IR 05000445/1989054

Resident Safety Insp Repts 50-445/89-54 & 50-446/89-54 on 890706-0801.No Violations,Deviations,Open Items,Unresolved Items,Strengths or Weaknesses Noted.Major Areas Inspected: Util Action on Previous Insp Findings & Plant Tours

ML20246E839
Person / Time
Site:	Comanche Peak
Issue date:	08/24/1989
From:	Livermore H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20246E810	List: IR 05000445/1989054 ML20246E806
References
50-445-89-54, 50-446-89-54, NUDOCS 8908300039
Download: ML20246E839 (16)

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U. S. NUCLEAR' REGULATORY COMMISSION

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OFFICE OF NUCLEAR REACTOR REGULATION NRC-Inspection Report: 50-445/89-54 Permits: CPPR-126

, 50-446/89-54 CPPR-127 Dockets: 50-445 Construction Permit 50-446 Expiration Dates:

Unit 1: August 1, 1991'

Unit 2: August 1, 1992'

Applicant: TU Electric Skyway Tower 400 North Olive Serptt Lock Box 81 Dallas, Texas ;5201 Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: July 6 through August 1, 1989 Inspection conducted by NRC consultants:

W. P. Chen - Parameter (paragraph 5)

P. Stanish - Parameter (paragraphs 2-4)

Reviewed by: a f#f4/f///L E'/ 5"2Y-E'O

'. H/ Livermore, Lead Senior Inspector H Date l

8908300039 G90823 PDR ADOCK 05000443 Q FDC

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i Inspection Summary:

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l- Inspection Conducted: July 6 through August 1, 1989 (Report 50*445/85'-54; 50-446/89-54 )

Areas Innpected: Unannounced, resident safety inspection of applicant's actions on previous inspection findings; follow-up on .

I violations / deviations; inspections of conduit supports Train C -

l 2-inch and under; review of design and installation of instrumentation tubing and supports; and plant tour Results: Within the areas inspected, no significant strengths or weaknesses were identified. No violations or deviations, open items, or unresolved items were identified.

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p DETAILS Persons Contacted

• J. L. Barker, Manager, ISEG, TU Electric

• J. W. Beck, Vice President, Nuclear Engineering, TU Electric '

• O. Bhatty, Issue Interface Coordinator, TU Electric

• M. R. Blevins, Manager of Nuclear Operations Support, TU Electric

• H. D. Bruner, Senior Vice President, TU Electric

• H. M. Carmichael, Senior QA Program Manager, CECO

• D. J. Chamberlain, Licensing Lead Engineer, Unit 2, CECO

• J. T. Conly, APE-Licensing, Stone and Webster Engineering Corporation (SWEC)

• W. G. Counsil, Vice Chairman, Nuclear, TU Electric

• B. S. Dacko, Licensing Engineer, TU Electric

• D. L. Davis, Nuclear Operations, Resulta Engineer Managsr, TU Electric

• R. J. Daly, Manager, Startup, TU Electric

• G. G. Davis, Nuclear Oparations Inspection Report Item Coordinator, TU Electric

• G. L. Edgar, Attorney, Newman and Holtzinger

• D. M. Ehat, Consultant, TU Electric

• J. C. Finneran, Jr., Manager, Civil Engineering, TU Electric

• C. A. Fonseca, Deputy Director, CECO

• B. P. Garde, Attorney, CASE

• J. H. Greene, Site Licensing, TU Electric

• W. G. Guldemond, Manager of Site Licensing, TU Electric

• P. E. Halstead, QC Manager, TU Electric

• J. C. Hicks, Licensing Compliance Manager, TU Electric

• C. B. Hogg, Chief Manager, TU Electric

• R. T. Jenkins, Manager, Mechanical Engineering, TU Electric

• J. J. Kelley, Manager, Plant Operations, TU Electric

• J. J. LaMarca, Electrical Engineering Manager, TU Electric

• D. M. McAfee, Manager, QA, TU Electric

• S. G. McBee, NRC Interface, TU Electric

• W. E. Nyer, Consultant, TU Electric

• G. Ondriska, Startup, TU Electric

• E. F. Ottney, Program Manager, CASE

• S. S. Palmer, Project Manager, TU Electric

• P. R. Raysircar, Deputy Director / Senior Engineer Manager, CECO

• D. M. Reynerson, Director of Construction, TU Electric

• A. H. Saunders, Quality Surveillance, TU Electric

• A. B. Scott, Vice President, Nuclear Operations, TU Electric

• J. C. Smith, Plant Operations Staff, TU Electric

• J. F. Streeter, Director, QA, TU Electric

• C. L. Terry, Unit 1 Project Manager, TU Electric

• R. D. Walker, Manager of Nuclear Licensing, Tt] Electric

• J. R. Waters, Site Licensing Engineer, TU Electric

• R. G. Withrow, EA Systems Manager, TU Electric

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1 l The NRC inspectors also interviewed other applicant employees L during this inspection perio * Denotes personnel present at the August 1, 1989, exit meeting.

L l Applicant's Action-on Previous Inspection Findincs (92701B)

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(Cicsed) Open Ite.m (445/9516-O-52): During ERC

" reinspection of Verification Packase I-S-COSP-071, which was witnessed by the NRC inspector, ERC identified the following conditions as subject to evaluation as potential deviaticns:

(1) A plate size was incorrec (2) A nut was botcomed out on Hilti bolt thread As a' result of these observations, the applicant issued Nonconformance Rep 0rt (NCR)-M-86-100359sX which was dispositioned to replace the conduit support in question (C14W13102-05).

Tne NRC inspector has reviewed Design Change Authorization (DCA) 29860, Revision 4, which details the new support, as well as the inspection report that documents the installation and QC inspection of the suppor Based on the above reviews, this item is closed- (Closed) Open Item (445/8914-O-01; 446/8914-0-01): NFC review of the mechanical equipment commodity revealed that coupling and alignment requirements related to connectiag' rotating equipment was not identified as an inspection attribute on the commodity attribute matrin (CAM)-

TU Electric stated that alignment of mechanical equipment was not in.cluded in the Post-Construction Hardware Validation Program (PCHVP) since all safety-related equipment would be realigned prior to plant operation by startup and operations. The NRC Could not verify if all realignments would be performe In this inspection period, the applicant provided a list of all safety-related rotating equipment annotated with the realignment statu This list indicates that either realignments were not necessary, as in the case of direct drive equipment (i.e., no couplings), CPRT verified alignment and the equipment was not disassembled, or that vibration sensitive equipment was tested and if no vibration problems were detected alignment was considered to be adequate. The NRC inspector concurs with the

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applicant's assessment that the attribute was adequately addressed. This item is close (Closed) Unresolved Item (445/8875-U-01 446/8871-U-01):

During a plant tour, the NRC inspector identified a sway strc? clamp on support SW-1-102-007-S48R which had ears that were visibly not parallel. The concern with this

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clamp was that bending stresses in the load pin may exceed the conditions analyzed by the vendo In this inspection periode the NRC inspector reviewed the corrective actions taken by the applicant in response to Violation 445/8912-V-03 (See paragraph 3.a). The inspections and rework undertaken in response to this violation fully address the concern addressed abov Based on those actions, this item is close . Follow-up on Violations / Deviations (35960, 92702) (Closed) Violation (445/8912-V-03): The NRC inspector had previously identified the following examples of inadequate inspection of pipe supports:

(1) MS-1-003-001-C725 - The beam attachment had one ear that was ben (2) FW-1-018-718-C72K - The snubber clamp on this support does not provide the necessary clearance to allow for the full range of angular motio (3) CT-1-038-418-C62S - The spring load column is cocked beyond the tolerance of ASTM-A-12 (4) CS-1-002-700-C52S - No sight hole in one of the spring load coupling (5) CC-1-258-003-C53R - The spherical bearing in the sway strut paddle end is partially dislodge (6) RC-1-135-004-C51K - The clamp for this snubber will not allow the full range of angular movemen (7) CC-1-207-020-C53R - The space between the cars of ,

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the clamp exceeds maximum toleranc (8) FW-1-096-002-C62K - Inadequate clearcnce between the clamp and snubber body to allow the full range of angular movemen (9) FW-1-096- 002-C62R - Space between the ears of the clamp exceeds the maximum toleranc i i

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(10) MS-1-340-001 d C52S - The eye nut is bound against the i top of the pipe clam (11) CC-1-269-700-C53A - one of the welds has a fit-up gap that exceeds the criteria of the weld procedure I specificatio (12) MS-1-344-700-C52K - The spherical bearing on the paddle end of the snubber is completely' dislodge (13) RC-1-018-038-C51K - The space between the ears of the clamp exceeds the maximum toleranc (14) FW-1-098-701-C62K .The jam nuts on both sway strut bodies are loos (15) MS-1-RB019-005-2 - The clamp ears are bent to less

.than the minimum allowable dimensio (16).CT-1-014-001-S22S - The threaded rod on this support interferes with the supporting stee (17) SI-1-070-006-S22R - The ears on the cotter pin are not sprea (18) BR-X-106-064-S43R - Baseplate not grouted properl (19) CS-1-900-702-S42R - Jam nut for the sway strut body not tightened properl (20) SI-1-060-006-S42R - Clamp ears not parallel and load pin not parallel to clamp bol (21) CS-1-106-717-C42R - Cotter pin missin (22) CS-1-106-723-C42R - Cotter pin missin (23) CC-1-016-700-A43R - Cotter pin ears not spread (previous inspection finding 445/8865-o-01).

In response to this violation, the applicant's Senior Management directed the performance of a walkdown of all 4 reasonably accessible pipe supports by engineering to identify potential programmatic problems. The general conclusion of the evaluation of the observations was that the CPSES pipe support installation program is effective in assuring that design requirements are properly implemente Specific details relating to the number of observations, categories and root causes were contained in Project Technical Report (PTR)-06, " Engineering Evaluation of Pipe Support

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E Inspection Issues," which was included ao an attachment to f!

[' Corrective Action Request (CAR)89-004.

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Corroctive actions included rework for those items deemed to have been the result of isolated circumstances or damage due to ongoing construction and maintenance. It was determined that th0 reason for several of the identified discrepancies was insufficient QC inspection criteria. Stis necessitated changes to Specification 2323-MS-100 and inspection Procedure AQP 11.3 to address attributes necessary to ensure sufficient clearance to accommodate angular rotation of mechanical snubbers, and sway struts. These additional / revised attributes required QC reinspection of certain pipe supports affected by this revision to the specificatio Corrective steps taken to preclude repetition of these conditions include:

TU Electric has established a surveillance program to monitor completed commodities-to assure they are maintained in an acceptable conditio . TU Electric has implemented an increased awareness program which includes

Instructing the appropriate Construction Department personnel to emphasize the general policy memorandum which cautions against damage to installed hardwar Posting of clearly visible signs highlighting the general policy memorandum in various rooms / areas of the plan . The QA. Department will develop a procedure to provide QA involvement in the Room / Area turnover programs and in monitoring of commodities to assure they are maintained in an acceptable conditio . ASME QA Procedure AGp 11.5, "ASME Component Installation Verification," was revised to include verification of completeness of pipe supports within the NIS-2/N-5 boundary prior to finalizing the NIS-2/N-5 ASME Code Certificatio The NRC inspector has reviewed CAR-89-004, the Engineering Report PTR-06, Revision 0, as well as Consolidated Engineering and Construction Organization (CECO) letter CECO-0942. These documents ultimately conclude that the conditions addressed in Significant Deficiency Analysis Report (SDAR) CP-69-11 are reportable. The NRC inspector also reviewed DCA-17041, Revision 1, which details the changes made to Specification MS-100 and details the required reinspection along with the changes to AQr-ll.3, " Fabrication, Installation, Repair,

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L Replacement, and Modification Inspection of Componcnt L Supports," and the specific NCRs generat?d in response to the L documented NRC inspection i'indings. Based on the above i actions, this violation is closed, a Conduit Supports Train _Q_LeJs than pr Equsi to 2"_(35960, {

37055, 4P053) ,

In this inspection period, the NF2 inspector feviceed Comanche Peak Engineering, Engineering AssessrAent Procedure CPE-CPE-EAP-CS-018, Revision 0, " Trait!.C 2-Inch Diametor and ,

Under Program Maintenance Reduction." This procedura Was initiated due to the feet that Train C ccnduit isss than or

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l equal to 2-inch diameter located in Unit 1 and common areas L was quclified fcy system interaction considerations under the Corrective Action Program (CAP). The CAP vilidated Train C by either qualifying: (1) the pot 9ntial interaction of the conduit system and associated safety-related egaipment as a result of postulated seismic collapse or latera) away of Train C or (2) the conduit support structure design ensures seismic integrit If conduits and cor.sduit supp9rts were qualified by (1) above a comprehensive maintenance effort would be required during the lifc of the plant to ensure that new unacceptable interactions are not introduced when new safetycrelated equipment is installed or (2) when existing structures, which may have been utilized as protective barriers, are altered or remove As an alternative to continuously monitoring and updating Train C design documentation, a main +enance reduction program ;

is being implemented to minimite future inaintenance of Train C conduits and conduit suppcrts. This program abould demonstrate that the majority of conduit systems are supported on supports whose structv.ral integrity has been demonstrated l during implementation of the CAP and are not seismic hazards, I as such, need not be monitored throughout the life of the plan Only the " unique" supports whose structural integrity has nct been dencastrated will require future maintenance or qualification. This program is be!.ng implemented by a {

walkdown to identify and dccument the location of unique supports, as well as identification 6f all unacceptable ,

interactions with unique supports and unacceptable sway >

interactions with pendulum type light fixture The NRC inspector accompanied applicanc personnel o? a field demonstration of the implemcatation of Procedure EAP-018 to determine how walkdown engineers were evaluating " acceptable" deviations of regular supports, impact of isclated unique supports, and acceptability of rugged supports (supports which are inherently rugged due to a high degree of redundancy - )

1.e., ratio of Lttachm.ents to concrete, bracing, etc. to j

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number of conduits supported). Subsequent to this

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demonstration, a meeting was held to' discuss NRC questions / concerns relative to performance offthis EAP as.well j '

asLinterface_ requirements relative to shared conduit supports iand' junction boxe In'this meeting, the-applicant'was able:

to adequately address and resolve.all-the NRC concerns with~

thefexception of'a concern relativeDto the procedural C o' guidelinesffor the supporting scheme for small diameter Train C conduit connecting-to junction boxes with TrainEC'

conduit larger than 2 inche To; resolve the concern over;how1'the. loads from theismall bore'

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conduit were factored into.the analysis of the " mixed":

-junction boxes, which are the. responsibility'of Ebasco, a i .

reeeting was held with Ebasco's conduit grou In this. . ,

I meeting,'it was determined that Ebasco had defined the design requirements that formed the basis of-Impell's walkdown-criteria 1 for conduit attached to mixed junction boxe Whe asked iffthe small. diameter Train C conduit loads were 4-factored into;their analysis, Ebasco stated that they had qualified these junction boxes based on their engineering 1 j udge. ment. However, since the Systems Interaction Program (SIP) .had. identified 91 Train C junction boxes that, if.they were to fall, could damage safety-related components, the NRC

. inspector stated that objective evidence of structural ~ .

adequacy for the junction boxes or their supports would be required. In response to this, Ebasco reviewed the .f 91 junction boxes in question and determined that 1 junction box is supported on a cable seismic restraint (CSR) and detailed analysis was available for this configuration, 39 junction boxes are supported on "nonis supports," which only support dead weight, and 51 are support.ed cn seismic (S-0910) supports. Ebasco performed an analysis for each of the 51 junction boxes that were supported seismically. This analysis included the applicable loads from the junction. box itself and all the conduits attached to it, this total load was then compared to the capacity of-the appropriate S-0910 support. Ebasco concluded based on this analysis that all of q these boxes were; adequately supported. For the boxes -

supported on "nonis" type supports, a-somewhat different analysis technique was utilized. Ebasco screened all of the junction boxes.and identified five worst-case examples. These examples were selected using the following criteria: )

(1) junction boxes with the largest loads, combined with )

.(2!) the'1 east number nf conduits greater than 2-inch diamete This selection made the following assumptions: (1) small diameter Train C conduit would provide no support to the h l junction boxes and that (2) the "nonis" support for the I junction boxes failed so that the load from the junction box was supported from the larger diameter conduit support Again, this analysis determined that the junction boxes, even if their supports failed, would be adequately supported by the

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associated conduits and not fall and cause damage to safety-related equipmen Based on the NRC inspector's review of th0 analysis performed'

.by Ebasco, it was concluded that tha walkdown instructions-provided to Impell for the shared junction bcxes are adequat i No deviations or violations were identifie . Design and Installation c,f Instrumentation Tubing and Support 152051, 52053, S2055)

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During this report period, the NEC inspector conducted a review to assess the adequacy of the program developed by i TU Electric relating to the design and installation of safety-related Seismic Category I instrumentation and controls (I&C) tubing and tubing supports. Particular attention was given to the TU Electric resolution of Ccmanche Peah Response Team (CPRT) and external issues and SDAR issues as identified in Appendix A and B, respectively, of the TU Electric's CAP I&C Project Status Report (PSR). ,

l As described in the PSR, the issues were to be resolved on the (

basis of: (1) design criteria consolidated in Design Basis l Documents (DBDs) developed under the Design Basis Consolidation Program (DBCP) portion of the CAP and (2) inspections (including Field Verification Method {FVM] ;

inspections) and engineering evaluations performed under the-PCHVP portion of CA ,

During the review, the NRC inspector found that as committcl to in the PSR, instrumentation specification had been i.ssued and both the tubing supports and support placement series drawings had been modified to reflect the design requirements of the DBDr. I?urther, the NRC inspector found that of the approximately 430 safety-related instrumentation loops in Unit 1 and common areas which were designed and installed prior to the cap only a few had been found to be acceptable, even with extensive support modifications, during FVM inspections. The majority of the loops required entensive design verification analyses of the tubing layout und support hardware modifications to be in accordance with the CAP validated design requiremerit Accordingly, the NRC inspector evaluated applicable CAP related specifications, DBDs, FVM inspection procedures and results, drawings and calculations, and performed walkdowns of tubing and tubing support The NRC inspector reviewed design basis documents DBD-EE-15,

" Instrument Installation and separation," Revision 2, i

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Augwit 31, 1985, and DBD-CS-009, " Instrument and Tubing

.9upport Design," Revision 2, March 10, 1988. The review found that Sectien 3.0, Codes and StanCArds, of DLD-EE-15 required the design, procurement, and installation for instrument tubing system be in accordance, with the ASME B&PV Code. In addition, Section 5.0, " Functional Requir9ments," of DBD-EE-15 specified detailed requirements for slope cf tubing, tubing and support installation, materials of construction, seismic instrument racks, stands and supports in Seismic Category I buildings, flexible hose assemblies, and expansion loops. The

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review also found that Section 3.9, " Codes and Standards," of DBD-CS-089 required the design of Seismic Category I tubing supports be in accordance with the AISC and AISI specifications and the AWS welding code. Furthermore, Section 4.0, Design Criteria and " Functional Requirements," of DBD-CS-089 specified detailed design requirements including loading combinations, seismic amplification factors, allowable stresses, and design interfacing requirements. In particular:

(1) both the 2323-I-001, " Seismic Tubing Support Package," and the 2323-I-002, " Criteria for Seismic Tubing Support Placement," series drawings were referenced for the placement and type of tubing supports; and (2) the 2323-Ml/M2-2100,

" Instrument Installation Details"; 2323-Ml/M2-2600,

" Instrument Locations"; and 2323-Ml/M2-2800, " Instrument Rack Drawings" series drawings were referenced for the location of racks, individually mounted instruments and panels. The review concluded that the design and installation require.ments specified in DBD-EE-15 and DBD-CS-089 for the safety-related instrumentation tuhing and supports were adequate to assure that the design and installation would be secomplished in a controlled manner and the tubing and supports perform their intended safety function. The review also cencluded that tnese DSD-EE-1$ and DBD-CS-089 requirements adequately address related CPRT, external, and SDAR issue The NRC inspector reviewed the revised specification issued l

during the CAF: Specification CPES-I-1018, " Installation of Piping / Tubing and Instrumentation," R'evision 3, October 10, l 1988, and related DCA 78372, Revision 5, February 14, 198 The review fovnd that the specification adequately reflected the design criteria in DBD-EE-15 and DBD*CS-089 as committed to in the CAP PSR. Subsections 2.1 and 2.12 of Section II,

" Piping /Tvbing and Instrumentation, Safety Class 1, 2, and 3,"

of Specification CPES"I-1018 defined installation requirements I relating to tubing (impulse lines), flexible hose assemblies i and expansion loops, piping, tubing supports, seismic rack l

assemblies and loca2 stands, instrument ~ mounting, welding, pressure tests, and documentation. Specifically, this specification required that: (1) tubing be installed and L connected in accordance witn the 2323-Mi-2100 series drawings; (2) flexible metal hose assemblies be installed in accordance with the ECE-M1-2100 series general notes and the applicable

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2323-M1-2500, " Instrument Tabulation Sheets," series drawings; (3) Seismic Category I tubing supports be in accordance with the 2323-I-001 series drawings and tubing span and support placement be governed by the 2323-I-002 series drawings and the TNE-Il-0069, " Seismic Tubing Support Span Lengths,"

drawing; and (4) Seismic Categcry I instrument racks and local stands be in accordance with the 2323-M1-2800 series drawings and the TNE-Il-0071, -0078, and -2804 drawings, respectivel Subsequently, the NRC inspector conducted a detailed review of the TV Electric process for the design of safety-related instrumentation tubing and supports:

First, it was determined that the design of tubing layouts was based on the guidelines of Impell Corporation (formerly EDS Nuclear, Inc.) Report No. 01-0210-1065, " Tubing Support Criteria," Revision 4, March 13, 1987,- and SWEC Calcu]3 tion 16345-EM(B)-041, " Uniform Methods of Analyzing Special Tubing Configurations," Revision 3, June 3, 1988. The Impell report provided guidelines for the layout e.nd placement ce supports for instrument tubing based on simplified conservative methods of analysis which have been incorporated into the standard routing and support placenent configurations in the 2323-I-002 scries drawings. Loadings ceneidered were pressure, weight, seismic, and thermal expansion. Allowable stresses and load

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combinations were in accordance with ASME B&PV Code,

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section III, class 2 and 3 criteria. SWEC Calculation 16345-EM(B)-041 provided a uniform method for analysing tubing l configurations which did not satisfy the conservative l guidelines of the 1mpell repor (During the review, the WRC

inspector found that this method of nualysis was used primarily by SWEC to validate the design of tubing between instrument rcot valves .and the first three dimensional [3D)

restraint downstream of the valves.) Th2 SWEO method pf analysis was based on the applicable section of SWEC-PSAS f Procedure CPPP-7, " Design Criteria for Pipe Stress and Pipe '

Supports," Revision 4, February 10, 1982. Procedure CPPF-7 wac developed as part of the CAP in response to the many l piping and pipe support issues and was based on ASME B&PV Code criteri Specification of the ASME Code for the design of tubing layouts Was found tc be in accordance with requirements of D3D-EE-15, DBDaCS-089, and Specification CPES-I-iD18 and hence acceptabl Second, it was determined that the design of tube supports was based on the criteria in SWEC Calculation 16345-EM(B)-024

" Design Criteria for E'/aluating Instrument Tubing Suppcrts,"

Revision 2, June 15, 1988. The requirements specified in this document include design loads, load combinations, allowable stresses, connection design, seismic accelerations, and tubing clasp design. The SWEC Calculation 16345-EM(B)-034 criteria were utilized in SWEC Calculations 16345-EM(B)-008 through-021, and other calculations to validate the design of the

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standard tubing support configurations shown in the 2323-I-001 series drawings. The design criteria in SWEC Calculation 16345-EM(B)-034 were consistent wit.h the criteria in DBD-EE-15, DBD-CS-089, and Specification CPES-I-1018 and hence acceptable and their utilization in the SWEC support design validation calculations was in accordance with CAP PSR commitment The 2323-I-001 serics drawings have been revised to incorporate design changes including changes necessary to resolve CAP related issues. For example, drawings 2323-I-01-T02, -T03, -TOS, -T06, T09, -T09B, -T11,

-T12,-and -T13 centain specific requirements for bolt materials. Specification of these requirements was part of the preventive action in the resolution of SDAR CP-87-44, i

"Unistrut Tubing Support Bolting," reported by TU Electric on January 29, 1988,.(See Issue No. B2 of Appendix D to the I&C PSR). Additionally, drawings 2323-I-001-T08A, " Single and Double Tube Suppcrts, Type 8," Revision CP-2, November 30, 1988, and 2323-I-001-T08B, " Single and Double. Tube Supports, Type 8," Revision CP-3, December 6, 1988, showed the 3-D tube clamp design developed to resolve SDAR CP-88-21,

" Instrument Tubing Clamp," reported by TU Electric on January 29, 1988, (See Issue No. B10 of Appendix B to the I&C PSR). The issue in the SDAR was that J. C. White 1 3-D tube clamps were functionally inadequate if attached )

directly to concrete or unistrut channels. This construction deficiency is currently under review by the NR Third, a review was conducted to verify the compliance of the designs for instrument tubing and tube supports with the design criteria. The review was based on a sample of design validated loops for the following three instruments:

> X-PI-268B, 1-PI-4762, 1-LS-4795. Results of the review were as follows:

E-PI-268B: The review found that the design of the loop for this instrument was verified during a FVM inspection performed in 1988 except for local damage (kinking) of the tubing, incorrect tagging of the instrument plate and five of the seven supports not being installed in accordance with the 2323-I-001 tubing support series drawings. Results of the inspection were documented in FVM Package X-PI-268B-(IWP)-308, Revision 0, dated February 11, 1988. The package indicated that the loop installed prior to the CAP was acceptable from a strces viewpoint, i.e., the loop routing and support locations were acceptable on the basis of the 2323-I-002 support {

placement series drawings and tha Impell Tubing Support j Criteria Report No. 01-0210-1065. Calculations performed in Section 5 of the package to assess the root valve tubing configuration had concluded that the configuration was

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acceptable.. Additionally, Section 5 of the package had also concluded that: (1) the tubing spans vete in accordance with drawing TNE-I-0069, Revi$ ion CP-1, and thus acceptable; and (2) the layout os dhe tubing from sui > port No. S to support No. 2 was in accordance with the 2323-I-002 cories drawing aild also thus acceptanle.-

Deviations from the tube support installation requirements; specified in Etie 2323-I-001 series drawings wers found during (

the inspection and were documented in Section 8.3 of t.he FVM package. They required the initiation of.nonconformance reports (NCRs) or design chanpa authorizations (DCAsi-for their dispositio {

I The review concluded that the FVM inspection utilizad in evaluating the instrument loop for instrument X-PI-268B wai l acceptable to assure compliance with the applicable design criteri FI-4762: The i'eview found that the design of the lo9p was approved by Design Change Authorization - Confirmation Required (DCA-Ca', No. 23532, Revision 2, dated September 27, 1988. Initially, the loop was inspected during the FVM program and the results dopumented in FVM packs.ge No. 1-PI-4762-IWP-200, Revision 0, dated August 23, 198 The tubing routing and support placement found during the {

inspection, as modified by the support relocati.on per item 3 of the DCA-CR, were eva) Rated in SWEC Calculation 16345-EM(S)-107, Revision 0, dated Octo'a cr 7, 1938, and found to be acceptable. Stress levels in the tubing between the root valve and the first 3-D support downstream of the valve were evaluated on the basis of the SWEC Calculation 16345-EM(B)-041 analysis metho The evaluation indicated that the ASME B&PVC,Section III, Class 2, NC-3600, Equation (10), Sa allowable stress was j exceeded en the basis of the use of the ASME Code stress intensification factor (SIF, 1) value of 2.3 for threaded Swagelok tube fittings (Section 10.A.1.c of the calculation). )

Use of a lower SIF value of 1.5, however, indicated that the l Sa allowable stress was not exceeded (Section 11 of the !

calculation). Use of the lower SIF value was based on SWEC generic Calculation NP(B)-139, Revision 0, September 29, 198 ;

A review of this generic SWEC calculation found that the lower i

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SIF value was developed on the basis of fatigue testing in accordan6e with paragraph NC-3673.2 of the ASME Code and hence acceptable. Stress levels in the remainder of the loop were evaluated on the basis of the 2323-I-002 series drawings and found to be acceptabl I

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Based on the results of SWEC Calculation 16435-EM(S)-101, Revision 9, and the support 1e10 cation and modifications

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defined in Section.7 of DCA-CE No. 23532, Revision 2, the design of the loop was approved subject to implementation of the rework identified. The support modifications specified in the DCA-CR were in accord.snce with the 2323-I-001 tubing support series of drawing .l The review-concluded that DCA-CR 23532, Revision 2, provided an acceptable basis for issaring compliance of the design of tne. instrument loop for instrument No. 1-PI-4762 with the applicah3e design criteri LS-47%i: The review found that the design of the loop for this instrument was approved by a DCA-CR p.rocess similar to that utilized for instrument No. 1-PI-4762. The pre-CAP configuration of the loop was also inspected during the FVM and the results documented in FVM package Nos. 1-LS-4795-IWP-399, Revicion 0, dated August 9,'1988, and supplementary package No. 1-LS-4795-IMP-399 SP1 dated March 3, 1989. These FvM packages indiciced that flexible hose and all four s:Ipports were not in accordance with installation requirements. Subsequently, SWEC Calculation 16345-EM(S)-098, Revisien 0, dated October 2, 1988, verified the acceptability of the tubing routing and support spacing on the basis of the 2323-I-002 support placement series of drawings and Section 7 of DCA-CR No. 77387, Revision 4, dated May 26, 1989, specified modifications to the supports based on the 2323-I-001 tubing support series dra' wings. DCA-CR No. 77387, Revision 4, approved the design subject to implementation of the rework specified therei The review concluded that CA-CR No. 77387, Revision 4, provided an acceptable basis for assuring compliance of the design of the instrument loop for instrument No.1-LS-4795 with applicable design criteri Fourth, walkdowns were conduct 6d to verify compliance of the modified as-built configurations of the instrumentation loops with the modified designs required by the CAP. Walkdowns (in full or in part) were performed of the following five instrumentation loops: 1-FT4619, 1-PI*02468, 1-PI-2486, 1-PI-4762, and X-PI-268B. During the walkdown the tubing instal 3.ation (including routing end support location, location and type of fittings, and damage to and slope of tubing) and support installation (including design details, type, function, walding, and damage) were inspected and found to be in &ccordance with the design and construction requirements as required by the applicable DCA-CRs. One item not inspected was the flexible hose in loop 1-LS-4795. The flexible hose was enclosed in a temporary housing for protection against !

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damage due to traffic through and ongoing construction

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activities in the are Based on the preceding results of revicus and walkdowns, it was concluded that the design and installation of instrumentation tubing and supports was in accordance with TU Electric CAP cominitments. The revi6ws found that:

(1) applicable specifications and criteria documents were modified to_ reflect DBD requirements; (2) instrumentation loops designed and installed prior to the CAP were FVM inspected.during the PCEVP program in accordance with DBD requirements; and (3) loop. designs, modified as necessary by NCRs or DCAs, were validated on tLe basis on calculations or revalidated standard design configuratiofis contained in the

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2323-I-001 and 2323-I-002 series drawings. Additionally, the walkdowns found that instrumentation locps were installed in accordance with their designs. Instrumentation loops designed and installed in accordance with the TU E3ectric CAP program will perform their intended safety functio . Plant Tours (37051, 37055, 48053, 49063, 50073)

The NRC inspectors made frequent tours of Unit l'and common arcas of the facility to observe items such as housekeeping, equipment protection, and in-process werk activities. No violations or deviations were identified and no items of significance were observe . Exit Meeting (3G703)

An exit meeting was c.onducted August 1, 1989, with the applicant's representative identified in paragraph 1 of this report. No written material was provided to the applicant by the inspectors during this reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed hy the inspectors during this inspectio During this meeting, the NRC inspectors summarized the scope and findings of the inspection.

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