IR 05000445/1981010
| ML20010G036 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/07/1981 |
| From: | Randy Hall, Andrea Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010G030 | List: |
| References | |
| 50-445-81-10, 50-446-81-10, NUDOCS 8109150260 | |
| Download: ML20010G036 (6) | |
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U.S. NUCLEAR ?.EGULATORY COMMISSION OFFICE OF INSFECTION AND ENFORCEMENT
REGION IV
Report:
50-445/81-10; 50-446/81-10 Dockets:
50-G5; 50-446 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Facility Name:
Comanche Peak, Units 1 and 2 Inspection at:
Comanche Peak Steam Electric Station, Glen Rose, Texas Inspection Conducted: July 20-23, 1981 Inspector *
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A. R. Johnson, Reactor Inspector, Engineering & Materials Date Section 4'
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Approved:
R. E. Hall, Acting Chief, Engineering & Materials Section Date Inspection Summary Inspection on July 20-23, 1981 (Report: 50-445/81-10; 50-446/81-10)
Areas Inspected:
Routine, unannounced insoection of safety-reldted construction activities pertaining to installation, inspection and documentation of safety-related instrumentation installations for components and systems.
The inspection involved 36 inspector-hours by one NRC inspector.
Results: No violations or deviations were identified.
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8109150260 810811 PDR ADOCK 05000445 g
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DETAILS 1.
Persons Contacted l
Principal Licensee Personnel R. G. Tolson, TUGCO, Site QA Supervisor
- B. C. Scott, TUGCO, Quality Engineering Supervisor
- R. E. Camp, TUGC0/EDS Nuclear, Lead Startup Engineer
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- R. K. Wirth, TUGCO, QF Instrumentation and Control Engineer W. Mahan, TUGCO, QE Electrical Engineer
- C. G. Creamer, TUSI, Project Instrumentation and Control Engineer
- T. G. Wardlow, TUSI/B&R, Instrumentation Engineer R. Michaels, TUGCO, QE Engineer W. Cromet.ns, TUGCO, Turnover and Document Control D. Llewellyn,TUGCO/B&R, NCR Co-ordinator/Docur.ent Control F. Yeager, TUGCO, Field Document Control The NRC inspector also interviewed other licensee and contractor personnel during the course of the inspection.
- Denotes those attending the exit interview.
2.
Safety-Related Instruments and Instrument Tubing Installations
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a.
Observation of Completed Work i
The NRC inspector inspected a total of 13 safety-related instrument and associated instrument tubing installations, which had been completed and turned over to the licensee (TUGCO), to ensure that
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installations were in accordance with FSAR, TUSI/B&R 3pecifications
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and drawings, TUGC0/B&R quality instructions and p ocedures, and industry standards.
These installations were portions of safety-related systems involved in Post Accident Monitoring (PAM) and Normal Plant Process (NPP) control.
Neither RPS or ESFAS instrument installations have been completed for turnover to date.
The instruments were inspected for proper type, tagging, range, rating, location, cleanliness, physical protection, documentation of environmental or seismic qualification, and review of'QC inspection records (manufacturer's record sheets and instrument installation checklist).
The instrauent tubing installations were inspected for proper location, routing, safety identification, material traceability, alignment, leveling, separa-tion, freedom of movement, and physical protection. The respective QC inspection records were also reviewed by the NRC inspector (e.g., manufacture >'s record sheets, component modification cards, design change authorities, inspection reports, etc.).
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i The NRC inspector observed t!-
vae slope for the drain line, upstream of the isolation *
<e for each of the four Refueling Water Storage Tank Level *
ing installations (1-LT-930, 1-LT-931, 1-LT-932, and 1-LT-933)
ceeded the 1 " maximum allowance as specified in TUGC0 Qua' y Instruction QI-QP-ll.8.1, Revision 8,
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paragraph 8.1.C.
TUG ~
cngineering, havino made an evaluation, I
determined that ther. was no basis for restricting gravity drain line slopes to the 1 " maximum dimension, and agreed to change the drawings and specifications to conform with the "as built"
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j configuration.
The following instruments and instrument installations were
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inspecteo:
1-LT-930 Refueling Water Storage Tack Level PAM 1-LT-931 Refueling Water Storage Tank Level PAM l-LT-932 Refueling Water Storage Tank Level PAM j
1-LT-933 Refueling Water Storage Tank Level PAM X-PT-5855 Control Room Pressure PAM q
I X-FT-ESS6 Control Room Pressure PAM l-TE-5402 Conto.nment Temperature PAM i
1-TE-5403 Containment Temperature PAM l-LS-6712 Chiller Water Tank Level f;PP 1-LS-6713 Chiller Water Tank Level NPP 1-FIS-4650 Component Cooling Water Flow to Chillers NPP
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l-LS-3375A Diesel Fuel Level NPP l-LS-3375B Diesel Fuel Level NPP The following governing quality instructions and procedures were reviewed by the NRC inspector:
TUGC0 QI-QP-ll.8.1, Revision 8 TUGC0 QI-QP-16.0.4, Revision 0 B&R QI-QAP-ll.1.33, Revision 0 B&R 35-1195-ICP-4, Revision 4 B&R QI-QAP-ll.1.24, Revisio.: 5-3-
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The following governing seismic tubing support placenent packages
were reviewed by the NRC inspector:
Gibbs & Hill, Inc. 2323-I001, August 21, 1979 Gibbs & Hill, Inc. 2323-I002, November 1,1979 No violations or deviations were identified.
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b.
Observation of Completed Work With Instrument Certification Incomplete The NRC inspector inspected two safety-related instrument and instrument tubing installations for the Post Accident Monitoring Condensate Storage Tank levels, which had been completed, turned over to the licensee (TUGCO), and which were currently in service.
i The instrument assemblies and installation were for the Rosemount j
level Transmitter, Model 1153.
The documentation delineating I
adherence to IEEE Standard 323(Environmental Qualification) and i
IEEE Standard 344(Seismic Qualificatioa) had not yet been sub-j mitted, or approved, from the instrument manufacturer, thus
rendering the certification for these instruments incomplete.
I NCR E-80-00088, dated January 27, 1981, had been issued by the licensee (TUGCO) to this effect.
The NRC inspector reviewed i
the Class IE Equipment Qualification Milestone Status Report and verified that the identification and tracking method used Tcr certifying instruments was adequate.
No violations or deviations were identified.
The instrument tubing installation for the two safety-related Condensate Storage Tank Level instruments (Rosemount Model 1153)
were inspected by the NRC inspector for proper location, routing,
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safety identification, material traceability, alignment, leveling, F ysical protection.
The separation, freedom of movement, and
NRC inspector also reviewed the respective QC inspection records (manufacturer's record sheets, component modification cards, i
design change authorities, inspection reports, etc.).
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The governing quality instructions, quality procedures, and seismic tubing support / support placement packages, listed in paragraph 2.a above were used as acceptance criteria by the NRC inspector during the above inspection activity.
The NRC inspector observed that both instrument tubing drain lines were physically deformed from their respective seismic supports as a result of the adjacent ccnstruction act vities and/or traffic through the instrument instal?ation areas.
Both instrument facilities were currently in temporary-use service at this time, during the construction phase, and were operated by the licensee (TUGC0). The
protective covers employed prior to turnover had been removed once
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the equipment was place,i in temporary service. Damage to these instrument installations weald appear to require replacement /
repair of the instrument tubing and a documented reirspection on the part of the operating utility (TUGCO), prior to permanent use.
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The NRC inspector also obserled that a heat trace system had been installed and employed after turnover by the licensee as evidenced i
by no record on the QC Instrument Installation Checklist (MSR)
prior to turnover. The NRC inspector determined that the heat trace system was not safety-related, and that it had been installed
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by the licensee as an interim measure until the compartment dcors to the outside environment were installed.
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The NRC inspector found that no licensee (TUGC0) procedures had yet
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been issued, regarding instrument installations, to address the responsibilities, activities, and documentation requirements of the operating utility (TUGCO), after release and turnover of the safety-relatea instrument systems, subsystems, and components by the con-struction utility (TUSI). No licensee (TUGCO) procedures were found to delineate and control the activities to maintain, remove, repair, modify, assemble / disassemble permanent plant instrumentation equip-ment, after release / turnover to TUGCO.
This matter is considered as an unresolved item pending clarification of applicable requirements and commitments.
c.
Observation of In-process Work The NRC inspector inspected ten safety-related instrument and instrument tubing installations, which h d completed fabrication, and were currently in service, but were not released for turnover in that the QC records were incomplete (e.g., instrument installation checklists (MRSs) did not have complete QC signoff on all items).
These ten safety-related instrument facilities employed temporary instruments (not certified for safety-related application), calibra-tion, and had been installed to facilitate the interin opc"ation of the Service Water pumps and Component Cooling Water Heat Exchangers during the construction phase to provide construction air conditioning.
The QC records for these instrument installations are being retained at the Field Control Center until QC signoff and turnover at some later date after which they will be forwarded to the permanent record storags (QA vauit).
Ten safety-related instrument tubing installations were inspected by the NRC inspector for proper location, routing, safety identification, material traceability, alignment, leveling, separation, freedom of movement, and physical protection. The respective QC in?cection records were also reviewed by the NRC inspector (e.g., manufacturer's records sheets, component modification cards, design change authori-ties, inspection reports, etc.).
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The following instrument installations were inspected:
I X-PS-4290 Service Water Pumo Pressure j
X-PS-4291 Service Water Pump Pressure X-PS-4296 Service Water Pump Pressure l
l X-PS-4297 Service Water Pump Pressure 1-PT-4252 Station Service Water Pump Pressure 1-PT-4253 Station Service Water Pump Pressure 1-FT-4535A Component Cooling Water Heat Exchanger Flow 1-FT-4536B Component Cooling Water Heat Exchanger Flow
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l-FT-4537A Component Cooling Water Heat Exchar.ger Flow 1-FT-45373 Component Cooling Water Heat Exchanger Flow The governing quality instructions, quality procedures, and seismic tubing support / support placement packages, listed in paragraph 2.a above were used as acceptance criteria by the NRC inspector during the above inspection activity.
No violations or deviations were identified.
3.
Unresolved Items i
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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of violation. An unresolved item relating to post turnover protection of permanent instrumentation is discossed in paragraph 2.a.
4.
Exit Interview l
The NRC inspector met with the licensee representatives (denoted in
?aragraph 1) and Mr. R. G. Taylor (NRC Resident Peactor Inspector) at I
the conclusion of the inspection on July 23, 1981. The NRC inspector summarized the purpose, scope and findings of the inspection.
The NRC inscactor also discussed possible ingredients of a licensee pro-gram which would correct the problems related to the above noted unre-solved item.
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