ML17054A017
| ML17054A017 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/25/1983 |
| From: | Anderson C, Plisco L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17054A014 | List: |
| References | |
| 50-410-83-06, 50-410-83-6, NUDOCS 8308240468 | |
| Download: ML17054A017 (20) | |
See also: IR 05000410/1983006
Text
50XICE ~U
1 1983
AS OF
REGION I HAS NOT OBTAINEDPROPRIETARY
CLEARANCE IN ACCORDANCE WITH 10 CFR 2. 790o
U. S.
NUCLEAR REGULATORY COMMISSION
Region I
'eport
No. 50-410/83-06
Docket No. 50-410
License
No.
CPPR-112
PHority
Category
A
Licensee:
Nia ara
Mohawk Power Cor oration
300 Erie Boulevard
West
S racuse.
13202
Facility Name:
Nine Mile Point Station
Unit 2
Inspection At:
Scriba
New York and Cher
Hil'1
New Jer'se
Inspection
Conducted:
Ma
16 - June
1
1983
Inspectors:
.
R. Plisco,
Reactor Engineer
/
d te signed
date
signed
Approved By:
/
C. J.
ers,
Chief, Plant Systems
Section,
Engineering
Programs
Branch
%j
iQ
date
signed
Ins ection
Summar
Ins ection
on
Ma
16 " June
1
1983
Re ort No. 50-410/83-06
Areas Ins ected:
Routine,
unannounced
inspection of elect7 ical components
and
systems,
observation of work and work activities,
review of quality records
and quality assurance
procedures,
review of design verification/interface
procedures
and implementation,
and comparison of as-built plant to
FSAR commit-
ments.
The inspection
involved 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> onsite
and
18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> at Stone
and
Webster Engineering Corporation,
Cherry Hill, New Jersey
by one
NRC region
based
inspector
and one supervisor.
/
Results:
One violation was identified ( Inadequate
review of design
document).
D
DETAILS
1.0
. Persons
Contacted
"W.
- <<J
<<C.
<<<<J
<<J
L.
T.
4<<F
C
F.
"A.
<<y
G.
Baker,
Lead Construction Engineer guality Liaison
Bunyan,
Lead Electrical Engineer
Fischer,
Construction Engineer
Haug,
Compliance
and Verification
Janas,
Lead Electrical Engineer - qA
Jodway,
Associate
gC Technician
Kolleski, Jr., Construction Engineer
McDonnell, gA Resident
Millian, Lead Compliance Engineer
Osypiewski,
Lead gA Engineer
Smith,
Lead Construction Engineer
Ward, Assistant
Manager - Project, Engineering
Weakley, Construction Liaison
Wilkins, gC Inspector
Stone
and Webster. En ineerin
Co
oration
S
C
S
<<<<R
<<J
D.
- M
<<<<A
p.
B.
K.
<<<<J
<<<<p
<<<<G
- F
- M
<<<<R
<<A.
- L
<<<<K
C.
Agarwal, Principal Licensing Engineer
Allen, Principal Nuclear Engineer
Chamberlain,
Assistant Engineering
Manager
Crocker, Assistant Project Engineer
Crowe, Assistant Superintendent
of FgC
Das, Electrical Engineer
Gallagher,
Licensing Engineer
Gibson,
Senior
FgC Engineer
Gillman, gA Department Representative
Gwal, Lead Electrical Engineer
Heft, Construction Supervisor
Huggon,
gC Engineer
Khanna,
Supervisor Electrical
Engineer ing
Lord, Manager,
Engineering Assurance
Maturse, Principal Control Engineer
Nolan, Principal Electrical Engineer
Novar, Preventive
Maintenance
Manager
Oleson, Assistant Superintendent
Engineering
Ott, Assistant Division Manager Electrical Division
Pierre,
Principal Engineer
Pinney,
Lead Licensing Engineer
Rovetti, Supervising Engineer
Shea,
Superintendent
of Engineering
Thompson,
Superintendent
of FqC
Varadarajan,
Assistant. Project Engineer
Zappile, Project Engineer
I
3
"R. Schulz,
Senior Resident Inspector
"denotes
those present at exit meeting at Nine Mile Point Unit 2,
May 20,
1983
~denotes
those present at exit meeting at
SWEC, Cherry Hill, New Jersey,
May 26,
1983
2.0
Plant Tour
The inspector
observed
work activities in progress,
completed work and
construction status during a general
inspection of the electrical
con-
struction activities in various areas of the site.
Work items were
examined for obvious defects
and for violations with regulatory requirements
and licensee
commitments.
The presence of quality control inspectors
was
observed in various locations throughout the site.
Craft and supervisory
personnel
encountered
in work areas
were interviewed.
No violations were identified.
3.0
Emer en
Diesel Generators
3.1
Recei t I'ns ection and Material Certification
The following documents
were reviewed:
Quality Assurance
Inspection
Plan (QAIP) No.
N20QAD77FA001,
Revision
OA, Change 2, dated
September
10, 1982,
Receiving
Inspection - General.
Quality Assurance
Inspection Report (QAIR) No.
E100818,
Standby
Diesel Generator
Systems - Engine 2-101.
QAIR No.
E100820,
Standby Diesel Generator
Systems - Engine
2-103.
Material Receiving Reports
(MRR) No. 81-2398,
No. 81-1627,
No.
81-0807,
No. 81-0710.
Stone
and Webster Engineering Corporation
(SWEC) Specification
No.
NMP2-E081A for Standby Diesel Generator
Systems,
including
Addendum 5 dated October 5, 1979.
Discrepancies
were noted in two Quality Assurance
Inspection
Reports
concerning the emergency diesel'enerators.
Although the diesels
were receipt inspected
on the
same day, using the
same revision of
the inspection plan, different inspection attributes
were assigned
by the two inspectors.
Also, the QAIR for 2EGS"EG3 (Division II)
indicated that the Electrical Insulation Test was not applicable,
although
a receipt megger
was required
by site procedures.
The QAIR
for 2EGS*EGI (Division I) indicated that the insulation test results
were satisfactory.
The gAIP requires that the inspector witness the
resistance
testing.
Mhen questioned
by the inspector,
the licensee
cou1d not explain the reason or cause of the discrepancy,
excepttttat
during this time period a contractor
had been conducting all megger
tests,
and may not have had
a
gC witness.
The licensee
searched
the
equipment megger records
and produced
documentation of megger tests
performed
on March 5, 1981 for 2EGS*EG1 and April 27,
1981 for
2EGS*EG3.
Both initial megger tests
were completed satisfactorily,
and subsequent
tests
also have been satisfactory
and periodically
witnessed. by gC.
Upon review of further documentation,
the inspector
verified that the minimum inspection attributes
had been
completed.
The inspector
had no further questions.
I
The receipt megger test sheets
reviewed for
2EGS~EGl indicated that
the megger test that was required. one week after the space
heaters
were energized
was conducted
on March 12, 1981.
The same data sheet
and other related
documents
indicate that the heaters
were not
energized until March 13, 1981.
When questioned
by the inspector,
the licensee
could not determine the reason for this apparent failure
to follow procedures.
Prior to the conclusion of the inspection,
the
licensee
issued
a Nonconformance
and Disposition Report
No. 4783,
on
May 24, 1983, which identified this deficiency as
a nonconformance.
The periodic megger checks
performed after the space
heaters
were
energized
were satisfactory.
'his
item is unresolved
pending review of the licensees
corrective
action (50-410/83-06-01).
The receipt documentation for the diesel
generators
indicate that
the /AIR's are still open due to incomplete documentation.
Engineer-
ing and Design Coordination Report
(EEDCR) No. P40310
was issued
on
January 5, 1981 in order to get permission to ship the diesel
gener-
ators from the contractor without all of the seismic tests
and
equipment qualification reports
approved.
The specification,
NMP2-
E031A,- requires that the shop inspector verify that all seismic tests
or calculation reports
and equipment qualification reports
are
approved
by the engineers
before the equipment is released
for
shipment.
The waiver of this requirement
was approved
under
the
condition that the final approval of the reports would be verified by
Field guality Control
(FqC) at the time of pre-installation inspec-
tion utilizing field inspection plan N2-E061A-097.
(See Section 3.3
concerning qualification Testing)
The inspector
had no further questions.
3.2
~St
C t
1
The following documents
were reviewed:
Specification
NMP2-E03IA for Standby Diesel Generator
Systems,
including Addendum 5, dated October 5, 1979.
I
Specification
NMP2-SM01, Storage
and Maintenance
During Storage
of Permanent
Plant Equipment,
Revision 9, dated February 3,
1983.
Cooper Energy Services
(CES) Engineering Standard
SC-54-1N,
Initial/Annual Jobsite
Inspection of Sentry Engine/Generator
Sets,
Revision 0.
CES Service Representative
Report,
dated January
6,
1982.
CES Engineering Standard
SC-54N, Jobsite Storage of Sentry
Engine/Generator
Sets.
guality Standard
(gS) 15.1,
Nonconformance
and Disposition
Report, Revision A, Change 1, dated
December 26, l979.
guality Assurance
Program,
Section 15, Nonconforming Materials,
Parts or Components,
Revision D, dated
September
30,
1982.
Purchase
Order NMP2-FP0-13850,
dated
Decembe~
21,
1981 (For a
diesel
generator initial inspection per
CES Procedure
SC-54-1N
paragraph 3).
gAIP N200SM01FA001, Storage
and Maintenance
During Storage for
Permanent
Plant Equipment,
Revision
OE,
Change
00, dated
May
12,
1983.
gAIP NZOOSM01FA002, Storage
and Maintenance
During Storage of
Permanent
Plant Equipment,
Revision
OB, Change 2, dated
November 10,
1982.
Specification
NMP2-SM01, Storage
and Maintenance
During Storage of
Permanent
Plant Equipment, states
in Section
NMP2-E031A that at one
year intervals,
arrangements
are to be made with Cooper Energy
Services
(CES) to conduct
an onsite equipment inspection for the
diesel generators.
'Purchase
Order NMP2-FPO-13850
requested
the
initial inspection.
On January
6, 1982,
as
documented
by a
Service Representative's
Report,
an inspection of the diesel
was
'onducted.
The representative
noted seven deficiencies
on the two
diesels.
These were brought to the attention of the licensee
by a
written report,
and also licensee
representatives
accompanied
the
service representatives.
Nonconformance
and Disposition Report (N88)
No. 4104 was issued
on December 7,
1982 to identify three of the
seven items.
Two other items were documented
on
MRR 81"2571.
The
remaining two items were not documented.
When questioned
by the
inspector,
the licensee stated that these
two items, both concerning
oil. leaks,
would be corrected
by the vendor
upon installation.
Documentation could not be provided to indicate
how these
items were
to be tracked to ensure they were corrected.
gAP Section
15 states
that nonconforming
and unsatisfactory
items shall
be controlled to
prevent their inadvertent
use or installation.
While physical
segregation
and marking are preferred,
other means of identification
(e.g.
marking, tagging, etc.) are acceptable
when physical
segrega-
tion is impracticable.
The diesel
generators
were neither segregated
nor:identified as nonconforming in reference to
N&D No. 4104.
Prior
to the completion of the inspection,
on Hay 24, l983, the licensee
initiated NM No. 4783 which identified the two remaining items from
the diesel
inspection
as unresolved.
The licensee
informed the
inspector that the
N&D tags were hung on the diesel
generators prior
,to the conclusion of the inspection.
The inspector
had
no further questions.
3.3
ualification Testin
The following documents
were reviewed:
Final Safety Analysis Report (FSAR) Section 8.3.
Engineering
and Design Coordination Report
(E&DCR) No.
P40310.
Specification
NMP2-E031A, Standby Diesel Generator
Systems,
including Addendum
5 dated October 5, l979.
gualification Plan
No. 1744-1,
dated
Hay 15,
1981.
Report on %itness Tests of KSV-16-T Engine Generator
Set
2EGS"EG3,
Revision 1, dated October 29,
1981.
Nonconformance
and Disposition Report No. V024, dated
November
4,
1980.
Engineering
and Design Coordination Report No. P40,310.
The Nine Mile Point Unit 2 Final Safety Analysis Report 'states that
the qualification tests for the standby diesel
generators will be
completed in accordance
with Regulatory Guide 1.9,
IEEE Standard
387-1977
and
The inspector
reviewed the licensee
commitments,
the equipment specifications,
and the documentation for
the tests
already completed to ascertain
the status of the qualification
tests
and verify conformance to the licensee
commitments.
Various tests
required by IEEE 387-1977 are not specified in the
equipment specification
and have not been completed or planned.
For
example,
the load capability qualification test specified in Section
6.3.1 of IEEE 387-1977,
and clarified by Regulatory Guide 1.108,
requires that the diesel
generators
run for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at the continuous
rating,
and two hours at the short time rating;
The design specification
requires
a test at 115K of plant design
emergency
load for one hour.
The actual
shop acceptance
test
was conducted at rated continuous
load for four hours
and 110K of continuous
load (4840kw) for two
hours.
4.0
Emer
Various tests
are inconsistent with the testing requirements.
For
example,
the start and load acceptance
qualification tests
described
in IEEE 387-1977 Section
6. 3.2 require that immediately after the
diesel
generator
reaches
rated frequency
and voltage
a single step
load equal to or greater than
50K of continuous
load is to be applied.
(Approximately 2200
kw)
The design specification requires that 50K
of the continuous
load rating be applied
30 seconds after rated
voltage and frequency are achieved.
The shop acceptance
test consisted
of applying 2000
kw after frequency
and voltage
had stabilized for
some time.
Another test applied
a 2000
HP motor while the diesel
was
accelerating.
No equivalent test
has
been
completed.
The start and load acceptance
qualification tests consisting of
approximately
300 valid start
and loading tests specified in the
and the design specification
have not been completed,
as
recommended
by IEEE 387-1977 Section 6.3, at the engine manufacturers,
nor have they been scheduled.
The discrepancies
noted above indicate that the licensee
should
evaluate whether the current schedule
and test plan .will ensure that
the required qualification tests
are completed
on the diesel
generators.
This item is unresolved
(50-410/83-06-02)
pending further evaluation
of qualification test data.
en
Switch ear
Load Se uencin
Lo ic
The following documents
were reviewed:
Final Safety Analysis Report.
Calculation
EC-32,
Emergency Diesel Generators - 2EGS"EGl and
2EGS"EG3 Loading Calculation,
Revision 2, dated April 22,
1983.
General Electric Letter NMP2-2668, dated April 19,
1979.
Stone
and Webster Engineering Corporation
dated March 14,
1983.
General Electric Drawing 807E170TY Revision
8 and Revision 3.
SPEC drawing 24-9.4B.
SPEC drawing 7241001001E.
The Final Safety Analysis Report was compared to licensee
and contractor
drawings to determine if the licensee
commitments
corresponded
to the
actual
design
and installation.
The two sections
reviewed in the
FSAR which describe the load sequencing
logic, Sections
7.3 and 8.3, are inconsistent with each other.
The two
sections
specify different load sequencing
times for the
ECCS systems
and
also different sequences
for the applicable
pumps.
For example,
Section
7.3 of the
FSAR states that with a simultaneous
Loss of Coolant Accident
(LOCA) and Loss of Offsite Power
A and
B will start
after a 5 second time delay and
LPCI pump
C and the
LPCS pump start
immediately, yet section 8.3 has
LPCI pumps
A and
8 starting at 1 second,
and the
C and
LPCS pumps at six seconds.
The logic diagrams in the
FSAR were equally inconsistent.
After a review of the
SWEC drawings
and
GE drawings it was determined that Section 7.3 was.written by GE, therefore,
their design was reflected,
and Section 8.3 was written by SWEC using
their logic.
The discrepancies
were not noted in the
FSAR document review
(See Section 5.0).
In GE letter NMP2-2668, dated April 19., 1979, the-
Notes of Conference for an April 10-13,
1979 meeting,
QN requested that
the pump sequencing
and time delays
be chan'ged to their design.
On March
14,
1983
SWEC again requested
GE, by letter 9M2-13,854, to verify if the
sequencing
was acceptable to GE's design.
The licensee provided the
inspector
a copy of GE. Dwg. 807E170TY Revision 8 on May 26,
1983 that
incorporated these
changes.
The licensee
also stated
Chat the accident
analysis
was completed using the numbers specified by GE.
The exact time
delays
used in the analysis
could not be determined
from the
FSAR since
only a maximum total time for injection flow was given.
Calculation
EC-32,
Loading Calcu1ation
was
reviewed by the inspector
and it was found to be inconsistent with the
numbers specified by the. FSAR.
The calculations,
used to verify the
diesel
generator sizing,
used
numbers that'ere
on the average
1QX lower
than the
FSAR.
The
SWEC engineer responsible for the ca1culation stated
that the
FSAR numbers
were incorrect and a change would be submitted.
The inspector
informed the
NRC Project manager
by letter of the observed
FSAR discrepancies.
The,FSAR is currently under review by the
NRC.
5. 0
Desi
n Verification/Interface
The following documents
were reviewed.
Final Safety Analysis Report (FSAR).
Engineering Assurance
Procedure
(EAP) 5.3, Preparation
and Control
of Manual
and Computerized Calculations
(Nuclear Projects),
Revision
3, January
31,
1979.
EAP 3.1, Verification of Nuclear Power Plant Designs,
Revision 2,
February 8,
1977.
Project Guideline (PG) 2, Design Review of gA Category I'Nuclear
Safety-Related
Systems,
Revision 4, November 13,
1981.
L
~
~
PG 45, Interface for NSSS Portion of FSAR, Revision 0, April 23,
1982.
Engineering Assurance Audit Report, Project Audit No. 36, February
22-,26,
1982.
Engineering Assurance Audit Report, Project Audit No. 39,
November 8
- December 6, 1982.
Notes of Conference,
Second
PGCC Review of 24-9.4, October 31,
1977.
Notes of Conference,
Design Review of the Standby Diesel Generator,
December 19,
1978.
guality Assurance Audit Report of Cooper Energy Services,
April 5,
1983.
EAP 2.', Preparation,
Review and Control of Licensing Reports,
Revision 0, December 30, 1982.
PG 1, Licensing Documents - Preparation,
Review, Approval, and
Control, Revision 3, October 20,
1982.
The load sequencing
scheme
was inconsistent in Sections
7.3 and 8.3 of
the
FSAR (See Section 4.0).
The discrepancy
between the
and
GE load
sequenciqg
was not discovered in the document reviews
and subsequently
incorrect data was submitted in the
FSAR.
SPEC Engineering Assurance
Procedure 2.9, Preparation,
Review and Control of Licensing Reports,
states that the draft text shall
be reviewed by Project Engineering to
ensure all project requirements
are met.
"The draft text shall
be reviewed
by individuals or groups that provided input to the draft'text..
The
purpose of the review is to ensure that the input was transcribed
and
interpreted correctly."
Project Guideline
No. 1, Licensing Documents-
Preparation,
Review, Approval, and Control states
that "Approval by
of sections
prepared
by others
means that these
sections
are satisfactory
from. an interface standpoint
and that there is proper integration and
compatibility by other designs with those of the overall plant."
Project
Guideline 45, Interface for NSSS Portion of FSAR, states that "The
Project Engineer will approve all sections in accordance
with PG 1.
Approval by SPEC of GE prepared
sections
means that these sections
are
satisfactory
from an interfacing standpoint
and that there is proper
integration and compatibility of GE designs with those of the overall
plant."
Contrary to the above,
the
FSAR was prepared,
reviewed and approved
and
submitted to the
NRC with the noted incorrect information and discrepancies.
The
GE portions of the
FSAR were not satisfactory
from 'an interfacing
standpoint
and there
was not proper integration
and compatibility with the
design of the overall plant.
P
10
This failure to adequately
review a design
document is a violation of 10 CFR 50, Appendix B, Criterion III.
(50-410/83-08-03)
6. 0
Unresol ved Items
Unresolved items are matters
about which more information is needed to
determine whether it is acceptable
or a violation.
Unresolved
items are
discussed
in Paragraph
3.3.
7.0
Exit Interview
The inspector
met with the licensee's
representatives
(denoted in Paragraph
1.0) at the conclusion of each portion of the inspection,
on May 20,
1983
at the construction site,
and on May 26,
1983 at
SWEC, Cherry Hill, New
Jersey.
The inspector
summarized the findings of the inspection
and the
licensee
acknowledged
the inspector's
comments.
~
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