IR 05000387/1980006
| ML17138B764 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/16/1980 |
| From: | Ebneter S, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17138B760 | List: |
| References | |
| 50-387-80-06, 50-387-80-6, 50-388-80-04, 50-388-80-4, NUDOCS 8102040319 | |
| Download: ML17138B764 (11) | |
Text
Report No.
Docket No.
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-387/80-06 50-388/80-04 50-387 50-388 License No.
CPPR-101 CPPR-102 Priority Category Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown, Penns 1 vania 18101 Berwick, Pennsylvania InsPection conducted:
April 1-4 and g-10, 1g80 Inspection at:
Facility Name:
Sus uehanna Steam Electric Station, Units 1 and
Inspectors:
R.
J aolino, Reactor Inspector
~s )6Ã da e signed date signed date signed Approved by:
S.
0.
bneter, Chief, Engineering Support Section No. 2, RC8ES Branch ate signed Ins ection Summar
Combined Ins ection of Unit 1 and 2 on A ril 1-4, 1980 and A ril 9-10 1980 Combined Re ort Numbers 50-387 80-06
'50-388/80-04 d:
R
,
d t 1i y i p ti by gi
1 d i-
. spector of the licensee's work activities and documentation pertaining to.the instal-lation of safety-related instrument components/systems; review of previously identified unresolved items and items of noncompliance; facility tour and discussions with craft personnel.
The inspection involved 49 inspection-hours on site by one regional based inspector.
~ 'esults:
In the areas pertaining to installation of instruments, four items of noncompliance were identified:
infraction - failure to provide protective measures
'(para. 4.a); infraction - failure'to provide adequate quality control measures (para.
4.b); infraction - failure to establish controls for field fabrication and instal-l
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lation of incorrect parts (para. 4.c);
and infraction - failure to follow instruc-tions (para. 4.d).
Region I Form 12 (Rev. April 77)
S~oao.d 0 5 I I
'ETAILS Persons Contacted Penns lvania Power and Li ht Com an
- R. A. Beckley, Site N(A
- E. Carroll, Site NqA S. Ellis, Engineer - Level III (ISG)
- W. H. Gul,liver, Acting Resident N(AE R. Henry, Startup Test Field Engineer (ISG)
G. Kuczynski, ISG Coordinator
- M. E. Lazarawitz, Resident Engineer
- R. Prego, Site NgA
- A. Sabol, Manager N(A (intercom hookup w/Allentown)
- H. E. Stokes, Senior Project Engineer Construction
- R. Schwan, Supervisory Engineer, NgA (intercom hookup w/Allentown)
Bechtel Power Cor oration D. Davies, Instrument Engineer E. Davies, General Foreman (pipe/tray)
- M. Drucker, Assistant Lead gAE S.
Evans, Assistant Lead (}C (electrical)
J.
Hogue, Termination Engineer D. Hughes, General Foreman (terminations)
H. Jones, Foreman J.
Kato, Electrical Engineer J.
Khandhar, gA Engineer (mechanical)
- H. F. Lilligh, Project gA Engineer P.
Mahood, Civil Engineer
- J.
E. O'ullivan, Assistant Project Field Engineer
- K. D. Peterson, Assistant Project Manager G. Rosenberry, Pipe Superintendent J. Wasilchak, General Foreman General Electric Com an R. Arditi, gA Electrical A. Lilick, Construction Engineer
- T. M. Levasseur, Site gA Manager U. S. Nuclear Re ulator Commission
- R. Gallo, Senior Resident Inspector
- G. Rhoads, Resident Inspector
denotes those present at the exit intervie.
Plant Tour he inspector observed work activities in progress, completed work and p ant status in several areas of the plant during a general inspection of Units 1 and 2.
The inspector examined work items for obvious defects or noncompliance with NRC requirements or licensee commitments.
Particular note was taken regarding the presence of quality control inspectors and indications of quality control activities through visual evidence such as inspection records, material identifications, nonconformance and acceptance tags.
In addition, the inspector interviewed cr aft and supervisory per-sonnel encountered in the work areas.
3..
No items of noncompliance were identified.
Status of Previousl Identified Ins ection Findin s a.
(Closed Unresolved Item 50-387 79-08-03 Licensee response to IE Bulletin No. 77-01 did not specify repeat ac-curacy range of installed time delay relays.
The inspector examined licensee documentation (PP&L Letter No.
PLA-406) which provided the information required, by IE Bulletin No. 77-01.
This item is resolved.
b.
0 en') Unresolved Item 50-387/79-08-05 Incomplete response by licensee to IE Bulletin No. 78-01.
The IE Bulletin requests information regarding the use of General Electric relay (Cat.
No.
CR120A) in safety-related equipment and/or in non-safety-related areas in which a fire resulting from flammable relay contact cover could affect safety-related equipment.
The inspector examined licensee documents (PP&L Letter No. PLI-5243 and PLA-405) to determine compliance with IE Bulletin No. 78-01.
The documents indicate that the CR120A relays are not used in any of the safety-related equipment, however, no determination was made with regards to the use of the relay in non-safety-related areas.
c ~
This item remains open.
(Closed Unresolved Item 50-387 79-14-04 Pertaining to a method or procedure for reworking/repair of cables that have gouges, nicks, abrasions, cuts.
The inspector reviewed licensee procedure FP-E-7, Revision 8, dated February 27, 1980.
Section 3.5 of this procedure delineates the method to be used for repair of damaged cables.
This item is resolve d.
Cl osed Item of Noncom 1iance 50-387/79-35-01 Pertaining to the use of identical markers for identifying electrical service conduit to the Spray Pump and the RHR Pump.
The inspector reviewed licensee memo No. PLA-444, which discusses cause and corrective action imposed for identifying equipment/com-ponents.
The inspector verified licensee corrective action.
This item is resolved.
e.,
Closed) 'tem of Noncom liance 50-387 79-36-03 Pertaining to the tagging of nonconforming items.
=The inspector reviewed licensee memo No.
PLA-453, which discussed cause and corrective action.
The inspector determined licensee corrective action to be adequate.
This item is resolved.
f.
(0 en) Unresolved Item 50-387/79-02-02 Pertaining to gCI-E-5.0 and gCI-E-5. 1 regarding the deletion of gC verifications of use of controlled electrical terminating tools and failure to identify levels of inspection as required by licensee docu-ment SF/PSP-G 6.3', Revision 2.
The inspector reviewed the gCI documents referenced above, noting that the licensee chose to further downgrade inspection requirements by deleting all in process inspections and verification.
The inspector determined this to be. unacceptable.
This item remains unresolved pending NRC review of licensee justifi-cations for downgrading the inspection program.
4.
Instrument Com onents/S stems - Mork Observations-The inspector examined work performance, partially completed work and com-pleted work pertaining to safety-related instruments to determine whether the requirements of applicable specifications, work procedures, drawings and instructions have been met in areas relating to installation, storage and maintenanc Areas a.
b.
examined as follows:
I The inspector examined the hydraulic Control Rod Drive (CRD) instal-lation in the Unit 2 Reactor Building, elevation 719'
0".
The in-spector noted that measures had not been established to control or prevent damage/deterioration to the interconnecting cable assembly connectors (amphenol and BNC type connectors).
Section 3.3-6 of licensee procedure FP-G-ll states, in part, that:
switchgear and other electrical components shall be protected and main-tained during lay-up as required by Vendor Instructions."
(Lay-up is
defined as "idle condition of equipment and systems during and after installation with protective measures applied as appropriate - ref.
Reference 5 of Vendor Specification No. GE-22A2724, Revision 3, states, in part, that:
"... Control and instrumentation supplied by GE...shall be stored inside heated ( IH) and shall be covered and sealed as neces-sary to protect against dirt, dust and other airborne contaminants...."
Licensee gA personnel inspected the Unit 2 CRD installation on April 9, 1980, verifying NRC findings.
Nonconformance Report No. 5656 was issued by the licensee on April 9, 1980 for potential corrosive damage involving 92 units.
The licensee was informed that this item was an item of noncompliance and an infraction of 10 CFR 50, Appendix B, Criterion XIII, which states, in part, that:
"...cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage and deterioration...."
(50-388/80-04-01)
The inspector examined the RCIC pump suction pressure instrument tubing runs from instrument panel 1C017, connection Al, A5 and A6 in the Unit
Reactor Building, elevation 645'
0", area 28, to determine licensee con-formance with installation drawing nos.
JD-28-1-1A, JD-28-1-1E and JD-28-1-1F.
The inspector noted that the slope of the instrument tubing did not ap-pear to conform to drawing requirements of > inch per foot.
Licensee gC personnel were called to confirm the NRC findings.
Measurements made by licensee personnel indicated that the slope met drawing requirements, however, the inspector observed that the measurements made by licensee gC personnel were made using a one foot long level indicator.
The inspector noted that the licensee gC personnel were making their measurements by placing the level indicator at the lowest point of the sagging instrument line between tubing anchor points.
llith the level instrument in this position the readout indicated the tubing to be within the slope tolerance referenced on the drawing.
The inspector suggested licensee gC make
additional measurements by using a straight edge on the instrument tube anchor brackets (uniform machined part)
and then place the level indicator on the straight edge.
This measurement, over a 10 foot length. indicated the slope was 1/8 inch per foot instead of the re-quired
>4 inch per foot, an error of 50 percent.
The inspector informed the licensee that the tools and methods used for measuring the slope of instrument lines are inadequate and that this is an item of noncompliance and an infraction of 10 CFR 50, Appendix B, Criterion II, which states, in part, that:
"...the quality assurance program shall provide control over activities affecting quality of... systems....
Activities affecting quality shall be accomplished under controlled conditions.
Controlled conditions include the use of appropriate equipment....
The program shall take into account the need for special controls...test equipment, tools and skills to attain the required quality and need for verification of quality by inspection and test...."
(50-387/80-06-01)
The inspector examined thermoelement seismic support brackets for the RCIC equipment area leak detection system in the Unit I, Reactor Building, elevation 645'
0", area 28.
The inspector noted that the bracket for thermoelement No.
TE-1N023A did not conform with other thermoelement seismic support brackets installed in the area.
Thermoelement drawing ZE-53, Sheet 812, Revision 0, specifies drawing ZE-53, Sheet 812, Revision I for seismic class I
thermoelement support for local, mounted instruments.
Instead, the licensee used seismic support type FI-25 per drawing ZJ-G16, Sheet 25, which is designated as seismic category I tubing support.
This item had not been inspected by licensee gC, however, the inspector questions the adequacy of licensee control on'field fabrication and installation of similar type items being fabricated by craftsmen having jurisdiction in different areas of construction (electrical/mechanical).
The licensee was informed that this item was an item of noncompliance and an infraction of 10 CFR 50, Appendix B, Criterion VIII, which states, in part, that:
"...Measures shall be established for the identification and control'f...components including partially fabri-cated assemblies....
These identification and control measures shall be designed to prevent the use of incorrect parts and components."
(50-387/80-06-02)
The inspector examined the Unit 1 and 2 upper and lower relay rooms.
The inspector observed that the Unit 2 upper/lower relay room had no visible means of controlling temperature and humidity.
Section 3.3.6 of licensee procedure FP-G-11 states, in part, that:
"switchgear and other electrical components shall be protected and maintained during lay-up as required by... Vendor Instructions."
Reference 5 of Vendor Instruction, Specification No.
GE-22A2724, Revi-sion 3, states, in part, that:
"...Control and instrumentation supplied by. GE...shall be stored inside heated ( IH) and shall be covered and sealed as necessary against dirt, dust or other airborne contaminants If during in-plant or final location storage the heat and venti-lating conditions are not adequate to ensure that condensation cannot occur on equipment, condensation controls....must be employed."
The licensee was informed that this was an item of noncompliance and an infraction of 10 CFR 50, Appendix B, Criterion V which states, in par t, that:
"Activities affecting quality shall be prescribed by documented instructions...and shall be accomplished in accordance with these instructions...."
(50-388/80-04-02)
The inspector examined the Standby Liquid Control System level/tempera-ture instrument installation to determine licensee conformance to drawing Nos. E-9-19-02-06, E-9-45-04-06, M-125-01-11-17 and M-148-01-07-08.
The inspector noted that the system, which had been turned over to the licensee startup group, did not include heat tracing of the pump suction line from the storage tank as required per drawing M-148, Revision 7.
The licensee stated that the heat tracing was scheduled to be added at a later date.
The inspector had no further questions.
No items of noncompliance were identified.
The inspector exami'ned instrument tubing installations in Units 1 and 2 noting the use of compression type fittings.
Vendor instructions recommend a suitable method for applying compression type fittings.
Upon examination of several compression type connections, the inspector could not determine whether the compression fittings were installed in accordance with the recommendations noted in the Vendor Instructions.
gC personnel in the area stated they do not perform in-process inspec-tion of compression fittings.
The licensee stated that compression fittings are checked for leaks during the hydro-test.
The inspector determined this to be inadequate in that there is no assurance that the craftsmen making the connection did not exceed Vendor recommended installation instructions that could result in damage to the tubing and possible future failures at this point due to line vibrations.
In subsequent discussions with the licensee and the Vendor (called in by the licensee)
on April 10, 1980, the Vendor representative indicated the instructions only establish minimum requirements to effect a
pressure seal and to permit the remaking of the seal for a limited number of remakes.
The Vendor representative also indicated the manufacturer may conduct tests to determine the extent to which the user of compression fittings could exceed the recommended installation instruction and its effect.
This item is unresolved pending NRC review of licensee evaluation and corrective acti on.
(50-387/80-06-03; 50-388/80-04-03)
s.
Instrument Com onents S stems -
ualit Records The inspector reviewed pertinent work and quality records for in-place.
storage of safety-related equipment to determine whether the records re-flect work accomplishments consistent with NRC requirements and licensee commitments in the areas of surveillance, legibility, accuracy, approved signatures and ease of retrieving data.
a.
The inspector examined surveillance data for the Standby Liquid Control System noting that the last surveillance inspection was performed on February 14, 1980 and that the system had been turned over to licensee startup group on March 7, 1980.
As of April 10,, 1980, the monthly surveillance inspection had not been done.
Administrative Procedure AD-6. 10, Revision 2; Section 5. l. 1 states, in part, that:
"From the time of blue tagging up until the system is placed into initial opera-tion mode, PP&L staff, will continue applicable portions of Bechtel Construction Storage/Maintenance program.
The licensee indicated that there is a procedural change in progress due to a similar finding by the resident inspector involving 480 V
Motor Control Centers which has been reported as an item of noncom-pliance in the Resident Inspector's Monthly Report No. 50-387/80-01.
This item is unresolved pending NRC review of licensee corrective action.
(50-387/80-06-04)
b.
The inspector determined that the above documents were legible, com-
.plete, accurate, readily retrievable and reviewed by authorized per-sonnel.
No items of noncompliance were identified.
6.
Instrument Cables/Terminations
- Work Observations The inspector examined conduit installation in Unit 2 Reactor Building, Pipe Area I-106, elevation 668'
0".
The inspector noted that conduit AIM090 installation does not conform with the bend requirements of Specification E-49, Revision 22, which limits the bend radius to the equivalent of 4 - 90 bends between pulling points.
The accumulated bend radius for AIM090 totaled 375o.
This item had been inspected and approved on August 2, 1979.
The licensee stated that a rework order (MC-FR PANIC-248) was issued on July 24, 1979 to allow two additional conduits to be installed through the penetration and maintain 1 inch separation.
The licensee implied that the conduit AIM090 may have been moved during that time.
The licensee indicated the error would have been identified on re-inspection.
Rework was completed on August 10, 1979.
Re-inspection of installation has not been done to-dat Subsequent discussions with the licensee indicate that the re-inspection could possibly be limited to the rework order and miss the nonconforming total bend radius.
This item is unresolved pending NRC review of licensee corrective action.
(50-388/80-04-04)
7.
Instrument Cables Terminations - Records Review The inspector reviewed Vendor LOCA qualification data for cable splices using heat shrinkable tubing.
The inspector determined that the Vendor data (Franklin Institute Report No. FC-4033-3)
was unacceptable for use in environmental qualification of containment cable splices since the report does not address acceptance criteria for cable splice configuration or preparation of the test speci-mens used in the LOCA qualification tests.
The inspector could not deter-mine which of the three vendor instruction documents for fabricating Class lE qualified cable splices was used for the test specimens.
This item is unresolved pending NRC review of licensee evaluation and cor-rective action.
(50-387/80-06-05; 50-388/80-04-05)
8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncom-pliance.
Unresolved item(s) identified during the inspection are discussed in Details, Paragraphs 4.f; G.a,
'6 and 7.
9.-
Exit Interview The inspector met with licensee and construction representatives (denoted in Details, Paragraph 1) at the conclusion of the inspection on April 10, 1980.
The inspector summarized the purpose and scope of the inspection and identified the inspection findings.
The NRC Senior Resident Inspector and the Resident Inspector were present at this meeting.