IR 05000219/2003001

Notice of Violation from Insp on 850219-0301 & 11-22. Violations Noted:Design Control Measures & post-turnover Wiring Changes for Class 1E Wiring Not Documented & Bolts, Fasteners & Pump Motors Unmarked

ML20132F316
Person / Time
Site:	Millstone, Oyster Creek
Issue date:	07/12/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20132F300	List: IR 05000219/2003001 ML20132F297
References
50-423-85-04, 50-423-85-4, NUDOCS 8507180387
Download: ML20132F316 (4)

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APPENDIX A NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket No. 50-423 Millstone Nuclear Power Station, Unit 3 License No. CPPR-113 During the NRC Construction Appraisal Team inspection from February 19 - March 1 and March 11-22, 1985 and in accordance with 10 CFR 2, Appendix C, the following violations were identified (Section references are to Inspection Report No. 50-423/85-04): CFR Part 50, Appendix B, Criterion III, as inplemented by Northeast Utili-ties Quality Assurance Program (NUQAP) Topical Report, Quality Assurance Pro-gram (QAP) 3.0 requires that measures be established to assure that applicable regulatory requirements are correctly translated into specifications, drawings, procedures and instruction Contrary to the above, as of March 22, 1985, the licensee's design control measures for Class 1E wiring did not assure that applicable requirements were correctly translated into appropriate documents, in that eight termination tickets were not revised to incorporate required engineering changes (Section II.B.2.b.(6)).

This is a Severity Level IV Violation (Supplement II). CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be accomplished in accordance with appropriate instruction Contrary to the above, as of March 22, 1985, activities affecting quality were not accomplished in accordance with prescribed instructions as evidenced by the following: Discrepancies involving post-turnover wiring changes for Class 1E cable terminations were discovered and were not documented at the time as re-quired by Section 5 of the NNECo Startup Manual (Section II.B.2.b.(6)). Errors in document and specification distribution, filing and updating were identified at the controlled drawing stations. That resulted in lack of the drawing correctness specified in SWEC Construction Methods Procedure 11.1, Job Site Document Control, Revision D, and SWEC NEAM 32, Supplier Technical Document Review and Distribution - Millstone 3 - NUSCO, Revision 9 (Section VII.B.1).

This is a Severity Level IV Violation (Supplement II). CFR 50, Appendix B, Criterion VII and NVQAP QAP 7.0 require that measures be established to assure that purchased equipment conform to the procurement document f 8507180387 850712 gDR ADOCK 0500 3 f 0F?ICIALRECORDCOM L

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., Cont try to the'adove,.aC of March 22, 1985, measures were not adequate to

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+ s vend 68 supplied tantd and sheat exchangers were received, accepted and in-with welds thad were undersized or had an unacceptable surface condi-

[ } N.:] tion (SectionIV.B.2{.',' s p'  % t ;+ ;TpIs is a Severityjlevel '1V Violation (Supplement II).

i )\ N s ij g p>f 1hCFRPart50,AbpendixB,CriterionVIIIandNUQAPQAP8.0requirethat

J iN) 1 g rpasures be established for the control of materials, parts and components ctat,p'revent

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Contrary to the above, as of March 22, 1985, the material traceability and

}s , . control of some fasteners, including bolts for mounting large pump motors, have not,been adequate to assure the use of correct materials in that:

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" Unmarked l mounting bolts were used for the motors on the Quench Spray ji Y)i, Pumps (3QSS-P3A, B), Safety Injectian Pump (3SIH-P18), Chemical Volume ControlPumjs(3CHS-P1A,B;P3A,B,C),andComponentCoolingCharging

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A Pumps (3CCE-P1A, B).

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(Inmarkedbiltswereusedintheba'tteryrackassembliesinthefivebat-

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Unmarked bolts were used in motor control centers to connect adjacent-

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D je d.\(3CES*TBMB30).5<Unmarked bdln.were used for mounting Control Board Te

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< o $ 1 h# p This'is d Severity Level IV Violation (Supplement II).

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. 10 CFR Part 50, Appendix B, Criterion X and NVQAP QAP 10.0 require that a

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<- Contrary to the above, as of Marco 22, 1985, the licensee's inspection program j g 'j6 kd lnot: executed, to verify conformance with design documents in-that:

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>' + FQC acceptance criteria for placement of pipe supports and restraints

f /were different than engineering design. That resulted in support at-tachment locations which were not as depicted by design drawings, as

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jalackofaccountingforwidelocationchangesinsupport/restraintde-sign calculations and in the associated FQC acceptance criteria (Section

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FQC accepted eq'uipment foundation bolting connections which were not

/ installed as designed (Section III.B.5.b).

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Appendix A 3 Accepted welds in skewed pipe supports were not of the size required by design (Section IV.B.3).

This is a Severity Level IV Violation.(Supplement II). CFR Part 50, Appendix B, Criterion XVI and NVQAP QAP 16.0 require measures to assure that conditions adverse to quality are promptly identified and cor-rected, including action to avoid repetitio Contrary to the above, as of March 22, 1985, the licensee had not: Promptly identified and corrected numerous separation deficiencies in vendor or modified vendor wiring installations within the main control boards (Section II.B.2.b(2)). Provided measures to bring about prompt action to avoid recurrence of significant nonconformances noted in N&Ds and irs (Section VIII.B.1.b(1)). Adequately corrected previously identified deficiencies in the area of preventive maintenance after turnover of equipment to operations (Section VIII.B.1.b(2)). Adequately corrected identified document control deficiencies (Section VIII.B.1.b(4)).

This is a Severity Level IV Violation (Supplement II).

Pursuant to 10 CFR 2.201, Northeast Nuclear Energy Company is required to submit to this office, within thirty days of the date of this letter transmitting this Notice, a written reply including: (1) corrective steps taken and results achieved; (2) corrective steps to be taken; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response tim The reply directed by this Notice is not subject to clearance by the Office of Management and Budget as otherwise required by the Paperwork Reduction Act of 1980, PL 96-51 .

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APPENDIX B CONSTRUCTION PROGRAM WEAKNESSES The NRC Construction Appraisal Team (CAT) identified the following construction program weaknesses at Northeast Nuclear Energy Company's Millstone Unit 3 during the period February 19 - March 1 and March 11-22, 198 . Control of work on systems and components subsequent to turnover from Con-struction to the testing organization requires improvement. This is indicated by the deficiencies found in the control of wiring changes, and preventive maintenance deficiencies found in the mechanical and electrical areas subse-quent to turnover to the startup organizatio Additional attention is needed to ensure that missed maintenance activities are evaluated as to the potential damaging effects on the components. These findings indicate the need to re-evaluate the controls applied to activities subsequent to system turnover from Construction to Operation . A number of hardware deficiencies were identified which appear to have been caused by a lack of effective communications between the design, construction, and inspection groups. Design parameters were in some cases not properly translated into inspection criteri For example, pipe supports have been installed and accepted by QC with dimensional tolerances not in accordance with the design calculations. In addition, a lack of thoroughness on the part of the design organization was identified. Examples identified include: omis-sion of the Residual Heat Removal System from the pipe support " lugs-in-con-tact" review; wiring termination changes made to drawings without the issuance of the necessary documents to control the actual construction work; inadequate technical justification for the acceptance of unmarked fasteners in certain motor control centers; and conflicting details for a structural steel end connectio . A significant number of document control errors were found at both the Quality Control and Construction drawings stations. This is of particular concern in that the deficiencies in document control had been identified previously, and the number of audits increased to monitor the situation. In fact, a 100%

audit of all drawing stations had been performed just prior to the start of the NRC CAT inspection. The corrective actions taken had not been effective, howeve . A number of findings indicate that the effectiveness of Quality Control in-spection activities needs to be improved. These findings include the area of piping as-built drawings, mechanical equipment foundation anchorage, struc-tural steel connections (welded and bolted), piping support welding (pipe straps and skewed fillet welds), and pipe support miscellaneous hardware (lock nut tightness, cotter pin installations, etc.). Also, vendor deficiencies were identified in the areas of tank and heat exchanger fillet welds (prm sure boundary and supports), performance of load indicating washers, and marking of fastener The foregoing identified weaknesses require additional management attention to assure that completed installations meet design requirement FFICI AL EECCED CCFY L "