IR 05000423/1985069
| ML20140C804 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/16/1986 |
| From: | Eselgroth P, Finkel A, Joe Golla, Nicholas H, Vankessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20140C802 | List: |
| References | |
| 50-423-85-69, IEIN-83-20, NUDOCS 8601290002 | |
| Download: ML20140C804 (45) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I Report N /85-69 Docket N License N CPPR-113 Priority Category B Licensee: Northeast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conduct < v her 12-M; 20-22; 25-27,1985 Inspectors: M%~ l N( !-IL D H. F. qva51Ces el, Reaf to'r Engineer date
\ 15-8G H.H.Nichol'as,Startupfonsultant ,
date
/'Y Y A. E. Finkel, - ad Reactor Engineer date Oh g Gol
/h
,'Rhactor ngineer
/ ~/6- 86 date Approved By: /' /(-f(
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P. W. Eselgt h, Chief, Test Programs Section date Operati Branch, DRS
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Inspection Summary: Inspection on November 12-14, 20-22, 25-27, 1985 (Inspection No. 50-423/85-69)
Areas Inspected: Routine unannounced inspection of the Preoperational Test Program (P0T) including the witnessing of the Hot Functional Tests (3 INT-Appendices), the review of preoperational test procedures, the evaluation of the test results of completed tests, the witnessing of the Emergency Diesel Generator acceptance tests and the RPS tests, the review of the test results of the SIT and ILRT, witnessing of the retests on the modified lube oil system of the two EDGs, the review of the QC/QA involvement on the EDGs modified lube oil system installation and subsequent flushing and testing by NNEC0/NUSCO QA/Q The inspection covered 326 manhours onsite by four region-based inspectors and one NRC Engineering Consultan ,
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IWTAILS 1.0 Persons Contacted Northeast Nuclear Energy Company A. Andreya, QC Supervisor R. Bradley, Startup Engineer M. Brown, I&C Supervisor
- J. Crockett, Superintendent Millstone 3 D. Dickerson, S.tartup Engineer E. Fries, Startup Engineer M. Gentry, Assistant Startup Supervisor N. Hulme, Startup Engineer W. A. Loweth, Startup Engineer
- D. Miller, Jr. , Startup Manager W. Richter, Startup Engineer S. Sudigala, Assistant Startup Supervisor Northeast Utilities Service Company R. Bush, Project Manager
- K. Gray, NQA Staff Assistant B. Kaufman, Project Engineer J. Laware, Engineering Technologist, QA L. J. Nadeau, Project Engineer B. Nichols, Project Engineer
- J. Rhodes, Project Engineer
- 5. Orifice, Project Engineer Stone and Webster Engineering Corporation (SWEC)
W. Matajek, Project Advisory Engineer D. Taylor, Project Engineer U.S. Nuclear Regulatory Commission (USNRC)
- H. H. Nicholas, Engineering Consultant
- J. A. Prell, Lead Reactor Engineer
- R. J. Summers, Project Engineer
- Denotes those in attendance at exit meetin .
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2.0 Licensee Actions on Previous Inspection Findings 2.1 Open Items of Preoperational Test Program (Closed) Unresolved Item 50-423/84-08-01, " Questions on Calibration of Instruments Used in Tests" References (1) NNECO Internal Memorandum from D. Dickerson to J. Duddy,
" Resolution of NRC Inspection Number 84-08-01", dated October 4, 1985, with enclosures Discussion The NRC questioned the elimination of Appendix A from test procedures which required instrument documentation of calibration due dates and QA numbers. Only instruments used to record data would be recorde In reference (1), NNECO reasoned that installed instrumentation, as used in the test, were calibrated. Also, while test change 3 elimin-ated the requirement to record the calibration date of installed instrumentation, the instruments had, in fact, been calibrated at the time of the test, as shown in Enclosure 1 of Reference Furthermore, the identified instrumentation was used only to monitor the system and was not required to determine if flushing acceptance criteria were being me In view of the above considerations, this item is close (Closed) Unresolved Item 84-20-02, " Service Water Intrusion into Auxiliary Feedwater" References (1) Meeting Minutes 12-18-84, PORC 3-84-108, Millstone 3, page 5, NUSCO (2) Northeart Utilities memorandum, MP-3-SU-47, M. E. Gentry to J. O. Crockett, "Results of Investigation into PIR 48-84, Service Water Crosstied to Auxiliary Feedwater", dated December 3, 1984 (3) Northeast Utilities memorar.dum, NMC-85-175, M. J. B. Hudson et al to L. A. Chatfield, " Millstone 3 Condensate and Feedwater Systems: Assessment of Corrosion Damage Subsequent to Sea Water
- Intrusion", dated July 29, 1985
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- 4 Discussion There were two direct causes of the service water intrusion
- The mispositioning of Henry Pratt butterfly valve 3SWP*V24 The operator believed he closed the valve because the valve position pointer was in the closed positio This was not true
because the pointer set screw had slippe . The spoolpiece 3SWP-010-189-3 had been re-installed and should
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not have been. This was the result of an instruction in the work order for the auxiliary feedwater system hydrostatic tes Both causes were investigated in depth (see Ref. 2) as-were the consequential damages of the incident. The lessons learned from
- the investigation have been applied to future operations. The J slipping of the set screw on the Pratt valves turned out to be a generic problem and was picked up under the corrections for i the Valve Position Indication Problem, another open item
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(50-423/85-02-01). The correction consisted of drilling a hole f in the pointer shaft to ensure positive mechanical penetration i of the set screw. The second problem was addressed by instruc-ting Construction Work Permit writers to clearly identify the I
scope of work and to follow existing procedures. System clean-liness was restored in the contaminated portion of the Auxiliary Feedwater Syste Samples were taken to verify the system's cleanliness in accordance with the acceptance criteria for chloride concentration and water conductivity. An evaluation
! also was made of the permanent effects on the AFW system com-l ponents exposed to the contamination existing after the incident.
- These evaluations were made by NUSCO Nuclear Materials and i
Chemistry Section (Ref. 3).
The consequences of the exposure were minor for most materials.
3 Recommendations were made and followed. The inspector had no i
further questions on this item.
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- (Closed) Unresolved Item 85-06-01, " Late POT Procedure Submittair for
- NRC Review (60 Day Rule)
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Reference (1) Letter D. Dickerson to W. Potter, NNECO, " Resolution of NRC i Inspection Number 85-06-01", October 10, 1985
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Discussion
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A survey made by the licensee (see Ref. 1) indicates that approximately 78% of the Phase 2 test procedures were submitted 2 months prior to the performance release date. This survey, however, does not include
- any of the Phase 3 test procedures (precore hot functional). More
- than 50% of the Phase 3 test procedures were delivered for NRC review i less than 60 days prior to test performance.
Since Phase 2 and 3 tests have been completed, this item is considered close i'
(Closed) Unresolved Item 50-423/85-06-02, "No Means of Shifting Lube
. Oil Filter on Running EDG Diesel Engine When Delta P is Exceeded" i References:
(1) Deficiency No: DDR-338, NUSCO, March 19, 1985
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(2) Engineering and Design Coordination Report, E&CCR T-P-07233, Stone and Webster Engineering Corp. (SWEC), September 4, 1985
- (3) E&DCR T-J-07809, SWEC, October 21, 1985 (4) E&DCR T-J-07827, SWEC, October 21, 1985 (5) E&DCR T-P-07879, SWEC, October 26, 1985 -
- Discussion
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The licensee has responded to the Unresolved Item by installing the additional filter on both Emergency Diesel Generators. Both of the filters for each unit are mounted off-skid on independent foundation The installations are ccmplete and one of the EDGs has been retested
with the (flushed) modified system. No problems have been encountered.
- This item is close !
(Closed) Unresolved Item 85-12-02, " Reactor Head Vent Valve Problems" References (1) Letter J. N. Steinmetz, Westinghouse-WRD to R. W. Ackley, SWEC, NES 39092, " Reactor Head Vent Valves", dated August 5,1985
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(2) Deficiency DDR 395, June 6,1985, NNECO (3) Interoffice Memo Barrett Nichols, NUSCO, to Harold Thompson, NNECO, "RCS Head Vent Valves", dated September 19, 1985 l
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4 i Discussion
- The head vent valves were wired so that any transient which caused
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, the valve to open would hold them open, i.e., the signal was locked in. Such opening of the valves constitutes " inadvertent opening of
- the reactor pressure boundary" and is not acceptable (Ref.1).
! The wiring was modified to prevent this kind of operation of the valves.
I The inspector witnessed the retest after the wiring modification.
The problem was resolved. This item is closed.
4 (Closed) Violation 50-423/85-23-01, " Flooding Service Building Caused
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by not Following Test Procedure" References
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(1) Letter Northeast Utilities Company (NUSCO) to USNRC Region I,
" Response to I&E Inspection No. 50-423/85-23", dated August 7, 1985 (2) NUSCO Internal Memorandum, NNEC 3-2628, from J. O. Crockett to Distribution", Millstone Unit 3 Startup Manual, Revision 4",
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dated August 19, 1985
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Discussion Testing and flushing activities were accomplished without closing valve FPW-V555 as required by procedure (red tag). Partial flooding of the service water building resulte NUSCO's response to the violation (Ref.1 and 2) was that the cause of the flooding incident was a personnel error. Additional controls would be put in place to l prevent or reduce future chances of reoccurrence of the same or similar J
events. These additional controls were identified in Rev. 4 of the Startup Manual (Ref. 2). Since the adoption of these new control measures, no further flooding accidents have been observed. This item is close (Closed) Unresolved Item 50-423/85-25-01, "EDGs Fuel Oil Filter
, Located in Area Which Could be a Fire Hazard"
References (1) Engineering and Design Coordination Report, E&DCR T-P-07134, _
Stone and Webster Engineering Corp. (SWEC), August 28, 1985
- (2) Deficiency No. DDP-550, NUSCO, July 21, 1985
l (3) E&DCR T-P-07904, SWEC, October 29, 1985
l (4) E&DCR T-P-07513, SWEC, September 23, 1985 i
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Discussion The Fuel Oil Filters of the EDGs are mounted at fuel injector elevation on the diesel engine. It was perceived that failure of the filter head flange seal or nearby fuel oil piping (tubing) could spray fuel oil into the open generator enclosure and cause a fire. Fuel oil piping in the vicinity of the filter did experience a failure cracked tee. Oil, however, did not spray but oozed out of the crac The licensee has responded by installing a protective housing around the filters. This housing is sealed and draine Housing and drain piping are seismically supporte The inspector has no further questions on this ite (Closed) Unresolved Item 50-423/85-25-01, "EDGs Fuel Oil Filter Located in Area Which Could be a Fire Hazard" References (1) Engineering and Design Coordination Report, E&DCR T-P-07134, Stone and Webster Engineering Corp. (SWEC), August 28, 1985 (2) Deficiency No. DDR-550, NUSCO, July 21, 1985 (3) E&DCR T-P-07904, SWEC, October 29, 1985 (4) E&DCR T-P-07513, SWEC, September 24, 1985 Discussion The fuel oil filters of the EDGs are mounted at fuel injector eleva-tion on the diesel er.gin It was perceived that failure of the filter head flange seal or nearby fuel oil piping (+,ubing) could spray fuel oil into the open generator enclosure and cause a fir Fuel oil piping in the vicir.ity of the filter did experience a failure, cracked te Oil, however, did not spray but oozed out of the crac The licensee has responded by installing a protective housing around the filters. This housing is sealed and draine Housing and drain pipin; are seismically supporte The inspector has no further questions on this ite (Closed) Unresolved Item 50-423/85-43-01, " Emergency Diesel Fuel Oil Pump Failure due to Dirt in Piping on Suction Side of Pump" References (1) Plant Incident Report No. 116-85, " Emergency Diesel A Fuel Oil Pump Failure", incident date August 2, 1985, report date August 5, 1985
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(2) Construction Work Permit, CWP M3-85-17518 Discussion The inspector reviewed the work order for the ongoing piping modifica-tio The work order clearly identified the need for cleanliness during this piping modification and inspection by Field Quality Con-trol (FQC). An inspection report was produced by FQC, Again, this report showed that there had been an inspection for cleanliness prior to closing the pipin Ref. (2) indicates that the suction lines of the failed pump had not been flushed while the rest of the system had been. It would appear that the pump failure was caused by the dirt in the pump suction lines which had not been flushed. There was no requirement for it to be flushe: The licensee replaced the pump, flushed the dirty suction lines, and
- retested the syste No reoccurrence of this event has been experi-enced. This item is closed.
(Closed) Unresolved Item 50-423/85-43-02, "EDG Modified Fuel Oil Filter Part Identification Problens"
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(1)~ E&DCR No. T-P-07721, SWJC, October 11, 1985 (2) E&DCR No. T-P-07849, SWEC, October 23, 1985
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Discussion
i Parts identification for the modified fuel oil filter parts of the Emergency Diesels was found to be the same as for the old parts. The
. licensee contacted the filter manufacturer (Nugent) directly for uni-que identification of these new parts. Nugent supplied new drawings with;the new part numbers. The inspector was informed that this in-formation will be entered into the PMM The inspector had no further questions on this ite (Closed) Unresolved Item 85-61-01, " Lack of POT Procedure for TD/
, Auxiliary Feedwater Pump Tests"
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Reference (1) Memorandum F. Chamberland (NNECO) to H. F. vanKessel (USNRC),
" Turbine Driven Auxiliary Feedwater Pump", November 7,1985
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Discussion The phase 1 procedure for the mechanical testing of the turbine driven Auxiliary Feedwater Pump, T3322-1M07 had been used in phase 1 using auxiliary steam. During the phase 3 testing of the AFW system under 3 INT-3019, main steam became available to retest the turbin Pro-cedure T3322-1M07, however, was not used to complete the phase 1 testing which included the speed adjustments to the Terry Turbine governor. The inspector witnessed these tests and was satisfied that the speed adjustments were effective and that name plate ratings on the turbine were achieved. The licensee agreed to make sure that the test data obtained would be duly recorded. The inspector had no further questions on this ite (Closed) Unresolved Item 85-61-03, " Illogical Sequence of Annunciator Panel Identification" References:
(1) "PMMS ID N3CB MCB SYS 3414," Work Order M3 85 3486C, for Correc-tive Maintenance, dated November 4, 1985, " Main Board Annunciators Need to be Numbered" Discussion Annunciator panels 2A through F were not identified on the main con-trol board (MCB). The illogical identification sequence adopted for these panels led to errors in interpretation during the phase 3 test-in Letters and nunbers have been placed on the MCB to correct this omissio This item is close (Closed) Unresolved Item 50-423/85-61-05, "Use of Surveillance Procedures in lieu of POT Procedures on Reactor Protection System (RPS)
References:
(1) Surveillance Procedure SP-3446F31, " Refueling SSPS Tests",
Revision (2) Surveillance Procedure SP-3446B11, " Solid State Protection System (SSPS) Operational Test", Revision Discussion
. The original POT procedures T3406P and T3409-P had been deleted and the surveillance procedures, references 1 and 2, will be used in their plac Since the surveillance procedures are not under the jurisdic-tion of the Joint Test Group (but under PORC), they would not have the benefit of JTG review and approval.
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A comparison of the referenced surveillance procedures with the deleted POT procedures revealed that test coverage is more meaningful and com-l plete in the case of the SP The problem of not having JTG coverage,
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was overcome by an agreement with JTG to include these items in their l review cycle. This agreement was duly recorded in the JTG meeting
- notes. The inspector had no further questions on this ite (Closed) Unresolved Item 85-61-07, " Processing of 42 NRC Identified Test Exceptions with Safety Significance" References:
i (1) PCP List, " Items of Special Interest, Computer Listing of Phase
2 Work Items, Run Date November 20, 1985, Data Date November 20, 198 Discussion Some 42 items were selected from the current PCP listing, a licensee listing of test exception work items to be completed prior to Fuel Load, at a meeting with the licensee at the NRC Regional Office, on the basis of safety significance (see Ref.1). All of these items
. were resolved with the exception of 6 items which the licensee wanted
! to retie to later startup milestones. Three of these 6 items were deficiencies of the Polar Crane. These 3 items were discussed with the licensee. All of these items concerned subcomponents which would not be used in the initial fuel load operations. The other 3 items were acceptable for completion by later milestones of the startup program. The inspector had no further questions on this ite .2 Open Items (NTOL)
(Closed) Construction Deficiency 50-423/82-00-05 (S0-25), " Failure of pinion gear shear keys in Limitorque Model SB0 motor operated valves."
Westinghouse letter NEU-4655 dated August 6, 1985 to Stone & Webster stated that their review of the shop orders for Millstone Unit 3 indicates that none of the seven EMD manufactured valves, supplied to NEU, used an SB-0 series Limitorque actuator. Therefore, no changeout of pinion keys was require Licensee letter F0887A dated November 1,1985 to the NRC repeated the above and determined that this is not a significant deficiency for Millstone Unit l Based upon the acove considerations, this item is close ;
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i 11 (Closed) Unresolved Item 50-423/82-10-01): "Inspectability of RPV nozzle il_ cast pipe double welded joint."
l The inspector reviewed documentation provided by the licensee and data sheeis representing the ultrasonic examination of reactor coolant loop welds, including nozzle to safe end welds and safe end to main
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coolant piping welds. These examinations were performed by Westing-house Electric Corporation personnel to meet ASME Section XI preservice inspection requirement Based on the above, this item is close (Closed) Significant Deficiency Report (50-423/83-00-03, SD34), "ITT Grinnell Figure 306/307 mechanical snubber attachment interference."
IE Information Notice 83-20 was issued to identify a potentially significant interference problem pertaining to specific ITT Grinnell mechanical snubber assemblies known as Figure 306/307. The potential interference and associated loads could possible bind a snubber and prevent the snubber from performing its intended function, subse-quently, affecting the associated piping system. To resolve this issue, ITT Grinnell performed various. tests for the considered worst case hardware interferences which produced results with acceptable snubber performance. Supplemental to the technical test report No.
PE-499-1 by ITT Grinnell, the licensee elected to survey suspect snubbers on site. Snubbers found with unsatisfactory clearance were to be replaced or modified according to vendor approved procedure The inspector reviewed the ITT Grinnell test report, SWECO E&DCR No's. F-J-20972, T-J-00758, and F-J-34605 and the associated SWECO QA report The inspector had no further questions on this potential interference problem pertaining to these snubbers considering this evidence of the licensee's efforts to address IE Information Notice 83-2 This item is closed.
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(Closed) Construction Deficiency Report 83-00-09 - Containment Liner Stud Spacing in Excess of Design The seismic forces due to SSE were used as a loading condition in the overall analysis of the reactor containment as well as in the design of the reinforced concrete wall, steel liner, and the anchor stud The forces produced from the SSE that must be designed for are in-plane shear and the normal forces produced by the overturning momen The in plane shear and the normal forces are maximum at the base of the containment. These forces line'arly reduce to a minimum at the spring line about 130 feet from the bas The reinfcrcement in the concrete wall has been designed for the maximum in plane shear combined with the normal force (couple) due to overturning moment. The liner and the anchor are not load carrying components required to resist these forces in the membrane zon .
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! The location of missing anchors is in the membrane zone. Therefore, the effects of the global SSE forces on the anchors need not be con-sidered. However, in the local area of the missing anchors, the ef-fect of the seismic horizontal excitation due to the SSE does produce an out-of plane inertia force on the liner. Consequently, the anchors will have an additional tensile force from the 3/8 inch thick liner
, with an acceleration of 0.6g. Based upon this horizontal response of
, the containment at the spring line, a tensile force of about 15 pounds
/ anchor is produce This additional 15 pounds / anchor tensile force is small enough to be considered negligible in the overall anchor evaluation.
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Therefore, the effects of the SSE have been considered in the evalua-tion, and these effects are insignifican This response and the response to questions 220.39 and 220.40 close this CDR ite (Closed) 83-14-02 Violation, " Radiographs Exceed Density Requirements of ASME Code" This item concerns the Tubeco pipe weld radiographs that had pene-trameters placed across the area of interest and other radiographs that exceeded code film density requirement During an onsite inspection, the inspector rereviewed radiographs with the licensee and agreed to the ecceptance of the penetrameters across the area of interest, due to an ASME Section V code change of requirements. Also, the inspector reviewed re-radiographs of welds with prior density problem Based on the above corrective action, and the preventive action changes the licensee made to the sites radiographic program, this item is ac-ceptable to the NR This item is considered close (Closed) Significant Deficiency (84-00-07, SD 56), "Tubeco Unacceptable Shop Weld Piping Radiographs".
NRC review of Tubeco shop radiographs during inspection 423/83-14 and l 84-20 resulted in NNECO review of all QA Category 1, ASME III, Class 1, 2 and 3 Tubeco shop weld radiographs with the exception of several recirculation spray system (RSS) welds. The letter dated November 1, 1985 (0peka to Murley) summarizes the review results and corrective actions including both reradiography and repair to weldments required to reach compliance with the ASME Code Section III fabrication and inspection requirements. One weld, FWS-15-7-4-2 (Shop Weld C), was
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noted in this letter to be scheduled for fin;l radiography during the week of November 13, 198 !
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13 The review of radiographs and records of NDE of 2192 weldments iden-
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tified 49 RT (radiographic) rejects, 24 MT (Magnetic Particle Test)
rejects and one UT (ultrasonic) reject. These rejected welds were evaluated to determine the safety implication of the rejectable NDE indications. The result was that the safety related functions of the
, associated piping systems would not have been affected if the reject-able NDE indications had gone undetected. Therefore, the problem was i found not to be a significant deficiency. Of the 74 rejectable indi-cations, 70 were repaired to conform to the ASME Code Section III requirements. A total of 699 weldments had additional NDE performed to assm'e ASME Code compliance. After review of the above letter of November 1, 1985, its references, and the November 7, 1985 memorandum
from SWEC (Nace) to NUSCO (Bush), the inspector concluded that the Tubeco shop weld radiographic issue had been suitably reviewed and that adequate corrective actions had been take The remaining problem is that several welds in the RSS system do not
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have radiographs, have poor quality radiographs, or show ASME Code unacceptable indications on the radiographs. These RSS system welds are located in concrete and are not accessible for reexamination or repair. The 12" inch diameter RSS process pipe is type 304 stainless with a 0.375 inch nominal wall thickness. The minimum wall required, to survive the required hydrostatic pressure test of 155 psig, is 0.019 inch. The NNECO review of the RSS piping radiographic issue
! and basis for requests for exemption from the ASME Code inspection requirements is contained in the September 18, 1985 letter by Opeka to Youngblood. The inspector reviewed this letter, concluding that i the radiographic examination documentation of the RSS welds is not a safety issu This item is closed.
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(Closed) Unresolved Item 84-01-01, "Impropoer Material Substitutions Bahnson Air Units."
Unresolved Item 84-01-01 concerns improper material substitution by
- the Bahnson Company on heating, ventilation, and air conditioning units supplied to Stone & Webster for the Licensee.
i Four instances of substitution were identified as follows:
1) Self tapping screws are being used to fasten the cooling coils to the HVAC unit frame whereas high strength (ASTM A 193 B8)
bolts are required by the seismic analysis (identified by S&W).
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1 Disposition:
Stone & Webster Engineering Corp. (SWEC) Nonconformance and Disposi-tion reports, (N&D) 3530 and 10848, were written requiring replacement of the self tapping screws with acceptable nuts and bolts. Verifi-cation of this action was made on September 24, 1985 by SWE The Inspector finds this disposition acceptable and this item close ) Stove bolts and wing nuts were used to attach the fan motor belt guard whereas high strength (ASTM A 193 B7) bolts were required by the seismic analysis (identified by S&W).
Disposition:
S&W Engineering and Design Coordination Report, (E&DCR) F-B-22957, i-required reinstallation of the belt guards in accordance with the i '
manufacturers accepted design. The completed work was inspected and accepted by SWEC on November 29, 1984. The inspector had no further questions on this ite This item is closed.
1 3) Low strength bolts were used to attach the Barry Blc <er fans to i
the HVAC unit frame whereas high strength (ASTM A 4t9) were required by the seismic analysis (identified by NPC).
Disposition:
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SWEC N&D 9088 required the low strength bolts to be replaced by
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acceptable bolt This work was inspected and found to be acceptable by S&W on March 4, 1985. The inspector had no further questions on
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this item. This item is close ) Improper material substitution by S&W was noted on three of the ten units (3HVC*ACU38, 3HVC*ACU4A, and 3HVC*ACU48) in that low i strength, drilled-in, anchors were used to anchor the air hand-ling units to the floor , whereas high strength (ASTM A325) anchor bolts were required by the seismic analysis and the Bahnson drawings (identified by NRC).
Disposition:
SWEC N&D 8523 required installation using acceptable bolts. This work was inspected and accepted by SWEC on November 5, 1984.
I The inspector has no further questions on this item. This item is
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(Closed) Unresolved Item 84-01-03, " Lack of Vendor Documentation
- Requirements."
. The licensee is depending on subcontractor-stored QA records to establish material traceability. An example of these records are the as-built drawings annotated with the applicable material heat number These drawings are only available at the Bahnson manufacturing facil-
- ity and the recordkeeping requirements committed to by the licensee
and S&W were not invoked in the procurement specificatio Disposition:
Attac':ent 1 to the letter from the S&W Project Engineer to the licu aee, dated November 7, 1985, states: "these as built drawings have since been submitted to SWEC (transmittal from Flakt Products, Inc., to SWEC dated 10/15/84)."
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The inspector accepts this disposition since the required records are now controlled by SWEC.
t Unresolved Item 84-01-03 is closed.
, {0 pen) Noncompliance Item 423/84-23-01, " Cables Not Properly i
Installed or Color Coded."
, Cables from vertical trays were unsupported for a distance of 10 fee l Cable vertical runs in cable spreading room, of 20 feet or more, were i attached to support structure by plastic (non-seismic) tie wrap Black cables, entering electrical penetration, were not identified as required to indicate division / channel orientation.
This item remains open pending licensee walkdown.
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(Closed) Unresolved Item (50-423/85-00-03), " Potential Inoperability of Fire Dampers."
The applicant, in testing fire dampers functionally under normal flow conditions, determined that some dampers needed to be modified in order to properly close. The modifications included the addition of weights
, or additional springs to aid damper closure. However, due to high duct work air velocities, some dampers continued to fail the function-
, al tests even after the modifications. The applicant identified the
! dampers involved and revised the Emergency Operating. Procedure 350 to
include the step that, in the event of a fire, the associated verifi-
! cation fan will be turned "off." This item is resolved.
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(Closed) Construction Deficiency 432/85-00-19 (SD-86), " Seismic Qualification of GE Relay, Type PVD-21" General Electric Type PVD21 Differential Relay located in the Class 1E 4160 volt switchgear caused circuit breaker trip due.to mechanical impact to the door. Analysis alone is not able to accurately deter-mine that a potential common mode failure of both Class 1E busses could not occur. The relays were to be reteste Licensee's letter F0846A, dated October 18, 1985, stated that the retest of the PVD21 relays, to verify the seismic qualification, was performed and that the relays exceeded the seismic requirements for the 4160 Class 1E switchgea Based upon the above considerations, this item is close (Closed) Bulletin 85-02, "Undervoltage Trip Attachments of Westinghouse DB-50 Type Reactor Trip Breakers" l
Faulty undervoltage trip attachment (UVTA) did not provide enough lifting force to the breaker trip bar. The breaker is identified as the Westinghouse Type DB-5 The licensee identified a misoperation of Westinghouse DS-416 Reactor Trip Switchgear (CDR 83-00-04) due to a missing retaining ring on one of the two UV attachment pivot shafts. The licensee issued Engineering and Design Coordination Report, E&DCR T-C-00950, dated July 12, 1984 which listed the following three changes:
Westinghouse Field Change No. Notice NEUM-10563, change shunt trip attachment hardwar *
Westinghouse Field Change No. Notice NEUM-10564, change undervoltage trip assembl * Westinghouse Field Change No. Notice NEUM-10565, add the auto-shunt trip pane The above changes were verified by using Test Procedure T-340-601E02 titled, Reactor Trip Switchgear, Tag Lineup Form, Valve Component Test Matrix Form, Low Voltage Power Circuit Breaker Test Data, Low Voltage Circuit Breaker Electrical / Mechanical Test Data, Low Voltage Circuit Breaker Trip Test, and the Bus Bar and Termination Resistance Data Sheet A review of the test results indicated that the changes made per E&DCR No T-C-00950 to the 05-416 breakers were within the sper.fication requirements of drawings 2476-230-001-031, 032 and 03 This item is close .
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(Closedj Non Compliance Item 432/85-04-01, " Inadequate Class 1E Wiring Design Control" t
The licensee's design control measures for Class 1E wiring did not assure that applicable requirements were correctly translated into appropriate documents. Eight termination tickets were not revised to incorporate required engineering change Licensee's response letter A05058, dated August 16, 1985, indicated that:
This item was a random error / oversight and not a programmatic concer * The program for initiating termination information had been improve * Policy change required termination ticket to be issued at the same time as the initiating drawing change document to reduce inconsistencie;.
None of the identified inconsistencies resulted in a technica]
concern affecting the final configuration of associated circuitry after component checkout in Phase-1 start-up testin ,
The licer ee has taken the necessary corrective action to correct and prevent this problem in the futur This item is close (Closed) Unresolved Item 85-04-94, " Unmarked Fasteners Used for Safety Related Equipment" Unresolved Item 85-04-04 concerns specific discrepancies on seven drawings and errors in document distribution, filing, and updatin Except for 1(d) below, all other parts of this item are closed as follows: Discrepancies involving post-turnover wiring changes for Class IE cable termiaations were discovered and were not documented at the time as required by Section 5 of the NNECO Start-up Manual (Section II.B.2.b.(6)). Drawing EE-3Do-S requires WHT-BLK conductor of cable 3LMSBPC002 to De terminated on terminal TB-640 P Conductor was not terminate .
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Disposition:
This conductor terminated on production maintenance management system (PMMS) work order M3-85-12284 and was inspected by SWEC on 5/8/8 Drawing EE-3DP-5 shows Red Conductor of Cable 3CCPBC 350 at TB-648 Pt 18 and GRN-Blk as spare. As installed, Red is space and Grn-Blk is terminated as abov Disposition:
The inspector reviewed the drawing and found it had been revised to reflect the as built conditio Drawing EE-3DP-5 shows ORG-Blk conductor of cable 3CCPBC615 as spare but it is terminated at TB-654 Pt 2 Disposition:
This conductor has been lif ted and made a spare per PMES work order No. M3-85-3603 Drawing EE-2DQ-5 shows Blk-WHT conductor of cable 38YSIPC601 on TB666 Pt 15. This wire is on TB666 Pt 14 which is in the process of being correcte Drawing EE-3DK-6 shows GRN-BLK conductor of cable ?SWPAOC350 on TB-609 Pt 22 and Whi-BLK were on TB-609 Pt 24. As installed is opposit Disposition:
The above conductors are reversed on both ends. The drawing has been revised to reflect the as built conditio Drawing EE-EGK-3 shows BLK conductor of cable 3RPSA0x812 on TB-506 Pt 4 and WHT on TB-506 Pt 5. These conductors are reverse Disposition:
Evaluation by SWEC indicates field condition is correc The drawing has been revised to reflect the as built conditio Drawing EE-3GT-3 shows BLK conductor of cable 3RPSPX812 on TB-506 Pt 4 and WHT on Pt 5. As installed, these are reserse .
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j The conductors have been corrected in the field and the drawing
revised to reflect the as built conditio . Errors in document and specification distribution, filing and updating were identified at the controlled drawing station That resulted in lack of the drawing correctness specified in SWEC Construction Methods Procedure 11.1, Job Site Document
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Control, Revision 0, and SWEC NEAM 32, Supplier Technical
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Document Review and Distribution-Millstone 3-NUSCO, Revision 9 q (Section VII.B.1).
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As a direct result of this iten, SWEC developed the Millstone Auto-mated Document Record Information System (MADRIS) to assure that or-ganizations using documents were cognizant r.f the correct revisions and applicable change notices to documents they use. Phase I of this
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System became operational on August 12, 1985. This phase contained nine distribution lists and nine indices of 15 types of design docu-j ments and six types of change control document This item is closed.
(Closed) Unresolved Item 85-04-05, Inadequate FQC Inspection of Pige Supports, Foundation Bolts and Welds" Unresolved Item 85-04-05 has three parts relating to the SWEC Field
- Quality Control (FQC) effectiveness. These three parts are closed as
! follows: FQC acceptance cr.iteria for placement of pipe supports and restraints were different than those of design engineers. That
! resulted in support attachment locations which were not as i depicted by design drawings, as noted in 5 specific support attachment locations, and as indicated by a lack of accounting for wide location changes in support / restraint design calcula-tions and in the associated FQC acceptance criteri Disposition:
i During a subsequent inspection (Inspection Report No. 50-423/85-54)
- the inspectors did a walk down of accessible portions of the Quench
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Spray System, the Recirculation Spray System, and the Residual Heat
- Removal System. This walk down included pipe supports and restraints.
l This inspection found substantial agreement with the as-built drawings
- indicating that FQC inspections are now adequat This item is close . FQC accepted equipment foundation bolting connections which were not installed as designed .
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Disposition:
SWEC has reinspected all QA Category I equipment foundation bolting and rejected 42 pieces. The inspector has verified that the bolting is acceptabl . Accepted welds in skewed pipe supports were not of the size required by desig Disposition:
During Inspection (Report No. 50-423/85-54) The inspector performed a detailed examination of 29 supports. No evidence of undersized welds was found. Based on this inspection, the problem of undersized obtuse welds has been correcte This Item is close (Closed) Violation 85-04-06, " Lack of Prompt Identification and Effective Corrective Actions in Conditions Adverse to Quality"-
This violation concerns the prompt identification and correction of conditions adverse to qualit Four items were specifically iden-titled as follows: Violation - Numerous separation deficiencies within the main control boards had not been promptly identified in vendor (or modified vendor) wiring installation Disposition An inspection performed with Production Maintenance Management System (PMMS) Work Order M3-85-37560 on panels 3CES* MCB-MB1 through MB8 has been performed. Cable separation has been found to be in accordance with the acceptance criteria of E350, Appendix C, Section 6.1 para-graph 4 and Section This violation is closed, Violation - Measures have not been provided to bring about prompt action tc avoid recurrence of significant nonconformances noted in N&Ds and ir Thie items remains open. The response provided by the licensee did not address how specific nonconformances reported in NGDs and IRS are analyzed to determine the cause and what system is used to prevent repetitio .
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21 Violation - Previously identified deficiencies in the area of preventive maintenance had not been adequately corrected after turnover of equipment to operation Disposition The inspector has reviewed procedure MP 3704A, Revision 1, Preventive Maintenance Program, and MP 3719MB, Revision 0, Mechanical Equipment General Inspections and found them acceptable to preclude future problems. In addition, routine scheduling is now being done via the PMMS (computer database) through automatic issuance of work order This violation is close Violation - Identified document control deficiencies have not been adequately correcte Document control has been addressed in item 85-04-0 Based on the decision to close that item, this violation is close (Closed) Unresolved Item (50-423/85-14-01), "EDG - Fuel Injection Pumr Seizure Problems" As a result of recurrent Emergency Diesel Generator Fuel Injector Pump failures / seizures, the Licensee contracted with FEV of America to con-duct an independent analysis of the problem. The FEV of America Re-port (FEV-108-85-11) concluded that the failures were probably caused by particulate debris in the pumps and nozzles. The probable reasons for this contamination were identified as a combination of: 1) insuf-ficient cleanliness due to poor quality control during and after manu-facture; 2) dirt which was not removed by steady flow flushing proce-dures; 3) fuel filter bypass due to warped filter plates; and 4) weld slag from a T-fitting on the clean side of the fuel oil filte This report, in conjunction with licensee's actions discussed in Inspection Reports 85-24 and 85-27, and the successful completion of diesei test-ing suggests that this problem has been resolve The inspector had no further questions on this ite '
(Closed) Violation _ 423/85-22-01, "ASME Code Rejectable Indications of RSS Pipe Welds" Two of thirty four safety related pipe welds radiographed by the NRC had ASME Code rejectable indication These indications were.not previously identified by radiography. One of these welds is a Tubeco Shop weld which is addressed in the response to the construction deficiency report (CDR) 84-00-07. The otner weld is a field weld
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that was disposicioned and repaired under the nonconformance and disposition report (N&D) number 14076. The inspector reviewed the response to the Violation dated September 12, 1985 and N&D 14,07 This documentation indicates that the field weld has been repaired and radiographed. Corrective and preventive actions were noted in the response to the violatio This item is close (Closed) Unresolved Item (423/85-22-03), "Elencated Indications in Welds CHS-FW5 and FW8" Field radiographs with weld edge undercut were not noted on radio-graphic reader sheet During the NRC NDE-Van inspection, the licensee radiographs and reader sheets for 106 field welds were reviewed. The radiographs for two welds contained elongated indications that during the NRC inspection were found to be undercut on the outside surface of the weld The reader sheets for these two welds CHS9 FWS and CHS 15 FW8 were re-viewed and noted as corrected to indicate the presence of outside surface indication This item is close (Closed) Unresolved Item (423/85-22-04), " Adequacy of Ultrasonic Test
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Block UT-7" This item references the 3.28" thick ultrasonic test block UT-7 manu-factured from a cast elbow, SA 351 grade CF8A. This test block is applicable to main coolant loop cast pipe from 27 inch to 31 inch Inside Diameter and 2.1 to 3.81 inch thicknes The letter of July 1, 1985 (0peka to Young Blood), including the NNECO responses to specific questions concerning the ultrasonic inspection technique using test block UT-7, was reviewed. The test block was found to provide a conservative reference for the ultrasonic examina-tion of the cast piping materia This item is close (Closed) Unresolved Item 85-23-02, " Seismic Adequacy of Vital Battery Supports" The design requirements did not specify maximum spacing between the battery cells and the rack stringer .
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The licensee issued Deficiency Report Nos. UNS 4326 and 4325 identi-fying the various battery and rack conditions identified in IE Report 85-2 Engineering and Design Coordination Report (E&DCR) 00732, dated October 17, 1985 identified the modification work required on the battery rack system. The required work was documented in Produc-tion Maintenance Management System (PMMS) work orders M3-85-34628, l 34634, 34638, 34641 and 24701. Verification of the work was document-ed by the licensee's quality assurance program in document NEC-00144, I
system number 34530, AWO-M3-85-30719 dated October 17, 1985.
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On a sampling basis, the inspector verified that the above work was completed and inspecte This item is close (0 pen) Unresolved Item 85-28-01, " Lack of Equipmer. ~lualification Data for Litton Veam Connectors" The licensee uses bayonet type (Litton-Veam CIR Series) electrical connectors to achieve the environmental seal at the connector inter-( face with their control instrumentatio The inspector identified varying degrees of connector tightness between various connector installations. Based on these observations, the sealing qualities of the connector assembly were questione The licensee completed a qualification test program on (15) fifteen Litton-Veam cable-connector assemblies (CIR Series) during November 198 The qualification testing was performed by the National Technical Systems (NTS) DC Division, Hartwood, VA 22471 (Report N A) for the Litton-Veam Division of Litton Systems, Inc.,
Watertown, CT (06795).
The test descriptions and results of Section 6.0 of the qualification report are documented in the report with test failures being defined with reasonable corrective actions being taken. The problem with the qualification report is that no testing of the LOCA profile in Attach-mer.t A of the qualification specification was performed. The High Energy Line Break profile (Out-of-Containment) was performed with the data being supplied with the qualification repor This item remains open pending licensee's supporting test data demonstrating that the Litton-Veam CIR Series connectors have passed the LOCA profile (In-Containment) as described in the NTS qualification program plan No. 558-1657, Revision _ _ - - _ - _ - _ _ _ - _ . - - - _ _ _ _ -
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(Closed) Unresolved Item 85-34-02, " Equipment Qualification Evaluations for Silicone Rubber Used in Instruments" Activation Engineer Different for same material. The inspector raised the question to the Licensee as to why two Environmental Qualification Test Reports (Action Report No. 16683-1 and Wyle Report No. 57654)
gave different activation energies for the same silicon rubber used in the Kamen Model KDA-HR Area Detectors to determine qualified Life (40 years).
The inspector, idependently calculated the activation energy (EA)
using the Arrhenius equation:
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Ta = Ea 'l -1] exp ts , Kb .Ts Ta)_
ihe numerical values for aging and temperature were extracted from the Acton Test Report. The activation energy calculated is 0.75 eV in lieu of 0.91 eV which is given in the report. The difference in valves was due to an error in the test report when converting from degrees centigrade to degrees Kelvin. Although the slight difference, the activation energy of 0.75 eV environmentally qualifies this sili-con rubber for 40 years and is a conservative value. Additionally, activation energies are not necessarily the same for the same materia The energies calculated are a function of testing; i.e., elasticity (Acton Test Report) and Compression (Wyie Test Report) will yield different activation energie Further, the Wyle Report listed an activation energy of 1.86 eV which yielded a qualified life of 228 years which, additionally, supports qualificatio This item is considered close (0 pen) Unresolved Item 85-36-02, " Updating of Procurement Procedures" Administrative Control and Nuclear Engineering and Operation procure-ment related procecures were not updated to reflect the inclusion of MP-3. This is an unresolved item pending revision to ACP-QA-3.03, ACP-QA-4.01, ACP-QA-4.02, ACP-QA-4.03, NE0-6.01, and NE0-6.0 The inspector has reviewed ACP-QA-3.03 Revision 28, ACP-QA-4.01 Revision 12, and ACP-QA-4.02B Revision 0 and found them acceptabl The inspector reviewea the following procedures and found them not acceptable for the reasons c'.ite .
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ACP-QA-4.03 Revision 14- The licensee has not approved or implemented this revision. NE0 6.01 Revision 1 - The licensee has not approved or implemented this revision. NE0 6.02 - Revision 2 has been approved but the body of the procedure indicates the Revision 10 as correc The licensee must approve the correct revisio (Closed) Unresolved Item 85-41-01, " Inadequate Wire Terminations for Emergency Diesel Generator Control Panels" Emergency Diesel Generator (EDG) control panel wire terminations were inadequate. Industries Panels did not have an adequate QA/QC inspec-tion plan for wire terminations when the EDG panels were fabricate The licensee conducted a one hundred percent reinspection of the wire terminations for the ';11owing panels: 3EGS*PNL 1A, 18; EGD*PNL A, B; 3EGS*TBEG 1A, 18. The inspection and work was controlled by E&DCR T-E-06020 and associated N&Ds. The inspector observed this work activity several times and interviewed workmen reterminating wire as well as QC inspectors who were monitoring the work activity. The work is complete and this item is close (0 pen) Unresolved Item 423/85-50-01, "Namco Model 180 Limit Switch Missing Parts" Licensee needs inspection plan and attribute inspectio This item remains open pending NRC review of the re-inspection which has not been complete (Closed) Unresolved Item (50-423/85-51-03, "Use of Controlotron Flow Meter for Service Water System" Due to inconsistent flow measurements obtained by use of a control-otron flowmeter for the service water system, the licensee has decided to use installed plant instrtmentation and modified system lineups for surveillance purposes. The inspector reviewed surveillance pro-cedure SP 3626.4, " Service Water Pump 35WP*P1A Operation Readiness Test", and finds the method acceptabl This item is close . .( Closedl, Unresolved Item (85-53-01), " Deviations from Fire Protection Evaluation Report (FPER)"
The Branch Technical Position (RTP) 9.5-1 guidelines requires that fire detection systems are provided in areas that contain safety related systems. The inspector identified safety related areas where detection systems were not provide .
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The applicant submitted, to the NRC, documentation indir., ting which safety related areas do not have fire detection capability along with the technical justification for the deviation from the guideline In areas lacking detection and where technical justification was not provided, the applicant installed additional detection systems. BTP 9.5-1 also requires fire proofing the structural steel members forming a part of a fire barrier. The applicant prepared an analysis that identifies the steel members requiring fire proofing and implemented all wor ,
This item is resolve (Closed) Unresolved Item (50-423/85-53-02), " Fire Barrier Adequacy Concerns" The fire barrier concerns, raised by the NRC, were adequately address-ed by the applicant. The following is a point by point evaluation.of the applicant's actions in this are The concern about fire door modifications or unlabeled fire doors was l addressed in a deviation request from the guidelines of Branch Technical Position 9.5-1 - submitted to NRR for approval. The technical justi-fication provided for the deviation request was found acceptable by NRR. Another concern was the testing of spare conduit penetration l seals. The applicant has installed penetration seals in these con-duits that have a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rating.
r Finally, the concern of functionally testing the fire damper under plant operating conditions, was addressed by the applicant by per-forming these tests and modifying the dampers, where necessary, to assure their closur The applicant's actions in this area were reviewed by both NRR and Regional personnel. No unacceptable conditions were identifie This item is resolve (Closed) Unresolved Item (50-423/85-53-03), " Fire Protection for Areas That Do Not Meet the Guidelines of BTP 9.5-1" A deviation request from the guidelines cf Granch Technical Position (BTP) 9 5-1 Section C.S.c has been approved by NRR subject to the implementation of certain fire protection features. The deviation request concerned the Reactor Building and Auxiliary Building areas that did not meet the separation criteria identified in the above mentioned section of the BT NRR determined that the applicant's technical justification and alternative fire protection features are adequat .
This item is ciose .
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(Closed) Unresolved Item (85-53-04), " Testing cf Gaseous Suppression System" The NRC staff was concerned about the method of testing the gaseous suppression systems, and the adequacy of the tests. The primary concern was about the agent concentration and the duration of this concentration. The staff was also concerned about possible penetra-tion seal degradation as a result of the room overpressurizatio The licensee stated that the gaseous systems testing was completed successfully and that the test results had been submitted to the NRC for review. No unacceptable conditions were identifie This item is resolve (Closed) Unresolved item 432/85-53-07, " Operator Safety from Industrial Hazards" During a walkdown of the safe shutdown procedures it was cbserved that the emergency diesel generator shaft was exposed. This could present a hazard to the operator which may prevent him from performing the necessary operation functions required by the procedur The licensee has issued a PMMS Nuclear Work Order Nos. M3-85-35092 (DDR269) and M3-85-34208 to provide a guard screen. The 3EGS*EG-B diesel Work Order was signed after completion on November 1, 1985, and 3EGS*EG-A diesel Work Order was signed after completion on November 7, 1985. This work was observed to be complete on the "B"
diesel by a Region 1 inspector on November 6, 1985 and partially complete on the "A" diesel on the same day, i
The licensee has taken the necessary correction and this item is close (Closed) Unresolved Item (50-423/85-55-02), " Lack of Control on Control Room Alarm Book" The Control Room Annunciator Book has been updated and issued as a controlled document, OP 3264, as required by Regulatory Guide 1.33 and ANSI NI8.7-197 The inspector had no further questions on this ite .
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(Closed) Unresolved Item (50-423/85-55-07), "Three Loop Operation Versus OP3301D" Review of the " Final Draft" Technical specifications indicates that three loop operation will be authorize Revisions to OP 3301 0, Reactor Coolant Pump Operation, are not require The inspector had no further questions on this ite (Closed) Unresolved Item (85-68-01), " Fire Emergency Procedure" The inspec:or reviewed the current (draft) revision of Fire Emergency Procedure E0P-3509, Revision This revision of the procedure in-cludes the requirement for fire fighters to assemble at the fire equipment locker . . . c -a = + .o the scene of the fire and it also includes the fire strategies for a fire in any fire are No unacceptable conditions were identifie This item is resolve (CJ:9'd) Unresolved Item (85-68-02), " Fire Watch Mands-On Training" The inspector reviewed the training lesson plan provided to persons assigned fire watch duties and did not identify any unacceptable condition This item is resolve .0 Preoperational Test Program (Phase 2 and 3)
3.1 Test Procedure Review Scope The test proce es listed in Attachment A were reviewed for adminis-trative and, selectively, for technical adequacy and to verify that test planning sati:,fies regulatory guidance and licensee commitment Discussion The first approved PORC/JTG preoperational test procedures (Revision 0), in many instances, continue to be issued late for NRC revie Approved test procedures are to be submitted to the NRC 60 days prior to the start of the tes Although many o' those Rev. O procedures were reviewed by the NRC in draft form, their review has to be final-ized before the test is performed. The inspector concentrated on the review of the approved procedures (Rev. 0) which were issued since the last inspection (423/85-61).
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The procedures were examined for:
Management review and approval
Procedure format
- Clarity of stated objectives
- Pre-requisites
Environmental Conditions
- Acceptance criteria and their sources
Initial conditions
- Attainment of test objectives
- Test performance documentation and verification
- Degree of detail for test instructions
Restoration of system to normal after testing
Identification of test personnel
Evaluation of test data
Independent verification of critical steps or parameters
- Quality control and assurance involvement The Reactor Protection System Surveillance procedures (2), as listed in Attachment A, will be used in lieu of the preoperational test pro-cedures which have been deleted. This deviation from commitment 2 is discussed under Unresolved Item 50-423/85-61-05 in Section 2.1 of this repor Findings No noncompliances were identified by the inspector within the scope of this inspectio .2 Test Witnessing Scope Selected steps of the Preoperational Test Procedures, as discussed below, were witnessed by the inspecto _________
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Test witnessing by the inspector included observations of:
- Overall crew performance
Use of latest revised and approved procedure by test personnel
Designation of one person in charge of conducting the tests
Availability of sufficient test personnel to perform the tests
Coverage of test prerequisites
- Use of acceptance criteria to evaluate test results
Verification tnat plant supporting systems are in service
Inservice status of calibrated special test equipment required by the test procedure e
Adherence to the test requirements of the test procedure during the tests ( *
Timely and correct action by test personnel during the performance of the tests
Data collection for final analysis by test personnel The inspector independently verified readings of system parameters during the test Discussion
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Witnessed steps 7.1.31 through 7.1.34 of procedure SP 3446F31, Revision 0, approved October 15, 1985. The h-1 sequence could not be completed because the orange bus power was not availabl The test was completed successfully later. No noncompliances were observed during this tes Witnessed the special test 85-3-35 for the Emergency Diesel Gen-erator (EDG) "B". A visicorder was on hand to record the voltage and frequency transient following the receipt of the simulated ESF signal. The actual time observed, to recover specification conditions, was 8 seconds (10 seconds requirement). Item 2 of paragraph 2.6 could not be accomplished because the breaker would ,
not close. The test will have to be repeated to obtain the re-sults for paragraph 2.6, item .
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Witnessed the testing of EDG-A modified lube oil system. An additional strainer has been installed to make it possible to shift from one strainer to the other during EDG operation when the need arises (delta P of filter excessive). The test showed that the system works as intende Witnessed the parallel fusing test on EDG "A". The test was successfu Findings No noncompliances were observed for the tests within the scope of this inspectio .3 Test Results Evaluation hop _e The test procedures listed in Attachment C were reviewed to verify that adequate testing was accomplished in order to satisfy regulatory guidance and licensee commitments and to ascertain whether uniform criteria were being applied for evaluating completed preoperational tests in order to assure their technical and administrative adequac Discussion The test results were reviewed for:
Test changes
- Test exceptions
Test deficiencies
- Acceptance criteria a
Performance verification
Recording of conduct of test
- QC inspection records
- System restoration to normal
Independent verificaticn of critical steps or parameters
Identification of test personnel
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Verification that the test results have been approved The NRC effort on test result evaluation (TRE) takes 2 directions:
(1) Review of the part of the test results which had no test exception (s).
(2) Review of the test exceptions, deficiencies, and retest result The second part was reorganized by the licensee, at the inspector's request, to: Postpone test exceptions (UNSATS), which would not affect the Fuel Load operations, to later startup milestones (P-Post Core Hot Functional; I-Initial Criticality; A-Power Ascension; C-Commercial Operation). Identify priorities and schedule for the UNSATS which would have to be resolved prior to Fuel Loa The information on the second activity was collected in separate foloers to which the NRC inspectors have immediate access. This effort by the licensee became known as the " Orange Folder Program".
The acceptability of postponing the completion of certain phase 2 and 3 tests to later startup milestones was reviewed by the inspecto It was found that the licensee had been very conservative in their regrouping of test completion The licensee has made periodic reports on the status of procedure completions during this inspection. This information together with the availability of the orange folders made it possible for the NRC inspectors to follow each step made by the licensee toward completion of each tes In this inspection, the inspector concentrated on the completion of those tests which were identified to be tied to the Fuel Load mile-stone (F).
The test results for the CILRT were reviewed in the 3rd week of this inspectio The test results obtained in July 1985 for Integrated Leakage Rate Tests types A, B and C were reviewed against the Mill-stone 3 Technical Specification (3.6.1.2) to ascertain compliance with the regulatory requirenents of 10 CFR 50, Appendix J and to verify that the final test results satisfied the procedural accept-ance criteria. The test results were well within the criteria of acceptance (.675 weight %/ day) as shown below:
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Total Time Mass Point Analysis Analysis Item Weight %/ day Weight %/ Day Lam, Leakage Rate Calculated 0.0669 0.0747 UCL, L,, plus Upper Confidence Level 0.0692 0.106 A succecsful supplemental test was also performed which verified the above result No violations or deviations were observe Findings No items of noncompliance were identitied by the inspector within the scope of this inspectio The following systems could not be completed to date but are a part of the preoperational test progra (1) Containment Spray (2) Integrated Reactor Control System (3) Nuclear Instrumentation System The inspector will follow these items under Inspector Follow Item G0-423/85-69-0 .4 Emergency Diesel Generator (E0G) Status The lube oil systems of both units have now been modified to include another strainer. These systems have been flushed and have been tested successfully. Both strainers are presently mounted off the EDG ski The fuel oil filters no longer present a fire hazard. A box has been built around these filters to prevent fuel oil spray in the direction of the generator enclosur The box is drained and the drain piping is supported seismicall From the testing of these units (approximately 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on the A unit), '
it is evident that these units will be reliable unit The 35 consec-utive starts and stops for these units were performed without a proble .
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i 4. QA/QC Interface Scope FQC documentation, in the EDG Lube Oil System modifications to incorporate duplex filters, was reviewed for coverage of this activit Discussion FQC documentation, as identified in Attachment C of this report, was reviewed by the inspector for the scope of the inspections and the nature of their finding From these reports, lt would appear that good overage was provided for this important modificatio Findings No noncompliance was identified by the inspector within the scope of this revie . Exit Interview At the conclusion of the site inspection on November 27, 1985, an exit interview was conducted with the licensee's senior site representatives (denoted in Section 1). The findings were identified and previous inspection items were discussed.
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Attachment A to 50-423/85-69 I Test Procedure Review and Verification (1) T3303-P002, Revision 0, Approved 11/1/85, " Polar Crane Preoperational Test" (2) T3345-CP007, Revision 0, Approved 11/8/85, " Loss of DC Power" (3) 3-INT-2007, Revision 0, Approved 11/12/85, "ISI Valve Stroke Time Testing" (4) 3-INT-2008, Revision 0, Approved 11/8/85, " Ventilation Systems Filtration Units Efficiency and Performance Tests"
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(5) SP-3446B11, Revision 0, Approved 10/30/85, " Solid State Protection System Auto Logic / Master Relay Test" (6) SP-3446F31, Revision 0, Approved 10/30/85, " Refueling SSPS Tests" l
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Attachment B to 50-423/85-69 Test Results Evaluation (1) 3-INT-2001, Computer Programs Test Appendix J1, Revision 0, Approved 6/1/84, Pump on Motor Run Times Test Results Approved 9/17/85 (2) T331-BA, Revision 0, Approved 6/7/85, Auxiliary Boilers, Auxiliary Boiler Feedwater and Condensate Test Results Approved 10/29/85 (3) T3346-AP001, Revision 0, Approved 12/13/84, Emergency Diesel Generator
"A" - Mechanical Test Results Approved 11/1/85 (4) 3-INT-2001, Computer Programs Test Appendix 3R7, Revision 0, Approved 11/9/84, Xenon Prediction Test Case Test Results Approved 9/30/85 (5) 3-INT-2001, Computer Programs Test Appendix 3J9, Revision 0, Approved 8/31/84, Reactor Engineer NSSS Data Sheet Test Results Approved 9/30/85 (6) 3-INT-2001, Computer Programs Test Appendix 3D5, Revision 0, Approved 8/31/84, Point Substitutions Test Results Apprcved 9/30/85 (7) T3346-AP003, Revision 0, Approved 6/17/85, Emergency Diesel Generator A Licensing Test Test Results Approved 11/10/85 (8) T3321-AP, Revision 0, Approved 5/20/85, Feedwater and Recirculation Test Results Approved 11/10/85 (9) T3316-CP, Revision 0, Approved 8/19/85, Steam Generator Blowdown System Test Results Approved 11/10/85 (10) T3330-EP, Revision 0, Approved 1/10/85, Safety Injection Pumps Cooling Systems Test Results Approved 11/10/85 l
(11) T3316-AP001, Revision 0, Approved 6/25/85, Main Steam Test Results Approved 11/10/85 (12) T3349-P002, Revision 0, Approved 9/20/85, Safety Parameter Display System Timing Test Results Approved 11/10/85
Attachment B 2 (13) T3319-BP, Revision 0, Approved 8/9/85, Condensate Makeup and Draw-off System Test Results Approved 11/10/86 (14) T3316-BP, Revision 0, Approved 4/3/85, Steam Dump Controls Test Results Approved 11/10/85 (15) T3315-BA, Revision 0, Approved 7/30/84, Main Steam Valve Building Ventilation Test Results Approved 11/10/84 (16) T3304-AP001, Revision 0, Approved 4/6/85, Charging, Letdown and Purification Systems Test Results Approved 11/10/85 (17) T3332-AP002, Revision 0, Approved 12/20/84, Cold Shutdown Integrated Air System Test Results Approved 11/10/85 (18) T3340-CA, Revision 0, Approved 7/9/84, Primary Grade Water Test Results Approved 11/9/85 (19) T3326-P, Revision 0, Approved 5/6/85, Service Water
, Test Results Approved 11/8/85 (20) T3307-BP002, Revision 0, Approved 6/17/85, Residual Heat Removal System Test Results Approved 11/10/85 (21) T3327-A, Revision 0, Approved 3/18/85, Screen Wash System Test Results Approved 11/9/85 (22) 3-INT-2001, Precore Hot Functional Testing Appendix 3011, Revision 0,
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Approved 10/2/85, Pressurizer Testing Test Results Approved 11/10/85 (24) 3-INT-3000, Precore Hot Functional Testing Appendix 3036, Revision 0, Approved 10/8/85, Feedwater Hammer Test Results Approved 11/9/85 (25) 3-INT-3000, Precore Hot Functional Testing Appendix 3013, Revision 0, Approved 8/12/85, Steam Generator Checmical Feed Test Results Approved 11/8/85 (26) 3-INT-3000, Precore Hot Functional Testing Appendix 3008, Revision 0, Approved 8/15/85, RTO Cross-Calibration Test Results Approved 11/9/85
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Attachment B 3 (27) 3-INT-3000, Precore Hot Functional Testing Appendix 3031, Revision 0, Approved 9/26/85, Voice Page/ Evacuation Alarm Test Test Results Approved 11/9/85 (28) 3-INT-3000, Precore Hot Functional Testing Appendix 3017, Revision 0, Approved 10/30/85, Individual Loop Isolation (N-1)
Test Results Approved 11/9/85 (29) 3-INT-3000, Precore Hot Functional Testing Appendix 3006, Revision 0, Approved 10/10/85, Steam Generator Blowdown Test and Flow Calibration Test Results Approved 11/9/85 (30) 3-INT-3000, Precore Hot Functional Testing Appendix 3002, Revision 0, Approved 9/25/85, Reactor Cooalant Pump Data Test Results Approved 11/9/85 (31) 3-INT-3000, Precore Hot Functional Testing Appendix 3035, Revision 0, Approved 10/10/85, Loss of Instrument Air Test Results Approved 11/9/85 (32) 3-INT-3000, Precore Hot Functional Testing Appendix 3004, Revision 0, Approved 8/13/85, Solid Plant Pressure Control Test Results Approved 11/9/85 (33) 3-INT-3000, Precore Hot Functional Testing Appendix 3015, Revision 0, Approved 9/28/85, Service Water System Test Results Approved 11/9/85 (34) 3-INT-3000, Precore Hot Funct'ional Testing Appendix 3023, Revision 0, Approved 10/1/85, Turbine Generator Test Results Approved 11/9/85 (35) 3-INT-3000, Precore Hot Functional Testing Appendix 3010, Revision 0, Approved 8/23/85, Main Feed Water System Test Results Approved 11/8/85 (36) 3-INT-3000, Precore Hot Functional Testing Appendix 3033, Revision 0, Approved 10/21/85, Post Accident Sampling System Test Results Approved 11/10/85 (37) 3-INT-3000, Precore Hot Functional Testing Appendix 2024, Revision 0, Approved 9/17/85, Electrical Distribution Test Results Approved 11/10/85 (38) 3-INT-3000, Precore Hot Functional Testing Appendix 3025, Revision 0, Approved 8/21/85, Steam Oump and Controls
. Test Results Approved 11/10/85
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Attachment B 4 (39) 3-INT-3000, Precore Hot Functional Testing Appendix 3027, Revision 0, Approved 9/21/85, HFT Primary Relief Valve Testing Test Results Approved 11/11/85 (40) 3-INT-3000, Precore Hot Functional Testing Appendix 3014, Revision 0, Approved 7/8/85, Remote Shutdown with Cooldown Test Results Approved 11/11/85 (41) T3346-AP002, Revision 0, Approved 12/13/84, Emergency Diesel Generator B
- Mechanical Test Results Approved 11/11/85 (42) 3-INT-3000, Precore Hot Functional Testing Appendix 3028, Revision 0, Approved 10/7/85, Safety Injection System Test Results Approved 11/11/85 (43) T3340-BA001, Revision 0, Approved 6/22/84, Water Treatment System Test Results Approved 11/11/85 (44) T3330-BA, Revision 0, Approved 6/13/85, Turbine Plant Component Cooling Water Test Results Approved 11/11/85 (45) T3303-P001, Revision 0, Approved 4/10/85, Fuel Transfer System Test Results Approved 11/11/85 (46) 3-INT-3000, Precore Hot Functional Testing Appendix 3019, Revision 0, Approved 9/30/85, Auxiliary Feedwater Test Results Approved 11/11/85 (47) T3304-CP, Revision 0, Approved 7/23/85, Boric Acid System i Test Results Approved 11/11/85 (48) T3415-P005, Revision 0, Approved 1/20/84, Isolator Cabinet Group CESBS Test Results Approved 11/11/85 (49) T3345-CP001, Revision 0, Approved 7/5/83, 125 VDC Channel 1 Test Results Approved 11/7/85 (50) 3-INT-3000, Precore Hot Functional Testing Appendix 3009, Revision 0, Approved 10/3/85, Component Cooling Water Test Results Approved 11/12/85 (51) T3345-CP002, Revision 0, Approved 7/5/83, 125 VDC Channel 2 Test Results Approved 11/7/85 (52) T3345-CP003, Revision 0, Approved 7/5/83, 125 VDC Channel 3 Test Results Approved 11/7/85
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Attachment B 5 (53) T3345-CP004, Revision 0, Approved 7/5/83, 125 VOC Channel 4 Test Results Approved 11/7/85 (54) T3345-CP005, Revision 0, 125 VDC Channel 5 Test Results Approved 11/12/85 (55) T3345-DA, Revision 0, Approved 4/25/83, 125 VOC Channel 6 Test Results Approved 11/7/85 (56) 3-INT-3000, Precore Hot Functional lesting Appendix 3012, Revision 0, Approved 9/24/85, Rod Control System Test Results Approved 11/12/85 (57) T3303-P002, Revision 0, Approved 11/1/85, Polar Crane Test Results Approved 11/12/85 (58) 3-INT-3000, Precore Hot Functional Testing Appendix 3020, Revision 0, Approved 10/1/85, Circulating Water System Test Results Approved 11/12/85 (59) T3325-AA, Revision 0, Approved 5/16/85, Circulating Water System Test Results Approved 11/12/85 (60) T3311-AP, Revision 0, Approved 8/7/85, Reactor Plant Sampling Test Results Approved 11/12/85 (61) T3301-P002, Revision 0, Approved 6/6/85, Reactor Coolant System Test Results Approved 11/12/85 ,
(62) 3-INT-3000, Precore Hot Functional Testing Appendix 3029, Revision 0, Approved 4/10/85, Chemistry Guidelines Test Results Approved 11/12/85 (63) 3-INT-2004, Revision 1, Approved, 8/24/85, ESF with Loss of Offsite Power Test Results Approved 11/12/85
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(64) 3-INT-3000, Precore Hot Functional Testing Appendix 3021, Revision 0, Approved 7/18/85, Pipe and Pipe Support Transient Vibration Testing Test Results Approved 11/13/85 (65) 3-INT-3000, Precore Hot Functional Testing Appendix 3001, Revision 0, Approved 9/10/85, Reactor Plant and Turbine Plant Sampling Test Results Approved 11/13/85 (66) 3-INT-2001, Computer Programs Test Appendix 3R9, Revision 0, Approved 11/9/85, Xenon Follow Test Case Test Results Approved 11/11/85
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l Attachment B 6 (67) 3-INT-2001, Computer Programs Test Appendix 3S2, Revision 1, Approved 8/31/84, Flow Corrections Test Results Approved 11/11/85 (68) 3-INT-2001, Computer Programs Test Appendix 3RI, Revision 0, Approved l 9/27/84, Rod Supervision Test Case Test Results Approved 11/11/85 (69) 3-INT-2001, Computer Programs Test Appendix 3R2, Revision 0, Approved 9/18/84, Reasonability Check and Time Average of Incore Thermocouples Test Case Test Results Approved 11/11/85 (70) 3-INT-2001, Computer Programs Test Appendix 3J4, Revision 0, Approved 8/31/84, Boration and Dilution
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Test Results Approved 11/11/85 (71) T3314-AP, Reviion 0, Approved 3/27/85, Auxiliary Building HVAC System Test Results Approved 11/15/85 (72) T3346-AP004, Revision 0, Approved 6/17/85, Emergency Diesel Generator B Licensing Test Test Results Approved 11/15/85 (73) T3415-P004, Revision 0, Approved 1/20/84, Isolator Cabinet Group CESBR Test Results Approved 11/15/85 (74) 3-INT-2001, Computer Programs Test Appendix 3R6, Revision 0, Approved 2/22/85, Computations Based on In-Core Thermocouples Test Case Test Results Approved 11/15/85
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(75) 3-INT-2001, Computer Programs Test Appendix 3J12, Revision 0, Approved 6/29/84, Reactor Plant Aerated Drains Water Inventory Test Results Approved 11/15/85 (76) 3-INT-3000, Precore Hot Functional Test Appendix 3030, Revision 0, Approved 10/2/85, RCS Leak Detection Test Results Approved 11/15/85 (77) 3-INT-3000, Precore Hot Functional Test Appendix 3005, Revision 0, Approved 2/11/85, Ventilation System Tests Test Results Approved 11/15/85 (78) 3-1NT-3000, Precore Hot Functional Test Appendix 3037, Revision 0, Approved 9/10/85, RCS Heat Loss Test Results Approved 11/15/85 (79) T3349-P001, Revision 0, Approved 6/11/85, Plant Computer Test Results Approved 11/16/85
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! Attachment B 7 (80) T3301-P001, Revision 0, Approved 3/18/85, Reactor Coolant and Associated
- System Fill and Hydrostatic Test l
Test Results Approved 10/11/85 (81) 3-INT-2002, Revision 0, App-oved 4/24/85, Integrated Leak Rate and l Structural Integrity Test Test Results Approved 9/17/85 (82) 3-INT-3000, Precore Hot Functional Test Controlling Procedure, Revision 0, Approved 9/3/85 Test Results Approved 11/18/85 (83) T3341-BP, Revision C, Approved 12/12/83, Halon-1301 Fire Protection System Test Results Approved 11/18/85 (84) T3341-AP, Revision 0, Approved 7/22/85, Fire Protection - Water Test Results Approved 11/18/85 i (85) 3-INT-3000, Precore Hot Functional Testing, Appendix 3007, Revision 0, Approved 6/25/85 Test Results Approved 11/18/85 (86) 3-INT-3000, Precore Hot Functional Testing, Appendix 3016, Revision 0, Approved 9/21/85 Test Results Approved 11/18/85 (87) 3-INT-2003, Revision 1, Approved Approved 8/16/85, ESF Without Loss of Normal Power Test Results Approved 10/7/85 (88) T3304-AP003, Revision 0, Approved 3/11/85, Boronometer Test Results Approved 11/23/85 (89) 3-INT-3000, Precore Hot Functional Testing, Appendix 3022, Revision 0, Approved 9/20/85, Snubber Expansion Examinations Test Results Approved 11/25/85 (90) T3345-CP007, Revision 0, Approved 11/8/85, Loss of DC Test Results Approved 11/25/85 (91) T3345-CP006, Revision 0, Approved 8/28/84, 125 VDC Duty Cycle Testing Test Results Approved 11/25/85 (92) T3720-BP, Revision 0, Approved 9/21/85, Station Emergency Lighting Test Results Approved 11/25/85 (93) T3404-P, Revision 0, Aoproved 8/7/85, Digital Radiation Monitor System Test Results Approved 11/25/85
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Attachment B 8 (94) 3-INT-3000, Precore Hot Functional Testing, Appendix 3003, Revision 0, Approved 8/20/85, RHR System Operation Test Results Approved 11/19/85 (95) T3341-DP, Revision 0, Approved 3/18/85, ESF Building HVAC Test Results Approved 11/9/85 (96) T3341-FP, Revision 0, Approved 4/10/85, Control Building HVAC Test Results Approved 11/21/85
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Attachment C to 50-423/85-69 QC Occumentation Pertaining to EDG Lube Oil System Modifications to Incorporate Duplex Filters E&DCR No. T-P-07233 CRN Number Line Designation F0C Signature Date
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CP-360533-004 3-EGO-004-8-3 10-12-85-005 3-EGO-004-8-3 10-13-85
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-006 3-EGO-750-14-3(B-) 10-19-85 i -16-3-012 N/A 11-4-85
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-007 3-EGO-004-11-3 10-19-85 l -008 3-EGO-750-14-3 10-22-85 I-009 3-EGO-150-18-3 10-25-85-010 3-EGO-004-8-3 10-25-85-011 3-EGO-004-11-3(B-) 10-26-85-013 3-EGO-004-9-3 11-5-85
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-8-3 CP-360532-010 3-EGO-004-1-3 10-13-85 l -004-4-3 i -011 3-EGO-004-1-3 10-14-85-014 3-EGO-750-7-3(A-) 10-18-85-15-3(A-)
-015 -15-3(A-) 10-20-85-016 -7-3 10-22-85-017 3-EGO-004-1-3 10-26-85-018 N/A 11-02-85-020 N/A 11-04-85-019 3-EGO-004-1-3 11-02-85-021 -4-3 11-04-85-022 -1-3 11-05-85-023 -1-3(A-) 11-05-85 l -026 -1-3 11-12-85
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-4-3 11-12-85 l
Weld Tech. Sheets /FW Line Designation FQC Signature Date W3-02-01/25 3-EGO-004-4-3 10-19-85
/26-1 -4-3 11-08-85
/27-1 -4-3 11-08-85
/28 -4-3 11-08-85
/29 -4-3 11-08-85
/30 -4-3 10-19-85
/31 -4-3 11-12-85
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