ML18004A319

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Insp Rept 50-400/86-50 on 860609-13.Violation Noted: Inadequate Corrective Action to Prevent Damage to Instrument Tubing
ML18004A319
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 07/16/1986
From: Conlon T, Gibbons T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18004A317 List:
References
50-400-86-50, NUDOCS 8607290090
Download: ML18004A319 (17)


See also: IR 05000400/1986050

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report No.:

50-400/86-50

Licensee:

Carolina

Power

and Light Company

P. 0.

Box 1551

Raleigh,

NC

27602

Docket No.:

50-400

.

Facility Name:

Harris

1

Inspection

Conducted:

une 9-13,

1986

Inspector:

T. D. Gib ons

Accompanying Personnel:

C.

F rd

Approved by:

T. E.

Con on,

Se

>on Chief,

Engineering

Branch

Division of Reactor Safety

License No.:

CPPR-158

7- fs-KD

Date Signed

ate Signed

SUMMARY

Scope:

This routine,

unannounced

inspection

conducted

in the

areas

of

instrumentation

work and work activities.

Licensee identified items, unresolved

items,

and heating, ventilating and air conditioning systems.

Results:

One violation was identified - Inadequate

corrective action to prevent

damage

to instrument tubing.

86072'F0090

Bb0721

PDR

ADOCK 05000400

8'DR

m

ij

+E.

E

E

IL

t

REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees

  • J. L. Harness,

Assistant Plant General

Manager

  • D. Tibbitts, Supervisor Regulatory

Compliance

  • C. L. McKenzie, Acting Director gA/gC Operations
  • R. W. Prunty, Jr., Harris Plant Engineering

Support

(HPES)

  • N. J. Chiangi, Manager gA/gC
  • K. V. Hate, Principal Engineer

gA

  • J. L. Dority, Startup Supervisor
  • H. L. Williams, Principal

Engineer

HPES

Other Organization

  • R. L. Bryant, Resident

Engineer Construction - Daniels Construction

Company

(DCC)

NRC Resident

Inspector

  • G. Maxwell, Senior Resident

Inspector

  • Attended exit interview

.2.

Exit- Interview-

=

The inspection

scope

and findings were

summarized

on June

13,

1986, with

those

persons

indicated

in paragraph

1 above.

The inspector

described

the

areas

inspected

and

discussed

in detail

the

inspection

findings.

No

dissent'ing

comments

were

received

from the licensee.

The following new

items were identified during this inspection.

a.

Violation, 400/86-50-01,

Inadequate

Corrective Action to Prevent

Damage

to Instrument Tubing, paragraph

5.

b.

Inspector

Followup

Item 400/86-50-02,

Evaluation

of the

Walkdown

Program for Tubing Clearances,

paragraph

5.

The

inspector

examined

several

documents

which were

marked proprietary,

however,

none of the proprietary data

was used in the report.

3.

Licensee Action on Previous

Enforcement Matters

a.

(Closed)

Unresolved

Item 400/86-26-01,

Incorporation

of Instrument

Tubing Separation

Criteria.

The inspector

discussed

this issue with

HPES personnel

and

examined

drawings which show the plan view of all

tubing in

an area.

This plan

view drawing identifies all possible

\\

F

~

1

tubing separation.

The tubing isometric drawings

are

developed

using

the plan view to define the areas

where separation

may be

a problem.

The inspection

procedures

require that the tubing

be installed

by the

isometric

drawings.

These

drawings

contain

the dimensions

to insure

that tubing separation

requirements

are

met.

The inspector

has

no

further questions.

The licensee

has

substantiated

that there

are

no

ITE Type

HE-3-M040

breaker

on site

but

has

identified other

ITE molded

case circuit

breakers

which exhibit the

same

discrepancy

that is identified in

IEN 85-16.

'The site will test all

molded

case circuit breakers

installed.

A total of 411 breakers

have

been identified for testing.

To date,

373 have

been tested of which 12 were found not acceptable

and

have

been replaced.

4.

Unresolved

Items

Unresolved

items were not identified during this inspection.

Instrumentation

Components

and System - Work Observation

(52053)

The

inspector

selected

the

following systems,

process

variables

and

components for examination:

Engineering

Safety Features

Actuation System

(ESFAS)

Variable

Device

b.

(Closed)

Unresolved

Item 400/85-24-03,

Overload Trips Setpoints of ITE

Type HE-3-M040 Molded Case Circuit Breakers

Pressurizer

Pressure

Level Transmitter

Level Transmitter

Pressure

Transmitter

Pressure

Transmitter

Pressure

Transmitter

(Associated

Instrument

1LT-461

1LT-462

1PT-444

1PT-457

1PT-445

Sensing

Lines)

Reactor Protection

System

(RPS)

Variable

Device

Reactor

Coolant

Flow

Flow Transmitter

1FT-424

Flow Transmitter

1FT-425

Flow Transmitter

1FT-426

(Associated

Instrument Sensing

Lines)

l'I

5

I

Safety-Related

Display Instruments

(SRDI)

Variable

Steam Generator

Level

Components

in Storage

Device

Level Transmitter

Level Transmitter

Level Transmitter

Level Transmitter

(Associated

Instrument

Device

1LT-474

1LT-475

1LT-476

1LT-477

Sensing

Lines)

y

Flow Transmitter

2FT-477

(Barton Model 752/2468)

Flow Transmitter

2FT-476

(Barton Model 752/2466)

Pressure

Transmitter

1PT-950s

(Barton Model 752/2661)

The following documents

provided

the

basic

acceptance

criteria for the

inspection:

a.

General

Documents

Carolina

Power

5 Light Company,

Corporate guality Assurance

Department

Procedure,

CQC-11, "Instrumentation

Inspection,"

Revision 7, March 19,

1986.

Carolina

Power

5 Light Company,

Corporate guality Assurance

Department

Procedure,

CgC-12,

"Mechanical

Inspection,"

Revision 16,

March 16,

1986.

Carolina

Power

8 Light Company,

Work Procedure,

WP-304, "Installation

of Safety-Related

and

Seismic

Process

Tubing

and Instrumentation,"

Revision 6.

Carolina

Power

5 Light Company,

Work Procedure,

WP-300,

"Instrument

Work Package

Preparation

and Control," Revision 9.

Carolina

Power

8 Light Company,

Work Procedure,

WP-302, "Installation

of Supports for Safety/Seismic

Related

Instrumentation,"

Revision 17.

Carolina

Power

5 Light Company,

Work Procedure,

WP-305, "Installation

of Tube Track/Impulse

Line/Instrument

Identification Markers/Tags,"

Revision 2.

Carolina

Power

5 Light Company, Technical

Procedure,

TP-54, "Inspection

of Instrumentation,"

Revision 2.

'

1

Carolina

Power 5 Light Company, Technical

Procedure,

TP-67, "Inspection

of

the

Installation

Seismic

Class

1

and

Seismically

Designed

Instrumentation

Support," Revision 0.

b.

System

Documents

ESFAS - (Pressurizer

Pressure)

Ebasco

Drawing - CAR-2165-G-801,

Revision

14

CPLL Drawing - IS/1-RC-245, Revision 8

RPS - (Reactor

Coolant Flow)

Ebasco

Drawing

CPRL Drawing-

CP8L Drawing-

CP8L Drawing-

- CAR-2165-G-800, Revision

13

IS/1-RC-231,

Revision

8

IS/1-RC-232, Revision

5

IS/1-RC-233,

Revision

7

SRDI - (Steam Generator

Level)

Ebasco

Drawing

CP5L Drawing-

CPSL Drawing-

CPKL Drawing-

CPRL Drawing-

- CAR-2165-G-044,

Revision

16

IS/1-FW-286, Revision

7

IS/1-FW-287, Revision

12

IS/1-FW-288, Revision

6

IS/1-FW-289, Revision

6

Each of the

components

listed

was

examined

and

compared

with applicable

quality documentation

to determine

whether receiving inspection activities

had

been controlled

and accomplished

in accordance

with approved

procedures.

The inspector verified that

component attributes

such

as identification,

physical condition,

and associated

quality documentation

were

as specified

by procedural

requirements.

For the

systems

listed

above,

the inspector

verified that Unit 1 components

had

been installed in the plant

and stored

in place pending plant startup.

Additionally, several

components

were

examined

in

warehouse

storage

locations

to determine

whether

the

proper

storage

activities

had

been

accomplished.

The

warehouse

storage

level,

component

identification,

storage

environment,

and

associated

licensee

inspection activities

were

determined

by the inspector

to

be in accordance

with applicable require-

ments.

With regard to the installation of instrumentation

components,

the

inspector verified that the proper procedures

and drawings

had been

used for

installation, that specified materials

were

used,

and that the components

were properly located

and mounted.

Component identification was clear

and

in accordance

with approved

design

documents.

The

examination

of

components

which monitor reactor

coolant

pressure

disclosed

that

several

safety-related

instrument

sensing

lines

routed

between

the reactor

pressure

vessel

and the secondary

shield wall have

been

damaged

by construction activity.

'Damage to the following sensing lines

has

resulted

in

a tube configuration which violates

engineered

slope require-

ments.

C1-R9-1-T31-LP

C1-R8-1-T27-LP

C1-R8-2-T27-HP

C1-R4-4-T27-LP

These violations

were

discussed

with licensee

personnel

who issued

Work

Request

and Authorization

Form 2005 to document

and correct this condition.

The licensee

also

produced

CP&L Nonconformance

Report

(NCR) 85'-2000,

dated

October

9,

1985,

and

a

subsequent

CPSL Corrective Action Report,

dated

November 4,

1985 which document

damage

to instrument lines similar to that

observed

by the inspector.

The documents

specify corrective action which

included repair of the instrument lines involved and issuance

of a letter to

craft

supervisors

and

area

superintendents

providing instruction

on

protection of permanent

plant equipment.

All corrective actions associated

with these

reports

were

completed

by

December

of 1985,

thus

the

damage

observed

by the inspector indicates that the corrective action taken to date

has

not

been

effective

in preventing

damage

to

these

safety-related

instrument lines.

While it is recognized that similar deficiencies

have

been identified by the

licensee,

and that procedures

are in place to identify future deficiencies,

the

frequency,

nature,

and

extent

of instrument

line

damage

observed

indicates

that additional

licensee

attention is required.

The corrective

action

established

by

NCR 85-2000

has

not protected

or prevented

the

recurrence of damage to instrument lines.

This is a violation identified as

400/86-50-01,

Inadequate

Corrective Action to Prevent

Damage to Instrument

Tubing.

The inspector also identified deficiencies with regard to spacing criteria

between

several

safety-related

instrument

sensing

lines

and hot pipe.

The

following instrument

lin'es

were

observed

in direct

contact

with the

reflective insulation of pipe 2CS3-83SN-l.

C1-R9-6- T33-HP

C1-R9-5-T33-LP

C1-R9-8-T34-LP

C1-R9-7-T34-L P

Discussions

with licensee

personnel

disclosed

that

an

ongoing

program of

inspection is being

performed

in accordance

with the requirements

of two

Harris

Plant

Engineering

Manual

of Instruction,

walkdown

procedures.

Regulatory

Guide

1.29, Verification Walkdown,

and

the Interdisciplinary

Clearances

Verification Walkdown procedures

were reviewed

by the inspector

and

found to

be 'thorough

and

comprehensive.

With regard to the specific

deficiencies

observed,

a review of historical

records

indicate that at the

time of the

most

recent

walkdown, reflective

insulation

had

not

been

installed

on pipe

2CS3-83SN-1.

Consequently,

the deficiencies identified

would not have existed.

As construction activity continues,

further walkdowns will be required to

assure

that similar conditions

are identified,

evaluated

and corrected.

This issue is considered

an inspector followup item pending evaluation of

the

walkdown program.

This inspector

followup item will be identified as

400/86-50-02,

Evaluation of the Walkdown Program.

6.

Licensee Identified Items

a ~

b.

(Closed)

Item 400/CDR-85-23

Standby

Diesel

Generator

- Intake

and

Exhaust

Yalve Springs

(10 CFR 50.55(e)).

The final report

was

submitted

on Nay 29, 1986.

The report has

been reviewed

and determined

to

be acceptable.

The inspector

held discussions

with responsible

licensee

representatives

and

reviewed

supporting

documentation

to

verify that the corrective actions identified in the report

have

been

completed.

Transamerica

DeLaval

Incorporated

(TDI) notified the licensee

of

a

potential

problem with valve springs

which were not 'adequately

shot

peened

by the

Belts

Spring

Company.

The

licensee

identified

60

deficient springs

on engine

lA and

an additional five on engine

1B.

The licensee

also identified that the

2A and

2B diesel

engines

have

deficient springs.

The spring replacement for 1A and

1B is documented

on

Work Request

and Authorization

AEYU-1 and AEYT-l. It should

be

noted

that

the

two Unit 2 diesel

engines

in storage still

have

deficient springs.

(Closed)

Item 400/CDR 85-213,

Undetectable

Failures

in

ESFAS

(10 CFR 50.55(e)).

The final report

was submitted

on December

13,

1985.

The

report

has

been

reviewed

and

determined

to

be

acceptable.

The

inspector

held discussions

with responsible

licensee

representatives

and

reviewed

supporting

documentation

to verify tHat the corrective

actions identified in the report

have

been completed.

Westinghouse

identified this concern to the licensee

on Parch

28, 1985.

When

the

reactor trip breaker

is

opened

(Reactor

Tripped)

the

P4

permissive

permits

the operator to block actuation of Safety Injection

and to enter

the recirculation

mode.

The original

procedure

for

testing required

use of 'jumpers

and portable test equipment.

Westinghouse

offered

the

licensee

an

optional

modification which

mounted

a switch

and meter to allow for testing without jumpers

and

portable

test

equipment.

During

an

evaluation

of the

optional

modification, Westinghouse

identified

a possibility of an undetectable

failure could remain.

Westinghouse

issued

a field change notice

(FCN)

C(LM-10650 to correct this

item.

The licensee

incorporated

the

FCN

with the

work, performed

by

Work

Request

and

Authorization

Form

1-1065-NXJ.

The inspection

was documented

on

NCR 85-1251.

(Closed)

Item 400/CDR 85-220,

Standby

Diesel

Generator - Control

Panel

Wiring

(10 CFR 50.55(e)).

The final

report

was

submitted

on

December

11,

1985.

The report

has

been

reviewed

and determined

to be

acceptable.

The inspector

held discussions

with responsible

licensee

representatives

and

reviewed

supporting

documentation

to verify that

the corrective action identified in the report have

been

completed.

TDI has identified that

a vendor

RTE Delta Corporation

(RDC) reported

that

some shielded'ire

insulation

was

cracking.

The

vendor

recommended

replacement

of the

cables.

The

licensee

issued

NCR

84-1940,

Field

Change

Request

(FCR)

E-5521

and

Work

Request

Nos.

85-AAWHI and 85-AAWJI.

The replacement

of the affected

17 cables

per unit was accomplished

and accepted

by gC.

(Closed)

Item 400/CDR 83-130,

Main Reactor Trip Breakers - Undervoltage

Trip Attachment

(UVTA) (10 CFR 50.55(e)).

The final report

was

submitted

on

March 29,

1985.

The report

has

been

reviewed

and

determined

to

be

acceptable.

The inspector

held discussions

with

responsible

licensee

representatives

and

reviewed

supportin'g

documentation

to verify that the corrective (action) identified in the

report have

been completed.

Westinghouse notified the licensee that

a deficiency existed concerning

the retaining ring groove

on

UVTA.

Westinghouse

provided

new UVTA's

which had

a wider groove which will accommodate

the

new retaining ring.

The replacement" of the

UVTA's has

been accomplished

in accordance

with

the approved

design

documents

and work procedures.

The replacement

is

documented

on

WP-137-E-1240

Deficiency

and Disposition

Report

(DDR)

1480,

and

FCR I-973.

Close)

Item 400

CDR 86-226,

480 Volt Switchgear - Breaker

Failure

10 CFR 50.55(e)).

The final report

was submitted

on

June

12

1986.

The report

has

been

reviewed

and

determined

to

be acceptable.

The

inspector

held discussions

with responsible

li'censee representative

and

reviewed supporting

documentation

to verify that the corrective actions

identified in the report have

been completed.

A Brown Bovere

Corporation

(BBC) type

LK-16 circuit breaker failed

during hot functional test.

Investigation

by

BBC identified that there

were two factors which could cause this failure,

a 'design

change to the

blade

pivot point which

added

loading to the contact

opening

and

closing force and improper maintenance

which could cause

a accumulation

of f'iction

on

the

opening

spring

mechanism.

BBC

issued

two

installation bulletins

(IB) 8604,

Lubrication and'ontact

Cleaning

Procedure

for

BBC Type

LK Circuit Breakers

and

IB 8605 LK16, LKB16,

LKDK LK20, and

LKE20 Booster Spring Installation.

IB 8605

recommends

installation of booster

springs

to the existing tripping springs

to

offset the forces

due to the change

in the pivot point.

The booster

springs will restore

the opening force to the original design level

by

adding

56

pounds

of force.

The

change

was

incorporated

under

the

supervision of BBC representatives

and documented

in FCRE-6031.

BBC

1B

l

f,

ti

i

C

II

I

l

1

8604

provides

additional

detailed

maintenance

instructions for the

LK-16 breakers.

The licensee will have the site maintenance

procedures

revised to incorporate

188604 recommendations

by July 15,

1986.

f.

(Closed)

Item 400

CDR 85-214,

Standby Diesel

Generator - Control

Panel

Ventilation

(10 CFR 50.55(e)).

The final report

was

submitted

on

November 15,

1985.

The report

has

been

reviewed

and determined

to be

acceptable.

The inspector

held discussions

with responsible

licensee

representatives

and

reviewed

supporting

documentation

to verify that

the corrective

actions identified in the report

have

been

complete.

Transamerica

DeLaval

Incorporated

(TDI) supplied

these

panels

which

were manufactured

by RTE-Delta Corporation

(RDC).

RDC informed TDI and

the licensee

that the exciter regulator

components

generated

more heat

than could

be dissipated

by natural

convection ventilation which was

provided.

RDC submitted

a design

using four ventilation

fans which

have

been qualified to

IEEE 323 and

had been approved

by Bechtel

Power

Corporation for another

licensee.

The

licensee

and its designer

accepted

the design.

The fans

were installed

under the direction of

RDC representative.

The following

FCRs

were -issued

to

document

installations

N-1729,

E-514TR1,

E-5135

and

I-2269.

The licensee

has

verified that the fans maintained

the

panel

below 120'F during

a

24

hour test of the diesel.

Heating, Ventilation, and Air Conditioning Systems

(50100)

The inspector

reviewed

the

Environmental

gualification

Document

Package

(E(DP) for

a fan motor and solenoid

which is

used with an air operated

actuator.

The

EgDP

number

4.15

Hl was for eight

fan motors built by

Reliance

Motors.

The motors

are

model

TEAO built on

a

449T frame.

The

package

appeared

to be complete

and acceptable.

The inspector

examined

EgDP

42. 1SH1

on

17 Bettes

Pneumatic

Actuators of five varieties.

EgDP 3.2 for

the solenoids

which supply the pneumatic

pressure

to the actuators

was then

examined.

The inspector

examined

the

package

for Asco solenoids

models

NP-8316,

NP-8320,

and

NP-8321.

The

package

appeared

complete

and

acceptable.

Within the areas

examined,

there were

no violations or deviation identified.

e