IR 05000410/1986009

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Insp Rept 50-410/86-09 on 860222-0418.Violation Noted: Improper Design Control for Routing Class 1E Electrical Cables
ML17055B676
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 05/08/1986
From: Linville J, Meyer G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17055B670 List:
References
50-410-86-09, 50-410-86-9, NUDOCS 8605190279
Download: ML17055B676 (46)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

Docket No.

License No.

Licensee:

86-09 50-410 CPPR-112 Category B

Niagara Mohawk Power Corporation 300 Erie Boulevard Syracuse, New York 12302 Faci 1 ity:

Location:

Dates:

Inspectors:

Nine Mile Point, Unit 2 Scriba, New York February 22, 1986 to April 18, 1986 R.A.

Gramm, Senior Resident Inspector S.D.

Hudson, Senior Resident Inspector G.W. Meyer, Project Engineer J.R. Stair; Reactor Engineer Reviewed by:

Approved by:

Mey, Pro Engineer Linville, ief, Reactor Projects Sec on 2C, DRP a

e Ins ection Summar

Ins ection on Februar

1986 to A ril 18 1986 Re ort No. 50-410/86-09 d:

work activities, procedures and records relative to IE Bulletins, structural integrity test, electrical raceway installation, preoperational test procedure review, preoperational test witnessing, and Three Mile Island action plan open items.

The inspectors also reviewed licensee action on previously identified items and performed plant inspection tours.

The inspection involved 313 hours0.00362 days <br />0.0869 hours <br />5.175265e-4 weeks <br />1.190965e-4 months <br /> by the inspectors.

Results:

One violation was identified:

Improper design control for routing Class IE electrical cables (paragraph 6).

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DETAILS

~Summa'nresolved items included setpoint control for Technical Specification items, applicability of Air Balance Inc. fire damper problems, and applicability of Clow Corp. butterfly valve problems.

Thirty (30) items of the thirty-four (34) previous inspection findings reviewed were closed.

Also, two (2).IE Bulletins out of the four (4) Bulletins reviewed were closed.

The procedure and preparations for the containment Structural Integrity Test were found acceptable.

A violation was found concerning unacceptable design control for installation of Class IE electrical cables in the non Category I Reactor Building stair tower.

Another unresolved item was identified involving apparent oversights in the Standby Gas Treatment System preoperational test procedure.

Parts of six (6) tests were witnessed with no resulting problems.

Forty-two (42) Three Mile Island (TMI) Action Plan open items were entered into the Open Item System.

Review of the status of the inspection program showed preopera-tional test procedure reviews and test witnessing to be largely completed, while the the majority of test result reviews, operational readiness in-spections, and open item closeouts remain to be complete.

Project Or anizations:

Niagara Mohawk Power Corporation (NMPC)

Stone and Webster Engineering Corporation (SWEC)

General Electric Company (GE)

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 require-ments 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:

The inspector reviewed NMPC letter NMP2L-0675 dated March 31, 1986 from C.V. Mangan to E.G.

Adensam.

The licensee committed that the Diesel Generator ambient air temperature alarm setpoint would be 70 degrees.

The inspector had previously verified the setpoint at 65 degrees.

The licensee reviewed design documents LSK-22-7A and ESK-10ANS-635 and ascertained the setpoint had not been raised.

This item is unresolved pending licensee verification of how Technical Specification changes are translated into design documents.

(86-09-43)

~I1 I ~

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The inspector reviewed'RC Vendor Branch inspection report 99901005/85-01 regarding Air Balance Incorporated fire dampers.

The report described extensive problems with the implementation of the Air Balance Incorporated quality assurance program.

The report additionally described the failure of the fire dampers to close under certain flow conditions.

Preliminary information indicated that Air Balance dampers had been provided to Nine Mile Point Unit 2.

The inspector asked the licensee to confirm whether Air Balance fire dampers are utilized onsite.

(86-09-44)

The inspector reviewed a

CFR 21 report filed by Philadelphia Electric Company on March 13, 1986 in regards to Clow Corporation butterfly valves.

The report described galvanic corrosion between the carbon bearings and stainless steel shaft of the valves.

The corrosion caused excessive stroke times for the valves.

The inspector noted the valve failure was documented by a

INPO Nuclear Network notification on January 27, 1986.

The inspector asked the licensee to confirm whether Clow Corporation butterfly valves are utilized onsite.

(86-09-45)

No violations were identified.

3.

Licensee Action on Previousl Identified Items (Closed)

CONSTRUCTION DEFICIENCY (83-00-18):

Vortex formation during ECCS pump operation.

The inspector reviewed the following documents:

SWEC calculation HGE-199, "Calculation of Depth of Submergence Inlet Dimensions 5 Swirl Effects for ECCS Suction Inlets".

SWEC calculation A10. 1-E-59, "Determination of Potential Air Ingestion in ECCS Suction Lines during LOCA/MSLB".

SWEC calculation HGE-200, "Vortexing, Air Ingestion and Required Submergence Depth at the RCIC Suction Inlets".

SWEC calculation ES-078,

"Post LOCA Minimum Suppression Pool Level".

SWEC calculation HCE-198, "Determination of % Air Void Fraction

& Vortex Types at ECCS Suction Strainer Inlets".

Engineering and Design Coordination Report (E8DCR)

P12955.

SWEC engineering determined the minimum submergence depths of the pump suction lines that would result in excessive air ingestion and inlet swirl.

The suction lines were redesigned to provide sufficient submergence in accordance with NUREG-0897.

NMPC gA verified the completion of installation activities on the modified suction lines.

This item is close r

!

b.

(Closed)

CONSTRUCTION DEFICIENCY (83-00-19):

Main Steam Isolation Valve actuator bearings.

The inspector 'reviewed the following documents:

SWEC file STRS 5.360-5013B,

"Seismic Test MSIV Actuator".

Crosby Test Report 4259, "Interim Test Report for Series 600 Actuator Latching Mechanism Life Cycle Proof Test".

SWEC Report of a Problem MEC-092.

Nonconformance and Disposition Reports 13455, 14366, and 14060.

SWEC Inspection Reports MSA33069, XSA02786, and M5A33120.

Engineering and Design Coordination Report F13024 Work Control Reports 6975, 6973, 6974, 6976, 6977, 6978, 6979, and 6980.

Crosby Valve and Gage Co. letter dated February 15, 1985 (Part 21 report for EFCO-600 Series Actuator)

Equipment Qualification Maintenance Program Data Sheets P303 DAD Rev.

1 and P303 DAC Rev.

1.

The roller bearings were redesigned to accommodate the actual loads.

The modified actuator was qualified by Crosby Valve and Gage.

The inspector reviewed the site maintenance program and verified the recommended adjustment and replacement frequencies for the actuator mechanism.

The modified roller bearings were installed onsite.

This item is closed.

c.

(Open)

CONSTRUCTION DEFICIENCY (83-00-23):

Quality Assurance classi-fication of the Reactor Building roof.

The inspector reviewed the following documents:

Nonformance and Disposition 6240.

SWEC Inspection Reports S3031755, S3031756, S3031757, S3031758, S3031759, S3031760, S3032178, S3032973.

SWEC upgraded the Reactor Building roof to a

QA Category I structure.

SWEC engineering reviewed the QC Inspection program for the QA Cate-gory III fabrication, the roof deck material certifications, the H.H. Robertson Company QA program, the welder qualification test record, the roof deck material physical and chemical test results, the strength values for stainless steel fasteners, and the panel sealant characteristics.

The as fabricated structure was found by SWEC "accept-as-is" pending conduct of the secondary containment negative pressure test.

This item remains open pending satisfactory completion of preoperational test POT-20 P'

d.

(Closed)

VIOLATION (83-06-03):

FSAR information regarding the diesel generator load sequencing.

The inspector reviewed the following documents:

FSAR section 7.3.1

~ 1.1.4.

FSAR Tables 8.3-1 and 8.3-2.

Logic Diagram LSK-24-9.4C "Standby Diesel Generator Load Sequence".

GE letter NMP2-2668 dated April 19, 1979.

The above documents defined consistent load sequencing for the standby diesel generators.

The licensee has instituted an FSAR verification program that was discussed within NRC Inspection Report 85-26.

This item is closed.

e.

(Open)

UNRESOLVED ITEM (83-16-07):

Control Rod Drive (CRD) restraint beam bolting.

The inspector examined the CRD restraint beam high strength bolting.

Several long slotted hole connections were not provided with plate washers in accordance with AISC.

This item remains open pending licensee review of FSAR commitments regarding A325 bolting.

f.

(Closed)

FOLLOWUP ITEM (83-18-46):

Undersized welds on the Enter-prise support system.

The inspector reviewed the following documents:

NMPC gA Surveillance Report W-84-703.

NMPC Corrective Action Request 84.0043

'CI Nonconformance Reports NMP-083, NMP-454, NMP-458, NMP-466, NMP-468, NMP-482 R/1, NMP-633, NMP-486.

RCI Calculation SA-1661-ART-63.

RCI Drawings NMP-015,

"CRDHS Pipe SPRT SYS Inside Containment

degree Side".

RCI performed a reinspection of the Enterprise welds and repaired the identified undersized welds.

Subsequently, a verification performed by the licensee identified further undersized welds that were not corrected by RCI.

RCI conducted personnel training on weld inspec-tion techniques and then performed a reinspection of all accessible Enterprise welds.

Repairs were performed as necessary.

The inspector reviewed the engineering calculation that supported an "accept-as-is" disposition for several welds.

The inspector examined several welds on the Enterprise support and all were found in conformance with design requirements.

This item is close ;

fI N,

g.

(Closed)

VIOLATION (83-18-75):

Inspection records did not document appropriate design drawing revision or applicable design change documents.

The inspector reviewed the following documents:

NMPC Surveillance Reports E-84-493, E-84-634, E-84-545, M-84-611, M-84-623, M-84-574, and M85-843.

SWEC letter 9M2F-14617, 9MF-180, and 9MF-311.

NMPC Corrective Action Requests 84.0058, and 84.0161.

Field Quality Control Instruction (QCI) 6.01 Rev.

G, "Tracking of EKDCR/ACNs for FQC Closure" RCI letter RCI-NMP2F-116 and RCI-QA/QC 850277.

NMPC QAP 10.30 Rev.

4, "Quality Assurance Department Inspection Activities".

SWEC Quality Assurance Inspection Plans (QAIPs) N20S204BFA001, N2HSBOLTFA001 and N20S207PFA003.

RCI QAI-10-1, "Quality Control Inspection"

~

JCI QAS-1101, "Visual Weld Inspection" QAS-1005, "Fabrication and Installation Procedure (Category 1)".

ITT FQC-4.2-14-19,

"Inspection of Installed Pipe Supports".

FQC-4.1-4-8,

"Visual Examination of Welds/Base Material".

The licensee amended site inspection procedures to require that documents utilized to perform QC inspections are referenced on the associated inspection records.

The inspector reviewed the QC pro-cedures and verified the current programs require the inspection reports to reference the applicable design documents.

Reactor Controls, Inc. (RCI) utilized MIL-STD-105D to select

Engineering Change Notices (ECN) for reverification.

The RCI re-verification identified that the ECN installation and inspection requirements were satisfactorily implemented.

SWEC performed an investigation of design change documents, Engi-neering and Design Coordination Reports (E&DCRs) and Advance Change Notices (ACNs), associated with safety related work.

One hundred and twelve (112) design changes affecting SWEC installations were rein-spected by Field Quality Control (FQC).

In all cases the design changes had been previously closed without specific QC verification because the documents were incorporated into design drawings.

The rei nspections were sati sfactory except for items that had not yet been presented for QC inspection.

One hundred and forty seven (147)

design changes affected Johnson Controls Inc. (JCI) work activitie ~

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SWEC FgC verified that the associated JCI work packages and inspec-tion records had ensured prior verification of the design changes by JCI gC.

Four design changes affected ITT-Grinnell (ITT) work activities.

SWEC FgC verified that the documents had been previously incorporated in the planner packages and had been verified by ITT gC.

The reverification of a total of two hundred and sixty-three (263)

safety related deisign changes has provided a satisfactory level of confidence that previously completed work was satisfactorily inspected by gC organizations even though the original inspection records did not reference the appropriate design documents.

This item is closed.

h.

(Closed)

VIOLATION (83-18-76):

Design changes not incorporated into associated construction drawings.

Based upon the licensee corrective actions implemented in response to items 83-18-77 and 83-18-87 dis-cussed in sections 3i and 3j of this report, respectively, this item is closed.

i.

(Closed)

VIOLATION (83-18-77):

Design changes not identified at the work location.

The inspector reviewed the following documents:

NMPC Surveillance Reports E-84-493 and E-84-630.

SWEC letters 9M2F-14,620 and 9M2F-16,512.

SWEC Interoffice Memorandum C3/12177/100/5YWPC dated March 19, 1984.

Project Guideline (PG)

100,

"NMP2 Document Control Program".

The licensee instituted the following corrective actions to upgrade the document control program:

The outstanding posted design changes that existed for the one hundred and forty five ( 145) drawings were incorporated in accordance with project requirements.

The number of site drawing issue stations was consolidated.

Survei llances were performed to ensure all engineering documents were available at the drawing issue stations.

A computerized posting system was implemented to replace the manual posting system.

The practice of only posting design changes against a lead drawing for certain types of drawings was eliminated, and the changes were posted against the applicable drawing W c's Po

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Project requirements for timely approval or incorporation of Advance Change Notices were implemented.

Based upon the licensee actions, this item is closed.

j.

(Closed)

VIOLATION (83-18-87):

Incorporation of Advance Change Notices (ACNs) into design drawings.

The inspector reviewed the following documents:

NMPC letter NMP2L-0624.

NMPC Surveillance Reports M-84-497 and E-84-630.

Project Procedure (PP)

77 Rev.

10,

"Advance Change Notices (ACN)"

PP16, Engineering and Design Coordination Reports (E&DCRs)".

Project Guideline (PG)

22 Rev.

2, "Documentation of BOP As-Built Status".

Project Requirement (PR)

10 Rev.

3,

"Advance Change Notice (ACN)

Program Requirements".

SWEC Site Engineering Group (SEG)

Memo 157.

Current ACN approval status report.

The project procedures were amended to require that ACN approval occur within the specified time from the ACN issuance date.

The rate of ACN approval was accelerated such that only two hundred and fifteen (215) Category 1 ACNs have not yet been approved.

The licensee has committed to approve Category 1 ACNs prior to Fuel Load.

The current policy is that ACN initiation requires the approval of the Superintendent of Site Engineering.

The inspector reviewed the open ACN report and verified that ACNs are closed in a timely manner by engineering.

The inspector was informed that the current backlog of unapproved ACNs is scheduled to be eliminated within two weeks.

Based upon the extensive engineering efforts that reduced the popu-lation of ACNs and the revised procedure, and policies that assure timely closure and low ACN initiation rates, this item is closed.

(Closed)

FOLLOWUP ITEM (83-18-97):

Adequacy of gC inspection conduct.

The licensee performed reinspection of the following plant components:

pipe supports, instrument tubing supports, HVAC duct

. supports, electrical equipment, Reactor Controls, Inc. installations, electrical cables, raceway cable terminations, mechanical equipment, structural steel, concrete expansion anchors, concrete surfaces and nuclear coatings.

The identified deficiencies were assessed by licensee engineering and quality assurance, and appropriate correc-tive actions were implemented.

Inspection Reports 85-26 and 85-21 document the licensee hardware verification efforts.

This item is close ll r

(Closed)

FOLLOWUP ITEM (83-18-98):

Adequacy of QC inspection attributes.

The licensee corrective actions for associated open items 83-18-05, 83-18-20, 83-18-25, 83-18-27, 83-18-58, 84-19-04, 85-03-01, and 85-27-03 were reviewed and closed in NRC Inspection Reports 85-17, 85-25, 85-13, 85-25, 85-25, 85-25, 85-24 and 86-01, respectively.

The appropriate QC inspection procedures were modified and reinspections were performed as required.

NMPC QA performed surveillances of inspection procedures and associated changes.

This item is closed.

(Closed)

FOLLOWUP ITEM (83-18-100): Electrical QC inspections

~

The licensee corrective actions for associated items 83-18-02, 83-18-05, 83-18-07, 83-18-15 and 83-18-93 were reviewed and closed in NRC Inspection Reports 85-12, 85-17, 85-17 84-19 and 85-12, respectively.

The SWEC inspection program was modified to reflect that deferred installation of separation barriers would be tracked with an "L" code.

The inspection records for previously accepted raceways were amended as necessary to reflect the actual barrier installation status.

Several installation specifications were amended to prohibit the protrusion of support members into the cable tray cross-sectional area.

Installed raceways were reinspected to assure that permanent IDs were appropriately installed.

The SWEC inspection program was modified to require permanent ID installation prior to QC acceptance of raceways or cables.

The SWEC inspection program was modified to require that partially pulled cables received enhanced QC inspection.

The control of PGCC separation was increased through revised inspec-tions and as-built verifications.

NMPC QA has maintained surveillance of electrical installation and inspection activities.

This item is closed.

(Closed)

FOLLOWUP ITEM (83-18-102):

Control of SWEC Inspection Reports.

The licensee corrective actions for associated open items 83-18-10 and 83-18-66 have been reviewed and closed in NRC Inspection Reports 85-10 and 85-27, respectively.

SWEC Type C Inspection Reports were added to the QA trending program, and the long outstanding Inspection Reports were closed by SWEC.

This item is closed.

(Closed)

FOLLOWUP ITEM (83-18-103):

Control of inspection of deferred work.

The licensee corrective actions for associated items 83-18-18, 83-18-02, 83-18-07, 83-18-13 were reviewed and closed in Inspection Reports 85-17, 85-12, 85-17 and 85-12, respectively.

The SWEC inspection procedures for deferred installation of cable IDs, raceway IDs, electrical separation barriers, and Kellum Grips were modified to properly document the deferred work.

This item is closed.

(Closed)

FOLLOWUP ITEM (83-18-105):

Instal 1 ation and inspection of bolting material.

The licensee corrective actions for associated open items 83-18-20, 83-18-21, 83-18-22, 83-18-60, 83-18-61 and 83-18-62 have been previously reviewed and closed in NRC Inspection Reports 85-25, 85-27, 85-19, 85-13, 85-25 and 85-13.

Reinspections were performed by the licensee on both mechanical and electrical

'I

h 1 ll

equipment to verify the use of proper bolting material.

The seismic qualification reports were reviewed by the licensee in relationship to the as-built conditions to verify consistency of bolting material.

The installed bolting hardware on the battery racks and motor control centers was found acceptable by SWEC engineering.

The unmarked bolts on the Control Rod Drive restraint beam were replaced.

The inspector has previously examined nine installed mechanical components to assure the use of proper bolting material.

This item is closed.

(Closed)

FOLLOWUP ITEM (83-18-109):

Technical justification for accept-as-is engineering dispositions and nonconforming item description.

The licensee corrective actions for associated open items 83-18-17 and 83-18-88 have been reviewed and closed in NRC Inspection Reports 85-10 and 85-44, respectively.

Inspection Report 85-03 documented the satisfactory review of one hundred and twenty Nonconformance and Disposition Reports.

This item is closed.

(Closed)

FOLLOWUP ITEM (83-18-111):

Handling of Type C Inspection Reports (IRs) and documentation of nonconforming conditions on Engineering and Design Coordination Reports (EKDCRs).

Licensee corrective actions for associated open items 83-18-88, 83-18-89, 83-18-10 and 83-18-66 have been reviewed and closed in NRC Inspec-tion Reports 85-44, 85-44, 85-10 and 85-27, respectively.,

The Type C Inspection Reports (IRs) were added to the QA trending program.

Long outstanding Type C IRs were closed by SWEC.

Site engineering personnel were re-trained on proper nonconformance documentation requirements.

The Reactor Controls Incorporated (RCI) nonconformance program was enhanced.

This item is closed.

(Closed)

CONSTRUCTION DEFICIENCY (84-00-26):

Corrosion of the internal surfaces of the Main Steam Isolation Valves (MSIVs).

The inspector reviewed the following documents:

Local Leak Rate test results for valves 2MSS"HYV6A, 6B, 6C, 6D, 7A, 7B, 7C and 7D.

Nonconformance Disposition reports 10524, 10523, 10510, 10488, 10277, 10276, 10419 and 10963.

E&DCRs C91012B, C91247 and C91393B.

Technical Specification sections 3/4.4.7, 3/4.6. 1.2 and 3/4.6. 1.

FSAR section 5.4.5 and Table 6.2-60.

Licensing Document Change Notice 1333.

Licensee examination of the MSIVs had identified corrosion in the area of the spool seats.

Each MSIV was machined to remove valve body material around the affected area.

Corrosion resistant Inconel 625 overlay was deposited by the GTAW process.

The overlay welds were

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machined and inspected by liquid penetrant methods.

The MSIVs were subsequently hydrostatically tested.

The inspector verified that the average local leak rates were less than the

SCFH acceptance criteria.

In process machining, welding and inspection activities on the MSIV repairs were witnessed by NRC inspectors as documented within Inspection Reports 84-18 and 84-19.

This item is closed.

t.

(Closed)

CONSTRUCTION DEFICIENCY (84-00-33):

Condensate accumulation in Reactor Core Isolation Cooling (RCIC) steam supply line.

The inspector reviewed the following documents:

SWEC Inspection Reports PGA13456 and P5A15107.

SWEC letter 9M2-17120.

GE letter dated July 27, 1984 from C.G.

Lewis to R. E. Miller.

SWEC ASME Control Drawing DP-376D.

ITT-Grinnell isometric 57-10.

The steam supply line was redesigned to include a

1 inch diameter drain line to preclude condensate accumulation.

A 1 inch bypass line was also installed to minimize the length of unheated steam supply line.

The inspector examined the installed steam supply line modifications.

This item is closed.

u.

(Closed)

CONSTRUCTION DEFICIENCY (84-00-43):

Bonney Forge sockolets manufactured from unqualified stock material.

The inspector reviewed the following documents:

SWEC Problem Report PR-gA-8.

Nonconformance and Disposition Reports 8147, 12958 and 13639.

ASME Interpretations 111-1-83-173 and 111-1-83-146.

SWEC Inspection Reports X5A02968, XSA02971, X6A00072 and X4001951

~

The licensee returned one hundred and two sockolets to Guyon Alloys.

The licensee received sufficient documentation from the vendor to determine the acceptability of the remaining nine sockolets.

SWEC Procurement guality Assurance and the gA departments of thirty eight (38)

ASME suppliers determined that no other suspect Bonney Forge material had been utilized onsite.

This item is closed.

v.

(Closed)

CONSTRUCTION DEFICIENCY (84-00-53):

Undersized Multifunc-tion Support welds.

The inspector reviewed the following documents:

'k VI I'

RCI drawings NMP-008 Revision 5 and NMP-017 Sheets 1 and 3.

RCI calculations SA-4030-ART-81 and SA-4030-ART-43.

RCI Engineering Change Notices01-093 and 01-102.

RCI Nonconformance Reports NMP-186, NMP-187, NMP-212, and NMP 213.

RCI Surveillance Inspection Report Jan 85007.

NMPC Corrective Action Request 84.0174.

NMPC Surveillance Reports W-84-1175 and W-85-014.

The five undersized shop fabricated welds were found acceptable by RCI engineering.

The five other undersized welds on the Group 1.supports were reworked to the design requirements.

The RCI inspectors were retrained on weld measurements, inspection requirements, and drawing interpretation.

RCI engineering issued reduced minimum fillet weld size requirements for the Multifunction Support.

Two hundred and thirty Multifunction Support welds were reinspected.

The minimum weld size requirements were satisfactorily achieved for the installed welds.

The inspector sampled fillet welds in the Group 4, 5, 6, 8, 9,

10, ll and 12 portions of the Multifunction Supports and all examined welds met the engineering requirements.

This item is closed.

w.

(Closed)

CONSTRUCTION DEFICIENCY (84-00-56):

Over-pressurization of a

Low Pressure Core Spray (LPCS) check valve.

The inspector reviewed the following documents:

SWEC Engineering Change Notices (ECN) CSL-025, CSL-020 and RHS-047.

E&DCR Z32271F.

ASME Form NR-1 for valve 2CSL*V9.

ASME Form NIS-2 for valve 2CSL*V9.

The installed valve was hydrostatically tested at. 900 psi to support rerating the valve at 254 lbs. interpolated pressure class.

The valve data sheet and flow diagram were revised accordingly.

The inspector reviewed the ASME Section XI reports for the rerating of the valve.

Based upon the demonstrated acceptability of the installed valve with respect to the system pressure, this item is close C I'

(Open)

CONSTRUCTION DEFICIENCY (85-00-02):

Containment liner zinc primer.

The inspector reviewed Licensing Document Change Notice 1696.

The improperly cured zinc primer was identified as DBA quali-fied based upon qualification tests performed with properly cured zinc primer.

The inspector asked the licensee to review the proposed FSAR change with respect to actual plant conditions.

This item remains open.

(Closed)

CONSTRUCTION DEFICIENCY (85-00-04):

Main Steam Isolation Valve actuator bearing.

This item is a duplicate of Construction Deficiency 83-00-19 that was reviewed and closed in section 3.b of this report.

This item is closed.

(Closed)

CONSTRUCTION DEFICIENCY (85-00-30):

Seismic clearance between primary containment and structural steel framing.

The inspector reviewed the following documents:

Nonconformance and Disposition 14015.

SWEC Inspection Reports S6A60257 and S6A60256.

SWEC engineering issued directions to remove portions of the framing steel to provide sufficient clearance from the primary containment liner.

The inspector verified the completion of the modifications to the framing steel.

The inspector discussed the total plant clearance'alkdown program with cognizant SWEC engineering personnel.

This item is closed.

aa.

(Closed)

VIOLATION (85-03-03):

Failure to establish and implement preventive maintenance for safety related components.

The inspector reviewed the licensee's response to the violation, NMPC letter NMP2L0422 dated May 30, 1985, and determined that it adequately addressed the required corrective actions.

Stone and Webster Inspec-tion Report-Type C no.

MSS 03016 documented that the Preventive Maintenance Work Order Card for the HPCS diesel generator has been corrected to specify the required inspections.

A licensee Interoffice Correspondence dated May 29, 1985 documented the review of 50 other Preventive Maintenance Work Order Cards by SWEC Field (}uality Control.

No other errors were identified.

This item is closed.

bb.

(Closed)

UNRESOLVED (85-13-06):

Control Rod Drive installation measurements.

The inspector reviewed the following documents:

Nonconformance and Disposition Report RC-131.

GE Field Deviation and Disposition Reports (FDDRs) KG1-0421, 0369 Rev.

1, 0421 and 595.

Reactor Controls, Inc. (RCI) Surveillance Reports June 85-85 and June 85-117 fII

RCI procedure NMQA-12-1, Rev.

1, "Control of Measuring and Test Equi pment".

The RCI QA procedure was revised to address the control of measuring and test equipment (M&TE) provided by other organizations, The control rod measuring tool length was reverified to assure that it was within tolerances.

RCI investigated the calibration of other GE supplied M&TE.

This item is closed.

cc.

(Closed)

UNRESOLVED ITEM (85-13-04):

Leak rate testing of Main Steam Isolation Valves (MSIVs).

The inspector reviewed NMPC Inservice Testing program relief request GVRR-1.

The MSIV leak rate test will be performed in accordance with 10 CFR 50 Appendix J in lieu of ASME Section XI for Category A valves.

The responsibility for approval of the relief request is with the office of Nuclear Reactor Regulation.

On the basis of the proposed leak rate testing methodology, this item is closed.

dd.

(Closed)

FOLLOWUP ITEM (85-19-03):

Review of NMPC QA/QC program.

The inspector reviewed the following documents:

NMPC Surveillance Report 85-10646.

NMPC letter 9MSTQA85-549.

QA Procedure 10.30, "Quality Assurance Department Inspection".

QA Instruction 10.30-03,

"Supplementary Instructions for Per-forming Inspection Activities at NMP2 Nuclear Station During the Startup

& Test Phase.

The QA procedures were revised to require that the QC inspectors annotate the inspection report with the appropriate document that defines the accept/reject criteria for the inspections NMPC QA performed a review of 1936 Quality Control Inspection Reports (QCIRs) to verify that the appropriate design document was referenced on the QCIR.

The current NMPC Startup QA program was additionally reviewed with respect to the QA concerns identified during the NRC Construction Appraisal Team inspection.

This item is closed.

ee.

(Closed)

FOLLOWUP ITEM (85-19-04):

Post hydrostatic test liquid penetrant examination of RPV welds.

The inspector reviewed the following documents:

E&DCR C03282.

GE Field Deviation Disposition Request (FDDR) KG1-033 e'

Nuclear Energy Services (NES) ISI Sketch 228.

NES examination records RPV-KB32 and RPV-KC32.

GE installation specification 22A7409 was amended to require the liquid penetrant examinations of only the jet pump instrumentation penetration welds and the RPV safe-end welds.

The inspector was informed that all fifty two (52)

RPV nozzle to safe-end welds and two (2) jet pump instrumentation penetration seal-to-vessel nozzle welds have been satisfactorily liquid penetrant examined.

This item is closed.

ff.

(Closed)

UNRESOLVED (85-25-02):

Conduct of piping system as-built examinations.

The inspector reviewed the following documents:

RCI procedure ABWD-2, "Recirculation System Walkdown Procedure".

RCI NCR NMP-405.

NMPC gA Surveillance Report, M85-00919 RCI drawing SA-4017.

Project Procedure PP93, Rev.

3, "Category 1 Pipe Stress and Supports Final Reconciliation".

Licensing Document Change Notice 1690.

RCI engineering evaluated the dimensional discrepancy identified during the as-built walkdown for drawing SA4017 and found no adverse impact upon the piping analysis.

The RCI scope of work was amended to include the as-built walkdown of the GE designed recirculation piping.

The inspector was informed that NMPC gA had verified that the RCI walkdown personnel were appropriately trained.

This item is closed.

gg.

(Closed)

INSPECTION FOLLOWUP ITEM (85-27-01):

Licensee to establish procedures to evaluate the impact of fires on permanent plant equip-ment.

The inspector reviewed Construction Site Instruction, CSI 1.43, CSI 1.43, "Reporting and Replacing Damaged Permanent Plant Equipment and Parts",

Revision 4, which now requires an inspection of the affected equipment by the Site Engineering Group (SEG)

and Field guality Control to document any apparent or suspected damage.

The SEG will disposition all identified items.

The inspector also reviewed an Interoffice Correspondence from H. Pierre to R. Hyslop dated December 31, 1985 which summarized the review of 117 past Fire Reports.

Two pieces of equipment were damaged and had been desig-nated for repair or rewor J A

lp

>14 I

I l

I'I I,

hh.

(Open)

UNRESOLVED (85-25-03):

Diesel generator testing.

The inspector reviewed the proposed licensee surveillance testing that should be performed subsequent to accomplishment of the reliability testing.

Pending NRR review of the proposed licensee approach, this item remains open.

ii.

(Closed)

UNRESOLVED (85-30-01):

Documentation of flushing performance.

The inspector has previously reviewed flushing results for selected safety related piping systems and has interviewed some engineers responsible for flushing.

The test engineers stated that the flushes were performed to achieve the required system velocity.

The inspector has reviewed the associated test results and verified the existence of quantitative data from which the velocity can be derived.

The inspector reviewed test procedure MF.GENE.001 Rev.

6,

"General Flushing Method" which was revised to require documentation of the monitored test parameter to verify that required flush velocity was achieved.

This item is closed.

jj.

(Closed)

UNRESOLVED (85-31-01):

Design margin for large bore pipe supports.

The inspector reviewed SWEC calculation 517.45.05-NZ(C)-121 Rev.

2, "Relaxation of Fillet Weld Size Inspection Criteria".

SWEC expanded the sample to include two hundred (200) supports comprised of nine hundred and twenty five (925) welds.

The welds exhibited design margins between four and ninety nine percent.

The bu'i lt-in design margin supports the weld length and size tolerance criteria.

This item is closed.

kk.

(Closed)

VIOLATION (85-36-01):

Electrical equipment bolting.

The inspector reviewed the following documents:

Nonconformance and Disposition Report 14,428.

SWEC IRs E6440467 and E6A40382.

SWEC Procurement Quality Assurance letters dated February 7, 1986.

NMPC QA Surveillance Report SR-86-10244.

Electro-Mechanics Drawing 44101-B and 42488.

GE Drawing 142D8581,

"Reactor Protection Limit Switch Mounting".

Within Panel 405, four slots were enlarged, and the four bolts in question were replaced with 1/2 inch bolts.

SWEC QC verified the remainder of the vendor bolting hardware was satisfactory within panel 2CES*PNL405.

The NMPC Startup organization verified that the

"other twelve Electro-Mechanics pieces of equipment were satisfactorily installed.

The inspector examined a limit switch installation sup-plied by Electro-Mechanics and verified the acceptability of the bolting hardware.

This item is close '4

'I

4 ~

Licensee Action on IE Bulletins and Circulars The inspector reviewed licensee records related to the IE Bulletins and Circulars identified below to verify that: the IE Bulletins and Circulars were received and reviewed for applicability; a written response was provided if required; and the corrective action taken was adequate.

The following IE Bulletins and Ci rculars were reviewed:

IE Circular 80-16, Operational Deficiencies in Rosemount Model 510 DU Trip Units and Model 1152 Pressure Transmitters.

The inspector requested that the licensee provide copies of the following documents:

GE Field Disposition Instruction TYAM and TYBR.

GE Field Deviation and Disposition Request KG1-3348.

GE PWA 3648KG Rev.

1 and 1B.

SWEC N&D 12134.

The licensee was additionally requested to provide evidence that Rosemount had reworked two trip units prior to delivery to the site.

This item remains open.

IE Bulletin 73-4, Defective Bergen Patterson hydraulic shock absorbers.

Only mechanical shock absorbers are utilized at Nine Mile Point Unit 2.

This item is closed.

IE Bulletin 80-07, BWR Jet Pump assembly failure.

The inspector examined the following documents:

GE Field Disposition Instruction ( FDI) 26-31263.

GE Service Information Letter 330.

GE letter NMP2-3410.

NMPC Inservice Inspection Program.

The jet pump beam bolt preload was reduced from 30,000 to 25,000 pounds in accordance with GE instructions.

The licensee has scheduled visual examinations of the jet pump assemblies at periodic intervals.'he preload reduction in conjunction with the fact that the NMPZ stress levels in the beam are below the level in the BWR 3 design should result in increased time to possible crack initiation.

This item is closed.

IE Bulletin 80-16, Potential Misapplication of Rosemount Inc. Models 1151 and 1152 Pressure Transmitters with Either "A" or "D" Output Codes.

The licensee was asked to provide the following documents:

GE FDI TYEF.

E&DCR F02057.

GE PWA 3648KG Rev.

1 and 1B.

This item remains open.

5.

Structural Inte rit Test The inspector reviewed the following documents that pertain to the con-tainment Structural Integrity Test (SIT):

Regulatory Guide 1. 18, "Structural Acceptance Tests for Concrete Primary Reactor Containments".

FSAR Section 3.8.1.7.

FSAR Table 1.8-1.

PSAR Section 13.6.3.38.

Test Procedure MS-201-SIT, "Structural Integrity Test".

SWEC Specification S401C,

"Structural Acceptance Test for Concrete Primary Reactor Containment".

Engineering and Design Coordination Reports (E&DCRs) C93634, C93679A, C93971.

Nonconformance and Disposition Reports 10739 and 11012.

NMPC letter dated February 10, 1976 from G.K.

Rhode to J.F. Stolz (NRR).

SWEC Quality Assurance Inspection Plan N20-S401CFA001.

Brewer Engineering Lab Report 772, "Procedure for Strain Gage and Sister Bar Installation".

NMPC Quality Assurance Checklist.

SQA-S-001-84.

SWEC Inspection Reports S7017480, S0016195, S1013006, S0015367, S0015368, S0015369, S0015370, S7017504, S0015365, S0015366, S7017482, S7017484, S6A60820, S6A60786, S6A60787, S6A60790, S6A60791, S6A60792, S6A60788, and S6A60789.

The'inspector examined the exterior surfaces of primary containment that were prepared for crack mapping.

One quadrant around the personnel hatch was prepared in lieu of the symetrical equipment hatch.

Other crack mapping locations were examined at other elevations.

The inspector

V

1

examined the Direct Current Displacement Transducers (DCDRs) that were set to measure radial and tangential displacements around the personnel hatch'he inspector reviewed the locations where strain gages were affixed to primary containment reinforcing bar s.

The inspector noted that str ain gages had not been installed at elevations 302 ft. and 322 ft.

The licensee had previously generated NED 11012 that accepted the condition based upon the fact that sufficient data could be obtained from the remaining gages to determine the containment response.

The inspector reviewed SWEC guality Control Inspection Reports for the installation of the embedded strain gages.

The inspector interviewed Teledyne test personnel during the SIT pres-surization test.

The data gathering and data reduction equipment was examined.

The inspector reviewed calibration and certificates of conformance records for the various instruments.

The inspector observed the crack mapping at the 30 psig plateau.

The measured parameters for the 10 and 20 psig levels were reviewed by the inspector.

The inspector reviewed the test procedure and SWEC specification and verified that the containment pressurization and depressurization were properly specified; that a one hour hold at each pressure plateau was required before starting crack mapping; that environmental conditions were monitored before and during the test; that a special drywell floor test would be performed at 25 psig; and that displacements and strains would be measured throughout the test cycles.

No violations were identified.

Electrical Racewa Installation The inspector identified two Class IE rigid conduits, 2CX164GA and 2CX192YA, which had been installed within the Reactor Building exterior stair tower.

The stair tower is not a Category I structure and therefore is susceptable to postulated seismic, wind or missile damage.

The Nine Mile Point

FSAR section 8.3. 1. 1 states that all Class IE equipment is located within Category I structures.

The inspector reviewed IEEE 308 that additionally specifies that Class IE equipment shall be capable of performing its function during all design basis events.

The failure to properly route the Class IE conduits to provide protection from potential design basis event hazards is a violation of 10 CFR 50, Appendix B, Criterion III. (86-09-46)

The inspector was subsequently provided with SWEC Report of a Problem dated 4/17/86.

SWEC investigation found that 5 conduits, 2 junction boxes and 2 safety related tubing runs were inappropriately located in the stair tower.

The raceways provide power for heat tracing of the two tubing runs that supply HVAC air samples to the associated radiation monitors.

Prep erational Test Procedure Review

t

The inspector reviewed the following preoperational test procedures:

N2-POT-201,

"Primary Containment Integrated Leak Rate Test".

N2-POT-61-2,

"Standby Gas Treatment"

~

The procedures were reviewed in preparation for test witnessing for tech-nical and administrative adequacy, and for verification that the planned testing would satisfy regulatory guidance and licensee commitments.

The procedures were reviewed to verify proper licensee review and approval, correct format, test objectives, prerequisites, initial conditions, test data recording requirements, technical adequacy and system restorati on.

The inspector identified the following questions to the licensee relative to the Standby Gas Treatment system preoperational test procedure:

The system auto initiation for low reactor level and high drywell pressure was not included.

FSAR section 6.5. 1.2 that identified the system capability of 3500 cfm flow within 25 seconds was not verified.

The above concerns are unresolved pending licensee review of other test procedures that may incorporate the items of concern (86-09-47).

No violations were identified.

8.

Preo erational Test Witnessin The inspector witnessed portions of Preoperational Tests:

N2-POT-201, Primary Containment Integrated Leak Rate Test.

N2-POT-100A-l, Division I Diesel Generator.

N2-POT-100A-2, Division II Diesel Generator.

N2-POT-100B, HPCS Diesel Generator.

N2-POT-97, Reactor Protection.

N2-POT-31, Residual Heat Removal.

and verified that the test was conducted in accordance with the approved procedure, test equipment was calibrated, temporary test signals or blocks were adequately controlled, and test exceptions were properly documented.

NMPC guality Assurance (gA) personnel provided independent overview of the system tests'he testing was properly conducted, and the inspector had no questions.

No violations were identifie I II P'

r n,

II t

Three Mile Island Action Plan 0 en Items As a result of the Three Mile Island (TMI) plant accident, generic reactor enhancements were developed by the NRC.

NUREG-0737 documents the specific action requirements.

The following TMI issues are required to be reviewed and closed by Region I prior to Fuel Load:

Task No.

Descri tion 0 en Item No.

ISA.1.1/1 I.A. 1. 1/3 I.A.1.2 I.A.1.3.1 I.A.1.3.2A I.A.2.1.4 I.B.1.2 I.C.1.1 I.C.2 I.C.3 I.C.4 I.C.5 I.C.6 I.C.7 II.B.4 II.D.3 II.E.4.1/2 II.E.4.1/3 II.F.2/4 II.K.1.5 II.K.1.10 II.K.1.22 II.K.1.23 II.K.3. 15 II.K.3.18 II.K.3.16 II.K.3.22 A/B II.K.3.24 II.K.3.25 A/B II.K.3.27 II.K.3.28 III.A.1.2.1A III.A.1.2.1B II.B.3 II.F.1.1 Shift Technical Advisor Shift Technical Advisor Shift Supervisor Responsibilities Shift Manning Overtime Shift Manning-Min. Crew Immediate Upgrade of RO & SRO Training Evaluation of Organization and Management Short Term Accident Analysis Shift Relief and Turnover Procedures Shift Supervisor Responsibilities Control Room Access Procedures for Operating Experience Feedback Independent Verification NSS Vendor Review of Low Power Test Procedures Training for Mitigating Core Damage Relief and Safety Valve Indication Dedicated Hydrogen Penetrations Dedicated Hydrogen Penetrations Inadequate Core Cooling Instruments IE Bulletins - ESF Valves IE Bulletins Operability IE Bulletins IE Bulletins RV Level HPCI and RCIC Isolation ADS Actuation Relief Valve Challenges RCIC Suction HPCI/RCIC Space Cooling Power on Pump Seals Common Ref.

Level Qualification of ADS Accumulators Upgrade TSC and EOF Upgrade OSC Post Accident Sampling Accident Mon. Procedure 86-09-01 86-09-02 86-09-03 86-09-04 86-09-05 86-09-06 86-09-07 86-09-08 86-09-09 86-09-10 86-09-11 86-09-12 86-09-13 86-09-14 86-09-15 86-09-16 86-09-17 86-09-18 86-09-19 86-09-20 86-09-21 86-09-22 86-09-23 86-09-24 86-09-25 86-09-26 86-09-27 86-09-28 86-09-29 86-09-30 86-09-31 86-09-32 86-09-33 86-,09-34 86-09-35

II.F.1.2 II.F.1.3 II.F.1.4 II.F.1.5 II.F.1.6 II. K.3. 13 III.D.3.3/14 Accident Mon. Iodine

& Noble Gas Accident Mon. Hi Range Accident Mon. Cont.

Pressure Accident Mon. Cont.

Level Accident Mon. Cont.

Hydrogen HPCI

& RCIC Initiation Level Inplant Rad. Monitoring 86-09-36 86-09-37 86-09-38 86-09-39 86-09-40 86-09-41 86-09-42 The licensee has been previously informed of the necessity for Region I to close the above listed items.

Ins ection Pro ram Status The Construction Inspection Program (MC 2512) is approximately 95 percent complete.

The approximate Preoperational Test Program (MC 2513) inspection completion status is as follows:

Area Ins ection

%

Com lete Procedure Review Mandatory Primal 100

Test Witness Mandatory Primal

25 Results Review Mandatory Primal The approximate status of operational readiness inspection is as follows:

Area Ins ection

% Com lete Operations Staffing &

Procedures Tech Spec Review QA Maintenance Fire Protection Fuel Receipt Surveillance Rad. Controls Rad.

Waste Security Emergency Planning

75

5

100

35

40

iW'I

Additional inspections will be performed in each area to verify readiness for fuel load.

The approximate NRC open item status is listed below.

Backlogged items have been presented for closure but have not yet been reviewed by NRC Region I.

Area Total Number

~f0 NRC Backlogged Items Construction Deficiencies Violations Unresolved/

Followup Items Bulletins TMI Items SER Verifications

83 26/56%

8/61%

30/36%

3/75%

'0/95%

0/0%

Total 192 11.

Mana ement Meetin 107/56%

At periodic intervals during the 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 discus-sions held with licensee representatives on April 18, 1986, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction Oi