IR 05000346/1976013
| ML19329B127 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/19/1976 |
| From: | Hayes D, Jablonski F, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19329B122 | List: |
| References | |
| 50-346-76-13, NUDOCS 8001300705 | |
| Download: ML19329B127 (30) | |
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UNITED STATES NIICLEAR REGULAT.. COMMISSION
OFFICE OF INSPECTION AND ENFORCDIENT
REGION III
Report of Construction Inspection IE Inspection Report No. 050-346/76-13-Licensee:
Toledo Edison Company Edison Plaza 300 Madison Avenue
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Toledo, Ohio 43652 Davis-Desse Nuclear Power Statica License No. CPPR-80 Unit 1 Category:
B e
Oak llarbor, Ohio-Type of Lic'ensee:
B&W, PNR 871 MWe Type of Inspection:
Special Announced
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Dates of Inspection:
June 8-11, 19'76 (2 42 6 M S 5. -
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Y Principal Inspector:
C. C. Williams (Date)
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Accompanying Inspectors:
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R. Paolino (Region I)
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Other Accompanying Personnel:
D. W. Ilayes
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J. C. LeDoux i
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Reviewed By:
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Projects Section
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SUMFIARY OF FINDIMCS
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Inspection Summary Inspection of June 8-11, 1976 (76-13):
Reviewed status and results to date of the licensecs special reinspection of wiring, raceways and other cicetrical installations.
Reviewed previously identified items of noncompliance.
Observed work activity and reviewed QA/QC considerations for installation of fire barriers and scals.
Six items of noncompliance and one deviation were identified relative to electrical and fire scalant material installations.
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Items of Noncompliance A.
Infractions 1.
Contrary to 10 CFR 50, Appendix B, Criterion V, reworked electrical items were not inspected by the Engineering Inspec-tion Team as specified in Procedures EIP-008-5, Revision 2, dated November 20,. 1975 and EIP-008-1, Revision 3, dated November 7, 1975.
(Paragraphs 3.c. (1) and (6), Report Details)
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2.
Contrary to 10 CFR Part 50, Appendix B, Criterion XVI, the licensee failed to identify and/or take corrective action for a condition adverse to quality relative to, essential channel I
. ( ~x and II cables. located in cabinet C5716 which were found to be (
in contact with nonessential cables located in the same cabinet.
(Paragraph 8.e, Report Details)
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3.
Contrarytotherequirementsof10CFRPart50,hppendixB, Criterion VII, and Bechtel Specification No. 7749-M-255. Brand Industrial Services sealant materials had been installed although it had not been established that the material met specification requirements.
Furthermore, this matter had not been identified by the licensee as nonconforming.
(Paragraph 1.c. (3)(a), Report Details)
B.
Deficiency 1.
Contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion XVII, neither qualification nor indoctrination and training records were available at the site for Brand Industrial Services (BISCO) QA/QC and production personnel.
(Paragraph 1.c.(2), Report Details)
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Cuatrary 'to the requirements of lu JFR Part 50, Appendix B,
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Critorion V, and Brand Industr Lal Services, Inc., 4tuality
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j Control Procedttre No. 006; an approved range of acceptable V
scalant material densitics used for acceptance criteria was not availabic at the site.
(Paragraph 1.c.(3)(s), Report Details)
3.
Contrary to the requirements of 10 CFR Part 50, Appendix B, Criteria V, and the Toledo Edison Company QA Manual Section 5.7.3, The Brand Industrial Services, Inc., Scalant Material Mixing Procedurc No. 207M, was not availabic at the site, and had not been approved for use at the site.
(Paragraph 1.c.(3)(c),
Report Details)
Licensee Action on Previously Identified Enforcement Items A.
Borated Water Storage Tank - Failure To Report (IE Inspection Report No. 050-346/76-02)
C The proposed corrective action for the above item is outlined in Toledo Edison's NCR number 888.
In response to Region III's letter dated March 12, 1976. 'The licensee responded to the notice of an infraction in a letter dated April 12, 1976 and submitted an interim report per 10 CFR Part 50, Paragraph 50.55(e) dated February 20, 1976.
Repair of the storage tank is incomplete.
The infraction aspects of this matter are considered resolved.
The submittal of the final report and impicmentation of,the proposed repair arc open
[,,_ j items and will be revi,ewed during a subsequent IE inspection.
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B.
Indoctrination and Training Records Not Available (IE Inspection Report No. 050-346/76-02. Paragraphs 1.a.(5) - (7))
The corrective action for the subject item as outlined in the Toledo Edison Company (TECO) letter dated April 12, 1976 in response to Region III letter dated March 12, 1976, was examined during this inspection.
Indoctrination training and qualification records for 21 Johnson Controls Company QA and inspection personnel were examined and considered acceptabic.
This matter is resolved.
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Licensee Action on Previously Identified ucviations Electrical Fire Barriers (IE Inspection Report No. 050-346/76-02 Paragraph 2.c)
The licensee has detailed further commitments regarding fire barriers in
Toledo Edison Company's response letter to Region III, dated April 12,
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1976.
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Fire barrier criteria are delineated in Bechtel Drawing No. 7749-E-302A, A
shocts 16A and 1615.
Bechtel Drawing No. E 356, sheeta 12, 13, and 14, I\\~ ')
provide details for fire barrier installations within the cabic spreading area.
(Neither set of drawings has been accepted by TECO as yet.)
Requirements for fire barrier installations outside the spreading room have not been identified on drawings.
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Asbestos free marinite has been identified as the rigid thermal insulating'
material to be used as a fire barrier.
No installations have been made as of June 11, 1976.
This matter remains open pending further IE inspections that establish:
(1) All arcas requiring fire barriers have been identified and documented on drawings, (2) Referenced drawings are approved by TECO, and (3) Installations are in accordance with approved drawings.
Other Significant Findings
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A. - Systems and Components 1.
Unresolved Item - Unclear QA Program R'cquirements Various areas of The Brand Industrial Services, Inc., (BISCO)
QA program are unclear in their response to J') CFR Part 50, Appendix B requirements.
(Paragraph 1.c. (1)(a), Report Details)
2.
Unresolved Item - Channel Designation and Separation 7s\\v)
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Channels 1 and 3 are common for Inverter YV3. In terms of the channel separation requirement this does not appear acceptable.
However, the licensee indicated that a basis
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for the acceptability of this commonality of channels
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would be made available.
(Paragraph 7.c, Report Details)
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b.
The 125V DC supply cables in essential DC distribution panels DIN, DlP, D2U, and D2P do not appear to meet the separation criteria as stated in the FSAR Section 8, Paragraphs 8.3.1.2.25 and 8.3.2.2.7.
Further review of this matter as to engineering justification is planned.
(Paragraph 7.b, Report Details)
3.
' Unresolved Item - Questionable Lack of Instrument Calibration The Brand Industrial Services, Inc. Electro - Mechanical device used to proportion and blend scalant materials has temperature and speed control devices which are not calibrated.
(Paragraph 1.c. (1)(c), Report Details)
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Unresolved Item - Documentation at doworked items
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A system is to be developed to identify and document rework
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performed in accordance with the recommendations of Engineering Inspection Reports.
(Paragraph 3.c.(3), Report Details)
5.
Unresolved Item - Apparently Deficient EIR Lon Book Adequate information is to be provided in the Engineering Inspection Report (EIR) Log Book on items reported closed out to substantiate conclusions.
(Paragraph 3.c. (5), Report Details)
6.
Unresolved Item - Apparently Incomplete Documentation Verification is required whether BCM FL 14-3672, dated April 6, 1976, which addresses itself to EIRs 1 through 668 and 2000 series should also encompass.EIRs 5000 series.
(Paragraph 3.c.(7), Report Details)
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7.
Unresolved Item - Battery Room Conduit Sealoffs The use of an explosion proof box without conduit.sealoffs in
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battery room 429B is questionable.
(Paragraph 7.d, Report Details)
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8.
Unresolved Item - Essential Cable Manhole Identification
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Manhole (s) containing essential cables are not identified.
(Paragraph 8.d, Report Details)
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9.
Unresolved Item - Containment Vessel Particulate Monitoring Svstem
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Final Safety Analysis Report (FSAR) instructions, tables, and
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as-built parameters appear to be in conflict.
(Paragraph 8.f, Report Details)
B.
Facility Items (Plans and Procedures)
Unresolved Item - Inadequate Certification Document
.The Brand Industrial Services, Inc. material certification
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docurent daes not appear to provide adequate information to establish a basis for acceptance of material at the site.
(Paragraph 1.c. (1)(b), Report Details)
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Manage Gal itemo
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The inspectors were idformed that Mr. G. L. Roshy has replaced Mr.
sj D. M. Moeller as s Lte Q. C. Manar,cr for Finchbach and Moore, incorp-orated, (the electrical contractor).
This change occurred May 1, 1976.
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D.
Noncompliance Identified and Corrected by Licensee None.
E.
Deviation Contrary to the FSAR Sect' ion 11, Paragraph 11.4.2.1, the installa-tion of the reactor vessel particulate monitor will not provide a
representative sample.
(Paragraph 8.f, Report Details)
F.
Status of Previously Reported Unresolved Items
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Identification Requirements of IEEE 279 (Inspection Report No. 050-346/76-02) (OPEN)
ReviIsion No. 18 to the Final Safety Analysis Repor.t now indicates,
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in figure 7-1, that instruments are listed in accordance with the Master Instrument Index.
The licensee has established a system for distinctly identifying
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field components in the reactor protection system as documented (
in Bechtel letters No. 4674 dated May 7, 1976 and No.' 4697 dated May 10, 1976.
This item remains unresolved until physical
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installations of the identification tags are complete and verified.
2.
Inappropriate Closure of Nonconformance Reports (NCR's) (Inspection Reports No. 75-03, 75-07, 75-13, 75-16, 75-20, 75-23, 75-24 and 76-02) (OPEN)
Documentation regarding charcoal used in filters supplied by CVI Corporation is discrepant.
This matter was not examined during this inspection and remains unresolved.
3.
Incomplete Test Data (Inspection Reports No. 75-03, 75-07,
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75-13, 75-16, 75-20, 75-23, 75-24 and 76-02)
Rupture test of filters is being evaluated.
This matter was not examined during this inspection and remains unresolved.
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4.
fgipment Secured liv " lit i t i-Kwik" Devices (T E Inupe,etion
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M ortn Np. 75-10, 75-15, 75-16, 75-20, 75-23, 75-24, Is \\
and 76-02)
(OPEN)
This matter was not examined during this inspection and remains unresolved.
5.
Motor Operator Valves (IE Inspection Reports No. 75-16, 75-10, 75-21, 75-23, 75-24 and 76-02) (OPEN)
This matter was not examined during this inspection and remains unresolved.
6.
Reactor Protection and Safeguard System Cabinets (IE Inspection Reports No. 75-23, 75-24 and 76-02) (OPEN)
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The protection and safeguard systems internal cabinet wiring appears to be in conflict with IEEE-279, 1971, Section 4.7.2.
This matter has been referred to IE Ileadquarters for resolution c
and remains unresolved pending receipt of their response.
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Management Interview
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A.
The following persons attended the Management Interview at the conclusion of the inspection.
Toledo Edicon Company (TECO)
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L. E. Roe, Vice President, Facilities and Development s_-
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E. C. Novak, Project Engineer J. D. Lenardson, QA Manager G. W. Eichenauer, QA Engineer M. D. Calcamuggio, Electrical Engineer R. F. Blanchong, Construction Superintendent
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huclear Regulatory Commission IE:III J. C. LeDoux, Chief, Engineering Section D. W. Ilayes, Chief, Projects Section R. D. Martin, Reactor Inspector (Test and Startup)
J. E. Foster, Investigation Specialist Bechtel Corporation (Bechtel)
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C. L.11uston, Field Construction Manager S. M. Cantor, Electrical Engineer
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C. D. Miller, CPDE-7-
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s Cleveland Electric il l um inaling
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J. M. Lastnvka, QA Engineer
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B.
Matters discuused and comments, on the part of the management personnel were as follows:
1.
The inspector stated that his review of the blockout scalant contractors QA/QC program, test and certification records, and sealant installation activity disclosed several items of noncompliance and unresolved matters, the details of which are
identified heroin.
The licensec's management acknowledged these remarks.
(Paragraph 6, Report Details)
2.
The inspector stated that his review of the specification and
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design parameters of safety relief valves numbers PSV1529, PSV1550, PSV1510 and PSV2761 identified on drawing No. A2616 Revision F showed that ASME code and specified application
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requirements were complied with.
The licensecs representatives acknowledged this remark.
3.
The inspector stated that he reviewed the status of the primary system valve installations, relative to their impact on the forthcoming primary system hydrostatic test.
It appears that only one primary system valve remains to be installed.
The installation of this valve was in progress during this inspec-
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It uns reported that all balance of plant valyes required x_,/
for the hydrostatic test are in place.
4.
The inspector stated that he revieued the corrective action taken in regard to the lack of training and indoctrination records for the Johnson Controls QA/QC personnel.
This review showed that all such records and certifications are now available at the site.
The licensee's management acknowledged this remark.
5.
The inspector stated that he discussed with F&M the history of welding activity on seismic supports for electrical conduit and other electrical components at the site.
While this activity was not fully inspected during the current inspection the inspector indicated that the intended goal of a future inspection examination was:
(1) to establish what welding records are available and the number of "uninspected" welds made prior to the identification of these components as
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safety related, and (2) to-examine the corrective actions
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and renul t.s taken by TECO and its contract.or in regard to n
this welding.
The licendee's representatives acknowledged V ).
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these remarks.
6.
The inspector stated that he reviewed the progress of corrective action for the buckled borated water storage tank and the-associated 10 CFR Part 50.55E documentation.
The status of corrective action is commensurate with TECO commitments.
7.
The inspector stated that relative to the followup electrical inspection, considerabic rework by the licensee is still required in all areas and further OIE inspection would be required.
(Paragraph 2, Report Details)
8.
The inspector stated that hn evaluation of cable separation was made relative to the 2000 series of Engineering Inspection Reports-(EIR).
During visual inspection, discrepancies were
determined to have been corrected per the provided Bechtel engineering analysis.
No new significant discrepancies were identified.
(Paragraphs 2.b, 3.c, 3.e, and 3.f, Report Details)
9.
The ' inspector stated that he reviewed documents relative to the General Electric Company static trip devices for AK3-25 and AK3-50 air circuit breakers and possible reporting require-ments per 10 CFR 50.55(c).
(Initial licensee ::RC contact was made by telephone on May 13, 1976).
The licensee stated that
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this matter was considered to be reportable and would be reported in the very near' future.
10.
The inspector stated that he reviewed TECO supplied documenta-tion relative to the identification of field mounted instruments in accordance with IEEE 279. Implementation will be verified by OIE inspectors.
11. The inspector stated that he reviewed newly established fire barrier criteria and relative drawings.
Drawings require approval, barrier requirements outside of the spreading room have not been established and installations have not been verified by OIE inspectors.
12.
The inspector stated he reviewed corrective action taken on
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the EIRs relative to Adverse Environment Conditions, (Series 5000) the Field Fabrication of Conduit Supports and the instal-lation inspections being performed by FSM/CE.
During the review, the inspector identified one item of noncompliance,
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fa aure t'u conduct Inspectlonn oc,.c procedures, and three
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unresolved items.
(Paragraphs 3.c. (1), 3. c. (3), 3.c. (5), and 3.c. (7), Report Details)
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The inspector summarized the findings with regard to,the-installation of essential electric cabic and in particular, I
the review of.the licensco Engineering Inspection Reports (EIR' s).
Three unresolved matters were identified relative to cabic separation in essential DC distribution panels, a channel
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designation anomaly, and a questionable electrical installation I
in the 1A battery room.
The licensee acknowledged these remarks.
(Paragraph 7, Report
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Details)
i 14. The inspector summari cd the findings (cable scperation) with
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representatives of the licensee and contractor organizations, i
and reported that he had identified an infraction relative to
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essential channel separation, 'a deviation relative to the c
construction of the containment particulate sampling system and two unresolved matters invol'ving the identification of essential cable manholes and the.apparently un-isokinetic construction of the containment particulate monitoring system.
(Paragraph 8, Report Details)
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REPORT DETAILS
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Personn Contacted The following persons, 'in addition to individuals listed under the Management Intervicu section of this report, were contacted during the inspection.
Bechtel Corporation (Cechtcl)
W. C. Lowery, Electrical Quality Assurance Engineer J. Gonzales, Engineering Inspec. tion Team Leader I
S. Saba, - Electrical Supervisor, Gaithersburg (GPD)
J. Yesko, Engineer, (GPD)
R. Yamrus, Engineer (GFD)
R. W. Jackson, Supervisor Mechanical (CPD)
L. Meyers, Small Pipe Design q
M. Patel, Civil Engineering (GFD)
J. T. Vogel,. Assistant Civil Engineering Supervisor (GFD)
G. Decker, Assistant Chief Engineer Civil (GFD)
R. Mcdonald, Civil Engineer J. DeVoge, Civil Engineer R.' Glass, Lead Field Engineer Electrical G. Aller, Assistant Field Engineer
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Fischbach and Moore, Incorporated (FEM)
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A. E. Auble,-Lead QC Inspector
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W. L.: Columbia, Assistant Project Engineer
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F. Kollin, Proj ect Manager G. D. Kraus, Lead Field Engineer G. L. Roshy, QC Manager
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T. H. Winhoven, Electrician'
H. Fosholdt, QC Specialist
R. Wallace, QA Inspector J. Ilarris, QC Documentation Coordinator W. Wolever, Electrician T. Farmor, Engineer F. Fishback, Electrician
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S. Fox, Engineer
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Johnson Controls, Incorporated, (JCI)
R. W. Jones, QA Manager M. A. Barnhart, Inprocess Inspector
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lirand _Toduf- -ta l Si rvices, I n c. _ ( !; l * iQ),
f 11. J. Runnel, Sit.c Manager
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W. 7,med, QC Innpcetor (
l T. C11more, Project Foreman s-To]cdo Fallnon Company (TECO)
E. Wilcox, Field QA Specialist P. Harducci, Field QA Specialist C. Daft, Fic1d QA Engineer 1.
Penetration Seals and Block-out Closures a.
Inspection Objective-The objective of this inspection was to examine the contractor's QA/QC program and its impicmentation relative to:
(1) personnel and instrumentation qualifications, (2)
test and installation records, and (3) material certification c
for compliance to the specifications and TECO QA program commitments.
The contractor for this work is Brand Industrial Services, Inc. (BISCO).
b.
Inspection Objectivos Accomplished By:
(1)
Review and examination of the BISCO QA program Manual No. 114 approved by TECO on December 16, 1974.
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(2)
Review and examination of the associated DISCO QC
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procedures i.e., MP-207,* QCP-009, Mixing procedure No. 207, QCP-003, QCP-004,. QCP-005, QCP-008-and IP-207.
(3)
Revi.ew and examination of the TECO-BISCO specification No. 7749-M-255, "for furnishing and installation of
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penetration seals and block-out closures."
(4)
Discussion with TECO and BISCO management personnel and craftsmen.
(5)
Observation of the mixing of sealant material components (Isocyanate Resin), and the associated acceptance standard.
(6)
Observation of class-1 placements of the scalant i.e.,
electrical conduit item No. 7034, and No. 7033.
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.pection Findingu c.
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The contractor's installation crew and-QC personnel appeared (
capable, and Junta 11ation of the Isocyanate resin sealant in class-1 locations had commenced prior to this inspection.
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With'the significant exception of the items ident:1 fled below, the areas reviewed appeared to meet the TECO speeif1-cation requirements.
(1)
Unresolved Matters (a)
The following areas of the BISCO QA program manual did not clearly respond to ' the requirements:
The QA program does not appear to address or reference a criteria for its basis.
The BISCO QA program section QAP-4, apparently in response to 10 CFR Part 50, Appendix B, Criteria 9, does not clearly address the subjects of " qualified procedures and j
qualified personnel."
The BISCO QAP-No. 8, an apparent response to 10 CFR Part 50, Appendix B, Criteria 7, does not clearly address " required conformance to procurement
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documents" nor does it address " effectiveness evaluation" of BISCO vendors.
The BISCO QA program does not address the training and indoctrination of production personnel or.QA/QC personnel.
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(b)
Material certifications provided by BISCO for the various components of the sealant material do not appear to meet the criteria necessary to demonstrate
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conformance to 10 CFR Part 50, Appendix B, Criteria 7.
The present certification (1) does not identify the authority of the_ person who signed it, (2) does not identify those specification parameters which have not been met, nor does it address the specific identity
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of the quality requirements.
(Also see Paragraph 1.c. (3) (a) below).
The licensee indiceted that this matter would be further examined.
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(c)
The BISCO E1cetro mechanical device used to proportion mix and install the isocyanate resin scalant, has an array of speed (RPM) and temperature control devices.
These device are not ca: ibrated.
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a minianement contendu th.
the set points on this
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device have no effect on quality.
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tors' examination, mixinn personnel indicated that if
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the set points were changed the " quality" of the
'g product would also channe.
During thin Inspection the facts were not established.
It appears on the basis of the inspectors examination, that these control devices should be calibrated in response to 10 CFR Part 50, Appendix D, Cri terion 12.
The licensee indicated that they would further examine this matter.
(2)
Deficiencies Contrary to 10 CFR Part 50, Appendix B, criterion 17, neither certifications nor training records were-available to verify that BISCO QA/QC and appropriate production personnel had received indoctrination, training and/or other measures to demonstrate and c
facilitate proficiency in performing quality related
activities.
A BISCO representative indicated that such records exist at their home office in Illinois.
The inspector pointed out that the documented BISCO QA/QC program fails to include scalant mixing and production personnel in the specified training and indoctrination measures.
h (3)
Infractions
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(a)' Contrary to 10 CFR Part 50, Appendix B,' Criterion 7, which states in part that " Documentary evidence that material and equipment conform to procurement require-ments shall be available at the nucicar power plant site prior to installation or use of such material and equipment", BISCO isocyanate resin scalant had been placed in class-1 locations although scalant material testing requirements of the specification had not been performed.
BISCO material certifications erroneously indicate that materials comply with "all applicable P.O. specification requirements." TECO to BISCO specification No. 7749-M-255, paragraphs 7.1 through 7.5, specify that documented test results demonstrating flame resistance, chemistry and physical properties, halogen content, and hose stream tests of the scalant
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shall be provided.
Such test documentation was not available.
Infact, performance of some tests was not
planned until July, 1976.
This nonconformance was not documented by TECO nor BISCO.
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s (b)
Contrary to the requirements,of 10 CFR Part 50, p)
Appendix B, Criterion V which states in part that-( V
" Activities af fecting quality shall be prescribed by documented - - - procedures - - - and'shall be accomplished in accordance with these instructions,-
procedures.
" and BISCO quality control
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procede.rc No. 006 paragraph 2.1.1.6 which requires that "a range of acceptable sealant densities" be submitted to the site; such a dccument showing a range of sealant acceptance criteria was not availabic.
Furthermore, no documentation was at the site to establish that the one density reference standard availabic met procedural requirements, i.e.,
was within the acceptable range of sealant densitics.
(c)
10 CF'R Part 50, Appendix B, Criterion V, states in part that " activities affecting quality shall
<
be prescribed by documented instructions, procedurcs,
- - - and shall be accomplished in accordance with these instructions procedures, or drawings." Further, the Toledo Edison QA manual section 5.7.3 states
-
in part that "The Toledo Edison Manager, quality assurance is responsibic for jointly approving the QA aspects of procedures which assure control ^f purchased Q-listed items and servicce." Contrary gg to the above, BISCO scalant mixi'ng procedure No. 207M f
)
ref'erenced by Instellation Procedure No. 207 was not x_ /
available at the site and had not been reviewed nor
approved by Bechte1 and Toledo Edison.
,
-2.
Follow-up Elcetrical Inspection a.
The purpose of the inspection was to determine if the licensee had corrected deficiencies identified by the Bechtel Engineering Inspection Team (EIT) while performing
-
a 100% reinspection of all site installed electrical equipment, wiring, cable and raceway.
b.
Methods included:
-
(1) Review of EIT documented engineering inspection records (EIR) relative to reinspection of:
essential cables, cabic separation and equipment exposed to adverse environment.
(2)
Review of pertinent EIR analysis /rcsolution by Bechtel, Gaithersburg Power Division (GFD).
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s v) Ul rect DIE obnervation to vei ify that no new def1-ciencien were telentified relative to:
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. (a)
raceway idenLifI. cation (b)
raceway debris (c)
raceway sharp edges at entry, exit or other routing points (d)
cable identification (e)
cable damage (f)
raceway physical overloading (g)
excessive hending radius (h)
cable support (i)
cable routing including separation
.
(j) matching cable pull card and circuit schedule (k)
adverse environment, i.e. high pressure, high temperature or adjacent to potentially hazardous nonseismic equipacnt
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(1)
cable separation within control cabinets All elements of the recommended GPD disposition had been c.
impicmented, i.e. work completed according to the analysis /
resolution including, as appropriate, follow-up through individual contractor's nonconformance system and-Engineering Class I conduit hanger group.
d.
as of May 25, 1976, the licensco reports the following
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status of completed reinspection areas:
.
(1)
installation cf essential cables - 85%
(2)
cable separation - 70%
(3)
adverse environment - minimal
_(4) Class 1-E scismic conduit supports - no report
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Findings relative to cabic separation (EIR, series 2000).
e.
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.Thc OIE inspector reviewed 4011echtel Engineering Tuspection-
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Reports (MLR), including perLluent analysis, and observed
1 corrective action taken.
The sample included areas of motor operated valves, motor operated vaIve local control stations, motor control centers, '480 vol t switchgcar, 4.16 KV switehnear, local and remote diesel generator control panels, safety features actuation system (SFAS)
panels, reactor protection system (RpS) panels, RPS trip switchgear and battery rooms.
13esides cable separation,
.
other discrepancies were identified in the EIR including sharp edges, installation of raceway, support of cubic, cable routing,-improper terminations, raceway overfill, repair of damaged cabic, excessive bending radius, and bridging of redunant cabics.
Only 70% of the sample had been completely reworked and reinspected by the Engineering Inspection Team (EIT).
Completed items appeared to have been satisfactorily corrected in accordance with the analysis / resolution provided by Bechtel including appropriate. review and approvr.1 by TECO of the Cabic Separation Record. Those items not completed were observed by the OIE inspector to be in various stages of completion.
It was apparent that rework was being
. performed in accordance uith the analysis / resolution provided, i.e. redundant channel cables were placed in flexible metal conduit where required, sharp edges protected, etc..
No f ~'g new significant discrepancies were idcutified by the 01E (
)
inspector.
x- /
.f.
The inspector made the following observations:.
-(1). Cable supports which had been added to SFAS cabinets had either been subsequently removed or broken thus placing strain on plug terminations.
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(2) Repaired electrical plug connections located at the bottom of SFAS cabinets were not protected to preclude further damage.
(3)
SFAS cabinets had exposed electrical terminals at waist height which were not covered to preclude possible short circuiting.
The licensce's representative stated that appropriate resolution of items (1), (2) and (3) above would be pursued.
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(4) ~ Cables located in panel 5715 did not appear to be S
, properly dresned or supported.
FlJI Inspection pick up
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(IPU) No. 30310 identifi.ed thin problem. The (M inspector was Informed that 73 1pu's and 68 insepetion r. ports (IR) remain aututanding,, in addition'to all other remainini; rework items.
Proper cloccout of thene items will be verified by OIE inspectors.
(5)
Field installed Main Steamline Rupture Instrumentat-lon (MSRI) mechanical separation barriers, impulse line protection and ciectrical separation requirements appeared to be adequate.
(6)
With reference to IE Report 050-346/75-10, De' tails section, No. 16, cable conductors were verified not to have been jammed into remote push button control stations.
Verification by OLE was made during an inspection performed August 18-20, l975.
This matter
,
was inadvertently omitted from report No. 050-346/75-16.
g.
EIR's, inspection records and other-correspondence reviewed during the inspection include:
(1)
TECO letters No. TB3243, No. TB3313 and No. 3323.
(Cable Separation Log)
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(2)
TECO conference memorandum No. 300.375.06 (G. E. Breakers)
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(3)
Bechtel letters No. 4697 and No 4674 (Instrument ider.tification)
(4)
Bechtcl drawings E356, sheets 12, 13 and 14; and 7749-E-302A, sheets 16A and 16B.
(Fire Barrier Criteria) -
(5)
Engineering inspection report numbers and F6M associated records as follows:
.
(a)
2017 (k)
2230 (u)
2307 (ee)
2490
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(b)
2094 (1)
2231-(v)
2359 (ff)
2491 (c)
2102 (m)
2237 (w)
2382 (gg)
2492 (d)
2103 (n)
2238 (x)
2412 (hh)
2499 (e)
2134 (o)
2279 (y)
2419 (ii)
2509 (f)
21~36 (p)
2283 (z)
2427 (jj)
2511
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(g)
2152-(q)
2284 (na)
2428 (kk)
2512 (h)
2154 (r)
2285 (bb)
2472 (11)
2514 (1)
2188 (s)
2286 (cc)
2487 (mm)
2516 (j) -2193 (t)
2296 (dd)
2488 (nn)
2554 l
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Revt.
o f liedork' u_n Eng ineerinf1_h ;Imc on Reportn ( Adve r::e
Environment Cont: Edera t lon :)
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a.
Inspection OhleetLves To ascertain whether rework recommended on findinns identified in Engineering Inspection Reports (EIns) 5000_ series relative to adverse environment and other considerations was performed, inspected and the items closed out.
b.
Inspection Objectives AccompTished Hv (1) Revlcu of Procedure EIP-008-5, Revision 2, dated November 20, 1975.
c (2)
Review of Procedures EIP-008-1, Revision 3, dated November 7',
1975.
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(3)
Visual inspection of rework that had been reported as
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complete.
.(4)
Bechtel GPD letter to Bechtel Construction Manager and Toledo Edison Company - BBC 3990, dated November 21, 1975.
(5)
Bechtel GFD letter to Bechtel Construction Manager-
!
and Toledo Edison Company - BBC 4299,. dated
'~'s February. 10, 1976.
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(6)
Procedure',for design of-Class 1, Electrical Conduit Supports, Procedure No. CEPCS-1, Revision 2, dated November 5, 1975.
(7)
Installation. Procedure for Essential Hangers and f
, Supports, IP-7749-E-14-6a.003, Revision 1, dated August 15, 1975.
(8)
Installation Inspection Procedure for Essential llangers and Supports IIP-7749-E14-7a.003, Revision 1, dated August 18, 1975.
c.
Inspection Findings l
^
(1)~ Noncompliance / Infraction
.
Procedure EIP-008-5, Revision 2, dated November 20, 1975, titled " Procedure for Install.ition Inspection of
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Ennential 1:lectrical 1:quipme.. for Exposure to Adverne Environment" page 4, Paragraph 6.ll, ' states, in part
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[]
- Reinspection and cloneout of ELR (Engineering Inspection
-
Reports) Items will be handled per EIP-008-1, Revision 3,
i dated November 7, 1975, Section 9.3."
,
Section 9.3 of the above procedure titled " Procedure
,
for Installation Inspection of Essential Cabics by
_ Engineer Inspection Team" states, in part "As-discrepan t items are reported reworked by the responsible
'
partics, the EIT-(Engineering Inspection Team) will reinspect the rework and close out satisfactorily reworked items".
-Contrary to the above requirements, EIRs were reported
closed without the EIT reinspecting the reworked items.
.
-The inspector stated that failure to follou procedures was an item of noncompliance / infraction and contrary to e
requirements of 10 CFR 50, Appendix B, Criterion V.
,
(See Paragraph 3.c.(6) below)
,
,
(2)
Upgrading Nonessential Conduit' Supports to Seismic Class 1 to Preserve the Inter,rity of Essential Cables I
and Components EIRs 5019, 5020, 5052, 5053, 5055, 5058, 5059, and
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5061.
j -
-s The above EIRs were resolved by.the Ergineering Class-1
'
i Conduit llanger Team in the field by preparing conduit support drawings and generating data sheets which
,
provided a means of cross-referencing the appropriate conduit support tabulation drawings, conduit support drawings and the plan view drawings.
These drawings were issued to Fischbach and Moore /Colgan Electric (F&M/CE) the electrical contractor for rework.
.
F&M/CE reported completion of the rework and the items were reported. closed.
F&M/CE did not maintain records of additional work l
performed on conduit supports to meet drawings require-ments.
Further, neither the F&M/CE QC nor the EIT
performed final inspections of reworked items.
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The IE:ILI inmector verified and detertained that con-
- f^g duit suppor
,ere in accordance ui th speelfled drawings.
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During.verift,ati.on, the inspector determined that data-sheets (c. r; ira 5053 and SG59 contained tytmaraphical errors. The errors were acknowledged and corrected.
During discussions with FSM/CE personnel, the EIT lead representative, the licensee's representative and the conduit hanger team leader, it was acknowledged that the contractor should document the rework performed and conduct necessary inspections.
(3)
Unresolved Item The inspector noted a.n apparent lack of adequate informa-tion (records) to demonstrate that rework and inspections were complete.
The licensee representative and the F6M/CE personnel explained that they would develop and implement
<
a system to document rework performed, including any additional material used,'on the data sheets.
The inspec-tions by the contractor QC,and-EIT may also be documented on the same data sheet prior to close out.
This matter
~
will be reviewed during a subsequent inspection.
(4) Drawings Modified to Reflect As-Built Installations EIRs 5002, 5004, 5010, 5011,.5026, 50'27, 5035, 5036, and f w)
i g-
5052.
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The discrepancies identified in the above EIRc can broadly be classified in three categories.
(a) Conduit support incorrectly tagged.
The IE:III inspector verified and determined that Cor.duit 28419A in Room 208 was now identified with the
,
correct tag.
(b)
In cases where conduits were not routed as per
,
drawings, appropriate drawings were revised.
The i
IE:III inspectur determined that this was accomplished.
(c)
EIRs 5035 and 5036 identified that a 14" x 14" blockout was not shown on Drawing C241.
These EIRs were
' reported closed out with CPD letter BT 6082.
The
,
.
revised Drawing C241 did not shou the blockout. 'The GPD civil supervisor _was consulted and he provided infonnation that the blockout was identified on drawing C207 instead of C241.
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lin r et _o l ved ILcm The LE:ILI' Inspector stated that information provided f]1 for the above ment ioned EtR closcouts was tusufficient to verify the corrective action taken.
The LE:IIC
~ inspector pointed out that iLcensee representatives-have apparently not is:<ued necessary instructions to document adequate informatLon so as to permit verification that the item was closed out properly.
Corrective action to be taken will be verified during a subsequent inspection.
(6)
EIRs With Onon NCRc Reported Closed EIRs 5030, 5047, 5075, and 5076.
As a result of discrepancies identified in the above EIR's, Noncenformance Reports (NCR's) B257, B258, B261 and B-262 were cenerated by F&M/CE and forwarded to Bechtel GPD. Although the NCRs remained open pending resolution c
by CPD, the EIRs were reported closed.
The IE:III inspector pointed out to the licensee that this method of closing EIRs was contrary to the requirements cf Procedures EIP-008-5 and EIP-008-1.
.
(7)
Unrosolved Iten The IE:III inspector reviewed letter BCM No. FL 14-3672, f-'s dated April 6,1976, which addresses itself to inspection (
)
of rework regarding EIR items 1 through 2543.
F&M/CE stated N- ^
that they did not receive a similar letter for reinspection
,
relative to EIR items 5000 series.
The inspector inquired whether such a separate letter exists and if not, whether letter FL 14-3672 should also encompass EIR items 5000 series.
It appears that such a letter directed to F&M/CE informing them of the documentation on rework and QC inspections is necessary-to control'this quality affecting activity.
The licensee representative stated that he would investigate and furnish the necessary information.
4.
Review of Seismic Class 1 Field Fabrication Facilities (Adverse Environment Considerations)
a.
Inspection Objectives
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To ascertain whether F6M/CE is fabri.cating the various supports in the on-site fabricating facilities with approved drawings, approved materials, appropriately stored wcld
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rod, and qualified uciders.
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b.
ynspection ob jecther. Acconglinhen ny,
[/ ~N (1)
Review of the drawingn for approvaLu.
.
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-(2)
Review of welilor qualification records.
-(3)
Review of " Welding Call Sheets" maintained at che weld shop.
"
(4) Verifying whether the shop weld was stamped with the
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stamps of the wcidor (who perfonned the uciding) and the welding inspector.
(5) Verifying storage of weld rod to the manufacturer's
'
recommendations.
c.
Inspection Findinus (1) Only weld rod type E6010 and E7018 vere being used for
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all welding activities whether safer.y related or not.
(2) Weld rod type E6010 manufactured by Lincoln was stored in the shop in a heated box.
(3) Weld rod type E7018 manufactured by Che:r: tron was stored in an cven.
At the time of the inspection, the dial thermometer uns indicating 270 F.
Weld rods were being
['~'}
issued to the field in portable ovens which are to bc
,
\\, 'f energized in the field.
During the current inspection,
'~
the inspector observed that portable weld rod ovens ucre energized.
(4)
Drawings used for fabricating supports were verified and contained necessary approvalu.
,
(5)
" Welding Call Sheets" were being used to document fit up inspections, weldor activities and welding inspections.
.
However, i.t was observed that a correlation between this
,
document and the fabricated support was not maintained because it was not'a requirement.
The inspector stated that without such a correlation tracking the welding activities un a given support is very difficult.
The welding inspector acknowledged the advantage and stated that he would formulate such a correlation.
(6) The inspector reviewed weldor qurlifLcation records and determined that seven weldors were inadvertantly
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recorded as being <!nalified to procedure QAP-6 instead of QAP-l.
The FIJt/CE welding inspector aclotowledged w
)
the dJncrepancy as a typographical error and inaltiat.ed v
an Inspection !!. port IR Mo. 0626 the sinne ' day requestinr that records be corrected.
The welding inspectors were qualified.
Verification c f Innpections 'on Field Welds (Adverse Environment Considerations)
a.
Inspection Ob}ectives To ascertain whether Conduit Supports No. CS 832-405-06 and.
No. CS 833-405-07 were installed according to requirements.
b.
Inspection Objectives Accomplished Bv
_(1) Visual inspection of supports in the Auxiliary j
Building, Area 8, Room 405, Elevation 603.
(2) Using documents:
F&M/CE, Checklist IIP-7749-E14-7a-003,
.
Revision 3, Page 7, Drawing E 302A, Sheet 168.
c.
Inspection Findings (1)
Conduit supports were installed as pe,r drawings.
,
(2)
Identifications of the wcldor and welding inspector
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vere stamped adjacent to ucids on Conduit Support CS-832-405-06-2.
(3)
Records of the identified weldor verified that he was qualified.
6.
Welding Inspections
_
a.
Inspection Objectives To ascertain whether welding inspections detected any discrepancies in welding activitics.
b.
Inspection Objectives Acccmplished By Review of nonconformance reports written en this subject.
c.
Inspect'on Findings
.
The inspcitor reviewed the following Nonconformance Reports generated by F6M/CE and determined that welding inspections
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were being perfor:ned dJscrepaneles were beinn Identifled and resolutions were being requested f rom appropriate personnel.
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(1) NCR i5-298, dated June 2, 1976, indicated that Cundult Support No. 9084 (P!000 unintrut) was welded to an 1-beam without pre-heatity; the weld area.
Bechtel Engineering was requested to provide dinposition.
(2) NCR A-115, dated May 24, 1976, identified that a conduit support fabricated to Drawing E-302A, Sheet 257, was removed from the P&M/CE k' eld Shop and installed without inspection and before the weldor and inspector stamped it.
Disposition:
Scrap.
(3)
NCR A-114, dated May.19, 1976, identified that a conduit support was installed without evidence of weldor identificatian or inspection.
Further, it was indicated that welds were reported painted over obscuring the identification.
Disposition:
Replace.
(4)
NCR A-112, dated May 15, 1976, reported that a conduit support fabricated to Drawing 7645-313-SW was purchased.
'
The support consisted of a unistrut P1001 with a plate welded to the end.
The weld was covered with galvanizing.
The report identified that the support did not meet Drawing E-302A and F&M/CE QC inspection requirements.
Disposition:
Replace.
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(5) NCR A-111, dated May 15, 1976, identified two conduit s
'
hangers which were fabricated, welded and installed in the field without inspections.
Corrective action suggested two alternatives:
(a) to scrap the hangers or (b) to add corner brackets as per Drawing E-302, Sheet 189, Details.
(6)
NCR A-110, dated May 15, 1976, identified a conduit support fabricated in the F&M/CE shop on May 16, 1976, without an approved drawing.
The support had been installed in the annulus space on the outer channel of a walk way at approximately Elevation 600-(azimuth-265).
It was recommended that a hold tag be placed pending
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approval of the drawing.
Personnel were instructed not to fabricate or install hangers without approved drawings by the Bechtel Resident Civil Engineer.
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NCR A-lfil, dat ed April 2'), 1 h,. identified four (4)
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condttit hangers whleh were fahrleated in the Ptdl/CE p
shop without fit up inspections or being recorded on the " Welding Call Sheet".
It van recommended i
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L that Con::truction pornonnel be instructed to follow approved ' procederes regarding fit-up inspection and
'" Welding ~ Call Sheets."
Scrapping of the four (4)
conduit hangers was recommended.
Corrcetive action was reported to hc.ve been accomplished by instructing the construction personnel to follow approved procedures.
Engineering concurred that there was no indication that the hangers were cerapped.
Followup of this matter'is planned.
7..
Installation of Essential Electric Cable - Eneineering Inspection Reports t,EIRs)
a.
The inspector reviewed representative EIRs and the associated documentation relative to their resolution.
EIR review included:
~(1) Violaticas of separation criteria in junction box-s and manholes; (2)
Installation of cable in overfilled riscrs and wire-ways;
,
(3)
Improper cable routing;-
(4)
Installation of improper size cable; and (5)
Installation of vertical conduit runs without appro-priate supports.
b.
The required separation has not been maintained, nor have barriers been installed between 125 VDC supply cables in cach of the essential DC distribution pancis: DIN, DIP, D2N, and
D2P. This appears to deviate from FSAR statements (Para-
.
graphs 8.3.2.2.7 and 8.3.l.2.25).
This matter remains unresolved pending further review of cugineering evaluations.
c.
With-regard to essential DC distribution panels, the inspec-tor noted what appeared to be a deviation from FSAR separation criteria, but which is actually a channel designation anomaly.
Channel 1 and channel 2 DC motor control centers supply
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125VDC throonh e.,nenLLal DC dintrinut. ion panei DIN to tha 125VDC/120VAC inverter YV3, labeled ch:nnel 3.
Channel 2
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supply is ener;*,ized only for mainteacoce when t hutdown.
Thus (
channut I and channel 3 are actiually a conunon line.
A similar situation exists in D23.
For panels DIP and D2p, channel l and channel 2 supply invertern 1 and 2, and thus the apparent deviation does not exist.
An engineering evaluation to cuta-blish a banis for acceptance of this apparent ec.mmonality of
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channels 1 and 3 (and 2 and 4 for Panel D2N) was not available.
This matter is conr.idered to be unresolved.
d.
As a result of cabic ICnH1285D_being pulled short of its destination, the cable is to be terminated in a nonexplosive proofbox (JT4616) in' battery room 429B.
Furthcrmore, conauits entering this bon are not sealed. The licensec's
. position is that the battery room is not classified as a hazardous area.
The FSAR Section 8, Paragraph 8.1.5, (Item No. 3, page 8-3)
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states, in part that:
"Revelant NEC reccmmendations are used as guidos in the design." Section 9 of the FSAR on page 9-2, item No. q references the "NFPA standards." NEC is endorsed as NFPA 70-1975. The inspectors conclusion based on revieu of Ch: pter 5 of NEC (1975) is that the battery room should be classifLed as a hazardoun area, Class I, Division II.
The use of a nonenplosive proof box is permissible, however, conduit sealoffs are required.
This is considered to be unresolved, j
8.
Installation of Essential Electric Cable and Containment,
,
Particulate Sanr. ling
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Scope of Inspection Purpose of the inspection uas to determine if the licensec had corrected previously reported nonconforming conditions regarding the installation and routing of essential cables.
The following items were inspected and are considered acceptable, except as noted:
Installation and routing of essential cables.
,
General housekeeping condition of cabic trlys and wire
.
ways.
a.
Cable Installation and Routing
.
The inspector audited the licersee's Engineering Inspection Report (BIR) documentation and cualysis of recommended corrective action and implementation.
(Q).
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e ny dirc et observation the innpectoc reviewed innta11atjun, routing and corrective action Implemented f or selected -
(#O)
essential cable runs as recorded by the 1311, cable pull card and electrical circuit schedule, Rev. 35) dated April 17, 1976.
The essential cables and associated pn11 card / circuit sc.hedule selected for audit included the following:
Item No.
EIR Cablo No.
From To Pull Card Rev. ':n.
1.
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2CVD1113AE EV1469 C5717 R37
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2.
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1CV23611 EVMU33 C5717 33-C 3.
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2CBF1-126F CDF11A-1 CS705 34-C 4.
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2PBFill8A BF11A BFilE 21-C 5.-
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1PBE1216A BE12A C6706 32-C 6.
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ICAFPT013 CDE12A-1 C5709 37-C 2 CAD 113F AD113 ADIOS 31-C 7.
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8.
547 1CAFPT01C CDE12A-1 C3630 37-C
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9.
563 1CBEll47E BE11D CDE11D 34-C 10.
595 1CEE1223A BE12A CDE12A-2 37-C 11.
601 1CBE1160F belle CDYE2 F39-C 12.
620 2CBF1118F BF11A CDYF2 F32 13.
626 2CBF120711 BF12A C3630
14.
640 2CBF1106E DF11A CDF11A-2 34-C 15.
659 2CV1357E RC3702 BF14 39-C 16.
666 2CSFC24!!
V5021 JT2730 39-C 17.
673 10BE1223C CDE12A-2 C5705 37-C
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679 1CSFCllJ V1424 JT3810 F33
"
19.
702/703 1CBE1271G
- CDE12B C5717 R37
.
The inspector verified that nonconformances reported for items one thru cighteen above had been satisfactorily corrected.
Item 19 had not been corrected and is discussed in the following paragraph.
b.
Corrective Action The inspector noted ths.t corrective action for the discrepancy noted in EIR 702 for item 19 had not been implemented as yet.
Separation between essertial and non-essential cable is not maintained.
Essential cable ICBE1271C is still in contact with non-essential cables ACX0203A, ACX201A, ACSANNF, ACSASA,
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ACSASLTAV and BPDF2225A.
The separation barrier recommended by CPD for installation where 12 inch separation could not bc maintained, had not been installed.
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in addition,.a. spare et.nentiai canie !PilSPAlm04 had been pulled tuto manhole 1111100'> and remains in contact with non-eust ulla! cdbles lil>l:F2225A and APlil:2205A.
This is an observation and will be reviewed during,
subsequent inspection.s.
c.
Cable Separation-
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While inspecting items 1, 2 and 19, the inspector observed that required separation between other essential cables (channels 1 and 2) and non-essential cables (channels A and B)
was not maintained.
Essential channel I cables located in the left side compartment of C5716 are in contact with non-essential cabics ALNNI829 and BLNN1222.
Essential channel 2 cables located in the right side compartment of C5716 are in contact with non-essential cables llL:CII221 and ALNNIS28.
This is an infraction.
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,d.
Identification /Tacginc Manholes MII3001, HII3004 and M113005 through which safety related
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cables are routed are not physically identified or tagged.
Instructions or other information' regarding identification of these manholes was not available for review during the current inspection.
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h This item is considered unresolved pending further review by
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a subsequent inspec tion.
e.
Cable Trays / Wire Ways By direct observation, the inspector viewed the cabic trays and wire ways and found them to be free of dirt, debris and
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sharp edges.
The essential cables routed through these trays / wire ways appeared to be free of insulation damage and suort radius bends.
f.
Process and Effluent Radiological Monitoring Systems Section 11.4.2.1 of the licensee's Final Safety Analysis Report (FSAR) states that the sample system for each off-line monitor is designed to provide a representative sampic to the
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respective detector.
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uuring thin innpec t ion, the inspec or noted thal the j
sampling li.ne to the safety related (Q-linted)' contain::sent
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vennej particielat e monitors (No. 5029, 5010) contained nuaer-
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ous right annla herdn and'U-bends in the approximately 200 f t..
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from the-partlenlaLe monitor to the camplinn point at the
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top of the rehet:or necondary shield wall.' Thin construction (numerous rinht angles and ll-bends in the sample line) recuits in particulate plate-out and ImpactLon, to preclude the
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j possibility of the particulate reaching the detector.
This matter is considered c deviation to FSAR commitments.
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I Further, FSAR cection 11, Paragraph 11.4.2.1 states in part
that ".
. 'wliere particulato activity levels are measured
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the systen is-designed for isokinetic sampling." Ilowever,
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Table 11-50 of the.FSAR does not specify flow rates for: the
-. subject monitors and states thc t flow rates are "not applicabic".
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These tso-requirements appear to be in conflict.
Moreover
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the as-built (one inch line) above the reactor secondary shield wall does not include apparatus for isokinetic sampling.
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Followup review of.this matter is planned.
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