ML20009F029

Final Deficiency Rept Re Seismic Instrument Tubing Support, Initially Reported 810604.Engineering Documents Will Be Evaluated & Revised.Completed Installations Will Be Surveyed.Noncompliant Conditions Will Be Reworked

ML20009F029
Person / Time
Site:	Comanche Peak
Issue date:	07/01/1981
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
10CFR-050.55E, 10CFR-50.55E, TXX-3358, NUDOCS 8107280616
Download: ML20009F029 (3)

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Mr. G. L. Madsen, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Dr., Suite 1000 Docket Nos. 50-445 Arlington, Texas 76012 50-446 COMANCHE PEAK STEAM ELECTRIC STATION SEISMIC INSTRUMENT TUBING SUPPORT FILE NO: 10110

Dear Mr. Madsen:

In accordance with 10 CFR 50.55(e), we are submitting the attached report of actions taken tc correct a deficiency regarding inadequate seismic instrument tubing supports. We previously made a verbal report to your Mr. R. G. Taylor on June 4,1981.

Supporting documentation is available at the CPSES site for your Inspector's review.

If we can provide any additional information, please advise, Very truly yours, k-. Gary R.

RJG:kh Attachment cc: NRC Region IV - (0 + 1 copy)

Director, Inspection & Enforcement - (15 copies) c/o Distribution Services Branch, DDC, ADM.

U. S. Nuclear Regulatory Commission Washington, D. C. 20555

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8107280616 810701 PDR ADOCK 05000445 S PDR

r TXX-3358 July 1, 1981 ATTACHMENT SEISMIC INSTRUMENT TUBING SUPPORT DESCRIPTION OF DEFICIENCY Construction activities for Instrumentation and Control (IAC) are controlled at CPSES by packages 2323-I-001 and 2323-I-002, which are issued in accordance with established engineering procedures. The 2323-I-001 package consists of typical supports used to seismically support instrument tubing. The 2323-I-002 package provides guidelines for layout and support of instrument tubing. These packages were developed and implemented by CPPE based upon criteria and load conditions provided by a subtier design vendor - EDS Nuclear Inc. (Report No.

01-0210-1065).

The vendor has stated loads provided by the report were the " maximum expected loads on tube supports.... generated in worst case conditions."

Upon further revia of the criteria, the vendor has advised the criteria wat provided based on an Operational Basis Event (0BE) in lieu of a Safe Shutdown Event (SSE).

Analysis of Safety Implications Original loads, as specified by the vendor when applied to field installation, result in a maximum induced load per tube of 23 lbs.

applied to any support at any location. Revised criteria (0BE to SSE),

in conjunction with revised methodology for load application, increases maximum induced loading to 50 lbs. axial and 35 lbs. lateral. The result is that certain tubing supports for safety-related instrumentation could fail during a SSE.

Corrective Action

( Corrective action for the subject deficiency will consist of evaluation l and revision of engineering documents, a field survey of all completed installations, and disposition and rework of non-compliant conditions.

This evaluation will involve the determination by calculation of maximum induced loads derived from review of " worst case" conditions per the vendor's revised criteria. These calculations will be reviewed by the i vendor. In addition, typical supports will be analyzed to determine

maximum allowable loads. Using this data and revised vendor criteria,

[ packages 2323-I-001 and -002 will be revised to properly reflect SSE load configurations. These actions will be controlled in accordance with established engineering procedures / instructions.

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TXX-3358 ATTACHMENT July 1, 1981 Page The survey will be performed jointly by CPPE and QC personnel using a detailed checklist and will address all completed installations. All nonconforming conditions will be controlled in accordance with established procedures for nonconforming items. The survey will commence upon the completion of criteria revision efforts and indoctrination of personnel. All nonconformances will be dispositioned accordingly.

The anticipated completion date for corrective actions is January 4, 1982.

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