IR 05000414/1985028

Insp Rept 50-414/85-28 on 850722-26.Violation Noted: Missing or Nonexistent Instrument Protection Records,Per Const Procedure 438

ML20134J903
Person / Time
Site:	Catawba
Issue date:	08/07/1985
From:	Conlon T, Ruff A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134J887	List: IR 05000414/1985028 ML20134J884 ML20134J889
References
50-414-85-28, NUDOCS 8508290517
Download: ML20134J903 (7)

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. UNITED STATES

[pn strugo NUCLEAR REGULATORY COMMISSION

,[ g REGION ll g j_ 101 MARIETTA STREET, * * ATLANTA, GEORGI A 30323

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Report.No.: 50-414/85-28 Licensee: Duke Power Company 422 South Church Street

~ Charlotte,' NC - 28242 Docket No.: 50-414 License No.: CPPR-117 Facility Name: Catawba 2 Inspection Conducted: July 22-26,-1985 Inspector: M I. [g/ J///rf A. B. Ruff 7// ' D&te Signed Approved by: IzM

.T. E. Conlon, Sect'on Chief

[- 7- Y Date Signed Engineering Branch

' Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection involved 36 inspector-hours on site in the areas of instrument components and systems, observation of work, record review and review of procedure Results: One violation was identified - Missing or Nonexistent CP-438, Instrument Protection, Records

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REPORT DETAILS Persons Contacted-Licensee Employees

• E. M. Couch, Project Manager

• T. B. Bright, Engineering Manager

• L. R. Davison, Project Quality Assurance (QA) Manager

• B. Childers, General Maintenance Supervisor

• R. Biven, Electrical Instrument Supervisor

• D. Mills, Construction Electrical Engineer

• G. Williams, QA Project Technical

'* S. Kelley, Instrument / Electrical Technical Support

• G. Hull, Instrument / Electrical Technical Support Other licensee employees contacted included construction craf tsnen, engineers, technicians, security office members, and office personne NRC Resident Inspector

• P. H. Skinner, Senior Resident Inspector

• Attended exit interview ,

- Exit' Interview The inspection scope and findings were summarized on July 26, 1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license Inspector Followup Item 50-414/85-28-01, Review of Receiving, Seismic, and Environmental Qualification Records for Instruments, paragraph Violation 50-414/85-28-02, Missing or Nonexistent CP-438, Instrument Records, paragraph The licensee did not identify as proprietary any of the materials provided to or: reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters l This subject'was not addressed in the inspectio . - Unresolved Items Unresolved items were not identified during the inspectio ,

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. . Instrument Components and Systems - Procedures Review-(52051)

The Construction Department Quality Assurance ' Program was reviewed to determine whether the safety analysis report (SAR) requirements concerning

- the safety-related instrumentation area have been translated into proce-dures, specifications, and drawings. -The ' activities and applicable proce-dures reviewed are detailed as follows.-

- Preparation, Review and Approval of Procedures and Quality Records r

The preparation, review, approval, revision and distribution of Quality Assurance (QA)-procedures for Construction Department and QA Project Division personnel is controlled by Procedere A-1, Preparation and Issue of QA Procedures, and F-1, Construction Procedures. These procedures provide instruction in the preparation.of procedures and assigns responsibility to insure that the proper technical expertise is factored into.the procedures. The review of completed work procedures and inspection documents are performed by the various working groups at Catawba.- After the documents are turned over to Project QA for final review and approval they become records. QA-301 Rev. 8, Management of Project QA Records, covers this review and approval- action. QA-301 states that personnel that perform this record review are to be traine Receipt Inspection The receipt inspection is _ controlled by Procedure P-1, Rev. 20, Receiving Inspection, which establishes the method to assure that items received at the site meet the requirements of the procurement documents (Specifications). P-1 requires visual inspection, vendor document review, . identification verification, and compliance with the required storage level. Additionally, the procedure defines acceptance criteria to determine status and required documentation, Handling and Storage Procedure P-3, Rev. 18, General and Special Storage Maintenance Inspaction Requirements, establishes measures to assure that items are stored and maintained in accordance with purchase documents and other established requirement This procedures defines the source of storage, maintenance requirsments, frequency of inspections, and the necessary documentatio CP-438, Rev. 3, Instrument Protection, applies to the instrument after it is-installe It establishes measures to assure that instrument '

protection and/or storage maintenance requirements are considered and initiated, if necessar m ,

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d. -Installation,' Inspection and Construction Testing

QA Procedure M-61, Instrumentation Process Control and Inspection; F-l',

Construction Procedures; CP-623, Origination and Routing of Instru-mentation Process Control, and Drawing.ICS-A-20,-Instrument. Standards -

-Installation Field Practices establishes the requirements inspection, and documentation for instrument equipment installation. The M-61 Procedure -is supplemented by supplemental -inspection instructions designated by M610 Serial Numbers. These serial number instructions

11sted below provide specific. installation-verifications and acceptance criteria for instrument and component M-61D Serial'

Numbers and Revisions Title I-1, Rev. 1 Safety Class Tubing I-2, Rev. 2 Instrument Tube Supports Erected in accordance with the ASME NF code I-3, Rev. 8- Safety /Related- (Use Code 9)

Instrument Installation I-4, Rev. 8 Soleniod Valves I-5,'Rev. O Solentod Valves - Active Control Valve Installations

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I-6, Rev. 4 Thermowell (TW), Test Well (TX)

Installation I-7, Rev. O PressureTestConnections'(PX),

FEs with Taps Only I-8, Rev. 7 . Instrumentation Final Walk-through I-9, Rev. O Root Valve Assembly Configura-tion I-10 Rev. 1 Configuration of Instrument Reservoirs I-11, Rev. 0 Use Code 8 Items Which Form a Part of the Pres:ure Boundary ,

I-12, Rev. O Flow Glasses (FG), Level Glasses (LG)

M-1, Rev. Process Tubing Erection Inspection L'- 4

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. Material and Component lI'dentification'

The material and equipment identification is verified as part of P-l'

' inspection activity and various instrumentation process ' control installations, and _ inspections.- During . any portion' of . receipt-inspection, storage, installation,:or. routine inspections when an item is identified as not conforming with QA, Design or Code requirements, the item :is processed as a nonconforming : item in accordance. with Procedure Q-1, Control of Nonconforming Item . Construction Testing and Calibration

.The licensee's representative stated testing and calibration in the instrumentation area was not performed by the construction departmen These types of activities are perfonned by the startup group in the Power Production Departmen g .- Change. Control

. QA Procedures G-1, Document Control, and CP-631, Unit 2 Change Manage-ment, establishes measures to assure that all QA Condition documents and/or their revisions are controlled at the work' site. This control also includes retrievability and status of work resulting from. issuance of documents and their revision Within the areas examined, no violations or deviations were identified..

- Instrument-Com Review (52055)ponents and Systems - Work Observation (52053) and. Records The' inspector selected the following instruments and components for an

examination of field work and records review

Instrument and/or Component Description 2NCFT5000 Reactor Coolant (RC) Flow

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Transmitter 2NCLT5150 Pressurizer Level Transmitter

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.2NCP5153 Pressurizer Level Indicator (Receiving gage) in the Control Roo Receives signal from 2NCLT5150

! 2NCPT5150 Pressurizer Pressure Trans-

, mitter I 2SMPT5080 SG A Steam Line Pressure l Transmitter

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Instrument and/or Component Description

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.2SMP5080; Steamline- Pressure - Indicator

~(Receiving gage) in the Control Room Receives Signal .fromi 2SMPT5080

'2NCRD5860 Resistance Detector for RC Temp 2NCCR5860 and 2NCP5860 Recorder and Temperature indi-cator (Receiving gage) in the

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Control Roo Items receive signal from 2NCRD5860 The 1ocation, orientation, mounting, anchoring, ' identification, clean-

liness, physical protection, redundancy, separation, tubing runs and

slopes, where ' applicable, were examined to insure that they complied with_ drawings including instrument standard ICS-A-20 and the applicable M-61 Instrument Process Control and Inspection Document .

Where applicable,- the M-61 Installation and Inspection Records', P-1 Receiving Records .and P-3 Storage Records for the above listed items were reviewe The P-1A receiving Inspection Report for Pressure Transmitter 2SMPT5080'

has a Quality Release (QR) that was contingent on a successful-

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completion :of = an' environmental qualification test. No records-were available with.this P-1A report to indicate that this was-accomplishe A licensee's representative did find a new-QR that indicated that the qualification test was successful. The seismicL and' environmental qualification records are-located at the Duke Power Company's' General Offices. .The licensee also indicated that-some receiving gauges such as 2NCP5860 and 2SMP5080 are standard stock items. These are assigned QA Condition #1 status and fall under 10 CFR 50 Appendix'B requirement The receiving inspection; and' seismic qualification for these gauges-along with environmental qualification records forL instrument 2NCR5000, LT5150, PT5150, 2SMPT5080 and 2NCRD5860 will be examined on a future inspectio This is identified as- Inspector Followup Item (IFI) 50-414/85-28-01, Review ~of Receiving, Seismic,'and Environmental '

Qualification Records -for Instrument After an instrument is installed, its protection and any special-maintenance is reviewed and documented by the Equipment Maintenance

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Departmen ' This requirement is specified in CP-438, Instrument Protection. .The CP-438 records for instruments 2NCFT5000, LT5150, PT5150, ' 2SMPT5080 and 2NCRD5860 could not be locate This is identified as violation 50-414/85-28-02, Missing or Nonexistent CP-438, Instrument Record ,

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An as-built drawing verification was performed for the orientation and physical location-of instrument No. 2NCRD5860, Resistance Detector, and 2NCFT5000, Flow Transmitter. Drawings CN2680-1 Rev. 8, Nozzle Identifi-cation and Location Primary Loops, Reactor' Coolant System, and CN2499-01.10 Rev. 28, Instrument Location Reactor Building Elevation 565' and Below, were used for this verificatio QA-300, Construction Surveillance, requires periodic audits of the construction program activities. Two surveillance Reports, C85-51 and C85263, in the instrumentation area were examined. This examination showed that surveillances were performed in accordance with a planned schedule, records were sufficiently detailed to verify intent, findings were reported for evaluation and corrective action, followup action was taken and that surveillance personnel were independent of work that was being observe Within the areas examined, no violations or deviations other than the one reported above were identified.

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