IR 05000443/1985013

Insp Rept 50-443/85-13 on 850506-10.No Violation Noted.Major Areas Inspected:Turnover Portion of QA Program for Preoperational Testing,Qa/Qc Overview & Interface Activities

ML20133F218
Person / Time
Site:	Seabrook
Issue date:	07/12/1985
From:	Eapen P, Kessel H, Prell J, Racho E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133F196	List: IR 05000443/1985013 ML20133F194
References
50-433-85-13, 50-443-85-13, NUDOCS 8508080190
Download: ML20133F218 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-13 Docket N License N CPPR-135 Licensee: Public Service Co. of New Hampshire P. O. Box 330 Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: May 6 - 10, 1985-Inspectors: a ;7-/8 -8[

PreKRepctorEngneer date NNLibLdC H. Van Kess 1, Reactor Engineer

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. Racho, React /r Engineer, IAEA Observer 7-io- W date Approved b . S- bh _

Dr. P. K. Eape6, Chief, 7 a[7.1-date' '

Quality Assurance, DRS Inspection Summary: Inspection on May 6-10, 1985 (Report No. 50-443/85-13).

Areas Inspected: Routine, announced inspection of the Turnover per.'on of the Quality Assurance Program for pre-operational testing, including QA/QC overview and interface activities. The inspection involved 114 inspector-hours by two region-based inspectors and one IAEA observe Results: No violations were identifie PDR ADOCK 05000443 G PDR

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DETAILS 1.0 Persons Contacted New Hampshire Yankee J. Azzopardi, Quality Assurance (QA) Engineer l F. Bean, Supervisor, QA Engineering l R. Cliche, Supervisor, Pipe Support Program

• D. Covill, Manager,-Project QA Surveillance

• S. Dunphy, Supervisor, Startup Test Department (STD) Technical Support G. Kann, STD

• J. Marchi, Manager, Quality Control (QC)

• D. McLain, Startup Manager R. Paddock, Owners Construction Group

• S. Reuwer, Supervisor, Project Completion J. Singleton, Assistant Manager, QA Engineering, Records, Special Projects

• J. Tefft, Project Engineer

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• Temple, Supervisor, QA Startup

• J. Warnock, Manager, Nuclear Quality

• R. Wedges, Station Startup Coordinator

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Yankee Atomic Electric Company (YAEC)

• V. Sanchez, Licensing United Engineers and Constructors, Inc. (UE&C)

• P. Corvino, Turnover. Coordinator D. Lambert, Manager, Project Field QC J. Kephart, Manager, System Completion and Turnover

• B. O'Connor, Superintendent, Field, QC

'*G. Williams, Compliance Coordinator U.S. Nuclear Regulatory Commission

• R. Barkley, Reactor Engineer

• A. Cerne, Senior Resident Inspector

• H. Wescott, Resident Inspector The inspector also interviewed other personnel during the inspectio * Denotes those present at the exit intervie s

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2.0 Turnover Program 2.1 Program Review 2. The procedures referenced in Attachment I were reviewed and discussed with the licensee. A presentation was given by the licensee to describe the startup program and the plant turnover proces . A flow diagram was developed by the inspector for the plant turnover process. The turnover procedures, referenced in Attachment 1, the information obtained from the licensee's presentation (see 2.1.1 above) and the discussions held with key members of the Startup and Test Department (STO) and the QA/QC groups at the site, constituted the basic inputs for the flow diagram. The Licensee was requested to review the flow diagram for accuracy and to provide corrections and ad-ditional information for the finalization of same. The final version of the diagram will tue used by NRC inspectors to improve the efficiency and effectiveness of their effort The following observations were made in the course of preparing the flow diagram: New Hampshire Yankee accepts plant components and sub-systems before construction verification testing has been performe Some construction verification testing is done by construction under a written agreement with STD. The primary reason for this early control by-STD is the desire to make test personnel and future opera-tors intimately familiar with the plant equipment through participation in the construction verification program for that equipmen . There are no detailed procedures for individual or joint walkdowns of systems. Some general walkdown require-ments are found in ASP-4, and the scope of a walkdown inspection is outlined in form ASP-04-04. The partici-pants for the final walkdown are identified prior to the walkdown, but are given the option to waive parti-cipatio . A general computerized punch list is used to record and track incomplete or deficient items of any kind prior to (sub) system turnover from construction to the ST It is called the Project Completion Work List (PCWL).

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The PCWL lists and assigns priorities for all incom-plete or deficient hardware and software item Con-struction, guided by these priorities, works on these

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items-continuously. Prior to the scheduled turnover date for a given system, the Startup Test Engineer .

(STE) for that system reviews-the open items of the PCWL for their significance with regard to the tests to be performed. If it is vital for the correct exe-cution of the test, the STE can reject the system until the items are corrected. Items which can be corrected after turnover are transferred to an exception list called the " Incomplete Items List "(IIL)" which is used after turnover and becomes a part of the Construction Completion Turnover Packag . Incomplete or deficient items, which must be completed before turnover, are not uniquely identified on the P.CW The licensee agreed to consider the use of unique identi-fiers for such incomplete or deficient item . The BIP System Walkdown Report, Form ASP-04-04, an at-tachment of ASP-4 (Reference 2), is used to identify the items to be checked during a walkdown. ASP-4, how-ever, does not supply clear guidelines on how this form is to be.used with regard to the definition of the scope of the inspection and, also, how this walkdown report should interface with the PCW . Control is exercised on Engineering Change Authoriza-tions (ECAs) after Construction Completion Turnover (CCT). STD can reject ECAs if it judges the change unnecessary for the proper functioning of the system (or structure). Such control, however, does not exist prior to CCT. The inspector witnessed ECAs at work on his first walkdown for the chlorination system (see section 2.3). .

7. .The overall site organization is project oriented. The individual project parties such as United Engineers and Constructors (UE&C)and Yankee Atomic Electric Company (YAEC) are used in functional groupings which all report to New Hampshire Yankee (NHY) management. These func-tional groupings such as the Startup and Test Depart-ment (STD), therefore, identify with NHY even though the individuals report administratively to another i

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compan NHY, presently, is a Diiision of Public Ser-vice of New Hampshire (PSNH). The flow diagrams pre-pared by the NRC will be revised to more clearly re-flect the project orientation of toe site organiza-tion by using the titles of the ert fact groupings more prominentl .2 Implementation Review The inspector participated in the following walkdowns:

(1) Final walkdown of CL-M-1 (Chlorination System / Mechanical),

Non Safety-Related (2) Final Walkdown of SWA-M-1 (Service Water Pumphouse Ventilation

/ Mechanical), Safety-Related (3) In Process Walkdown of CL-I-1 (Chlorination System /Instrumen-tation), Non Safety-Related (4) Final Walkdown of (S-E-7) (Component Cooling Water System

/ Electrical), Safety-Related (5) Final walkdown of CS-E-7, (CVCS Thermal Regeneration Deminera-lizer), Non Safety-Related During the above walkdowns, the inspectors verified the proper use of Form ASP-04-04, the use of the latest revision of approved drawings and the presence of walkdown participants in accordance with procedure ASP-0 The inspectors also verified that all of the items listed.on ASP-04-04 were given appropriate attention and observed the recording of any findings on those item During the walkdown of CL-M-1, item (2) above, -the inspector noted improper valve position indications in several valves. This concern was brought to the attention of the licensee as the same valves are used in safety related systems. The licensee's actions in this regard will be reviewed in future NRC inspections. Although this walkdown was final, an Engineering Change Authorization (ECA) had been received a week ago to install a potable water supply for the mechanical seals of the Chlorination Pumps. The inspector was informed that this would delay the CCT for this system considerabl .

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During the final walkdown of SWA-M-1 for the service water pumphouse ventilation system (safety-related), the inspector noted that all walkdown parties identified in ASP-4 were present. The System Test Engineer (STE) insisted that corrections of the fan motor vibration pads be completed prior to turnover. This item had been recorded on the PCWL and also appeared on the form ASP-04-04 (Walkdown Report).

It was the only major item still'to be completed prior to turnove All walkdown participants signed off on the ASP-04-0 The inspector accompanied the final walkdown team for the electrical cable terminations of the CVCS Thermal Regeneration Demineralizer (CS-E-7). The walkdown was performed by a CCT Team composed of representatives of YAEC-QA, STD and SCD. During the walkdown, the inspector observed the following:

Component lists and as built drawings were used to identify the electrical components and terminations contained within the boundaries of the BIP syste The detailed walkdown was properly executed to verify the actual completion of the BIP syste Deficiencies were identified and documented on Form ASP-04-0 After the walkdown, all participants signed off on Form ASP-04-0 The as built drawings ideuified in Attachment 1, which were used in the walkdown, were verified by the inspector to be the latest revi-sio .3 The following CCT packages were selectively reviewed to verify the completeness of the accepted packages:

BIP#CS-M-1, Revision 5, "CVCS Volume Control Tank" BIP#CS-E-5, Revision 13, "CVCS Letdown" BIP#CS-E-4(A), Revision 3, "CVCS-BTTZS Chiller System" The inspector verified that CCT packages were completed, including the signatures of responsible personnel, in accordance with procedure TPI-01, Revision 7, Construction Completion Turnove .4 Findings No violations or unresolved items were identified during this inspec-tion of the turnover program and its implementatio ,

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3.0 QA/QC Interface and Overview of Turnover Activities

.3.1 Program and Implementation Review The applicable. references in Attachment I were reviewed, a briefing of the turnover program given by the contractor / licensee was attended, discussions with QA/QC contractor / licensee personnel were held, a QA/QC flow diagram was prepared and discussed with the contractor /

licensee and two turnover walkdown inspections were mad All site QA/QC activities are under the control of a NHY Startup Test Department-(STD) Project Construction QA Manage STD QA/QC respon-sibilities are divided among three organizations: YAEC, both station and off-site; UE&C; and Pullman-Higgins (P-H). Having all three or-ganizations under a single manager helps assure that a uniform, re-sponsible and coordinated QA startup test program is implemente UE&C is responsible for performing QC construction completion inspec-tions of all mechanical, electrical, I&C, and piping systems iden-tified in the BI In addition, UE&C performs a first and second level review of all records associated with the BI P-H is responsible for performing all ASME related work associated with piping or hanger systems. Prior to turnover, the P-H QA/QC department reviews the BIP records package for completeness and accuracy, and performs QC inspections of all BIP identified piping and hanger system YAEC-QA performs NDE reviews, surveillances, and audits of construc-tion turnover activitie Upon completion of construction / inspections activities related to the BIP, the YAEC station QA group reviews the BIP record package. YAEC-QA participates in approximately 100% of all final walkdowns for the turnover of safety-related systems. They re-view and sign-off on the final- BIP package. During startup and test-ing, YAEC-QA (STD) will perform surveillance of tagging and testing activitie Upon completion of all startup testing activities, the STD defines the Conditional Acceptance Turnover (CAT) Boundary Package. The CAT package is used for turning systems over to the plant from the ST It may consist-of all or parts of several other BIPs. Prior to the station accepting the CAT package, the package-is reviewed by the station Turnover Review Committee (TORC).

The inspector accompanied.the walkdown 4.eam for BIP# 1-CL-I-1, (Chlor-ination system /I&C nonsafety-related) and a final walkdown of BIP#SWA-M-1, (Service Water Pumphouse Ventilation / Mechanical, safety-related). (See paragraph 2.2 for the details of the walkdowns).

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3.3 Findings-QA/QC coverage of the turnover from construction to startup testing is well coordinated and comprehensive. However, the QA/QC program for turnover of systems from startup testing to plant acceptance has not been documented. It should be noted that no safety related systems had yet been turned over to the plant. Joint audits of the CAT pro-gram by the YAEC-QA (STD) and the Plant-QA department are planne It is.also intended that Plant QA will be represented on the TORC re-viewing the CAT Boundary packag It is intended that YAEC-QA will perform a record review of the CAT package prior to turnover, perform approximately 100's walkdown of safety-related systems prior to turn-over, and have the YAEC QA manager sign the CAT package prior to turn--

over. When informed that this program has not been documented, the licensee agreed to develop and document a program for QA/QC involve-ment for the CAT progra No violations were identifie .0 Management Meetings Licensee management was informed of the scope and purpose of the inspec-tion at an entrance interview conducted May 6, 1985. The findings of the inspection were discussed with licensee representatives during the course of the inspection. An exit interview was conducted May 10, 1985 at the conclusion of.the inspection (see Paragraph 1 for attendees) at which time the findings were presented to licensee management. The licensee's management acknowledged the inspection finding At no time during this inspection was written material other than the turnover flow / decision tree diagram provided to the licensee by the inspector r

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r ATTACHMENT 1 DOCUMENTS REVIEWED .Seabrook Station, FSAR Chapters 14 & 17 Procedure No. ASP-4, Revision 1, " Boundary Identification Package (BIP) Construction ~ Completion Turnover Compliance and Documentation Coordination," by New Hampshire Yankee (NHY) Test Program Instruction TPI-01, Rev. 8, dated May 3, 1985,

" Construction Completion Turnover" Test Program Instruction TPI-03, Rev. 3, dated May 9, 1984,

" Conditional Acceptance Turnover" Test Program Instruction TPI-11, Rev. 7, dated August 29, 1984,

" Work Requests" Test Program Instruction TPI-33, Rev. 7, dated February 27, 1985,

" Incomplete Items List" Test Program Instruction TPI-02, Rev. O, dated April 15, 1982,

" Transfer of Operational Jurisdiction"

- Letter from UE&C, Systems Completion Department (SCD) to Distri-bution, dated April 24,1985, "Walkdown Punchlist", signed by P. P. Corvinio with attached BIP System Walkdown Reports for '

BIP No. CL-M-1, dated April 23, 1985 and April 24, 1985

- Drawing #9763-M-310940, sheet FA6a, " Process Control System cabinet #(CMM-CP-6) Cable Schematic", Revision 4 1 Drawing #9763-M-310940 Sheet FA6b, " Process Control System Cabinet #(MM-CP-6) Cable Schematic", Revision 7 11. DWG #9763-M-310181, Sheet FDIr, " Station Computer" 1 DWG #9763-M-310181, -Sheet JW4ca, " Station Computer System 1RTU-F Cable Schematic", Revision 2 13. DWG #9763-M-310891, Sheet E07/11 9 , "CS System A Train non-vital Control Cable Schematic", Revision 5

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2 Attachment 1 1 DWG #9763-M-310891, Sheet E97/111, "CS System A Train non-vital Control Schematic", Revision 4 15. DWG #9763-M_310891 Sheet FB3/35a, "Demin-3E to HY-E-6 ISO.VLV.,

1-V-293, Schematic Diagram", Revision 2 16. DWG #9763-M-310891 Sh-FB3/370, "Demin-3E to HY-E-6 ISO. Valve, 1-V-294, Schematic Diagram", Revision 3 17. DWG #9763-M-310891, Sheet-FB3/29a, "HY-E-6 to E-7 Bypass Valve, 1-V-301, Schematic Diagram", Revision 4 18. DWG #9763-M-310891 Sheet-FB 3/25a, "HX-E-7 to E-8 ISO VLV 1-V-306, Schematic Diagram", Revision 4 19. DWG #9763-M-310891 Sheet FB3/27a, "HX-E-7 to E-8 ISO Valve 1-V-310, Schematic Diagram", Revision 4 20. DWG #9763-M-310891 Sheet FB3/31a, "Demin-3 Bypass Valve 1-V-311 Schematic Diagram", Revision 4 21. DWG #9763-M-310891 Sheet FB3/33a, "HY-E-7 Bypass Valve, 1-V-312, Schematic Diagram", Revision 3 22. DWG #9763-M-310891 Sheet FB3/12d, "CS Thermal Regeneration Switching Cable Schematic", Revision 5 23. DWG #9763-M-310891 Sheet F41b", DM-1 to CS-F-2 Isolation Valve 1-HCV-387, Schematic Diagram, Revision 3 2 DWG H9763-M-310891, Sheet E18/13b, "CS System A Train Non-Vital Control Cabie Schematic", Revision 1 25. YAEC QA Instruction Construction Completion Turnover 26. Boundary Identification Package #1-CS-E-7, "CVCS Thermal Regeneration Demineralization", Revision 7 2 BIP System Walkdown Report (initial walkdown punchlist) 1-CS-E-7 28. ASP-3, Revision 1, Nonconformances, NHY 29. Master Boundary Identification Package (BIP) Index, April 8, 1985 3 Field General Construction Procedure (FGCP)-40, Revision 0, System Completion Interface, UE&C

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3 Attachment 1 31. Field Instrumentation Procedure (FIP)-30, Revision 3 UE&C QC Instrumentation Checklists 32. ' Field Electrical Procedure (FEP)-505, Revision 0, Installation and Inspection of Cable Terminations, Exhibits I through XIII, UE&C 33. Pullman-Higgins (P-H) Procedure X-4, Revision 12, Final Inspection 34. P-H X-23, Revision 01, Pullman Turnover Procedure 35. P-H XVII-6, Revision 02, QA Records Review 36. Seabrook Station Startup Quality Assurance Interface Agreement, April 16, 1985

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