IR 05000443/1983005
| ML20023B488 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/20/1983 |
| From: | Cerne A, Gallo R, Gramm R, Narrow L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20023B484 | List: |
| References | |
| 50-443-83-05, 50-443-83-5, 50-444-83-05, 50-444-83-5, IEB-82-04, IEB-82-4, IEB-83-01, IEB-83-04, IEB-83-1, IEB-83-4, NUDOCS 8305050119 | |
| Download: ML20023B488 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I 50-443/83-05 Report No.
50-444/83-05 50-443 Docket No. 50-444 CPPR-135 Category A
License No. CPPR-136 Priority
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Licensee: Public Service Company of New Hampshire
1000 Elm Street Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Units 1 and 2 Inspection at:
Seabrook, New Hampshire Inspection conducted: March 1 - April 8,1983 (lb -
H$/B Inspectors:
A.C.Cerne, Sr. Resident Inspector date signed 7 A h%
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R. A.Granun, Resident Inspector date signed W
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L.M. Narrow, Lead Reactor Engineer date signed k
Approved by:
R.M.Gallo, Chief, Projects Section 1A, dat6 signed Division of Project and Resident Programs Inspection Suninary:
Unit 1 Inspection on March 1 - April 8,1983 (Report No. 50-443/83-05)
Areas Inspected: Routine inspection by the resident inspectors and one regional inspector of work activities, procedures and records relative to system and component installation; structural steel erection; electrical cable and instrument tubing installation;and the control of field drawings for piping and supports. The inspectors also reviewed licensee action on previously identified items and bulletins and performed plant inspection-tours.
The inspection involved 154 inspector-hours, including nine off-shift hours by three NRC inspectors.
Results: No violations were identified.
Unit 2 Inspection on March 1 - April 8,1983 (Report No. 50-444/83-05)
Areas Inspected _: Routine inspection by the resident inspectors and one regional inspector of work activities, procedures and records relative to shared system 1 ista11ation,structur-al steel erection,and field drawing control for piping and supports The inspectors also reviewed licensee action on previously identified items and bulletins and perfonned plant inspection-tours. The inspection involved 36 inspector-hours including one off-shift hour, by three NRC inspectors.
Results: No violations were identified.
8305050119 830401 PDR ADOCK 05000443
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DETAILS 1.
Persons Contacted Yankee Atomic Electric Company (YAEC)
F. W. Bean, Lead Electrical QA Engineer D. L. Covill, Lead Civil QA Engineer R. E. Guillette, Sr., QA Engineer (Framingham)
J. H. Herrin, Site Manager (PSNH)
G. F. Mcdonald, Jr., QA Manager (Framingham)
J. F. Nay, Jr., Lead Mechanical QA Engineer P. Oikle, NDE Level III (Framingham)
J. A. Philbrick, Senior Project Engineer (PSNH)
S. B. Sadosky, Lead Start-up/ Test QA Engineer J. W. Singleton, Field QA Manager R. Tucker, Engineer (Framingham)
L. Walsh, Operations Manager (PSNH)
United Engineers and Constructors (UE&C)
R. H. Bryans, Site Engineering Manager J. J. Carrabba, Preventive Maintenance Supervisor P. A. Giansiracusa, Lead Engineer, Construction Design Group B. J. Huselton, Power Discipline Engineering Manager D. C. Lambert, Field Superintendent of QA J. J. Murphy, Supervisory Structural Engineer C. R. Pletcher, Electrical Start-up Supervisor T. P. Vassallo, Jr., Quality Assurance Lead Engineer Fischbach-Boulos-Manzi (FBM)
A. B. Caldwell, QC Supervisor H. P. Patel, Project Engineer R. F. Watt, Project QC Manager Perini Power Constructors (PPC)
A. J. Coviello, QC Supervisor J. J. George, Structural Steel Engineer Pittsburgh DesMoines Steel Co. (PDM)
W. A. Stiger, QA Manager Pullman-Higgins (P-H)
R. G. Davis, Field QA Manager D. J. Evans, Construction Supervisor (Unit 1)
l D. B. Hunt, QA Records Supervisor C. A. Scannell, Assistant Resident Manager l
Royal Insurance J. C. Anzivino, Authorized Nuclear Inspector Nuclear Installation Services Company (NISCO)
R. L. Schelling, Field QA Manager
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2.
Plant Inspection-Tours (Units 1 & 2)
The inspectors observed work activities in-progress, completed work and plant status in several areas of the plant during general inspections of the plant.
The inspectors examined work for any obvious defects or noncompliance with regulatory requirements or license conditions.
Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconfoming material identification, housekeeping and equipment preservation. The inspectors interviewed craft personnel, supervision, and quality inspection personnel as such personnel were available in the work areas.
During the course of the inspection, the following items were noted by the inspectors and resolved with no further questions:
-- The compatibility of two different types of HVAC duct sealant (Dow Corning 795 and Duro-Dyne S-2) was questioned where both sealants were used in combination. Subsequent issuance of a UE&C memorandum (MM11881A) clarifies the proper construction practice of duct sealant application.
-- The applicability of USNRC Regulatory Guide 1.29 position C.2, to the design of the Diesel Generator (DG) crane. rail supports (reference:
UE&C Foreign Print FP52926) was questioned. These rails are currently undergoing a seismic engineering review in accordance with the criteria for further evaluation established by UE&C Technical Procedure, TP-4.
-- Installation of a Unit 1 DG exhaust system expansion joint appeared to be in variance with the manufacturer's instructions (reference:
FP21808). Acceptable erection conditions were achieved through solicitation and use of the manufacturer's recommendations.
-- The bolting arrangement of a Grinnell variable spring pipe support was questioned relative to the governing UE&C drawing M800151S, Sheet 12.
Further evaluation of the substitute bolting arrangement determined it to be acceptable per ASME Section III, NF paragraph 4720.
-- The cracking of certain containment liner dome Tee stiffener welds was questioned. PDM Additional Work Notice No.43 had been issued to inspect all the Tee stiffeners and repair as necessary. These repairs were documented.
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-- Spray application of Pyrocrete fireproofing material on structural steel within the Unit 1 cable spreading room was observed. The protection provided installed components and cables was noted.
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During this inspection period, the Unit 1 turbine lubricating oil flushing operation comenced and continues. The inspector examined the filter bags utilized for sequential bearing system flushes and examined the set-up of the temporary flushing pump. Conduct of the operation and impact upon connection of the turbine to the turning gear were discussed with start-up engineers.
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With regard to all of the above inspection items, no violations were identified.
3.
Licensee Action on Previously Identified Items a.
Previous Inspection Findings 1)
(Closed) Violation (443/82-03-06):
Inadequate inspection of a pipe support and surface mounted electrical struts. The inspector reviewed the disposition to Pullman-Higgins nonconformance report, NCR 2209, specifying removal of the existing pipe support and rework in accordance with UE&C Engineering Change Authorization (ECA) 25/1308A.
He also reviewed the disposition to FBM NCR 064, requiring retrofit of 58 electrical strut supports where existing damaged washers shall be replaced in accordance with ECAs 03/1668A and 03/1628D.
In both cases, the responsible contractors conducted additional craft and quality control personnel retraining. Verification that the reworked items meet the new design criteria is provided by QC reinspection of the NCR dispositions and engineering control of the ECAs for retrofit activities. Corrective action appears to have adequately addressed both the hardware deficiencies and the inadequate inspection concerns. This item is closed.
2)
(Closed) Unresolved item (443/82-11-02 & 444/82-06-02):
Procedural deficiency on electrical tool calibration. The inspector reviewed interim procedure change No.1 to FBM procedure FECP-601 (Revision 4).
Calibration due dates are now controlled by marking the exact calibration expiration date on each tool and piece of measuring and test equipment (MT & E). Since MT & E records exist to verify proper past calibration for all electrical tools, the inspector has no further questions on the FBM calibration procedures. This item is closed.
b.
Construction Deficiency Reports (CDR) - 10CFR50.55(e)
1)
(Closed) CDR (443 & 444/82-00-03):
Possible binding of motor control starters supplied by Gould; also reported as a 10CFR21 Report to Region I by Gould. The inspector reviewed UE&C NCR 1404, the final disposition and closure of which documents replacement of 46 contact carriers in motor control centers (MCC) where a field inspection by a Gould representative identified insufficient spacing to preclude binding between the carrier post and the support housing. The inspector examined one such retrofitted assembly, checking for the required freedom of movement. He also discussed with start-up and QA personnel the steps taken to verify the acceptance of installed units, to include surveillance of the retrofit work and reinspection and dynamic testing of the electrical starter supply to all safety-related MCC motor loads. Additionally, Gould has taken corrective action during the manufacturing stage, by modifying the affected parts, to prevent future recurrence of this problem. This item is closed.
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2)
(Closed) CDR(443&444/82-00-05): Class IE safety-related cables traverse the tank farm area in non-seismically supported conduit.
The inspector reviewed Engineering Change Authorization (ECA)
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03/1735A and UE&C drawing F301254 to verify that the conduit carrying
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the Class 1E cables had been upgraded to safety-related (ie: seismic)
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standards. QC records were examined for exposed conduit support.
inspections in the tank fann area (eg: supportnos.10802&10803).
The inspector noted four-embedded conduit sleeves, through which
thd upgraded safety-relatdd conduit will pass,had been installed without inspection prior to concrete placement.
NCR 220 was generated, an inspection of the as-built sleeves was conducted, and the sleeves were accepted since it was detennined that they comply with design
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requirements. The inspector reviewed the conduit redesign, subsequent installation and inspection to safety-related requirements and considers this item to be closed.
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3)
(Closed)CDR(443&444/82-00-15): Non-seismic control room office i
partitions. ECA 01/40470 and UE&C drawing F102973 were examined by l
the inspector to verify that the partition had been structurally redesigned. The redesign provided tie rods and additional floor anchors to constrain the mode of failure under seismic loadings,such that collapse would occur away from safety-related components within-the control room. The inspector questioned the quality assurance requirements for the additional partition supports, particularly
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with regard to the inspection process required by UE&C Specification QAS-5 (for non-safety related items within Category I buildings).
Subsequently, ECA 01/4156A was issued to apply QAS-5 inspection to
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the partition structural steel components. This item is closed.
c.
IE Bulletins (IEB)
1)- (Closed)
IEB 82-04:
Deficiencies in primary containment electrical assemblies. The inspector reviewed Westinghouse drawings (UE&C
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FP32363) for the containment electrical penetrations, both the modular
type and the 15 kv medium voltage penetration, manufactured by the
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Westinghouse Electronics Tube Division. He confinned that Bunker
Ramo electrical penetrations are not used at Seabrook Station and verified that the Deficient Products List, published in accordance with UE&C Administrative Procedure, AP No.49, lists the Bunker Ramo assemblies, thus preventing the future procurement or utilization of such deficient components. This Bulletin is therefore not applicable to Seabrook.
2)
(Closed)
IEB 83-01: Failure of reactor trip breakers (Westinghouse l
DB-50). The inspector examined the installed Unit i reactor trip breakers (Trains A & B and bypasses) and detennined that Westinghouse DS-416 (stored energy) breakers have been procured for Seabrook Station. He reviewed the Westinghouse drawing (UE&C FP 30591)
illustrating the undervoltage trip coil and shunt trip energization i
logic and verified bi-weekly storage inspections of the installed breakers in accordance with Westinghouse NSSS Component Receiving and Storage Criteria, Volume II. Since IEB 83-04, in conjunction with IE Info Notice 83-18, discusses failures of DS-416 type breakers,
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appropriate licensee action will be tracked by that bulletin.
Consequently, IEB 83-01 is considered redundant and not applicable to Seabrook and'is therefore closed.
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4.
Preparation and Control of Field Drawings for Piping and Supports As part of a change in overall management.of the P-H contract, UE&C has assumed ~ responsibility for preparation and control of field drawings for piping and supports. This work was previously the respo.nsibility of P-H.
A number of P-H employees will continue to work on preparation of field drawings, but under UE&C supervision. UE&C field administrative procedures have been prepared for control of this work. QA procedures have been revised by both UE&C and P-H to accomodate the revised organization and work scope.
The change in overall responsibility was effective December 1,1982 and implementation of the revised engineering function was effective-February 3,1983.
The inspector discussed preparation and control of field drawings with representatives of YAEC, UE&C and P-H.
The discussion included the scope of work, engineering changes, stop work orders, training, QA and any problems during the transition. The inspector also reviewed selected UE&C administrative and QA procedures; and P-H QA procedures.
Field drawings and process sheets will be prepared by UE&C. The drawings will be reviewed and approved by UE&C and will be reviewed and accepted by P-H.
The process sheets will be added to the drawings by UE&C based on'P-H procedures and will be. reviewed and approved by P-H.
Engineering changes will be process d in the + cme manner.
The inspector examined the following. procedures:
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-- UE&C Field Administrative Construction Procedure (FACP) No.7,
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" Preparation and Control of Field Drawings - Piping Erection Isometrics"
-- UE&C FACP No.8, " Preparation' and Control of Field Drawings - Pipg Support Installation Drawings"
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-- UE&C QA Procedure 2-C, Revised 2/16/83, " Interface with Fabricators and Installers"
-- UE&C QA Procedure 4-C, Revised 3/15/83,s" Control of Field Drawings, Piping Erection Isometrics and Pipe Support Installation Drawings"
-- UE&C QA Procedure QA-3-1 dated 3/8/82, " Surveillance of Site Power Engineering" The inspector was informed that FACP No.7 and No.8 had been reviewed during a series of meetings between representatives of YAEC, UE&C, and P-H.
This represents joint agreement on workable procedures for conduct of field engineering under the new program. All personnel involved in this program have received training based on these procedures.
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The inspector examined the schedule for performance of surveillance inspections.
FACP No.7 and No.8 are scheduled for surveillance bi-weekly. Three surveilla ye inspections of FACP No.7 and two of FACP No.8 have been performed to date.
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The inspector reviewed surveillance Report No.095 and No.099 and Enyineering Notification Report (ENR) No.26 which identified unsatisfactory conditions and established datas for,a response.
The inspector was informed that a UE&C audit had been planned for March,1983 but had been cancelled because of an ASME review at that time. The next audit was scheduled for March,1984 and the schedule did not provide a new date for the cancelled audit. An audit of this program by YAEC is scheduled for April 1983.
No major problems were identified in implementing this program. The number of personnel assigned to this werk has increased approximately 100% and a further increase is' planned. A strong effort is being made to reduce the backlog of stop work orders (SWO). These are primarily based on design revisions in progress. Such revisions are now required to be evaluated in order to determine the necessity for issuing an SW0. The inspector discussed the need for establishing criteria for this determination and was informed that an instruction memorandum would be issued for this purpose.
The inspector reviewed P-H Corrective Action Report (CAR) No.69 and the UE&C response thereto, identifying document control problems associated with the. interface of the new UE&C construction c'esign group with the existing P-H Field Document Control section. As of April 1,1983, the UE&C response to CAR 69 and their recommended program of new interface controls for P-H document usage had been accepted by P-H management. The inspector noted the involvement of YAEC QA personnel, as well as the upper field management of both the construction manager and Pullman-Higgins, in arriving at an acceptable solution to an interface problem a'ssociated with the revised organizations and. responsibilities.
No violations were identified.
5.
Piping and Pipe Supports (Unit 1)
The inspector, on a random basis, observed in-process welding on both piping and pipe supports. He checked the existence of engineering isometrics, weld process sheets, and weld rod requisition slips at each work area. The configuration and status of examined welds were verified to be consistent with the available documentation. The following welds were evaluated by the inspector:
- Piping CBS-1206-02 F0207 CS-365-01 F0103 CC-709-01 F0105-MS-4000-04 F0404 CC-818-01 F0102 MS-4002 F0803 CS-318-02 F0206.
Supports M/S 8126-SG-21 840-SG-19
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No violations were identified, t
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6.
Structural Steel Installation (Units 1 & 2)
a.
The inspector reviewed the following procedures which pertain to the erection of structural steel:
-- UE&C Specification 12-1 for Structural Steel
-- Perini (PPC) QCP 10.21 Structural Steel Inspection
--1QCP 10.23 Welding Inspection
-- QAP 12.0 Calibration Control
-- FCCP-153 Erection of Structural Steel
-- FCCP-155 Installing and Tightening of High Strength Bolts Using Tension Set Fastening System
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-- FCCP-156 General Weld Procedures for Structural Steel The procedures were evaluated for adequacy relative to the Seabrook Station FSAR, the AISC Manual of Steel Construction, the AWS D1.1 Structural Welding Code, and ANSI Standard N45.2.5.
No violations were identified; however, one item remains unresolved.
Section 5.4 of ANSI N45.2.5, as endorsed by NRC Regulatory Guide 1.94 and committed to in Section 1.8 of the Seabrook FSAR, requires that inspection torque wrenches be calibrated weekly, as a minimum. However, PPC QAP 12.0 specifies a 45 day calibration interval for the torque wrenches utilized for structural steel inspection. This conflict in calibration practice is being evaluated by UE&C (reference: YAEC Blue Sheet 52) from standpoints addressing both the specific calibration issue and the generic question as to whether other RG 1.94 commitments have been correctly incorporated into affected specifications and procedures.
This item remains open pending resolution of the Blue Sheet 52 inquiry and other Blue Sheet concerns discussed in paragraph b. below.
b.
The inspector examined the structural steel at elevation 75 of the cooling tower and evaluated the installed conditions with regard to UE&C and Cives drawings and one design change, ECA 01/3189B.
Several beams were inspected for connection details, welding and the general configuration of the structural members. The inspector reviewed erection and inspection records to include PPC weld data cards, structural steel reports, material test reports, QC checklists, and receipt inspection documents. No violations were identified.
The inspector also examined some structural steel framework supporting electrical cable trays within the Unit 1 Containment at azimuth 320',
elevation 0.
He noted certain bolted connections to be in variance with the standards for structural joints using high-strength (A325) bolts,
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as specified by the AISC Manual of Steel Construction. While the existing
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configuration resulted from an engineering disposition to PPC NCR 1439, the inspector questioned the adequacy of the long-slotted hole connections
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from both workmanship and design load direction considerations. Subsequently the licensee requested that the A/E technically justify the disposition toNCR1439(reference: YAEC Blue Sheet 51).
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l Pending NRC review of the responses to Blue Sheet 51 for adequate design considerations and Blue Sheet 52, discussed in paragraph a. above, for
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compliance to standard comitments, the questions raised with regard to structural steel installation and inspection remain unresolved (443&444/83-05-01).
7.
Component and System Installation a.
ComponentInstallation(Unit 1)
The inspector observed the installation of the following NSSS components:
-- Reactor Pressure Vessel (RPV) Internals
-- Reactor Coolant Pump Motor 1C Quality Control inspection by the installation contractor (NISCO) and QA surveillance by YAEC were verified. NISCO interface with Westinghouse representatives and use of applicable Westinghouse installation documents
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and drawings were also confirmed.
In evaluating the installation processes and controls, the following documents were reviewed:
-- NISCO Procedures:
ES-4031-PSCNH-01 ES-4031-PSCNH-03 ES-4031-PSCNH-011 WPS-10.1.3
-- UE&C Drawings F805052 and foreign print FP54673
-- Westinghouse Instruction Book for the Reactor Coolant Pump, FP54502 While no violations were identified, the inspector noted that NISCO welding procedure, WPS 10.1.3, required clarification of the qualified thickness range for welding of materials with notch toughness design specifications. The NISCO Field 0A Manager agreed to include notation of the thickness limits in a revision to the WPS and YAEC QA engineers agreed to follow-up this change. No prior welding had been accomplished to the subject WPS and the inspector had no further questions on this issue.
b.
System Installation (Units 1 & 2)
The inspector reviewed the design bases for the habitability sy: Lc for the control room complex, focusing on the control room make-up cir M)
ventilation system. He examined the in-place Unit 1 piping, HVAC ductwork, and components (valves, fans, dampers and limit switches)
and traced, via drawings, the connection of Unit 2 CBA piping to the Unit I system. Design changes on the FN 27 A & B fan installations were evaluated (ie: ECAs 06/0834C & 74/1653B); the damper purchase order (225-03) and piping specification (248-1) design criteria were reviewed for consistency with the safety-related application of the system; and certain P-H piping installation records were examined for correct erection standards and QC coverage.
No violations were identified; however the inspector raised the following questions:
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(1) Since CBA make-up air to tinit 1 from the remote west intake is supplied thru piping which is routed in the Unit 2 diesel generator building,~what measures will be established to secure this supply of air, particularly with regard to the flanged pipe connections at elevation 51, while Unit 2 construction activities are in progress?
(2)SinceANSIB31.1pipingstandardshavebeenspecifiedforthe procurement and installation of the CBA piping, are quality assurance requirements invoked for such nonsafety-related piping consistent with the ultimate safety-related application of the CBA make-up air system?
(3) What are the final installation details for CBA fans FN-27 A & B, since the current governing design document (ECA 06/0834C) specifies temporary fan installation for the purpose of start-up testing?
Pending licensee response to these questions, the adequacy of the existing CBA make-up system is currently unresolved (443 & 444/83-05-02).
Since certain components in the CBA system had been turned-over to start-up jurisdiction, the inspector had the opportunity to evaluate turnover controls with regard to Seabrook Test Program Instruction, TPI-01.
He examined Boundary Identification Packages (BIPs) CBA-M-9A and CBA-M-9B for the appropriate contractor construction completion turnover approvals and noted that the required rework of fans FN-27 A & B was listed on the Start-up Test Department " Incomplete Items List" (reference: TPI-33). The turned-over items had been appropriately tagged and the status and control of these items were discussed with QA personnel. The inspector identified no procedural violations or control problems in the turn-over of the subject CBA components.
8.
Electrical Cable and Instrument Tubing Installation (Unit 1)
a.
The inspector examined in-process installation and records for the in-core instrument t:bing runs being erected from the seal table to the tubing penetrations on the bottom of the Reactor Pressure Vessel. Johnson Controls' (JCI) Installation / Fabrication (I/F) Packages were reviewed on a sample basis to confirm process controls and QC inspections consistent with JCI procedures. The tubing socket welds were evaluated with regard to ASME Section III, NB welding (and NDE requirements; the inspector noting that the weld procedure in use FICP-WP-808) was qualified for manual, gas tungsten arc welding of the subject P8 material socket welds and that socket weld fit-up gap was specified and inspected.
An ASTM material substitution for the tube couplings, noted on JCI drawing 1-INC-T-12B, was checked for both authorization and impact upon the welding and weld procedure qualification to the variables delineated in ASME Section IX. The inspector noted that final go/no-go internal diameter configuration inspections of the as-welded tubing runs were specified and had been accomplished.
No violations were identified.
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b.
The inspector reviewed various FBM cable installation and termination practices and procedures for criterie consistent with FSAR, Regulatory Guide and IEEE commitments and confomance to UE&C specifications and drawing notes and details.
Included in the review were FBM construction procedures, FECP-504 and 505; quality control procedures, QCP-504 and 505; and UE&C Wiring Systems Notes and Typical Details, M300230. The following field conditions and activities were randomly inspected and evaluated with regard to procedural requirements:
-- Various cables (codes AG1P, AD6P, AG6P) were checked for traceability.
Prior to pulling, such traceability is provided by reel number; after cable pulling, it is uniquely provided by cable date code and footage markers.
-- The termination of safety-related train A cable (FCl-FF7) to the Protection System Safeguards Test, Train B Cabinet was verified on the computerized cable schedule (CASP).
-- Service Water Pump House cable tray 81X1RA was verified to have received QC inspection prior to installation of safety-related cable in accordance with QCP-504.
-- The relocation of 125V DC electrical distribution panels (E93 & E94)
had been properly authorized by Site Approved Change (SAC)
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43/0154A and correctly implemented in accordance with the details of UE&C drawing M300228, Sheet C-22.
-- The installation of new Motor Control Centers ( MCC E515 and 615)
was detailed on UE&C drawing F310431 (Revision 18) and structural support work was proceeding in accordance with ECA 59/4257A.
-- The utilizathn of one grade (nuclear-qualified) of Raychem heat shrink tubing for site-wide cable application was confirmed.
With regard to the above inspection items, no violations were identified; however, certain issues remain unresolved as discussed below.
FBM procedure QCP-505 requires the inspection of cables for cuts or damage to the cable insulation, to include documentation of same on an NCR for further evaluation. However, where the cable jacket is cut away for termination purposes, field practice has been to seal the cut end of the cable jacket with approved electrical tape. The inspector questioned whether this sealing practice, which is not specified in the governing construction procedure (FECP-505), could in fact mask a section of damaged insulation, since QC inspection is not required prior to tap application. The licensee has requested that FBM engineering personnel evaluate and address this concern.
Additionally, the inspector questioned the decision not to apply the QA and inspection provisions of FBM procedure QCP-504 to the cable-pulling activities of nonsafety, associated cable, particularly where such cable runs in trays carrying safety-related cable. An analysis of FSAR commitments to Regulatory Guides 1.30 and 1.75 (Revision 2) and IEEE Standards 336-1971 and 384-1974, coupled with the statement in the licensee
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response to an NRR Request for Additional Information (RAI 430.149)
indicating the intent that associated circuits be " installed" to meet these comitments, led to a licensee decision on March 16,1983 to issue e Stop Work Order (FBM-SWO-002) on all safety-related and associated cable pulling within the Nuclear Island boundary. Upon the issuance of interim procedure changes to the affected FBM procedures (IPC 8 to FECP-504, IPC 2 to FECP-202, and IPC 3 to QCP 504), the stop work order was rescinded and future associated cable pulls were QA covered and inspected in the same manner that safety-related cable pulls had been and are handled.
With regard to those associated cables already installed in the nuclear island, the licensee initiated a Task Force Investigation to determine if the associated cables installed prior to March 16,1983 meet the intent of IEEE 1336-1971 for'insta'11ation,' inspection and testing req'uirements.
On April 11,1983 the results of the Task Force investigation were published in a Report (Group # EEG SB 37/83), which was reviewed by the NRC inspector.
Qualitative evidence was provided to substantiate a conclusion that the associated circuits in question do meet the intent of IEEE 336-1971.
However, to provide further quantitative evidence of quality workmanship and installation, the task force has recommended the initiation of a quality control inspection program to randomly sample associated cable installations in accordance with established QC verification criteria.
This sample inspection will be documented in retrofit reports and will include provisions to increase sample sizes if problems are identified.
The inspector informed licensee personnel that until the results of the associated cable retrofit inspection program are obtained, this issue remains open.
Pending NRC review of those results and also pending review of the evaluation of the practice to tape cut cable jackets at tenninations, discussed earlier, these electrical items remain unresolved.
(443/83-05-03).
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 6, 7b, and 8.
10. Management Meetings At periodic intervals during the course of this inspection, meetings were held with senior plant management to discuss the scope and findings of this inspection.
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