ML20129D544

Insp Rept 50-423/85-23 on 850520-0614.Violation Noted: Failure to Implement Test Procedure Identified After Flooding in Parts of Svc & Control Bldgs

ML20129D544
Person / Time
Site:	Millstone
Issue date:	06/28/1985
From:	Mccabe E, Roxanne Summers NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129D501	List: IR 05000423/1985023 ML20129D495 ML20129D526
References
50-423-85-23, NUDOCS 8507160565
Download: ML20129D544 (6)

See also: IR 05000520/2006014

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.: 50-423/85-23

Docket No.: 50-423

License No.: CPPR-113 Category: C

Licensee: Northeast Nuclear Energy Company

Facility: Millstone Nuclear Power Station, Waterford, Connecticut

Inspection At: Millstone Unit 3

Inspection. Conducted: May 20 - June 14, 1985

Inspector: k. bo

R. J.( Summers, Project Engineer

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Date

Approved by: & bOr I a G l2.s lt.r

E. C. McCabe, Chief, Reactor Projects Section 3B Date

Inspection Summary: Inspection 50-423/85-23 (May 20 - June 14, 1985)

Routine unannounced safety inspection (95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br />) of previously identified items,

facility events, Type C leak rate testing, and the vital batteries.

A violation for failing to implement a test procedure was identified after the

occurrence caused flooding in the parts of the Service and Control Buildings (De-

tail 2). An unresolved item pertaining to the proper construction of the seismic

support structure for the vital batteries was also identified (Detail 4). Other-

wise, no unacceptable conditions were found.

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DETAILS

1. Licensee Action on Previous Inspection Findings

The inspector reviewed the licensee's responses and corrective actions, where

required, for the items listed below. During this review it became evident

that, although the licensee has a program for tracking the closeout of these

inspection findings, no centralized system for control of the closecut support

documentation exists. The licensee also identified this matter end corrective

actions are pending.

(Closed) Unresolved Item (83-17-02): Cables splices made not described in

FSAR. This item was closed together with Item 83-18-02 during NRC Inspection

50-423/85-08; however, no update was done at that time. Based on the splice

location and the licensee's ability to inspect and test the splice if neces-

sary, this item was found acceptable as documented in Branch Technical Post-

tion 8.0. This item is closed.

(Closed) Unresolved Item (84-01-02): Traceability of 1/4 inch, SB-402 plate

and weld filler metal for the Bahnson HVAC, safety-related air handling units.

Stone and Webster QA conducted a review of Bahnson documentation. It was de-

termined that the CMTRs for the plate and weld filler metal, listed as "not

required" on 8 of the 10 HVAC units, was in fact available and included in

the documentation packages for the other 2 HVAC units. This was due to these

materials being identical for the HVAC' units and therefore 2 of the packages

served as " master documentation packages" for all 10 units. The documentation

packages are being reorganized to preclude future misinterpretations. This

item is closed.

(Closed) Unresolved Item (84-03-01): Acceptance criteria for duct metal warp-

age. New criteria were established in E&DCR F-B-33823. These criteria were

based on actual " pull test" data on various manufactured duct sections and

joints. The inspector reviewed the referenced E&DCR and cupporting documen-

tation. The new criteria is equivalent to the old in that structural integ-

rity is assured as long as ductwork corners did not exhibit localized damage

such as discontinuities (local denting or buckling). The inspector had no

further questions.

(Closed) Unresolved Item (84-03-02): Stress calculations for rivets connecting

sheet metal to supports where the specified 1/32 inch gap criterion was not

met. Subsequent to the request for this calculation (to grant relief from

the gap criterion), it was determined that no relief was granted. The accept-

ance criteria remained as originally specified. E&CDR P-J-6434 was developed

to specify the minimum number of acceptable rivets required for various duct

sizes based on seismic calculations. FQC inspections were conducted to verify

that the minimum number of acceptable rivets were in place. This item is

closed.

(Closed) Inspector Follow Item (84-03-03): Potential ducting backfit list due

to the changes in acceptance criteria (84-03-01 and 84-03-02). The licensee

stated that the acceptance criteria for the localized denting of duct metal

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did not change and therefore no backfit was required for this item. The ac-

ceptance criteria for the rivet gap also did not change, rather, the minimum

number of acceptable rivets for specific ducting was developed. FQC inspec-

tions of ducting were made and nonconforming conditions were handled through

the normal (N&D) procedure. This item is closed.

(Closed) Inspector Follow Item (84-06-03): Vendor report on Pacific Scientific i

mechanical snubbers subject to micro-cracks of the capstan spring identified

in Significant Deficiency (SD) 46. The inspector reviewed the data supplied

by the vendor. All snubbers tested satisfactorily; however, since the vendor

has no acceptance criteria pertaining to the spring micro-cracks, 86 of 181

snubbers were " repaired" with new springs. All the units were recertified

as operable. This item is closed.

(Closed) Unresolved Item (84-23-03): Justification and basis for use of

standard hex nut with no locking device to fasten raceway splice plates.

Three types of cable tray splice plate hardware were used at the site. Splice

plates designed by the cable tray vendor utilized supplied hardware which had

locking devices. The third design, from SWEC, used standard hex nut hardware

with no locking devices. Section 3.1.2.4 of Procedure No. E-350 requires that

the joints between tray sections be made up tight and rigid using the full

compliment of bolts, washers, and locking devices as required by the manufac-

turer's design or as specifically instructed by the engineers. The use of

the hex nut was specifically instructed by the engineers on Drawing No.

12179-EE-34JC-5, Cable Tray Support Miscellaneous Details. This item is

closed.

(Closed) Unresolved Item (04-03-08): Review of program to control concrete

core boring. The licensee has implemented adequate controls for identifica-

tion and issuance of core boring equipment. These controls will identify '

future missing equipment if not returned to the warehouse within 7 days of

issuance. In addition, drill bits have been identified with positive mark

numbers and site searches were conducted to find any uncontrolled bits. To

preclude failure of FQC to witness core cuts to verify proper authorized cut-

tings of reinforcing bars, a change was made to Procedure FCP-268, Control

Procedure for Diamond Tipped Bits and Core Cutters, which requires FQC veri-

fication on all core bores. A review of core cut cards was conducted and core

cuts that had no FQC verification were identified. Where possible, inspec-

tions were made to verify that reinforcing bar was not cut, where not author-

ized by engineering. For the three cases where neither inspection nor suffi-

cient documentation existed, the nonconformance was resolved by assuming that

all of the possible reinforcing bar was cut and calculations were made that

justified that the existing reinforcing steel was sufficient. This item is

closed.

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(Closed) Violation (84-04-04): Failure to identify a design change. The lic-

ensee supplemented their original response to this violation to include ad-

ditional reviews of work performed by other designers, and to specifically

identify design changes where the engineer failed to backcircle the change

on the affected drawing. A total of 6 discrepancies were found in a review

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.of 200 design changes. However, all of the 6 changes were properly documented

on the Record of Drawing Change and could be traced to other documentation

such as E&DCRs, so that configuration control was maintained. A number of

programs at the site had been previously initiated to strengthen the configu-

ration control at the facility. These programs would prevent FQC inspection

of "as-built" conditions to a not-current revision to a drawing. In addition,

the preliminary and final walkdowns document these types of discrepancies,.

which are then entered into the work tracking system and tracked through

satisfactory completion. -No needed additional corrective actions were iden-

tified. This item is closed.

.(0 pen) Unresolved Item (84-23-04): Effect of corrosive battery room atmosphere

on exposed inter-cell cable assembly. The inter-cell connections are to be.

re-terminated after covering with Type WCSF-1000N Raychem heat shrink tubing.

This work will be accomplished and witnessed and documented by FQC in accor-

. dance with E&DCR T-E-05027. This item remains open until work is complete.

2. Event Followup

On May 30, 1985, a flooding event occurred when the Service Building Fire

Protection Water header was pressurized with fire water in support of testing.

Preparations had been completed to support a flush of the system per Test

Procedure No. T3341A1F02, Flushing Phase I Test of Fire Protection Water, with

Test Change No.-2, dated July 27, 1984. Prior to this event, Work Order (WO)

No. M3-85-02435 was issued and completed to place the system in the required

test configuration. The test engineer failed to include in the WO the placing

of a red (danger) tag on Valve 3FPW-V555. The danger tag was required by Test

Procedure T3341A1F02. Failure to implement the procedure resulted in the

flooding event and is a. violation of 10 CFR 50, Appendix B, Criterion V and

the Northeast Nuclear Energy Company Startup Test Manual (423/85-23-01).

The flooding event itself caused no apparent equipment damage. However, since

some water did drain underneath a closed door into the Control Room, safety-

related equipment could be endangered by such an event. Had not operator re-

covery actions been prompt, this event would have been more significant.

This event could have been avoided had the operating staff exercised suffi-

cient control prior to filling the fire water header. The completed WO, es-

tablishing the system configuration, was available for the Control Room Shift

Supervisor. This WO clearly stated: " break the flange downstream of Valve

3FPW-V555." That opened the system in the Service Building. No one verified

that the system was ready to be filled or noticed that the open flange coupled

with the_open valve (3FPW-V555) breached the system integrity. There is a

general step in the test procedure for " Release for Performance" which re-

quires the Shift Supervisor to verify that all of the plant systems are ready

for the test to begin. This was done; however, a significant delay (9 months)

between this approval and actual test performance occurred. Nonetheless, there

was no requirement to re-verify the test conditions.

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3. Containment Local Leakage Rate Testing

l On May 21, 1985, the inspector witnessed the Type C leakage testing of con-

. tainment atmospheric monitoring system isolation valve 3 CMS *CTV21. The test

! was conducted in accordance with approved Preoperational Test Procedure

! T3312A1M03, Local Leak Rate Test - Type C, Revision 0, and the test equipment

was properly calibrated. The inspector verified the test valve line-up and

l reviewed the documentation of the test results. During the test, leakage was

observed through the packing of the test connection valve. The corrected flow

rate test result was unsatisfactory and a retest was to be scheduled following

repair to the test connection valve. The test personnel were knowledgeable

of the test procedure and proper use of the test equipment. No unacceptable

' conditions were identified.

4. Review of GNB Batteries

The inspector reviewed the construction documentation, including as-built

drawings, of the safety-related GNB batteries. The design requirements did

not specify any maximum spacing between the cells and the rack stringers.

Based on correspondence from the vendor to the NRC, the licensee was to be

informed that a maximum 1/4 inch gap was recommended because the seismic

qualification program was conducted with a gap of 1/8 inch to 1/4 inch. This

information was received by NUSCo but was not forwarded to the site foi review

or implementation. The inspector observed the condition of the batteries and

noted the following:

a. Batteries 3018-1, 3018-2, and 301A-1 appeared to have excessive gap

(greater than 1/4 inch) between the end cell and the rack side stringer;

b. Battery 3018-2 was missing a battery rack side support rail adjacent to

cell location 16; and,

c. Battery 3018-2 utilized a different type of cell spacer material than

the other safety-related batteries.

On June 6, 1985, the licensee issued Deficiency Report Nos. UNS 4326 and 4325,

identifying the conditions noted in (a) and (b) above, respectively. The

licensee also stated that the responsible engineer would determine if the

proper type (s) of cell spacer material was used as identified in (c) above.

The proper construction of the GNB batteries is unresolved pending licensee

action on the above 3 items, including identifying how item (b) occurred and

why the vendor design information specifying the maximum cell / stringer gap

was not forwarded to Millstone 3 for action (423/85-23-02).

5. New Fuel Receipt, Inspection, and Storage

New fuel receipt, inspection, and storage activities were observed for fuel

received on June 5 and 14, 1985. Activities observed during the inspection l

included radiological surveys of the shipping casks, opening of the casks and -

initial surveys of fuel assemblies, transfer of fuel assemblies to the in-

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spection station, inspection and cleaning of the assemblies and their inserts,

and transfer to the spent fuel pool storage location. Documentation support-

ing these activities were reviewed. Physical protection and radiological

controls were in accordance with requirements. The SRO in charge of the new

fuel receipt was knowledgeable of the activities and the controlling proce- r

dures and NRC license requirements. No deficiencies were observed.

6. Plant Tours

Periodic tours of the site were made during the inspection. Particular at- [

tention was given to housekeeping and cleanliness in the containment struc- l

ture, auxiliary builuing, emergency safety features building, emergency diesel-

generator rooms, control room, and the fuel handling building. Flushing of

the emergency diesel generator fuel oil system was periodically observed due

to the potential fire hazard involved. Except for conditions observed in the

vital' battery rooms (Detail 4), no deficiencies were observed.

7. Unresolved Items

Unresolved items are matters about which more information is required in order

to ascertain whether they are acceptable or not. An unresolved item identi-

fled during this inspection is discussed in Detail 4.

8. Exit Meeting

~At periodic intervals during the course of this inspection and on June 14,

1985, meetings were held with senior plant management to discuss the scope

and findings of this inspection. At the exit on June 14, 1985, the licensee

acknowledged the apparent need for a centralized control system for documen- .

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tation that addresses actions taken on previous inspection findings as dis-

cussed in Detail 1. This matter is being reviewed by licensee management.

No proprietary information was identified as being in the inspection coverage.

At no time during the inspection was written material provi.ded to the licensee

by the inspector.

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