ML20151B549

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Insp Rept 50-425/88-10 on 880222-25.Violations Noted.Major Areas Inspected:Electrical Work Observation & Records for Raceways & Instrumentation Procedure Review & Work Observation for Instrument Calibr
ML20151B549
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 03/30/1988
From: Conlon T, Hunt M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151B541 List:
References
50-425-88-10, NUDOCS 8804080278
Download: ML20151B549 (6)
v • d • e


See also: IR 05000425/1988010

Text

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-0 4 UNITED STATES

j ,' ,j* NUCLEAR REGULATORY COMMISSION

REGION 11

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101 MARIETTA ST, N.W.

% ATLANTA, GEORGIA 30323

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. Report No.: 50-425/88-10

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Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket No.: 50-425 License No.: CPPR-109' .

Facility Name: Vogtle 2

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Inspection Conducted: February 22-25, 1988

Inspector:

M. D. Hunt

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Date Signed

Accompanying Personnel: ' M. Miller .

Approved by: /W y So W

T. E. Conlon, Chi'bf Date' Signed

Plant Systems Section

Division of Reactor Safety

SUMMARY  ;

Scope: This routine, unannounced inspection was in the areas of Electrical

Work Observation and Records for Raceways and Instrumentation Procedure Review i

and Work Observation for Instrument Calibration.

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Results: One violation was identified.

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8804080278 880331

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

  • J. Adams, Lead Instrumentation Engineer, Mechanical Discipline
  • S. Boutwell, Instrumentation and Control Supervisor, Maintenance (Startup)
  • C. Coursey, Maintenance Superintendent (Startup)
  • E. Duke, Assistant Manager, Electrical Discipline
  • M. Duncan, Instrumentation and Controls Supervisor, Nuclear Operations
  • D. M. Fiquette, Manager, Field Construction - Unit 2
  • J.- J. Gilmartin, Staff Engineer Supervisor, Mechanical Discipline
  • L. B. Glenn, Manager, Quality Control
  • E. D. Groover, Quality Assurance Site Manager, Construction
  • H. Handfinger, Plant Startup Manager
  • A. W. Harrelson, Manager Electrical Discipline
  • C, W. Hayes, Quality Assurance Manager - Site
  • R. E. Holland, Electrical Construction Supervisor
  • C, W. Rau, Manager Mechanical Discipline
  • P. D. Rice, Vice President and Project Director

Other licensee employees contacted included construction engineers,

technicians, and office personnel.

NRC Resident Inspector

  • R. Schepens
  • Attended exit interview

2. Exit Interview

The inspection scope and findings were sumarized on February 25, 1988,

with those persons indicated in paragraph 1 above. The inspectors

described the areas inspected and discussed in detail the inspection

findings. No dissenting coments were received from the licensee. The

following new items were identified during this inspection:

VIO-88-10-01, Violation - Failure to issue Field Change Requests (FCR)

for addition of fire protection piping to cable tray

supports.

URI-88-10-02 Unresolved Item (URI) - Review the requirements for the

perfomance and acceptance criteria of instrument loop

checks during construction acceptance tests

The licensee did not identif~ as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.

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3. Licensee Action on Previous Enforcement Matters

.This subject was not addressed in the inspection.

4. -Unresolved Item

An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or

deviation. One unresolved item identified during this inspection is

discussed in Paragraph 6.

1 5. Electrical Components and Systems-Work Observation (51053).

The inspectors selected several raceway supports for examination. The

supports selected were parts of conduit and cable tray systems. The

inspection was conducted to verify that proper materials- had been

specifieo and installed; weld inspections were performed as required,

anchor bolt torque requirements had been verified; the supports met the

specification requirements for spacing; and, the location of the supports

-met the construction drawing requirements.

The QC inspection and acceptance of raceways and supports is performed in

accordance with Procedure E0-T-02, Quality Control Raceway and Inspection

Checklist. This checklist requires, verification that support materials

and bolted assemblies meet the detail drawings as specified; and

verification of welded assemblies for adequate size, length, type and

configuration. Additionally, the Q/C inspector reviews the appropriate

j drawing Field Change Requests (FCR) to verify that all changes from the

original design have been evaluated. Procedure ED-T-02 requires a minimum

of 10% test of bolt torques.

The following conduit runs were examined to verify installation in

accordance with procedures, specifications and drawings:

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2BE8F2RS05D

2BE8F2RL135

2BE445RLO91

2BE445RLO87

2AE445RLO79

i 2AE445RLOS6

The following cable trays supports were examined for various attributes

used by the QC inspectors for acceptance of the installation:

TS160360 TS15437D TS154306

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TS160197 TS154493 TS154285

TS149301 TS154508 TS154311

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TS149347 TS154320 TS154200

TS17566 TS154298 TS17187

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It was noted that fire protection pipe support attachments were mounted on

some of the above lish4 cray supports. In some instances, the cable tray

supports had been inspected, accepted and documented by the electrical QC

inspectors. The inspectors inquired about the method for permitting

additional attachments to be made to the cable tray supports and what

reanalysis was performed that assured that the support loading would

remain within seismic requirements for which it was designed. The

inspectors- were advised that attachments were not made to cable tray

supports -until a seismic reanalysis was made and a FCR issued. The.

inspectors selected eight supports on which additional attachments were

mounted for review of the required documentation. The review of records

for these eight supports revealed that Support Nos. TS-154-370, TS-154-493

and T3-154-508 did not have FCRs for the addition of the fire protection

piping supports. The licensee later determined possible two other cable

tray supports had additional attachments that had not yet been evaluated.

Specification X3AR01, Section E8 states "No pipes, ventilation ducts, or

other non-electrical material or equipment shall be permanently attached

to or supported by the cable trays on the tray support systems, unless

otherwise approved by Engineering." The licensee was advised that the

failure to control the attachment of un-evaluated permanent fire

protection piping supports to the cable tray supports appearc to be a

violation of construction Specification X3AR01-E8 and is identified as

50-425/88-10-01, Failure to Issue FCRs for Addition of Fire Protection

Piping Supports to Cable Tray Supports.

Before the inspectors completed this inspection, the licensee had held

training sessions for the craftsmen instilling the fire protection piping

cn the subject of attachments to cable tray supports and how they are

controlled. The licensee advised the inspectors that the undocumented

attachments would have been found during a finalization walkdown. While

the final walkdown may have identified these supports, it is important to

perform the construction as specified to insure that all specifications

and drawings requirements are met and appropriate inspections performed.

6. Instrument Components and Systems - Procedure Review (52051)

The inspectors reviewed the licensee's program to determine the

requirements and methods used for implementing construction testing

[ calibration] for instrumentation. After the insiallation phase of

construction is completed, the instruments are either released for test or

turned over to the Nuclear Operation Department (N.O. Dept.) for testing.

The N.O. Dept. is responsible for instrumentation calibration during the

initial test program (ITP). The facility's Safety Analysis Report,

Chapter 17.1.6, states the start up manual sets forth the general policies

and procedures for the initial test program and that procedures for plant

operation and maintenance may be used.

The inspectors examined the following procedures in or referenced in

Start-Up Manual [ SUM] relating to the ITP for instrumentation calibration:

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SUM-1 Start-Up Manual Introduction and Control

SUM-3 Preoperational Test Program Organization, Responsibilities,

and Interfaces  ;

SUM-5 Rules for Performing Procedures

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SUM-11 Construction Acceptance Test Program ,

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SUM-12-A Construction Acceptance Test Implementation

Operations Deficiency Reports (ODR)

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SUM-18

SUM-24 Initial Test Program Personnel Certification  ;

j 00201-C Quality Control Inspection Program l

85301-C Work Planning and Hold Point Assignment  !

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4 CAT-E-08 Instrumentation  ;

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These procedures in the SUM define the requirements, administrative  :

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controls, and organizations for conducting Construction Acceptance Tests

(CAT). CAT-E-08, Instrumentation, is the general CAT procedure used for

i implementing instrumentation calibration during the initial test phase.

CAT-E-08, Instrumentation, requires the Miintenance Department (Nuclear .

Operation) will calibrate instrumentation using approved maintenance

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procedures in conjunction with CAT-E-08. These approved maintenance

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procedures are instrument / loop specific and have been developed for .

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instrument, channel, or surveillance calibration requirements when the .

plant is operational (fuel loaded),

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The initial instrument / loop calibration is performed using the specific I

maintenance procedure (s) as required by CAT-E-08. However, in Section t

Check, of CAT-E-08 Step 6.4.1 requires all components to be loop i

6.4, Loop (after initial calibration) to ensure the loop will perform its

checked i

intended function. A note in Step 6.4 specifically states the Channel

< Status Check performed by the Maintenance Procedure (s) does not fulfill ,

requirements of the Loop Check. The requirements for the performance and

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the acceptance criteria of the Loop Check in Section 6.4 of CAT-E-08 nes9s

to be further reviewed to ensure the intended function of the loop is

adequately tested. This loop check situation will be examined further

during subsequent inspections and is identified as Unresolved Item (URI) '

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50-425/88-10-02, Review the Requirements for Performance and Acceptance  :

Criteria of Instrument Loop Checks During Construction Acceptance Testing l

(CAT-E-08).

i Within the areas examined, no violations or deviations were identified.  !

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7. Instrument Components and Systems - Work Observation (52053)

The inspectors observed testing and calibration activities for two safety

related instruments in the containment building. The instruments were the

pressurizer Pressure Transmitter 2PT-457 and the pressurizer Level

Transmitter 2LT-461.

The work package for each _ instrument was examined to determine if the

latest approved drawings and procedures were being used. Each work

pachge was found to be complete containing all the required

documentation. Both packages contained the general Construction

Acceptance Test (CAT) Procedure CAT-E-08, Instrumentation, and the

specific maintenance procedure for the instrument calibration. The two

maintenance procedures, for calibration vere:

24527-2 Pressurizer Pressure Protecticn Channel 3 2PT-457

Analog Channel Operation Test and Calibration

24531-2 Pressurizer Level Protection Channel 3 2LT-461

Analog Channel Operation Test and Calibration

Each of these procedures was reviewed and the inspector verified the

required calibrated measuring and test equipment was being used by the

instrument technicians. However, neither transmitter could be calibrated.

Pressure Transmitter 2PT-457 had the signal wires incorrectly terminated.

This required the technicians to suspend work and initiate an Operation

Deficiency Report (ODR) as required by Procedure SUM ')8, Operations

Deficiency Report (ODR).

The technicians attempting to calibrate Level Transmitter 2LT-461

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suspended work when they experienced set-up problems and were not sure of

the calibration requirements. The QC inspector agreed work should be

stopped until the instrument foreman could be notified and clarify the l

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calibration requirements.

Within the areas examined, no violations or deviations were identified.

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