IR 05000410/1985013
| ML17058A506 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/28/1985 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17058A505 | List: |
| References | |
| 50-410-85-13, NUDOCS 8507160150 | |
| Download: ML17058A506 (62) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 85-13 Docket No. 50-410 License No
~
CPPR-112 Priority
Category A
Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard S racuse New York 13202 Facility Name:
Nine Mile Point Unit 2 Inspection At:
Scriba New York Inspection Conducted:
A ril 29 1985 to June
1985 Inspectors:
R.A.
Gramm, Senior Resident Inspector G.A.Malton, Senior Resident Inspector R.M. Mheeler, Resident Inspector Approved by:
J Pr j lie, Chi
, Reactor ects Section
,
DRP ate Ins ection Summar Ins ection on A ril 29 1985 to June
1985 Re ort No. 50-410/85-13 Areas Ins ected:Routine inspection by the resident inspector of work activi-ties, procedures and records relative to Allegations, guality Performance
~
Management Program, SMEC Engineering and guality Assurance audit, diesel generator exhaust system, startup quality assurance, control rod drive system hydrostatic test, instrumentation tubing and supports, preoperational test procedure review, main steam isolation valve testing, piping and pipe supports, structural steel, and control rod drive installation.
The inspector also reviewed licensee action on previously identified items and performed plant inspection tours.
The inspection involved 238 hours0.00275 days <br />0.0661 hours <br />3.935185e-4 weeks <br />9.0559e-5 months <br /> by the inspectors.
Results:
No violations were identified.
8507i60i50 850708 PDR ADOCK 050004io G
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F I
DETAILS Project Or anizations Nia ara Mohawk Power Cor oration NMPC Stone and Webster En ineerin Cor oration SWEC General Electric Com an GE ITT-Grinnell Industrial Pi in Inc.
ITT Johnson Controls Inc.
JCI Reactor Controls Inc.
RCI Plant Ins ection Tours The inspector observed work activities in-progress, completed work and plant status in several areas during general inspection tours.
Work was examined for any obvious defects or noncompliance with regulatory requirements or license conditions.
Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation.
The inspector interviewed craft supervision personnel, and quality inspection personnel in the work areas.
Observations are noted below:
FSAR Section 9. 1 was reviewed in conjunction with SWEC specification P232G,
The inspector noted that the FSAR specified the racks to be ASME NF items while the specification allowed the fabri-cation to be either ASME NF or AISC ~
SWEC has issued Licensing Document Change Notice (LDCN) 1S7S to reconcile the FSAR with the actual criteria to which the racks were fabricated.
The inspector had no further questions.
Site project management personnel presented the concept of a production drawing freeze to the inspector.
The concept is based upon the fact that the project has essentially completed the construction phase, that Engineering and Design Change Coordination Reports (E&DCRs) are tracked as separate work entities, and that such design change documents will be incorporated into drawings after plant turnover.
The inspector informed the licensee that such a concept is in conflict with current site commit-ments to revise drawings when five outstanding design changes have been posted against a drawing.
The inspector also pointed out that as-built documents should be finalized prior to license issuance.
The licensee acknowledged the inspector'
comments and committed to provide a detailed procedural change that wi 11 describe how the drawing freeze wi 11 be implemente h\\
The inspector examined field installations of electrical components.
The following installations were questioned and the licensee demonstrated that the inspectors concerns had been previously addressed:
Conduit support ICA334 violated spacing requirements from an embedded unistrut channel.
The unistrut had been marked and attachments were restricted in accordance with drawing EE37CE.
Electrical junction box 2EJS;,PNL304B was supported by grouted anchor bolts.
This condition was documented on N&D 6504 and th'e bolts were actually thru wall.
Cables exiting from tray 2TC0924 had an unsupported span in excess of 36." The engineering criteria for the cables in question allowed up to 48" of unsupported span and Quality Control (QC) verified the acceptability of the noted installation.
Partially pulled cables at tray 2TK192G had been removed from the harness and were covered with debris.
The inspector was presented with SWEC Inspection Reports (IRs)
E5A44716 and E5A44637 which docu-mented the deficient storage conditions.
The inspector reviewed the ITT Quality Accountability report for April 1985.,
He noted that the rejection rate for ASME weld radiography had increased.
The acceptance rate for hanger weld and mechanical attributes has improved.
No violations were identified.
3.
Licensee Action on Previousl Identified Items (Open) Construction Deficiency Report (82-00-15):
Failure to obtain required review of ITT weld planner package.
ITT issued planner DR 2136 (F)
S3 for repair to Field weld 400 on ISO 1-16 without the required SWEC review and approval.
ITT Interoffice Correspondence ( ITT-IOC-2322) documents that seven unreviewed planners were issued on October 29 and 30, 1982.
When the inspector was provided with details regarding weld 400, he asked the licensee to provide additional documents to demonstrate that all of the deficient planner packages were subsequently reviewed by SWEC.
This item remains open.
(Closed)
Unresolved Item (82-12-05):
Control of Measuring and Test Equipment (M&TE) program.
Problems had been identified concerning the calibration of survey instruments, maintenance of M&TE usage logs, and control of M&TE storage.
The following documents were reviewed which govern the M&TE program:
1l l ~
Construction Method Procedure (CMP) 1.8, "Control of Measurement and Test Equipment" CMP 1.6, "Field Check, Care and Calibration of Survey Equipment" QAD 12. 1, "Verification of Measured Data" QCI 12. 1,
"SKW Calibration Program" CSI 19. 1, "Control of Measurement and Test Equipment" The above procedures provide for control of M&TE through the main-tenance of usage logs and storage under suitable conditions.
The areas surveyed by transit 08133, and level 08001 did not have discernable dimensional problems as verified through subsequent surveys.
The torque wrenches that had been lost had not been used for any acceptance inspections.
The SWEC program provides for calibration of survey equipment at six month intervals.
The licensee ascertained that the calibration intervals were adhered to.
Site personnel were retrained. to the enhanced MME program procedures.
This item is closed.
(Closed)
Unresolved Item (83-05-06): Inspection of pipe support toler-ance gaps after permanent pipe setting.
ITT QC inspections had accepted tolerance gaps between the pipe and pipe support prior to permanent pipe setting.
This practice did not ensure the desired gaps were maintained through final pipe sitting.
The Field Quality Control procedure FQC-4.2-26,"System Walkdown prior to Turnover" was issued to establish a final verification of the piping system prior to turnover by ITT.
The checklist contained in proce-dure FQC-4.2-26 includes an attribute for the verification of the pipe support, tolerance gaps in accordance with the quantitative criteria within FQC-4.2-14.
Based on the ITT system walkdown requirements for gap verification, this item is closed.
(Closed)
Unresolved Item (83-17-09):
Conduct of HVAC weld inspec-tions.
The licensee investigated the concern regarding the use of hand sketches during the course of HVAC support inspections.
The hand sketches had been used for information only and not for actual acceptance criteria.
The inspection report system was modified such that all drawings used during a support inspection are to be docu-mented on the associated Inspection Report ( IR).
The inspector reviewed Inspection Plan ( IP) N20P413LFA001 which requires visual weld inspection to assure that weld size, length and location are i'
conformance with the design drawings.
The inspector reviewed seven inprocess and final weld IRs and noted that in all cases the associated engineering drawings were referenced.
This item is close 'I
(Closed)
Fol lowup Item (83-18-09):Conduit section disassembled without Punch List Item Reports (PLIR).
Conduits 2CC999PD3, 2CC999PD2, 2CC999PD8 and 2CC999PD had been disassembled without the requisite PLIR to notify QC that a previously accepted item had been reworked.
In order to resolve the concern regarding inadequate rework control, procedure QS-14. 1 has been instituted and is dis-cussed in the close out of NRC item 83-18-08 contained in report 85-10.
Noted below are the improperly disassembled conduits and the associated reinspection records:
Conduit Number-2CC999PD IR Number E4047074 closed NED 8548 E5A41320-2CC999PD2-2CC999PD3 E4046067 E5A41716 E4045997 E5A41320-2CC999PD8, E3K00522 closed N8D 9110 closed NED 9707 Based on the reinstallation and reinspection of the disassembled conduit, in conjunction with the enhancement of the rework control procedure, this item is closed.
f.
(Closed)
Followup Item (83-18-23):
Inadequate procedures to assure analysis of site hardware modifications on seismic qualifications.
A formal program to analyze field changes made to seismically quali-fied IE electrical components did not existed Project Procedure PP94,
"Review of Changes and their Effect on Qualification of Class IE and Seismic Category I and II equipment has been issued to address formal reviews for affects on seismic qualifications.
The SWEC Structural design criteria was also revised to incorporate specific guidance concerning calculations affecting equipment/structural interfaces.
Based on the revision to the structural design criteria and the issuance of PP 94, this item is closed.
g.
(Closed)
Followup Item (83-18-25):Clearances between piping and other structures did not meet specification requirements.
Six instances of specification violations 'for clearance requirements between piping and other commodities were identified. Additionally, numerous instances of clearance violations were observed between adjacent piping and supports.
ITT generated a
FQC procedure which requires a
f)$
ll
e, )L
. er
detailed review of clearances between the final piping system com-ponents and adjacent commodities.
ITT procedure FQC-4.2-26 has been issued and includes a checklist which requires a clearance verifi-cation.
The specific clearance problems identified were documented via appropriate deficiency documents.
All the deficiency documents have been closed out.
Based on the deficiency document closure and the issuance of ITT FQC procedure FQC-4.2-26 this item is closed.
(Open)
Followup Item(83-18-32):Adequacy of ITT Quality Control Pro-cedure FQCR 4.2-34-1.
"The ITT procedure was revised such that the attributes required to be examined by field engineering were changed to have QC perform the acceptance.
The licensee committed to imple-ment a,SWEC review of sub-contractor QA procedures.
The SWEC QA program review checklists were reviewed and found to encompass the essential QA program elements of the ANSI standards and applicable Regulatory Guides.
The QA program review was only accomplished on a
one time basis and would not evaluate future procedural and QA manual revisions as committed in response to the Management Analysis Corporation recommendation.
This item remains open pending SWEC implementation of an ongoing QA review effort.
Closed)
Followup Item (83-18-37):
Descrepancies in Mechanical equip-ment bolting related to torque values.
Table III-7 within Inspection Report 83-18 provided a detailed listing of equipment bolting speci-fied torque compared with the bolting torque found during the inspection.
Generally, the field torque values compared favorably with the designed torque values.
Torque values have been found to vary up to 20% due to relaxation, rust, lubrication and other factors.
It was established that FQC witnessed the initial design torque during installation.
Based on the variables involved with bolting torque, the values listed in CAT Table III-7 are acceptable.
Based upon the FQC witness of installation bolt torque, this item is closed.
(Closed)Followup Item (83-18-38):HVAC duct support mislocated.
The general notes in the '-
.
HVAC support drawings did not provide a
tolerance relative to the 12 foot maximum span length between supports.
E&DCR C02265 was issued to provide location tolerances between HVAC supports.
The FQC inspection plan N20P413LFA001,
"Ventilation and Air Circulation System Ductwork" was revised to include an inspection attribute for maximum span length between supports.
All previously installed and inspected HVAC supports were re-inspected by FQC to the tolerance requirements given in EKDCR C02265.
As a result of the reinspection, Nonconformance and Dispos'i-tion report 7368 was issued which identified 29 supports that were not in compliance with the design tolerance.
All 29 supports were dispositioned by engineering
"Accept As Is."
Training sessions were given to FQC personnel to emphasize the inspection.attribute for duct support spacing tolerances.
Based on the reinspection of all HVAC supports, the retraining of FQC and the changes to the inspection plan, this item is close fJ
~
(Closed)
Followup Item (83-18-56):
Inadequate controls for concrete unit weight.
All concrete mixes used in shielding areas were designed to meet a dry unit weight requirement of 135 lb/cu.ft.
Although the mixes were designed to provide a margin to achieve the desired 135 lb/ft unit weight, no requirement existed to review and evaluate concrete fresh unit weight to a prescribed lower bound value.
Based on lab tests, Engineering established that a loss of 3 lb/cu.ft could be conservatively expected for most mixes.
Since no correlation tests were available for Mix g, a
5 lb/cu.ft loss was considered for shielding verification requirements and a 3.7 lb/-
eve ft. loss was found for mix B600. All concrete mixes placed in shielding areas were reviewed using the weight loss values and it was verified that these areas meet radiation shielding require-ments.
SWEC issued EKDCR FO 1211 which requires that engineering be notified when the fresh unit weight is below 138 lb/cu.ft. Based on the engineering review of concrete unit weights and the change to the specification, this item is closed.
(Open)
Followup Item (83-18-58):
Conduct of concrete surface inspec-tions.
SWEC Inspection Plan N20S203GFA001 includes criteria to verify repai r of damaged concrete during inprocess surveillance of concrete anchor bolt installations.
The licensee identified that 132 surveillance inspections have been performed in accordance with that plan, however only 9 have specifically referenced the attribute regarding concrete repair.
The licensee further identified that
Nonconformance and Disposition reports have been written to document the correction of concrete surface defects.
The inspector witnessed current base plate installation activities, and found the concrete surface condition to be acceptable under the base plate.
Mhile there is no evidence that the base plates installed to date have covered surface defects, review of Regulatory Guide 1.55 and ANSI N45.2.5-74 reveal that post-placement inspections are to be performed to verify that the required concrete surface finish is obtained.
The inspector requested that the licensee review site construction procedures to ascertain the criteria promulgated for concrete surface finish.
Pending further NRC review of applicable construction procedures applicable to post placement examinations, this item remains open.
(Closed)
Followup Item (83-18-60):
Fastener discrepancies found on mechanical equipment.
The following equipment was identified with fastener descrepancies:
Service Mater Pump 2SMP*P1C Service Mater Pump 2SMP*P1A Unit Cooler 2HVR*UC413B RHR Pump 2RHS P1C
Q
, C
High Pressure Core Spray Pump 2CSH'Pl High Pressure Core Spray Pump 2CSH*P2 Low Pressure Core, Spray Pump 2CSL*P1 Low Pressure Core Spray Pump 2CSL'P2 Reactor Mater Cleanup Pump 2WCS*P1 Hydrogen Recombiner 2HCS~RBNR1A/8 All of the hardware descrepancies for the listed equipment was either corrected to conform with the drawings or the requirement was deleted per an engineering approved change document.
As part of the corrective action associated with the fastener descrepancies, NMPC directed that SWEC develop a sampling plan for reinspection of safety related equipment to verify conformance with the design requirements.
In response to the NMPC directive SMEC inspected 48 electrical penetrations and 2 pumps which were part of the sample originally selected by the NRC inspection.
It was apparent to the inspector that the selected sample was not representative of similar installations.
The inspector selected several additional mechanical installations to perform an independent reinspection.
The inspector reviewed the F(C documentation packages and examined the assoc-iated field installations as identified below:
Nechanical E ui ment 2HVK~CHL18 2EGA*TK2A 2EGA"TK28 2HVK*CHL1A 2EGA*TRP-4 2MCS"P6A 2MCS*P68 2MCS*P6C 2SFC"TK18 In addition to the review for conformance of the in place fastener hard-ware to the design requirements, the traceabi lity of the embedded anchor bolts for 2EGA~TRP4, 2HVK*CHL1A and 2HVK*CHL18 was also reviewed.
The FgC documentation packages, field inspections of installed hardware and the
1,
traceability for the embedded anchor bolts were all acceptable.
Based on the NRC reinspections and the resolution of the specific CAT identified descrepancies, this item is closed.
o.
(Closed)
Followup Item (83-18-62):
CRD restraint beam bolts were accepted by RCI without appropriate head markings.
GE issued Field Deviation Disposition Request (FDDR) KG1-09-192 to direct SWEC to replace the CRD bolts with correctly marked material.
SMEC N&D 6031 and Engineering and Design Coordination Report (EKOCR) F11416 direct the replacement of the bolts with those marked according to GE draw-ing N22 and for hardened washers to be installed.
SWEC IR M4021890 documents the bolt replacement inspection.
The licensee identified the CRD Restraint Beam vendor to be the source of the material deficiency.
This item is closed as the bolting hardware in question has been replaced to satisfy the design requirements.
(Closed)
Followup Item (83-18-63):Uncontrolled unused weld rod.
Unused and partially used weld rod, type E7018, was found at various locations throughout the plant.
Site contractors were directed by NMPC letter NM QA 524 to implement certain actions to improve weld material control.
Specific actions included:
Meld rod attendants shall witness return of unconsumed/scrapped electrodes Electrodes scrapped due to moisture are weighted and recorded.
All supervisors are required to monitor work areas on a daily basis for compliance with rod stub can use and to keep the area clear of improperly discarded electrode stubs NMPC QA conducted several surveillances throughout the plant to determine compliance with the committed corrective actions.
Several concerns were generated as a result of the survei llances and the contractor weld filler material control procedures were changed to enhance control of unused filler material.
Recent NMPC QA survei llances have shown improved weld rod control performance.
Based on the satisfactory weld rod control survei llances, performed by NMPC QA, this item is closed.
p.
(Closed) Violation (83-18-81):Failure to adequately control the installation of safety-related fasteners and inadequate control of unused weld rod.
In the closure of NRC items 83-18-37 and 83-18-60, as discussed previously within thi s report, the specific corrective measures to preclude continued problems in the fastener area was examined.
The inspector also reinspected a
sample of mechanical equipment and did not identify any concerns relative to the installed fasteners.
The traceabi lity of embedded fasteners was also investi-gated and found adequate for the selected items.
The resolution of
unused weld rod is discussed in the closure of NRC item 83-18-63 above.
More frequent surveillances and revised procedures have been implemented to achieve better controls over unused weld rod.
Based on the corrective actions taken, this item is closed.
(Open)
Construction Deficiency Report (84-00-11):
Design drawings for Residual Heat Removal (RHR) system heat exchanger.
The structural steel drawings for both RHR heat exchangers were corrected to reflect the requisite bracing details required by the structural analysis which had been omitted previously.
A design change log was initiated to track outstanding items to be incorporated by the draftsman into the engineering drawings.
The design engineers reviewed power, elec-trical and control drawings to assure that lateral bracing require-ments have been satisfied.
As the root cause problem appears to be inadequate technical review of the issued structural drawings, the inspector requested that the licensee review the corrective actions necessary to address that generic concern.
This item remains open.
(Closed) Construction Deficiency Report (84-00-45):Electrical termination hold points bypassed.
The licensee identified through an exit interview, that a Field Quality Control inspector had not per-formed mandatory hold point inspections of electrical cable termi-nations.
This item is related to NRC items 84-09-03 and 84-09-04.
Nonconformance and Disposition (NCD) reports 8536, 8?48 and 8795 were generated to document the cable terminations inspected by the QC inspector in question.
The heat shrink insulation was removed so that the lug compression could be checked.
A sight hole was drilled to verify proper insertion of the conductor into the lug.
The heat shrink was then reapplied.
Cables that were torqued without QC witness were determinated, tested and relanded with appropriate QC witness.
Cable 2EJSAGL001-FR Phase 2 and 3 had insufficient protrusion into the Lug and Cable 2EJSAGLOOZ-FR Phase 3 had a crack in the cable jacket as documented on N5D 8980.
The deficient cable areas were cut off, relugged and relanded.
The licensee interviewed twelve QC inspectors involved with cable pull activities and found that all of the remaining inspectors were cognizarit of the hold point inspections.
This item is closed.
(Closed)
Unresolved (84-02-02):
Maintenance of diesel generator ambient temperature conditions.
The licensee has responded to FSAR Question F430.74 regarding the measures to be implemented to control the air temperature within the Diesel Generator building.
The thermostat setting was to be a minimum of 65 degrees F with alarm annunciation in the control room.
The inspector verified through review of Logic Diagram LSK-22-7A Rev.
6 and Drawing ESK-10ANN-635 that the low temperature alarm was set for 60 F.
The
licensee notified all lead engineers that instrument set point in-formation must be established to be consistent with the FSAR data.
The diesel generator thermostat set point calculation was reissued on February 19, 1985 which will lead to the correction of the LSK, FSK, and Loop Calibration reports.
This item is closed.
(Open) Violation (84-06-04):
Inspection status for structural steel members.
This item remains open pending licensee response to the EA/QA Audit Item 61 regarding erroneous structural steel inspec-tion status.
(Closed)
Unresolved (84-09-03):Documentation of dissimilar bus bar material concerns.
The inspector was presented with a memorandum from the alleger's supervisor.
The supervisor stated that approxi-mately one week prior to the contact with the NRC, a question had been generated by the alleger regarding the termination hardware.
The s'upervisor directed that the pertinent vendor documents be reviewed to ascertain the bus bar material.
The alleger subsequently identified that the wrong termination hardware had been used.
The alleger was directed to determine whether he had inspected other equipment which had the plated bus bar material.
The supervisor stated that the information was being evaluated for generic impact prior to contacting of the NRC.
This item is closed based upon the licensee statements that actions were underway to assess the extent of the termination problems prior to the contacting the NRC.
(Open) Violation (84-11-04):
Design change control measures.
The SWEC directive regarding Division Manager review and trend analysis of design change documents was reviewed by the inspector.
The program provides for the identification of common problems to prevent repetitious errors within future design changes.
The Engineering Mechanics Division review of December 5,
1984 noted that 18% of the design changes were to correct errors within previously issued E8DCRs or ACNs.
The Electrical Division review of April 18, 1984 documented that 12% of the design changes were to correct previous errors.
The reports additionally identified that 8% and 9%
respectively of the change documents corrected wrong or incomplete drawings.
Pending identification of licensee corrective actions taken in regard to the design change reviews, this item remains open.
(Closed)
Unresolved (84-15-08):
Amendment of SWEC Inspection Reports.
Inspection report N2P28380005 had been amended after issu-ance to include additional attributes that had been verified during the course of the inspection.
The additional items were determined to be correct by the licensee from a review of the associated vendor documentation.
The Inspection System Handbook has been revised to give clear direction on the means to amend an Inspection Report ( IR).
The original shop inspection report in question was marked void as required.
This item is close I
(Closed)
Fol 1owup Item (84-21-03):
Inspection frequencies for Hilti bolt inspections.
ITT used an IOM to define the inspection frequencies for Hilti Bolts.
ITT's Quality control procedure 4.2-16 for the inspection of Hilti bolts was revised and specifically defined the required inspection frequencies.
The JCI surveillance
= inspection frequency was defined as daily.
surveillance to determine whether
~JCI complied with the daily fre-quency and concluded that JCI could not provide objective evidence that these survei llances were conducted daily.
To resolve these concerns, JCI revised the Hilti bolt inspection procedure QAS-1104 to define the inspection frequency for drilling operations as weekly depending on the nature of the work being performed.
Based on the revisions to the ITT 8 JCI Hi'lti bolt inspection procedures, this item is closed.
(Closed)
Followup Item (84-21-08):
Hardmarkings for Preservice and Inservice examination weld identification.
The PSI/ISI program did not include provisions for hardmarking weld identification numbers.
SWEC issued EKDCR FO 2222 adding the requirement to hardmark or band the weld identification members to the ISI weld joints.
Based on the issuance of EEDCR FO 2222, this item is closed.
(Closed)
Construction Deficiency Report (85-00-03):
Safety related valve operators within a non-seismic structure.
SWEC engineering has issued the following drawings:
ES-14BG-1, "Missile Protection Valves 2-SWP-MOV 30A & B Screen-well Bldg.
EL285" ES-14BH-1, "Missile Protection Valves 2-SWP-MOV 77A 5 B
Screenwell Bldg.
EL261" Provisions have been made to surround the valve operators with a steel enclosure of 2 1/2" thick plate.
The enclosure will prevent potential missiles from damaging the valve operators.
This item is closed.
aa.
(Open) Construction Deficiency Report (85-00-05): Incorrect switches for Residual Heat, Removal (RHR),
Low Pressure Core Spray (LPCS),
and High Pressure Core Spray (HPCS)
pumps.
The licensee identified that spring return three-position switches had been installed in lieu of 2 position switches on panel 2CEC*PNL601.
The inspector reviewed the following documents:
NMPC QA Suspected Trend Investigation Report STIR-2S-0002-85 NMPC QA CAR 85-1005 Deficiency Reports 121,165 and 166
t
GE FDDR KG1-3638 N8(D 11,082 E&DCR F42596 While the deficient switches had been properly reworked, it was noted that GE had not been contacted prior to the switch replacement and no evidence existed to demonstrate that other pump control switches had been reviewed for consistency with design requirements.
This item remains open.
bb.
(Closed) Construction Deficiency Report (85-00-12):
Use of unapproved insulation material for motor leads.
Specification E061A directs that Raychem
"NMCK" or "NPKV" heat shrink kits be used to insulate 600 volt motor lead connections.
SWEC Inspection Report E4009502 documents that cable 2SWPFYK004-To was wrapped with Okonite tapes and that Category II Raychem material was used.
Nonconformance and Disposition (NED) report 9727 identified five additional deficiencies regarding Service Water pump strainer motor lead connections.
The deficient insulating materials were removed and the leads re-insu-lated with a approved Okonite taping method.
SWEC QC was further directed to reinspect all safety related motor leads, excluding terminal blocks, for proper insulating material.
SWEC IR E4078184 documents the satisfactory reinsulation of the motor leads identified on NKD 9727.
SWEC IR E4009894 and NKD 10, 127 documented the improper insulation of cable 2CSLNGK001 which was reworked in accordance with an approved taping method.
Engineering and Design Coordination Report C52,527A provides detailed instructions for generic taping of cable connections.
Training records for course NMFJlEN0240,
"Cable Terminations" document QC personnel training for insulating motor leads.
The inspector also reviewed training records for craft personnel for a course which covered the taping procedures This item is closed.
cc.
(Closed)
Unresolved (85-03-04):
Revision of General Electric supplied electrical equipment anchorage details.
The licensee determined that SWEC had communicated with GE regarding the alternate mounting details for switchgear 2ENS*SWG101.
The following documents were reviewed:
GE Installation Manual GEH-1802W,
"Metal Clad Switchgear Types M26 and M36" I
EKDCRs P40435, C42842, C43904 GE drawing 006482630,
"Installation Details for Indoor Metal Clad Switchgear:
TWX 9411028
prll V
SWEC advised GE on 1/28/82 that the switchgear anchorage would be modified.
GE responded via TWX 02N194 dated 2/2/82 that the SWEC modification was acceptable'his item is closed.
dd.
(Open) Unresolved Item (85-04-02):
Control of licensing commitments and accuracy of FSAR information.
By NMPC letter NMP2L0405 dated May 14, 1985, a commitment was made that the EA.audit would check the incorporation of design documents irrto engineering drawings.
The inspector discussed this audit aspect with the audit team leader and found that no explicit directions were contained in the audit plans to address this item and that as of the site visit, positive veri-fication of drawing.incorporation had not been made.
Within sections 2,7, 11 and 12 of this report various discrepancies were identified between the content of the FSAR and site design documents or'ield conditions.
The adequacy of the licensee FSAR verification program will be monitored in future inspections.
This item remains open.
During the inspection period, the inspector conducted inspections and in-terviews in response to allegations presented to the NRC.
The inspector and licensee actions resulting from the allegations are noted below:
a.
(RI-85-A-32): The NRC received an allegation that an electrical gC inspector had failed to properly document unsati sfactory conditions; that the inspector had directed unauthorized rework; that the licensee had covered up the problems relative to the deficient inspector; and that other quality personnel could substantiate the alleger's concerns.
The inspector interviewed the quality personnel named by the alleger.
All three individuals stated that the inspector in question had improperly performed an electrical separation inspection on one
'occasion and that there had been no further recurrence.
The inspector was presented with the following documents that relate to the incident in question.
SWEC IR E4018534: written by the inspector in question to properly document the wiring separation deficiencies.
The rework was accomplished in accordance with site instructions.
SWEC IR E4502550: written to document the lack of procedural compliance for identification of wiring separation problems.
All the PGCC electrical inspectors were re-trained regarding the proper documentation of unsatisfactory conditions and use of four hour unsatisfactory rework form SWEC training records for course NMFJ1QJ040:
Documents the training of the PGCC electrical inspectors on Quality Standard (QS) 14.2 regarding the Inspection Report system.
NMPC QA Surveillance Report E84-1302: written to document the occurrence wherein the QC inspector in question had not properly followed procedures'his allegation was not substantiated as the problem appeared to be isolated, steps have been taken to prevent recurrence, and the requisite deficiency documents were written regarding the lack of procedural implementation.
b.
(M-RI-84-A-177): The NRC received an allegation that tensile strength and hardness records had been falsified for steel rod products from Crucible Steel.
Crucible Steel had allegedly provided the products to several clients including "Nine Mile Island".
The inspector reviewed SWEC site Procurement Order records.
No direct orders were found to have been placed with the following vendors:
Crucible Steel Mayer Metal Newport News 'olled Alloys Fry Steel E.M. Jorgensen Brahco The inspector did not find any evidence that the questionable steel products had been used onsite.
(RI-85-A-34): The NRC was informed that a motor assembly had been improperly installed in unit cooler 2HVR~UC403A.
The alleger stated that an electrical conduit had been disassembled by non-qualified personnel.
The alleger stated that the concern had been reported to the Quality First program.
The inspector interviewed th'e Quality First personnel that had in-vestigated this item.
He was informed that the concern had been found to be invalid as the disassembly had been monitored by QC; that this was related to a craft jurisdiction concern; and that the reassembly had been properly performed.
The inspector then reviewed the following documents that pertain to the unit coolers and the quality assurance requirements governing rework:
Nonconformance and Disposition Report 7475
t ",g eW $
American Air Filter manual NESE593 Appendix D, "Installation; Operation and Maintenance Instructions for Safety Related Unit Coolers with Safety Related Air Cooling Coils at Nine Mile Point Nuclear Station 2.
SWEC Inspection Plans, N20E061AFA003, N20E061AFA025, N20E061AFA026, N20E061AFA040.
Quality Standard 14. 1 The N&D documented a problem involving an improper grease added to the motor bearings.
The motors had then been removed, sent to the vendor for rework and returned to the site for installation.
The inspector ascertained that a Rework Control Form is not required in those cases that an NED directs Quality Control (QC) accepted work to be disassembled.
The vendor instructions document the necessary steps to remove and replace the unit cooler motor.
The inspector interviewed the SWEC QC inspector that had monitored, the motor rework.
The inspector was knowledgeable of the vendor requirement,s.
The inspector then examined the unit cooler installa-tion.
No plant cables had been terminated to the motor and the motor leads were found in satisfactory condition.
The conduit and junction box is an integral part of the motor, and they have to be removed in order to replace the motor.
The inspector was informed that temporary electrical craft had participated in the removal and reinstallation of the motor in question.
The allegation was not substantiated as the motor rework was per-formed in accordance with the quality assurance program under properly controlled conditions.
d.
(RI-85-A-69): The NRC received an allegation that Nonconformance Report 7356 had been improperly dispositioned to allow a pipe support bearing pad to remain in place although the associated weld size was indeterminate.
The alleger stated that the Quality First Program had been contacted regarding this concern.
The inspector interviewed the Quality First personnel.
They stated the item was installed and that it was acceptable from an engineering standpoint.
The inspector reviewed the following documents relative to the questionable pipe support:
ASME III-ND SWEC drawing BZ-11BM-1 SWEC NKD's IG-6982 and IG-7356
'h I W
a
ITT Inspection Reports 85-050-005253, 85-04-04826, E1461H, FU937PR, FU8359 SWEC calculation Z11-0038-1 An integral attachment had been abandoned in place because the 1/4" weldment to the pipe could not be accurately measured.
The bearing
,
pad had been ground around the edges and the weld size was indeter-minate.
Visual inspection had been performed on the attachment weld by ITT QC and the weld quality was acceptable.
The inspector reviewed the SWEC calculation which showed that only vertical loads are transmitted through the bearing pad.
The calculation further demonstrated that allowable stress values in the pipe were achieved even under the presumption that the pad was not in place.
The allegation was not substantiated as ASME code requirements have been fulfilled relative to w'eld quality, that adequate weld size is present to maintain the pad in place to transmit dead weight loads, that removal of the pad weld could cause detrimental affects to the pipe exterior surface, and that the engineering disposition to the nonconformance report was proper.
(RI-85-A-12):
The NRC received an allegation that improper changes had been made to an engineering specification for Gould switchgear, and the associated failure to verify fastener torque within the equipment.
The licensee was requested by Region I, in a letter dated April 9, 1985, to investigate the identified concerns.
The licensee responded by letter dated May 8, 1985 that no unauthorized changes were allowed to the specification and that torque requirements had been provided for the Gould equipment.
The inspector reviewed the Quality First records relative to the fastener investigation.
He examined the document control log for Specification E061A, "Specification for Electrical Installation" which listed design changes implemented between March and June 1984.
The licensee personnel stated that 872 Engineering and Design Coor-dination Reports (E&DCRs) or Nonconformance and Disposition (N&D)
reports were written within that timeframe, 66 of which were related to fastener torque.
The licensee found that all the changes were properly generated and reviewed.
The inspector independently sampled.
the design changes and found them correctly approved.
The inspector verified that the licensee had identified the safety related Gould equipment purchased under Specifications E015N and E015Q.
The inspector reviewed SWEC Quality Control records related to two switchgear installations and eight motor control centers that were supplied by Gould.
He examined installation criteria and inspection records for the shipping split housing connections, main bus, and
~ '
ground bus connections relative to fastener torque and material type as follows:
2EJS~US1 Brown Boveri installation manual provides shipping split torque requirements for a 3/8" bolt to be 15-35 ft-lbs, and for 1/2" bolt to be 30-45 ft-lbs IRE4008343 documents satisfactory torque of housing connections and main/ground bus bar connections on 9/12/84.
N&D 9371 was issued to document use of commercial grade hardware at housing connections and main/ground bus bars.
Per vendor response to E&OCR F01760A, the vendor drawings were corrected and the installed material ascertained to be acceptable.
2EJS*US3 IR ESA43711 documents on 9/10/84 that the housing connections and the main/ground bus bar hardware were torqued to vendor requirements within Brown Boveri installation manual.
N&D 9291 which documents commercial grade hardware at housing connections, was closed on 3/4/85 after vendor response that installed hardware was acceptable.
IR E4008459, which questions the hardware material used for the main and ground bus bar connections, is still open.
2EHS*MCC101 N&D 8468 documented 5/16" bolts installed on ground bus in lieu of 1/4".
Vendor specified torque of 11 ft-lb, was checked per IR E4008959 dated 8/23/84.
N&D 9197 dated 9/15/84 which documented questionable ground bus bolt material remains open.
IR E4008345 dated 7/29/84, which documented questionable bolting material for housing connection was accepted, per E&DCR F01756 by the vendor as installed.
IR E4008345, which further docu-mented the lack of torque requirements for the housing connec-tion hardware, remains open.
SWEC drawing 0001-340-211-156B provides torque requirements of 30 ft-lbs for the main bus hardware.
IR E4008345 documents satisfactory torqu sC'
' N&D 7334 dated 3/18/84 questioned the installed material on the main bus, and was acceptable to the vendor per E&OCR F01756 as commercial grade hardware.
The associated drawings were corrected.
2EHS~MCC102 N&O 8468 documented 5/16" bolts installed on the ground bus in lieu of 1/4".
The vendor specified ll ft-lb torque for the bolts.
IR E4009012 dated 8/23/84 documented satisfactory bolt torque.
IR E4008693 dated 8/12/84 documented the lack of torque criteria for the housing connection bolts.
N&0 9331 provided vendor torque criteria of 10 ft-lb.
IR E5A42307 dated 4/1/85 documen-ted satisfactory-torque of the housing connection bolts.
The bolt material requirements were specified by E&DCR F01756.
IR E4008693 dated 9/28/84 documents the torque of the main bus hardware to 30 ft-lb and verification of correct material.
2EHS "MCC103 N&D 8468 documented the installation of 5/16" bolts in lieu of 1/4" for the ground bus.
The vendor specified a torque of 11 ft-lb and IR E4009013 dated 8/23/84 documents acceptable torque of the ground bus hardware.
N&D 9197, which documented questionable material installed on the ground bus, remains open.
N&D 9395 dated 9/27/84 documented the lack of torque criteria for the housing connections.
The vendor subsequently specified 10 ft-lb torque.
The connections have not yet been torqued.
E&DCR F01756 specified the material to be used for the housing connections which was verified as documented by IR E4008816.
The main bus hardware material and torque are specified by E&DCR F01756 and SWEC drawing 0001-340-211-156B respectively.
IR E4008816 documented satisfactory inspection of both items.
2EHS*MCC301 N&D 8468 documented
.the installation of 5/16" bolts in lieu of 1/4" for the ground bus.
IR E4009014 dated 8/23/84 documented
"
satisfactory torque to 132 in-l,
'a
N&D 9197, which documented the questionable material installed on the ground bus, remains opens N&D 9361 dated 9/15/84 documented that the housing connection bolt material was commercial grade.
The vendor subsequently found the installed hardware acceptable.
IR E4008044 dated 7/5/84 which documented that no torque criteria was provided for the housing connection bolts, remains open.
The main bus hardware material and torque are specified by E&DCR F01756 and SWEC drawing 0001-340-211-156B respectively.
IR E4008044 dated 7/5/84 documents satisfactory torque to 30 ft-lbs.
2EHS*MCC302 N&Ds 8138, 8880 and 8468 documented that the ground bus torque requirements were not specified.
On 8/27/84 the bolts were torqued in accordance with the vendor criteria of 132 in-lb as documented on N&D 8468.
N&D 9197, which documented questionable material installed on the ground bus, remains open.
N&D 9290 dated 9/15/84 documented the lack of torque criteria for the housing connections.
IR E5A42306 dated 3/17/85 docu-mented the housing connection torque of 10 ft-lb.
The use of commercial grade bolts for the housing connection was found acceptable by E&DCR F01756..
The main bus hardware and torque criteria are specified by E&DCR F01756 and SWEC drawing 0001-340-211-156B respectively.
IR E4008771 dated 9/15/84 documented satisfactory torque to 30 ft-lb.
2EHS"MCC303 N&D 8468 documented that the ground bus torque requirements were not specified.
On 8/23/84 the bolts were torqued to satis-factory values as documented on IR E4009011.
N&D 9197, which documented the questionable material installed on the ground bus, remains open.
N&D 9393 dated 9/26/84 documented the lack of torque criteria for the housing connections which was subsequently provided by the vendor as 10 ft.-lb.
IR ESA42306 dated 3/17/85 documented the bolt torqu f'ly
The use of commercial grade bolts for the housing connection was found acceptable by EEDCR F01756.
The main bus hardware and torque criteria are specified by EBDCR F01756 and SWEC drawing 0001-340-211-156B respectively.
IR E4008779 dated 8/15/84 documents satisfactory torque to 30 ft-lbs.
2EHS"MCC Al and Bl The motor control centers had no shipping splits as reflected on SWEC drawings 0001-340-211-164C and 0001-340-211-166C.
As a result of the document review, the inspector found that SWEC Quality Control (QC) had controlled shipping split hardware installations to ensure that the proper bolting material was used and torqued appropriately or that open deficiency documents will track the installation to an acceptable completion status in the future.
Further, no evidence of unauthorized changes in the installation criteria were identified.
The allegation was not sub-stantiated on the basis of the inspector's review of the QC records.
During the course of the document review, the inspector observed that an extremely large number of documents were generated to resolve a relatively simple problem related to the shipping split hardware and torque requirements.
He noted that at least
E8DCR, 14 NKDs, and 18 IRs had been written to date regarding shipping split hardware of the Gould equipment.
It was apparent that rather than seeking a
generic solution, the installations were corrected in a piece meal manner which contributed to some difficulty in establishing the equipment installation status.
No violations were identified.
5.
ualit Performance Mana ement Pro ram The inspector reviewed the eighteenth Quality Performance Management Program (QPMP) report issued by NMPC.
He attended the associated licensee executive board meeting.
The inspector noted that adverse trends were identified by the licensee staff and that responsible personnel were tasked to provided corrective actions for the noted problems.
No violations were identified.
6.
SWEC En ineerin and ualit Assurance Audit a
~
The inspector reviewed the audit plans and checklists generated for the joint Engineering Assurance (EA) and Quality Assurance (QA) audit of the Reactor Core Isolation Cooling (RCIC) System.
He specifically reviewed the following documents:
il
Overall Audit Plan,"Quality Assurance Auditing Division Audit of As-Constructed Condition of Reactor Core Isolation Cooling System and Associated Structures" EA-106, "Program for Completion of the Engineering Assurance In-Depth Technical Audits Nine Mile Point 2 Project" QA Audit Plan NM-20.04,"Reactor Core Isolation Cooling System Instrumentation" NM-20.05,"RCICS Piping Components and Supports" NM-20.06,"RCICS Electrical Equipment" NM-20.07,"RCICS - Civil and Structural" NM-20.08,"RCICS Material Verification" He found that the QA audit plans provided the necessary attributes to conduct a hardware verification of the installed RCIC components.
b.
During the conduct of the QA audit, the inspector accompanied the auditors during the hardware walkdown as documented below:
Electrical: Conduit 2CH999GA depicted on drawing EE-420F-10 was examined for identification, size, support spacing, unsupported cable length and conduit configuration.
Piping: Support BZ-452MA was examined for weld quality, weld size and member configuration.
Isometric ICS-57-10 was'ompared to the as-built drawing for a dimensional verification.
Equipment:
The RCIC turbine installation was examined relative to installation design drawings.
Instrumentation:
Tubing run depicted on drawing EK-400A-5 was examined relative to design requirements.
Solenoid operated valve 2 HVC'SOV171 was examined for the quality of vendor fab-rication and field installation acceptabi'lity.
The inspector observed that the auditors were familiar with site commitments and design specification requirements.
The hardware walkdowns were thorough.
The inspector further monitored the activities of the on-site EA audit team.
He accompanied electrical auditors during their review of cable (2EHSAGL202 and 2EHSAGL203) installation.
The cables were examined for proper identification, routing, separ ation requi rements and proper support.
The EA audit team further reviewed the technical adequacy and completeness of engineering documents such as Advance Change Notices (ACNs), Engineering and Design Coordination Reports (EBDCRs)
and
,4
Nonconformance and Disposition Reports (N&Ds).
The inspector inde-pendently sampled a number of the same documents reviewed by the audit team.
The inspector noted that NNPC had committed that the audit, would verify proper incorporation of t,he design changes into design draw-ings, this was apparently not going to be performed until the inspector informed the audit team leader of the commitment.
The licensee control of commitments is discussed further in section 3.dd of this report.
The inspector reviewed the action items generated during the course of the EA/QA audit which documents concerns or deficiencies.
He will review the licensee corrective actions that will be generated in response to the audit action items.
(85-13-01)
7.
Diesel Generator Exhaust S stem As a followup to IE Information Notice number 85-25 entitled
"Consideration of Thermal Conditions in the Design and Installation of supports for Diesel Generator Exhaust Si lencers",
the inspector reviewed the vendor drawings, the Field Quality Control (FQC) docu-mentation packages and the as constructed condition of the diesel generator exhaust si lencers.
The vendor silencer drawings designated the following anchoring details:
Silencer Number Bolt Torque On Fixed End Bolt Torque On Slidin End 2EGA*TRP-4 2EGA*TRP-2A 2EGA*TRP-2B 45 ft-¹ 150 ft-¹ 150 ft-¹ 25 ft-¹ 10 ft-¹ 10-ft-¹ Additionally the sliding end bolt holes were designed to be slotted to accommodate thermal growth of the si lencers.
The FQC inspection records document'ed that the bolting had been torqued to the values noted above.
The three si lencers were inspected and were found to be in compliance with the vendor drawings regarding foundation config-uration.
It was noted however that despite the thermal design considerations the concrete support pedestal had cracked during diesel generator testing activities.
The concrete had cracked at the fixed end of silencer 2EGA~TRP-2A.
SWEC SEG investigated the cracked pedestal and concluded the cracking resulted from inadequate clear-ance between the foundation bolts and the silencer base plate in the lateral direction normal to the centerline of the silencer.
Based on this determination SWEC issued E8DCR C45594 to slot the fixed end bolt holes in the lateral direction to accommodate movement in this direction.
To correct the damaged concrete on the foundation pedestal an NKD is being issued to document and disposition the
cracked pedestal'he inspector will review the resolution of the concrete cracks.
(85-13-0R.)
b.
It was also noted during the inspection of the silencers that the si lencers were gA Category I but were not tornado missile protected.
FSAR Table 3.2.-1, FSAR Section 3.8.4. 1.3 and FSAR Section 9.5.8.2 were reviewed by the inspector to determine whether tornado missile protection is required for the si lencers.
Conflicting information was contained within the FSAR relative to the extent to which the exhaust system had been provided with missile protection.
The system design provides for protected relief valves in the event the backpressure becomes excessive.
SWEC issued LDCN 1615 to clarify and correct the FSAR description of the exhaust system.
Accuracy of FSAR information is discussed further in Section 3.dd of this report.
No violations were identified.
8.
Startu ualit Assurance The inspector reviewed NMPC guality Assurance Procedure 16.03, "Corrective Action Requests."
A Corrective Action Request (CAR) is initiated to assure that programmatic deficiencies are identified and corrected in a controlled manner.
He reviewed the following CARs that have been generated by the Startup guality Assurance organization:
Number Subject 85-001 85-002 85-003 85-004 85-1000 85-1001 85-1002 85-1003 85-1004 85-1005 85-1006 85-1007 85-'008 85-1009,.
85-1010 Inaccurancies within turnover deficiency tracking system Deficiency Reports Spent Fuel. Pool flush cleanliness Integrated Flush Temporary Modifications Inspection of electrical jumpers (reported as 50.55(e)
item)
NMPC Custody tags Project Guideline for test activities Work Control Request signoff Engineering review of pipe supports General Electric related Deficiency Reports (reported as 50.55(e)
item)
Flushing acceptance criteria gA review of Deficiency Report dispositions Bypassed gA holdpoints on Deficiency Reports Control of superceded procedures Development of test matrices
The inspector observed in two cases that significant construction hardware deficiencies had been identified within the CAR system.
He further noted that at the inception of the CAR program, responses from the test organi-zation were found less than adequate by NMPC QA.
This trend appears to have improved such that adequate CAR responses are now obtained.
No violations were identified'ontrol Rod Drive S stem H drostatic Test Hydrostatic test activities associated with the Control Rod Drive (CRD)
piping from the Hydraulic Control Unit (HCU) to the CRD stub tubes were observed by the inspector.
RCI work package WP-027-C and procedure HY-100
"Final Hydrostatic Leak Test Procedure for Control Rod Drive Hydraulic System" were reviewed and found to contain sufficient instructions to perform the test,.
RCI QC was observed to verify the hydro system valve line up in accordance with procedure HY-100.
The calibrated test pressure gauge PG-1B-2 was positioned on the downstream side of the test pump discharge valve.
The hydro pressure was increased to the test pressure of 2250 PSIG for a period of 10 minutes in accordance with ASME Section III subsection NB, paragraph 6221.
The test pressure was then reduced to 1750 psig and the individual pipe welds we'e inspected.
Based on compliance with the requirements of ASME Section III and hydro test procedure HY-100, the inspector had no further questions.
Instrumentation Tubin and Su orts, The inspector reviewed Engineering and Design Coordination Report'(EKDCR)
F12039 and Nonconformance and Disposition (NKD) Report JC-637.
The design change had upgraded two Solenoid Operated Valves (SOV's),four Air Operated Valves (AOVs), and the associated tubing to QA Category I standards.
The inspector noted that a number of the associated tubing supports had already been fabricated as non-QA Category I items.
The inspector was informed that SWEC QA had previously questioned the EKDCR disposition.
He was subsequently presented with a revised disposition for N&D JC-637 which analyzed each 'installed support and the associated material documentation for acceptability/or rework as necessary.
The inspector questioned SWEC engineering as to the reason for the tubing upgrade initiation.
He was informed that Engineering Change Notice RDS-002 had added the valves in question.
SWEC engineering further stated that a change in design philosophy had directed that for remote mounted SOVs which perform a vent function, the intermediate tubing is classified QA Category I.
The inspector questioned engineering as to whether a plant wide review had been performed to identify whether other intermediate tubing runs were properly classified.
In response, SWEC reviewed 688 SOV installations and found seventeen cases where the valves were mounted remotely.
SWEC confirmed that in all seventeen cases JCI had installed the runs to QA Category I standards.
The review found two
[ ~
cases of document control problems which were addressed by the Site Engineering Group (SEG).
The SEG review ensures the proper gA categori-zation of the remote mounted SOV situations.
The inspector reviewed the FSAR Table 3.2.-1.
He verified that the Automatic Oepressurization System (ADS) portions of the Instrument Air System were classified as safety related on SWEC diagrams 12-1F and 12-1L.
He had no further questions.
No violations were identified.
ll.
Prep erational Test Procedure Review The inspector reviewed the following documents for requirements relative to preoperational testing of the Division III 125 volt emergency DC system:
FSAR Section 8.3.2. 1.2, 14.2.3.2, 14 '.2.6 Table 8.3. -10, 14. 2-10-1 Figure 8.3.-10 Regulatory Guides:
1.32, "Criteria for Safety-Related Electric...:
Power Systems for Nuclear Power Plants" 1. 128, "Installation Design and Installation of.Large Lead Storage Batteries for Nuclear Power Plants" 1. 129," Maintenance, Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants" General Electric drawings 807E183TY 731E302AF General Electric Specifications:
MPL A42-3300/22A2271 BA,
"Preoperational Test Plan" MPL E22-4010 22A1483,
"High Pressure Core Spray System" Project Manual Section 3.6, "Startup and Test Plan" IEEE 450-1975,
"Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations" IEEE 308-1974, "Criteria for Class IE Power Systems for Nuclear Generating Stations" IEEE 484-1975, "Installation Design and Installation of Large Lead Batteries for Generating Stations and Substantions" Stewart and Stevenson
"CED Installation and Operating Instructions for Stationary Batteries"
The inspector reviewed draft copies of preoperational test procedure N2-POT-74-3, "Div. III Emergency D.C. Systems" and Interim Operations Surveillance Procedure N2-OSP-BYS 021,"Div I/II/IIIBattery Performance Discharge Test."
He reviewed the test procedures for technical verifi-cation that the planned testing would satisfy regulatory guidance and licensee commitments regarding battery capacity, recharge and load profiles.
The inspector attended the Joint Test Group meeting at which time the procedure was reviewed.
The inspector identified the following unresolved concerns to the licensee (85-13-03):
The load profile specified within the test is inconsistent with the existing FSAR Table 8.3-10.
The inspector reviewed the revised GE load profile. ke requested that the licensee assure the imposed loads are determined in accordance with Regulatory Guide 1.32 worst case situations, and that Table 8.3-10 be corrected.
Procedure N2-POT-74-3 was apparently approved for use while an integral portion of the test as described by procedure N2-OSP-BY5 021 was still in draft form.
There are no assurances that the two pro-cedures will be reviewed simultaneously to ensure the total preoperational test acceptance criteria will be met.
12.
Main Steam Isolation Valve Testin The inspector reviewed the following documents that pertain to leak rate testing requirements for the Main Steam/Isolation Valve (MSIV) testing:
FSAR section 5', 6.2 Regulatory Guide 1. 141,
"Containment Isolation Provisions for Fluid Systems" ASME Section XI, Subsection IMV ANS-56.2,
"Containment Isolation Provisions for Fluid Systems" NE(D 9952 Nine Mile Point 2 Preservice and Inservice Inspection Program SMEC specification P203D,
"Hain Steam Isolation Valves"
V
0
The inspector noted that the MSIVs had been leak rate tested at the vendor facility.
Subsequently, the valves have been disassembled and portions of the inner surfaces have been clad to correct a corrosion problem.
He reviewed Section XI which categorizes the MSIVs as type A valves, for wh'ich leak rate testing is required prior to placing the valves in opera-tion as well as after valve disassembly.
The inspector questioned licensee test personnel who stated that no design pressure leak rate tests are planned for the MSIVs.
He was subsequently informed that a exemption will be requested for the valves.
The conduct of preservice leak rate testing on the MSIVs is an unresolved concern pending licensee request and NRR acceptance of the test exemption.
(85-13-04)
13.
Pi in and Pi e
Su orts a.
The inspector visually examined the following large bore piping welds:
ISO 25-19 Shop weld 10 ISO 25-19 Field weld 10 The welds were acceptable.
The inspector further reviewed the ITT inspection records for the welds.
ASME Section III requirements were satisfied.
b.
Inprocess welding activities were observed on the following installations by the inspector:
whip restraint 2-ICS-PRR-011 support B2-418LL weld 2-ICS-266-A field weld
small bore support BZ-421EX-3 field weld 20R1 ISO 66-19 The appropriate documentation for planner packages, inspection records, and material traceabi lity were satisfactory.
C.
The inspector examined pipe support BZ-409D-1.
The support attach-ment points were on two pipe runs, and it was not attached to the building structure.
He reviewed design specification P301N which stated that pipe supports shall not be supported from other piping systems'e requested that SWEC engineering review the apparent inconsistency between the design and specification.
SWEC issued EKDCR F02332 to clarify the specification to allow for piping support attachments to other piping systems when approved by engineerin l k
't
Pipe support BZ-139AD was examined by the inspector.
He observed that the sway strut was not centered in the rear bracket and that the centering bushings appeared to be missing.
SWEC QC examined the support and confirmed that the bushings had not been properly installed.
The inspector was informed that QC had not performed a
configuration inspection of the support.
To date, SWEC has not performed any small bore support configuration walkdowns.
The inspector reviewed the BZ control drawing, sketch SK-MS-81-6-11 and Inspection Plan N20P301FA0001.
SWEC completed the following actions to assure that the proper bushings are installed in the sway struts and snubbers:
recall all affected drawings to add requirements for special QC documentation of the pin end hardware.
conduct training of quality personnel on the installation requirements of the sway strut assemblies.
No violations were identified.
14.
Structural Steel In primary containment a structural steel beam (Mark number G6406-1)
was observed to be disassembled by the inspector.
SWEC FQC was contacted to ascertain if the beam disassembly and subsequent reassembly is being properly controlled.
FQC produced Rework control Form FCF S-041 which authorized beam disassembly and established hold points for mating surfaces and bolting inspections during reassembly.
Based on the Rework Control Form, the inspector had no further questions.
'I r
The North and South auxiliary bay stairways were examined by the inspector to determine compliance with applicable requirements.
He found that the North auxiliary bay stairway beam to embedment plate connections did not comply with AISC criteria.
Contrary to the AISC code, plate washers had not been installed over the long slotted holes used in the beam to embed-
'ent plate connection.
SWEC FQC was contacted and it was determined that the stairways had not been turned over to FQC for inspection.
These stairways were installed several years ago.
The inspector was provided a
copy of E&DCR F01906 which downgraded portions of the stairways from QA Category I to QA Category III.
The inspector reviewed fulfillment of Regulatory Guide 1.29 aspects with SWEC engin0ering and he was additionally informed that only during a
control room fire scenerio are the stairs required for emergency operator access.
With regard to the slotted high strength bolting connections without plate washers, FQC provided the inspector with copies of N&D 12,267 and N&D 12,268.
These two N&D's included all the connections observed without plate washers.
The N&D's were written because FQC had not per-formed high strength bolting inspections since the vendor erection
I
- ~
i
drawings did not call for field torquing.
It was noted that all noncon-forming stairway connections except for one had not been inspected.
FgC indicated the inspected/accepted connection was nonconforming and would be addressed on an unsatisfactory IR. Within Inspection Report 85-10 an improperly accepted Hilti bolt was identified which was accepted by the same inspector that accepted the nonconforming connection discussed above.
The inspector has the following unresolved concerns (85-13-05):
The apparent lack of timely (}C inspections for the stairways Inadequate inspection conduct by the FgC inspector who accepted the nonconforming Hilti bolt and structural steel installations.
15.
Control Rod Drive Installation The inspector reviewed GE specification 22A4053, "Control Rod Drive Installation" and associated RCI work package 36.
The inspector observed the dimensional verification of the flange to uncoupling rod and from the uncoupling rod to the spud.
RCI was observed to use GE tool W86047 to obtain the CRD dimension number 2 (174.406
" 0.031").
RCI additionally used a calibrated inside micrometer to obtain the final measurement.
The inspector obtained a
GE calibration report for tool W86047 which identi-fied the length as 173.434" while RCI had presumed the item to be 173.437" long.
The inspector further noted that the rod is composed of six sections which are threaded together.
The following concerns were expressed to the licensee relative to the RCI measurement of the CRD items:
~
The GE length calibration may not reflect the length achieved after field assembly as the threaded pieces may not be assembled in the same manner as was done during calibration.
The GE calibration report does not identify at what temperature the rod was calibrated, thermal elongation/contraction could occur depending upon the relative temperature at the area the rod was used.
The RCI Neasuring and Test Equipment (MATE) program does not adequately control items received from outside sources.
The GE cycle for 52 week re-calibration requirements may not ensure the accuracy of the rod length at intermediate times due to wear, disassembly, and thermal considerations.
The above concerns are unresolved pending the licensee investigation regarding the use of the GE tool and the validity of the RCI CRD measure-ments.
(85-13-06)
16.
Unresolved Items
Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable items, or violations or deviations.
Four unresolved items were identified within this inspection in paragraphs 11, 12, 14 and 15.'7.
Mana ement Meetin s
At periodic intervals during the course of this inspection, meetings were held with senior plant management to discuss the scope and findings of this inspection.
Based on the NRC Region I review of this report and discussions held with licensee representatives on June 7,
1985, it was determined that this report does not contain information subject to
CFR 2.790 restriction ~ 1
~ ~