IR 05000443/1985015
| ML20137Z900 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/13/1985 |
| From: | Bettenhausen L, Cerne A, Cheung L, Eapen P, Finkel A, Jeffery Grant, Kamal Manoly, Reynolds S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20137Z860 | List: |
| References | |
| 50-443-85-15, NUDOCS 8510080401 | |
| Download: ML20137Z900 (81) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Region I Report N /85-15 Docket N Construction Permit N CPPR-135 Category A Licensee: Public Service of New Hampshire Post Office Box 330 Manchester, New Hampshire 03105 l Facility Name: Seabrook Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: June 3-14, 1985 Inspectors: h. N .apen,ka Dr. P. /14vt Tea 6 Leader
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A. K rne, Assistant eam Leader (SRI)
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'[ Tite (fhY M. Che ng, Reactor En
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' Date Gt'W A. E. Finkel, Lead Reactor Engineer rhihr
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4 M.3 har Grant, Reactor Engineer sl1+lsr
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Date hWW K. A. Manoly, Lead Reactor' Engineer Y?//df Date
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S. D. Reynolds, Lead React 6r' Engineer YK Date 8l Approved By: /d 'f 8 Dr. L. H. Bet'tenhausen, Chief, Operations Date Branch, Division of Reactor Safety gno"es$$h G
Inspection Summary: Announced Construction Team Inspection on June 3-14, 1985 (Report Number 50-443/85-15)
Areas Inspected: Construction Site Management, Quality Assurance, Design Change Program, Electric Systems, Instrumentation and Control, Mechanical and Structural Systems, and Welding and Metallurgy. The inspection involved 567 hours0.00656 days <br />0.158 hours <br />9.375e-4 weeks <br />2.157435e-4 months <br /> onsite inspection by five region-based inspectors, one senior resident inspector and one supervisor, Results: Three violations, three unresolved items, three weaknesses and three strengths were identifie .
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Table of Contents b
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1. -Persons Contacted...................................... 4 J Inspection Purpose & Scope ............................ 5
' Seabrook Station Site Management....................... 7 ,
- Quality Assurance and Administrative Controls.......... 10
- Design Change Contro1.................................. 17 Mechanical Components and Supports..................... 25 Welding and Meta 11urgy................................. 39 I Instrumentation and Controls........................... 49
.' Electrical Systems..................................... 60
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j_ 1 Licensee Actions on Previous NRC Findings. . . . . . . . . . . . . . 66
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11. Unresolved Items....................................... 67 12. Management Meetings....................................
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Attachment 1 - Documents Reviewed...........................
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DETAILS 1.0 Persons Contacted 1.1 New Hampshire Yankee
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J. Azzopardi, QA Engineer F. Bean, Field QA Engineer i R. Cummings, Jr., Independent Reviewer W. Derrickson, Senior Vice President J. DeVincentis, Director, Engineering & Licensing T. Feigenbaum, Independent Review Team Leader G. Gram, Director of Construction R.'Guillette, Assistant Construction QA Manager W. Johnson, Vice President G. Kann, STD Test Group Manager
D. Maidrand, Assistant Project Manager J. Marchi, Startup QC Supervisor ,
G. Mcdonald, Construction QA Manager !
W. Middleton, QA Staff Engineer D. Perkins, Field QA Engineer V. Sanchez, Licensing Engineer -
J. Singleton, Assistant QA Manager J. Tefft, STD Project Engineer D. Turner, Field QA Engineer H. Wingate, Engineering '
1.2 United Engineers and Constructor (UE&C)
R. Leonard, R&QA Manager D. McGarrigan, Project QA Manager M. McReona, Sr. Project Engineering Manager 1.3 USNRC R. Barkley, Reactor Engineer H. Wescott, Resident Inspector *
The above listed personnel attended the exit meetings held on June 14, 198 Other managers, supervisors, engineers, quality technicians and craftsmen were also contacted during the inspectio ;
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2.0 Inspection Purpose and Scope Introduction On April 18, 1984, Public Service Company of New Hampshire suspended all construction activities at Seabrook Station. The licensee reor-ganized with project control under New Hampshire Yankee Division management and resumed limited construction on July 23, 1984. The
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reorganization resulted in several major changes at the site. These changes included restructuring of the site organization, introduction of new contractors, use of new procedures, and termination of some existing contractors. The management control and scope of some Qua-
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lity Assurance activities were also changed under the new site organ-ization.
, The NRC had several concerns in the engineering, design and installation of electrical and instrumentation system These con-cerns were identified in the NRC Systematic Appraisal of Licensee Performance (SALP) report dated February 19, 198 ,
2.2 Purpose & Scope of Inspection
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The purpose of this inspection was to assess the effectiveness of the
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construction activities resumed under the new site organization through a multi-disciplinary review of selected portions of key safe-ty related systems at the Seabrook Statio The selected systems l were Safety Injection (SI), Residual Heat Removal (RHR), Heating Ven-tilation and Air Conditioning (HVAC), and Diesel Generator Jacket
- Cooling System These systems and the disciplines were selected on the basis of reactor safety and the system's relative contribution to " Core Melt l Probability", as stated in the licensee's Probability Safety i
Assessment Report (PSA). The PSA report identified that the loss of
. offsite power and seismic events were the highest and the next i highest contributors to the core melt probabilitie (It should be l- noted that the median core melt probability for Seabrook Station, as calculated by the licensee is only about one in 5300 years.)
Therefore, the team reviewed the electrical design features of selected systems including those required to mitigate the conse-quences of a loss of offsite power even The team also reviewed those design features of selected systems that are required to
! mitigate the consequences of a design basis seismic even ;
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At the time of this inspection, several systems, including those por-tions of the emergency core cooling systems (ECCS) within the contain-ment, were completed and turned over to the preoperational test grou Therefore, the team selected the safety injection (SI) system and the residual heat removal (RHR) system, two subsystems of the ECCS, to assess the adequacy of the engineering, design, installation, and the effectiveness of management overview, Quality Assurance, and interface control measure The adequacy of the selected systems was assessed by reviewing those portions of SI and RHR systems within the containment. The interface between the RHR, a low pressure system and the reactor coolant system,
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a high pressure system, was reviewed for the High Pressure / Low Pres-sure system boundary requirements. The SI system was also used to assess the effectiveness of the newly established Piping and Piping Support Closecut Task Team Program (PAPSCOTT). Section 6 of the Seabrook Station Final Safety Analysis Report provided design basis details of the SI and RHR system The probability risk analysis aspects for these systems are detailed in Section 7.8 of the Seabrook Station PSA repor The licensee has a new contractor for the Heating, Ventilation and Air Conditioning (HVAC) System Therefore, portions of HVAC system were selected to assess the effectiveness of the new contractor and to assess the adequacy of the design of attending systems. Jacket cooling water system for the diesel generator was another supporting system' reviewed for adequac The team sampled and assessed as appropriate the adequacy of the elec-trical, instrumentation and control, mechanical, structural and metal-lurgical features for each of the main system and their required sup-porting system The adequacies of the administrative controls, QA/QC measures, and management involvement were also reviewe The details of this inspection are documented in the following section Specifically, Section 3 provides an assessment of the construction management, Section 4 a review of the QA/QC and Administrative Controls, Section 5 a review of the design change controls, Section 6 a discus-sion of structural and mechanical design, Section 7 a discussion of metallurgical considerations, Section 8 a review of the instrumenta-tion and control design and Section 9 a review of the electrical feature The team identified three strengths and three weaknesses, three unre-solved items and three violations. Except for the identified weakness and violations detailed in individual sections and summarized in Ap-pendices A and B to the cover letter for this inspection report, the team noted a high level of management involvement in the quality and control of the site construction activities and acceptable standards
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for quality implementation. The overall program and its implementa-
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tion were consistent with the licensee commitments in the final and j preliminary safety analysis reports for the Seabrook Station.
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3.0 Seabrook Station Site Management t
The overall site management was reviewed to assess the effectiveness and adequacy of management overview in safety related activitie .1 Organization As discussed in Section 13 of the Seabrook Final Safety Analysis Report, the licensee has consolidated the Nuclear Production, Con-struction, Quality Assurance and other site support activities under the Senior Vice President who reports directly to the President of the newly formed New Hampshire Yankee organization. Negotiations were underway with the New Hampshire Public Utility commission to incorporate New Hampshire Yankee Electric Corporation separate from Public Service of New Hampshire (PSNH). Until the necessary federal and local approvals are obtained, the New Hampshire Yankee organiza-tion will function as a Division of PSNH. The New Hampshire Yankee is chartered to act as the managing agent for the Seabrook Joint Owners in the construction completion and operation of Seabrook statio The Seabrook construction activities are under the direct supervision
.of the Senior Vice President who is stationed at the site. Director of Construction, Director of Engineering and Licensing, and Director of Management Control, direct and manage construction, engineering, and management control activities, respectivel Each of these directors report directly to the senior Vice President. Site Nuclear Production activities are organized under a Vice President. Quality Assurance and Project Overview Administrative Services are organized under another Vice Presiden After the reorganization, the licensee has retained United Engineers and Constructors (UE&C) as the key architect engineer. The number of independent contractors, was reduced to less than five from more than twenty prior to the reorganization. The licensee limited the site personnel to five thousand from a pre-reorganization limit of eight thousand. The reporting levels were reduced from eleven or more to the current five level At the time of this inspection, the site employed about 5100 person-nel including 3000 craft, 700 engineering personnel, 400 QA/QC per-sonnel, and other support personnel. The organization was functional and several new programs such as Piping and Piping Support Closeout Task Team (PAPSCOTT) were in progress. Given below are the details of the findings in the site management are . .--_ - - - . _-. -. _ . - _ -.
3.2 Findings (1) Consolidation of Site Engineering Activities The licensee recognized the need and consolidated all the project engineering responsibilities under the Director of Engineering and Licensing, who ensures that the entire organiza-tion receives consistent direction and guidance from a single source. He interfaces with the Startup Manager, Project Con-trols Manager, Project Construction Manager, QA Manager, NSSS Vendor and the Architect Engineer and assures that the final product is licensable and technically acceptabl The Director of Engineering and Licensing was successful in coordinating the responses from the NSSS vendor, the licensee's corporate engi-neering office, the Architect Engineers and the site contractors for NRC Engineering and design concerns raised during the course of this inspectio (2) Commitment to Quality Assurance The licensee's commitment to quality is clearly stated and pro-vided to the employees in the employee handboo The site Quality Assurance personnel were qualified and experienced in various engineering disciplines and are capable of assessing the adequacy of the programs audited or reviewed. The site manage-ment was dedicated to bring in performance oriented individuals for QA audits and inspections. Management recognizes the role of QA and is supportive of QA functions. See Section 4 of this report for further details of the team's assessment of site QA activitie (3) Communication The site senior management holds weekly staff meetings and attends key project meetings. The flow of information appeared to be prompt and effective. The senior management was appraised of technical issues, such as, pump vibration problems at startup and installation discrepancies in pipe support The senior management was concerned about the problems associated with the reorganization and made every effort to provide factual infor-mation to the working level site personnel promptly. In order to expedite effective communication of information affecting site personnel, the site management convenes regular meetings of the top one hundred key site personne As a result, the working level personnel were found to be well informed in the day-to-day financial concerns at the site. The licensee publishes the site newspaper, the Standard, every two weeks to
inform the site personnel about key issue This publication also highlights daily activities of selected groups onsite. For example, the June 7,1985 issue of the Standard contained a two page article "taking a glimpse into the day of a Seabrook Station pipefitter" with photographs and interviews with the pipe fitter The morale of the Engineering, Construction, QA and Craft personnel contacted during this inspection was observed to be high.
(4) Allegation Resolution Site management also realized the need for attention to employee concerns and allegations and established an employee allegation resolution program at the sit The allegation resolution office is staffed with full time experienced and qualified personne The available internal means of problem resolution are well established and made known to the personnel during the indoctrination training.
(5) Awareness of Probability Risk Analyses The licensee has undertaken and completed a probability safety assessment (PSA) study for the Seabrook Station. The study was performed by a consultant (Pickard, Lowe and Garrick).
The licensee is also developing probability safety concepts to identify root causes for failure The licensee maintains a dedicated staff at the corporate engineering office for the support of PSA at all Yankee plant Seabrook station has an experienced full time engineer to attend matters related to PS He is assisted by the corporate staff and the contractor on an as needed basis.
(6) Initiatives to Learn from the Industry Experience The site uses the knowledge gained from other Yankee plants and the personnel trained and qualified at other Yankee facilitie In addition, the site management keeps abreast of the experience at .other construction sites through direct contacts and review of INP0 good construction practice Good practices are implemented at the site. The licensee developed his schedule for system completion based on previous experiences at other site As a result, except for five subsystems, the licensee was able to complete the first 650 subsystems as schedule Problems identified in construction deficiency reports generated from other sites are reviewed to develop and implement measures to preclude such occurrences at the Seabrook sit _
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(7) Commitment to Training The licensee has established positive measures to assure ade-quate training onsit Training requirements and matrices are established for all personne The training records were readily available and curren (8) Housekeeping The licensee has established positive measures in housekeepin Procedure FGCP-8 governs the housekeeping activities at the site. Management and Quality Assurance consider housekeeping as an on going activity. The workers are instructed to clean work areas each shift. Key personnel are assigned to monitor work areas on a routine basi In addition, QA/QC surveils and monitors the site and issues inspection reports. As a result, the cleanliness of the site improved substantiall Except for isolated instances, the team found the site at a high level of cleanlines Items (1) through (8) above indicate that the site management has recognized the need for improvement in key areas and instituted adequate measures to strengthen these areas. These measures were working well at the time of this inspection. The team concluded that the above are positive attributes of an effective management system and these positive attributes collectively constitute a licensee strength.
4.0 Quality Assurance and Administrative Controls As documented in Section 17.1.1.1 of the Seabrook Station FSAR, the licensee has delegated to the Yankee Atomic Electric Company (YAEC) the responsibility for the development, execution, and administration of the quality assurance program for construction and preoperational testing activitie Project reorganization under New Hampshire Yankee (NHY)
management control did not affect YAEC's defined QA responsibilitie Thus, during this inspection period, the inspector reviewed the latest revision, dated 2/15/85, to the YAEC Seabrook Station Quality Assurance Manual and Revision 3, dated 4/1/85, to the YAEC Field QA Group Manual and Procedur He specifically selected the following criteria for further review to determine both the adequacy of programmatic controls and the effectiveness of program implementation:
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Organization to include staffing and contractor control l
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Reports to management and management involvement
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Trending of deficiencies / problems
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QC inspection criteria With regard to the Administrative Controls being utilized by manage-ment at Seabrook, the inspector selected for review the following programs, with particular interest in the new program developments since the restart of construction under NHY management contro Control of contractor interfaces
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Contract procurement
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Project management of 50.55(e) evaluations and FSAR revisions
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Independent Review Team (IRT) utilization
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Piping and Pipe Support Closeout Task Team (PAPSCOTT) Program interfaces
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Employee Allegation Resolution (EAR) Program The details and findings for each inspection area are discussed below:
4.1 Organization The inspector reviewed the current organizational structure of the project QA organization, noting its evolution thru a major change in QA reporting lines from the contractors to the YAEC Construction QA Manager, implemented on 3/1/84, and an organizational restructuring of the site QA organization, effective 1/21/85. The present Seabrook QA organization has project oriented lines of direction / control of various internal YAEC groups (e.g.: startup QC, surveillance, audit, and quality engineering functions). In any case, responsibility is demonstrably vested with the YAEC Construction QA Manager, who is stationed onsite, and with independence provided by a reporting line for QA matters from him thru the YAEC Corporate QA management struc-ture, to upper NHY managemen .
4.2 Overall Quality Assurance Function The inspector reviewed a sample of recent "Seabrook Project Quality Assurance Evaluation Reports," prepared by the YAEC Director of Quality Assurance (Corporate) to the President and Chief Executive Officer of PSNH, and confirmed adequate overview of the engineering and various construction QA activities and an awareness and commun-ication of the potential problem areas. Evidence of Project Quality Trending of problems (primarily NCRs) by major contractor and YAEC functional group was noted and checked not only for compliance with the requirements of the pertinent NHY Project Procedure (i.e.: QP-1),
but also for management attention and action to correct the iden-tified problem For implementation of corrective action to problems of a generic nature, the inspector noted procedural control (i.e.: QP-2) for Corrective Action Reports (CAR) and the assignment of responsibility for followup. QA management also has available for their use a means of initiating corrective action by way of Management Action Requests (MAR) and Immediate Action Requests (IAR) where awareness and action on the part of upper construction management is required to effect immediate corrective measures. The inspector reviewed a sample of MARS and IARs to evaluate the completeness of the corrective steps taken to address the cause of the identified problem The inspector also sampled the surveillance checklists utilized by YAEC QA Level II inspectors in the performance of their scheduled surveillance activities, interviewed the YAEC Project QA Surveillance Manager, and checked master surveillance schedules by discipline for the timeliness of coinpleted inspection In the instrumentation, structural, piping, engineering, and preoperational testing areas, the inspector confirmed the use of surveillance criteria consistent with construction procedure requirements. The surveillance reports, documenting coverage of a specific preoperational test (1-PT-8), were reviewed for compliance with the applicable Test Program Instruction criteria. The use of holdpoints by YAEC inspectors in witnessing the conduct of 1-PT-8 was both verified and discussed in greater detail with the YAEC Startup QA Superviso The inspector specifically tracked management followup of some specific unscheduled surveillances performed on two instrument racks within the containment. Review of a QA Memorandum (File Q1.1.4/
YFQA-411) dated 5/28/85, revealed that while some workmanship defic-iencies identified by the surveillances had been correctly documented on NCRs for specific corrective action, further QA effort was in progress to better define and scope the problem from a programmatic standpoint so that the recommendations for corrective measures would have more generic impact. In this regard, IEEE 336 criteria are being evaluated as an augmentation to the existing inspection pro-cedures and consideration is being given to extend the scope of future inspection to beyond the safety-related installation These efforts er.emplify a strength in the Seabrook QA program in that strong and effective corrective action appears to be directed to the programmatic causes of the given problem, and not just to the identi-fied deficiencies. As also with the use of the CARS, MARS, and IARs, the Project Quality Trending program appears to be effective as both a problem prevention and diagnostic tool and represents another example of a Seabrook QA program strength.
4.3 Administrative Controls In reviewing several of the licensee's management and administrative controls, the inspector found widespread, multidisciplinary utiliza-tion of the site Independent Review Team (IRT) to address problem areas and concerns. He reviewed an IRT Report (IRT-015) dated 5/7/85, assessing the existing interface between the NSSS vendor and the A/E for the Seabrook projec At a meeting with engineering personnel to discuss generic component clearance criteria used for design and construction guidance (reference: UE&C Technical Proced-ure, TP-8), the involvement of the IRT in reviewing the program and making recommendations was evident. Also, the inspector noted that the IRT is utilized as the Technical Support Team for the Seabrook Employee Allegation Resolution (EAR) Program, because of their inde-pendent nature as consultants to the NHY Vice President. A close working interface between the IRT and the YAEC QA organization also exists and has added to the strength of the QA progra The inspector also reviewed the current programmatic controls for the Seabrook EAR program, initiated in 198 He interviewed the EAR Program Manager, reviewed the NHY program scope and the EAR Operating Procedure, and examined a sample of the case file Specifically checked were EAR allegation / concern acquisition methods, the method of keeping upper management informed of EAR activities and results, and the way feedback is provided to both employees and EAR personnel where corrective action within the scope of other organizations is required. Management support of the EAR appears evident, commencing at the NHY corporate executive level. The inspector also noted that the IRT ' conducted an adequate audit of EAR Program on 4/16/85, the report of which was made available for the inspector's review.
4.4 Project Controls (10 CFR 50.55(e) Reports and FSAR Changes)
With regard to project controls for 10 CFR 50.55(e) Construction Deficiency Report (CDR) evaluation, the inspector noted that docu-mentation requirements have been established by NHY Administrative Site Procedure, ASP-3; UE&C Administrative Procedure, AP-48; and YAEC Project Policy No. 27. The inspector reviewed recent guidance dated 3/20/85, disseminated by the Construction QA Manager and the Director
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of Engineering and Licensing for use by all engineering and QA per-sonnel in the determination of 50.55(e) reportability for identified deficiencies. During the course of this inspection, specific NCRs were checked for documented evidence of the licensee's evaluation of the subject deficiencies for reportability under 10 CFR 50.55(e).
The inspector also noted that the " Action Requests for Corrective Action" used by the EAR Program require 50.55(e) evaluations for substantiated concerns involving safety-related material.
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cerns were identified in this are Reporting of Construction Deficiency Reports at Seabrook is control-led by the YAEC Licensing Office, which works with both UE&C engi-neering and YAEC QA in the evaluation process. Another YAEC licen-
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sing function is the control of FSAR changes. Amendment 54 to the Seabrook FSAR/PSAR was submitted to the NRC Division of Licensing on 3/12/85. The inspector discussed with a YAEC Project Engineer the overall control of FSAR revisions, specifically questioning how removal of the Boron Injection Tank (BIT) from the ECCS piping was being controlled from a licensing standpoint. Westinghouse is pro-viding the supporting technical analysis for this design change.
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Pending completion of this analysis and preparation of the necessary documentation, affected FSAR sections will be revised and included in a future amendment to the FSAR. By letter dated 6/13/85, the licen-see informed the NRR Division of Licensing of their intent in regard to removal of the BI .5 PAPSCOTT Program l
Another recently instituted program at Seabrook is the Piping and Pipe Support Closecut Task Team (PAPSCOTT), which provides an organ-izational framework and guide for the completion of the ASME pipe and pipe support systems, as-engineered, as constructed reconciliation of ASME pipe and pipe support systems IE Bulletin 79-14 as-built review, and ASME code stamping and documentation requirements. During dis-cussions with the PAPSCOTT Coordinator and his QA engineer, the inspector questioned what roles QA would play in the verification /
surveillance of the various PAPSCOTT activitie The licensee provided a matrix of organization responsibilities for performance of the various QA functions and the inspector had no further questions on this issu However, with respect to several other verification / inspection pro-grams, such as the TP-8 program for component clearances, the TP-10 program for structural embedment verification, and the final building walkdowns prior to preoperational turnover, it was not clear to the inspector how such efforts would be consolidated and coordinated as construction is completed. NRC unresolved items (83-15-04, 84-15-01 o
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and 84-17-03) document specific questions in this area. The inspec-tor reviewed licensee responses to these questions as documented in YAEC Blue Sheets 66 and 85 and as provided by the PAPSCOTT program scope. Based upon the licensee positions and actions on the indi-vidual itens, the licensee appears to have implemented adequate corrective actions for the individual ite However, the larger question of how all the various inspection criteria (e.g.:
TP-8, TP-10) will be coordinated for the final building inspections remains. As in the case of PAPSCOTT, the licensee recognized the need for a structured approach to the final area inspection process, given the diverse criteria which must be checked. Pending licensee presentation of evidence of a programmatic approach to the final building inspection, to assure all verification programs are imple-mented as intended, this item remains unresolved (443/85-15-01).
4.6 Purchase Order Control The inspector also examined Purchase Order 249-7, regarding the penetration sealant contract work and Revision 4 of the Specification 249-7 on the same subjec This new contract had recently been awarded to Brand Industrial Services, Inc. (BISCO) and the inspector reviewed a draft copy of the BISCO QA Manual and a copy of a YAEC QA Audit Report on BISCO. An open NRC unresolved item (84-17-04) on the fire rating and hydrostatic head pressure requirements for certain penetration seals was satisfactorily answered by Revision 4 to Specification 249- Also, on 2/7/85, the licensee requested a revision to the Moderate Energy Line Break (MELB) study to clarify an inconsistency with some design criteria for penetration seal plate The inspector determined that based upon his review, the process for selection of a contractor for this new sealant work appears to be consistent with program and QA requirement .7 Contractor Control and Engineering Change Authorizat!on (ECA)
Utilization With regard to Construction Manager control of individual contractor work, the inspector noted a UE&C Field General Construction Proced-ure, FGCP-27, governing Contractor Interface on Released Equipmen However, with regard to other contractor interfaces, there was no generic document to assign responsibility for the interface proces As an example, a design change (ECA 05/102323A) was issued to attach an I&C support to an ASME pipe support with the pipe support struc-tural member being strengthened by stiffener plates on either side of the beam we Since the UE&C I&C organization could not jurisdic-tionally attach the stiffener plates to the pipe support (Note:
Pullman-Higgins (P-H) would be called upon to modify the ASME support under their jurisdiction), they completed the I&C support installa-tion, inspected, accepted, and turned it over to start-up without the
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stiffener plates installe The inspector interviewed P-H engineer-ing and QA personnel and learned that P-H was not aware that stiff-ener plates had to be added to their pipe supports because the pipe support drawing had not been included as an affected drawing on the
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Engineering Change Authorization (ECA).
This problem was discussed with construction manager, QA and engineering personnel and procedural changes are forthcoming to address stiffener addition, particularly where contractor interfacing is require The inspector informed licensee management that this specific case of an interface control problem constituted one example (See Paragraph 6 for other examples) of a violation of 10 CFR 50, Appendix B, Criterion I (443/85-15-02).
Also, as in the case of ECA 05/102323A, other ECAs (eg: 25/102267A)
were identified to be lacking a list of all drawings / documents affected by the subject design chang This, along with other examples provided in paragraphs 5 and 8 of this report, reflects a weakness in the administrative control of design changes.
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4.8 Independent Measurements /In-Process Work Sampling The inspector also made independent measurements on some pipe sup-ports within containment to verify ECA implementation, as sampled from a design change log. He reviewed high-strength bolting criteria for several disciplines and specifically reviewed the work being accomplished to HVAC installation procedure, IP-21. The HVAC QA supervisor was interviewed, NCRs and record files examined, and a
~ YAEC Audit Report of HVAC activities reviewed. UE&C QC organization provides Level I inspection support to Pullman Construction
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5-Industries (PCI) as the HVAC contractor. Since this same QC organ-ization had provided QC to the UE&C organization which had previously done the work, the transition of procedures, records, and program appeared to be adequat .9 Conclusions
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Except for the weaknesses and part of a violation discussed above, the inspector found the licensee's Quality Assurance and Administra-tive Control measures to be conducted in accordance with the regulatory requirements and licensee's commitment '
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5.0 Design Change Control Areas of design change control reviewed during this inspection were:
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Program for design changes per Engineering Change Authorizations (ECA)
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Program for design changes per Nonconformance Reports (NCR)
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Translation of site design change controls into a new site procedure governing in part, design changes per NCRs
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UE&C Engineering Assurance surveillance of UE&C safety-related activities
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Change Document Tracking system The above areas were inspected in relation to the RHR, Safety Injection, and Diesel Generator (DG) Jacket Cooling Water Systems. Also, part of the DG Jacket Cooling Water System was walked down and inspected for conform-ance to applicable P& ids, isometrics, ECAs and NCR The details and findings for each inspection area are discussed belo .1 Organization UE&C, Philadelphia, provides the engineering, design, and construc-tion management services for Seabrook Unit 1. YAEC provides project administration, overall control of the facility design, construction coordination, quality assurance and facility licensin YAEC also conducts post-construction activities, such as preoperationel test-in Westinghouse Electric Corporation has furnished the nuclear steam supply system (NSSS).
Prior to construction restM % sly 1984, numerous contractors were involved in Seabrook cos W ,i activitie Following restart, these activities were consliamt and UE&C was given responsibility for the majority of remaining construction. In turn, many design and design change responsibilities were transferred from the UE&C Home Office in Philadelphia to the sit .2 Engineering Change Authorization (ECA) Program An ECA is one of the documents used by the licensee to authorize design changes. ECAs are used to identify, document, and control changes and/or exceptions to drawings, specifications, calculations, or other design documents. A Request-For-Information (RFI) can be
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l 18 I used when no change or exception to a design document is required, but interpretation or clarification is neede Both ECAs and RFIs are governed by - AP-15, " Project Design Changes, Engineering Change Authorization and Request-For-Information," and TP-23, " Supplemental Information for Design Change and Nonconformance Disposition Programs."
The inspector selected a sample of ECAs and reviewed them for the following attributes:
--
adequacy of change description
--
reason /need for change
--
evidence of technical justification in ECA disposition
--
adequacy of technical justification
--
availability of calculations /other analyses
--
affect on original design intent
--
independence of reviewers and approvers / evidence of inter-disciplinary review when required
--
identification of "affected" documents
--
involvement of Authorized Nuclear Inspector (ANI) in ASME-related items
--
implementation of ECA disposition
--
consistency with overall program requirements of AP-15 The ECAs reviewed and discrepancies identified by the inspector are listed below:
19/105466A No calculation referenced. (Drawing must be retrieved before calculations can be identified.) No reason given in disposition as to why flex hoses in a line being evaluated for upgrading to ASME, Class 3 were not or need not be evaluate /105713A Incorrect drawing " note" referenced - minor revision needed to correct EC /3605A/B No discrepancies identified.
.
73/3552A No calculations reference /7226A TP-8 violations - Program requires dispositioning per an RFI when no design changes are mad /3836A No discrepancies identifie /104048A Support drawing not listed as an "6ffected" documen /101560B No discrepancies identifie /102323A Support drawing not listed as an "affected" documen . . __ _ - . _. _ _. _._. _.-
r
.
The inspector discussed the disposition of ECA 19/105466A with licensee representatives to determine why flex hoses, which are part of upgraded lines on the DG Jacket Cooling Water System, were not included in the analysis leading to the ECA dispositio The inspector was informed that these flex hoses were supplied by the DG vendor (Colt) and had been manufactured to standards which were equivalent to ASME Section III, Class 3 requirements. The inspector reviewed SER Section 9.5 and determined that NRR had accepted the design of the DG engine-mounted cooling water piping and associated components as being equivalent in design to ASME, C1.3 requirement The flex hoses in question are part of the vendor-supplied DG asso-ciated components. The inspector agreed that because the affected lines were being upgraded to ASME, C1.3 and the flex hoses had already been accepted as being equivalent to ASME C1.3, the flex hoses need not be part of the analysis. (See Section 5.4.) The inspector had no further questions concerning this issu The inspector concluded that the discrepancies identified above (except for the flex hose concern) are in conflict with the licen-see's procedure, AP-15, and are considered part of a programmatic weakness in design change control, as discussed in Section 5.8 of this repor .3 Design Changes per Nonconformance Report (NCR) Program Following. construction restart, the licensee approved the use of NCRs for authorizing design change ASP-3, "Nonconformances," was approved as the site method for initiating, dispositioning, control-ling, and completing field work pertaining to a nonconforming condi-tion. QA-15, " Nonconforming Material, Parts, or Components," governs UE&C's use of NCR Both ASP-3 and QA-15 require the dispositioned nonconforming condition to result in a document that provides all the required verified technical information necessary for implementation.
.
Two of four possible dispositions for an NCR are " accept-as-is" and
" repair," both of which involve deviations from the original desig NCRs dispositioned as such require design change controls similar to those placed on ECAs. To determine whether such controls were being implemented, the inspector selected a sample of NCRs and reviewed them for the following attributes:
--
description adequacy for the nonconforming condition
--
evidence of technical justification in the NCR disposition
--
adequacy of technical justification
--
availability of calculations / analyses
--
affect on original design intent
--
independence' of reviewers and approvers / evidence of inter-disciplinary review when required
--
identification of "affected" documents
--
involvement of ANI in ASME-related items
--
identification of nonconforming items in the field via " HOLD" tags
--
use of Limited Work Authorizations or Work Requests to perform work on nonconforming items
--
consistency with overall program requirements of ASP-3 The NCRs reviewed and discrepancies identified by the inspector are listed below:
82/509 No discrepancies identified.
93/1285A No discrepancies identified.
82/383 Inaccurate problem description with no additional clarifi-cation given in the interim action disposition. Indeter-minate status on need to evaluate for 50.55(e) reporta-bility.
82/373 Same discrepancy as in 82/383.
74/2957 No discrepancies identified.
93/1352A No discrepancies identified.
82/513A No discrepancies identified.
82/513B No discrepancies identified.
82/513C Misclassification of valve operato Inaccurate problem descriptio Lack of technical justification evident as part of an " accept-as-is" dispositio Inadequate and-inaccurate justification for determination of nonreporta-bility under 50.55(e). No traceability for RFI 99/105921A (issued as result of NCR 82/513) back to the original problem in 82/513. "Still Valid" information from Revision B not included in Revision C.
82/522A No discrepancies identified.
54/5332 No discrepancies identified.
73/9609A No discrepancies identified.
73/7432A No discrepancies identified.
73/10558A Lack of technical justification evident as part of an
" accept-as-is" disposition.
74/3058A No discrepancies identified.
82/501A Lack of clarity as to classification of a safety-related component.
93/667 Voided in error - misinterpretation of seismic design requirements (See Section 8.4 for details).
93/666 Voided in error - misinterpretation of seismic design requirements (See Section 8.4 for details).
74/2532B No discrepancies identifie The inspector discussed the subject of apparent lack of technical justification for " accept-as-is" dispositions on NCRs 82/513C and 73/10558A with the licensee. NCR 82/513C involved failure of four safety-related control valves to completely close, and NCR 73/10558A involved zero gap violations on a pipe support. Neither NCR dispo-sition identified nor referenced details of the justification use Through further discussions with Site Engineering and Startup per-sonnel, the inspector determined that technical justification did exist, but not in a readily retrievable manner. This lack of evident technical justification along with the discrepancies identified above is in conflict with the licensee's procedure, ASP-3, and is con-sidered part of a programmatic weakness in design change control as discussed in Section 5.8 of this repor .4 Diesel Generator Jacket Cooling Water System The Diesel Generator (DG) Jacket Cooling Water System (JCWS) main-tains the temperature of the diesel engine within a safe operating range under all load conditions and maintains the engine coolant preheated during standby conditions to improve starting reliabilit The JCWS is designed to Seismic Category I, ASME Section III, Class 3 requirements. Engine-mounted piping and associated components (not necessarily engine-mounted) are considered part of the DG package supplied by Colt Industrie As part of the design change control review, segments of the DG JCWS were walked down and inspected for conformance to applicable P& ids (F-805019, F-202103), isometric drawings (DG-4423-01, DM-5503-04),
and ECAs and NCRs affecting those drawings. As a result of this inspection, the inspector identified the concern regarding ECA 19/105466A as detailed in paragraph The inspector did bring to the licensee's attention the lack of an ASME Code break between the Expansion Tank (ASME, C1.3) and demin-eralization line, DM-5503-05, on P&ID F-202103 (non-ASME). The 1 licensee agreed that a Code break was required and issued ECA 02/106741 to indicate that the ASME, C1.3/non-ASME break is located at the nozzle weld on the Expansion Tank in Train A and Train The inspector identified no further discrepancie .5 Design Change Control Requirements Prior to construction restart, design changes were dispositioned per ECA Following construction restart, the licensee approved the use of NCRs for design changes. To control NCRs and their use as design w______________-_-_-
.
change documents, the licensee developed and approved ASP-3, "Noncon-formances," and revised TP-23, " Supplemental Information for Design Change and Nonconformance Disposition Programs." The inspector reviewed these procedures in relation to existing design change controls of AP-15 and noted the following differences:
--
AP-15 requires all contents of a superseded ECA be included in a revised EC (ASP-3 does not address this for design change NCRs.)
--
TP-23 requires that ECAs have "affected" documents. (TP-23 does not explicitly distinguish between design change NCRs and other NCRs, and therefore, does not explicitly require "affected" documents for design change NCRs.)
--
AP-15 requires that ECAs affecting an existing UE&C or contrac-tor procedure be followed up by an Interim Procedure Change (IPC) within five working days after the ECA is issued. (ASP-3 does not identify instances in which NCRs cannot be used for design changes. If a design change NCR can indeed be used to change a procedure, ASP-3 does not address the IPC requirement.)
--
AP-15 requires ECAs be incorporated into affected documents within 180 days. (ASP-3 requires incorporation within 60 days.)
--
AP-15 requires a monthly review for unincorporated ECAs. (ASP-3 requires a quarterly review for NCR incorporation.)
The inspector discussed the above differences with the licensee. The inspector was informed that a consistency review between AP-15 and ASP-3 had not been completed during the development of ASP-3. How-ever, the licensee commented that the individuals responsible for the development of ASP-3 were individuals intimately involved with AP-15 development and implementation. Following further discussions, the licensee initiated a review to identify all the differences between the two procedures and evaluate the applicability of AP-15 design change controls to ASP- This lack of a consistency review to ensure that all applicable design change control requirements of an existing site procedure (AP-15) were incorporated into a new procedure (ASP-3), which re-quired equivalent design change controls, is considered part of a programmatic weakness in the licensee's administration of the design change control program. This weakness is discussed in Section 5.8 of this repor The inspector identified no further discrepancie I
. - -. . _ - - - - _ _ - . - _ . . _ _-
.
- -
,
5.6 Change Document Tracking System
'
The licensee has implementd a new tracking system for design changes. This system, identified as Change Document Tracking (CDT),
is one subsystem of the feabrook Construction Information System
>
(CIS). Other subsystems include: Project Completion / Incomplete Items System, Hanger Status System, and Unit Cost System. CDT allows
an individual to identify outstanding and historical design changes affecting a particular drawing, specification, or other design docu-ment because the design change documents are indexed to the design
! document CDT tracks design incorporation, field work completion (for NCRs), and general design document status.
'
In order to assure the quality of the system, CDT has been developed in a manner that prevents anyone other than the responsible data-entry individuals from changing and/or adding to the data base. Data-
, entry and changes to the data base have been assigned to a limited i
number of people onsite. However, retrieval of data has been made available to anyone onsite requiring such information. CRT terminals i are located throughout the site. In the event CDT is down, provis-ions -have been made to continue operation using a manual logging
<
system. Also, hardcopy printouts of CDT data are maintained at all drawing stations with updates to the printout being made on a weekly basis.
Throughout this inspection, the inspector used the CDT to retrieve data on the RHR, SI, and DG JCWS. The inspector found the system easy to understand and use. However, the inspector did note that CDT is still being updated with historical data. Until this historical data has been entered into the data base and further debugging of the system is completed, individuals cannot rely solely on CDT to provide them with all the pertinent design change informatio The inspector identified no discrepancie .7 Engineering Assurance j In addition to YAEC's surveillance of UE&C, the onsite Engineering Assurance (EA) group of UE&C conducts surveillances of certain UE&C l safety-related activities, such as the use of ECAs and NCRs in rela-tion to their procedural requirement EA prepares a checklist
,
identifying the requirements of a particular procedure (e.g. AP-15
'
for ECAs). The checklist represents the formal surveillance report.
!
.
J
,
_ - _ _ _ _ _ _ . _ . . _ _ , .- __ _ __ _ , _ , _ . -.-_ .__ _._ -.
. _ _ _ .. _ _ . __ _ _ _ _ _ _ . _ _ _.
k i
j< 24
!
The inspector reviewed the following surveillance reports on NCR
activities:
i
! 553 3/11/85 Postponed because of revisions being made to NCR
! progra l 559 3/13/85 Postponed because of revisions being made to NCR
- program.
588 4/18/85 No EA-identified discrepancies.
l 600 5/8/85 No EA-identified discrepancie ! 601 5/10/85 No EA-identified discrepancie i
The inspector had no questions, but did note that the surveillances i
were only administrative in nature, i.e., EA reviews items such as timely resolution, maintenance of NCR files, and review and approval independence. The EA surveillance does not include a review of the
- technical conten The inspector also reviewed the following EA surveillance reports on i
ECA activities:
,
576 4/14/85 [No EA-identified discrepancies in these
- 586 4/18/85 surveillances.]
'
592 4/26/85 606 5/14/85 i 618 5/31/85
!
The inspector had no questions concerning these surveillances, and j concluded that although the surveillance activities of the EA group i do not include a review of the technical aspects to ECAs and NCRs, i they do provide an additional level of review for quality assuranc The inspector identified no discrepancies.
l l 5.8 Conclusions 4 It is apparent that the licensee has taken positive steps in stream-
} lining the design change process, while still providing adequate
! controls, by relocating much of the Architect / Engineering staff from the Home Office in Philadelphia to the site, and allowing certain
'
I design changes to be approved per NCRs. The licensee has also i revised the ECA and NCR form, making them very similar to one another, thus reducing the number of different procedural require-l ments.
,
Although the inspector concluded that the overall design change con-trol program is adequate, the inspector informed the licensee that a j weakness in the administration of the program in relation to site
- procedural requirements did exist as evidenced by the following
i i
i
)
i i
l
-. - - - . - - - . - - - - -- -
.
25 discrepancies in NCRs and ECAs, such as lack of evident tech-nical justification for " accept-as-is" dispositions, lack of
"affected" documents being identified, and approval of inaccur-ate problem and disposition descriptions, and lack of a consistency review to ensure that all design change control requirements of an existing site procedure (AP-15) were reviewed ,for applicability to a new procedure (ASP-3) requiring design change control The inspector concluded that the above discrepancies could lead to inadequate design, construction, inspection or testing, and are representative of a programmatic weakness in the administration of the design change control program (443/85-15-03).
6.0 Mechanical Components and Supports This portion of inspection covered the following areas:
Piping and pipe support installations for RHR and SI System *
Piping and pipe support as-built reconciliation progra *
Heating, ventilating and air conditioning (HVAC) system Various functions and activities contributing to the design and construc-tion of mechanical installations before the construction shutdown and after the restart in 1984 were reviewed to determine whether acceptable engineering practices, regulatory requirements, and licensee commitments had been met. The details and findings for each inspection area are discussed belo .1 Organization Engineering and design activities related to piping, pipe supports and HVAC system supports are performed by United Engineers and Constructors (UE&C), the Architect / Engineer (A/E) of recor Pullman Power Products (PPP) previously known as Pullman Higgins (P-H), is responsible for the fabrication, erection, and quality control activities related to installation of safety-related piping and supports before the shutdown and af ter the resumption of con-struction. As a result, installation and inspection procedures for these activities remained unaffected by the restart. UE&C is respon-sibile for the second level surveillance and audits of PPP activities as well as the resolution of construction related Engineering Change Authorizations (ECA's) and Nonconformance Reports (NCR's). The licensee's quality assurance group provides the third level QA/QC audits of PPP activitie The licensee's walkdown of completed piping and support installations for "as-built reconciliation" has just starte This activity is conducted by UE&C as part of the Piping and Pipe Support Close Out Task Team (PAPSCOTT) progra The fabrication, erection, and quality control activities related to HVAC duct work and support installation were performed by Hirsch-Arkin-Hershman Fabricators (HAH) prior to the construction shutdown in 1984. After the restart of construction, the fabrication and erection of HVAC installations are the responsibility of Pullman Construction Industry (PCI), while quality control activities are being performed by UE&C.
6.2 Piping and Pipe Support Installations The Residual Heat Removal System (RHR) piping, between the RHR pump RH-P-8B and the cold leg of the Reactor Coolant System (RCS),
was selected to assess the level of compliance of piping and pipe support installations with the applicable codes, standards, and specification This was accomplished by a review of quality docu-ments, examination of pipe and pipe support installations including independent measurements of parameters such as, pipe wall thickness, pipe ovality and pipe support weld dimension Applicable sections of the documents listed in Attachment I were reviewed in part to verify that applicable regulatory, requirements, design basis and FSAR commitments for system components and supports, are correctly translated into specifications, procedures, and instruction The documents reviewed included specifications and procedures gover-ning the fabrication and erection of piping and pipe supports includ-ing concrete expansion anchors. The review also included technical procedures governing the location of attachments to embedded plates and attachments to building structural steel (Beam Verification Program). Procedures used by design personnel in the preparation, documentation and control of pipe support design calculation were also reviewed during this inspectio No violations were identified during this revie However, lack of clarity and conflicting gap tolerances in Procedure JS-IX-6 contributed to the violation discussed in item (2) of para-graph 6.3 belo __ _ . _ _ _ _ .
.
27 .
6.3 Verification Walkdown and Independent Measurements Inspection A physical inspection was performed of piping and pipe support installations on the RHR system piping between the nozzle of pump RH-P-8B and the cold leg of the RCS. The purpose of the inspection was to verify that installed configuration are complying to construc-4 tion drawings and/or any field authorized changes. The verification effort was conducted using visual inspection in addition to perform-ing independent measurements of selected piping and support compo-nent The verification of piping and pipe support installations included the following attributes:
Checking actual configuration against support drawing, including dimensions;
Checking directions in which hangers restrain piping and clear-ances between pipe and hangers;
Checking connections to the proper structure;
Checking sizes of weld on hangers; including welded attachments j to pipe;
,~
- Checking baseplate dimensions and location of structural attach-ment on the baseplate;
Checking baseplate bolts for tightness, edge distance, and minimum embedment for a representative sample of anchor bolts;
Checking that restraint bleed holes are open and free from foreign material;
Checking valve types, orientation and tagging;
Checking proper grounding of floor mounted supports;
,
Checking code data plates for shop welds; and a Checking that movement of piping due to vibration, thermal expansion, etc., would not likely contact other pipes, supports, I
equipment or components.
,
- Verification by independent measurements included the following
attributes:
,
!
A
.
Piping outside diameter (00) at two perpendicular axes to check for cross section ovality;
- Piping wall thickness;
- Fillet weld measurements;
Dimensional verification of support structural members including baseplates; and
Dimensional verification of valves, flanges and support location along piping run A listing of the piping systems and pipe supports examined during this inspection is provided in Table 6- Table 6-1 Listing of RHR System Piping and Supports Installations Inspected Isometric Piping Pipe Support Independent Drawing N System N Number Valve N Measurement RH-157-01 1-RH-157-1-601-8" 157-SH-1 8"-RH-V40 P 1-RH-157-1-601-8" 157-SG-2A S 1-RH-157-1-601-8" 157-SH-28 S 1-RH-157-1-601-8" 157-RG-3 S 1-RH-157-1-601-8" 157-RG-4 1-RH-157-1-601-8" 157-RG-5 RH-157-6-601-3/4" 1-RH-3/4"-V43 RH-157-02 1-RH-157-1-601-8" 157-SG-7 S 1-RH-157-1-601-8" MS-157-SG-10 8"-RH-V45 RH-157-03 1-RH-157-1-601-8" 157-RG-11 P 1-RH-157-1-601-8" 157-SV-16 RH-158-01 1-RH-158-2-601-8" 158-SH-8 S 1-RH-158-2-601-8" 158-SV-2 RH-158-02 1-RH-158-2-601-8" 158-SG-7 1-RH-158-2-601-8" 158-SG-4 HCV-607 RH-158-03 1-RH-158-2-601-8" 158-SG-9 1-RH-158-2-601-8" 158-RG-11
_ _ _ _ _ - _ - _ .
.
Table 6-1 (Continued)
Isometric Piping Pipe Support Independent Drawing N System N Number Valve N Measurement RH-158-04 1-RH-158-4-2501-6" 158-SG-24 1-RH-158-4-2501-6" 158-SG-23 1-RH-158-4-2501-6" 158-SG-33 1-RH-158-4-2501-6" 158-A-20 158-RH-05 1-RH-158-3-2501-8" 158-SG-17 S (M/S-275-SG-5)
1-RH-158-3-2501-8" 158-SG-16 1-RH-158-3-2501-8" 158-SG-15 158-RH-06 1-RH-158-3-2501-8" 158-SV-14 RH-8-V26 158-RH-07 1-RH-158-5-2501-6" 158-SG-25 RH-6-V29 1-RH-158-5-2501-6" 158-SG-26 RH-6-V63 1-RH-158-5-2501-6" 158-SG-28 158-RH-08 1-RH-158-5-2501-6" 158-SG-30 1-RH-158-5-2501-6" 158-SG-32 1-RH-158-5-2501-6" 158-SG-33 1-RH-158-5-2501-6" 158-RM-35 S1-203-04 1-SI-203-2-2501-10" Notes: Designations (P) and (S) for independent measurements verifica-tion refer to piping and support respectivel . The correlation between pipe supports designation and loading restraint function is tabulated below:
Type Symbol Restraint Function D. W Sesimic Transient Thermal Anchor A X X X X Support Hanger SH X X Support Guide SG X X X X Restraint Guide RG X X X Variable Spring SV X Snubber RM X X
_ _ _ _ _ __ ._ _ ____. _ _ __ _ _ _ _ _ _ _ _ . _ - __ _ - _ _ _ _ .
,
The inspector identified the following concerns: i
'
(1) Pipe Support No. 157-SH-2B is a bi-lateral box structure restraint on a horizontal pipe run, located approximately 9'-7h" from the RHR pump (RH-P-88) discharge. A zero clearance was i specified between the piping and the top member of the support structure. The support was constructed and inspected according to the design drawing. The design temperature for the RHR Line
- 157 is 400 F. Upon line heatup, thermal expansion would bind
'
.
the piping to the support. This in turn will induce local com-pressive stresses in the piping. Additionally, it will inhibit i
the free axial movement of the line contrary to the assumptions of the piping stress analysi l The licensee was notified of this finding and was requested to ,
i
'
identify similar pipe supports for which a zero clearance was '
specified on the design drawin '
,
In a meeting conducted onsite between the NRC staff and repre-
-
sentatives from the licensee to discuss actions initiated by the
^
license in this regard, UE&C informed the staff that a survey is being conducted on 1740 pipe supports which were designed before the issuance of the design guidelines for pipe supports in
- February of 1980. At the conclusion of this inspection the
- licensee had completed reviews for 900 support Of the 900 l supports reviewed by UE&C, 21 supports had zero clearance
'
The eight anchors
'
specified (8 anchors and 13 bi-laterals).
were evaluated and qualified by analysis in a study performed in 1 1984 for all anchors with specified zero clearance. Evaluation of the thirteen bi-lateral supports will be deferred until the ;
completion of the remaining 840 ~ support Upon completion of t the review, all identified supports with zero clearances will be analyzed and corrective action, if needed, will be taken. The licensee committed to complete this review and report the find- '
'
ings within sixty day ! The design and installation of bi-lateral pipe restraints with l
'
zero clearance is a violation of ASME Section III, Subsection NC '
3624.1(c) which requires that hangers and supports to be designed to permit expansion and contraction of the piping
- between anchors. It is also in violation of Section 3.5.7.1 of
,
UE&C Specification 9763-006-248-51 for the assembly and erection i of piping and mechanical equipment, which requires all hanger 1 installations to accommodate for thermal growt The above l
)
identified concerns are contrary to the requirements of 10 CFR !
50, Appendix B, Criterion I and UE&C Procedure QA-1 in that UE&C as A/E did not assure the control of quality related activities j relative to design. This finding along with the concerns iden-
'
tified in paragraph 4.7 and item 2 below collectively constitue a i
- violation. (443/85-15-04)
,
1
<
- - - . . - - - _-- -- - .-_- . . - - - - _ - - _ _ _ . -
l I
.
i 31
,
- (2) Pipe Support No.157-SG-17 is a bi-lateral restraint on a
. horizontal run of the RHR pipin The support drawing ;
i specifies a 1/16" clearance between the piping and the top
. member of the support structur However, the support was i
found to be installed with zero clearance. A review of the
- requirements for pipe gaps in Section 11.3.1 of (PPP) Pro- cedure JS-IX-6, and further discussions with UE&C and (PPP)
l personnel, indicated that the requirements for clearances
!
in the installation and inspection of pipe hangers were i being interpreted differently by different organizations i l- such that supports with specified clearances were accepted l
- as long as a minimal clearance existed during fit-up. This l was attributed to the vagueness and contradiction in the requirements of the above procedure. The licensee was
! requested to evaluate the identified deficiency and its ,
!
^
cause, in addition to the identification of other supports '
which are installed and inspected with similar clearance problem. Results of the licensee's evaluation are expected within sixty day !
i This is also another example of a violation of the requirements in ASME Section III, Specification 345-51, Criterion I of i Appendix 8 to 10 CFR 50 and UE&C Procedure QA-1 in that UE&C as discussed in item 1 above. This is the third example for the
,
violation discussed in item 1 above. (443/85-15-05) -
6.4 Review of Design Activities i
Review of design activities was performed by auditing pipe support design calculations for the RHR and SI system piping. Specifically,
, M/S 275-SG-5: Multiple pipe support which includes the support for
'
RHR piping 158-SG-17 and !
M/S 236-A-5 and M/S 236-5-236-RG-3 for SI line No. 236-1-601-2".
! were reviewed to verify that the calculations were performed accor-
- ding to administrative engineering and design procedures and that j they meet the regulatory requirement In addition, a review was performed of various Engineering Change i Authorizations (ECAs) which addressed piping an1 support installa-
.
tions for the RHR piping line #157 and 158. The review was intended I
to assess the cause of the change or deviation from the design draw-
ing and the technical adequacy of the engineering resolutions or alternatives provided. The reports reviewed are listed below in j Table 6-2 along with the particular component or support affecte ,
j j
l I L i
i t
. - _ _ _ _ . . _ ___ _ ._
.
i Table 6-2 ECAs Reviewed for RH-157 and RH-158 Piping Document Component Affected
--
ECA 25/100060-B 158-RM-31(Support)
--
ECA 25/105013-A 158-RM-18 (Support)
--
ECA 735131-A 157-RG-8 (Support)
--
ECA 25/8298-A 2487-SG-205 (Support)
--
ECA 192552-A RH-155-2-601-8" & RH-158-2-601-8"
--
ECA 25/101235-B Spec. 18-17, 248-43 & 46-1
--
DCN 08/0669-B 202-RM-15, 201-RM-15, 203-RM-15 and 204-RM-15(Support)
155-RM-31, 158-RM-35, 163-RM-12 and 162-RM-13 (Support)
--
ECA 191458-A FWO409 on RH-158-4-2501-6"
--
ECA 253525-A 158-SG-23(RHR-Support)
, --
ECA 252994-A 157-SG-13 and 157-SG-14 (Supports)
--
ECA 252363-C 158-SG-33(Support)
--
ECA 250150-A 157-SG-2A and SH-2B (Supports)
The inspector identified the following concerns:
The review of design calculations for pipe support No. 158-SG-17 (included with M/S 275-SG-5), indicated that the calculations for the weld design, between part No. 4 (tube steel) and part No. 14 (channel section), were not performed, though it was specified on the design drawin Upon discussion of this finding with UE&C design personnel, it was evident that the requirement for documenting the design assumptions was not always adhered to, as required by the General Engineering Design Procedure (GEP-0005), and the Administrative Procedure (AP-22)
for design calculation The licensee acknowledged the need for training for the pipe support design engineers to emphasize the requirements for design control as described in UE&C Procedures AP-22 and Procedure PSG-1-3001 for preparation, documentation and control of pipe support calculation The licensee agreed to complete the required training by August 15, 1985. This item is unresolved pending the licensee's evaluation of the identified calculation deficiency and completion of the proposed
'
training (443/8575-06).
i
-
. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
.
.
6.5 Piping and Pipe Support As-Built Reconciliation Program A review of the piping and pipe support as-built reconciliation pro-gram was performed during this inspection. This activity is being conducted by the Pipe and Pipe Support Close Out Task Team (PAPSCOTT).
The charter of the PAPSCOTT program is threefold:
--
Reconcile as-built piping and pipe support installations
--
Complete piping preoperational thermal / vibration testing
--
Closecut of the above tasks to support the commercial operation date The program is headed by a task team coordinator, who is assisted by an independent review tea The various disciplines contributing to this ef fort are headed by a sub-task team coordinator. These activ-ities include: balance of plant (80P); NSS reconciliation; NSSS tFermal/ vibration; safe team; B0P vibration; construction; QA/AI; startup; and planning / schedulin A flow chart (Figure 6-1) identifies the major steps and sub-programs contributing to the PAPSCOTT effort which are required to support the ASME system hardware completion and documentation close-out for plant licensin The various steps and procedures required for the execution and completion of each sub-task in the above chart are identified in a memorandum from the PAPSCOTT task coordinato Some of those pro-cedures were reviewed in the course of this inspection, with partic-ular emphasis on those procedures pertaining to the reconciliation and analysis of as-built piping and support installations. The pro-cedures reviewed are listed in Attachment 1 of this repor The staff also reviewed a PAPSCOTT program status report which included charts identifying the starting data, percentage completion and planned completion date of the various activities in this program.
6.6 _ Review of ASME System Field Data Completion Program The inspector conducted a sample review of the on going effort by UE&C's team for the ASME system field data progra The team con-sists of sixteen members who are performing and coordinating the walkdowns and draf ting of as constructed configurations. The team activities started a few months prior to this inspection. Since many of the pipe support installations are at various degrees of comple-tion or had not received a final QC inspection, the as-built isometrics are being prepared and marked as preliminary pending the completion of QC inspections (QAC).
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FIGURE 6-1 ASME COMPLETION PROGRAM FLOW CNART l
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' AS-ENGINEERED j ANALYSIS / REDESIGN
i s u
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.o INITIAL DESIGN m INSTALLATION
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- i y I
AS-CONSTRUCTED INSTALLER "NA"
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RECONCILIATION s AS-CONSTRUCTED m N-5 CODE DATA i SCOPE DEFINITION
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PROGRAM
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REPORTS $
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"N" p N-5 CODE f DATA REPORTS
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RECONCILIATION , ,
AS-BUILT / CHANCE m RECONCILIATION
' ANALYSIS i CONTROL PROGRAM N-3 CODE DATA REPORT
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A e
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The licensee's field team activities are conducted according to pro-cedures FAEP-1, TP-26, and TP-2 A review of three reconciliation piping packages for the safety injection system was performed during this inspection. Each package contains a preliminary piping isometric drawing, marked up field verified drawing by Pullman and applicable ECA's and NCR' The reconciliation packages reviewed included model 511.55, model 515.20 and model 515.4 In addition, a walkdown was conducted by the staff to verify the conformance of as-built configurations of piping and support systems in the above models to the reconciliation drawings. Table 6-3 iden-tifies these piping systems by isometric numbers and related supports inspecte Table 6-3 Piping Systems and Supports Inspected Piping Isometric N Support N .55 263-SG-3 511.55 263-RG-4 511.55 263-RG-5 515.20 M/S 236-RG-2 515.20 M/S 236-A-5 515.20 236-SG-7 515.40 M/S238-SG-3 515.40 238-RG-2 515.40 238-SG-7 No violations were identified.
6.7 Safety Related Heating, Ventilation, and Air Conditioning Systems (HVAC)
The HVAC activities performed by HAH fabricators prior to the shut-down in 1984, and those performed by PCI after the restart were reviewed to determine the adequacy of HVAC systems completed and accepted by Q .
Applicable sections of the documents relating to the fabrication, installation and inspection of HVAC duct, equipment and supports were reviewed in part to verify that applicable regulatory requirements, design basis, and FSAR comments for HVAC safety related systems are correctly translated into specifications, procedures and instruc-tion The documents reviewed are listed in Attachment 1 of this repor No violations were identified during this review.
6.8 Walkdown Inspection of HVAC Ductwork, Equipment and Support Installations The inspection included visual and physical examination as well as independent measurement The verification of HVAC system instal-lations included the following attributes:
- Checking actual configuration against component support drawings, including dimensions;
- Checking directions in which hangers restrain ductwork and maximum clearances between ductwall and hangers;
- Checking connections to the proper structure;
- Checking sizes of weld on hangers and ductwork welded stiffeners and joints;
- Checking baseplate dimensions and location of structural attach-ments on the baseplate;
- Checking baseplate bolts for tightness, edge distance, and minimum bolt embedment for a representative sample of anchor bolts;
- Checking duckwork for uniformity of cross section and freedom of holes, dents and wrinkles;
- Checking for proper structural member sizes and bolt identifica-tion on hangers; and
- Checking for tolerance and gaps between hanger baseplates and concrete wal The HVAC system ccmponents and support installations inspected are tabulated in Table 6-4 including the location of the installations and applicable drawing number No violations were identifie _ _ - _ _ _ _ _ _ _ _ _ _ __ -
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Table 6-4 HVAC System Installations Inspected i Component
- FabricatorlType [ Component No.l Location IDrawing N ;
,
HAH l Fan Support lFN-20-33 l Control Bld I SM-604094 l i l l lEl 50' - 0" l ,
i HAH l Duct Support lFN-33-34 l Control Bld l l
, l l lEl 21' - 6" l 604094 l HAH l Duct Support lFN-22-59 l Control Bld l Fab. Dwg. # l
.,
l l lEl 50' - 0" [FN-22-59 1 HAH l Duct Support lFN-22-60 l Control Bld l Fab. Dwg. # l l l lEl 50' - 0" l 22-60 l
- HAH l Duct Support lFN-22-57 l Control Bld l Fab. Dwg. # l lEl 50' - 0"
'
l l l 22-57 l
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PCI l Duct Support lEAH-FN-69-2 lM.S. & I SM-60460 l l l IEl. 3' - 0" l l PCI l Fan Support lEAH-69 lM.S. & SM-604078-3 & l ;
,
l l IE1. 3' - 0" l ECA # 0680248A l i
, PCI l Duct Support lEAH-FN-68-2 lM.S. & l SM-604601-3 & l
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i l l lE1. 3' - 0" l ECA #0105576A l
) PCI l Duct Support lEAH-FN-69-1 lM.S. & l 604078-3 l
]
t l l lEl 3' - 0" l l
- PCI l Fan Support IFN-47A-478 l Containment l SM-604141-1 1 4 l .1 lEFW, El. 27' - 0"l l 3 PCI l Duct Support lFN-68-3 lM.S. & l SM-604078-3 l 9 l l 1 El. 3' - 0" l l
<
! PCI l Duct Support lFN-1-98 l Containment l SM-604-132-4 l j l l l E1.(-) 26' - 0" l l (
) PCI l Duct Support lFN-1-97 l Containment l SM-604-132-4 l j l l lEl (-) 26' - 0" l l I
6.9 QA/QC Involvement in Piping, Supports and HVAC Activities The licensee's audits for UE&C and other contractors activities in
+ the area of piping, pipe supports and HVAC were reviewed.
J The licensee's audits are conducted and reported according to the i requirements of the General Audit Procedure No. 9.1 of the Seabrook
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Station QA manual and Section Q-119 of the Construction Quality Assurance Guidelines (CQA).
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The licensee conducts four audits annually at UFLC corporate office in any discipline of engineerin Site audits are conducted once a year for every engineering discipline. These audits focused on the following procedures which implemented ANSI 45.2.11 requirements at the sit *
9763-PSG-1-3001 - Preparation, Documentation and Control of Pipe Support Calculations
- GEOP-0005 - General Engineering Design Procedure
AP-15: Admin. Procedure for Design Change
- AP-22- Admin. Procedure for Preparation of Calculation
AP-54: Admin. Procedure for Verification of Calculations The following licensee audit reports were selected for review: YAEC Seabrook audit report No. SA799CS332 on 1/16-25/1984 of HAH on site activities, in the area of QA program, procurement document control, instructions and procedure The audit identified four deficiencies which were subsequently resolve . YAEC Seabrook Audit Report No. SA810CS341 or 2/15-22/84 on site and HAH office in Philadelphia. The audit covered HAH QA pro-gram concerning the identification and control of materials, parts, and component Three deficiencies were identified in this audi . YAEC Seabrook audit report No. SA838CS363 on 6/26/84 of HAH at Seabrook station. The audit covered QA records and open SSCA items from previous audit No deficiencies were observe HAH's QA program at the time of the audit was limited to the review and turnover of quality assurance record . YAEC Seabrook audit report No. SA870VE029 was conducted at UE&C home office on 11/13-16/84 to review of the beam verification progra Thirteen deficiencies were identified during this review. Attached to the audit report was UE&C's response to the audit findings. As a result of this audit, a technical repre-sentative from YAEC was stationed at UE&C corporate office for several weeks to follow-up on the implementation of this progra i
39 YAEC Seabrook audit report No. SA888UE030 at UE&C corporate office on 1/28 to 2/1/85. The audit was conducted to verify the adequacy and the level of compliance to the established quality assurance program in design control, control of purchased mate-rial, and equipment and services in the instrumentation / control, and electrical disciplin The audit identified three deficiencies and two observations and closed out thirteen findings from previous inspection The licensee's conclusion from this audit was that UE&C was ade-quately implementing their QA program and engineering services for Seabrook projec . YAEC Seabrook audit report no. SA905UE031 at UE&C office on 4/22-26/8 The audit covered design control, procurement document control, audits, ' inspections, control of measuring and test equipment, handling, storage and shipment. The design portion of the audit covered HVAC and pipe support system. In the design control area, ten calculation sets were reviewed for pipe supports in addition to eleven calculation sets for HVAC system One deficiency was identified in the pipe support area, and two in the HVA No violations were identified.
7. Welding and Metallurgy The objective of this portion of the inspection was to determine the licensee effectiveness and program adequacy in controlling and performing welding activities in accordance with design requirements, SAR commit-ments, and applicable codes, specifications, and procedures. The effect of recent organizational changes in the welding effort was also reviewe Work in progress, completed work, records of completed work, and welding procedure specification documents were reviewed. An additional objective was to determine if the personnel involved in welding engineering, welding and inspection activities were adequately trained and qualified to perform their duties in accordance with the applicable requirement Welding activities related to the fabrication of American Society of Mechanical Engineers (ASME) piping for portions of the RHR and SI systems, various types of structural supports for the RHR and SI Systems and HVAC duct work were reviewed. These activities were conducted in accordance with ASME Section (SC) III NB, NC, and NF; B31.1; AWS D1.1, and AWS 09.1 Code Completed work package documentation reviews included weld history records, NDE inspection records and appitcable non-conformance reports (NCR's). Welder serial numbers were obtained from visual inspection of welds and weld history records. Qualification records for these welders were reviewed for conformance to the applicable code ..
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Welding conducted by Pullman-Higgins, PCI and HAH was inspected. Generic issues important to structural welding, such as, verbatim compliance to D1.1, qualification tests for flare bevel welds, and preheat were re-viewed. The UE&C adoption program for Pullman-Higgins ANSI B31.1 welding procedure specifications (WPS), procedure qualification records (PQR), and welder performance qualification (WPQ) records was reviewed. The details and findings for each of the inspection areas are described below:
7.1 Organization Installation, welding, NDE, and QC inspection of piping is performed by Pullman-Higgins with second level inspection and QA by UE& Installation and welding of HVAC ducts and supports is performed by PCI with QA/QC coverage by UE&C and QA surveillance by the license .2 General Welding Review The inspector reviewed the following documents related to the walk-down inspectio (Field welding by Pullman-Higgins)
Welding package for RH-158-01 (Class 2) which included the following:
8 welders WPQ records were reviewe * Welding package for RH-158-03 (Class 2) which included the
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following:
- Field welds F302, 302, 303
- NCR 4710
WPQ records of one welder
Welding package for RH-158-08 (Class 1) including the following:
- NCR's 2456, 3589, 2545, 4997, and 4930 which included records damaged by fire
.
- Verified certified material test reports for the following:
Consumable insert AT464107, 3/32" diameter E316 filler metal Heats A, C&D-4237T316
- Filler metal purchase order documents for P0's 27707 and 10219
Three welders WPQ records were reviewe The documents reviewed met quality program and codes and standards requirement The inspector reviewed the UE&C program for filler metal control and conducted an inspection of two filler metal issue stations and the warehouse storage area for filler metal Portable electrode ovens are properly employed for hygroscopic electrodes. Review of FGGP-17 indicated that UE&C recently changed the requirement for discarding electrode stubs to permit them to be discarded in more conveniently lccated recepticles than at the filler metal distribution center The inspector found a few electrode stubs on the floor adjacent to the pressurizer relief tank. This is considered to be an isolated case as the inspectors found no other improperly discarded stubs during the two week period of this inspectio Inspection of the filler metal distribution (issue) stations indi-cated that the filler metals were properly identified (with AWS/ASME designations), filler metal heat numbers were maintained, storage ovens were at proper temperature, thermometers were properly cali-brated and the filler metal issue QAE personnel were fully knowledge-able of their functions. The warehouse storage area inspected indi-cated the filler metals to be properly stored and identifie How-ever, one filler metal (utilized for balance of plant welding) was identified by its commercial designation rather than by AWS/ASME designation. Review of the applicable WPS showed that both designa-tions were indicated thus minimizing the adverse effect of using the commercial designatio The filler metal control system met licensee quality requirements and met or exceeded minimum codes and standards requirement The following filler metal certified material test reports (CMTRS)
were reviewe Filler Metal Size Heat Lot Manufacturer E70T-1 0.045 50573 -
Alloy Rods E70S-2 1/8"x5/32" 421N3602 -
Consumable insert (SANDVIK)
E70S-3 0.035 3101 -
RAC0 E70S-3 0.045 3101 -
RAC0 ERNiCrMo-3 3/32" NX96C2AK -
HAPD ER316L 3/32" C4735T316L -
ARCOS ERCuAt-A2 3/32" G5739 FMK-1 AMPC0 ERCuAt-A2 1/16" V9719 CYM-2 AMPC0 E70S-2 1/8" 065433 LINDE E308L-16 1/8" -
11097-1 SANDVIK E308L-16 3/32" -
50348-1 SANDVIK E309L-16 1/8" -
90147-1 SANDVIK E309L-16 3/32" -
90110-1 SANDVIK The material reviewed met applicable Codes and Standards requirements and purchase order requirement No violations were identifie (1) Performance Qualification Welding qualification records of P-H welders and PCI welders were reviewed. Included were welders qualified to ASME SCIX, AWS D1.1 and AWS 09.1 requirements. The inspector also observed a welder qualification test including cleaning, fitup, stencil-ing identification, welding, visual inspection, removal of bend specimens, bending, and visual inspection of bend results for a special PCI flux cored arc welding (FCAW) performance qualifica-tion required by DR 52-5137- The inspector also observed a standard D1.1 new hire PCI welder performance qualification test and the bending of the test assembl Review of PCI qualification records indicated deficiencies in the methods used to record the actual thickness welded and the
" mode of metal transfer" for short-circuiting gas metal arc welding (GMAW-S) welder Review of the PCI welder performance and UE&C welder performance program indicated that neither had an independent QC verifica-tion of the results of destructive or non-destructive tests nor an additional QC sign off of the performance qualification records, however, independence in the examination of performance qualification test plates is not an ASME Code requiremen _ _ _ _ . .- _ - - . . - .
d
The qualification recordkeeping meets the requirements of UE&C FWP-2 paragraph 3.6. UE&C provides QC surveillance inspection in the P-H and PCI welder performance area and the licensee performs QA surveillance audits on these activitie The inspector reviewed the system used by PCI for indoctrination training (S-FWP1.1/9.1) of new welders and found it to be an
"
acceptable method for the purpose intende During review of the P-H welder qualification records it became apparent that P-H is utilizing the interpretation of SCIX QW 404.28 for gas tungsten arc welding (GTAW) which indicates that qualification with any F6 filler metal qualifies for any other F6 filler metal including consumable inserts (QW 404.22 still applies). Discussions with UE&C and the licensee confirmed that this is considered a site wide positio UE&C stated that although F numbers are not listed in SFA 5.30, they purchase
- consumable inserts to both SFA 5.30 and the applicable SFA5.9 or SFA 5.18 specifications for chemistry which establishes an F i
number. The inspector indicated that this position met SCIX requirements as clarified by interpretations and was a judge-4'
mental engineering positio The licensee and UE&C committed that they would write a letter clarifying this position to avoid
! future confusion on this issue.
During the course of this inspection, DR-52-5137-A was written on the use of an unqualified procedure and welder by PCI. This was identified by the licensee. The inspector attended tech-l, nical meetings where the resolution of this problem was dis-
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cussed. It was determined that removal and re welding was less
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satisfactory than an after-the-fact qualification of the pro-
- cedure and welder. The inspector found the engineering solution to the problem to be acceptabl See paragraph 7.4 for the corrective actions taken by the licensee in this regard.
The welder qualification programs met requirements except as
- specifically note No violations were identifie (2) Preheat In the course of the review of welding specifications and pro-cedures it was noted that there is a plethora of preheat rules for welding similar structural type configurations (ASME SCIII NF, 831.1 and D1.1). This necessitated a further stud The UE&C general rules for preheat are specified in FWP-18 Para-graph 5.2.6.1 which states that preheat shall be in accordance i
with the applicable WPS and 5.2.6.3. Paragraph 5.2.6.3 states that preheat shall be the highest temperature required for the material (s) or material thickness (es) being joined.
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UE&C FWP-43 Rev. O specifies the preheat requirements for pip-ing, components and support welds fabricated in accordance with ASME SC III and ANSI B31.1. Paragraph 4.4.4 of FWP-43 indicates the preheat shall be the highest temperature for the materials or material thicknesses being joine This document also directly reproduces the applicable sections of the ASME and ANSI B31.1 codes, Although these codes are not explicit, the signif-icant UE&C Ularification statement is that the preheat is based on the thicker material joine Review of the materials uti-lized for fabrication indicated that there were essentially no materials utilized which exceeded the 0.3% carbon level refer-enced in the ASME and B31.1 codes. The thickest and most highly restrained joints welded are fabricated to AWS D1.1 (which clearly indicates that preheat is based on the thickest member being joined). Review of typical WPS and weld data packages indicates that preheat is correctly and conservatively addressed on both a " Codes and Standards" basis and on the more important engineering (metallurgical) basis even though the code reference documents are not explicit, at times confusing, and in some cases not conservativ No violations were identifie (3) Welding QA The inspector reviewed a rough draft copy of the licensee's QA audit of PCI (#SA916CS426) conducted May 28-31, 1985. As cur-rently written this audit will indicate 9 deficiencies and 2
, observation The deficiencies were in material storage, mate-
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rial traceability, document control and distribution, inadequate parameters for " pin" welding, and inadequate control of charge sheet Actions are being taken to recti fy these problem area Also reviewed were the following YAEC Field Quality Assurance Surveillance Reports:
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Date IMS# l
.x 4/10/85 E-01-13-01: PCI Welder Qualification 5/24/85 H-09-13-09: PCI Support Welding 5/14-16/85 H-09-13-09: PCI Compliance to S-FWP-1.1/9.1
., 5/16-17/85 G-07-02-13: In process welding of supports (PCI)
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5/8-9/85 G-07-04-13: Compliance to procedures (PCI)
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5/2-3/85 H-09-13-09: Compliance to S-FWP-1.1/9.1 (PCI)
4/23-25/85 H-09-13-09: Compliance to S-FWP-1.1/9.1 (PCI)
4/30/85 Q-03-02-09: Huck Fastener Installation (PCI)
4/19/85 H-09-13-09: Review of documents (PCI)
The audits indicated thorough QA surveillance of PCI activitie '
UE&C will use the authority of B31.1 paragraph 127.5.3 to utt-lize (adopt) Pullman-Higgins B31.1 welding procedures, welding procedure qualifications; and welder performance qualification As this is not permitted in ASME SCIX this will be limited to 831.1 weldin This system meets the licensee's approval as required in 127.5. The inspector reviewed many of the
" adopted" procedures. Those procedures reviewed are listed in Attachment No violations were identifie (4) D1.1 Welding There are a number of specific areas where there have been con-flicts between the general commitment to 01.1 and actual prac-tices at many specific location The inspector investigated many of these areas to obtain the licensee's and UE&C's posi-tion. The licensee's positions in the inspected areas are summarized below:
- UE&C follows 01.1 paragraph 6.5.6 and requires a distin-guishing mark (by the QC Inspector) on joints inspected (even though quality system recordkeeping documents exist which would meet the intent of the requirement).
- The use of materials not specifically listed in 01.1 Table 4.1.1 are handled by appropriate Request For Information
- (RFI) and Engineering Change Authority (ECA) documents which meets the " Engineer's" approval requiremen ,
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- UE&C has conducted welding tests to veri fy that actual throat dimensions meet engineering assumptions for flare i bevel joints in accordance with the intent of 01.1 para-graph 2.3. : *
Welding processes not specifically approved as pre qual-ified in D1.1 paragraph 1.3.1 (e.g. - GTAW) have been qualified by tests in accordance with D1.1 paragranh rules.
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The utilization of ASME SCIX procedures and performance qualifications permitted by D1.1 paragraph 5.2 are author-ized in FWP document *
Prior to general adoption of the AWS A2.4 welding symbology required by D1.1 paragraph 1.5, UE&C utilized their own welding symbol interpretation document j'nd clarified spec-ific problem areas in ECA document .
In order to always meet the maximum undercut rules regard-less of direction of the application of stress UE&C adopted a zero undercut rule
Where the minimum fillet size rules of Table 2.7 and the size of individual pass rules of paragraph 2.7.1 were not desired, UE&C conducted extensive welding qualification tests to provide engineering justification for their practices
Where partial penetration joints with included angles of less than 45 were employed, UE&C conducted qualification tests to justify the engineering assumptions for effective throat *
For highly restrained joints, specific bead sequence de-tails were utilized to provide explicit " directions to the welders."
The following documents related to modifications or clarifica-tions of AWS D1.1 welding requirements were reviewed:
RFI 5933188 - welding of ASTM: A108 rods and studs to A36 plates
ECA 5930968 - clarification of flare bevel site rules
RFI 593602A - welding of ASTM:A120 materials
RFI 5937108 - use of partial penetration joint rules for skewed angles
ECA 59004807C - Reinforcement requirements for skewed "T" joints
ECA 594810A - Prequalification of seal welds The licensee stated that upon NRR approval of the Nuclear Con-struction Issues Group (NCIG) Visual Weld Acceptance Criteria (VWAC) document NCIG-01 they would review the document for
applicability at Seabrook, conduct specific training for QC inspectors, request an FSAR change authorization, and utilize the document for inspection of D1.1 weld No violations were identified.
7.3 HVAC Welding (1) Visual Inspection of HAH HVAC Weldments Approximately 337 HVAC completed duct support welds made by HAH were visually inspected for compliance to drawings, welding specifications, HAH QP-3 and AWS D1.1 inspection criteria. Minor spatter and surface slag was noted on two welds where the geo-metry would tend to cause magnetic arc blow problems. There were a few minor irregularities in weld size for less than 10%
of the length. It was obvious that the zinc had been removed from galvanized structural shapes prior to welding and re-painted with zinc rich paint. On some of the " plate to floor embedments there was minor edge meltin The weld irregular-ities were not sufficient to render any of the welds rejectable and the general weld quality was acceptabl The supports inspected were RN20-33 and FN22-5 No violations were identifie (2) PCI HVAC Welding Program The inspector reviewed the PCI program for HVAC duct and support welding. PCI is responsible for welding procedure qualification and welding fabrication and UE&C has engineering and QC respon-sibilit The scope of the PCI work is limited to sheet metal welding to AWS D9.1 and structural support welding to AWS D The stiffeners to duct welds are in accordance with D9.1. Most of the D1.1 joints use pre qualified procedure rules whereas the D9.1 requires visually inspected procedure qualification test assemblie The welders are qualified to 09.1 and D1.1 as applicable. UE&C utilizes the effective throat penalties (where applicable) required by D1.1 in their design assumptions. D pre qualified joint geometries are utilized in the WPS docu-ments, however, the AWS letter designations for the joint con-figurations are not used in the drawings or in the WPS docu-ment The PCI general welding Procedure S-FWP-1.1/9.1 is written to meet the requirements of UE&C WS- No violations were identifie .
(3) Visual Inspection of PCI HVAC Welding PCI HVAC welding was visually inspected by a random selection of current work in progress with D9.1 and D1.1 welding utilizing the GMAW-S and shielded metal arc welding (SMAW) processes. The inspector observed joint preparation, tack welding to obtain proper root opening on square butt duct welds, GMAW-S duct weld-ing, and SMAW support fillet welding. Duct welding was observed in the fabrication shop and in the power plan The welding parameters observed for GMAW-S welding were in the range uti-lized for procedure qualification tests. Completed single sided square butt joint GMAW-S welds were inspected visually on the inside (root) of the duct and showed complete fusion. As dis-cussed in paragraph 7.3.4 welder qualification test assembly welding and testing was witnessed. Welder qualification records for PCI HVAC welding were also reviewe (4) Review of PCI Welding Procedure Specifications (WPS)
The inspector reviewed PCI shop and field WPS documents for HVAC sheet metal and support welding to meet AWS D9.1 and AWS D respectively. The thicknesses of duct welded are heavy, 10 gage (0.135") and almost are out of the sheet metal rang Review of GMAW-S WPS procedures indicated that the voltage and amperage ranges specified exceeded that for legitimate usage of short-circuiting metal transfer mode and normal recommended ranges (e.g. AWS Handbook Sixth Edition Section 2, page 23.34).
The GMAW-S WPS also indicated that they were qualified according to 09.1 to 2T based on welding 3/8" plate (Weld has to pass visual inspectio No destructive testing required by D9.1). ,
The inspector discussed the lack of technical merit of the wide amperage / voltage range and the WPS documents which indicated qualification to 3/4" for a process known for its lack of fusion defects. The inspector requested a demonstration of the GMAW-S process at approximately 225 amps and 25 volts. This demonstra-tion showed that the mode of metal transfer was not by short circuiting but rather by pinch-off spray and the welding condi-tions were unmanageable for out of position weldin UE&C Welding QA and the licensee committed to write a letter to PCI clarifying that the GMAW-S processes are not permitted for site usage over 3/8" thickness and that the welding parameters are limited to the true short arc range (the D9.1 PQR amperage ranges). The action taken by UE&C shows good engineering prac-tice exceeding minimum code requirements as AWSD9.1 does not prohibit qualification to 2T and permits test assemblies for qualification to be examined by visual methods onl _ - - .. - - _ -
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7.4 Weaknesses in PCI Welding Program i The combination of DR 52-5137-A on use of an unqualified procedure and welder; deficiencies found in reviews of welder performance documentation related to " mode of metal transfer" and recording of actual thicknesses of test assemblies welded; and range of thickness and electrical variables in D9.1 GMAW-S procedures indicates a weak-nesses in the PCI welding program. As the licensee has taken appro-priate action to resolve the DR, committed to correct the errors in the performance qualification records, and committed to write clar-
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ification letters to restrict thickness and welding parameters to meet good engineering practice, this area will be considered a weak-ness. (443/85-15-07)
7.5 Strength in UE&C Welding Program
The UE&C Welding Engineering and Welding QA initiative in following prudent engineering judgement and criteria exceeding minimum " Codes and Standards" requirements in areas, where " Codes and Standards" rules show lack of conservatism, results in improved qualit This is considered a strength in the progra A few examples follow:
- continued use of portable electrode ovens has resulted in negligible instances of heat affected zone underbead crackin *
institution of fillet gap rules for NF supports (JS-IX-6 paragraph 8.8.1)
- zero undercut rules for D1.1 welding
- clear definition of preheat rules based on maximum thicknesses
= special testing conducted for single and multiple pass 3/32" electrode welds on varying thicknesses for D1.1 welding
- detailed tests on flare bevel joints
D1.1 areas which experiences have shown to require clarification or modification have been well addressed on an engineering basi .0 Instrumentation & Control Construction 8.1 Organization To assess the adequacy of the Instrumentation and Control design and installation activities, the flow and pressure instrument systems for
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. .. _- . - .__
the Safety Injection and RHR System were reviewed. Design specifica-tions and installation procedures were reviewed. Instrument instal-lations and instrument cable routing activities were observed and QC inspections were witnessed, and QA audit records were reviewe Independent measurements were also performed to verify the conform-ance of the installed equipment with the design specification New Hampshire Yankee has delegated the engineering and construction of the I&C systems to United Engineers and Constructors. At con-struction restart, UE&C assumed the installation and QC inspection functions of the instruments and instrument cables from Johnson Control Inc. At the time of this inspection, there were 230 instal-lation craftsman and 36 QC inspectors at the construction site to perform the instrument installations and inspection activities. New Hampshire Yankee provided QA surveillance and QA audits for the I&C installation activities performed by UE& The details and findings for each of the inspection areas are discussed below:
8.2 I&C Procedures The inspector reviewed the I&C installation procedures and related documents provided in Attachment 1 of this report to ascertain that NRC requirements and FSAR commitments were properly translated into the procedures for adequate control and installation of instrument components and associated items, and that the procedures covered special handling, installation and maintenance requirements, includ-ing those pertaining to seismic supports for instruments and impulse lines, preservation of internal cleanliness, and maintenance of component qualification requirement In reviewing the installation documents the inspector noticed that no seismic installation criteria ( for Design Basis Earthquake) were established in the licensee's instrument installation specification and installation procedures for instrument impulse lines across the interface of seismic buildings. There were no attributes for the QC inspectors to verify the adequacy of these seismic installation In July 21, 1984, when Johnson Control Inc. was performing the
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instrument installation, ECA 051383A was issued for the expansion joint installation of seismic instrument tubing in the East and West
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Mainsteam and Feedwater Pipe Chase area However, this ECA was never incorporated into the installation specification or procedures to cover other area A meeting was held on June 13, 1985, to discuss this deficiency. The meeting was attended by personnel from the New Hampshire Yankee, UE&C and NR In the meeting the licensee stated that the following corrective actions will be taken by July 1, 1985:
-. - - - - _ - - . . . _ _ _ , - ._-
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(a) Walk down all seismic buildings and review of all building-to-building instrument tubing installation for sei:mic anchor displacement (SAD) consideratio (b) Analyze any installations for which adequacy cannot be confirme (c) Revise installation specification 46-1 to add SAD requirement (d) Revise installation procedures FIP-18 and FIP-34 so that QC inspectors can verify that SAD was considered in desig (e) Conduct formal training of SAD requirement i The licensee was informed that the above failure to establish and implement seismic design criteria for instrument tubing was contrary to the design specification requirements of Criterion III of 10 CFR 50, Appendix This is a violatio (443/85-15-08)
8.3 Instrument Installation - Work Observation The inspector examined the completed installation of pressure and flow instruments, and pneumatic control valves in the Safety Injec-tion System and Residual Heat Removal Syste Location, configuration and installation (including mounting and anchoring) were according to the latest approved design or construc-tion specifications and drawing Specified instrument components and associated items had been use Components had been correctly and permanently identified. Cleanli-ness requirements had been maintained or otherwise satisfie In-stalled equipment was adequately protected from adjacent construction activities and protective coatings, plugs, bushings, and other mate-rials had been used as specifie Nonconforming components or con-ditions had been identified and controlled in accordance with approved procedures. Appropriate heat numbers were shown on the flow elements, and the numbers corresponded to the numbers in the original purchase orde The following instruments were examined:
a) SI-FE-918, 922 - Safety injection flow elements, (Reg. Guide 1.97 items),
b) RH-FE-610, 611 - Residual heat removal flow elements, (safety-related).
c) SI-FT-918, 922 - Safety injection flow transmitters (Reg. Guide 1.97 items, seismic Category ).
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. -- . . . - -- - - - _ . . .
d) RH-FIS-610, 611 - Residual heat removal flow indicating switches, (safety related).
e) RH-FE-618, 619 - Residual heat removal flow element, (Reg. Guide
1.97 items).
f) RH-FT-618, 619 - Residual heat removal flow transmitters (Re Guide 1.97 items).
g) RH-FCV-618, 619 - Residual heat removal HX bypass control valves (position indication portions are safety related).
8.4 Incorrectly Voided NCR's The inspector noticed that for flow transmitter SI-FT-918, the high pressure sensing line had an unclamped (seismic clamp) length of 92 inches in a 7 bend configuration, and the low pressure sensing line
'
had an unclamped length of 89 inches, also in a 7 bend configuration.
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Similar conditions were observed for flow transmitter SI-FT-922, except that the unclamped lengths were shorter, about 60 inche Upon further investigation, the inspector found that these problems
, had been identified by the I&C QC inspector and documented in NCR's i
93/667 and 93/666 respectively, all dated November 19, 1984. How-ever, these NCR's were not processed because they were voided by the lead QC inspector on November 21, 1984, due to his misinterpretation of seismic requirement The licensee was informed that the above ,
,
improper disposition of the NCRs was contrary to the procedure adher-
<
ence requirements of 10 CFR 50, Appendix B, Criterion The lead QC inspector assumed that this non IE and non ASME tubing was not safety-related and did not recognize the need for conducting the tube support activities under safety-related requirements for the protection of other vital safety-related components in the immediate vicinity and paragraph 5.1.6.2 of Seabrock Administrative procedure No. ASP-3 "Nonconformance," Revision 2 dated May 15, 1985. This is a violatio (443/85-15-09)
8.5 Negatively Sloped Instrument Tubing The inspector noticed that for flow transmitter RH-FT-618. both the high and low pressure impulse lines sloped upward at 3 angle from
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the source (pipe tap) to the root valves and 6 inches beyond the root valves to the flexible hose connection (a total of approximately 18 inches). This condition was identified by the I&C QC inspector and documented in NCR No. 93/489 item #1 on September 28, 1984. The '
disposition for this item was " accept as is" without providing appro-priate engineering evaluation. The high point in this case is not the root valve, but 6 inches beyond the root valv l
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The Architect / Engineer performed a calculation (SM #12346A0 on June 14, 1985, which provided additional justification for this NC This calculation indicated that the possible error caused by air bubbles would be less than 0.1% full scale. The inspector reviewed the calculation and found it to be acceptable.
8.6 Maximum Slope On Instrument Tubing I&C QC inspection attribute #9 on instrument tubing installations directs the QC inspectors to paragraph 5.9.1.2 of installation pro-cedure FIP-34, Revision 3 for tubing slope requirements. Paragraph 5.9.1.2 of F1P-34 requires the installed instrument tubing to be sloped between a minimum of is inch per foot and a maximum of 2 inches per foo On June 6, 1985, the inspector noticed that there were sections of installed instrument tubing for SI-F15-610 and 611 (4 sections, each about 3 inches long) sloped approximately 5 inches per foot. These were not reported by the QC inspector. Subsequently the inspector discussed the maximum slope requirements with four more I&C QC inspectors. Two QC inspectors stated that this should be docu-mented in the NCR and let the engineer make the disposition. The third QC inspector was not quite sure about this requirement and the fourth QC inspector stated that this would not be a requirement and can be disregarde This concern was brought to the attention of the licensee's manage-ment on June 7, 198 The I&C QC supervisor met with the NRC inspector on June 11, 1985, to discuss the 2"/f t. maximum require-men He stated that ECA #761215B was issued on February 6,1984 permitting the instrument tubing installation personnel to use tubing bent at approximately 45 , which was the case for the 4 sections identified by the NRC inspector. This ECA contradicted the statement specified in paragraph 5.9.1.2 of FIP-34, and caused much confusion to the installation craftsmen and QC inspector The licensee issued ECA 05/106137A on June 10, 1985, deleting the 2"/ft. maximum slope requirement. A copy of this ECA was not avail-able to the NRC inspector until June 14, 198 The licensee, trained the I&C QC inspectors in this ECA during the week of June 10, 1985. The I&C installation craftsmen were instructed in this regard by July 15, 198 The licensee was informed that this will be identified as a weakness in the instrumentation tubing installation program. (50-443/85-15-10)
I
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8.7 Instrument Cable Installation And Termination The inspector observed work performance pertaining to the installa-tion of instrument cables and terminations to determine whether the requirements of the applicable specifications, instructions and pro-cedures are being met in areas relating to the material type, size, routing, support, termination and separatio Items examined for this determination included:
a) Instrument cable routing and termination from flow switches (RH-FIS-610, 611) in the RHR Equipment Vault at Elevation -61'
to the Control Roo b) UE&C DWG 9763-M-310887 SH. B55c " Cable Schematic for Miniflow Isolation Valve FCV-610" Rev. 5 dated October 28, 198 c) UE&C Cable routing sheets - F20-532 and F20-SK8 dated September 25, 198 d) UE&C termination sheets for cables F20-SK8 dated January 17, ,
1985 and F20-S32 dated January 15, 198 e) Rework record WR RH-0155 for re-roating and re-terminating cables due to relocation of RH-FIS-610 & 611, dated May 24, 198 No unacceptable conditions were identified in tnese areas.
8.8 Independent Measurements The inspector performed independent measurements to veri fy the installation data for instruments and instrument cable For the instruments installations identified in paragraph b) above, the inspector measured the slopes, distances between seismic clamps and bending radii for the instrument impulse lines, verified the correct-ness of the instrument valve flow directions, and the instrument mounting configuration For the instrument cables and terminations identified in paragraph c) above, the inspector verified that the distances between redundant cables met the separation criteria, and that adeouate slack was provided when cables were terminated.
8.9 Store Room Tour The inspector toured the I&C storage areas and reviewed the storage activities and conditions of safety related instrument The components were stored in proper storage level designation and the components were properly identified. The storage conditions were controlled as specified and the nonconforming items placed in storage were identified and segregate .- _ -. -- . . ._ _ _ - -.- - - _ .
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The I&C storage area was located in the Gage and Calibration Build-i ing. The Gage Facility Supervisor was in charge of the storage. It was designated as Level B storage. All safety related items carried green release tags and were segregated from non-safety related item The storage conditions of the following safety-related instruments were observed:
1-SI-FY-2441, 2446, 2456 and 1-22SP-FY-0853 (all were ASCO solenoid valves Model NP-831654E, 125VOC).
1-SI-PT-2576, Rosemount Pressure Transmitter 2-RH-FIS-610, ITT Barton Differential Pressure Switch, (range:
,
0-73.2" W.G.)
1-CS-PI-9400, P98A,B Discharge Header Pressure Indicator, (Sigma International Instrument Model # 9-1151-2025)
i The inspector verified that these instruments were stored properl No unacceptable conditions were identifie .10 Westinghouse Document Reviews The inspector reviewed Westinghouse procurement specifications and '
'
purchase orders and determined that Westinghouse supplied instruments met the design requirement The following Westinghouse documents were reviewed:
(1) Westinghouse Specification Sheet No. 03810 for flow elements RH-FE-610 & 611; RH-FE-618, 619; RH-FE-918, 922, Revision 12,
, dated August 13, 198 (2) Westinghouse P.O. #546-CMT-280215-BM dated March 24, 1980 to Vickery Sims Inc. for flow elements identified in (1) above.
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(3) Westinghouse Specification Sheet No. 01412 for flow transmitters
SI-FT-918, 922, Revision 20 dated April 24, 198 (4) Westinghouse P.O. No. 546-CMT-423447-BN dated October 29, 1980, to Veritract Inc. for item (3) abov (5) Westinghouse Specification Sheet No. 04631 for Flow Switches RH-FIS-610, 61 '
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---w+-m--r v.----w -
---r w.mwe- iry -- - . __ . - - _ - --
i 1 .
(6) Westinghouse P.O. No. 546-CLP-488926-BN to ITT Barton Inc. dated i January 18, 1984 for item (5) abov ! (7) Westinghouse Specification Sheet No.11412 for flow transmitters RH-FT-618, 619.
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(8) Westinghouse P.O. No. 546-AMC-401660-BN to ITT Barton Inc. dated September 3, 1980 and P.O. change notice 546-CLP-401662-BN dated March 6, 1981 for item (7) abov (9) Westinghouse P.O. No. 546-CCF-207624-BN to Fisher Control C for control valves FCV-618, 619 (8-BA74R) and HCV-606, 607 (8-BA740) dated September 25, 1974, and P.O. change Notice No.
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546-CCF-207624-BN dated August 10, 1976, No. 546-CCK-207624-BN dated November 11, 1982, No. 546-CCJ-207624-BN dated
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December 18, 198 Within the scope of this review, no unacceptable conditions were identifie .11 QA Audit Records Reviews The inspector reviewed the QA audit records and audit schedules on I&C installation activities performed by UE&C and (previously) by Johnson Control In The audits were performed in accordance with Seabrook QA manual Section " General Audit Procedures" Revision 10, dated February 15, 1985 and the established schedules and plan Audit records were sufficient to verify that the intended purpose and i scope of audits were achieve Audit findings had been reported in sufficient detail to permit a meaningful assessment by those responsible for corrective action, final disposition and trendin UE&C had taken proper and timely followup action on those matters in need of correctio Items examined in this determination included QA audit schedule for 1985 dated December 13, 1984, and schedule for 1984 dated July 9,
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1984 and the audit reports listed below.
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. - - - - , , . --e----.- , , ~ - - - - - - - - _
-. .. . . - . . ._- .._ _-._
-- ..-
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Audit Report N Audit Dates Findings SA836CS362 June 19-29, 1984 22 deficiencies 1 observation SA847CS372 August 14-21, 1984 6 deficiencies
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2 observations SA857CS381 September 19 - 22 deficiencies October 12, 1984 2 observations
- SA859CS382 October 17-29, 1984 6 deficiencies
, 2 observations i
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SA871CS390 November 13-29, 1984 3 deficiencies i 2 observations
< SA876CS394 December 11-20, 1984 3 deficiencies
SA897CS410 March 11-15, 1985 1 deficiency 1 observation
The excess number of deficiencies in the second half of 1984 arose from the transfer of the I&C installation responsibility from Johnson Cor, trol s Inc. to UE&C. Most of the deficiencies identified were in
- the instrument tubing areas, especially the sloping requirement. All
! except seven of the deficiencies and observations were resolved and accepted by Q The seven unresolved items had been responded to and, according to the I&C QC supervisor, will be resolved soo The I&C QA audits were thorough, and the audit reports were docu-mented in a logical manner. The licensee has been informed that this 1 was a strength in their QA program. (See Paragraph 4 for an overall
- assessment of the QA/QC activities).
8.12 Nonconformance Report Reviews The inspector reviewed a selected sample of eight nonconformance reports.
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The records were legible, complete and properly reviewed by qualified
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personnel. The records were properly identified, stored, and can be retrieved in a reasonable time. The reports included proper resolu-tion and adequate justification was provided for accept-as-is
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disposition.
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- ._ -. .- . - - . . . = _ - -= _ ._ . . . . . . - .-.
!
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- The following nonconformance reports were reviewed
(1) NCR N /1351A " Tubing overspan on 1-RH-FIS-610" dated i May 22, 1985 (2) NCR No. 93/1365A " Work performed on CS-FT/FIS-7326 without work j package, ASME Class 2 lines" dated May 24, 1985 (3) NCR No. 93/760 " Safety related instruments CS-FT-7325 & 7326 released and installed without generating FMR" dated December 24, 198 (4) NCR No. 93/759 " Welding material issued on WMR No.10284 not 2A 3 verified prior to issue" dated December 27, 198 (5) NCR No. 93/732 " Flex hose supporting problem" dated December 14, i 1984
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(6) NCR No. 93/730 " Instrument tubing weld problems, eight items" dated December 14, 1984.
! (7) NCR No. 93/587 " Instrument tubing weld GR-316 weld wire Vs GR i 316L weld wire"
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, (8) 93/654A " Source Connection movements not listed in TP-5 for BIP
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SI-1-5" dated November 20, 1984.
< Within the scope of this review, no unacceptable conditions were identified. (See paragraph 5 for an overall assessment of the site
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NCR program).
8.13 Receipt Inspection Record Reviews The inspector selected seven receipt inspection records for revie The documents properly and uniquely identified received instruments and associated items. Applicable specification (regarding size, type, material, etc) of received items were met or otherwise note The instruments.and associated items were received in accordance with Procedure FGCP-3 " Receiving and Inspection of Items" Revision 10, dated May 6, 198 The following receipt inspection reports were reviewed:
(1) RIR No. 7046 for P.O. No. 9763-252-16 Date received: November 8, 1982 Items received: 30 ITT Barton pressure and differential pressure indicating switches l
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4 (2) RIR No. 6992 for P.O. No. 9763-252-16 Date received: October 27, 1982 Items received: 4 ITT Barton differential pressure switches
(3) RIR No. 8370 for P.O. No. 9763-252-16 Date received: February 14, 1984
Items received: 4 ITT Barton differential pressure switches (4) RIR No. 10371 for P.O. No. 9763-NSS 0325
, Date received: August 22, 1094 4 Items received: 2 Westin5 ause supplied temperature elements (5) RIR No. 10515 for P.O. No. NSS 325 Date received: October 26, 1984 Items received: 8 Westinghouse Supplied RTD's (6) RIR No. 10368 for P.O. No. NSS0325 Date received: August 13, 1984 Items received: 7 Westinghouse supplied differential pressure transmitters
(7) RIR No. 11222 for P.O. No. NSS0325 Date received: May 28, 1985 Items received: One Westinghouse supplied pressure transmitter
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Within the scope of this review, no unacceptable conditions were identifie t 8.14 Personnel Qualification Record Reviews The inspector reviewed the qualification records of five randomly selected I&C QC inspectors.
i The personnel qualification records meet the requirements of ANSI N45.2.6, 1978 and were being maintained in a current statu The records were sufficient to reasonably support qualification in terms of certification, experience, proficiency, training and testin The fiv:: inspectors reviewed were all certified as Level II inspec-tor > in d:fferent I&C area Each file reviewed contained vision
- examination report, resume, certificates, and training record Within the scope of this review, no unacceptable conditions were
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identified.
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9.0 Electrical Systems and Components
In order to . verify the adequacy of the installed electrical system and
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components, the team selected the electrical systems associated with the Safety Injection mode of ECC The inspectors verified the installation of equipment from the 4160 volt bus, switchgear, motor control centers,
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cables, and raceways to the valve operator Additionally, the quality assurance program for governing electrical installation, inspection and testing activities was also reviewed. Details for each inspection area are discussed below:
9.1 Organization United Engineers and Constructors (UE&C) provides the engineering, construction and inspection function for the field installation of I
the electrical equipment.
i 9.2 Electrical System Review The electrical system for the Safety Injection components is powered from the A and B Trains. The B train was selected for this inspec-tion.
! The B train 480 volt power is supplied from the 621 Motor Control
Center (MCC). The inspector verified and traced the following eq ui pn.en f Power Source Cable N To 4KV SWGR-6 RHR A77-M-12 RESID HT RMVL EDE SWG-6 Cubicle 11 (3/c 4/0) Pump B RH-P-8B 4KV SWGR-6 SI P-6B A76-M10 Safety Injection
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EDE-MCC E621 (3/c 12) Connect Va ;
SI-VIII
- MCC-E522 SI-V114 B49-V50 SI PP To Cold Leg
- EDE-MCC-E522 (3/c 12) ISO Val. SI-V114
MCC-E621 RH-FCV-611 B63-V24 RHR P8B Minimum l EDE-MCC-E621 (3/c 12) Flow Val . RH-FCV-611
<
MCC-E622 RH-Val 32 B58-V51 RH E 9A&B l EDE-MCC-E622 (3/c 12) RH-Val 32
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--- ._.-, ._ _ _ - , _ , . _ - . . _ , - - . _.---_.-._.. _ --_ _ _,_ , , _ _-. ---, - ..- ..__ _ , _. - ., - ___ _ ,_
. - - - = - - . . . . . - - - - - - - .. -- . _---. - - - - __ .
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Power Source Cable N To
. MCC-E621 RC Val 87 B61-1-124 ?EN 24 480V MED
! EDE-MCC-E621 (3/c 12) EDE-MM-100
! MCC-E521 RC88 B62-H19 PEN 19 4euv MED PWR
} EDE-MCC-E521 (3/c 12) EDE-MM-95
- MCC-E622 RH Val 26 B65-V48/1 RH E-938 Control EDE-MCC-E622 (3/c 8) ISOL RH-V26
! PEN 15 480V MED H15-V40 ACCUM TK 9B PWR EDE-MM-91 (3/c 4) Outlet ISOL SIV-17
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PEN 19 480V MED H-19-V28 RC-E-110 RHR PWR EDE-MM-95 (3/c 12) ISO Val 2 RC-V88 l 4KV SWGR-6-P-6B A76-F10/1 MCM Zone AF1,
. EDE SWG6, Cubicle-10 (1P/16) AF2 4KV SWGR-6 RHR A77-F20 MCB Zone BF1, P-8B EDE-SWG 6, (IP/16) BF2 3
^
4KV SWGR-6 P-6B A76-F10/2 MCB Zone AF1, DF2 EDE-SWG-6, (4/c 19)
j The cable pull confirm slips for each cable listed identified the i following information.
t
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Date Cable Pulled
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Feet Cut
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Cable Reel
--
Cable Size
--
Reel Tag No, and t
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Routing
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In each of the above items, the inspector verified that, quality
- control records for equipment, installation raceways, cable testing, f
and termination were complete and accepted by the responsible quality organization. In many cases the above equipment was installed and turned over to the start-up and test organization. Preventive main-
- tenance for the various equipment in the Safety Injection system is
,
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under the control the start-up and test organizatio i i
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Throughout the Safety Injection mode of the ECCS system, the inspec-tor noted that the installed electrical and instrumentation equipment were adequately protected from dirt, in accordance with the licensee's requirements. This is an improvement from previous NRC inspection finding No violations were identified.
9.3 Quality Control Records - Electrical Equipment The inspector reviewed the quality control installation records for the following equipmen volt Switchgear
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480 volt Motor Control Centers
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Centrifugal Charging Pumps (Drawing 9763-M-503335)
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Refueling Water Storage Tank Suction Valves Drawing 9763-M-503335)
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Charging Pump Miniflow Valves (Drawing 9763-M-503337)
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Safety Injection Pumps (Drawing 9763-M-503900), and
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Residual Heat Removal Pumps (Drawing 9763-M-503761)
The records for the above equipment were complete, outstanding items closed and acceptance of the data signed by the quality departmen No violations were identified.
9.4 Raceway and Cable Installation The inspector reviewed the records for the raceway installations and verified by inspection that the raceways from the 4160 volt switch-gear (B Train) to the 480 volt Motor Control Center (MCC-621) were installed per the drawing The inspector traced the cables from the 4160 volt switchgear, 480 Volt MCC, to the B Train components listed in paragraph 9.3.2. Using the cable pull tickets and walking the raceway system, the inspector verified that the cables were in the assigned raceways and were located as listed on the pull ticket No violations were identifie >
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9.5 Nonconformance Reports (NCR's) in Electrical Area The inspector reviewed and verified that the nonconformance reports in the electrical area were reviewed by management, closed in a reasonable time, action was complete and closed in the licensee tracking syste The inspector selected NCR's pertaining to the Safety-Injection mode of the ECCS system. NCR 82-509A issued on April 7, 1985, discussed a ]
vibration problem in the 1-RH-P-8B pump-moto On December 9,1984, the licensee's tests yielded vibrations within specifications for the RH-P-8B pump motor at the (29.85 Hz) and (1791 RPM). On March 26, 1985 with water temperature at 125 F and a flow of 640 gpm, the tests yielded vibrations in excess of specification During this inspection, the licensee was performing additional tests to determine the cause of the excess vibration level for testing of the RH-P-8B pump motor. The inspector witnessed the following test on the pump-motor syste These tests were conducted jointly with the start-up and test depart-ment and Westinghouse. The water temperature was maintained at 125 F for the flow rate. The test yielded vibration levels within specif-icatio During a previous inspection of the PH-P-8B installation, the licen-see identified that the bolts mounting the pump-motor to its seismic supports experienced bindin Correcting this condition may have corrected the vibration problem. To assure that the vibration prob-lem has been completely eliminated the licensee plans to monitor the PH-P-8B pump-motor during the Hot Functional testing program. This item will be tracked in the licensee's NCR system and be monitored during the test progra No violations were identifie i 9.6 Quality Control Inspection Reports (QCIRs)
The inspector selected quality control inspection reports of Train 8 of the Safety Injection for revie The attributes inspected were as follows:
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Installation Documents
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Identification
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Physical Integrity
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Connectors (Type)
-.- - - . _ _ _ _ .- -_ -_-_-_ -__ --
_ . . - - . - . . ._ - . .. -
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Separation
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Cleanliness
--
Leak i
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Grounding I
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Buswork
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Protective Devices For selected QCIRs, the inspector verified that the attributes used by the quality control electrical inspectors were acceptable and in accordance with the program documentation and training program. The
, inspector also verified that closed QCIRs were reviewed and accepted by the quality control organizatio No violations were identifie '
9.7 Quality Assurance Audits in Electrical Area The inspector verified that audits and surveillances of the elec-trical program were performed by the licensee and United Engineers
and Constructors (UE&C).
UE&C performed both internal and external audits as described in their quality assurance procedure QA-18, Revision 9, Dated February 28, 1985. The inspector selected the licensee audit of January 23, 1985, No.5B-18800. The scope of the audit encompassed 10 CFR 50, Appendix B, Criteria II (QA Program), Criterion V (Instructions, Procedures and Drawings), Criterion VI (Document Control), and Criterion XI (Test Control). The audit report identified previous audit findings that were open and carried them in the audit system as open items if they could not be close New items were identified and corrective action assigned with a number being assigned for follow-up action.
The licensees quality assurance organization follows outstanding i items until closed. The inspector reviewed corrective action for 25 closed items. For twenty of these items, the corrective actions were
, adequate to correct the identified problems. The 5 remaining items involved long term corrective actions and were not completed at the
time of this inspection.
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No violations were identified.
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65 j 9.8 NRC Systematic Assessment of Licensee Performance (SALP)
Assessing the NRC's findings in SALP report, 50-443/85-99, April 1985, the licensee established an Independent Review Team (IRT) to address and correct the cause of the problem. The licensee issued an IRT status report of the 12 SALP items with schedule dates for com-pletion of the task. The management overview of the NRC SALP con-cerns is a positive approach taken by this licensee to control areas of concern within their design. These 12 items are being tracked in the IRT repor Item 10, "I&C Tubing slope" was close This subject is discussed in Section 8 of this repor No violations were identified.
9.9 Physical Independence of Electric Systems During a review of the Final Safety Analysis Report (FSAR) it was ,
noted that the licensee did not endorse IEEE Standard Criteria for !
Independence of Class 1E Equipment and Circuits, IEEE 384-197 In
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Appendix 8A of the FSAR titled " Attachment C to AEC letter dated December 14, 1973 " Physical Independence of Electric Systems" the licensee presented their plan for compliance with IEEE-384 and Regulatory Guide 1.75 (Revision 2).
NRC acceptance of the licensee approach to compliance with Regulatory Guide 1.72 (Revision 2) and IEEE 384-1974 is stated in the Safety Evaluation Report (SER) dated March 1983, NUREG 089 The inspector had no further questions in this are ,
9.10 Failure of Limitorque Motor-Operated Valves Resulting From Incorrect Installation of Pinion Gear An inspection of the Limitorque operator revealed that the pinion gear had been installed in a reversed positio This reversed installation resulted in approximately one-third (1/3) of the normal gear mesh surface and the wearing away of the portion of the pinion gear teeth that were in contact with the shaft drive gea The licensee has assigned a special test procedure No. GT-E-113 to review all safety related MO The purpose of this procedure is to inspect for 10 CFR 50.55e deficiencies as well as Information Notices such as 85-2 This item is unresolved pending NRC review of the scope of GT-E-113 and the results of the inspection and corrective action taken to resolve identified problem (443/85-15-11)
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9.11 Conclusion The licensee has established various management tracking systems which are evaluating the electrical tasks that are being performed by UE&C under their update work scope. The systems are audited by management and it appears that timely corrective action is being taken. The cleanliness and operation of electrical equipment is improving. Management attention and actions are evident in this area and there was a noticeable improvement in the electrical hardwar No violations were identified.
10. Licensee Actions on Previous NRC Findings (Closed) Construction Deficiency Report 83-00-18 The deficiency involved the failure of Ten Gould molded case circuit breakers (40 AMP Trip, Model HE3M040) to pass the instantaneous overcur-rent trip tes The acceptance criteria of this test are based on the manufacturer's time-current curve ITE Electrical Products (Division of Seimans Allis), which is Gould's sub-supplier for these breakers stated that there was a discrepancy in the magnetic trip range between the published engineering data (time-current curves) and manufacturing data. Manufacturing data indicates that the trip range for this type breaker is 600 to 1000 amperes; whercar, the publisred time-current curve indicates 400 to 700 ampere The subject breakers were tested successfully at ITE factory when tested to the manufacturing data curve, but failed at the Seabrook site wheri tested to the published time current curv As part of the corrective action, Gould agreed to replace all circuit breakers identified by the licensee as stated in licensee's letter of June 3, 1985, No. SBN-810, review purchase orders to assure that class 1E requirements are clearly specified test all class IE circuit breakers, prior to shipment, to the requirements of NEMA AB-2, and issue test docu-ments for each test circuit breake During this inspection period the licensee informed the inspector that Gould has performed testing on replacement circuit breaker This item is close ,.
11. Unresolved Items and Program Weaknesses Unresclved items are matters about which more information is required to ascertain if it is acceptable, a violation, or a deviatio Unresolved items are discussed in paragraphs 4.5, 6.4 and 9.1 A program weakness represents a condition which, if left uncorrected, could lead to problems and/or contribute to the violation of a regulatory requiremen Program weaknesses are discussed in paragraphs 5.8, 7.4 and . Management Meeting An entrance meeting was conducted on June 3, 1985 to discuss the scope and details of this inspection. Management was informed of the findings on a daily basis. A mini-exit was conducted on June 7, 1985 to provide the status and to discuss the findings from the first half of the inspectio The inspector met with licensee representatives (denoted in paragraph 1.0)
at the conclusion of the inspection on June 14, 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 by the tea l
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ATTACHMENT 1 Documents Reviewed I QA and Administrative Controls Item No. Docu.nent N Revision Document Title / Subject 1 QP-1 00 Project Quality Trending 2 QP-2 00 Corrective Action 3 IRT-015 NSSS Interface
Guidance - 10 CFR 50.55(e):
Construction Deficiency Reporting 5 10 Quality Assurance Manual 6 SA926 BI001 Seabrook Audit Report 7 04 Moderate Energy Line Break Study 8 IP-21 Fabrication, Installation &
Erection of HVAC Duct Equipment and Supports 9 SA916 CS546 Seabrook Audit Report 10 Employee Allegation Resolution Program Operating Procedure 11 FIP-24 00 Release Equipment for Other Phases of Construction 12 FEP-202 00 Raceway, Cable, Termination Slip Handling 13 FEP-209 00 Field Modification of Equipment 14 QAM 24 Quality Assurance Manual for Seabrook Station
Attachment 1 2 15 QAM 03 Field Quality Assurance Group Manual and Procedure 16 RPRT February 1985 Seabrook Trend Analysis Report i
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Attachment 1 3 II Design Change Control Item N Document N Revision Document Title / Subject 1 ASP-3 02 Nonconformances 2 GEDP-0032 Control, Evaluation and Implementation of Design Changes 3 GEDP-0033 Control, Evaluation and Implementation of Review Comments on Design Documents 4 TP-23 04 " Project Reference Manual,"
Supplemental Information for Design Change and Nonconformances Disposition Program 5 AP-15 22 Changes to Project Documents, '
Engineering Change Authorizations (ECAs), and ,
Requests-for-Information (RFI)
6 AP-10 08 Design Change Notice ~(DCN)
and Budget and Expense Revision (BER)
7 AP-39 06 As-Constructed Engineering Document Program (As-Built)
8 FGCP-40 00 System Completion Interface 9 FGCP-31 01 Area Interfacing ,
10 QA-15 12 Nonconforming Material, Parts or Components 11 QA-1 15 Reliability and Quality Assurance Responsibilities and Organization
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Attachment 1 4 III Piping and Supports Item N Document N Revision Document Title / Subject 1 JS-IX-6 15 Installation and Inspection of ASME III (Pullman Power Products) Pipe Supports 2 FPP-2 0 Field Piping Procedure No. 2 ASME Pipe Installation (UE&C)
3 FPP-3 0 Field Piping Procedure No. 3 ASME Support Installation Procedure (UE&C)
4 9763-006-248-51 8 Specification for Assembly and Erection of Piping and Mechanical Equipment for Seabrook Station Units 1/2 5 AP-39 6 As-Constructed Engineering Document Program (As-Built)
6 9763-PSG-1-3001 1 Preparation, Documentation and Control of Pipe Support Calculations 7 GEDP-0005 4 General Engineering Design Procedures 8 9763-006-18-17 4 Installation of Concrete Expansion Anchors (UE&C)
9 IX-1 18 Hilti Installation and Inspection 10 FGCP-35 2 Hilti Installation and Inspection Procedure (UE&C)
11 TP-10 7 Technical Procedure for Loca-tion of Attachments to Embedded Plates 12 TP-16 2 Technical Procedure for Beam Verification Program
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Item N Document No. Revision Document Title / Subject 13 AP-22 Administrative Procedure for Calculations 14 PSDG 1 Pipe Support Design Guide-lines
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Attachment 1 6 IV HVAC Item N Document No. Revision Document Title / Subject 1 CP-2 2 HVAC Installation and Erec-tion Procedure (HAH Fabricators, Inc.)
2 QP-2 2 Inspection Procedure of HVAC Duct and Support Installa-tions 3 IP-20 0 Fabrication, Installation and Inspection of HVAC Duct, Equipment and Supports (PCI)
4 IP-21 0 Site Fabrication, Installa-tion and Inspection of HVAC Duct, Equipment and Supports
Attachment 1 7 V PAPSCOTT Item N Document N Revision Document Title / Subject 1 FAEP-1 0 ASME Field Data Completion Program for Piping and Pipe Systems 2 TP-26 2 As-Constructed Requirements of Piping Systems 3 TP-27 1 As-Constructed Program Requirements of Westinghouse Electric Responsible Systems 4 TP-33 1 As-Constructed Verification Progrtm for ASME Pipe and Pipe Supports 5 PGL-7 As-Constructed Piping System Stress Reconciliation and Calculation Close-Out Program 6 FACP-16 0 Engineering Certification Program
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Attachment 1 8 ,
VI Welding Item N Document N Revision Document Title / Subject l' UE&C QCP-10-10- 0 ASME Visual Weld Inspection Procedure 2 UE&C 9763-006-248-1 9 Shop Fabrication of Piping 3 QCP-1 ' UE&C 9763-006-248-1 9 Shop Fabrication of Pipe NHY - Interim Boric Program for Post-Cat, Pre-System &
Stamping Components - Not Final Signed Document 5 SA916CS426 YAEC Audit SA916CS426 on PCI 6 52-5137-A Use of Incorrect and Unqual-ified Welding on PCI Damper 7 SB-17615 B31.1 Qualification of Weld-T.F.A.12. ing Procedure and Performance Qualification (Transfer of Pullman Procedures to UE&C Per Para, 127.5)
8 FWP-18 0 IPC-2 to FWP-18 Para. 5. (Preheat)
9 FWP-25 0 P8 to P8 WPS 10 S-FWP-1.1/ Para. IV.4 (Preheat) in Ge Weld Procedure (PCI)
11 S-FWP-301- 0 D1.1/9.1 > 1/8" Carbon Steel Welding 12 FWP-43 0 UE&C Preheat and PWHT 13 A-6 0 FCAW 14 QP-3 1 HAH, Weld Inspection Procedure
Attachment 1 9 Item N Document N Revision Document Title / Subject 15 WP-32 0 P8 to P45 (GTAW)
16 WP-33 0 PQR-348 (Pullman) for WP-32 17 WP-34 0 P43 to P43 (GTAW/SHAW) (831.1)
18 WP-35 0 PQR-39 (UE&C) for WP-33 19 WP-28 0 WPS-G-45-45 (GTAW) (B31.1)
20 WP-29 0 PQR-510 for WP-28 (Pullman)
21 WP-19 0 P34 to P34 GTAW (831.1)
22 WP-20 0 PQR-509 for WP-19 (Pullman)
23 WP-21 0 P35 to P35 GTAW (B31.1)
24 WP-22 0 PQR-512 for WP-21 (Pullman)
25 WP-23 0 P1 to P5 (GTAW/SHAW) (B31.1)
26 WP-24 0 PQR-350 for WP-23 (Pullman)
27 WP-25 0 P1 to P1 GTAW/SHAW (B31.1)
28 WP-26 0 PQR-004A for WP-25 (Pullman)
29 WP-27 0 PQR-004B for WP-25 (Pullman)
30 FWP-18 0 General Welding Requirements and IPC2 & IPC3 31 WP-17 0 PI W/P43 Butter to P5 32 WP-14 0 P5 to P5 GTAW/SHAW (831.1)
33 WP-16 0 PQR-208A (w/PWHT) for WP-14 (Pullman)
34 WP-15 0 PQR-208D (w/o PWHT) for WP-14 (Pullman)
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Attachment 1 10 Item N Document N Revision Document Title / Subject 35 WP-11 0 P5 to P5 GTAW/SHAW (B31.11)
36 WP-12 0 PQR-206.1 w/PWHT for WP-11 (Pullman)
37 WP-13 0 PQR-218 w/o PWHT for WP-11 (Pullman)
38 WP-8 0 P1 to P45 GTAW (B31.1)
39 WP-9 0 PQR for WP-8 (Pullman)
40 WP-3 Non-ASME Process Control Sheet Continue Applies tc B31.1 (not AWS)
41 FWP-1 IPC2 IPC2, Rev. 1 Para. Rev. 1 (Permission for Transfer of B31.1 Procedures to UE&C from Pullman)
42 WP-6 0 P1 to P1 GTAW/SHAb (831.1)
43 WP-4 0 PQR-048A (w/o PWPI) for WP-6 (Pullman)
44 WP-5 0 PQR-0488 *w/PWHT) for WP-6 (Pullman)
45 S-SWP-300 0 (PCI) GMAW-S 46 S-FWP-300 0 (PCI) GMAW-S 47 S-SWP-301 0 (PCI) SMAW 48 S-FWP-301 0 (PCI) SMAW 49 S-SWP-304 0 (PCI) GMAW-S (Stainless)
50 S-FWP-304 0 (PCI) GMAW-S (Stainless)
51 S-SWP-305A 0 (PCI) FCAW w/E71T11 52 S-FWP-1.1/9.1 0 (PCI) General Welding Procedure
Attachment 1 11 VII Instrumentation and Control
. Item N Document N Revision Document Title / Subject i 1 F1P-34 3 General Installation of Instrumentation Systems 2 FGCP-7 9 Control and Calibration of Measuring and Test
. Equipment 3 FGCP-3 10 Receiving and Inspection of Items 4 TP-8 7 Technical Procedure for Separation Criteria 5 FGCP-6 4 Preventive Maintenance and Minimum Storage Requirements for In-Place Storage of Permanent Plant Equipment 6 9763-F-805008 13 Residual Heat Removal System P&ID 7 9763-F-805010 15 Safety Injection System High Head P&ID 8 FIP-18 3 NSR Installation / Inspection ,
Procedure / Seismic 9 FIP-30 3 Work Package Program 10 9763-006-46-1 9 Specification for Instrumen-tation Installations 11 RH-I-1-TH-003-5 0 Component Installation for RH-FIS-611, RHR Equipment Vault (South) El-61'-0" 12 QA Manual 7 Control of Purchased Material, Section Equipment and Service 13 QA Manual 10 General Audit Procedures Section Attachment 1 12 Item N Document No. Revision Document Title / Subject 14 95527 1 Westinghouse Equipment Spec-ification " Class 1E Instru-ment Design and Test Requirements" 15 2333D56 3 Westinghouse Drawing " Safety Class 1E AP Indicator with Switches Model #581" 16 955286 0 Westinghouse Equipment Spec-ification " Pressure and Dif Pressure Transmitters" 17 953096 2 Westinghouse Design Specif-ication "ASME Class 2 and Class 3 Butterfly Valves"
Attachment 1 13 VIII Electrical i
Item N Document N Revision Document Title / Subject 1 FEP-504 1 Installation and Inspection of Cable Site Training 2 FEP-518 1 Compilation of Quality Records Generated in Support of Safety / Seismic /IE Installa-tions 3 FEP-5 Installation of Safety and Non-Safety Electrical Equipment 4 FEP-505 0 Testing of Cable Terminations 5 QA-18 9 QA Audits for Seabrook Station 6 RG-1.30-1972 QA Requirements for the Installation, Inspection &
Testing of Instrumentation and Electric Equipment 7 RG-1.53-1973 Application of the Single-Failure Criterion to Nuclear Power Plant Protection Systems 8 RG-1.75 2 Physical Infependence of Electrical System 9 E1CSB18 Application of the Single Failure Criteria to Manually Controlle'] Electrically-Operated Valves 10 E1CSB27 Design Criteria for Thermal Overload Protection for Motors of Motor-Operated Valves 11 IEEE STD-308-1971 Standard Criteria for Class IE Electrical Systems for Nuclear Power Generating Stations
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c Attachment 1 14 Item N Document N Revision Document Title / Subject 12 IEEE STD-323-1974 Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations 13 IEEE STD-324-1971 Trial Use for Type Tests of Continuous Duty Class 1 Motor Installed Inside the Containment of Nuclear Power Generating Stations 14 IEEE STD-336-1971 Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations 15 IEEE STD-344-1975 Guide for Seismic Qualifica-tion of Class 1 Electric Equipment for Nuclear Power Generating Stations 16 ASP-3 1 Site Training 17 FSAR Amendments 47, 52 and 55, Sections 1.8 and 8.0 18 Topical Report Quality Assurance Program UEC-TR-002 19 0QA XVIII-2 20 Audit Report, January 22, 1985 l
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