IR 05000397/1979016
| ML17272A838 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/17/1979 |
| From: | Bishop T, Dodds R, Elin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17272A834 | List: |
| References | |
| 50-397-79-16, NUDOCS 8002280067 | |
| Download: ML17272A838 (27) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No.
Docket No.
o CPPR-93 Safeguards Group Licensee:
Washington Public Power SuPPly System P. 0.
Box 968 Richland Washin ton 99352 Facility Name:
W Inspection at:
Inspect i.on conducted:
OCtober 22-25, 1979 T. ii. Bishop, Rea or inspector
/)
J. 0. Elin, Reac r Inspector
~z/n z
Date Signed ll 1 Date Seined Approved By:
R. T. Dodds, Chief, Reactor Engineering Support Section, Reactor Construction and Engineering Support Branch j/ ~
d ~
Sunmary:
Ins ection on October 22-25 1979 Re ort 50-397/79-16:
Date Signed
/2
/'t Signed A~Id:
R d
dd d
d 'by dd yb dd y
y construct>on activities including:
Licensee action regarding sacrificial shield wall fabrication deficiencies; safety related pipe welding; project training and deficiency feedback programs; reactor protection system work activities and quality records; Pittsburgh-Des t1oines Steel part 21 report; and followup on items from previous inspections.
The inspection involved 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> on-site by two NRC inspectors.
Results:
Of the five areas inspected, three items of noncompliance were identified
~tree infractions-failure to maintain c1eanliness/protection of instrument racks, paragraph S.a; failure to maintain closure of instrument piping, paragraph S.a; failure to apply quality requirements to certain items of the reactor protection system, paragraph S.c.).
RV Form
'?19 (?)
sooss89
'" 0 &7
~
l
DETAILS 1.
Persons Contacted
'a ~
b.
Washin ton Public Power Su
S stem WPPSS)
~A.
D. Kohler, WHP-2 Project Manager M. E. Witherspoon, Division Manager, Quality Assurance
- K. D.
Cowan, Project Engineering Manager
- R. T. Johnson, Project Quality Assurance Manager
- G. I. Wells, Construction Manager
- W. H. Smith, Assistant Construction Manager
- G. K. Afflerbach, Start-up Superintendent
- J. F. Peters, Plant Administrative Superintendent
- J.
M. Steidl, Sr. Quality Assurance Engineer
- R. M. Foley, Project Management Specialist B. Green, Design Engineer J. Whitehead, Startup Engineer Burns and Roe, Inc.
BSR)
c'.
d.
- R. C. Root, WNP-2, Deputy Project Manager
%. J. Parise, Assistant Resident Construction Manager
- J. L. Good, Assistant Resident Project Engineer
- H. R. Tuthill, Assistant Project Quality Assurance Manager
"M. Giannini, Lead Civil Engineer L. F. Akers, Senior Welding Engineer J.
Propson, Senior Electrical Engineer J. Lauck, Quality Assurance Engineer J. Civay, Electrical Engineer E. Herzog, Instrumentation Engineer R. Carmichael, Quality Engineer WSH Boecon Bovee and Crail GERI WBG)
h P. Sly, Quality Assurance Manager L. Buckner, Quality Control Supervisor R. Lawton, Quality Assurance Engineer State of Washin ton
- G. Hansen, Senior Project Engineer, Energy Facility Site Evaluation Council
- Denotes those attending exit interview on October 25, 197.
Construction Status As of September 28, 1979, the licensee considered construction of the WNP-2 project to be 78% complete.
3.
Licensee Action on Previous Ins ection Findin s
a ~
(Closed)
Noncom liance 50-397/79-04
Identification and inter-c an ea s st o
brea ers.
The inspector examined interlocks and identification of 4160 volt and 480 volt br eakers in switchgear Sl1-3, SM-2, SH-6 and substa-tions 31, 32, 71, 73, 81 and 83.
The installation of interlocks and lables to identify class 1E breakers was found to be in compliance with the switchgear purchase specification in accordance with WPPSS response dated t1ay 10, 1979.
The inspector had no further questions in this area.
This item is closed.
Closed)
Followu Item 50-397/79-12 03):
Free water encountered w en rin sn e ects on t e sacr>
>cia s se wa SS J
.
co The subject of free water in the SSW was reviewed with cognizant Burns and Roe engineers.
While nonconformance reports have not documented the volume of water encountered, licensee investiga-tion has determined that the amount was small (only enough to cause streaking)
and that the volume of water did not present a dele-terious condition.
The water was determined to originate from an external source, i.e. weather, (at a time when the top of the SSW was exposed).
Concrete hydration precludes consideration of curing water as the source of*the water.
The inspector had no further questions on this matter.
0 en Followu item 50-397/79-12/04
A a
,
u to 1/2 inch, was identified between rin s 3 and of the SSW.
In investigating the gap licensee representatives determined that the SSW erector had not properly assembled the joint between rings 3 and 4.
Design drawings required that the rings be shimmed into position, welded together through plug holes, and the shim gap filled with material to assure adequate radiation shielding.
It was found that, in several cases, the erector had welded the fourth ring to the shims instead of ring 3, and that the resi-dual gap had not been properly filled with shielding material.
Licensee representatives reported these conditions to the NRC:RV as a 50.55(e)
item on October 4, 1979.
The licensee intends to
l t
J k
-3-provide a peripheral bevel weld at the joint for the transfer of tan-gential shear and radial loads between rings 3 and 4.
The repair welding and action to assure an adequate radiation shield in the gap will be examined during subsequent inspections.
Mhile exploring the problem of welding to shims the licensee found it necessary to remove one skin plate from the SSM.
Upon removal of the plate additional concrete voiding was observed.
Licensee representatives stated that the identification of these voids may modify the previously proposed plans to assess concrete voiding (see NRC 'Inspection Reports 50-397/78-10 and 79-08).
Licensee action in this area will be examined further when the corrective actions plans are more firmly defined (50-397/79-16/01).
(Open Followu Item 50-397/79-12/02
Investi ation into al e ations of oor ualit work on the sacrificia shiel wall.
On June 6 and 8, 1979 the NRC Region V office received nine alleg-ations regarding the sacrificial shield wall (SSW)
and related structures at WHP-2.
Two additional allegations were received on October 11, 1979.
NRC inspection reports 50-397/79-12 and 79-13 addressed the substantiation/nonsubstantiation of alleg-ation Hos.
1 through 8.
Allegations Hos. 9, 10 and 11 are addressed below.
Additional inspection results related to allegation No.
1 is also provided.
Refer to paragraph 4 of this report for additional information on the SSM.
Alle ation No. 9:
"tlagnetic particle inspection of structural stee by a Contract 21) subcontractor was changed from DC to AC which does not detect subsurface discontinuities and is con-trary to AMS D.1.1."
~gindin
The allegation was not substantiated.
AMS D.1.1. references ASTtl E-109 for NT procedure and techniques.
ASTH E-109 allows the use of alternating current when specified or specifically agreed upon.
Contractor memorandum of June 8 and 12, 1979 addressed the use of alternating current as noted in NRC inspection report 50-397/79-13.
Burns and Roe repr esentatives stated that the use of AC was verbally approved at that time.
The documentation of Burns and Roe concurrence is provided in Revision 7 of gCP-2 of August 23, 1979, which allows the use of AC on fillet and partial penetration welds 5/16 inch or less.
Alle ation No. 10:
"The 1/32 inch tolerance on the sacrificial s ield wall bearing plate was achieved only at the quarter points
(i.e. at 90 increments),
other locations around the base had more than 1/32 inch, in violation of the specification."
~Find1n
The al'legation was not substantiated.
The 1/32 inch tolerance refers to the bearing plate top surface levelness requirement.
This tolerance was provided in the spec-ification to assur'e plumbness of subsequent rings of the SSl<.
An examination of quality records revealed that the inability to meet this tolerance was properly documented (Burns and Roe, Transmittal BCBR-215-437B-9373 of May 13, 1976; Contract Change Request No. 362 of September 13, 1976; Burns and Roe letter No.
BRBC-215-F-76-2274 of October 7, 1976).
The tolerance was ulti-mately increased to 1/4 inch as noted in Leckenby Fabrication and Erection Procedure No. LFEP-1, Revision 2 which was approved by Burns and Roe on September 14, 1976.
Records establish that this increase in the tolerance was satisfactory to allow subsequent rings of wall to achieve required plumbness.
Alle ation No. 11:
"The shop fabricated segments appeared to be improper y heat stressed as evidenced by the metal discoloration on the inside surfaces of the curved sections."
The alleger did not have specific knowledge of improper heat stressing.
~Findin
Investigation is still in process.
Licensee represent-atives were requested to provide copies of the Leckenby procedures and associated quality records which address the fabrication of the curved sections.
These documents were not immediately available during the current inspection.
Accordingly, this item will be investigated upon receipt of the documents.
Followu Related to Alle ation No.
Allegation No.
1 was concerned with the application of weld cover passes to repair cracks in structural steel.
The allegation was not substantiated (NRC Report 50-397/79-12).
However, dur ing the investigation it was determined that structural steel lamina-tions are routinely repaired by grinding to a depth of 3/8 inch and rewelding.
The technical justification for this method of lamination repair was requested during the current inspection.
The justification was provided after the management interview on October 25, 1979.
A review of the information provided indi-cated that the lamination repair program may not be in full compliance with the structural Melding Code AllS D.l.l, in that the defects may not be explored to the required depth.
This item is considered unresolved and will be examined further during the next inspection (50-397/79-16/02).
-5-0 en Fol lowu item 50-397 79-14 01:
Contractors documented ins ectors trainin ro ram does not insure continued com iance wit A SI N
..6.
Contractor (HBG) representatives explained that no action had been taken to revise the inspectors training and qualification procedure (gCP-22) since it was in compliance with the contract specification.
The subject was reviewed with licensee representatives where it was noted the FSAR states that inspector training and qualifica-tion is in accordance with ANSI N45.2.6.
Licensee representatives agreed to review the situation to assure the contractor 's program is consistent with FSAR commitments.
This item will be reexamined during a subsequent inspection.
(Closed Followuo item 50-397 79-14/03
Meldin rocedure ua ification retests.
The licensee,and contractors actions to retest contract 215 welding procedure qualifications was examined during the current inspection.
The retest program was initiated in October 1978 when licensee representatives questioned the contractor's traceability of weld test records and the application of generic weld tests.
The r etest program and results have been analyzed by the contractor's Principal Melding Engineer, Burns and Roe Engineering Department, and the ASME code Authorized Inspector.
Each of these parties has conclu-ded, based on test results, that the welding procedures were sat-isfactory (as noted in MBG letter MBGMNP2-215-F-79-3131 of August 15, 1979 and Burns and Roe Memorandum from the Senior Melding Engineer of October 17~ 1979).
The test results,-
and the contrac-tor's and Burns and Roe conclusions, were examined and reviewed with cognizant personnel.
It was found that in several cases the initial coupons failed to pass specified tests.
The initial failure was attributed to a lack of strict compliance to WPS requirements in making the original test coupons.
These conditions were analyzed by cognizant parties and additional coupons welded in strict accordance with the welding procedure specification (MPS) and Project Engineering Directive No. 215-M-1049.
These coupons passed required tests.
The inspector has no further questions on this matter at this time.
(Open) Followup Item (50-397/78-09/05):
Actions to correct elec-trical wirin se aration defects in General Electric's Power Gen-eration Contro Com ex PGCC
.
Implementation of GE's action to correct conditions of inadequate electrical wiring separation within the PGCC was examined.
The
S t/ j
-6-deficiencies in the initial PGCC wiring were identified by GE in a Part 21 report to the NRC (see NRC Inspection Report 50-397/
78-09).
GE has issued approximately 25 field disposition reports, to date, providing corrective instructions.
>lire rerouting, separation, termination and inspection/test records were exam-ined for three rerouted wires of the HPCS system (FDDR-571 8925/E22A).
It was noted that the flexible conduit had not been firmly secured for the wiring inspected..
Other aspects of the rewiring were found to be properly performed.
Licensee representatives stated that the securing of conduits would be reviewed and appropriate actions taken.
Licensee representatives estimated that PGCC wire rerouting activities would be completed in the spring of 1980.
This activity will be examined further during a subsequent inspectjon.
(0 en ) Followu Item 50-397/79-04
Actions to correct elec-trica se aration defects in ba ance of ant BOP wirin 50.55 e
item
.
The licensee's.
program to assure adequate separation of electrical class IE wiring for BOP was examined during a previous inspection (see NRC inspection report 50-397/79-09).
The implementation of the program was examined during the current inspection.
Licensee representatives reported that a
FSAR change, detailing a revised separation criteria, was in the final stages of processing and will be submitted to the NRC's office of Nuclear Reactor Regula-tion shortly.
Separation review activities have progressed based on the revised criteria.
Engineering plan reviews and inspections of terminations have been completed by Burns Im Roe, resulting in the issuanceof 54 Project Engineering Directives to correct identified separation
'problems.
Approximately 15 more directives remain to be issued.
The program for controlling the actual rewiring activities was reviewed and found to be satisfactory.
Implementation of the rewiring activities will be examined during a subsequent inspection.
(0 en Unresolved Item (50-397 78-10 03
Information was not avai ab e to verif that t e c am s used to secure ri id e ec-trica con uit wi erform t eir intende function durin a seismic event.
Burns and Roe engineering is investigating the feasibility of assess-ing conduit clamp adequacy through computer simulation.
Licensee representatives estimate the feasibility study will require eight
i l'
-7-weeks to complete.
A second option being considered is actual dynamic testing of typical clamping configurations and loadings.
This item remains unresolved pending completion of engineering acti ons.
(Closed)
Followuo Item (50-397/78-10 07:
E ui ment maintenance sns ection recor forms are snconssstent wit corres ondsn The prograomatic aspects of the licensee's revised maintenance inspection program were examined during a previous inspection and were found satisfactory.
Implementation of the program was also previously examined (NRC report 50-397/79-08)
but was found to need additional efforts to assure equipment is maintained in accordance with the intent of the revised program.
It was noted that additional personnel training has been conducted by the responsible contractor (MBG).
A sample of five recently inspected pumps and valves and the associated inspection records were exam-ined (LPCS-P-1, RHR-V-31A, LPCS-Y-60, CEP-V-3A, and RCC-P-lB).
Based on the results of the examination it appears that the program is being properly executed.
The inspector has no further questions on this item.
0 en Followu Item 50-397 79-06 02
The containment enetration for a RPV samp in ine ma fai due to excess thermal c c in e
stem
.
The licensee's letter of February 22, 1979 informed IE:V of a design error which, if.uncorrected, would subject the RPV Sampling Line penetration (X690) to thermal cycling in excess of the design fatigue life permitted by the ASt<E Code.
The deficiency was identified during fatigue analyses of all instrument penetrations.
Project Engineering Directive No. 213A-CS-0120 was issued on September 28, 1979 directing the 213 contractor to utilize penetration No. X-77A as the RPY sampling line and to provide analytical justification for the use of the penetration based on one million thermal cycles.
This item will be examined further following completion of design activities.
4.
Sacrificial Shield >lail Fabrication Deficiencies a ~
Back round The sacrificial shield wall (SSll) was erected during the'1975 to
II
1977 period by a subcontractor to the 215 contractor.
The com-posite steel/concrete wall surrounds the reactor vessel and per-forms several functions including radiological shielding and (together with the containment vessel) lateral stability for the reactor vessel.
In addition, the SSW provides support for recirculation pumps and main steam/feed water pipe whip restraints.
The wall, which is approximately two feet thick and 30 feet in outside diameter, is attached to the reactor vessel support pedestal and extends upward approximately 48 feet.
In 1978, while in the process of making attachments to the com-pleted SSW, the 215 contractor discovered a concrete void and welding deficiencies in the wall.
The existence of these prob-lems caused the contractor to question the acceptability of the structure.
These concerns were transmitted to the licensee by letter on November 8, 1978 (No. HBGWNP2-215-78-1866).
The prob-lems of concrete voids and structural weld 'acceptability are being handled separately by the Construction Manager (CM).
In reference to concrete voids the CM developed a two-part plan for assessing the extent of voiding.
This consisted of selective neutron monitoring during initial operations and/or exploratory drilling through the SSW skin (See NRC Inspection Reports 50-397/
78-10 and 79-08).
By March, 1979, the CM had formulated a pro-gram to assess the structural weld acceptability of the completed wall (Burns and Roe Memorandum EM-79-188 of March 6, 1979).
The program called for a compilation of documentation relating to weld quality, a plotting of the known deficiencies on the struc-ture, an extrapolation of the known deficiencies to unknown areas, and an analysis,,qf the. structural adequacy based on the extr apola-tion.
Additional actions were to be taken based on the results of the analysis.
The 215 contractor provided documentation on identified deficiencies for use in the study.
In June, 1979, the NRC received specific allegations regarding SSW fabrication, and repairs to the wall and attached structures.
These allegations, and two others received in October, 1979, are addressed in NRC inspection reports 50-397/79-12 and 13 and para-graph 3b, c.
and d of this report.
On July 23, 1979, the 215 contractor initiated a quality review of the specification, procedures, and quality records associated with the subcontractor's fabrication and installation of the SSW.
This review program is outlined in WBG letter No.
WBGWNP2-215-79-3057 of July 30, 1979.
It is the purpose of this review to determine the credibility of the quality records submitted by the subcontractor and assure all required records are provided.
The review is scheduled to be completed by December 197 'h'
-9-b.
Inspection of Current Activities The current inspection included the examination of:
SSM related items from previous inspections (see paragraph 3 b, c, and d
of this report); the contractor's quality review of the SSW fab-ricator; and the CM program to assess structural acceptability of the wall.
(2)
Contractor's guality Review The review of the SSW fabrication/erection subcontractor includes a review of:
the quality requirements levied on the subcontractor; procedures which implemented the quality require-ments; records associated with the work including records of material certification, receiving inspection, welder qualifica-tion, weld procedure qualification, and inspector qualification,'nd verification of as-built record accuracy.
The status of the review and findings thus far were examined.
It was found that initial reviews of quality requirements, material cer-tification, inspection records, welding procedures, procedure qualifications, and welder/inspector qualifications were nearing completion.
No major deficiencies in quality requirements have yet been identified by the review.
The reviews have resulted in a list of missing material certifications.
The SSM fab-ricator reported that the certifications are available and will be forwarded to the site.
The reviews also identified two instances where inspectors'dentities cannot be readily traced.
This problem will also be relegated to the subcon-tractor.
T)e review appeared to be progressing in a controlled manner.
The progress of the review will be examined further during the next inspection (50-397/79-16/03).
Construction t1anager Assessment of Structural Adequacy.
The Ctl program to assess the adequacy of the SSW is being handled by the design offices of the A/f.
The status of the analysis was reviewed with site personnel.
The inspec-tor expressed concerns regarding the progress thus far.
In examining the data base for the defect extrapolation it was found that the base does not, include all known defects on the external surface of the wall.
Discussions with the contractor providing the data used for extrapolation es-tablished that they had provided a package of "typical" defects, not a complete listing of defects.
In addition, no efforts have yet been made to reinspect all accessible surfaces of the SSW to provide an accurate projection of defect rate.
CN representatives believed this reinspection was being performed by the 215 contractor as a part of the quality review.
Contractor representatives, however, clearly
jl
-10-did not feel a reinspection of the SSW was intended by the quality review, and, therefore, had not provided for a re-inspection.
Licensee representatives stated that the ex-ternal surface of the wall would be reinspected and results would be provided to the A/E's design office.
The inspec-tor also inquired about the statistical basis for the extra-polation program.
Site representatives did not have detailed information about this aspect of the assessment program but stated that the inquiry would be passed to cognizant per-sonnel.
Subsequent to the inspection, Burns and Roe representatives telephoned the NRC:RV office to report additional details regarding the SSW.
A SSW task leader has been assigned and a group of Burns and Roe and WPPSS engineers have been assigned to reinspect the SSW.
The reinspection and final analysis of the wall is scheduled to complete November 30, 1979.
The representatives stated that the engineers would be qualified weld inspectors and that welds would be cleaned of paint, etc.,
as necessary to assure an adequate inspec-tion.
The assessment program will be examined further during the next inspection (50-397/79-16/04).
Summar of Remainin Concerns on the SSW and Related Structures.
The fol-lowing tabulation provides a summary of open items per-taining to the sacrificial shield wall and related structural steel:
(2)
(3)
(4)
(5)
(6)
Concrete voids in'he SSW (50-397/79-16/Ol)
Repair of laminations in structural steel (50-397/79-16/02).
Weld attachment and gap void between rings 3 and 4 of the SSW (50-397/79-12/04).
Allegation of improper heating of SSW fabricated sections (all egation No. 11, 50-397/79-12/02)
.
Review of the SSW fabricators quality program and its imple-mentation, including material traceability and inspection documentation (50-397/79-16/03).
Reinspection of the SSW and assessment of structural ade-quacy (50-397/79-16/04).
-11-Inte rit of containment vessel airlock
CFR Part 21 item)
Pittsburgh-Des Moines Steel Company (PDN) notified the NRC and llPPSS of a condition discovered during a manufacturing test of an airlock.
It was discovered that, under extremely fast closing conditions, the door could bounce off the 0-ring/metal interface, preventing latch-ing.
Further turning of the handwheel would then close the equalizing valve and turn off the light indicating the door is latched and the equalizing valve closed.
llith this operation complete, the other air-lock door could be opened, violating the leak tight integrity of the airlock.
To correct this condition the licensee has issued Project Engineering Directive No. 213A-C5-0131 (of September 14, 1979) to design, install, and test a shock absorber in the airlock door system to assure latching.
The inspector has no further questions regarding this item at this time.
Safet Related Pi e Meldin On October 19, 1979 the NRC Resident Inspector assigned to llNP 1/4 observed a completed valve-to-pipe weld which did not appear to meet the ASME Code 3: 1 slope requirement for thickness transitions (ASME III, Figure NB-4233. 1(a)).
During the curr ent inspection the weld in question (RHR-V-148) and three similar valve-to-pipe welds (RHR-Y-116, RHR-V-115, and RHR-V-488) were examined.
Profi lometer repli-cations were made for the weld on RHR-V-148.
A comparison of the valve and preparation drawing and the as-welded condition depicted by the profilometer indicated that the required 3:1 slope was (within a distance of 1', times the wall thickness from the weld) was covered by weldment.
This condition is in accordance with the code.
A review of end prep-aration drawing details for "the remaining three valves, verified that the required 3:1 (within the required distance)
slope was provided on the valves.
The inspector has no further question on this aspect of the welds.
During the visual inspection of weld joints, two additional items arose.
A reduction in pipe outside diameter was noted immediately adjacent-to the weld in two areas (inlet side of RRC-V-608 and the lower side of RHR-V-148).
Licensee representatives agreed to perform ultrasonic thick-ness measurements of the pipe wall in these areas to verify adequate wall thickness.
The transition of the weldment-to-valve for the lower weld on valve RHR-V-148 was sharp, creating a possible stress riser (due to Knotch effect) for this joint.
Licensee representatives stated that this situation would be reviewed and appropriate action taken.
These two items will be further examined during a subsequent inspec-tion (50-397/79-16/05).
i 0'
-12-7.
Pro'ect Trainin and Deficienc Feedback Pro rams The general project training program and the individual contractor's deficiency feedback programs were examined during the current inspec-tion.
The specific training activities of four major contractors (contracts 215, 216, 218, and 220} were reviewed with licensee rep-resentatives.
The quantitative training figures provided indicate a
significant increase in attention to training since the 1JPPSS/NRC Enforcement Conference of June 1978.
Six contractors (Nos. 210, 213A, 215, 216, 218, and 220) programs to provide craft feedback on defective work were reviewed.
The programs are summarized in MPPSS tlemorandum No.
F-79-2242 of June 29, 1979.
The training and feedback programs being im-plemented at the llNP-2 site appear consistent with the licensee's commitment to the NRC to make improvements in these areas.
The in-spector has no further questions on these subjects at this time.
8.
Review of Reactor Protective S stem The inspector examined the installation of the reactor protective system functions of "nuclear system high pressure trip", "main steam line high radiation trip", and "turbine stop valve closure/turbine governor valve fast closure trip".
a.
Nuclear S stem Hi h Pressure Tri The inspector reviewed the records documenting certification and installation of the pressure transmitters associated with this protective function to insure compliance to the requirements of IEEE-279 as detailed in the FSAR and pertinent instructions and procedures.
The inspector examined instrument racks H22P026, H22P027, H22P005 and H22P004.
A heavy accumulation of dirt was present on all instruments and associated racks.
Additionally, the racks were being used by other construction trades for storage of equipment.
Numerous structural bolts and steel plates were lying both" on the racks and on various instrument transmitters.
For example, 37 steel support plates were found on rack H22P004 along with a gas pressure cylinder cap.
In addition, on rack H22P026 the following instruments had been removed, according to the licensee for calibration by MPPSS startup personnel, without protection of open impulse lines B22 N038A, B22 N036A, and B22 N036B.
Also, on rack H22 P005, in-strument transmitters C34 N004C and B22 N026C had been removed without protection of opened tube ends.
The inspector examined the unprotected tubing associated with these instruments and saw evidence of dirt accumulation inside
-13-the lines.
Fishbach/Lord Procedure CP208 requires
"covers, caps, plugs and other closures shall be maintained intact." It also requires that
"...mechanical cleaning shall be employed to keep the structure as clean and dry as possible."
Failure to maintain adequate cleanliness of transmitting instruments and associated sensing lines in accordance with established pro-cedures is an apparent item of noncompliance (50-397/79-16/06).
The inspector noticed various electrical cable which had been dis-connected from instruments on the racks examined.
It was not apparent that the cables had been tagged to insure proper re-connection of electrical wiring and instrument tubing during calibration or maintenance.
This item will be examined further during a subse-quent inspection (50-379/79-16/07).
- At the close of the work day the inspector identified seven process instrument lines, associated with 3 containment penetrations, open and unattended.
These instrument lines were under the control of Johnson Controls, Inc.
Johnson Controls, Inc. Procedure Ho.
SP-2005-H2 (Installation and Erection Procedure, gI and ASME III)
requi res all pipe and tube ends to be capped or otherwise closed at the end of each day.
The licensee stated that the problem of closure of systems may be the result of other crafts removing protective covers without authorization.
The failure of Johnson Controls to maintain system cleanliness in accordance with established procedures is an apparent item of non-compliance.
This is a repeat of a previous NRC finding of 27 February and 1 i'larch, 1979.
(50-397/79-16/08)
t1ain Steam Line Hi h Radiation Tri The inspector examined cabinets and cables associated with the main steam line high radiation trip feature of the reactor protective system for conformance to IEEE-279 as detailed in the FSAR and pertinent instructions and procedures.
Licensee representatives stated that a review of the routing of cables associated with this system was in process due to the installation of these cables through an opening in a cinder block wall in a seismic class II structure.
The inspector pointed out that the installation also routed these cables through areas of high energy piping and at several points supported the class IE cables from seismic cate-gory II structure The area of installation of class IE circuits in seismic class II structures is a followup item from previous inspections (50-397/
79-04/15).
This item will be expanded to include a review of the effects of high energy piping on class IE electrical cables installed in areas such as the turbine building.
Turbine sto valve closure/turbine overnor valve fast closure The inspector examined purchase documents, certification and in-stallation of instrumentation associated viith the turbine stop valve closure and turbine governor valve fast closure trips and compared them to IEEE 279-1971 as detailed in chapter 7 of the FSAR.
It was found that the four "turbine first stage pressure" pressure swi tches (PS N003 A through D), which sense power level and provide a low power bypass to the turbine trip function, were provided by General Electric with the reactor protection system and appeared to meet qualification requirements.
However, they were not clearly labled as class IE equipment.
Horeover, their sensing lines were not treated as safety related equipment and did not appear to meet the installation requirements of safety related equipment as to location and seismic qualification.
Position switches (POS N006 A through D), which indicate turbine stop valve positions, were supplied by the turbine contractor (Mest-inghouse)
along with pressure swi tches PS N005 A through D and PS N008 A through D.
Thyrse switches provide information of turbine governor valve fast closure via th'e governor valve hydraulic system.
All of these devices were supplied as coranercial grade items, contrary to requirements of the FSAR and IEEE-279.
The electrical cable for these devices was treated as non-class IE up to electrical terminal boxes TB-RPS-A1, TB-RPS-B1, TB-RPS-A2 and TB-RPS-B2.
The non-class IE wires from the above mentioned devices were to be terminated to class IE cables from the reactor protection system, in these terminal boxes which were located within the turbine missile cone approximately
feet from the turbine shell.
Finally, sensing lines to PS-005 A through D, were treated as non-safety related and were found uncapped.
The specification, purchase and use of non-class IE circuits and components and their direct connection to class IE cables is not in accordance with FSAR requirements for this system.
This is an apparent item of noncompliance (50-379/79-16/09).
-15-The licensee committed to review this system and clearly identify all boundaries between the safety class systems and non-safety systems.
In cases where these boundaries do not comply with present FSAR requirements the licensee will either seek amendment of the FSAR or bring the system into compliance.
This item will be examined during a future inspection.
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations.
Six.:unresolved items were identified during this inspection and are discussed in Paragraphs 3c, 3d, 4b(1), 4b(2),
6, and Sa.
10.
Mana ement Interview At the conclusion of the inspection a meeting was held with licensee and Burns
Roe representatives as denoted in Paragraph 1.
The activ-ities covered during the inspection and the observations and findings of the inspectors were discussed.
The inspectors expressed concern r egarding the poor coordination of the program to assess the structural adequacy of the sacrificial shield wall (paragraph 4b(2))
and the quality designations of reactor protection sub-systems (paragraph 8).
Licensee representatives stated immediate actions would be taken on these and the other findings identified during the inspectio )
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