IR 05000423/1985013
| ML20127J295 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/30/1985 |
| From: | Anderson C, Cheung L, Dev M, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127J271 | List: |
| References | |
| 50-423-85-13, NUDOCS 8506260542 | |
| Download: ML20127J295 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No. '50-423/85-13 h
i Docket No.
50-423
License No. CPPR-113 Priority Category B
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Licensee:
Northeast Nuclear Energy Company
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Post Office Box 270
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Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Energy Station, Unit 3
Inspection At: Waterford, Connecticut Inspection Conducted: April 8-12, 1985
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Inspectors:
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A. Finkel, Ledd Reactor Inspector >
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M. Dey, Reaitor Inspector dite
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L.'Cheun Reactor Inspec date Approved by:
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.C. F. Anderson, Chief, Plant System date Section, Engineering Branch, DRS
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Inspection Summary: Inspection on April 8-12, 1985 (Report N'o. 50'423/85-13).,
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Areas Inspected:
Routine, unannounced inspection of activities pertaining to the installation of safety-related ele,ctrical and instrumentation equipment, quality control documentation, training of personnel and status' of audits *and audit findings.
The inspection involved 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> onsite by three region-based inspectors.
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Results: No violations were identified.
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8506260542 850530 I<
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PDR ADOCK 05000423
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DETAILS 1.0 Persons Contacted 1.1 Northeast Nuclear Energy Company M. Brown, Supervisor, I&C Maintenance
- F. Comstock, Quality Assurance Engineer
- K.
Gray, Jr., Staff Assistant
- R. Lefebvre, Project Staff Engineer V. Machito, Quality Assurance Engineer L. Nadeau, Assistant Project Engineer D. Robinson, I&C Engineer T. Rogers, Planner 1.2 Stone and Webster Engineering Corporation
- R. Ackley, Project Engineer
- R. Clark, Field Quality Control Inspector D. Evans, Field Quality Control Inspector R. Fricia, Field Quality Control Inspector
- R. Ackley, Project Engineer C. Jones, Field Quality Control Inspector D. Klein, Field Quality Control Inspector R. Martin, Engineer W. Mullins, Field Quality Control Inspector
- L. Nace, Project Manager
- C. Sprouse, General Superintendent Construction W. Taylor, Chief Field Quality Control Supervisor
- G. Turner, Resident Field Quality Control Manager
- W. Vos, Senior Engineer Field Quality Control i
1.3 U.S. Nuclear Regulatory Commission
- T. Rebelowski, Senior Resident Inspector
- Denotes those personnel present at exit meeting. Other managers, supervisors, craftsmen and technicians were contacted during the course of this inspection as activities interfaced their areas.
2.0 Facility Tour The inspectors observed work activities in progress, completed work and construction status in the cable spreading room, control room, battery and switchgear rooms, reactor containment and the hydrogen recombiner area.
No violations were identifie n
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3.0 Instrumentation (Cables and Terminations) Work Observation 3.1 Equipment Installation The inspector observed work performance pertaining to the installation of air-operated valves and the associated limit switches and solenoid valves in the Residual Heat Removal System, Low Pressure Safety Injection System, and High Pressure Safety Injection System, to ascertain whether the requirements of applicable specifications and procedures are met.
3.1.1 Documentation Reviewed The inspector reviewed the following documents:
a)
SWEC Drawings FSK-27-7A Revision 10, dated June 15, 1984 and FSK-27-78, Revision 11, dated November 21, 1984 " Residual Heat Removal System Flow Diagram".
b)
Pneumatic control valves 3RHS*HCV606, 607; 3RHS*FCV618, 619; all located in the RHR Heat Exchanger areas in Auxiliary Building.
c)
Safety related air operated valves 3SIL*AV88898,D; 3SIL*CV8890A; 3SIL*AV8872C; 3SIL*CV8825; 3SIH*d889A.C; 3SIH*8823 and 8824; 3SIH*CV8881; all located inside reactor containment between O' and 12' elevation.
d)
SWEC Drawing No. 12179-EM-112A-1 " Low Pressure Safety Injection P&ID", dated April 14, 1982.
e)
SWEC Specification E-350 " Electrical Installation" Revision 7, dated Novmeber 13, 1984.
f)
SWEC Nonconformance and Disposition Report No. 9433, " Air-Operated-Valves Reversed in Field" Sheets 1 through 5, dated October 22, 1984.
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SWEC cable pull tickets for:
Cable No. 3SIHNOC782 dated November 23, 1982 Cable No. 3SILBOC901 dated November 23, 1982 Cable No. 3SIHNOC901 dated November 23, 1982 Cable No. 3SIHNOC671 dated November 23, 1982 Cable No. 3SILB0C631 dated November 23, 1982 Cable No. 3SIHN0C611 dated November 23, 1982 Cable No. 3SIHN0C725 dated November 23, 1982 Cable No. 3SILBOC791 dated November 23, 1982
Cable No. 3SIHN0C903 dated November 23, 1982
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3.1.2 Installation Observation The inspector observed that each of the air-operated valves identi-
'fied in pargraph 3.1.1 above were equipped with two NAMC0 limit switches (Model EA180-31302) mounted on the valve actuator.
These limit switches appeared to be in good condition and the mountings
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3.1.3 Findings The inspector noted that two valves (3SIH*88892 and SIL*8889D) were installed incorrectly and did not conform with the P&ID.
Upon in-vestigation by the licensee, it was found that this problem had been identified previously by the licensee's FQC inspector and documented in their Nonconformance & Disposition Report (N&DR) No. 9433, dated October 22, 1984.
The licensee also identified that the electrical wiring of these valves was reversed and required re-wiring. The inspector reviewed the engineering evaluation and proposed disposi-tion of these valves and found them to be acceptable.
The inspector also noted that valve 3SIL*CV8890B was incorrectly tagged 3SIL*AV88908. Upon notification of this inconsistency the licensee initiated actions to correct the valve tagging accordingly.
3.2. Instrument Cable Installation / Raceway Installation 3.2.1 Instrument Cable Installation The NRC inspector reviewed the QA records and discussed with four licensee FQC inspectors cable pulling, cable tray supports, and cable terminations. The inspector discussed the inspection attribute and disposition of nonconformances found during work inspections, with-the FQC inspectors. The FQC inspectors were found knowledgeable of the program requirements and associated documentation. The NRC inspectors witnessed FQC inspection work for cables pulls in the Hydrogen Recombiner area (Cable No. 3SSPBPC600, 3HCSBPC501, 3HV2BPC502,3HCSBPC601).
3.2.2 Cable Pull Tension Calculation Review The inspector reviewed the basis and criteria for the cable pull tension calculations performed by the field engineers at the site.
The calculations were based on the format outlined in the SWEC Specification E-350 (Electrical Installations).
Calculations were properly reviewed and signed by a person other than the originator.
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The specification required that the maximum number of turns in one pull shall not exceed 3C0, and the effective coefficient of friction for the cable pull lubrication shall not exceed 0.5.
3.2.3 Cable Inspection Attributes SWEC FQC (electrical) department had developed an " Electrical Inspec-tion Handbook" which provided guidance to the inspector to execute attribute inspection. Based on discussions with the FQC inspectors, the inspector determined that they had sufficient training and indoctrination to use the Handbook.
3.2.4 Findings The inspection attributes for power cable installations and general cable installation are listed in Attachments 3.5 and 3.6 respectively of SWEC QAD-10.18ML. These attribute lists contain sufficient instructions to assure that the requirements of site documentation are satisfied.
However, the inspector noted that the inspection attribute related to the temperature requirement for cable pull during cold weather had been deleted from the original inspection attribute.
This item is unresolved pending NRC review of the licensee's method for identification of the cable temperature attribute for the quality control inspector and determination of any adverse impact on the installed cable because of the deletion of the attribute.
(423/85-13-01)
4.0 Quality Assurance Program 4.1 NNECo I&C Department - Post Turnover Quality Control Activities 4.1.1 Personnel Training The inspector review the site specific training and qualification of personnel'in the areas of Instrumentation and Control (I&C), electri-cal field quality control, and training of craft personnel.
The following documentation was reviewed by the inspector:
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Millstone - 3 Instrument & Control Department Training Program, IC-3403, Rev. 2
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Millstone - 3 Administrative Control Procedure (ACP) - QA 8.16, Training Certification and Identification of Qualified Inspec-tion and Testing Personnel Millstone - 3 ACP-QA2.02A, Rev. 11, Installation Inspection
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The inspector verified that NNECo I&C has 24 full time regular and 25 full time contract technicians and specialists.
Functionally, they are divided into analog, digital, and mixed analog-digital groups.
The work force, on average, represents 91s years of work experience.
The qualification and certification of I&C personnel at Millstone-3 require 6 weeks of surveillance testing, system walkdown, written and oral examinations. The regular employees undergo 36 weeks of addi-tonal training including systems overview and classroom instructions.
A grade of minimum 80% is required to qualify these tests.
NNECo I&C department has two full time Senior instructors who conduct empicyee's
- training and indoctrination, qualification, certification and impart classroom instructions.
The inspector interviewed 11 I&C personnel on a sampling basis and reviewed the documentation of their qualification and training pro-gram.
The program is overviewed by NNECo QA organization which is responsible for their qualification certification. Also, NNECo QA reviews I&C training records and procedures and conducts audits to verify effectiveness of the implementation of the program.
The in-spector determined that the qualification and training of the I&C Specialists and technicians were in compliance with the schedule of the training program.
4.1.2 Construction Turnover NNECo I&C had e t:blished procedures for the I&C personnel to perform post-turnover quality control activities, such as: I&C equipment calibration, testing, preventive and corrective maintenance and repair, post maintenance testing, functional check, surveillance, and monitoring. I&C has recently imp?emented a production maintenance management system (PMMS) to plan equipment maintenance frequency and schedule.
It provides information on equipment maintenance history, QA/QC inspection requirement, housekeeping zones, and other vital equipment data. Another potential use of PMMS is in the area of scheduling of preventive maintenance and surveillance for the I&C equipment under the electrical Equipment Environmental Qualification (EEQ) program.
The inspector reviewed 11 preventive / corrective maintenance work orders, including work orders for EEQ equipment and found that the program implementation was in accordance with the program requirements.
4.1.3 Design Modification Request The inspector also reviewed Millstone-3 ACP-QA 4.06, Engineering Evaluation Procedure used by the I&C personnel to evaluate design modification requests (DMRs), as required by Millstone 3 Startup Manual, Rev. 3.
Any nonconforming materials installed are disposi-tioned with engineering justification and approval of a minimum of
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two joint test group (JTG) members.
DMRs are instrumental in track-ing all I&C materials nonconformances in such cases, prior to fuel load. The inspector reviewed 4 DMRs (Unsat) and found that the programmatic resolution of the nonconformances was satisfactory.
4.1.4 Shelf-Life Control The inspector toured the I&C lab and examined the shelf-life program for instruments and spare parts including the storage, handling and identification of age-sensitive materials.
He noted that the shelf-life related materials are identified by a unique identification number.
Procurement of such materials is treated as controlled item and required at least 18-months prior to actual expiration date.
The expired shelf-life items are disposed, nonetheless.
No violations were identified in the above areas inspected.
4.2 Preoperational and Post-Turnover Quality Control Activities - SWEC FQC (Electrical)
4.2.1 Gocumentation Review The inspector reviewed the following documents to verify the adequacy and effectiveness of training, and qualification of SWEC FQC elec-trical inspection personnel:
SWEC Quality Assurance Program Description (QAPD) as applicable
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to Millstone-3
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SWEC Quality Assurance Directive (QAD)-2.1, (Generic Procedure)
Continuing Education System SWEC QAD-2.5, Qualification and Certification of Personnel Per-
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forming Quality Assurance Activities
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SWEC Quality Assurance Department Continuing Education Program SWEC Quality Assurance Department Training Proficiency Progress
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Records (TTPPRs)
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SWEC FQC Inspector Handbook (Typical)
4.2.2 Field Quality Control (FQC) Personnel Qualifications The inspector verified that SWEC FQC has 196 regular full time employees and 95 full time contract QC inspectors.
SWEC FQC has one full time QC inspector who coordinates qualification, training, in-doctrination, and certification of FQC inspectors. The FQC inspec-tors' training is conducted according to SWEC QADs 2.1 and 2.5 which is based on the inspector's specific trade as delineated in TPPRs. A QC inspector is certified for his/her trade after successful comple-tion of classroom instructions, self-study materials, system walk-L____
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down, plant / specific and trade specific indoctrination, and written and oral tests. On successful completion of these basic requirements the FQC inspector is given a control copy of the inspector's hand-book.
This handbook lists inspection attributes as applicable to their specific job assignment.
The inspector interviewed 15 FQC inspectors assigned to cable installation, termination, and raceway installation, on a sampling basis, to verify their qualification, training and indoctrination, experience and certification. All these individual had several years of prior involvement in the construction, operation and outage of the several nuclear plants such as, St. Lucie, Vogel, Wolf Creek, WPPSS, Midland, Vermont Yankee, Maine Yankee, Seabrook, Millstone, and others including the U.S. Navy. The FQC inspectors qualification records files were also reviewed. A typical FQC inspectors quali-fication record file contain the following:
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Certificate of Qualification - Valid for 3 years b)
Eye - Examination Certificate - Valid for 1 year c)
Resume (experience)
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Education Description e)
Records of completion of self study materials 4.2.3 Field Quality Control Training Record Review
~The inspector reviewed the attendance sheets of the following train-ing classes to verify personnel attendance and the contents of the courses:
a)
SWEC Inspection Report System, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, dates 3/12/85 & 4/3/85 b)
SWEC QA Orientation, 2h hours, date 3/12/85 & 4/2/85 c)
SWEC N&D System, lh hours, date 4/2/85 d)
SWEC Problem Reports and Deficiencies, lh hours, date 3/25/85 e)
SWEC TPPR-000-010, Oral Examination, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> date 3/20/85 f)
SWEC Review of Aluminium Conductor, date 3/14/85 g)
ASME Code and Manual, 2h hours, date 3/12/85 4.2.4 Raceway Installation Program Review The inspector reviewed the following documents to verify adequacy and effectiveness of the quality control activities in the areas of Electrical Cable and Raceway installation:
SWEC QAD-10.17 ML, Cable Termination and Connection Inspection
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Rev.0, dated June 12, 1984 SWEC QAD-10.18 ML, Raceway and Cable Installation Inspections,
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Rev. B, dated June 8, 1984 SWEC FQC Electrical Inspection Handbook, Rev.1, sections I, J, K,
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L, P, Q, R and S
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.SWEC Specification E-350, Electrical Installation Rev. 7
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SWEC Specification E-527, Rev. 3
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SWEC Interoffice Memorandum on Computer Generated Ticket Review,
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dated April 4, 1985, from C. D. Nadrella to S. Calgiuri SWEC Interoffice Memorandum on Raceway and Cable Pull Tickets, dated
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April 4, 1985, from R. Clark to G. Turner The inspector reviewed Cable Pull Ticket No. 3 MSS APC 639, Inspection Report No. 35A0152, and E&DCR FE-40926 Subject-transfer of QC inspector signature from the field generated ticket to the computer generated ticket. The above two SWEC FQC IOMs have provided inter-pretation and clarification for the transfer of signature as delin-eated in SWEC specification E-527. The E&DCR FE-40926 has been properly dispositioned. Thenceforth, the practice of the Site Engineering Group (SEG) providing FQC signature on the Cable Pull Tickets had been discontinued.
In order to make the statement more understandable and unequivocal SWEC is revising the related section of specification E-527. Nonetheless, all field generated tickets with the actual inspector signature are considered quality records and SEG maintains them as such.
The inspector also reviewed the following FQC inspection records on a sampling basis, to verify program compliance with the site procedures:
Cable Pull Tickets - Cable No. 3RHSBPC014 dated 12/17/82 3RHSBPC012 dated 1/14/83 3SSPBPC600 dated 4/9/85 3HCSBPC501 dated 4/9/85 3HVZBPC502 dated 4/9/85 3HCSBPC601 dated 4/9/85 Cable Termination - Cable No. 3SIHBPC010 dated 1/8/85 3SIHBPC011 dated 4/29/83 3RCSBPX822 dated 10/30/84 3RCSBPX824 dated 10/30/84 3CESBPC665 dated 2/5/85 Cable Tray Support
.IR No. ESA0062 for support D220-51 & 52
Inspection Report
dated 1/28/85
E4A08587 for support D130-54 & D230-55
dated 11/2/80
This item is unresolved pending NRC review of specification E-527
which is to be revised to address the subject of providing FQC
signatures on cable pull tickets..(423/85-13-02)
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5.0 Battery Room Walls (Masonry)
Id Bulletin No. 80-11, dated May 8, 1980 identified a problem with
the structural integrity of concrete masonry walls with Seismic
Category 1 piping attached to them.
The licensee was required to
identify all masonry walls in their facility which are in proximity
to or have attachments from safety-related piping or equipment such
that wall failure could affect a safety related system.
5.1 Licensee Response to IE Bulletin 80-11
In response to the NRC Bulletin 80-11, the licensee re-evaluated all
existing masonry block walls in safety-related areas at Millstone-3.
The
licensee established a program to review all masonry walls that had loads
of 100 lbs. or greater attached to them.
The inspector reviewed the licensee program for compliance to the
criteria of IE Bulletin 80-11 in the following areas:
5.1.1
Documentation
On May 5, 1982 the licensee placed a construction hold (#89) of
masonry walls and attachments in category I buildings. Prior to the
release of Hold #89 (November 19, 1982) all future masonry walls in
safety-related areas were deleted from the drawing and replaced with
reinforced concrete walls and general notes were added to Stone and
Webster (S&W) drawings 12179-EA-1E and EA-1F prohibiting attachments
to existing block walls.
5.1.2
Battery Room Wall Attachments
The licensee completed their battery room block wall analysis in May
1982.
This analysis, using mortar strength test results, found the
wall stresses within operating plant allowables without additional
stiffening and therefore structural modifications were not made by
the licensee.
5.1.2.1
The licensee authorized (via E&DCR) restricted attachments,
such as, power receptacles, switches, equipment, etc., with a maximum
weight of 50 lbs. to the battery room block walls.
The inspector
verified that the E&DCR was based on engineering calculation
- 12179-SE0-SE-5256.
Based on the referenced calculation and the
response to IE Bulletin No. 80-11, the inspector determined that the
50 lb. limit was well within the requirements of the calculations for
these walls.
No violations were identified in the above areas inspecte.
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5.2 Field Change Requests
The inspector randomly selected licensee's Engineering and Design Coor-
dination Reports (E&DCR's) and Nonconformance (N&D's) Reports for com-
pliance with site documentation.
5.2.1
Use of Category 3 Item on Safety-Related Equipment
The licensee issued E&DCR FE-22563 for the use of category 3 bus
material to be used in safety-related panels 3EG*PNL A and B and the
main electrical taps of the diesel generators. On July 5,1984 the
licensee issued an inspection report IR E4A04804 tracking the E&DCR
for the use of the bus material without category 1 documentation.
On July 25, 1984 E&DCR FE-32888 superseded FE-22563. This new E&DCR
added copper bus bars to the EGS panels and called out section 5.2 of
specification E-350.
This section of E-350 is for non-engineered,
non-category 1 purchases.
On August 31, 1984 the licensee quality assurance organization issued
a quality assurance surveillance report (PC-2858) on E&DCR FE-32888
indicating that the bus bar material lacked technical and quality.
assurance requirements for the use in class IE, Q-listed equipment.
On September 27, 1984 in response to PC-2858 engineering issued E&DCR
TE-01473 which required that samples of the bus bar material be
tested for content.
5.2.2
Material Analysis
The bus bar material was sent to the Pittsburg Testing Laboratory for
testing to IAW ASTM-B-187-83 criteria.
On February 28, 1985 the Pittsburgh Testing Laboratory report was
issued stating that the bus bar material met the ASTM acceptance
criteria in the following areas:
Electrical Resistivity Per ASTM B187 and B193, and
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Rockwell Hardness Per ASTM 8187 and E18.
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The licensee engineering personnel signed E&DCR TE-01473 stating that
the copper Bus Bar was acceptable for installation in QA Category I
equipment based on the results of the Pittsburg Test Report.
In
reviewing the test report the inspector verified that the test data
was within the requirements of the above ASTM test criteria.
No violations were identified in the above areas inspecte E
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5.3 Institute of Electrical and Electronics Engineers (IEEE)
The inspector verified that Final Safety Analysis Reports (FSAR) criteria
has been transcribed into lower tier documents for site use in the
electrical and instrumentation areas.
5.3.1
NRC Inspection Reports
NRC inspection reports in the electrical and instrumentation areas
have discussed the compliance of the licensee's documentation to the
FSAR criteria.
The latest NRC report (IE 50-423/85-08), February
4-7, 1985 addressed, for example, process control cabinet wiring and
instrumentation tubing installation.
NRC inspection report 50-423/-
85-01, January 8-10, 1985 addressed, for example, the licensee
compliance with a Construction Deficiency Report 83-00-11 pertaining
to the Main Control Board terminations.
In each of the above references the inspection criteria and the
inspection personnel were knowledgeable of the site documentation
requirements which, in turn, reflected the FSAR criteria.
Further
discussions of the licensee personnel qualifications are discussed in
paragraph 4.0 of this report.
No violations were identified in the above areas inspected.
6.0 Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, or violations.
Unresolved items identified during this inspection are discussed in
Details, in paragraph 3 and 4.
7.0 Exit Meeting
The inspector met with licensee and contractor representatives (denoted
in paragraph 1) at the conclusion of the inspection on April 12, 1985.
The inspector summarized the scope and findings of the inspection as
described in this report.
At no time during the inspection was written material provided to the
licensee by the inspectors.