial Unit

Startup, Revision 0

The inspector noted that tha procedures followed the recommended format, the

change records were updated as required, and the procedure had the

appropriate review and approval signatures.

The inspector observed a Unit 2 nuclear equipment operator perform

OP/2/A/6350/01, Diesel Generator Operations, enclosure 4.6, D/G 2A Checklist

for ESF Actuation, enclosure 4.10, local Diesel Startup and Shutdown and

enclosure 4.18, Diesel Generator Cylinder Head Leak Detection. The

inspector noted the following:

- The operator was very familiar with the procedure and had no problem

using it. Additionally, the operator's use of the procedure was in

accordance with Catawba Nuclear Station Directive 4.2.1, Development,

Approval and Use of Station Procedures.

- Enclosure 4.6, step 8., states, Check D/G Engine Jacket Water Standpipe l

Water Level to be greater than or equal to 1 on level indication (as '

indicated by gauge located on standpipe). The gauge is located at the )

top of the standpipe, approximately 40 feet above the operators

location. The operator had to climb up a temporary ladder which was

not very secure to verify the reading. This is considered a personnel

safety hazard and should be evaluated.

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- Enclosure 4.18, Initial Conditions Section 1, is lacking step 1.3,

which is the step used by the operator to document which Diesel

Generator is having the Cylinder Head Leak Detection Test performed.

Unit one enclosure 4.18 has this documentation requirement.

- The operator referred to the Diesel Generator logbook as required by

the Diesel Generator Operating Procedure. This logbook appeared to be

used and maintained in accordance with OMP 2-28, Diesel Generator

Logbook.

6. Surveillance Requirements

a. The inspector reviewed section 3/4.3, Instrumentation of the Catawba

Draf t Technical Specifications (TS) for Units 1 and 2. This section of

the draft was compared to the Unit 1 Technical Specifications and no

discrepancies were found. The inspector also compared the Instrumenta-

tion section of the draft with the surveillance requirements listed in

the Catawba Nuclear Station Unit 2 Surveillance Report. This is a

computerized printout of all surveillance requirements. Included on

this report is the frequency, applicable procedure number, responsible

section, and Standing Work Request (SWR) for each surveillance

requirement. The inspector identified several discrepancies between

the Draft Technical Specifications surveillance requirements and the

Surveillance Report. These discrepancies are as follows:

- 4.3.1.1.16A - The Surveillance Report requires a weekly surveil-

lance for the Operations section which is not required by the TS.

This discrepancy is also applicable to Unit 1.

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4. 3. 2.1.10A - The TS have an 18 month surveillance for the

Transmission section that is not contained in the Surveillance

Report. This discrepancy is also applicable to Unit 1.

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4.3.2.1.10B - The TS have an 18 month surveillance for the

Transmission section that is not contained in the Surveillance

Report. This discrepancy is also applicable to Unit 1.

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4.3.2.1.11B - The Surveillance Report requires a monthly

surveillance for the Transmission section which is not required by

the TS.

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4.3.2.1.15C - The TS have a monthly and an eighteen month

surveillance for the Transmission section. However, the

Surveillance Report only lists two monthly surveillances. This

discrepancy is also applicable to Unit 1.

- 4.3.3.1B through 4.3.3.15 - No titles or descriptions are listed

in the Surveillance Report for the applicable surveillance

requirements.

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4.3.3.3.1B - The TS have a monthly surveillance for the

Operations section that is not included in the Surveillance

Report. This discrepancy is also applicable to Unit 1.

- 4.3.3.9A - The TS have a daily and a weekly surveillance for the

Operations section. However, the Surveillance Report only lists

an "as required" surveillance. This discrepancy is also

applicable to Unit 1.

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4.3.3.3.1 through 4.3.3.3.4 - The TS have an eighteen month

surveillance that is not included in the Surveillance Report.

This discrepancy is also applicable to Unit 1.

The inspector noted that, even though these discrepancies exist, the

licensee has all TS surveillance requirements included in a procedure

for Units 1 and 2. In addition, these procedures specify the proper

frequency given in the TS. Thus, the licensee has provisions to

conduct all Instrumentation Surveillance Requirements although their

Surveillance Report has some administrative discrepancies. These

discrepancies were identified to the Performance section which is

responsible for the Surveillance Report.

Followup of corrective actions for the discrepancies identified above

is Inspector Followup Items (413/86-05-02, 414/86-07-01)

b. The inspector reviewed implementation of the requirements of Technical

Specification 4.3.2.1 from Catawba Unit 2 Draft Technical Specifica-

tions which states, in part, that each ESFAS instrumentation channel and

interlock and the automatic actuation logic and relays shall be

demonstrated OPERABLE by performance of the Engineered Safety Features

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Actuation System Instrumentation Surveillance Requirements specified in

Table 4.3.2 of Technical Specifications. These surveillance require-

ments were compared to the Catawba Nuclear Station Unit 2 Surveillance

Report to determine if required surveillances were scheduled and

performed as required. A sampling of these procedures was reviewed to

determine if necessary requirements to perform the Technical

Specification Surveillances were incorporated.

Of the procedures reviewed, necessary requirements appeared to be

adequately implemented. In addition, these procedures, as well as some

others, were reviewed for administrative sufficiency and technical ,

validity. This review consisted of in-office analysis of procedures l

discussion of procedure content with licensee personnel, and procedure '

walk-through with licensee personnel.

Mode 1 Periodic Surveillance Items, PT/2/A/4600/02A, was reviewed, in

part, with the licensee. Control Room operators appeared knowledgeable

about the procedure and its requirements.

No discrepancies were noted.

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Routine Test Procedure, Type ITE 27H Relay, PT/0/A/4971/06/R, was

reviewed with a licensee technician. The technician appeared

knowledgeable concerning the procedure. The Test Data Sheet could be

improved by ordering the sign-off's in the order that the procedure is

done.

Engineered Safeguards Features Functional Test, TP/2/A/1200/03A, was -

reviewed in part. No discrepancies were noted. The Upper Head

Injection System Functional Test, TP/2/A/1200/03B, was reviewed in part

and appeared to be adequate.

! In conjunction with this review it was determined that the test method

should preclude the occurrence of an incorrectly connected pressure

transmitter such as the incident at McGuire Nuclear Station in 1984.

In conjunction with the procedural evaluation of the Upper Head

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Injection System, performance of Work Request No. 004229 SWR was

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partially observed. This work request which was to perform channel

calibration using IP/2/B/3222/10, Upper Head Injection Surge Tank Level

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for 2NILT5700, could not be completed because of apparent air in the

calibration lines.

i 7. Performance Procedure (42450)

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PT 0/A/4971/10/R Revision 0, Routine Test

Procedure: ITE 270 Relays

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- PT 0/A/4971/06/R Revision 0, Routine Test

l Procedure: Type ITE 27H Relay

- PT/0/A/4600/12 Revision 3, Chemistry Periodic Surveillance items

f - PT/2/A/4250/02C Revision 0, Turbine Control Valve Movement

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j - PT/2/A/4600/02A Revision 0, Mode 1 Periodic Surveillance Items

- PT/2/A/4600/03A Revision 0, Monthly Surveillance Items

) The following performance procedures were walked through with licensee. '

- PT/2/A/4250/02F Revision 0, Turbine Startup Pressure Switch Alarm Test

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- PT/2/A/4250/02B Revision 0. Weekly Main Turbine Valve Movement

i On procedures reviewed and walked through, no deficiencies were noted.

l However, the inspector did note some program enhancements that could improve

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the use and understanding of these procedures. These general notes are as

follows:

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- The inspector found that there is no uniformity in inclusion of the

Technical Specification Surveillance Requirement Number in the

reference section of the applicable procedures. Approximately 50% of

l the procedures reviewed referenced a particular surveillance require-

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ment. The inspector considers that addition of the Surveillance

l Requirement Number will aid licensee personnel in identifying Technical

Specification items and should be included in all procedures if

applicable.

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Discussions with the Transmission Section indicated that these

personnel are knowledgeable of their procedures as evidenced by

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procedure walkthroughs. However, the inspector noted that the section

! personnel were weak in dealing with the Technical Specifications and

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applicable surveillance requirements. In fact, the inspector had to

explain where the surveillance requirements originated and how they

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are included in the Surveillance Report. The inspector considers

that the section should receive more training with regards to the

meaning and importance of surveillance requirements and the Technical

Specifications. The inspector considers that this increased training

would aid the Transmission Section personnel in understanding the

reascris for developing procedures to implement surveillance require-

ments(and the significance of test data that falls outside of Technical

Specification limits.

8. Maintenance Programs (42451, 35743)

a. Maintenance Procedures

Maintenance procedures used to comply with Technical Specification 6.8.1 and Regulatory Guide 1.33, Revision 2, February 1978 were

reviewed for format, administrative controls, technical adequacy and

completeness. Specifically, Appendix A of Regulatory Guide 1.33

requires that maintenance that can affect the performance of safety-

related equipment and should be properly pre-planned and performed in

accordance with written procedures, documented instructions, or

drawings appropriate to the circumatances.

(1) MP/0/A/7150/36, Pressurizer Power Operated Relief Valve Corrective

Maintenance: Problems were found in this procedure which were

later determined to be generic to all plant maintenance

procedures. The licensee was aware of these problems and was

correcting them in the periodic 2-year procedure reviews. These

problems related to a lack of detail in the parts list section of

procedures and on the use of cleaners and lubricants. Many

procedures specify the use of " approved lubricants" or " approved

cleaners" and problems have developed when attempting to determine

which cleaner or lubricant is approved. The revised procedures

will clearly specify approved materials. Although the parts lists

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contained in the procedures are very general, lack part numbers,

and are incomplete, this is compensated for by the work request.

Planners provide a complete computer printout of parts and part

numbers and attach this to the work request.

(2) MP/0/A/7150-38, Pressurizer Safety Valve Corrective Maintenance:

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This procedure specifies the disassembly and reassembly steps for

the Pressurizer Safety Valves. Section 12, Restoration, calls for

resetting and checking of the relief valve setpoint to be

performed in accordance with MP/0/A/7650/37. MP/0/A/7650/37,

Relief Valve Set Pressure Testing and Adjustment, specifically

prohibits the use of this procedure on Main Steam and Pressurizer

Safety Valves. Licensee representatives stated that these

procedures were not used since safety valve work is contracted out

to a test laboratory. After the exit meeting, licensee

representatives stated that this error had been detected by them

during a procedure review, and a draf t revision of the procedure

deleted the inappropriate procedure. This was not verified and

will remain a follow-up item to assure correction (413/86-05-03,

414/86-07-02).

(3) MP/0/A/7600/55, Limitorque Actuators Type SMB-000 Corrective

Maintenance and MP/0/A/7600/58 Limitorque Actuator Type SMB-00

Corrective Maintenance: Various problems with these procedures

were noted. Licensee representatives provided a draft copy of a

revision to these procedures which were in the review and approval

chain which correctly addressed the inspector's concerns. The

inspector requested a copy of the maintenance procedure for

Limitorque Actuator Type SMB 0 through 5 and found that no

procedure is available. The licensee reviewed its list of

safety-related valve actuators and found that SMB-1 actuators were

installed in the Nuclear Service Water System, and SMB 3 actuators

were installed in the Safety Injection System. The licensee noted

that the procedure is only required prior to maintenance being

performed on these actuators and speculated that the reason a

procedura does not exist is that these actuators have never been

worked on. They indicated that a procedure would be developed.

This will be left as another example of inspector followup item

(413/86-05-03,414/86-07-02).

(4) MP/0/A/7150/04, Component Cooling Water Pump Corrective Mainte-

nance: An apparent typographical error was located in step 11.5.6

of this procedure. The torque values specified for the coupling

bolts are given as 20 ft-lbs on the second pass but are also

provided in a second location. This second location, on Data

Sheet page 6, gives the second pass torque values as 190 ft-lbs.

This will be left as an Inspector Followup Item pending the

licensee's determination of toe correct torque values (413/

86-05-03,414/86-07-02).

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(5) IP/0/A/3820/01, Limitorque Valve Operator Corrective Maintenance:

This procedure is for instrumentation and electrical maintenance

work on Limitorque actuators. IE Information Notice No. 85-22,

Failure of Limitorque Motor-0perated Valves Resulting from

Incorrect Installation of Pinion Gear, was closed out by the

licensee with no action based upon IP/0/A/3820/01 which requires

correct installation of the motor pinion gear. The invector

reviewed IP/0/A/3820/01 and verified that step 10.1.6 required the

pinion gear to be installed in the correct position; however,

there was no further guidance in the procedure to aid maintenance

personnel i n the determination of the correct orientation.

Drawings that were contained in the procedure did not depict the motor

pinion gear and the referenced Limitorque Maintenance Manual,

Bulletin SMBI-170 also contained inadequate precautions. A more

recent Limitorque manual, Bulletin SMBI-82A, provides an accurate

detail of the pinion orientation and a caution statement in the

reassembly instructions; however, this procedure was not

referenced in IP/0/A/3820/01 even though it is a controlled

reference manual on site. Since the type SMB-0 actuator requires

the most caution on pinion gear orientation, the inspector

requested a listing of safety-related SMB-0 actuators. Licensee

representation stated that although they use SMB-0 actuators in

non-safety-related applications, they do not have any in safety

related use. The licensee stated that the procedure would, none

the less, be revised to more clearly depict the correct pinion gear

orientation. This will be left as another example of Inspector

Followup Item (413/86-05-03, 414/86-07-02).

An additional problem was found with IP/0/A/3820/01 in that it

specifies the use of Unirex N2 grease in the main gearcase of

actuators (Steps 10.1.4 and 10.1.11). This is contrary to the

rrechanical maintenance procedures (MP/0/A/7600/55 and MP/0/A/

7600/58) and the Station Lubrication Manual. Unirex N2 grease has

not been evaluated for compatibility with the greases approved by

the Station or Limitorque Corporation. The licensee was unable to

determine the source of this error. This is an example of a

violation against Technical Specification 6.8.1 for inadequate

maintenance procedures (413/86-05-04). An additional example of

this violation was found in the Catawba Lubrication Manual. The

Station Lube Sheet (page 11 of the Valves System) contains the

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lubrication type requirements for Limitorque operators. The lube

sheet requires Nebula EP0 to be used in Limitorque operators

Models SMB-00 and SMB-000 serial numbers 295810 and higher and

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Models SM80, SMB1, SMB2, SMB3 and SMB4 serial numbers 302262 and

l higher. The lubrication manual does not specify the lubricant

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type to be used in operators with serial numbers below those

specified. This is critical since Limitorque has stated in

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Bulletin SMBI-82A that the standard lubricant shipped with

actuators below serial number 295810 for SMB-00 and SMB-000 was

Sun Oil Co. SOEP and that Sun SOEP cannot be mixed with Nebula

EP-0. Although this information was known by the licensee and a

memorandum from Preoperational Projects to the Manager, Catawba

Nuclear Station dated September 17, 1981 indicated that Catawba ,

Maintenance was to use administrative controls to prevent improper ;

lubrication, the Station Lube Sheet remained inadequate. This is

the second example of Violation 413/85-05-04.

Since various documents indicate that up to three different

greases (Unirex N2, Nebula EP0 and SUN SOEP) may have been used

in Limitorque Valve Actuators, the licensee initiated a review

of maintenance records to determine the potential for mixed,

incompatible grease being installed in safety-related actuators.

An additional review is to be conducted in order to document which

actuators are required to use only Nebula EP0 as a result of the

10 CFR 50.49 environmental qualification requirements and to

substantiate that this qualified grease is indeed installed in

the required actuators. On the completion of this review, the

inspector was provided an intrastation letter for the Maintenance

Superintendent to the Compliance Engineer, dated January 13, 1986,

stating, no mixing of lubricants was found in safety-related

limitorque actuators. To avoid the possibility of mixed

lubricants in the future: (a) procedures will be revised to

reference the Catawba lubrication manual prior to addition of any

lubricant in limitorque actuators, (b) the Catawba lubrication

manual will be revised to reflect the correct lubricant in

limitorque actuators by their serial number. Additionally, the

inspector was provided a letter dated January 14, 1986, Catawba

Nuclear Station Limitorque Valve Motor Actuators Approved Gearcase ,

lubricants, Duke File: CN-1205.19. This letter stated, it should

be noted here that Limitorque manufactures two levels of environ-

mentally qualified actuators in their SMB/SB/SBD line:

" containment chamber" and "outside containment" actuators.

" Containment chamber" actuator have been applied at Catawba both

inside and outside containment. "Outside containment" actuators

are applied only outside containment, with the following excep-

tion: IVX1A, IVX28, 2VX1A, and 2VX2B (These applications have

been justified; reference SNM-1205.02-614). 1,2VX1A and 1,2VX2B

are isolation valves for the Hydrogen Skimmer Fans located inside

containment. The isolation valve operator is actuated coincident

with the startup of the hydrogen skimer fans, which are started

by the containment spray actuation signal ten minutes after the

containment pressure reaches 3.0 psig on a postulated loss-of-

coolant accident. CNM-1205.02-614, Duke Power Company Design

Engineering - Mechanical Systems and Equipment Section Engineering ,

Justification Report, dated June 15, 1984, based the continued use

of an outside containment actuator inside containment on Design

Basis Event environmental conditions of temperature and radiation

exposure to the motor insulation only.

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10 CFR 50.49, Environmental Qualification of Electric Equipment

Important to Safety for Nuclear Power Plant, section (d), states

in part, the applicant or licensee shall include the following

information for this electric equipment important to safety in a

qualification file:

(1) The performance specifications under conditions existing

during and following design basis accidents.

(2) The voltage, frequency, load, and other electrical

characteristics for which the performance specified in

accordance with paragraph (d)(1) of this section can be

ensured.

(3) The environmental conditions including temperature, pressure,

humidity, radiation, chemicals, and submergence at the

location where the equipment must perform as specified in

accordance with paragraphs (d)(1) and (2) of this section.

Section (e), states in part, the electric equipment qualification

program must include and be based on the following: (1) Tempera-

ture and pressure, (2) Humidity, (3) Chemical effects,

(4) Radiation, (5) Aging, (6) Submergence, (7) Synergistic

effects,and(8) Margins.

On January 17, 1986, the inspector was provided with additional

information, a letter from Chief Engineer, Mechanical and Nuclear

Division to Manager, Catawba Nuclear Station dated January 17,

1986, the letter addressed the other environmental conditions for

the valve actuators including SUN SOEP grease and the licensee

stated that the information is sufficient to demonstrate that

IVX1A and IVX2B are environmentally qualified in accordance

with 10 CFR 50.49.

The inspector informed the licensee that lack of proper

documentation of the environmental qualification of IVX1A and

IVX2B motor operator, from November 30, 1985, until January 17,

1986, is a violation of 10 CFR 50.49 (VIO 413/86-05-05).

(6) Maintenance of Environmental Qualification of Electrical Equipment

Important to Safety (10 CFR 50.49): 10 CFR 50.49 requires that a

record of the environmental qualification of electric equipment

important to safety must be maintained to permit verification that

each item meets its specified performance requirements when it

must perform its safety function up to the end of its qualified

life. Implicit in this requirement is that records must be kept

to substantiate that periodic maintenance activities required to

maintain a piece of equipment in its qualified condition have been

performed. The licensee specifies these periodic maintenance

requirements in the Catawba Nuclear Station Equipment Qualifica-

tion Reference INDEX (EQRI). Station groups responsible for

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performance of EQRI mandated maintenar,ce have identified

outstanding maintenance activities and alternate actions which

they believe have satisfied the intent of the EQAI. The station

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requested a Design Engineering Review of these actions on

March 27,1985. As of January 9,1986, the Design Engineering

Review is incomplete. Although an in-depth review and revision of

the EQRI is in progress by Design Engineering, the potential

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exists that the qualifications of some equipment may have been

l compromised or invalidated due to a failure to maintain the

l equipment in its qualified condition through periodic maintenance

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activities. This item will be left as an Inspector Followup Item

pending completion of the Design Engineering review and

implementation of corrective actions if necessary (413/86-05-06,

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414/86-07-03).

b. Preventive Maintenance

The inspector reviewed procedures associated with maintenance

activities on equipment and components employed during plant

operations. Particular attention was given to the Preventive

Maintenance Department and their program. This, in turn, led to

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procedure reviews in the Instrumentation and Electronics Department as

well as the Maintenance Department.

- Procedure No. PM/IG-048 is the preventive maintenance program for

the instrument air system dryers. This is an annual maintenance

program for the refrigerated air dryers. The procedure references

CNM 1213.00-0135 as its technical manual. This manual was not

available in document control and was found to be superseded by a

drawing, CNM 1210.03-0095, on 8/25/83. The procedure did not

reflect this change. The referenced manual, CNM 1213.00-0135 was

found in a satellite document control in the Maintenance Depart-

ment. Upon review of the manual it was revealed that the drawing

that superseded the manual was derived from the manual itself.

These inconsistencies indicate two possible deficiencies.

First is that of a procedural discrepancy in that PM/IG-048

referenced a superseded document for a technical manual. This is

identified as another example of Inspector Followup Item (50-413/

86-05-03 and 50-414/86-07-02). Secondly, the satellite document

control station in the Maintenance Department not being up to date

with the central document control indicates a lack of adequate

document control. This is identified as Inspector Followup Item

(413/86-05-07,414/86-07-04).

Additionally, the inspector questions why a technical manual that

has comprehensive maintenance instructions and a troubleshooting

section would be superseded by only a drawing. This is an

inspector concern.

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Procedure No. PM/IG-049 addresses preventive maintenance on the

station air system on a semi-annual or refueling basis. The

procedure was clear and comprehensive. The inspector also reviewed the

referenced technical manual, CNM 1213.00-089 and found that the

maintenance procedure matched the suggested maintenance in the

technical manual with the exception of the flow control valve,

which had no maintenance specified in the procedure. The

inspector did not have the opportunity to determine whether this

was an intentional or inadvertent omission. This is an inspector

Concern.

The following procedures and their referenced technical manuals

were reviewed for completeness, clarity, and proper control. All

were judged adequate.

- PM/IG-023 Nitrogen System. Maintenance on a yearly basis. Vendor

Manuals: CNM-1340.00-0020, Indeeco Gas Preheater; CNM 1205.06-267

and 268, Fisher Technical Manual; CNM 1210.03-10, Moore Technical

Manaal.

- rM/IG-047 Instrument Air Compressors and Associated Equipment.

Maintenance on a quarterly and semi-annual basis. Vendor manuals:

CNM 1213.00-41, Gardner-Denver Air Compressor Service Manual; CNM

1213.00-43, Gardner-Denver Air Compressor Parts Manual; CNM

1320.00-1, Reliance Electric Air Compressor Motors.

- PM/IG-084 Auxiliary Feedwater Turbine / Pumps. Maintenance on a

semi-annual and annual basis. Vendor Manuals: CNM 1201/05-179,

Bingham Pumps; CNM 1201.05-269, Terry Turbines Technical Manual.

- PM/IG-085 Auxiliary Feedwater Motor Driven Pumps. Maintenance on

a yearly basis. Vendor manuals: CNM-1201.05-0360, Bingham Pumps

Technical Manual; CNM 1318.16-14 We-tinghouse Motor Technical

Manual.

The inspector noted that there was no scheduled preventive maintenance

un Limitorque valve operators. The present policy is to trend failures

first to see if preventive maintenance is needed. This is accomplished

three ways: (1) a quarterly review of frequent failures (three or

more) in a s (2) a yearly review of all systems and their

failures; (3)ystem;all work requests are processed through the Preventive

Maintenance Department and a pattern of failure may or may not be

noticed this way. The lack of preventive maintenance on Limitorque

valve operators is an inspector concern.

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The inspector also reviewed maintenance procedures.

- Procedure No. MP/0/A/2001/05 Westinghouse DS-416 Air Circuit

Breakers. Maintenance on a semi-annual basis. The procedure

appeared to be complete and clear. The Associated Technical

Manual (CNM 1399.40-0011) was in document control. The inspector

also tracked down the lubrication kit specified on a work request

that used this procedure and found it to be the proper type

specified in the vendor's Technical Manual.

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Procedure No. MP/0/A/7400/16 Diesel Engine Cylinder Head

Corrective Maintenance. Maintenance every refueling outage. This

procedure adequately addressed the maintenance requirements and

was well organized. However, the referenced technical manual was

listed as CNM 1302.00-237, Delaval Instruction Manual Vols. I &

II., and it was not found in Document Control under that number.

Instead it was found as CNM 1301.00-237. This could have been

just a typographical error, but it is another example of

procedural discrepancies identified as Inspector Followup Item

(50-413/86-05-03) and (50-414/86-07-02).

The inspector reviewed the following Instrumentation and Electronics

procedures. All were found to be adequately written and controlled.

- IP/0/A/3200/08A Train A Reactor Trip Breaker Trip Device Monthly -

Functional Test.

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IP/0/A/3230/06 Procedure for Disconnection and Connection of

Incore Thermocouple Cables.

- IP/0/A/3240/13 Excore Nuclear Instrumentation System - Detector

Plateau Curve Plotting.

In all of these maintenance procedures, there were clear instructions

as to tagging out the equipment being worked on, notifying operations

that work was being done, and subsequently removing the tags when the

equipment was put back in service.

9. Operating Staff Training (41301)

A training assessment was performed for Catawba Unit 1 and 2 under

inspection report nos. 50-413/84-93 and 50-414/84-42. This inspection

satisfies the objectives of Inspection Procedure 41301, Inspection of

Operating Staff Training.

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10. Followup on Previously Identified Items

IFI 413/85-12-04; The licensee stould take action to provide a management

review to ensure that when steps are deleted from procedures that they are

deleted in an appropriate fashion. CLOSED - The licensee stated that the

Shift Supervisor is the appropriate final reviewer of completed procedures

and no required post review is needed or desired.

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ML20141F378

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