IR 05000410/1986008
| ML17055B612 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/02/1986 |
| From: | Anderson C, Cheung L, Paulitz F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055B609 | List: |
| References | |
| 50-410-86-08, 50-410-86-8, NUDOCS 8605090142 | |
| Download: ML17055B612 (22) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-410/86-08 Docket No.
50-410 License No.
CPPR-112 Category B
Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Facility Name:
Nine Mile Point Nuclear Station Unit 2 Inspection At:
Scriba
'New York Inspection Conducted:
March 3-7 1986 Cg g
s Approved by:
C. J.
erson Chief, Plant System Section, EB, DRS
,nfl Inspectors:
g F. Paulitz, Reactor Engineer eac e En
'
ate dat date Ins ection Summar
Ins ection on March.3-7 1986 Ins ection Re ort No.
~/
Areas Ins ected:
Routine, unannounced inspection of the instrumentation system installation to determine whether the work performed and the required documentation is in accordance with established procedures, FSAR and licensee commitments.
Results:
Four violations were identified during the inspection.
These viola-tions pertain to:
safety to non-safety instrument/control cables separation; using uncontrolled drawing during electrical control circuit modification; not maintaining instrument cable connector environmental integrity; and, damage to instrument impulse tubing.
8605090142 860502
- DOCK 050004i2 PDR
DETAILS 1.0 Persons Contacted Nia ara Mohawk Power Com an
- R.
C G
J D
" M.
- W.
- A.
J B.
L.
L.
Matlock, Deputy Project Director Lee, Special Projects Millian, Lead Senior NC&V Engineering Afflerbach, Startup Manager Bufis, Startup
& Test Group Manager Brassard, Startup
& Test Ray, Special Projects Manager Hansen, Nuclear QA Operation Manager Vierling, Lead Reactor Engineer Bunyan, Engineer Beckham, Project QA Manager Weakley, Special Projects Dick, QA Engineer Fenton, Lead, QA Audit Group 1.2 Stone and Webster En ineerin Cor F
- J
- J
" A.
- p G
E W.
R.
Dam, Senior QC Engineer Drake, Startup
& Test Project Supervisor Arrington, FQC Resident Manager Gallagher, Site Licensing Engineer Terry, Project QA Manager Rovetti, Supervisor Engineering Conte, Senior Control Engineer Marsh, Assistant Superintendent, FQC Hubner, Assistant Superintendent Engineering Taylor, Assistant Superintendent FQC Askew, Senior I&C Inspector FQC 1.3 Johnson Control Inc.
Brown, FQC I&C Inspector 1.4 U.S. Nuclear Re viator Commission R.
S.
" Denotes Gramm, Senior Resident Inspector Hudson, Senior Resident Inspector those present at exit meeting conducted on March 7, 198.2 ~Fili
2.1 The inspector observed work activities in progress, completed work and plant status during general inspection of the control building and reactor building.
The inspector examined installed instruments, instrument cables and control cables in the area for any obvious defects or noncompliance with regulatory requirements or licensee commitments.
2.2 Particular note was taken of a modification in the Division ll electric switchgear room.
This modification was controlled by Design Request (DR) Number 14579.
This was a wiring change to add three missing fuse blocks to the control circuit of a motor operated valve in the service water system, 2SWP*FV47B.
The inspector noted that the drawings being used, EE-9NB-4, EE-9NG-4 and EE-9NC-4, were stamped for information only.
Neither the personnel performing the work nor the gC inspector check-ing the work were aware of the requirements of Start-Up Administra-tive Procedure No.
N2-SAP-104C concerning the control of working drawings.
The procedure section 5.4. 1, requires the Test Engineer to verify that all A/E drawings are current to the drawing Index and to stamp the drawing with a Verification Stamp.
The inspector observed that at least one of the three drawing being used did not have the verification stamp in accordance with the requirements of the procedure N2-SAP-104C; NMP2 Document Control Program No.
PG 100; SWEC gA Program, Document Control Section 6 and the FSAR commitment in Section 17.6 Document Control.
This is a
failure to follow the requirements of document control and is a
violation of 10 CFR 50 Appendix B, Criterion VI.
(50-410/86-08-01)
2.3 The inspector observed instrumentation and control cable separation, between division to division and division to non division, in the control building and the reactor building.
The specified separation requirements are contained in Specification for Electrical Instal-lation, revision 10, dated May 20, 1985, J.O.
12177, Specification No.
NMP2-E061A, Appendix I.
The FSAR commitment has been revised for electrical separation acceptance criteria which was incorporated into Table 1.8-1, Amendment 23.
The separation requirements, space dis-tance, between divisions and between divisions and non divisions has been reduced as a result of tests conducted by the licensee.
This is discussed in a licensee letter from C.
V. Mangan to E. Adensam, NRR dated February 14, 1985.
This reduced distance for the cable spread-ing'rea is 10 inches in all directions.
The inspector noted that an electrical cable, 2EGPNGN001, on the west side of the control build-ing at elevation 321 (Control Room Elevation)
was separated by 7 to 8 inches from the non-division cables, at penetration, 2WC564N14 and the one above.
The cables were not separated by an installed bar-rie I
The cable 2EGPNGX001 was exiting cable tray 2TK555G.
This area is defined as a cable spreading area.
It had been previously inspected by F(C and found acceptable.
This separation problem is a result of a failure to follow procedure NMP2-E-E061A and is a violation of 10 CFR 50 Appendix B, Criterion V.
(50-410/86-08-02)
3.0 Instrumentation Cable and Termination 3.1 Work Observation 3. 1. 1 General The inspector observed work activities in progress and completed work relating to the installation of instruments, instrument cables and cable terminations of the emergency core cooling system and the containment isolation system to ascertain whether the installation was performed in ac-cordance with applicable procedures, the FSAR and the licensee commitments.
3.1.2
~Sco e
Instruments examined for this determination included:
a.
Reactor water Level Wide Range Transmitter Location:
2CES*RAK004 EL 261"-0" COL 082-52 2ISC*LT-9A Channel Al GE B22 LTN091A 2ISC*LT-9C Channel A2 GE B22 LTN091E 2ISC"LT-llD Channel A2 GE B22 LTN081D Location:
2CES*RAK005 EL 261"-0" COL 159-53 2ISC*LT-11A Channel Al GE B22 LTN081A b.
Drywel1 Pressure Location:
2CES*RAK004 2ISC*PT-15D Channel Bl GE C72-PTN050A 2ISC*PT-17A Channel B1 GE B22 PTN094A 2ISC*PT-17C Channel B2 GE B22 PTN094E Location:
2CES*RAK0005 2ISC*PT-15C Channel Bl GE C72-PTN050D Documents reviewed included:
a.
Specification for Electrical Installation, revision 10, May 20, 1985, JO NO 12177, Spec.
No
~
NMP2-E061A
b.
Specification for Instrument Installation, revision 4, June 14, 1985, JO NO 12177, Spec.
No.
NMP2-C087A c.
Logic Diagram Balance of Plant ESF Actuation 12177-LSK-27-19G, revision 2 and 19H, revision
d.
Cable Pull Tickets for the above listed instruments e.
Loop Calibration Reports for the above listed instruments.
~Findin s
The inspector found that the instruments were: properly identified; included proper cable separation; and utilized correct cable routing.
However, the cable connections to the instruments were not installed correctly.
The inspector noted that the above instruments on the A
side of instrument rack 2CES~RAK004 cable environmental connector were loose at the instrument interface.
The inspector expanded the inspection to other instruments on these and other instrument racks and identified thirty two similar cases.
The licensee when told of this condition stated that this condition was known and identified on
'onconformance and Disposition Report (NEDR) No.
14791 and 15610.
This loose connection is only a problem where 90 degree conduit fittings are used between the seal and the trans-mitter.
The inspector compared the instruments found with loose connectors identified by the licensee against those identified by the inspector.
Three additional instruments 2ISC*PT40, 2MSS*FT16A and 2CSH*FT109 were identified by the inspector.
This information along with one instrument with an incorrect nameplate was given to the licensee.
The vendor, Rosemount, instruction manuals number 449b, revision B, number 4302, revision C, both specify that the threaded conduit fitting between the cable environmental seal and the transmitter should be turned by four to seven turns.
This design requirement was not translated into the electrical installation specification E061A revision
prior to cable environmental seal attachment to the in-strument transmitters.
The licensee has revised the speci-fication E061A by the Engineering 5 Design Coordination Report (E&DCR) No.
F02590 dated February 11, 1986.
However the licensee corrective action in NEDR No.
14791 and 15610
Ri
does not address all of the installed transmitters which have 90 degree conduit fitting with four threads as evi-denced by the three loose cable connectors identified by the inspector.
This incomplete corrective action is a
violation of 10 CFR 50 Appendix B Criterion XVI.
(50-410/86-08-03)
3.2 ualit Record Review The following records were reviewed for the instruments identified in paragraph 3. 1. 1 to ascertain whether the records meet the established procedures and whether the records reflect work accomplishment con-sistent with NRC requirements and FSAR commitments:
N8DCR NO.
12134 Replacement of Rosemount Transmitters with qualified model dated 12/2/81 Open NKDCR NO.
12862 Overtorque of Rosemount Seals dated 7/13/85 Closed N&DCR NO.
13332 Overtorque of Rosemount Seals dated 7/13/85 Closed NEDCR NO.
14474 Overtorque of Rosemount Seals dated 7/13/85 Closed NEDCR NO.
14947 Damaged Rosemount Flex Conduit dated 7/13/85 Open guality Assurance Inspection Report, E5A45719, 2CES*RAK004 Elev 261 RB Attributes 7, 13,Unsat.
dated 7/13/85 These NKDR's are found to be legible, complete and properly reviewed by qualified personnel.
The records were properly identified, stored and can be retrieved in a reasonable time.
The reports included proper resolution and adequate justification for
"accept-as-is" disposition.
Within the scope of this review, no unacceptable conditions were identified.
4.0 Instrumentation Com onents and S stem 4. 1 Mork Observation The inspector examined work performance pertaining to the instal-lation of safety related pressure and differential pressure transmitters (including flow and level transmitters)
in the Residual Heat Removal System and Recirculation System to determine whether the requirements of applicable specifications, NRC requirements and licensee commitments were met in the areas of receipt inspection, material qualification, procurement, installation and quality control inspectio 'p.
Ih
Items Examined For This Determination Include:
a
b.
C.
Safety-related flow transmitters 2RHS~FT10 in secondary containment at Elevation 261'".
Safety related differential pressure transmitter 2RHS'PDT24B and flow element 2RHS*FE10 in the Secondary containment at elevation 289'".
Safety related transmitters 2RHS*FT64A in the Secondary Containment at elevation 215'",
2RHS*FT14A and FT86A in Instrument Rack 2CES*RAK-018, 2RCS*FT6B, FT8B and FT83B in Instrument Rack 2CES~RAK-025, 2RCS'FT6A and FT8A in Instrument Rack 2CES*RAK-009, all located in the Reactor Building.
Stone and 'Webster (SEW) Specification No.
NMP2-C081A
"Instrument Installation" Revision 4 dated June 14, 1985.
Stone and Webster Inspection Plan No.
N20C081AFA002
"Instrument Installation" Revision OB dated February 11, 1986.
S5W Isometric Drawings:
DK-420GH, Rev.
DK-450DF-1, Rev.
DK-440BM-4, Rev.
DK-440BL-1, Rev.
DK-450DE-1, Rev.
DK-440BJ-1, Rev.
DK-450 DF-1, Rev.
DK-420EW-3, Rev.
DK-420EX-1, Rev.
DK-420EY-2, Rev.
1 dated 1 dated 4 dated 1 dated 1 dated 1 dated 1 dated 3 dated 1 dated 2 dated March 30, 1984.
November 30, 1983 December 06, 1984 March 17, 1983 November 30, 1983 January 19, 1983 January 30, 1983 November 10, 1984 August 22, 1983 June 5,
1984.
Inspection Surveillance Report (ISR):
ISR NOS.
16752, 16753, 16754, 8124, 8877, 12364, 7807, 16755, 16756, 7808, 8125, 11760.
JCI Walkdown checklist for R202 dated October 21, 1985.
Hydrostatic test report for R201 and R202 (Test No.
H*1436) dated September 11, 198 SKW Specification for Electronic Transmitter--
Category I, Rev
~
1 dated July 2, 1985 and instrument data sheets for transmitters identified in items a, b,
and c above.
S8W Speci ficati on for Orifice P lates - Category I, Rev.
2 dated February 15, 1984, and instrument data sheet for 2RHS*FE105.
~Findin s
On March',
1986, while in the Secondary Containment at Elevation 289'".
The inspector identified that the impulse line of 2RHS~PDT24B was damaged (appar-ently it was stepped on).
The inspector also identi-fied on March 5, 1986 in the Secondary Containment at Elevation 215'" above Instrument Rack 2CES*RAK025 that impulse line K-117 (for 2MSS'FT12D) was damaged.
Similar problems have been identified by NRC during a November 5 - December 21, 1985 inspection.
Sub-sequent to that finding, violation 410/84-19-03 was issued requiring the licensee to institute corrective actions to preclude recurrence.
The licensee's pre-vious corrective actions were not effective.
Follow-ing this identification of this recent probelm, the licensee stated that they would set up a program to require a
100% walkdown on the instrument tubing to identify and correct any tubing damage when the con-struction is completed.
This is in violation of 10 CFR 50, Appendix B, Criterion XVI which states that corrective actions shall be taken to preclude repetition of conditions adverse to quality (410/86-08-04).
b.
SEW Specification No.
NMP2-C081A requires that all pre-engineered instrument line shall be installed in accordance with 400 series EK drawings; Note 6 of Drawing EK 401 BC (also SEW Inspection Plan No.
N20C081AFA002 Rev.
OB item 13) requires the instrument impulse lines to have a slope of '," per foot minimum for pressure, flow and differential pressure devices unless otherwise noted.
On March 4-5, 1986, while in the Secondary Containment at various elevations, the inspector identified that the following instrument impulse lines had slopes less than ~" per foot:
K028, K029, K056, K067, K075, K034A, K108, K059 through K065 (all near Instrument Rack 2CES*RK009);
K001A between supports BZ416VH; R256 and R257 from BZ413AS to the tee immediately above the rack; R259 between BZ413AS and BZ413H (All these nonconformances were documented in N&DR No.
15762 dated March 6, 1986 by the licensee subsequent to NRC's finding); R201 and R202 near support BZ420BT at elevation 289'",
R222 above 2RHS*PT99A (These nonconformances were documented in /AIR No.
I6A80521 dated March 5, 1986 by the licensee subsequent to NRC's finding).
On March 10, 1986, following the completion of this inspection, the licensee called NRC stating that 1)
they found evidence that the impulse lines with less than
~~" per foot slopes had been identified before by the licensee and had been dispositioned based on engineering justification, and 2) transmitter 2RHS*PT99A (for R222)
had been downgraded to Category 2.
However, the supporting documents were not avai 1-able for NRC's review at the conclusion of this in-spection.
This item is unresolved pending NRC's re-view of licensee's supporting document to verify that 1) the nonconformances described above at the specific locations had been documented by the licensee before this inspection, 2) all these nonconformances had been properly dispositioned based on valid engineering justification, 3) proper documents exist showing when and why transmitter 2RHS"PT99A had been downgraded to Category 2, and 4) 2RHS"PT99A had been removed from the Master List of the Environmental gualification Program.
(50-410/86-08-05)
4.2 Inde endent Measurements The inspector performed independent measurements to verify the installation data for instrument and instrument tubing'or the instruments installation identified in paragraph 4. 1. la,b,c above, the inspector measured the slope, distance between tubing supports and the bending radii for the instrument tubing, verified the in-strument valve flow direction and the instrument mounting configuration.
4.3 Nonconformance Re ort Review The inspector reviewed a selected sample of eleven nonconformance and disposition report (NEDR's) listed below:
1.
NKDRPJC-736
"Tube routing for instrument 2RHS*FT105, for tubing R201 and R202" dated May 21, 1985 and closed August 6, 199.
N&OR ¹JC-1097 "As-built dimension deviated from R202" dated September 9,
1985.
Closed September 17, 1985.
3.
N&DR ¹14393 "Tubing routing not conformed to drawings" dated November 26, 1985.
Closed December 13, 1985.
4.
N&DR ¹14180 "Instrument not in proper location on Support" dated November 12, 1985.
Closed November 20, 1985.
5.
N&DR ¹14201 "Tubing material traceability dated November 14, 1985.
Closed November 20, 1985.
6.
N&OR ¹14033 "Tubing dimension discrepancies" dated October 30, 1985.
Closed November 5,
1985.
7.
N&DR ¹14243
"Dimension violation for K-095" dated November 16, 1985.
Closed January 9,
1986.
8.
N&OR ¹JC-903
"Damaged instrument" dated May 14, 1985.
Closed January 16, 1986.
9.
N&DR ¹14974
"Damaged dust cover" dated January ll, 1986.
Closed January 24, 1986.
N&DR ¹15089 "Incorrect Material" dated January 21, 1986.
Closed January 31, 1986.
11.
N&OR ¹15111 "Hilti bolt base plate out of tolerance" dated January 21, 1986.
These N&OR's were found to be legible, complete and properly reviewed by qualified personnel.
The records were proper ly identified, stored and can be retrieved in a reasonable time.
The reports included proper resolution and adequate justification for "accept-as-is" disposition.
Within the scope of this review, no unacceptable conditions were identified.
4.4 Recei t Ins ection Record Review The inspector selected six receipt inspection records for review to ascertain whether 1) the documents properly and uniquely identified received instruments and associated items, 2) applicable specifications (regarding size, type, material, Model No. etc.) were met or otherwise note The following receipt inspection reports were reviewed:
1.
IR No.
XSA00166 dated January 16, 1985 Date received:
December 28, 1984 Items received:
Two Rosemount Transmitters 2RHS*FT64A&B.
2.
IR No.
X4002200 dated June 13, 1984 Date received:
May 23, 1984 Items received:
22 orifice plates (flow elements)
from Permutit Company.
3.
IR No.
X3000985 dated April 18, 1983 Date received:
March 14, 1983 Items received:
Eight Rosemount transmitters 2RCS"FT6A&B; 2RCS*FT7A&B; 2RCS~FT8A&B; 2RCS*FT9A&B 4.
IR No.
X4001074 dated March 29, 1984 Date received:
March 22, 1984 Items received:
Six Rosemount transmitters 2RHS" FT14A, B&C; 2RHS*PDT18A 2SWP"FT13A&B.
5.
IR No.
X4001000 dated March 23, 1984 Date received:
March 14, 1984 Items received:
Three Rosemount transmitters 2RHS'FT86A, B & C.
6.
IR No.
M0001099 dated January 23, 1980 Date received:
January 4,
1980 Items received:
One 18" orifice assembly 2RHS*FE14A.
Within the scope of this review, no unacceptable conditions were identified.
5.0 Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, an item of noncompliance or a deviation.
Unresolved item identified during this inspection is discussed in paragraph 4. 1
~ 2 of this report.
6.0 Exit Interview An exit interview was held on March 7, 1986 with members of the licensee staff, denoted in Paragraph 1, at the conclusion of the inspection.
The inspector summarized the scope and findings of the inspection at that time.
The only written material provided to the licensee by the inspector was a
listing of requested licensee document ~1
~
J l