ML20151W248

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Insp Rept 50-425/88-12 on 880217-0331.Violation Noted.Major Areas Inspected:Preoperational Testing & Readiness Review Module 4, Mechanical Equipment & Piping
ML20151W248
Person / Time
Site: Vogtle Southern Nuclear icon.png
Issue date: 04/22/1988
From: Burger C, Patterson C, Schepens R, Sinkule M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151W233 List:
References
50-425-88-12, NUDOCS 8805030336
Download: ML20151W248 (27)


See also: IR 05000425/1988012

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

,-[- -

n REGION 11

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j 101 MARIETTA STREET. N.W.

W e ATLANTA. GEORGI A 30323

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Report No.: 50-425/88-12

Licensee: Georgia Power Company

P.O. Box 4545

Atlanta, GA- 30302

Docket Nos.: 50-425 Construction Permit No.: CPPR-109

Facility Name: Vogtle Unit 2

Inspection Conducted: February 17, 1988 - March 31, 1988

Inspectors: ba h -

hlS  %

p R. J. Schepens, Senior Resident Inspector Date Signed

@r. _

Ll.f & g g

h C. W. Burger, Resident Inspector Date Signed

@ <, . 4.}u )g g

C. A. Patterson, Project Engineer Date Signed

.

Accompanying Personnel: P. A. Balmain

Approved By: z3, L

M. V'. Sinkule, Section Chief Dite Signed

Division of Reactor Projects

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SUMMARY

Scope: This inspection entailed a routine, unannounced resident inspection

effort in the area of the preoperational testing and a special announced

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resident and region inspection effort in the area of Readiness Review Module 4,

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Mechanical Equipment and Piping.

t Results: One violation was identified in the area of system walkdown (Failure

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to provide adequate instructions to ensure the proper installation of flow

elements and orifices).

P8P 28834 88888 6 il

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

  • P. D. Rice, Vice President, Vogtle Project Director
  • R. H. Pinson, Vice President, Project Construction

G. Bockhold, General Manager

T. V. Greene, Plant Support Manager

  • C. W. Hayes, Vogtle Quality Assurance Manager
  • E. D. Groover, Quality Assurance Site Manager - Construction
  • S. T. Halton, Quality Assurance Support Supervisor

D. M. Fiquett, Project Construction Manager

  • G. A. McCarley, Project Compliance Coordinator
  • C. L. Coursey, Maintenance Superintendent (Startup)
  • H. M. Handfinger, Startup Manager
  • A. W. Harrelson, Electrical Construction Manager
  • R. E. Hollands, Electrical Compliance Supervisor
  • C. W. Rau, Mechanical Construction Manager
  • J. J. Gilmartin, Mechanical Engineer

L. N. Brooks, Civil Construction Manager

  • L. B. Glenn, QC Manager
  • R. W. McManus, Readiness Review Manager Lead Mechanical Engineer
  • R. C. Sommerfield, Readiness Review
  • J. E. Sanders, Assistant. Project Manager
  • W. C. Ramsey, Project Engineering Manager

L. D. Harless, Manager, Quality Concerns

  • P. T. Ciccanessi, Senior Regulatory Specialist
  • M. L. Hobbs, I & C Superintendent

"M. D. Duncan, I & C Supervisor

Other licensee employees contacted included craftsmen, technicians,

supervision, engineers, inspectors, and office personnel.

Other Organizations

C. Marcum, Westinghouse Project Manager

D. L. Kinnsch, Project Engineering - Bechtel

  • T. E. Richardson, Project Engineering Manager - Bechtel

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  • D W. Strohman, Project Quality Assurance Engineer - Bechtel

I *A. J. Ayob, VSAMU, Westinghouse, Supervisor

B. Edwards, Site Manager, PPP

J. Miller, Quality Assurance Manager

"D. D. Smith, Construction Engineer - Oglethorpe Power Company

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  • Attended Exit Interview

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2. Exit Interviews - (30703C)

The inspection scope and findings were summari7ed on March 31, 1988, with

those persons indicated in paragraph I above. The inspector described the

areas inspected and discussed in detail the inspection results. No

dissenting comments were received from the licensee. The licensee did

not identify as proprietary any of the materials provided to or reviewed

by the inspector during this inspection. Region based NRC exit interviews

were attended during the inspection period by a resident inspector. The

following items were identified during this inspection:

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(0 pen) Violation, 50-425/88-12-01 "Failure to Provide Adequate

Instructions to Ensure the Proper Installation of Flow Elements And

Orifices" - Paragraph 5.d.(1)(c).

(0 pen) Inspector Followup Item, 50-424/88-12-02 "Followup Licensee's

Corrective Action Relative To The Identification Of Unit Appli-

cability For Calculations" - Paragraph 5.b.(1).

(0 pen) Inspector Followup Item, 50-425/88-12-03 "Review Revised

Calculation X4C1202V43 Regarding Design Objectives and Conclusions" -

Paragraph 5.b.(1).

(0 pen) Inspector Followup Item, 50-425/88-12-04 "Review Revised

Calculation X4C1202V18 Regarding Case 3C Description" -

Paragraph 5.b.(1).

(0 pen) Inspector Followup Item, 50-425/88-12-05 "Review Revised

Calculation X4C1202500F1 Regarding The Evaluation Of Flow Failure ,

Detection & Ef fect On System Safety Function For Item No's. 85b,

86b, 87b, 8Sb, 89b, & 90b" - Paragraph 5.c.(1),

3. Licensee Action on Previous Enforcement Matters - (92702)

Not inspected.

4 Preoperational Test Program Implementation / Verification - (70302)(71302)

The inspector reviewd the present implementation of the preoperational

test program. Test program attributes inspected included review of

administrative requirements, document control, documentation of major test

events and deviations to procedures, operating practices, instrumentation

calibrations, and correction of problems revealed by testing.

Periodic inspections were conducted of Control Room Operations to assess l

plant condition and conduct of shif t personnel. The inspector observed  ;

that Control Room operations were being conducted in an orderly and

professional manner. Shif t personnel were knowledgeable of plant condi- '

tions, i.e., ongoing testing, systems / equipment in or out of service, and

alarm / annunciator status. In addition, the inspector observed shift

turnovers on various occasions to verify the continuity of plant testing,

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operational problems and other pertinent plant information during the

turnovers. Control Room logs were reviewed and various entries were

discussed with operations personnel.

Periodic facility tours were made to assess equipment and plant condi-

tions, maintenance and preoperational activities in progress. Schedules

for program completion and progress reports were routinely monitored.

Discussions were held with responsible personnel, as they were available,

to determine their knowledge of the preoperational program. The Inspector

reviewed numerous operation deviation reports to determine if requirements

were met in the areas of documentation, action to resolve, justification,

corrective action and approvals. Specific inspections conducted are

listed below:

a. Preoperational Tests

(1) Test Witnessing (70312)

The inspector witnessed selected portions of the following

preoperational test procedures as they were conducted. The

inspection included attendance at briefings held by the test

supervisor to observe the coordination and general knowledge of

the procedure with the test participants. Overall crew

performance was evaluated during testing. A preliminary review

of the test results was compared to the inspector's own

observations. Problems encountered during performance of the

test were verified to be adequately documented, evaluated and

dispositioned on a selected basis.

Procedure NRC Insp. Test Title Activity Observed

No. No.

2-3BG-01,R-0 70433 CVCS Preop Preop Of Charging

Isolation Valve

2HV-8105

2-3BJ-01,R-0 70434 SI Preop Intermediate Head

SI Cold Leg Flow

Balance And Pump

Run Out Verifica-

tion

2-3BJ-03,R-0 70434 SI Preop Accumulator No. 2

Dump L/0

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5. Readiness Review Module 4 Inspection

The following topics are discussed

Introduction

Review of Commitments

Engineering and Design Review

Safety-Related System Piping Insulation Review

Safety-Related Equipment Installation Review

Safety-Related Valve Installation Review

Conclusions

a. Introduction

This inspection report documents Region II inspection activities

relative to the evaluation of Georgia Power Company's (GPC's)

Readiness Review Module 4, Mechanical Equipment and Piping. The

scope of GPC's Module 4 encompassed the design, procurement, and

construction activities regarding safety-related mechanical equipment

and piping systems classified as American Scciety of Mechanical

Engineers Boiler and Pressure Vessel Code,Section III, Class I, 2,

and 3, which are included in Unit 2 piping systems and are not a part

of the nuclear steam supply system.

Readiness review Module 4 is one in a series of modules being

conducted by GPC that provide an evaluation of the design, construc-

tion and preoperation testing of the Vogtle Electric Generating Plant

Unit 2 to assure its operational readiness in accordance with

scheduled plans for obtaining an operating license. Module 4 is

intended to describe the method GPC complied with the project

commitments found in the Final Safety Analysis Report (FSAR) and is

not intended to make further commitments or revise in any way, prior

commitments.

The inspection was conducted to aid in determining whether Module 4

provided an acceptable basis for it's reported conclusion - that

adequate controls exist to ensure the quality of work and the

implementation of FSAR commitments within the scope of mechanical

equipment and piping for Vogtle Electric Generating Plant (VEGP)

Unit 2. The inspection report contains a description of the

inspector's activities and findings.

b. Review of Commitments

This section of the module defines commitments as project obligations y

to regulatory guides, industry standards, branch technical positions,

and other licensing requirements, to the extent defined in the FSAR.

This section also identifies the source of the commitments to be

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restricted to the FSAR and responses to NRC questions associated with

the FSAR. As defined, commitments which were considered by the

licensee to be most appropriately categorized in this module were

tabulated in a commitment matrix identified in section 3.2 of the

module. The licensee identified 248 commitments as being most ,

appropriately categorized in this module. '

This section of the module also defines an implementing document as a  !

working level document, either program control or test procedure,

that fulfills a construction commitment applicable to a specific ,

activity. Implementing documents were identified for each of the 248 .

commitments and this information was tabulated in an implementation

matrix identified in section 3.2 of the module.

The evaluation of this section consisted of reviewing the commitment

and implementation matrices delineated in section 3.2 as discussed

below.

(1) Evaluation of The Commitment and Implementation Matrix

Commitments applicable to the Nuclear Service Cooling Water

(NSCW) system were selected and reviewed to determine that:

1) All project commitments detailed in licensing documents for ,

the NSCW system had been properly identified, 2) Licensing  ;

commitments had been recognized and were addressed in primary

design / construction documents and whether responses to those  ;

commitments have been included in the appropriate working level

documents, and 3) Whether the commitment and implementation

matrices are accurate and demonstrate proper implementation of -

licensing commitments. The following commitments were reviewed ,

for the above noted attributes:

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Ref. FSAR Document / Design /Const.

No Source Subject Feature Implementation

683.00 1.9.2.7,2 Ultimate RG 1.27 DC 1202-A-1.0

Heat Sink

1743.00 3.1.5 PIP'C Sys. 10 CFR 50, DC 2415-2.0

Penetrating APP.J

Cnmt.

4916.00 3.2.2-1 NSCW Sys. NSCW PIP'G DC 1202-3.1E

Design & VLU's

Outside Cnmt.

ASME III CL3

4917.00 3.2.2-1 NSCW Sys. NSCW DC 1202-3.1E

Design PIP's & VLU'S

Ir. side Cnmt.

ASME III CL2

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Ref. FSAR Document / Design /Const.

No Source Subject Feature Implementation

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1778.00 3.8.2.1 Pipe ASME III, X4AQ10-4.1A  :

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Attached CL2

To Cnmt.  !

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Wall Sleeves

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1782.00 3.8.2.7 Testing Of ASME III, X4AQ10-8.2

CL2 Pipe NC-6000

Assemblies

5026.00 3.9.B.1.5.1 Weld Inspt. ASME III X4AZ01-

P3.3.0.A

Accept '77 Edition PPP IX-3-7.0 ,

Criteria Thru Winter PPP IX-18

Addenda '77

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5349.00 3.9.B.3 ASME III CL2 & 3 DC 1017-2,1

1 CL 1,2 & 3 PIPG NC & NO

Components '74 Edition

Thru Summer

'75 Addena

Ref. FSAR Document / Design /Const.

No Source Subject Feature Implementation

4913.00 9.2.1-1 NSCW Sys. Max. Heat X4C1202V18

Design Load During

Accident

Conditions

349.8

Million  ;

BTV/ Hour '

4914.00 9.2.1-1 NSCW Sys. Min. NSCW X4C1202V03

Design From Per

Train During

Accident

Conditions

15,733 GPM

, 384.00 9.2.1-3 NSCW Equip. NSCW Pumps DC 1010-T1

Design ASME III, ,

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Ref. FSAR Document / Design /Const. '

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No Source Subject Feature Implementation

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3525.00 9.2.1.1.1-C NSCW Sys. Seismic DC 1202-3.1E

Safety Cat, 1

Design

Basis

3749.00 9.2.1.1.1-G NSCW Sys. Designed To DC 1202-3.1A

Safety Perform ,

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Basis Function

Following '

L.O.C.A.

Automatically,

Assuming

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Loincident  ;

With a L,0.0.P

4912.00 9.2.1.1.1-H NSCW Sys. NSCW Designe( DC 1202-3.1P ,

Safety To Prevent '

Oesign Boiling

Basis Cnmt. Coolers

During L.O.C.A.

3750.00 9.2.1.1.1-I N S C\,' Sy s . Sys. Pressure DC 1202-3.1H

Safety Greater Than

Design Cnmt. Bldg.

! Basis Max. Design

Pressure i

4915.00 9.2.1.2.B NSCW Sys. NSCW Press. DC 1202-3.1H  !

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Oper. Higher Than X4C1202V15

Fluid In

Cooled

1 Safety-  ;

Related

Component

400.00 9.2.5 UHS RG 1.27 DC 1202-A-1.0 l

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401.00 9.2.5.1 UHS Seismic DC 1202-A-3.1A

Towers & Cat. 1 l

Basin

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Ref. FSAR Document / Design /Const.

No Source Subject Feature Implementhtion

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3755.00 9.2.5.1.1.A UHS Single DC 1202-A-3.1C

3542.00 Safety Failure

Design With

Basis L.0.0.P

418.00 9.2.5.1.1.8 UHS RG 1.27 DC 1202-A-1.0A

Safety

Design i

Basis

3541.00 9.2.5.2.2 UHS Fan Motors DC 1202-A-3.1B

Component Powered by

Description Class 1E

402.00 9.2.5.2.4 UHS BTP ASB 9-2 DC 1202-A-1.0

Performance  ;

403.00 9.2.5.2.4 UHS RG 1.27 DC 1202-A-1.0

Performance

4777.00 9.2.5.2.4 UHS BTP RSB 5-1 DC 1202-A-3.1C '

Performance

ASME III,

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4221.00 NRC QUES. NSCW Sys. DC 1010-T1

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0210.11 Cooling CL3

Water

Supply &

Return

Piping

For Pump

Motor Coolers

During the review of the implementation of the above noted

commitments, the inspectors had the following comments:

COMMITMENT NO. 3750.00 & 4912.00

Commitment No. 3750.00 states that "the NSCW system is to be

' designed such that system pressure is greater than containment

building maximum design pressure." The design implementation

for this commitment is referenced as Leing contained in DC

1202-3.H. However, the inspector could not verify this to be

i the case. Therefore, the following question was raised to the

licensee: What are the first and second order implementation

documeris for the subject commitment?

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The licensee's response was a follows: It has been assumed that

the "Interfacing Heat Transfer Systems" referred to in DC

1202-3.1H included the containment building air coolers, and

that the NSCW system serving them would be designed with a  !

higher pressure than the containment atmosphere. Upon further

investigation, it has been discovered that the "Interfacing Heat

Transfer Systems actually refer to the Component Cooling Water

(CCW) and Auxiliary Component Cooling Water (ACCW) Systems.

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Currently, there is no first order implementation of commitment

3750 in DC 1202. To correct this, design engineering will issue

Design Manual Change Notice No. 1202-6 which will add paragraph

3.1R to address a commitment requirement that the NSCW system

pressure be greater that the maximum calculated containment  !

atmosphere pressure following a LOCA. FSAR Change Notice

No. 559, filed on February 27, 1987, makes the change in

paragraph 9.2.1.1.1-1 from "Maximum Design Pressure" to maximum ,

calculated pressure. This change notice will be reflected in

FSAR Amendment 35. The licensee issued DMCN 1202-6 on March 8,

1988, therefore, this item is considered to be closed.

Regarding the second order implementation, the licensee informed

the inspector that it was contained in two design calculations:

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X4C120?V21, Rev. 2 Verification Of No Boiling In Containment

Coolers and X4C1202V43, Rev. O NSCW Flow Balance. After t

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further discussions with the licensee on this matter, the

4 licensee informed the inspector that calculations X4C1202V21,

X4C1202S19, and X4C1202V09 were originally applicable to both

Units 1 and 2. Due to later developments, it was decided to

recalculate the pressure drops across the restricting orifices

to balance the flows in the Unit 2 NSCW system. Therefore,

calculation X4C1202V43 was prepared to apply to Unit 2 only.

Revision 1 to this calculation was issued on March 2, 1988, and

covers train "B" of the NSCW system. Revision 2 is currently in

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preparation and will cover train "A".  !

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The inspector questioned the method utilized by the licensee for

determining which unit a calculation was applicable to? The

licensee stated that the Calculation Control Log (CCL) was the

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I document for determining unit applicability of a c31culation.

The inspector noted that the current Calculation Control Log

(CCL) reflected that calculations X4C1202V21, X4C1202519, and ,

X4C1202V09 as being applicable to both units. The inspector [

raised the concern relative to correctness of the Calculation <

Control Log. Also, the inspector questioned the appropriateness [

of using this method of documenting unit applicability versus  ;

specifying the unit applicability in the calculation so as to <

provide a positive reans for documenting engineering review and (

sign off of the calculation for Unit II applicability. -

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The licensee confirmed that when calculation X41202V43 was  :

issued for Unit II, the common calculations (X4C1202V21,

X41202519, and X4C1202V09) were not changed to Unit 1 on the CCL

and remained as common. Furthermore, the licensee conducted a

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review of all mechanical calculations to determine the extent of

the problem. This inspection revealed 4 additional calculations

with incorrect designators. Therefore, a total of seven out of r

eleven-hundred-forty six mechanical calculations had the

incorrect unit designator on the CCL. Based on the above

finding, the licensee has committed to re-review all calcula-  :

tions and insert a cover sheet which will specify the applicable '

unit designator and will be initialed and dated by the respon-  ;

sible engineer and engineering group supervisor. The inspector

, inforn:ed the licensee that, pending the completion of the above

noted corrective action this matter will be identified as

Inspector Follow Item 50-425/88-12-02 "Followup Licensee's

Corrective Action Relative To The Identification Of Unit

Applicability For Calculations."

Calculation X4C1202V43 was identified by the licensee as the

working level document for implementing commitment numbers

3750.00, "NSCW system shall be designed such that system ,

pressure is greater that containment building maximum calculated

pressure" and 4912.00 "NSCW system shall be designed to prevent

boiling in containment coolers during LOCA conditions". The

inspector reviewed the calculation and determined that the

design did incorporate the subject commitments. However, ths

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objective section of the calculation did not reflect these

commitments as objectives therefore the calculation did not  !

contain any conclusions relative te these design objectives. ,

The licensee committed to include these commitments as  !

objectives and state conclusions relative to these design

objectives when Revision 2 of the subject calculation is issued.

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The inspector informed the licensee that, pending the issuance

i of the revised calculation, this matter will be identified as

Inspector Followup Item 50 425/8S-12-03 "Review Revised '

Calculation X4C1202V43 Regarding Design Objectives And

Conclusions." .

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During the review of FSAR sections 2.4.11, 9.2.1, and 9.2.5 the

inspector questioned why was the following sentence in FSAR

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9. 2.1.1.1-J not considered a licensing commitment? "The NSCW

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System Is Designed To Minimize The Ef fects Of Water Hammer

Fo rc e s" .

The licensee's response was as follows: This sentence was

apparently taken in context with the seventh paragraph of FSAR  :

9.2.1.2.3 on page 9.2.1-4 in which the features of the NSCW

4 system that minimize the effects of water hammer are described.

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In as much as'these features appeared to implement the apparent

commitment in paragraph 9.2.1.1.1-J, it was interpreted as a

descriptive- statement when taken together with paragraph

9.2.1.2.3, and thus was . not considered a ' licensing commitment.

The inspector considers the licensee's response to be a.cceptable

and thus has no further questions'on this matter.

. COMMITMENT NO. 4913.00

Calculation X4C1202V18 NSCW/C0PATTA 11 Input Data /LOCA 1-Train"

was reviewed to determine the adequacy of the implementation of

FSAR commitment for a' maximum total NSCW heat. load of 349.8

million BTV/HR during accident conditions given in FSAR table

9.2.1-1. This commitment.was tracked by GPC asl readiness review

commitment Reference no. 4913.00. Results of all cases. studied

in this calculation to determine total' NSCW heat load were

higher than the values given in FSAR Table 9.2.1-1. GPC has

initiated FSAR Change Notice 559 to update the table.and will

include the revised heat load values in FSAR Amendment 35. The

inspector also noted that the description of one of the cases-

(case 3C) dealing with fouling factors in heat exchanger tubes

was misleading. The licensee committed to correct this

discrepancy in the next revision ~ of the calculation. The

inspector informed the licensee that, pending the issuance of

the revised calculation, this. matter will be identified as

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Inspector Followup Item 50-425/88-12-04 "Review Revised

Calculation X4C1202V18 Regarding Case 3c Description."

COMMITMENT NO. 4914.00

NSCW calculation X4C1202V03 "Verification Of NSCW Constant Heat

Loads And Flows" was reviewed to determine the adequacy of the

implementation of FSAR commitment- for a minimum NSCW flow of

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15,733 GPM per train during accident conditions given in Table

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9.2.1-1. This commitment was tracked by readiness review

commitment reference no. 4914.00.

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This calculation was performed to compile the latest available

constant heat load and maximum required cooling water flow rate

for all equipment cooled by the NSCW system, as well as the

component pressure drops.

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The inspector reviewed the calculation and noted that the data

used was based upon the latest vendor data as of February 27,

1985, In particular, the number for the heat load per train of

. the standby diesel generator coolers was different than the

number in the FSAR Table 9.2.1-1. The vendor number was

17.1 x 10 to the 6 BTV/HR. Since the FSAR had not been updated,

the inspector qtestioned what was being used as the design basis

of the plant.

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The licensee provided a copy' of a FSAR Change Notice No. 631,

which identified in January 1988, that the FSAR update was

needed. A meeting was conducted on March 9, 1988 with the

cognizant personnel concerning calculation reviews, FSAR

. changes, and licensing personnel to discuss this item. The

licensee provided project instructions which required calcula-

tions be reviewed for possible FSAR changes. This resolved the

programmatic. concern of updating the FSAR. The ' licensee

provided a copy of a temporary exemption request from 10 CFR

50.71(e), FSAR annual update, dated January 15, 1988, to the

inspector. The licensee is required to update the original FSAR

within 24 months of the date of the issuance of the operating

licensee. Unit 1 received its low power operating licensee on

January 16, 1987, and the updated FSAR is due January 16, 1989.

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The exemption would defer the submittal of the updated FSAR for

units one and two until 12 months after the licensee for unit

two expected in February 1989. The particular concern of the

standby diesel generator coolers heat load would be incorporated

in the update as requested by the exemption.

(2) Evaluation of Commitment Additions / Changes From Unit 1 To Unit 2

The Commitment matrix identified 13 commitments as changes from

those presented in the Unit 1 Module. Of these, seven were not

included in the Unit report, but were subsequently added by an

FSAR amendment and the remaining six were subsequently changed

by various FSAR amendments. The inspectors conducted a review

of the added commitments to verify proper implementation by a

working level document and the commitments which were revised

were reviewed to evaluate the significance of the change.

The inspectors reviewed the following commitments which were not

included in the Unit I report, but were subsequently added by

FSAR amendments as noted below:

Ref. FSAR FSAR Design /Const.

No Source Subject Amend Implementation

5107 3.6.2.1.1.B.4 No Welded 30 DC 1018-3.3.B.3

! Attach. d.1.a.

Within 5

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Pipe Dias.

Of Highest

Stress

location On

MS & tiFW

Systems

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Ref. FSAR FSAR Des'ign/Const.

No Source Subject Amend . Implementation

{ cont'd)

5108 3.6.2.1.'1.B.4 No Welded 30 DC 1018-3.3.B.3

Attach. d.1.b

Within 3X

.SQ.RT. Of

- Highest

Stress

Location On

High Energy

Sys. Other

Than MS & MFW

5026 3.9.1.5.1 Weld Inspt. 20 X4AZ01-P.3.0.A

Criteria PPP IX-3.7.0

ASME Code PPP IX-18

5027 3.9.B.S.1 Weld Irispt. 20 X4AZOI-P4.3.0.A

Criteria PPP IX-15-14

B31.1 Code PPP IX-18

5346 3.9.B.3 ASME III, 34 DC 1017-2.1

CL I PIP'G

Design Per

Sub NB '77

Edition Thru

Summer '79

Addenda

5349 3.9.B.3 ASME III, 34 DC 1017-2.1

CL II & III

PIP'G Design

Per Sub.

l NC & NO '74

'

Edition Thru

! Summer '75

l Addenda

5091 3.11.B.1 BTP MSB 3-1 25 DC 1018 - 3.3.B.6

L Designed To

Break

Exclusion

Criteria MS

i

PIP'G Thru

Cnmt.

l

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14

The i nspectors reviewed the following commitments which were

included in-the Unit I report, but were subsequently changed by

various FSAR amendments as noted below:

Ref. FSAR FSAR Design /Const.

No. Source Subject Amend Implementation

711 1.9.82.2 Sumps. For 19 - Adequacy Of CS Pump

Emerg. Core Available NPSH

Cooling & Recalculated To

CS Systems To Address

Additional Factors

2295 3.F.4.4 Propagation 16 Design Basis Pipe

Of Flood Failure Mode Change

Waters From From A Critical

Break In 96" Crack To A Full

CW PIP'G Into Circumference Break

Safety-Related In The 96" CW PIP'G -

Structures

Precluded By

Design ,

2816 6.3.2.2.9 RWST Designed 17 Stipulated A Recir

To Seismic Htr, Is Provided

Category 1 & To Maintain Min.

Htr. Provided Wtr. Temp.

To Maintain

Min. Wtr

Temp. Of 50%

4923 9.2.2.3.A Peak Load On 20 Peak Load On CCW

CCW Sys. Sys. And Time For

1-Train Oper. Achieving Cold

Is 189 x 10 To Shutdown Was

The 6 BTV/ Hour Revised Upward

Cold Shutdown

Achieved In

34 Hours

3535 9.3.3.4.A Testing Of 19 Pressurized

Pressurized Portions Defined

Portions Of As Pump Suction

Waste And Discharge

Collection PIP'G

Systems

Hydroed To

1 1/2 Times

DP

r

F

4-, - ,.--- , , ,e-------.v- -n.,-~. 9g

-

x- -,,yn,u ,-,,---en,, ----,,e.n---c-- -m- --y-,- , - - , , .---------en .n-ng-,

--

-

. .,

-

. .

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,

Ref. FSAR FSAR Design /Const.

No- Source Subject Amend Implementation

{ cont'd)

3834- 9.3.3.4.A Non Pressured 19 Non-Pressurized

Portions Of Portions Chg'd To

' Waste Equip. &~ Floor

Collection Drn's In Aux.

Hydroed At Bldg., Control

Atm. Press. F.H, Radwaste

Solidification,

ARB, RW Transfer,

And RW Tunnel

Transfer

c. Engineering and Design Review

(1) Calculation Review

A representative sample of NSCW system calculations were

reviewed to determine that objectives, assumptions, numbers and

conclusions in the calculation were valid. The following

calculations were reviewed:

Calc. No,/Rev Subject

X4C1202S00F1, Rev. 1 Failure Modes and Effect Analysis -

NSCW

X4C1202V03, Rev. 1 Verification Of NSCW Constant Heat

Loads and Flows

X4C1202V14, Rev. 1 Ultimate Heat Sink Weather Screening

X4C1202V15, Rev. 1 NSCW - ACCW - CCW Pressure Differential

Verification

X4C1202V18, Rev. 3 NSCW/COPATTA - II Input Data /LOCA - 1

Train

X4C1202V43, Rev. 1 NSCW Train "B" Flow Balance

During the review of calculation No. X4C1202500F1 (Failure Modes

And Effect Analysis For The NSCW System) the inspector

questioned the correctness of the conclusion reached in the

calculation for the method of failure detection and failure

effect on system safety function capability evaluation for

failure mode item 85b. (NSCW pump P4-001 discharge bypass line

.

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.

16

check valve). Item Nos. 86b, 87b, 88b, 89b, and 90b are also

effected. The calculation presently states that if the train

"A" bypass line check valve failed open with train "B" in

service that this would be indicated by flow indicators and a

low header pressure alarm in the control room. This would

result in the starting of the train B standby pump.

The licensee reviewed the inspector's comment and concurred that

the lower flow conditions would not be detected by the flow

indicators in the control room since the indicators are in

500 GPM increments and the amount of flow bypassed would be

approximately 200 GPM. In addition, this reduction of flow

would not be sufficient to cause the starting of the train "B"

standby pump. .However, this condition would be detectable in

the control room by the high flow alarm annunciator off of FSH

11776 on the train "A" inter tie line. The licensee committed

to revise the calculation to reflect the correct method of

failure detection and failure effect on system safety function

l

capability for items 85b, 86b, 87b, 88b, 89b, 90b. The

'

inspector informed the licensee that, pending issuance of the

i revised calculation, this matter will be identified as Inspector

Followup Item 50-425/88-12-05 "Review Revised Calculation

X4C1202S00F1 Regarding The Evaluation Of Flow Failure Detection

& Effect On System Safety Function For Items No's. 85b, 86b,

87b, 88b, 89b, & 90b."

(2) Review Of Code / Seismic Interfaces

A representative sample of Nuclear Safety-Related Systems were

selected and reviewed for ASME code and seismic category

interfaces. The purpose of this inspection was to verify that

the systems were designed to meet seismic category I require-

ments to ensure no loss of function during a safe shutdown

earthquake. The inspector reviewed the following system design

bases and P and ids to determine that appropriate ASME code and

seismic interfaces were invoked.

Document No. Title

DC-1203-6 CCW System Design Bases

2X4DB136,R-13 CCW System P & ID

2X4DB137,R-14 Trains A & B

DC-1202-5 WSCW System Design Bases

2X4DB133-1,R-21 NSCW System P & ID

2X40B134,R-18 Train A

2X4DB135,1,R-18

I

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17.

Document No. Title

(cont'd)

DC-1302-5 AFW System Design Basis

2X408161-1,R-19 AFW System P & ID

2X4DB161-2,R-18 Trains A & B

As a result of the above inspection, the inspectors raised the

following comments:

NSCW SYSTEM REVIEW

NSCW drain valve 2-1202-U4-129 off of the RHR pump motor. cooler

shown on P and ID 2X4DB134 reflects incorrect code / seismic

break. The inspector confirmed that isometric drawing 2K3-

1202-155-01- which reflects the as-installed condition s

correct. The licensee informed the inspector that this item was

a result of.a drafting error during incorporation of a DCN on to

the P and 10. Isometric /P and ID reconciliation discovered this

drain missing from the P and ID and a DCN was issued against

2X4DB134 on December 22, 1986. When it was incorporated in

April 1987 a draf ting error was made switching the code / seismic

break exactly opposite of the isometric drawing. The licensee

considers this to be an isolated case, and to ensure that this

is the case, the licensee - conducted a review of ten safety

related P and ids relative to the incorporation of 200 DCNs/

FERs No additional incorporation errors were identified during

this review. The licensee issued DCN No. 57 to P and ID

2X408134 to correct the identified discrepancy on March 28,

4

1988. The inspector finds the licensee's response to be

acceptable, therefore this item is considered to be closed.

Also, during the above inspection, the inspector noted that P

and ids in general don't reflect code / seismic breaks location

for all vent, drain, and test connection piping. The licensee

acknowledged this and issued DCN No.12 to P and 10 2X408101

which added a note to specify code / seismic locations for the

type of corrections noted above. The inspector finds this

action taken by the licensee to be acceptable, therefore, this

item is considered to be closed.

d. Safety - Related System Piping Installation Review

(1) System Walkdown Inspection

i Selected portions of the Nuclear Service Cooling Water (NSCW)

System Containment Spray (CS) System and High Head Safety

l

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18

Injection System, were walked down. The constructed piping

systems were compared to the piping and instrumentation diagrams

and the fabrication isometric drawings. Examples of items

checked were piping configuration, pipe class, weld location,

valve location and appearance, orientation, labeling, piping

support location, and engagement of threaded fasteners.

(a) NSCW System Walkdown

Train "A" of the NSCW piping system was walked down in the

NSCW tower and pump house, connecting tunnel to the

auxiliary building, auxiliary building, connecting tunnel

to the diesel generating building, diesel generator

building, and east of the U-II construction barrier on

level 3 of the control building. The inspectors conducted

the walkdown inspection with the piping and instrumentation

diagram and fabrication isometric drawings to verify that

the system was constructed as shown on the current approved

revision and in accordance with the piping and instrumen-

tation construction specification X4AZ01. The piping runs

inspected were designed and constructed to ASME boiler and

pressure vessel code (B and PVC),Section III Class III and

seismic Category 1 requirements. The following drawings

were used in the walkdown.

P&ID/ ISO /Rev. Title

2X4DB133-1,R-21 P&ID NSCW System - Train "A"

2X4DB134,R-18 P&ID NSCW System - Train "A"

2X408135-1,R-18 P&ID NSCW System - Train "A"

2K5-1202-023-01,R-7 FAB. ISO - NSCW Supply Header

2K5-1202-031-01,R-7 FAB. ISO - NSCW Supply Header

2K5-1202-033-01,R-7 FAB. ISO - NSCW Supply Header

2K5-1202-004-02,R-8 FAB. ISO - NSCW Supply Header

2K5-1202-004-01,R-6 FAB. ISO - NSCW Supply Header

2K3-1202-004-05,R-4 FAB. ISO - NSCW Supply Header

2K3-1202-037-01,R-7 FAB. ISO - NSCW Supply Header

2K3-1202-181-02,R-5 FAB. ISO - NSCW Supply Header

2K3-1202-408-01,R-4 FAB. ISO - NSCW Supply Header

2K5-1202-181-012,R-6 FAB. ISO - NSCW Return Header

2K5-1202-037-01,R-5 FAB. 150 - NSCW Supply To DG 1-A

2K5-1202-037-02,R-6 FAB. ISO - NSCW Supply To DG 1-A

2K5-1202-037-03,R-3 FAB. ISO - NSCW Supply To DG 1-A

2K5-1202-035-03,R-3 FAB. ISO - NSCW Return From DG 1-A

2K5-1202-035-01,R-5 FAB. 150 - NSCW Return From OG 1-A

2K2-1202-104-02,R-9 FAB. ISO - NSCW To ESF Chiller

2K2-1202-104-03,R-11 FAB. ISO - NSCW To ESF Chiller

2K2-1202-134-03,R-13 FAB. 150 - NSCW From ESF Chiller

2K2-1202-134-02,R-6 FAB. ISO - NSCW From ESF Chiller

b

. .

, .

.

.19

In general for. the items reviewed, the piping was found

installed in accordance with the drawings. One question

was raised for a support location on drawing 2K5-1202-

033-01. The drawing showed a support .at N0DE NO. 241 -

location between the discharge of the NSCW pump and the

pump house wall. However, the support was actually located

outside the pump house on the other side of the pump house

wall. The licensee stated that the node points on the

isometric drawing do not reflect the support location but

rather the pipe support drawings which are referenced show

the as-installed location. The licensee confirmed that

pipe support drawing (V2-1202-023-H004) which was

referenced for node point 241 reflected the as-installed

condition of the hanger. Therefore, this question was

resolved.

(b) Containment Spray System Walkdown

Train "B" of the Containment Spray System was walked down

in the auxiliary building, fuel handling building, and

containment building. The inspectors conducted the

walkdown inspection with the piping and instrumentation

diagram and the fabrication isometric drawings to verify

that the system was constructed as shown on the current

approved revision and in accordance with the piping and

instrumentation construction specification X4AZ01. The

piping runs inspected were designed and constructed to ASME

B and PVC,Section III Class II requirements. The

following drawings were used in the walkdown.

P&ID/ ISO /Rev. Title

2X4DB131,R-14 P&ID CS System - Train "B"

2K3-1206-019-01,R-6 FAB. ISO. - Spray Additive TK Piping

2K3-1206-019-03,R-7 FAB. 150 - Spray Additive TK Piping

2K3-1206-037-01,R-4 FAB. 150 - Spray Additive TK Piping

2K3-1206-048-01,R-8 FAB. ISO - Spray Additive TK Piping

2K3-1206-002-01,R-14 FAB. ISO - CS Suction Piping r

'

2K7-1206-002-01,R-11 FAB. ISO - CS Suction Piping

2K3-1206-002-02,R-5 FAB. ISO - CS Suction Piping

2K3-1206-002-02,R-10 FAB.150 - CS Suction Piping

2K3-1206-006-02,R-10 FAB. ISO - CS Discharge Piping

2K3-1206-006-03,R-5 FAB. ISO - CS Discharge Piping

2K3-1206-006-04,R-5 FAB. ISO - CS Discharge Piping

2K7-1206-006-01,R-5 FAB. ISO - CS Discharge Piping

2K4-1206-008-10,R-4 FAB. ISO - CS Discharge Piping

The piping system was found installed per the applicable

drawings for those items checked.

,

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20

.

(c) High Head Safety Injection System Walkdown

This inspection consisted of a .walkdown on the train "A"

centrifugal charging suction piping from the RWST and the

discharge piping thru the SI discharge valves and-into the

four reactor coolant loops. The inspectors conducted _the

walkdown inspection with the piping and ir.strumentation

diagram to verify that the system was constructed as shown

on the current, approved revision and in accordance with

the piping and instrumentation. construction specification

X4AZ01. The piping runs inspected were designed and

constructed to ASME B & PVC,Section III Class I and II and

seismic category 1 requirements. The following drawings

were used in the walkdown.

P&ID/ ISO /Rev. Title

2X4DB116-2,R-15 Chemical & Volume Control System

DCN 35 & FCR MFCRB-8751F

2X4DB119,R-15 Safety Injection System

2X4DB121,R-17 Safety Injection System

DCN 79, FCR's

17,860,MFCRB

17,741

During the walkdown, the inspector noted that P and 10

2X4DB119 did not reflect the correct installation of the

vent valves on the loop 4 cold leg injection line. The P

and ids reflected that the vent valves were installed

inside the shield wall. However, the actual installation

as shown on isometric drawing 2K4-1204-077-02,R-4, was

outside the shield wall. The licensee has reconciled the P

and ID to reflect the correct installation in accordance

with the isometric drawing by issuing DCN 29 to P and ID

2X408111 and DCN 34 to P and ID 2X4DB119. The inspector

considers this item to be satisfactory resolved.

.

In addition to the above noted discrepancy, the inspector

identified that flow elements (FE's) - 0924,0926, and 0927

were installed backwards. . These flow elements are located

downstream of the SI discharge valves in the SI injection

lines to the reactor coolant system cold legs for loops 1,

3, and 4 respectfully.

Several meetings were held with the licensee to discuss the

above NRC finding as well as an NRC concern about the

possibility for the performance of a preoperational flow

t

, . . _ . .

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21

balance test with FEs/ fos installed backwards since there

is no prerequisite in .preops for test supervisors to

check / verify the proper installation of FEs and F0s.

As a result of the above finding, the -licensee took

appropriate corrective action consisting of but not limited

to the following: 1) A walkdown of all FEs/F0s was

conducted which identified an additional 17 installed

backwards out of a total of 248. 2) PCN #7 was issued to

Pullman Power Products procedure IX-5 to specify installa-

tion instructions and to require QC verification of orifice

plate orientation in relation to flow. 3) Training was -

conducted of craft personnel .on how to install FE's/F0's.

4) FE/F0 installations will be limited to trained flush /

hydro personnel and 5) Test supervisors are required to-

verify FE/F0 orientation and document it in the test log

prior to the performance of a test.

The foregoing in considered to be in violation of 10 CFR

Part 50, Appendix B, Criteria V and will be identified as

Violation 50-425/88-12-01 "Failure To Provide Adequate

Instructions To Ensure The Proper Installation Of Flow

Elements And Orifices."

.

It should be noted that this item was not inspected by the

Readiness Review Staff during the performance of Module

No. 4 since it was scoped to be inspected in Module No. 20

Instrumentation and Controls.

The reason being that at the time of performance of Module .

'

No. 4 flow elements and/or orifices were not installed.

Therefore, it would not have been expected for the

> Readiness Review Staff to have identified this item during

the performance of Module No. 4.

(2) Review Of Documentation For Piping Installation

(a) NSCW Supply And Return Header Piping To Diesel Generator

(DG-1A)

An inspection was conducted of the train "A" NSCW supply

and return header piping to DG-1A piping fabrication sheets

to verify the following attributes: Proper material type

and certification per piping classification, properly

documented code data report for NPP-1 for fabricated

nuclear piping subassemblies, proper weld history documen-

tation, and proper non destructive examination (liquid

penetrant) Documentation for ASME III, Class 3 piping.

Piping fabrication sheets were reviewed for the following

spool numbers.

. . _ _ ____.

__ __ - _ _ . . _ _.. _ _,_ _ _ _ _ _ _ _

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Spool No. Fab. Sht. No. ~ Description

2-1202-035-S-01 4107 10" Return Header Pipe

Assembly

2-1202-035-S-02 4201 10" Return Header Pipe

Assembly

2-1202-035-S-03 4202 10" Return Header Pipe

Assembly

2-1202-035-S-04 4108 10" Return Header Pipe

Assembly

2-1202-035-S-05 4109 10" Return Header Pipe

Assembly

2-1202-035-S-06 4110 10" Return Header Pipe

Assembly

2-1202-037-S-01 4114 10" Supply Header Pipe '

Assembly

'

2-1202-037-S-02 4115 10" Supply Header Pipe

Assembly

2-1202-037-5-03 4116 10" Supply Header Pipe

Assembly -

2-1202-037-S-04 4205 10" Supply Header Pipe

Assembly

2-1202-037-S-05 4117 10" Supply Header Pipe

Assembly

2-1202-037-S-06 4118 10" Supply Header Pipe ,

Assembly

'

2-1202-037-S-07 4119 10" Supply Header Pipe

Assembly

(b) NSCW Tower Header and Distributing Piping

Documentation relating to selected portions of the NSCW

tower distribution piping supplied by the Marley Cooling

Tower Company was reviewed to verify that the piping met

the requirements outlined in Construction Specification ,

No. X4A002 "Specification For Nuclear Service Cooling

Towers And Associated Equipment". This specification

e

,. -- _ _ ,_.~,.,.z_._,-...,____..

.-___,1-.___..._,_..___,.___.___.._. _. - .- _ . . .

70' ,,

y . *

  • *

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23

states that-the design of the cooling tower, equipment, and

piping shall be in _ accordance with ASME Section III,

Class 3' ~and seismic Category 1 requirements. Specific

drawings and documents listed below were used to verify

that- the NSCW Train "A" header (2-1202-007-12) and branch

arm a ssembly _ (2-1202-007-8) were installed in accordance

with these requirements.

Isometric Orawings

2V5-1202-007-01 - Header

2V5<1202 007-02 - Branch Arm Assembly

Weld Process Sheets

007-W-101 - Branch Arm Assembly 8" Butt Weld

007-W-102 - Branch Arm Assembly 8"' Butt Weld

Pipe Support Installation Process Sheets

V2-1202-T07-H045 - Header Support Assembly Bracket

V2-1202-T07-H046 - Header Support Assembly

V2-1202-T07-H048 - Branch Arm Saddle Assembly

Bolting Verification Field Process Sheet

Spool 007-S-04 to Vendor

NPP-1 Code Data Reports

AP & E S/N 3692 - Header

AP & E S/N 2903 - Branch Arm Assembly

AP & E S/N 2932 - Branch Arm Assembly

Supplier Quality Verification Documentation Lists

Equipment Tag # 2-1202-W4-001 Distribution Piping And

Supports

Equipment Tag # 2-1202-W4-002 Distribution Piping And

Supports

Documentation Turnover Package

2-1202-P02

Marley Drawings

78-42913 Plan View Of Spray System

78-4717 Spray System Anchorage And Load Points

78-4718 Load Tables For Spray System

79-41025 Spray System Installation

79-41026 Spray System Installation Details

79-41027 Mechanical Equipment Installation

79-41271 Branch Arm Saddle Fabrication And Assembly

79-41285 Header Assembly

79-41425 Header Support Bracket Assembly

81-4882 Specifications Required For NSCW Towers

83-2450 Standard Torque Recommendation For Fasteners

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24

e. Safety - Related Equipment Installation Review

A ' representative sample of installed equipment was inspected to

verify that the as installed condition was in accordance with the

requirements specified. in the applicable manufacturer drawing and

installation manual, layout drawing, and piping and instrumentation

drawing. The following attributes were inspected: proper documen-

tation of installation on field process sheets (i.e. tightening. or

torquing of anchor bolts as required); proper evidence of equipment

maintenance and cleanliness during construction and startup; proper

equipment tag number and code plate serial number, proper nozzle

location, size and elevation; proper drain, vent, and relief

connections; proper handling of equipment; and proper code class.

The following equipment was selected on the basis of either being

cooled by or part of the Nuclear Service Cooling Water System by the

inspector and inspected for the above noted attributes:

Equip. No. Description Specification No.

2-1202-P4-001 NSCW Pump - Train "A" 2X4AF02-33

2-1202-P4-005 NSCW Pump - Train "A" 2X4AF02-33

2-1203-E4-001 CCW Heat Exchanger 2X4AE01-4

2-1217-E4-001 ACCW Heat Exchanger 2X4AE01-50

2-1501-A7-001 CTB Cooling Unit Coils 2X4AJ16-2

2-1501-A7-005 CTB Cooling Unit Coils 2X4AJ16-2

2-1511-E7-002 Reactor Cavity Cooling Unit Coils 2X4AJ16-4

2-1515-A7-001 Containment Aux. Cooling Unit 2X4AJ16-3

2-1592-C7-001 ESF Chiller 2X4AJ04-11

f. Safety - Related Valve Installation Review

A Representative sample of installed valves were inspected to verify

that the as installed condition was in accordance with the require-

ments specified in the applicable piping and instrumentation

drawings, isometric drawings, and instrumentation index or valve

designation list. The following attributes were inspected: proper

valve orientation and flow direction; proper valve sizing and type;

.

'

proper piping class (i.e. code class, pressure rating, material type,

and end connection type); proper tag and serial number; proper piping

of instrument air to air operated valves to ensure that valve will

1

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fail to the safe position on loss of air pressure; and proper

operator sizing to ensure closure against maximum operational

differential pressure conditions. The following valves were randomly

selected by the inspector and inspected for the above noted

l attributes:

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25

Valve No. Description Drawing No. Size / Type

2HV-780 Reac Cav & 2X4AR01-375- 10" Air Oper. Gate

Cnmt Sump

HDR ISO-

HV-2791A- Hydrogen Monitor 2X5AC07-109 3/4" Solenoid

. ISO Operated Globe

2HV-8030 PRT Fill ISO 2X6AA06-255 3" Air Operated

Diaphragm

2HV-8149C LTDN Orifice ISO 2X6AA06-341 3" Air Operated

Control

2HV-8160 CVCS LTON ISO 2X6AA06-428 3" Air Operated

Globe

2HV-8986A RHR Cnmt 2X5AC07-153 1"' Solenoid

Sump Pass Operated

Sample Train "A"

2HV-10466 RHR Train "B" 2X5AC07-107 3/4" Solenoid

Suct Line Vent Operated Globe

2HV-15214 CVCS Ltdn ISO 2X5AC01-291 3" Air Operated

Control

,

2-1204-U6-003 SI RWST 2X6AA06-250 3" Globe

Purif. Pump

Disch o

RWST ISO

2-1204-U6-128 SI RHR To 2X6AA06-389 8" Swing Check

HL Loop 1 ,

2-1204-U4-142 SI To C1 2X5AG08-58 2" Needle

Loop 4

4

2-1205-U6-001 RHR Train "A" 2X6AA06-400 12" Swing Check

Suct From

RWST

'

2-1205-U4-123 RHR Train "B" 2X6ARol-457 14" Check <

Suct From

Cnmt Sump

i

2-1206-U6-017 CS Train "A" 2X6AA06-391 8" Gate

HDR ISO

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Valve No. Description Drawing No. Size / Type

-(cont'd) i

2-1206-U6-018 CS Train "B" 2X6AA06-391 8" Gate

, HDR ISO

2-1208-U4-417 - CVCS Seal INJ 2X5AC08-50 1" Needle

- To RCP #4

2-1901-U4-039 WPSL _CDT HX 2X4AR01-355 3" Swing Check

Outlet HDR

g. Conclusions i

The inspectors have concluded based on a review on a representative

sample of the commitments designated in section 3.2 of module 4 that

the licensee has accurately defined licensing commitments from the

FSAR, responses to inspection and enforcement bulletins, and

correspondence to the NRC. In addition, the licensee has accurately

defined the working level implementing document utilized by site

personnel to ensure that these commitments (within the scope of r

module 4) are invoked during the design and construction phase. ,

Furthermore, based on independent NRC inspections of randomly

selected mechanical equipment, and piping systems, the inspectors

have concluded that the hardware inspected was installed per

licensing commitments in accordance with Regulatory requirements.

Therefore, it is recommended that'this module be accepted by the NRC. ,

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_ _ _ _ _ _ _ _ _ _ . _ _ _ . _ .

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