IR 05000354/1985051

Insp Rept 50-354/85-51 on 851021-25.Violations Noted: Inadequate Design Control of Nonconformance Repts & Failure to Follow Instructions,Procedures & Drawings

ML20138K187
Person / Time
Site:	Hope Creek
Issue date:	12/12/1985
From:	Anderson C, Cheung L, Schaeffer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138K178	List: IR 05000354/1985051 ML20138K175 ML20138K183
References
50-354-85-51, NUDOCS 8512180309
Download: ML20138K187 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-51

' Docket N License No. CPPR-120 Priority -

Category B Licensee: Public Service Electric and Gas Company 80 Park Plaza Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station, Unit 1 Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: October 21 - 25, 1985 Inspectors: , /v 3 L. Cheung, Reactor Engineer date

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M. Schaeffer, Reactor Engineer date Approved by: <

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C. J. Anderson / Chief, Plant Systems date Section, DRS Inspection Summary:

Inspection Period - October 21-25, 1985 (Inspection Report No. 50-354/85-51)

Areas Inspected: Routine, unannounced inspection by regional based inspectors of licensee work activities and documentation pertaining to the installation of electrical / instrumentation systems, components and associated control circuits. The inspection involved 79 inspector-hours on site by two regional based inspector Results: Two violations: Inadequate design control (one example) and failure to follow instructions, procedures and drawings (one example).

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DETAILS 1.0 Persons Contacted 1.1 'Public Service Electric & Gas C W.-Barbas I&E Techinician J. Bucknan Startup Test Engineer J. DeFabo QA Engineer

R. Donges Lead QA Engineer

J. Duf fy Supervising Engineer

A. Giardino Station QA Manager

R. Griffith Principal QA Engineer R. Hilditch QA Engineer

P. Kudless Maintenance Manager

S. La Brima Assistant General Manager, Hope Creek

M. Lavechia Principal QA Engineer

C. Lambert Supervising Engineer K. Long I&C Technician

M. Metcalf Principal QA Engineer J. Riddlemonser I&C Technician D. Shaffer NSSS I&C Group Leader 1.2 Bechtel Engineering Corporation

R. Bhatia Resident Engineer L. Carey Senior Electrical Engineer

W. Cole Lead Site QA Engineer

W. Goebel QA Engineer

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l G. Goldswith Resident Engineer

A. Indico Project Startup Coordinator

D. Long Field Construction Manager

G. Moulton Project QA Engineer

-P. Veer _ Field Engineering 1.3 USNRC

A. Blough Senior Resident Inspector

J. Lyash Resident Inspector

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Denotes personnel present at exit meetin . 0_ Facility Tour The inspectors observed work activities in progress, completed work and plant status in several areas during a general inspection of the site. The inspector examined work items for obvious defects or noncompliance with ND.C

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-3-requirements or licensee commitment Particular note was taken regarding the presence of quality control inspectors and indications of quality control

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activities through visual evidence such as inspection records, material identifications, nonconformance and acceptance tags. In addition, the inspector interviewed craft and supervisory personnel encountered in the work area. The only deficiency identified is discussed in Section Item 85-03-0 ,

3.0 Review of Nonconformance Report Records The inspector reviewed a selected sample of 8 nonconformance reports in the instrumentation area to determine whether:

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The records were legible, complete and promptly reviewed by qualified personnel i -

The records were properly identified, stored, and can be retrieved in a reasonable tim >

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The reports included proper resolution and adequate justification was provided for accept-as-is dispositio The following nonconformance reports were reviewed:

i NCR #8263 " Flex Hose Bulges" dated August 23, 198 . NCR #7786 " Incorrect Dimensions of Instrument Tubing and Supports" dated May 28, 198 . NCR #7710 " Damaged Threaded Pipe Nipple of Tubing Post Connector on FE-9589A" dated May 23, 198 . NCR #7900 " Modification on Instrument Support #S-45" dated June 19, 198 . NCR #8262 " Insufficient lengths of Flex Legs" dated August 23, 198 NCR #8180 " Damaged threat on Bellows Monitoring Connection for

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I-XJN-ID" dated August 12, 198 . NCR #7967 " Insufficient Channel Separation / Flex Hose Damage" dated July 9, 198 . NCR #7968 " Insufficient Channel Separation" dated July 9,198 ...

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-4-The QC inspector identified in NCR # 7967 and #7968 that the spatial separ-ations between redundant channel instruments PDT-N086A,B,C,0; N087A,B,C,D; N088A,B,C,0 and N089A,B,C,D were less than three feet. This was in conflict with the Instrument line Separation Criteria for redundant channels stated in Section 8-2 of Bechtel Specification 10855-J-825(Q), Rev.6. The Project Engineering Disposition for these two NCRs was " Project Engineering concurs with Field Engineering use-as-is dispositions. Concurrence is based on a review of the instruments' function and concluded that the instruments serve unrelated and non-redundant functions......"

o These sixteen instruments, however, are used to detect high flow in the main steam lines. They are required to serve related and redundant function Therefore, the licensee did not exercise adequate design control in their disposition of these NCR' '

The licensee was informed that the above is in violation of 10 CFR 50, Appendix B Criterion III " Design Control" which states in part that " Design changes, including field changes, shall be subject to design control mea-sures commensurate with those applied to the original design...".

(354/85-51-01)

4.0 Incorrect Wiring 4.1 Background Instrumentation loop calibrations are performed by the PSE&G start-up group once Bechtel Construction turns the equipment over. Defi-ciencies identified during the calibration phase are documented in Start-up Deviation Reports (SDR) and dispositioned by engineering, which is consistent with approved procedure On June 26 and July 22, 1985, PSSUG performed the required loop cali-brations for instruments E51-FT-N051 and E51-PT-N050 (RCIC flow and pressure transmitters) which were wired to GE Panel H11-P618. The results of the calibration of these transmitters were successfu Subsequent to the calibration, the transmitters underwent modifica-tion for the installation of moisture intrusion seals in the electri-cal conduit to meet environmental qualification requirements. The -

wires to the transmitters had to be de-terminated and butt-spliced after the seals were installed. As a result of this seal installa-tion, a recalibration of the transmitters was require .2 Event The inspectors witnessed the re-calibration process of the pressure and flow transmitters on October 24, 1985. One inspector witnessed activities at the pressure and flow transmitters, elevation 54' in the reactor building; the other inspector was positioned at the GE Panel H11-P618 where trip units E51-651 and E51-N650 are locate r .

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-5-These trip units supply power and test signals to the transmitter The GE panel is located on elevation 102' in the relay room. When test signals were initiated from the trip units, the transmitters failed to respond as designe The loop calibration for E51-FT-051 and E51-PT-N050 was terminate .3 Analysis and Conclusions The inspectors reviewed the circuit diagrams, cable termination tickets and QC inspection reports for the transmitters and the trip units, which revealed the following:

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GE Drawing 791E421AC, Revision 3 dated August 28, 1980 indicated that the wiring connections for transmitters E51-PT-N050 and E51-FT-N051 should be such that:

positive terminal of E51-PT-N050 connected to terminal 5511

- negative terminal of E51-PT-N050 connected to terminal 5512 positive terminal of E51-PT-N051 connected to terminal 5514

- negative terminal of E51-PT-N051 connected to terminal 5515

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the wiring from flow transmitter E51-FT-N051 to the terminal board (SS) inside GE H11-P618 panel had been reversed, ie.., the wiring on terminals SS-14 and SS-15 (wire colors white and black respec-tively) had been incorrectly terminated on terminals SS-15 and SS-14 respectivel the wiring from pressure transmitter E51-PT-N051 to the terminal board (SS) inside H11-P618 had also been reversed. The wiring on terminals SS-11 and SS-12 (white and black) had been incorrectly terminated on terminals SS-12 and SS-11 respectivel The drawings, termination cards, and QC inspection records agreed

.with the design, however the licensee could not provide explanation on why and when the wiring had been terminated in erro Subsequent to this finding the licensee startup test group generated an SDR and swapped the wiring of terminals SS-14 and SS-15, and the wiring of terminals SS-11 and SS-12, and according to the licensee, the instruments worke The licensee was informed that the above was in violation of 10 CFR 50 Appendix B, Criterion V " Instructions, Procedures, and Drawings" which-states in part that " Activity affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures or drawings...". (354/85-51-02)

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-6-5.0 Record Review of Receipt Inspection and Material Certification The inspector reviewed the receipt inspection records and material certifi-

. cations of a selected sample of two level transmitters (B21-LT-N081A&D)

and four pressure transmitters (B21-PT-N055B,F and -N056B,F) to ascertain whether the receipt inspection documents correspond to the received in-struments, components and associated items. The following records were reviewed:

1) QCIR No. NSSS-132551 dated April 17, 1985 For Rosemount Model

1. 1153GB8 PAN 0016 pressure transmitter ) QCIR No. NSSS-130824 dated March 15, 1985 for Rosemount level transmitters part No. 188C7360P00 ) General Electric Field Disposition Instruction No. WTIQ, Rev. O dated October 25, 198 ) GE Product Quality Certification No. AS318 dated April 2, 1985 5) GE Product Quality Certification No. AS338 dated February 20, 198 The inspector noted that the documents reviewed were legible and properly signed and dated. Within the scope of this review, no unacceptable condi-tions were identifie .0 QA Audit Record Reviews

.The inspector reviewed QA audit records on I&E installation and inspection activities performed by Bechtel Construction, Inc. to ascertain whether 1)

the audits were performed in accordance with PSE&G QA manual No. QAI 18-1

" audits by QA-E&C, Hope Creek" Revision II, dated April 10, 1984; 2) the audit reports contained sufficient data to verify that the intended purpose and scope of the audits were achieved; and 3) that audit findings had been reported in sufficient detail to permit a meaningful assessment by those

. responsible for corrective action, final disposition and trendin The following audit reports were review:

Audit Report N Audit Date Findings H-320 April 12 - May 8, 1984 6 noncompliances and 2 observations were identified H-349 March 5 - 14, 1985 No findings u

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-7-The findings in audit report H-320 were related mostly.to the clarity of Bechtel's instrument installation specification 10855-J-720 (Q). These findings were resolved within a reasonable tim ,

The~ inspector.found that these audit were thorough and were documented in a logical manne Within the' scope of this review, no unacceptable conditions were identifie .0- Instrument Calibration Records and-Test Data Review l The inspector reviewed Hope Creek instrument calibration procedures and a selected sample of calibration records to ascertain whether the records confirmed that calibration and related data were current, controlled and reflect actual conditions and that the calibrations were performed in accordance with approved procedures.

, ' Items' examined for this determination include:

1) PSE&G Procedure No. PSSUG-GTP-2 " General Instrument Calibration Procedure for Field Decries" Revision 4 dated May 6,198 ) .PSE&G Procedure No. PSSUG-GTP-3 " Instrument and Control Function

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Loop Calibration" Revision 3 dated March 28, 198 ) PSE&G Instrument Calibration Data Instrument Loop #1BCON055B for Instrument BCPTN055BE11, TPR BCC-0329, Revision 4 dated April 23, 198 ) Check list for Instrument Calib-M n ' 1BC-PT-N055BE11 dated-August 18, 1985.

, 5) Initial Device Calibration for Instrument No. 1BC-PISH-N655B-E11-B and 1BC-PISH-N655F-Eaa- ) _ Instrument Calibration Data for 1BC-PISH-N655BE11 Revision 1 dated October 9, 198 ) Instrument Calibration Data for 1BC-PISH-N655F-Ell Revisiott I dated

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October 9, 198 ) Initial Device Calibration TPR-BCC-0091 for transmitter 1BC-PT-N0568-E11 p dated March 20, 198 ) Instrument Calibration Data for IBC-PT-N056B-E11 Revision 1 dated January 2,'1985.

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-8-10) Initial Device Calibration TPR-BCC-0077 for 1BC-PT-N056F-E11 and 1BC-PT-N0568-E11, dated March 20, 198 ) Instrument Calibration Data for 1BC-PT-N050F-E11 Rev. 1, and 1BC-PT-N0568-E11, dated December 11, 198 ) Instrument Calibration Data for 1BC-PT-N055D-E11, Rev. 1 undated (not yet complete).

13) Instrument Calibration Data for 1-SM-CT-N081A-B21 Rev. I undated (not yet complete).

14) Instrument Calibration Data for 1-SM-LT-N0810-821, Rev. 1 undated (not yet complete).

The' inspector found that the instrument calibration records were legible, properly signed and dated and contained sufficient data for verificatio Within scope of this review, no unacceptable conditions were identifie .0 Status of Previously Identified Items (0 pen) 10 CFR 50 Appendix B Criterion V Violation 85-03-01 pertaining to uncapped instrument-tubing (Line No. PBC-V9950A) after disconnecting from the instrument (for testing).

The inspector verified by observation that Instrument line No. PBC-V9989A was properly connected back to the instrument. The inspector also observed additional instrument tubing conditions of numerous instruments in the surrounding areas; no uncapped field run tubing connections were observed after flushin In order to avoid repetition of this violation, the licensee included in section 5.6 of Procedure No PSSUG-GTP-2 Revision 5, dated October 24, 1985, the following:

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" Capping'of tubing is preferred at all times; however, it shall be mandatory following acceptance flushing."

The above corrective action is considered acceptable, however, during the facility tour, the ' inspector identified numerous uncapped instrument cali-bration connections on the GE transmitter racks (e.g. H21-P004, P005, P006, P014, P018, P027) in the Reactor Building at Elevation 77'. The affected

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-g-instruments are used to measure reactor water level (e.g. 821-LT-N027,

-N080A,-081A,-N091A,-N091E,-N0402A,-N0402E),reactorpressures(e.g.,

B21-PT-N008, -N090A, -N090E, - N090N, -N0403A, -N0403E, C32-PT-N005, -N008),

and differential pressures (e.g. E11-dPT-N058A, C32-dPT-N004A, -N017).

These connections are isolated from the instrument impulse lines by normally closed instrument valves. However, during calibration the instrument valves are opene Since no provisions were made to prevent dust from entering the lines the NRC's concern is that dust or debris can be accumulated in these connections and may eventually be introduced into the instrument lines during the cali-bration process. The inspector reviewed Hope Creek procedure PSSUG-GPT-2

" General Instrument Calibration Procedure for Field Devices" Rev. 5 dated October 24, 1985. No precautions were provided in the calibration procedure to preclude intrusion of accumulated dust or debri This item remains open pending licensee's corrective actions to prevent dust or debris intrusion into the instrument impulse line (Closed) CDR 84-00-04 General Electric HEA Relay Trip Force Values Out of Specification / Malformed Torsion Springs General Electric identified to the Licensee, in Service Advice Letter PSM 175.1, that HEA relays manufactured between September, 1980 and August, 1983 may exhibit Trip Force values which could cause malfunction, and recommended to the Licensee that all HEA relays manufactured between the above dates should be inspected to determine the force required to trip the relay; and any HEA relay not meeting the specified force be replace The licensee generated nonconformance report No. 3108 to document the inspection, testing and replacement of 13 suspected HEA relay The licensee was also advised by General Electric in Service Advice Letter PSM 165.1 that certain HEA relays manufactured between May, 1979 and December,1980 may fail to operate due to malformed torsion spring The licensee generated NCR no. 2264 to document and control the suspected hardware (26 HEA relays were involved).

The inspector reviewed both NCR's, verifying that the dispositioning and replacement of the HEA relays was in cccordance with the vendors requirement and also verified through QC Inspection Reports that all the suspected relays (A total of 39) were replace This item is considered close (Closed) 10 CFR 50, Appendix B, criterion V violation 85-17-01 Preventive maintenance lapse after construction turnover of "Q" equipment to PSEG startu , . - - , ,

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-10-On April 18, 1985, the NRC inspector identified numerous (approximately 400)

safety-related "Q" preventive maintenance activities that had not been performed in accordance with the schedule for equipment and systems turned over to PSSUG.

During this inspection, the inspector reviewed MD-AP, ZZ-010(Q) " Maintenance Department Procedure" revision 1, dated August 27, 1985, which was revised to. include measures to ensure that turned over equipment receives the

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required maintenance in a timely manner. In addition, the inspector reviewed the following Maintenance Activity Forms.

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Meggering of RHR pump motors

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physical rotation of reactor feed pump shafts

--: Cleaning of air filters for the vital bus UPS inverters The frequencies of the maintenance activities were in accordance with specified requirements and the licensee had a negligible PM backlo This item is considered close (Closed) Unresolved Item 85-10-02 Cable Tray Edge Protectors Bechtel's specific work plan / procedure SWP/-E-17 titled " Cable Installation" defines the criteria for the application of cable tray edge protector In a previous inspection, the inspector identified many locations where edge protectors were not installe During this inspection the inspector observed cable trays in the upper and lower spreading rooms, and general plant areas, and verified that cable tray edge protectors were installed where require This item is close .0 Exit Meeting The inspector met with licensee and construction representatives (denoted in paragraph 1.0) at the conclusion of the inspection on October 25, 1985 at the construction sit The inspector summarized the scope of the inspection, the inspection findings and confirmed with the licensee that the documents reviewed by the team did not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).

At no time during this inspection was written material provided to the licensee.