IR 05000400/1986030
| ML18019A998 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/22/1986 |
| From: | Conlon T, Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18019A997 | List: |
| References | |
| 50-400-86-30, NUDOCS 8606100579 | |
| Download: ML18019A998 (16) | |
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NUCLEAR REGULATORY COMMISSION o
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REGIONII o "',, U 101'MARIETTASTREET N W i.. )
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50-400/86-30
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I Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh,,NC 27602 Docket NoeI 50-400 Facility Name:
Harris Inspection Conducted:
April 14 - 18, 1986 Inspector:
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errsweat er Approved b~
T. E. Conlon, Section Chief Engineering Branch Division of Reactor Safety License No.:
CPPR-158 ate sgne Date Signed SUMMARY Scope:
This routine, unannounced inspection involved areas of safety-related instrument component installations and quality records.
Results:
No violations or deviations were identified.
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REPORT DETAILS Persons Contacted Licensee Employees
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A. Watson, Vice President, Harris L. Willis, Plant General Manager L. Harness, Assistant Plant General Plant Manager J. Chiangi, Manager, Quality Assurance/Quality Control (QA/QC)
L. Forehand, Director QA/QC C. Whitehead, QA Supervisor E. Rose, Operations QA Supervisor E. Strehle, Operations Project QA Engineer Tibbitts, Acting Director Regulatory Compliance A. Meyer, Project General Manager-Completion J.
Wagner, Engineering General Manager L. Evans, Engineer L. King, Instrumentation Engineer L. Betz, QC Supervisor I. Edwards, Project Engineer Instrumentation and Control E.
Willett, Resident Engineer Mechanical/Instrumentation F. Garner, CI Supervisor V. Hate', Principal QA Engineer L. Williams, Civil Project Engineer G. Wallace, Specialist-Regulatory Compliance R. Oates, Principal Engineer A. Stewart, Engineer H.,Smith, Operations Support Supervisor A. McGaw, Superintendent QA Brady, Civil Engineer Other licensee employees contacted included construction craftsmen, engi-neers, technicians, security office members and office personnel.
Other Organizations
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- G P. Kirk, Project Administrator, Daniels Construction Company (DCC)
L. Bryant, Instrumentation Supervisor, DCC Kramer, QA/QC Supervisor, DCC Walker, QA Surveillance, DCC Pehush, Engineer, Ebasco Fregonese, Engineer, Ebasco Damitz, Engineer, Ebasco Attarian, Electrical Engineer, Ebasco
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NRC Resident Inspectors
- G. Maxwell, Senior Resident Inspector
- G. Humphrey, Resident Inspector
- Attended exit interview Exit Interview The inspection scope and findings were summarized on April 18, 1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee.
Unresolved Item 50-400/86-30-01, Verify That Section 7.3.2. 1 of the FSAR is Revised As Described in Westinghouse Letter No. C(L-9308, paragraph 5.
Inspector Followup Item 50-400/86-30-02, Review of Licensee's Inter-disciplinary Clearances Verification Walkdown Program, paragraph 5.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions.
One unresolved item identified during this inspection is discussed in paragraph 5.
Instrument Components and Systems and guality Records Review (52053 and 52055)
The status of construction activities in the instrumentation and control areas was given as 90 percent complete.
The licensee indicated that only four safety-related level switches and approximately 30 local indicators remain to be worked.
At the time of the inspection, no in-process construc-tion of safety-related instruments were being performed, therefore, the in-process activities were not inspected.
The objectives of this inspection were to determine if activities relative to safety-related instrument components and systems are being accomplished in accordance with NRC requirements, SAR commitments, and licensee proce-dures and to determine whether inadequacies in completed work, partially completed work, or work activities in progress associated with instrument components indicate a management control problem or generic weaknesse '
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The inspector selected instruments from the reactor protection system, engineered safety features actuation system and instrument air system for examination to determine, by direct observation and independent evaluation, that the completed instrumentation installations'ere performed in accor-dance with NRC requirements, SAR commitments, and procedures.
The instru-ments selected are identified as follows:
Instrument Nos.
Function PT-1RC-0455-IW LT-1RC-0459-IW PT-1RC-0456-IIW LT-1RC-0460-IIW PS-01IA-9791-SB PS-01IA-9790-SA P T-01CT-0951-IIW PDT-1CB-768081-SB Pressurizer Pressure Transmitter Pressurizer Level Transmitter Pressurizer Pressure Transmitter Pressurizer Level Transmitter Instrument Air Pressure Switch Instrument Air Pressure Switch Containment Pressure Transmitter Containment Differential Pressure Transmitter A walkdown inspection of the above instrument installations was conducted to determine whether:
Location, configuration and installation (including mounting and anchoring)
are according to the latest approved design or construction specifications and drawings.
Specified instrument components and associated items have been used.
Components have been correctly and permanently identified.
Cleanliness requirements have been maintained or otherwise satisfied.
Installed equipment is adequately protected from adjacent construction activities and protective coatings, plugs, bushings, and other materi-als have been used as specified.
Instrument components and associated items, such as sensing lines and power supplies, maintain physical and electrical independence between redundant parts.
Safety-related protection systems and normal plant control system are adequately separated and isolated from each other.
Nonconforming components or conditions have been identified and con-trolled in accordance with approved procedures.
Status of completion, maintenance, and readiness for preoperational testing is indicated or otherwise documente C I
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Physical inspection of the instrument installations revealed the following concerns:
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Separation Between Redundant Instrument Tubing The separation between the tubing for instruments LT-1RC-0459-I-W, PT-1RC-0455-I-W, LT-1RC-0460-II-W, PT-1RC-0456-II-W, LT-1RC-0461-II-W, and PT-1RC-457-III-W do not meet the minimum two feet separation criteria specified by Ebasco between redundant instrument impulse lines.
This installation was approved by Field Change Requests (FCRs)
I-2526, Revision 1.
The FCR indicated that the effects of jet impinge-ment and pipe whip have been'considered and that the sensing lines fall within the same jet cone as shown on revision 0 to the FCR.
The FCR also indicated that there were areas where the separation had been reduced to ten inches.
These areas were identified as between tube tracks Cl-R9-4-T32 and Cl-R8-3-T28 and between tube tracks Cl-R9-3-T32 and C1-R8-3-T28 inside containment.
The above separation problems were also observed by the inspector during walkdown of the above pressurizer pressure and level instrumentation.
The inspector discussed the above separation issue with both licensee and Ebasco engineers.
They indi-cated that jet impingement and pipe whip are not a problem in this area, therefore, there is no single failure that would cause an inter-action between redundant channels of instrument tubing.
They also indicated that the minimum separation allowed by Westinghouse (in WCAP 8584/8670) for redundant instrument tubing was 18 inches.
The licensee representative indicated that Ebasco's design criteria used Westing-house interface criteria as a basis for developing two feet minimum separation.
However, there are places in the plant where Ebasco's 24 inch minimum separation could not be maintained.
In those cases, a
FCR was issued to approve the installation.
In approving FCR-I-2526, they analyzed the installation for jet impingement and pipe whip hazards and for completion of safety function.
The study done for the pressurizer instruments is documented on Ebasco's Calculation No. PRA-J-ISC-8, Revision 2, dated December 12, 1985.
The study indicates'hat there is no interaction between the instrument tubing and jets, however, an interaction between jet envelope'J-RC-35-1A and level transmitters (LT-1RC-459, 460, 461, and 462)
does occur but it was determined to be an acceptable interaction due to the fact that the target is not part of the essential system for the postulated pipe break. Therefore, by analysis they concluded that this installation was acceptable.
During a previous NRC inspection (50-400/85-26),
instances were found where the 24 inch separation criteria was not maintained between redundant core cool ant flow transmi tters FT-OIRC-414-1 W,
FT-01RC-415-II-W, and FT-01RC-416-III-W.
In this case, as in the one described above, the installation had been approved by a FCR.
Subsequent discus-sions with the AE/licensee revealed that the sensing lines for these
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instruments are not located in a jet impingement area due to "leak before break criteria," however, the cables supplying the electrical power to instrument racks Cl-R4 and Cl-R5 are subject to a jet impingment caused by steam generator blowdown.
The results of the analysis show that loss of the instrumentation signal due to steam generator blowdown (jet envelope RJ-BD-3-1B)
does not jeopardize shutdown or post accident operation.
This evaluation is documented in Ebasco Calculation No. PRA-J-ELE-11, Revision 2, dated November 22, 1985.
During inspection 85-26, an Inspector Followup Item 50-400/85-26-02 was identified to review the study on tube separation for the redundant core coolant flow transmitters.
The above study was reviewed by the NRC inspector and this item is considered closed.
However, a concern still remains regarding the acceptability of reducing the separation between redundant tubing to less than the minimum 18 inches specified by Westinghouse.
WCAP 8584 states in paragraph B.2. 1, "the minimum separation between redundant instrument impulse lines shall be at least eighteen inches in air in both horizontal and vertical directions in non-missile or jet stream areas and shall be maintained from its starting point at the root valves to the vicinity of the instrument.
If this separation is not possible, then a suitable barrier shall be used and it shall extend at least one inch beyond the line of sight between the redundant impulse lines."
The A/E considered that their evaluation for jet impingement and safety function actuation met the intent of this standard.
The inspector disagreed with Ebasco's interpretation and informed the licensee that this position was not consistent with the Westinghouse standard and that it appears that this concern should be brought to Westinghouse's attention for concurrence.
To resolve this concern, Ebasco wrote a letter to Westinghouse, dated April 23, 1986 (No. EB-W-2671), requesting Westinghouse concurrence for reducing the 18-inch separation based on Ebasco's common mode failure analysis method.
A subsequent letter was transmitted on April 25, 1986 (No. EB-W-2672), after Ebasco determined that WCAP 8584, Appendix B was a
design assumption used in the Solid State Protection System as referenced in the FSAR.
Therefore, Ebasco was now asking for Westing-house's concurrence to a proposed FSAR change that would allow analyti-cal justification as well as physical conformance to the requirement of the Appendix B position of WCAP 8584.
Westinghouse responded to the requests by Ebasco in a letter dated April 28, 1986 (No. CgL-9308), in which they concurred with the proposed modification of FSAR, Section 7.3.2. 1, third paragraph, to read as follows:
"The Shearon Harris Nuclear Power Plant complies either physically or with analytical justification with the interface requirements of Appendix B of WCAP 8584/8670."
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The inspector reviewed the above correspondence and concluded that this matter is unresolved pending licensee submittal of a change to the FSAR and acceptance by NRR.
This concern will be identified as Unresolved Item 50-400/86-30-01, Verify that Section 7.3.2.1 of the FSAR is Revised as Described in Westinghouse Letter No. C(L-9308.
Physical Clearances Between Instrument Hardware and Other Structures The physical clearance between the instrument tubing for Pressure Switch No. PS-01IA-9790-SA and a wall mounted conduit did not meet the minimum one inch requirement specified by drawing 8-431 and Procedure WP-304.
The clearance between the conduit and tubing was less than a
half inch.
Discussions with the licensee and review of work and inspection procedures revealed that gC inspectors do not inspect for clearances.
Instead, interdisciplinary reviews are being conducted prior to turnover to identify and correct all clearance problems.
This is described.in licensee work procedures WP-302 and WP-304.
The inspector interviewed Ebasco/CPSL personnel involved in the interdisci-plinary reviews.
They indicated that the final walkdowns have not been performed and that none of the areas have been turned over to opera-tions.
They indicated that a walkdown of elevation 261 in the reactor auxiliary building, the area where PS-01IA-9790-SA is located, has not been performed.
The inspector was also informed that gA surveillance will be performed on the interdisciplinary walkdowns and that correc-tive action will be handled by FCRs or DCNs.
The inspector informed the licensee that an Inspector Followup Item will be identified to review the gA surveillances and to sample some of the walkdown punch lists to verify the adequacy of the interdisciplinary walkdown program.
This will be identified as IFI 400/86-30-02, Review of Licensee's Interdisciplinary Clearances Verification Walkdown Program.
The inspector reviewed the drawings used to install the instruments identified on page 3 of this report.
The latest revision of the as-built drawings were reviewed to verify that all appropriate FCRs had been considered in construction and that there were no outstanding FCRs issued against the drawings which would effect the current as-built
.installation.
The drawings and associated open FCRs are identified as follows:
Dwg. No. 2166-G-453 FCR-E-2357 R/0 FCR-I-2691 R/2 FCR-I-3275 R/0 FCR-S I-612/R1
- Electrical not reviewed
- Reviewed but does not effect installation
- Reviewed but does not effect installation
- Did not review Dwg. No. 2166-G-450 - No open FCRs identified Dwg.
No. 2166-G-452 FCR-E-2357 R/0 - Electrical not reviewed
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Dwg. No. 2166-G-436-S05 - No open FCRs identified Dwg No. 2166-G-436-S02 FCR-AS-8555 R/1 - Not Reviewed FCR-I-3030 R/0 - Reviewed but does not effect installation FCR-I-3103 R/1 - Reviewed but does not effect installation FCR-SI-1042 R/1 - Did not review The results of the drawing review indicated that as-built installations were completed using the latest drawings and all appropriate FCRs had been considered.
The inspector reviewed the installation records, receiving inspection reports and qualifications for three gC inspectors and one welder.
The records were found to be retrievable, legible and in accordance with procedures.
The procedures for the preparation and control of Instru-ment Work Packages were delineated by the licensee in Work Procedure WP-300 and were found to be acceptable.
Within the areas examined, no violations or deviations were identified.
6.
(Closed) IFI 50-400/85-26-02, Review of Studies on Tubing Separation This item is discussed in detail in paragraph 5 above.
7.
Other Procedures and Drawings Reviewed C(C-ll, Instrumentation Inspection, Revision
gCI-ll.1, Instrumentation Inspection Instructions, Revision
WP-300, Instrument Work Package Preparation and Control, Revision
WP-302, Installation of Supports for Safety/Seismic Related Instrumen-tation, Revision
WP-304, Installation of Safety-Related and Seismic Process Tubing and Instrumentation, Revision
WP-306, Certification/gualification of Tube Bending Tools and ASNE Section III (Code-Class)
Stainless Steel Tubing, Revision
FCR:
FCR-I-1802 RO/R1, FCR-I-1819, FCR-I-2176, FCR-1216, FCR-AS-7799 RO, FCR-IS-436.RO and FCR-AS-8178 Rl
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