ML20010C570

First Interim Deficiency Rept Re Instrument Process Tubing. Rework Has Been Completed in non-NSSS Scope of Supply.Tubing Installations Have Been Redesigned in NSSS Scope.Final Rept Expected by 811016

ML20010C570
Person / Time
Site:	Grand Gulf
Issue date:	08/12/1981
From:	Mcgaughy J MISSISSIPPI POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
10CFR-050.55E, 10CFR-50.55E, AECM-81-283, NUDOCS 8108200202
Download: ML20010C570 (5)

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MISSISSIPPI POWER & LIGHTTCOMPANY

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EulMdMdidd5 Helping Build Mississippi P. O. B OX 1640, J AC K S O N, M S SIS SIP PI,3 9 2 0 5

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1. 5sfs $rTiTc OIs7d;f* August 12, 19 9 'P)

N7 P hl5 'e Office of Inspection & Enforcement N j ' (I' '

g U. S. Nuclear Regulatory Commission [ .

Region II .

19198] > 7 101 Marietta Etreet, N.W.

Suite 3100 [A.

u.s. ruu o ucutatoer cc - 55ca '1)b At'.anta, Georgia 30303 ) > U Attention: Mr. J. P. O'Reilly, Director !kllTb

SUBJECT:

Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416/417 File 0260/15525/15526 PRD-80/73, Interim Report fl, Instrtment Process Tubing AECM-81/283 References 1) AECM-81/49, 1/29/81

2) AECM-81/144, 4/14/81 On December 30, 1980, Mississippi Power & Light Company notified Mr. J.

Rausch, of your office, of a Potentially Reportable Deficiency (PRD) at the Grand Gulf Nuclear Station (GGNS) construction site. The deficiency concerns discrepant slopes in instrument process tubing.

Our evaluations have shown that this deficiency, had it remained uncor-rected, could have af fected the safety of operations of the nuclear power plant and is reportable under the provisions of 10CFR50.55(e). We are con-tinuing our investigation into the reportability of this deficiency under 10CFR21 and expect to provida our final report by Octeer 16, 1981. Our evaluation of safety implications and corrective actions are summarized in the attached interim report.

Yours truly, As f/"f "

,f J. P. McGaughy, Jr.

KDS:dr ATTACHMENT cc: See page 2 g7

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8108200202 810812 PDR ADOCK 05000416 S PDR Member Middle South Utilities System

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, Mr. 'J. P. O'Reilly. i , AECM-81/283 2

-NRC- Page 2 _

t cc: Mr..N. L.-Stampley

-Mr. R. B. McGehee Mr. T. B. Conner-

'Mr.. Victor Stello, Director-Of fice of Inspection &- Enforcement -

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

, Mr. _G. B. Taylor South Miss. Electric Power Association

-P. O. Box 1589 Hattiesburg, MS'39401 t

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l v ., . i bec: Dr. D. C. Gibbs Mr. J. Letherman Mr. J. N. Ward Manager of BWR-6 Licensing-Mr. J. P. McGaughy, Jr. General Electric Company Mr. W. A. Braun 175 Curtner Avenue Mr. R. Trickovic San Jose, CA. 95125 Mr. J. W. Yelverton Mr. L. F. Dale Mr. C. K. McCoy Mr. D. M. Houston Mr. T. H. Cloninger U. S. Nuclear Regulatory Commission Mr. R. A. Ambrosino Division of Licensing Mr. A. J. Iosue Washington, D. C. 20555 Mr. G. B. Rogers Mr. M. R. Williams Mr. L. E. Ruhland Mr. J. Matore Mr. D. L. Hunt U. S. Nuclear Regulatory Commission -

Mr. A. G. Wagner Division of Licensing Mr. P. A. Taylor Washington, D. C. 20555 PRD File File i

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Attachment to AECM-8'1/283'

-Page 1 of 2 I -

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- INTERIM REPORT NO. 1 FOR PRD-80/73

( I ._ Description-of the Deficiency A randon ' sample of instrument . process - tubing has disclosed a number. of instal- -

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- lations that do not meet the minimum slope requirement of Specification 9645-J-702.0, Re".=16. .Several of the discrepant installations had been accepted'by

-Field Engineering and Quality Control, rendering the quality of all installed _

safety-related tubing indeterminate.

This condition affects the following systems: Nuclear Boiler (B21), Reactor

' Recirculation (B33), Control Rod Drive Hydraulic (C11)', Feed Water Control"

- (C34), Remote Shutdown (C61), Reactor Protection -(C71), Heat' Removal (E12), Low -

Pressure Core Spray.(E21), High Pressure Core Spray (E22), Suppression Pool

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Makeup (E30). Leak Detection (E31), Feed Water (E38), Reactor Core Isolation Cooling (E51), Reactor Water Cleanup (G33), Fuel Pool Cooling and Cleanup (G41), Main and Reheat Steam System (Nil), Standby Service Water -(P41),1and Standby Gas Treatment (T48). It applies to both' Unit 1 and Unit 2.

The cause of:the deficiency stems from design and layout of the-tubing to the minimum requirements of the specification. The specifications for' process tubing installation state that a support be. established on a one inch per foot-slepe. If 'for any reason the support moves (e.g., when drilling a hole or the drill wanders), a nonconformance to 'the slope specification could result.

Other interferences encountered during installation might also require an-offset.- Because = the design and layout of the tubing installation 1-s to.the minimum requirements of the specification, .there is no latitude for problems

- encountered during the installation of the instrument process, tubing.:

The potential exists for the deficiency, as noted, to produce an error in essential instumentation in excess of design limits. - Potentially,-inaccurate instrument reading's/ trips could . adversely affect the safe operation of the plant. Since extensive-evaluation would be. required to establish the adequacy of the components to perform their intended safety function,- this deficiency is reportable under the provisions of 10CFR50.55(e). .

The evaluation has not been completed to determine the reportability of this deficiency under'the provisions of 10CFR21.

11. Approach to Resolution of the Problem The cause of the problem was that the design and layout of the tubing installation was to the'ainimum requirements of the specification. There is no latitude ' for -protless encountered during . the installation of the ' instrument

. process tubing. Acceptance of nonconforming conditions by engineering was caused by improper inspection methods. Quality' Control and Field Engineering misinterpreted the: latitudes' allowed'by the installation' specification J '

702.0.= This affects =all installed safety-related tubing.

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Attachment to AECM-81/283' Page 2~of 2 Specifications J-701.0 -(Non Safety-Related) 'and J-702.0 .(Safety-Related) were-p" -both revised by our Architect / Engineer to clarify slope requirements. -Out Constructor's Instrumentation' Field Engineering _and Quality Control personnel' were given training in the interpretation of-thcEnew slope requirements and requirements for 'the installation and acceptance of tubing.

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Changes fwere made by our' Constructor's Quality Control to QCI-0721T to accept '

deviations from the isometric drawing as allowed per Specification J-702.0 and r ail Quality-Contro personnel have been indoctrinated -to changes in QCI-0721T.

-All previoutly accepted safety-related tubing installations were reinspected. ,

Those that did not comply to the revised specification of J-702.0 were reviewed by our Constructor. They were ~either approved to use as is or were reworked.

Training and indoctrination of personnel, revisions to Specifications J-701.0 and J-702.C, and- changes to QCI-0721T will serve to preclude recurrence of the

( problem.

III. Status of Proposed Resolution All rework has been completed in the non-NSSS scope of supply. In the NSSS scope of supply, the tubing installations have been redesigned. . Rework' will be completed prior.to fuel load.

IV. Reason Why a Final Report Will Be Delayed Mississippi Power and Light has not completed the evaluation of the reportability of this deficiency under the provisions of 10CFR21.

V. Date When Final Report Will Be Submitted -

We expect to submit our final report by October 16, 1981.

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