ML20024F540

Responds to NRC 830711 Ltr Re Violations Noted in IE Insp Rept 50-413/83-12.Corrective Actions:Impulse Lines for Listed Loops Rerouted to Meet Drawing 1CS-A-20.3 Criteria. Weekly Design Engineering/Const Interface Meetings Held

ML20024F540
Person / Time
Site:	Catawba
Issue date:	08/09/1983
From:	Tucker H DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20024F526	List: ML20024F540
References
NUDOCS 8309090462
Download: ML20024F540 (3)

Text

._.( g Dunn Pownn Gowem l'.O.HOX 33180 CitAHLOTTE, N.C. 28242 IIAL 15. TUCKEH tr.exenoxr.

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August 9, 1983  % (70afg(6e

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Mr. James P. O'Reilly, Regional Administrator 3 U. S. Nuclear Regulatory Commission , h,2 Region II o fy 101 Marietta Street, NW, Suite 2900 u)

(y1-Atlanta, Georgia 30303 9y /.

Re: RII:PKV d

50-413/83-12 50-414/83-12

Dear Mr. O'Reilly:

Please find attached a response to Violation No. 413/83-12-01 as identified in the above referenced inspection report. Duke Power Company does not consider any information contained in this inspection report to be proprietary.

Very truly yours.

L. /b ec- -

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Hal B. Tucker RWO/php Attachment cc: NRC Resident Inspector Catawba Nuclear Station Mr. Robert Guild, Esq.

Attorney-at-Law P. O. Box 12097 Charleston, South Carolina 29412 Palmetto Alliance 2135h Devine Street Columbia, South Carolina 29205 8309090462 830831 PDR ADOCK 05000413 PDR Q

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JP0/RWO August 9, 1983 Duke Power Company Catawba Nuclear Station Violation: 10 CFR 50, Appendix B, Criterion V, as implemented by Topical Report Duke 1A, Section 17, paragraph 17.1.5 requires that activities affecting quality be accomplished in accordance with established drawings. Duke Power Company Drawing No. ICS-A-20.3, Rev. 6 requires that functionally redundant safety class instrument lines for nuclear safety related instruments meet the l physical separation criterion of 18-inches minimum. j l

Contrary to the above, an activity affecting quality was not accomplished in accordance with established drawings on April 13, 1983 in that the installed safety class instrument lines for nuclear safety related instrument Loop Nos.

ISM 511 and 1SM514 were found to be separated by several inches rather than by the minimum required 18-inches.

Response

1. The impulse lines for 1SM511 and 1SM514 did not meet the physical separation requirements of 1CS-A-20.3.

2. The failure by Construction to install these impulse lines in accordance with the requirements of ICS-A-20.3 was due to a misunderstanding between Design Engineering and Construction as to the method of notification of separation requirements. The impulseline separation criterimi of 1CS-A-20.3 is given in definition form which requires Construction to make an interpretation in order to implement the requirements. It was Construction's expectation that the specific applicability of the criteria of 1CS-A-20.3 would be specified on the instrument installation details for all loops requiring separation of impulse lines. This was not done as Design Engineering thought an agreement had been reached with Constuction that the criterimaof 1CS-A-20.3 was sufficient in itself.

! 3. Based on further review by Construction, NCI 16667 was issued addressing loops ISM 511 and 1SM514 and the following additional loops which were identified l

as being in violation of 1CS-A-20.3: 1SM508, 1SM509, ISM 511, 1SM512, 1SM514, l 1SM515,1SM517,1SM518, IVA500, IVA502,1KC563,1KC564, INC516, INC517, 1ND504, IND505, INV574, and 1NV607. The impulse lines for these loops will be rerouted as required to meet the criteria of 1CS-A-20.3 in order to resolve this nonconforming item report. As a result of the problems identified above, Design Engineering has conducted a complete review of impulse line separation requirements and has begun origination of drawings CN-1499-M152.00,

.01, .02, .03 and .04 which provide a detailed listing of the specific applicability of 1CS-A-20.3. Also, a revision to 1CS-A-20.3 has been initiated to reference these drawings for applicability of the criteria. Based on the results of this review, loops 1SM510,1SM513,1SM516 and 1SM519 were also identified as violating 1CS-A-20.3. All rework required to resolve these discrepancies will be initiated by Construction upon receipt of the CN-1499-M152 series drawings.

F

. e JP0/RWO

- August 9, 1983

4. The issue of the CN-1499-M152 series drawings and revision to ICS-A-20.3 to address specific separation requirements will assure that all impulse line separation requirements are properly documented and implemented in the field. No interpretation of criteria will be required of Construction.

In order to improve communication between Design Engineering and Construction I&C personnel, a program has been initiated to conduct a weekly Design Engineering /Constuction interface meeting. This program consists of a weekly visit by Design Engineering to the field location to observe installation practices and to discuss any Construction problems or concerns. These meetings should improve communications and prevent the recurrence of problems of this nature.

5. The weekly Design Engineering / Construction interface meetings are already in progress. The CN-1499-M152 series drawings will be issued and subsequent rework and reinspection will be completed by October 1, 1983.

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