IR 05000423/1985013

Insp Rept 50-423/85-13 on 850408-12.No Violation or Deviation Noted.Major Areas Inspected:Activities Pertaining to Installation of safety-related Electrical & Instrumentation Equipment & QC Documentation

ML20127J295
Person / Time
Site:	Millstone
Issue date:	05/30/1985
From:	Anderson C, Cheung L, Dev M, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127J271	List: IR 05000423/1985013 ML20127J268
References
50-423-85-13, NUDOCS 8506260542
Download: ML20127J295 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I ,,

Report No. '50-423/85-13 h i

Docket N

License No. CPPR-113 Priority --

Category B Licensee: Northeast Nuclear Energy Company

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Post Office Box 270

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Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Energy Station, Unit 3 5 Inspection At: Waterford, Connecticut Inspection Conducted: April 8-12, 1985 >

Inspectors: '

sk i f 8 A. Finkel, Ledd Reactor Inspector > ,

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s/m/es M. Dey, Reaitor Inspector '

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L.'Cheun Reactor Inspec date Approved by: ( To -

.C. F. Anderson, Chief, Plant System date Section, Engineering Branch, DRS /

Inspection Summary: Inspection on April 8-12, 1985 (Report N'o. 50'423/85-13) ., -

Areas Inspected: Routine, unannounced inspection of activities pertaining to the installation of safety-related ele,ctrical and instrumentation equipment, quality control documentation, training of personnel and status' of audits *and audit findings. The inspection involved 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> onsite by three region-based inspector .g j

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y4 Results: No violations were identifie '!

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DETAILS 1.0 Persons Contacted 1.1 Northeast Nuclear Energy Company M. Brown, Supervisor, I&C Maintenance

• F. Comstock, Quality Assurance Engineer

• K. Gray, Jr. , Staff Assistant

• Lefebvre, Project Staff Engineer V. Machito, Quality Assurance Engineer L. Nadeau, Assistant Project Engineer D. Robinson, I&C Engineer T. Rogers, Planner 1.2 Stone and Webster Engineering Corporation

• R. Ackley, Project Engineer

• R. Clark, Field Quality Control Inspector D. Evans, Field Quality Control Inspector R. Fricia, Field Quality Control Inspector

• R. Ackley, Project Engineer C. Jones, Field Quality Control Inspector D. Klein, Field Quality Control Inspector R. Martin, Engineer W. Mullins, Field Quality Control Inspector

• L. Nace, Project Manager

• C. Sprouse, General Superintendent Construction W. Taylor, Chief Field Quality Control Supervisor

• Turner, Resident Field Quality Control Manager

• W. Vos, Senior Engineer Field Quality Control i U.S. Nuclear Regulatory Commission

• T. Rebelowski, Senior Resident Inspector

• Denotes those personnel present at exit meeting. Other managers, supervisors, craftsmen and technicians were contacted during the course of this inspection as activities interfaced their area .0 Facility Tour The inspectors observed work activities in progress, completed work and construction status in the cable spreading room, control room, battery and switchgear rooms, reactor containment and the hydrogen recombiner are No violations were identifie n

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3.0 Instrumentation (Cables and Terminations) Work Observation 3.1 Equipment Installation The inspector observed work performance pertaining to the installation of air-operated valves and the associated limit switches and solenoid valves in the Residual Heat Removal System, Low Pressure Safety Injection System, and High Pressure Safety Injection System, to ascertain whether the requirements of applicable specifications and procedures are me . Documentation Reviewed The inspector reviewed the following documents:

a) SWEC Drawings FSK-27-7A Revision 10, dated June 15, 1984 and FSK-27-78, Revision 11, dated November 21, 1984 " Residual Heat Removal System Flow Diagram".

b) Pneumatic control valves 3RHS*HCV606, 607; 3RHS*FCV618, 619; all located in the RHR Heat Exchanger areas in Auxiliary Buildin c) Safety related air operated valves 3SIL*AV88898,D; 3SIL*CV8890A; 3SIL*AV8872C; 3SIL*CV8825; 3SIH*d889A.C; 3SIH*8823 and 8824; 3SIH*CV8881; all located inside reactor containment between O' and 12' elevatio d) SWEC Drawing No. 12179-EM-112A-1 " Low Pressure Safety Injection P&ID", dated April 14, 198 e) SWEC Specification E-350 " Electrical Installation" Revision 7, dated Novmeber 13, 198 f) SWEC Nonconformance and Disposition Report No. 9433, " Air-Operated-Valves Reversed in Field" Sheets 1 through 5, dated October 22, 198 g) SWEC cable pull tickets for:

Cable No. 3SIHNOC782 dated November 23, 1982 Cable No. 3SILBOC901 dated November 23, 1982 Cable No. 3SIHNOC901 dated November 23, 1982 Cable No. 3SIHNOC671 dated November 23, 1982 Cable No. 3SILB0C631 dated November 23, 1982 Cable No. 3SIHN0C611 dated November 23, 1982 Cable No. 3SIHN0C725 dated November 23, 1982 Cable No. 3SILBOC791 dated November 23, 1982

Cable No. 3SIHN0C903 dated November 23, 1982

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3. Installation Observation The inspector observed that each of the air-operated valves identi-

'fied in pargraph 3.1.1 above were equipped with two NAMC0 limit switches (Model EA180-31302) mounted on the valve actuator. These limit switches appeared to be in good condition and the mountings

were secure . Findings The inspector noted that two valves (3SIH*88892 and SIL*8889D) were installed incorrectly and did not conform with the P&I Upon in-vestigation by the licensee, it was found that this problem had been identified previously by the licensee's FQC inspector and documented in their Nonconformance & Disposition Report (N&DR) No. 9433, dated October 22, 1984. The licensee also identified that the electrical wiring of these valves was reversed and required re-wiring. The inspector reviewed the engineering evaluation and proposed disposi-tion of these valves and found them to be acceptabl The inspector also noted that valve 3SIL*CV8890B was incorrectly tagged 3SIL*AV88908. Upon notification of this inconsistency the licensee initiated actions to correct the valve tagging accordingl .2. Instrument Cable Installation / Raceway Installation 3. Instrument Cable Installation The NRC inspector reviewed the QA records and discussed with four licensee FQC inspectors cable pulling, cable tray supports, and cable terminations. The inspector discussed the inspection attribute and disposition of nonconformances found during work inspections, with-the FQC inspectors. The FQC inspectors were found knowledgeable of the program requirements and associated documentation. The NRC inspectors witnessed FQC inspection work for cables pulls in the Hydrogen Recombiner area (Cable No. 3SSPBPC600, 3HCSBPC501, 3HV2BPC502,3HCSBPC601).

3. Cable Pull Tension Calculation Review The inspector reviewed the basis and criteria for the cable pull tension calculations performed by the field engineers at the sit The calculations were based on the format outlined in the SWEC Specification E-350 (Electrical Installations). Calculations were properly reviewed and signed by a person other than the originator.

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The specification required that the maximum number of turns in one pull shall not exceed 3C0 , and the effective coefficient of friction for the cable pull lubrication shall not exceed . Cable Inspection Attributes SWEC FQC (electrical) department had developed an " Electrical Inspec-tion Handbook" which provided guidance to the inspector to execute attribute inspection. Based on discussions with the FQC inspectors, the inspector determined that they had sufficient training and indoctrination to use the Handboo . Findings The inspection attributes for power cable installations and general cable installation are listed in Attachments 3.5 and 3.6 respectively of SWEC QAD-10.18ML. These attribute lists contain sufficient instructions to assure that the requirements of site documentation are satisfied. However, the inspector noted that the inspection attribute related to the temperature requirement for cable pull during cold weather had been deleted from the original inspection attribut This item is unresolved pending NRC review of the licensee's method for identification of the cable temperature attribute for the quality control inspector and determination of any adverse impact on the installed cable because of the deletion of the attribut (423/85-13-01)

4.0 Quality Assurance Program 4.1 NNECo I&C Department - Post Turnover Quality Control Activities 4. Personnel Training The inspector review the site specific training and qualification of personnel'in the areas of Instrumentation and Control (I&C), electri-cal field quality control, and training of craft personne The following documentation was reviewed by the inspector:

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Millstone - 3 Instrument & Control Department Training Program, IC-3403, Rev. 2

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Millstone - 3 Administrative Control Procedure (ACP) - QA 8.16, Training Certification and Identification of Qualified Inspec-tion and Testing Personnel

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Millstone - 3 ACP-QA2.02A, Rev. 11, Installation Inspection (Planning)

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The inspector verified that NNECo I&C has 24 full time regular and 25 full time contract technicians and specialists. Functionally, they are divided into analog, digital, and mixed analog-digital group The work force, on average, represents 91s years of work experienc The qualification and certification of I&C personnel at Millstone-3 require 6 weeks of surveillance testing, system walkdown, written and oral examinations. The regular employees undergo 36 weeks of addi-tonal training including systems overview and classroom instruction A grade of minimum 80% is required to qualify these tests. NNECo I&C department has two full time Senior instructors who conduct empicyee's

- training and indoctrination, qualification, certification and impart classroom instruction The inspector interviewed 11 I&C personnel on a sampling basis and reviewed the documentation of their qualification and training pro-gra The program is overviewed by NNECo QA organization which is responsible for their qualification certification. Also, NNECo QA reviews I&C training records and procedures and conducts audits to verify effectiveness of the implementation of the program. The in-spector determined that the qualification and training of the I&C Specialists and technicians were in compliance with the schedule of the training progra . Construction Turnover NNECo I&C had e t:blished procedures for the I&C personnel to perform post-turnover quality control activities, such as: I&C equipment calibration, testing, preventive and corrective maintenance and repair, post maintenance testing, functional check, surveillance, and monitoring. I&C has recently imp?emented a production maintenance management system (PMMS) to plan equipment maintenance frequency and schedule. It provides information on equipment maintenance history, QA/QC inspection requirement, housekeeping zones, and other vital equipment data. Another potential use of PMMS is in the area of scheduling of preventive maintenance and surveillance for the I&C equipment under the electrical Equipment Environmental Qualification (EEQ) program. The inspector reviewed 11 preventive / corrective maintenance work orders, including work orders for EEQ equipment and found that the program implementation was in accordance with the program requirement .1.3 Design Modification Request The inspector also reviewed Millstone-3 ACP-QA 4.06, Engineering Evaluation Procedure used by the I&C personnel to evaluate design modification requests (DMRs), as required by Millstone 3 Startup Manual, Rev. 3. Any nonconforming materials installed are disposi-tioned with engineering justification and approval of a minimum of

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two joint test group (JTG) members. DMRs are instrumental in track-ing all I&C materials nonconformances in such cases, prior to fuel load. The inspector reviewed 4 DMRs (Unsat) and found that the programmatic resolution of the nonconformances was satisfactor . Shelf-Life Control The inspector toured the I&C lab and examined the shelf-life program for instruments and spare parts including the storage, handling and identification of age-sensitive materials. He noted that the shelf-life related materials are identified by a unique identification numbe Procurement of such materials is treated as controlled item and required at least 18-months prior to actual expiration date. The expired shelf-life items are disposed, nonetheles No violations were identified in the above areas inspecte .2 Preoperational and Post-Turnover Quality Control Activities - SWEC FQC (Electrical)

4. Gocumentation Review The inspector reviewed the following documents to verify the adequacy and effectiveness of training, and qualification of SWEC FQC elec-trical inspection personnel:

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SWEC Quality Assurance Program Description (QAPD) as applicable to Millstone-3

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SWEC Quality Assurance Directive (QAD)-2.1, (Generic Procedure)

Continuing Education System

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SWEC QAD-2.5, Qualification and Certification of Personnel Per-forming Quality Assurance Activities

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SWEC Quality Assurance Department Continuing Education Program

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SWEC Quality Assurance Department Training Proficiency Progress Records (TTPPRs)

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SWEC FQC Inspector Handbook (Typical)

4. Field Quality Control (FQC) Personnel Qualifications The inspector verified that SWEC FQC has 196 regular full time employees and 95 full time contract QC inspectors. SWEC FQC has one full time QC inspector who coordinates qualification, training, in-doctrination, and certification of FQC inspectors. The FQC inspec-tors' training is conducted according to SWEC QADs 2.1 and 2.5 which is based on the inspector's specific trade as delineated in TPPRs. A QC inspector is certified for his/her trade after successful comple-tion of classroom instructions, self-study materials, system walk-L____

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down, plant / specific and trade specific indoctrination, and written and oral tests. On successful completion of these basic requirements the FQC inspector is given a control copy of the inspector's hand-book. This handbook lists inspection attributes as applicable to their specific job assignmen The inspector interviewed 15 FQC inspectors assigned to cable installation, termination, and raceway installation, on a sampling basis, to verify their qualification, training and indoctrination, experience and certification. All these individual had several years of prior involvement in the construction, operation and outage of the several nuclear plants such as, St. Lucie, Vogel, Wolf Creek, WPPSS, Midland, Vermont Yankee, Maine Yankee, Seabrook, Millstone, and others including the U.S. Navy. The FQC inspectors qualification records files were also reviewed. A typical FQC inspectors quali-fication record file contain the following:

a) Certificate of Qualification - Valid for 3 years b) Eye - Examination Certificate - Valid for 1 year c) Resume (experience)

d) Education Description e) Records of completion of self study materials 4. Field Quality Control Training Record Review

~The inspector reviewed the attendance sheets of the following train-ing classes to verify personnel attendance and the contents of the courses:

a) SWEC Inspection Report System, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, dates 3/12/85 & 4/3/85 b) SWEC QA Orientation, 2h hours, date 3/12/85 & 4/2/85 c) SWEC N&D System, lh hours, date 4/2/85 d) SWEC Problem Reports and Deficiencies, lh hours, date 3/25/85 e) SWEC TPPR-000-010, Oral Examination, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> date 3/20/85 f) SWEC Review of Aluminium Conductor, date 3/14/85 g) ASME Code and Manual, 2h hours, date 3/12/85 4. Raceway Installation Program Review The inspector reviewed the following documents to verify adequacy and effectiveness of the quality control activities in the areas of Electrical Cable and Raceway installation:

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SWEC QAD-10.17 ML, Cable Termination and Connection Inspection Rev.0, dated June 12, 1984

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SWEC QAD-10.18 ML, Raceway and Cable Installation Inspections, Rev. B, dated June 8, 1984

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SWEC FQC Electrical Inspection Handbook, Rev.1, sections I, J, K, L, P, Q, R and S

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.SWEC Specification E-350, Electrical Installation Rev. 7

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SWEC Specification E-527, Rev. 3

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SWEC Interoffice Memorandum on Computer Generated Ticket Review, dated April 4, 1985, from C. D. Nadrella to S. Calgiuri

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SWEC Interoffice Memorandum on Raceway and Cable Pull Tickets, dated April 4, 1985, from R. Clark to G. Turner The inspector reviewed Cable Pull Ticket No. 3 MSS APC 639, Inspection Report No. 35A0152, and E&DCR FE-40926 Subject-transfer of QC inspector signature from the field generated ticket to the computer generated ticket. The above two SWEC FQC IOMs have provided inter-pretation and clarification for the transfer of signature as delin-eated in SWEC specification E-527. The E&DCR FE-40926 has been properly dispositioned. Thenceforth, the practice of the Site Engineering Group (SEG) providing FQC signature on the Cable Pull Tickets had been discontinued. In order to make the statement more understandable and unequivocal SWEC is revising the related section of specification E-527. Nonetheless, all field generated tickets with the actual inspector signature are considered quality records and SEG maintains them as suc The inspector also reviewed the following FQC inspection records on a sampling basis, to verify program compliance with the site procedures:

Cable Pull Tickets - Cable No. 3RHSBPC014 dated 12/17/82 3RHSBPC012 dated 1/14/83 3SSPBPC600 dated 4/9/85 3HCSBPC501 dated 4/9/85 3HVZBPC502 dated 4/9/85 3HCSBPC601 dated 4/9/85 Cable Termination - Cable No. 3SIHBPC010 dated 1/8/85 3SIHBPC011 dated 4/29/83 3RCSBPX822 dated 10/30/84 3RCSBPX824 dated 10/30/84 3CESBPC665 dated 2/5/85 Cable Tray Support .IR No. ESA0062 for support D220-51 & 52 Inspection Report dated 1/28/85 E4A08587 for support D130-54 & D230-55 dated 11/2/80 This item is unresolved pending NRC review of specification E-527 which is to be revised to address the subject of providing FQC signatures on cable pull tickets. .(423/85-13-02)

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5.0 Battery Room Walls (Masonry)

Id Bulletin No. 80-11, dated May 8, 1980 identified a problem with the structural integrity of concrete masonry walls with Seismic Category 1 piping attached to the The licensee was required to identify all masonry walls in their facility which are in proximity to or have attachments from safety-related piping or equipment such that wall failure could affect a safety related syste .1 Licensee Response to IE Bulletin 80-11 In response to the NRC Bulletin 80-11, the licensee re-evaluated all existing masonry block walls in safety-related areas at Millstone-3. The licensee established a program to review all masonry walls that had loads of 100 lbs. or greater attached to the The inspector reviewed the licensee program for compliance to the criteria of IE Bulletin 80-11 in the following areas:

5. Documentation On May 5, 1982 the licensee placed a construction hold (#89) of masonry walls and attachments in category I buildings. Prior to the release of Hold #89 (November 19, 1982) all future masonry walls in safety-related areas were deleted from the drawing and replaced with reinforced concrete walls and general notes were added to Stone and Webster (S&W) drawings 12179-EA-1E and EA-1F prohibiting attachments to existing block wall . Battery Room Wall Attachments The licensee completed their battery room block wall analysis in May 1982. This analysis, using mortar strength test results, found the wall stresses within operating plant allowables without additional stiffening and therefore structural modifications were not made by the license .1. The licensee authorized (via E&DCR) restricted attachments, such as, power receptacles, switches, equipment, etc., with a maximum weight of 50 lbs. to the battery room block walls. The inspector verified that the E&DCR was based on engineering calculation

1. 12179-SE0-SE-5256. Based on the referenced calculation and the response to IE Bulletin No. 80-11, the inspector determined that the 50 lb. limit was well within the requirements of the calculations for these wall No violations were identified in the above areas inspecte .

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5.2 Field Change Requests The inspector randomly selected licensee's Engineering and Design Coor-dination Reports (E&DCR's) and Nonconformance (N&D's) Reports for com-pliance with site documentatio . Use of Category 3 Item on Safety-Related Equipment The licensee issued E&DCR FE-22563 for the use of category 3 bus material to be used in safety-related panels 3EG*PNL A and B and the main electrical taps of the diesel generators. On July 5,1984 the licensee issued an inspection report IR E4A04804 tracking the E&DCR for the use of the bus material without category 1 documentatio On July 25, 1984 E&DCR FE-32888 superseded FE-22563. This new E&DCR added copper bus bars to the EGS panels and called out section 5.2 of specification E-350. This section of E-350 is for non-engineered, non-category 1 purchase On August 31, 1984 the licensee quality assurance organization issued a quality assurance surveillance report (PC-2858) on E&DCR FE-32888 indicating that the bus bar material lacked technical and qualit assurance requirements for the use in class IE, Q-listed equipmen On September 27, 1984 in response to PC-2858 engineering issued E&DCR TE-01473 which required that samples of the bus bar material be tested for conten . Material Analysis The bus bar material was sent to the Pittsburg Testing Laboratory for testing to IAW ASTM-B-187-83 criteri On February 28, 1985 the Pittsburgh Testing Laboratory report was issued stating that the bus bar material met the ASTM acceptance criteria in the following areas:

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Electrical Resistivity Per ASTM B187 and B193, and

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5.3 Institute of Electrical and Electronics Engineers (IEEE)

The inspector verified that Final Safety Analysis Reports (FSAR) criteria has been transcribed into lower tier documents for site use in the electrical and instrumentation area . NRC Inspection Reports NRC inspection reports in the electrical and instrumentation areas have discussed the compliance of the licensee's documentation to the FSAR criteria. The latest NRC report (IE 50-423/85-08), February 4-7, 1985 addressed, for example, process control cabinet wiring and instrumentation tubing installation. NRC inspection report 50-423/-

85-01, January 8-10, 1985 addressed, for example, the licensee compliance with a Construction Deficiency Report 83-00-11 pertaining to the Main Control Board termination In each of the above references the inspection criteria and the inspection personnel were knowledgeable of the site documentation requirements which, in turn, reflected the FSAR criteri Further discussions of the licensee personnel qualifications are discussed in paragraph 4.0 of this repor No violations were identified in the above areas inspecte .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, or violation Unresolved items identified during this inspection are discussed in Details, in paragraph 3 and .0 Exit Meeting The inspector met with licensee and contractor representatives (denoted in paragraph 1) at the conclusion of the inspection on April 12, 198 The inspector summarized the scope and findings of the inspection as described in this repor At no time during the inspection was written material provided to the licensee by the inspectors.