ML18019A490

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Insp Rept 50-400/85-39 on 851021-25.Violation Noted:Failure to Close Air Lines & Sensing Lines After Equipment Removal
ML18019A490
Person / Time
Site: Harris 
Issue date: 11/13/1985
From: Conlon T, Hunt M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18019A488 List:
References
50-400-85-39, NUDOCS 8511250158
Download: ML18019A490 (10)


See also: IR 05000400/1985039

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report No.:

50 4-00/85

3-II

Licensee:

Carolina

Power and Light Company

P.

0.

Box 1551

Raleigh,

NC

27602

Docket No.:

50-400

License No.:

CPPR-158

Facility Name:

Harris

~u

Inspection

Conducted:

October 21-25,

1985

Inspector:

M.

. Hunt

Approved by:

T.

E. Conlon,

Sec

on

hie

,

PSS

Engineering

Branch

Division of Reactor Safety

Date Signed

/-] -

A'ate

Signed

SUMMARY

Scope:

This routine,

unannounced

inspection entailed

35 inspector-hours

on site

in

the

areas

of instrumentation

procedures,

instrumentation

installation

(mechanical)

and instrumentation installation (electrical).

Results:

One violation was identified - Failure to close air lines

and sensing

lines after equipment

removal.

One

unresolved

item

was identified -

Review the

causes

of

NCR 85-1665 for

reportability.

Bsi 12

C~ OgOO{)400

5p158 85>~

PDR

ADO

,.

pDR

8

REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees

~R.

L. Bryant, Instrument Engineering Supervisor

N. J. Chiangi,

Manager,

equality Assurance/equality

Control (gA/gC), Harris

Nuclear Plant

(HNP)

~R.

A. Flodman,

Resident

Engineer - Instruments

  • G.

L. Forehand,

Director gA/gC,

HNP

"K. 0. Hate', Principal

gA Engineer

~C.

S. Hinnant,

Manager - Startup

"P.

W. Howard, Senior

Engineer,

Regulatory Compliance

~L. I. Loflin, Manager,

Harris Plant Engineering Support,

HPES

"R.

W. Prunty, Jr., Principal

Engineer,

HPES,

I8C

"R.

A. Somers,

Superintendent,

Construction Inspection

"E.

E. Willett, Discipline Manager - Instruments

"D.

C. Whitehead,

gA Supervisor

Other

licensee

employees

contacted

included

construction

craftsmen,

engineers,

technicians,

operators,

mechanics,

security force

members,

and

office personnel.

Other Organizations

J.

P. Kirk, Project Administrator, Daniels Construction

Company

NRC Resident

Inspectors

"G.

F. Maxwell

"S.

P. Burris

"Attended exit interview

2.

Exit Interview

The inspection

scope

and findings were summarized

on October 25,

1985, with

those

persons

indicated in paragraph

1 above.

The inspector described

the

areas

inspected

and

discussed

in detail

the

inspection

findings.

No

dissenting

comments

were received

from the licensee.

The following items were identified.

Violation 50-400/85-39-01,

Failure to close air lines

and sensing lines

after equipment

removal.

(Para.

6).

Unresolved

item 50-400/85-39-02,

Review the

cause

of

NCR 85-1665 for

repor tability.

(Para

6. )

~

~

3 ~

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

5.

Unresolved

items

are matters

about which more information is required to

determine

whether they are

acceptable

or may involve violation or devia-

tions.

One

new unresolved

item identified during this

inspection

is

discussed

in paragraph

6.

Instrument

Components

and Systems - Procedure

Review (52051)

The

inspector

reviewed

procedures

relating to the receiving,

storage,

installation,

inspection

and calibration of instruments

and

associated

equipment.

a.

Receiving

and storage

procedures

There

are

no special

receiving or storage

procedures

for instruments.

The site receipt inspection

requirements

required

by C(C-6, Receiving

Inspection,

applies

to all equipment received at the site

and

has

been

reviewed

during

numerous

inspections

in the

past.

The storage

of

equipment

is controlled

by Administrative Procedures

No. AP-X111-05,

Material Storage.

This procedure

is applicable to all materials

stored

on site that is covered

by ASME Section III.

b.

Installation

The mechanical

instrumentation

installation 'is controlled by Procedure

No.

WP-300;

Instrument

Work Package

Preparation

and Control.

This

procedure identifies other procedures

that will be required to complete

the instrument installation defined in the

Work Package.

The WP-300

procedure

covers .installation of the following:

Instrument

accessories:

filters,

instrument

valves,

manifolds,

regulations,

solenoid valves etc.

Air lines (branch signal):

pipe and tubing instruments

Instrument

Impulse Lines: capillary, pipe and tubing

Supports for instrument tube track and tubing

Any additional/repair of instruments

The work packages

developed

under this

procedure will contain

the

necessary

forms for documenting tubing and valve material

heat

numbers,

tubin'g bend verification, instrument

and valve installation (requiring

serial

numbers

and

other

unique identifiers)

as

well

as

material

verification including supports.

Various aspects

of mechanical

instru-

mentation installation are covered

by the following work procedures:

Procedure

No. MP-302, Installation of Supports for Safety/Seismic

Related Instrumentation

Procedure

No. MP-304,

Installation

of Safety-Related

Seismic

Process

Tubing and Instrumentation

Procedure

No. MP-305, Installation of Tube Track/Impulse Line/

Instrument Identification Marker/Tags.

Procedure

No. MP-306, Certification/qualification of Tube Bending

Persons/Tube

Bending Tools/ASME Section III (Code Class) Stainless

Steel

Tubing

The inspection of mechanical

instrumentation installation is performed

by the

guidelines

developed

in Procedure

No. TP-54,

Inspection of

Instrumentation.

The documentation

of inspections

of safety-related,

seismic

category

I (I8C

Code

Class

Nl,

N2

8 Sl) instruments,

fire

protection

instruments,

instrument tubing, capillaries,

tube support

brackets

and

clamps

and instrument

tube tracks

are

covered

by this

procedure.

This procedure lists the normal instrumentation

inspection

acceptance

criteria

such

as

sensing

line slope,

support

spacing,

material identification, .etc.

Any special criteria essential

to the

installation

and inspection

acceptance

are listed on the installation

specifications

and drawings.

The documentation

of the inspection of

the installation of local

instrument

panels

is required

by procedure

TP-28, Inspection of Equipment Installation.

The electrical

power

and

signal

cables

used for instrumentation

installations

are

inspected

and

documented

in accordance

with the

normal

electrical

cable

inspection

procedure

TP-38,

Inspection

of

Safety-Related

Fire

Protection/Detection

NonSafety-Related

Cable

Pulling

and

Termination.

All instrumentation

equipment

that is

classified

as electrically operated is inspected

and documented

by the

requirements

of TP-68 Inspection of Electrical

Equipment Installation.

Mithin the areas

examined,

no violations or deviations

were identified.

6.

Instrument

Components

and Systems - Mork Observation

(52053)

The inspector

selected

various safety-related

components

and mechanical/

electrical

interconnecting

equipment for inspection of activities relative

to the performance

of inprocess

and

completed

work to verify conformance

with the applicable

codes

and

standards

required

by the licensee's

SAR

commitments,

procedures

and

NRC requirements.

The following components

were

examined for compliance with the aforementioned

requirements:

PDT-lAF-2180-SB

PI-1CS-152BSW

FT-1S I-943S

FT-1SI-940S

PI-1CS-151

BSW

PI-1CS-153

BSW

LT-1FW-494 IW

LT-1FW-495 IIM

Differential

Pressure

Across

Aux

Feedwater

Pump Turbine Driven

Discharge

Pressure

Charging

Pump

B

Charging

Pump

8 Flow

Charging

Pump

A Flow

Discharge

Pressure

Charging

Pump

A

Discharge

Pressure

Charging

Pump

C

Steam Generator

Level

Steam Generator

Level

FT-1RC-414I; 415II, 416III

Reactor Coolant

Loop 2 Flow

FT-1RC-424I; 425II, 426III

FT-1-RC-434I; 435II, 436III

TE-1RC-412

BIM

TE-1RC-422 BIIM

Reactor Coolant

Loop 3 Flow

Reactor

Coolant

Loops Flow

Tave Temperature

Detector

Tave Temperature

Detector

Receipt inspection

records

of various

items listed were reviewed.

The

records

reviewed indicated that the equipment

was

examined for damage,

proper identification and in certain

instances

nonconforming

records

were

generated

to document

the lack of proper certification records

being available at the time of receipt inspection.

The records also

reflected

the fact that certain

components

had

been

returned

to the

supplier for modification and then returned to the site.

b.

C.

The storage

records for the

equipment listed were not reviewed since

the

equipment is

now installed.

The equipment

was protected

by fire-

proof covers that were installed over the local instrument racks.

In process

inspection of equipment

being installed

was

not examined

during this inspection.

The inspector

examined

the installation of the previous listed equip-

ment for proper location,

proper identification and protection

from

construction activities.

The

sensing

lines,

supports

and manifold

valves

were

examined

for proper installation

including slope

and

support separation.

During the inspection of panel

A-1 R-7 it was

found that additional

tubing

was

connected

to the manifold valves

for FT-1SI-940S

and

FT-1SI-943S.

This tubing

had been connected to some temporary instru-

ments

during testing.

The temporary

instruments

had been

removed

and

the

open

instrument lines

remained

connected

to the manifold valves.

Nearby at air operated

valves

3CC-Ll-SA and 3CC-L2-SB it was found that

the air lines to the solenoid air valves

had been disconnected

and the

instrument air header for these

valves

was also

open

(uncapped)

with

the

open

tube

end in the vertical position.

The inspector

was advised

that

a modification (relocation of the solenoid air valves)

had been

performed.

The

temporary tubing which connected

the instrument air

header

to the valve air cylinder operators

indicates that

some type of

temporary positioning of these

series

mounted valves

had been performed

by

operations/testing

personnel.

CP8 L

maintenance

Procedure

No. MMM-Oll, Section

5.3 states

that "Openings

and pipe ends shall

be

sealed at all times unless

they must be unsealed

to carry out necessary

operations."

The

two noted conditions

appear

to be

a failure to follow Maintenance

Procedure

MMM-011 and is identified

as violation 50-400/85-39-01,

Failure to Close Air Lines and Sensing

Lines After Equipment

Removal.

As-built verification

was

accomplished

by

comparing

the

actual

installation with the isometric

drawings that were part of the work

packages

-for installation of, the selected

components.

Within the work

package

is

a bill of material which identifies all the items required

for the installation.

The instrument details

CAR 2166 contains

the

Bill of Material

(B/M) for all instrument fitting needed.

From the

Drawings

CAR 2166-6-(400

Series)

the location/arrangement

drawings are

detailed.

From these

drawings the isometric drawing is developed

which

shows

supports,

identified welds by number, specifies

slope, etc.

The

installation of thefollowing "components

was verified by the isometric

(ISO) drawings listed:

POT-1AF-2180-SB

FT-1SI-943S

FT-1SI-940S

PT-1CS" 153

BWS

PT-1CS-121

SW

LT-1FW"494 IW

LT-1FW-495 IIW

ISO No.

337

ISO No.

118

ISO No.

119

ISO No.

47

ISO No.

85

ISO No.

294

ISO No.

295

The

inspector

reviewed

installation

records

for the

following

electrical signal/power cables for the listed components:

Cable

No.

11960K- SB

11960L-SB

10454K

10452J

10454B

10454A

10310D

10310H

10993A

SR1

10993B

SR2

~Com onent

4

P DT-1AF-2180-SB

PDT-1AF-2180-SB

FT-1S I-943S

FT-1SI-943S

FT-1SI-940S

FT-1S I-940S

PT-1CS-121SW

PT"1CS"121SW

LT-1FW-494 IW

LT-1FW-495 IIW

The pull cards

and termination records

documenting the installation of

the listed cables

were

reviewed

and found adequate

with the following

exception.

The inspection

attributes

listed in the

documentation

package

had all

been accepted

except the separation verification.

The

separation

criteria for the listed

cables

were

not

met

and

NCR

No. 85-1665

had

been generated

to identify the situation.

Further investigation of these

and other cable

separation

conditions

indicated

that

a sizable

number of cables

had

been

nonconformed

(NCR-85-1665) for separation difficulties.

The licensee

has

chosen to

develop

a list of all cables

(several

hundred) that

do not meet the

separation

criteria at

some point as part of the action for NCR No.

85-1665.

The inspector

questioned

whether the licensee

had

reviewed

the

NCR for reportability under

10 CFR 50.55(e).

The licensee

advised

that they feel that since

the problem is being identified at the

gC

.level the item is not reportable.

Further discussions

were held and

the

licensee

was

advised

that the condition will be identified as

unresolved

item 50-400/85-39-02,

Review the

Causes

of NCR-85-1665 for

Reportability.

This item will be examined in more detail during future

inspections..

v

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