IR 05000320/1977011

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IE Insp Rept 50-320/77-11 on 770321-24.Noncompliance Noted: Failure to Perform Required Checks of Containment Penetration Conductors
ML19220A597
Person / Time
Site: Crane Constellation icon.png
Issue date: 04/25/1977
From: Mcgaughy R, Narrow L, Sanders W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19220A592 List:
References
50-320-77-11, NUDOCS 7904230151
Download: ML19220A597 (16)


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Reg I Form 12 (Rev Feb 77)

P U. S. fiUCLEAR REGULATORY COMMISS10ti 0FFICE OF INSPECTIO!! AND ENFORCEtiENT

REGION I

IE Inspection Report No:

50 4 20/77-11 Docket No:

50-320 Licensee: _ttstrocolitan Edison Company License ?!a:

CPPR-66 uy Ca?

n Priority:

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Readino, Pennsvivania 19603 Category:

B Safeguards

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Location:

Middletown, Pennsylvania (THI-2)

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Type of Licensee:

PWR 2772 MWt (B&W)

Type of Inspection:

Routine, Unannounced Dates of Inspection:

March 21-24,1977 Dates of Previous Inspecti

March 14-18,1977 Re ting Inspector:

y-[//[77 L. Narrow, Reactor Inspector

/ DKTE Accompanying Inspectors: 'rY [ M xde d g/f, /77 W. F. Sanders - eactor Inspector

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/DATE 2F Y/u 77 A. E.'Finkel, Re/ctor Intpector

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DATE Other Accompanying Personnel:

Terr-1. Johnson, NRR DATE Reviewed By:

,[Y, M tt yh/7j

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R. W. McGaughy6tpj6f, Construction Projects Section

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BATE Reactor Construction and Engineering Support Branch

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S_UMMARY OF FINDINGS Enforcement Action Infraction 77-11-01 - Failure to perform required checks of containment penetration conductors. Contrary to 10 CFR 50, Appendix B, Criterion X electrical containment penetrations R-414, R-516, and P.-520 had been accepted by Fie!d QC although required resistance between conductor checks had not been performed as required by ECP-9-2.

(Details, Paragraph 3)

Licensee Action on Previously Identified Enforcement Items None.

Design Changes None.

Unusual Occurrences None.

t Other Significant Findings A.

Current Findings 1.

Unresolved Ite ;

77-11-02 - Documentation was not available to show that qualifications of consultant personnel temporarily assigned to Field QC had been reviewed and evaluated following completion of the~.. training--

(Details, Paragraph 4)

2.

Acceotable Items a.

Welding Documentation for Condensate Storage Tank B.

(Details, Paragraph 5)

b.

Deviation and Audit Reports for Structural Steel Installa-tion.

(Detail, Paragraph 6)

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Flushing and Hydrostatic Test Procedures and Records c.

for Decay Heat Lines.

(Details, Paragraph 7)

d.

Reactor Coolant Pipe Welding Nonconformances.

(Details, Paragraph 8)

Review of QC Records and Observation of the As-Installed e.

Condition of a Portion of the Decay Heat Line.

(Detafis, Paragraph 9)

f.

Observation and Records of Cable Pulls and Terminations of 4160 Volt Cable.

(Details, Paragraph 10)

Records of Instrument Calibration and Setting.

(Details,

Paragraph 11)

B.

Previously Recorted Unresoived Items The following items have been resolved:

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1.

Repair of Dike Riprap.

(Details, Paragraph 12)

2.

Electrical Termination Workmanship.

(Details, Paragraph 13)

3.

Licensee Identified Temporary Runs of Safety Reiated Cable.

(Details, Paragraph 14)

4.

Acceptance of Nonconforming Small Bore Piping Restraints by Field QC.

(Details, Paragraph 15)

The following item remains unresolved:

Fire in the ITE Motor Control Center.

(Details, Paragraph 16)

C.

Deviations None.

Exit Interview An exit interview was held at the site on March 24, 1977.66-113

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Persons Present Metrocolitan Edison Comoany J. R. Floyd, Supervisor of Operations R. W. Bensel, Electrical Engineer General Public Utilities Service Corporation R. F. Fenti QA Auditor S. Levin, Project Engineer M. J. Stromberg, Senior Site Auditor R. L. Wayne, Construction QA Manager J. E. Wright, Site QA Manager L. M. Zubey, Mechanical Engineer

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United Encineers and Constructors J. Carrabba, Field Superintendent QC/ Construction A.

Scope of Inspection The inspector stated that the inspection was conducted to review the status of outstanding items and QC program for piping electrical (

work and structural welding.

B.

Inspection Findings The inspector summarized the results of the inspection as listed in the Summary of Findings.

In each case the licansee acknowledged the information.

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DETAILS 1.

Persons Contacted Metrocolitan Edison Comoany D. Bensel, I and C Engineer J. M. Cajigas, Engineer R. Leffin, Supervisor, Mechanical Engineering Section

  • R. Stump Electrical Supervisor (Reading Office)

General Public Utilities Service Corporation R. F. Fenti. QA Auditor W. T. Gunn, Project Site Manager P. Karish, Electrical Engineer S. Levin, Project Engineer P. A. Levine, QA Auditor M. J. Stromberg, Senior Site Auditor J. E. Wright, Site QA Manager R. L. Wayne, Construction QA Manager United Engineers and Construction

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R. Crofton, Lead QC Engineer J. Godleski, QA Engineer K. Harvey, Office Engineer D. Lambert, QC Supervisor L. Lundstrom, QC Inspector J. O' Conner, QC Document Engineer D. Rhyne, Startup and Test Engineer J. Schmidt, Records Supervisor F. Statcher, Assistant Project Supervisor Gilbert Associates A. Miramori, Hydrology Engineer

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Burns and Roe G. T. Harper, Site Project Engineer

  • Telephone Conversation

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2.

General

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At a pre-inspection meeting with the licensee's representatives, the inspector discussed the scope and duration of the inspection.

The licensee's representative stated that information had been rectived from Babcock and Wilcox (B&W) concerning a cracked bolt on the reactor internal guide blocks at Davis-Besse.

As a result, B&W was preparing to modify the guide blocks at this plant.

This problem was reported to the inspector as a significant deficiency in accordance with 10 CFR 50.55(e).

The inspector was informed that approximately 200 men, primarily pipefitters and electricians, were working on a second shift.

The total work force including administrative and supervisor personnel was approximately 1750. Work was on schedule although modification of the guide blocks may result in a delay.

IE Circular No. 77-01, " Malfunctions of Limitorque Valve operators was discussed with the licensee's representative.

The inspector was informed that procedures are available for setting the torque limit switches.

However, provisions to assure that the valves are checked following maintenance and that operating personnel are properly instructed should be included under operating procedures and were not reviewed by the inspector.

i The inspector also audited memoranda dated August 29,1974, and September 18, 1974 from MPR Associates to GPUSC concerning review of Unit 1 problems for applicability to Unit 2 and corrective action, if any, required. The procedure consisted of review of Unit 1 problems; determination of applicability to Unit 2; deter-mination if already resolved by design; recommended action for open problems; and preparation of a list of open problems with rec-ommended action.

3.

Failure to Perform Required Checks of Containment Penetration Conductors The inspector reviewed UE&C procedure ECP-9-2, " Receiving, Handl-ing, Storing, Installing, and Testing of the 8KV and Low Voltage Electrical Penetration Assemblies," dated January 30,1976, Revis-ion 3.

Paragraph 6.2.2.2 titled " Low Voltage Penetrations, states the following, " Insulation resistance between conductors and between conductgrs and metal framework or headerplate shall ne greater than 10 ohms at room temperature for power and control conductor." Checks to verify these resistance values are required.

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The inspector aud._d the QC records for containment penetrations R-516, R-414 R-520, and R-500.

Resistance between conductor checks had not been performed for penetrations R516, R414, and

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R520. The data sheets of QC reports E14848 (R-516), E14860 (R-414), and E14901 (R-520), which formee. the basis for acceptance of

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the penetrations, did not contain entries for resistance between conductor checks as required by the afot2 mentioned procedures.

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QC reports were signed and dated by the OC inspector accepting the penetrations on June 10,11, and 28,1976.

Report E15133 (R-500)

had both the resistance between conductor and conductor to metal framework resistance values recorded on the data sheet.

Failure to perform the test requirements of UE&C Procedure ECP-9-2

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is contrary to the requirements of 10 CFR 50, Appendix B, Criterion l

X, which states, in part, "A program for the inspection of activi-ties af fecting quality shall be... executed...to verify conformance

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with documented instructions, procedures...." and FSAR paragraph 17.1.10.4, which states in part, " Activities affecting quality are verified by inspections...Their activities are conducted in accord-ance with written procedures, instructions, and checklists with the results documented...."

This item (77-11-01) is a noncompliance.

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Qualification of Field OC Personnel The inspector reviewed the requirements of UE&C Procedure CC 29-3, Revision 3, dated April 18, 1975, titled " Quality Control Personnel Trainino and Qualifications." Section B of this procedure states the following, "After two weeks of indoctrination and training...

an evaltation of the inspector's progress has been submitted by the responsible QC Engineer. This written evaluation is placed in the personnel file and documents successful completion of the training program.

An audit of the QC inspectors personnel files by the inspector indicates that evaluation of the Field QC inspec'ers progress had been placed in the files of UE&C employees.

How. er, a number of temporary employees have been assigned to Field QC. Thase men have been obtained from consultants now performing or who have prev-iou:

performed QC functions for the licensee. Written eval-uatit of the progress of the temporary employees was not avail-able in their personnel files although they had taken the pre-scribed indoctrination and training courses.

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The licensee's representative stated that this question would be reviewed to determine whether a written evaluation was or should be required for temporary employees by Procedure QC 29-3.

This item (77-11-02) is unresolved.

5.

Condensate Storage Tank - Welding Records The inspector examined the welding records shown below for weld joints B4, IV3, 3V2, HB2, and 2H4 of Condensete Storage Tank CO-TIB.

a.

Inspection records including visual and NDE inspections.

b.

Weld history records.

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c.

Welding material control records.

d.

Welder qualification records.

e.

Inspector qualification records.

No discrepancies were identified.

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6.

Deviation and Audit Reports - Structural Steel Installation Deviation Reports DRs The inspector examined the DRs listed below to determine whether the records are complete, legible, retrievable, and properly closed out.

DR No. 0091 - High Strength Steel Bolts

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DR No. 0174 - Anchor Bolts for Beam 231b2

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DR No. 0150 - Structural Steel Columns

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DR No. 0230 - Support Steel

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DR No. 0312 - Verticality of Beam

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Audit Reports The inspector examined Audit Reports No. GPUSC 75-31 and 76-02 as well as B&R Surveillance Report No. 4 all of which were concerned with structural steel installation.

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Audit Report GPUSC 76-02 was an aydit of repair of Core Flood Tank Two CF-T-1B anchor bolts during January 30-February 4,1 Records thereafter show corre-a le'ter dated February 5,1976.

spondence between GPUSC Audit Group, GPUSC Quality Assurance 16,1976, to UE&C resulting in QA instructions to UE&C on July upgrade inventory control and tagour items of stock steel which are The findings were closed out on August 12, 1976, af ter inspection of stock steel inventory and review of QC of doubtful origin.

packages show satisfactory control to have been established.

No discrepancies were identified.

Flushing and Hydrostatic Test Procedures and Records 7.

Hydrostatic and Flushina Procedures _

An inspection was made of the procedures and records related to the hydrostatic and flushing procedures for the Decay Heat systems The testing programs for this system was identifed to MTX #47.

developed to individually test it in six (6) sections which is documented on individual test reports and a marked print for a composite record.

Records of tests and the following procedures were reviewed:

I General Procedure for Hydrostatic and Pressure Testing of a.

Systems and Components TP 250/2.

General Procedure for Cleaning and Flushing Systems and Components b.

TP 250/4.

No discrepancies were identified.

Reactor Coolant Pipe Weldino Nonconformances 8.

An inspection was made of nonconformance records relative to theT reactor coolant pipe welding activities.

to determine whether the nonconforming activity or component is specifically identified ~ or described and whether the records are The complete, legible, retrievable, and properly closed ou review.

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Deviation Report No. 0512 - Ultrasonic Test Indication Deviation Report No. 0464 - Stress Relieve Temperature Deviation Report No. 0454 - PWHT on Inlet Nozzle (OTSG)

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Deviation Report No. 0069 - Are Strike on Spool Piece Deviation Report No. 0446 - PWHT on Weld Joint

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No discrepancies were identified.

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Insoection of Decay Heat Pioing An inspection was made of part of the decay heat systems from the first horizontal run outside of the 36" reactor vessel outlet pipe to the pump room, to ascertain whether the hardware and related

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records reflect work accomplishment consistant with Quality Assur-The decay heat lines j

ance plans, instructions, and procedures.

were selected for this inspection based on the information that Phase I inspection of these lines had been completed and they were It was noted in Phase II as defined in UE&C procedure QC-16-2.

that the inspection report contained a checklist of approximately 180 items that could be categorized into incomplete, rework, and deficient items that were to be corrected or justified by sub-Further information sequent action during the Phase II period.

obtained revealed that QC activities subsequent to the Phase I inspection were of a paper work nature and did not provide for another visual examination prior to the pipe surfaces becoming I

inaccessible by insulation, attachment of penetration seals, or installation of hanger and support.

The inspector discussed the possibility of surface damage to the

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piping subsequent to Phase I inspection with the licensee's representatives.

In order to assure that the condition of the system is not affected by other construction activities in the area, Field Change NoticeFCN (FCN) QC-241 was issued prior to completion of the inspection.

QC-241 revises UE&C Procedure QC-16-2 as follows:

Page 6 IV.C.4

"If insulation of a system and/or equipment is to be installed after Phase I has been completed but prior to Phase 11 final inspection, Quality Control will perform an inspection to assure that no degradation This inspection of the system has occurred since Phase I completion.

will be documented in an inspection report and will become part cf the Phase II documentation."

No discrepancies were identified.

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10.

Cable Pulls and Terminations The inspector examined the Burns and Roe cable pull slips for the fol'.owing cable pulls:

4160 volt Circuit No. HH20P Auxiliary Building 328'-0" to a.

Auxiliary Building 258'-6".

ES. Channel B.

b.

4160 volt Circuit No. HG20P Auxiliary Building 328'-0" to Auxiliary Building 258'-6".

ES Channel A.

Control Circuit No. MA274 C I.C. System (Red)

c.

d.

Control Circuit No. MA 22c ES Channel A (Red)

Control Circuit No. MA273C I.C. System (Red)

e.

The above cables were pulled and witnessed by QC inspection as defined in UE&C procedure ECP-3-2.

The inspector examined the 4160 volt and control cable termination, except for Control Circuit No. MA22c.

circuit were in the process of being pulled.The cables for this control The inspector witnesseo the cable pulls.

The inspector also observed that the terminations of circuits HH20P, HG20P, MA274C, and MA273C were completed and

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the documentation signec: by the QC inspector who verified the acceptance to the requirements of UE&C procedure ECP-3-2.

No discrepancies were identified.

11.

Instrument Calibration and Setting Records The inspector audited the procedures for the calibration and control of equipment that is being maintained by UE&C and their subcontractor UE&C Mechnical Construction Procedure MCP-13-2 titled " B of Plant Instruments," Revision 2, dated May 10, 1976 the calibration and control requirements for both UE&C and theirwhich esta contractors / vendors.

Instrument Control," Revision 5, dated August 9,1974, which establishes the DC inspection criteria.

The inspector audited selected site and contractor deviation reports

instrumentation record file, and internal audit reports as follows:

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Deviation Reports 0715, dated February 21, 1977, and Deviation Report 0701 dated February 7,1077, were reviewed and the inspector found that the disposition was made and approved in accordance with the requirements of UE&C procedure MCP-13-2 and QC-13-2.

b.

Instrumentation record files 1-1331, I-2323, and I-2324 were recorded with the equipment classification letter, calibration data, due dates, serial number of the item, and remarks.

The instrumentation data cards were signed and dated by.

the QC instrumentation engineer.

c.

Internal audit reports #130 dated January 19,1976, and #136 dated April 7, '976 on Johnson Controls and Johnson Controls /

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Mul ti-Amp. The :nspector found that these audits had been performed in accordance with the QA Program requirements, d.

Records of Make-Up and Purification System pressure monitoring components MU-2-PT, MU9dPT(H), MU32E/P(C), and MU-Pl-2001 for conformance with the calibration requirements of the QA program.

No discrepancies were identified.

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12. Repair of Dike Riprao Apparent erosion of the dike adjacent to the river water intake structures and settlement of riprap in other sections of the dike had been identified as an unresolved item. (Inspection Report 50-320/

75-06) The inspector with a Hydrology Engineer from the Office of Nuclear Reactor Regulation observed the repaired condition of the dike at locations which had shown evidence of settlement and reviewed the following documents.

a.

Letter Gilbert Associates, Inc. (GAI) tt, GPUSC dated July 27, 1976, which discussed the requirements for toe and slope protection.

b.

Letter GAI to the licensee dated December 9,1976, which stated that repair of dike had been performed in accordance with the letter (a. above) using stone meeting the gradation require-ments of GAI report " Dike Riprap Evaluation-Final Report" dated October,1975.

This item is resolved.

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13. Electrical Terminations - Workmanship Lack of requirements for proper installation of solderless electrical terminations had been identified as an unresolved item.

(Inspection Report 50-320/76-12)

The inspector reviewed UE&C Procedure ECP-3-2, Revision 22, "Re-ceiving, Storing, Handling, and Installing Wire and Cable." This procedure was revised by the licensee to correct a previously identified unresolved item concerning the criteria to be used for acceptance of cable terminations.

The quality control checklist for cable terminations in step 13 now states the following:

" Verify that all terminations on compression type terminal blocks are made as follows:

All strands of conductors are under terminal contacts and a.

conductors are properly compressed.

b.

Insulation is not under contact nor is stripped.to such a point that the bare conductor can reach other conducturs."

The inspector randomly selected Local Control Stations MB257C, HB159C, and MA6C for cable termination inspection and found that these criteria were met.

This item is resolved.

14. Temporary Runs of Safety Related Cable Licensee identification of temporary runs of safety related cable during an audit had been identified as an unresolved item.

(In-spection Report 50-320/73-19)

The licensee stated that the disposition of safety related cables HH108C, HH121C, HH97C, and HH132C which had been temporarily in-stalled in the cable room will be inspected and pulled in accord-ance with the requirements of UE&C procedure ECP-3-2.

This item is resolved.

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_QC Acceotance of Nonconforming Small Bore Piping Restraints By letter J. ' January ll,1977, the licensee reported, as a significant de Jciency in accordance with 10 CFR 50.55(e),

acceptance by Field QC of a number of small bore piping hangers whose installation did not conform to the isometric and standard

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hanger drawings.

The inspector examined the documentation shown below:

UE&C Mechanical Construction Procedure MCP-15-2, " Adjustments a.

of Pipe Supports and Design Changes to Pipe Supports," Revision 7, dated December 23, 1976 Paragraph 5 of Part III, Design Changes to Small Bore Pipe Supports had been revised to require

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that:

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The Piping Superintendent is responsible to conform to B&R typical hanger details. Where physically impossible he shall initiate a change request.

(2)

For safety related systems changes shall be made by EDR in accordance with Procedure GCP-1-2.

(3)

Installation is to proceed only after A-E approval.

b.

Notes of a meeting by GPU, B&R, and UE&C on December 15, 1976, at which it was agreed:

(1) To revise MCP-15-2 as shown in a. above.

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To expand typical hanger detail drawings to provide more detailed information.

(3)

To perform a 100% reinspection of all small bore piping hangers using revised drawings.

(4) QC to upgrade their inspection program.

B&R drawings FS-M-101A through 101E which s c.

on hanger installation.

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d.

Field Change QC-231 to QC Procedure QC-10-2 which adds require-ments for installation inspection for workmanship and visual inspection of minimum and reference dimensions.

The inspection

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checkli st for QC-10-2 is also revised to add a check cf hanger spacing.

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The inspector also audited records of reinspection of hangers on the Nuclear Service Closed Cooling Water System and the Auxiliary Building Sump System.

This item is resolved.

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16.

Fire in ITE Motor Control Center By letter dated December 22, 1976, the licensee reported, as a

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significant deficiency in accordance with 10 CFR 50.55(e), a fire in sa ITE Motor Control Center (MCC) caused by a misaligned stab in the stab assembly connected to a breaker associated with a pump starter.

The inspector examined the following documents:

DR No. 0659 the disposition of which called for a detailed a.

investigation of the cause of the fire to be conducted.

Supplement 1 to DR 0659 determined that the cause of the fire (

was as outlined in the licensee's letter and released UE&C to cleanup and remove damaged equipment.

Supplements 2 and 3 list additional damaged cables and provides for repairs in accordance with FCR No. 2355. This DR has been closeo.

b.

QC Inspection Report (QCIR) No.17476 documents results of investigation of fire.

QCIR No.18805 documents inspection of repair and shows work c.

complete and at

't.ble in accordance with FCR No. 2355.

d.

Licensee letters GQL 1754 and 0087 dated December 22, 1976,

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and January 26, 1977, both of which refer to an investigation to determine the acceptability of the material used as a vertical barrier in the MCC's and GpuSC internal memorandum dated March 17, 1977, which states. that an. agreement.h_as_Aeen reached with ITE to replace all horizontal and vertical barriers.

This work is in progress.

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Licensee letter GQL 1754 dated December 22, 1976, also states e.

that "A program has been initiated to check the stab alignment on other ITE motor control centers..."

DR. No. 0677 has been written to identify mis-stabs on other units and is still open.

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f.

IE Circular 77-03 which recommends that the licensee verify that his maintenance procedures contain adequate provisions

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to insure that the stab connnections in these units are properly aligned. The inspector was informed by the licensee's representative that the replacement vertical barriers which are to be installed will also align the stabs and therefore serve to prevent mis-stabs.

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This item remains unresolved pending review by an NRC inspector of installation of replacement vertical barriers in all safety related ITE MCC's or other satisfactory resoltuion of items d, e, and f above.

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