TXX-6673, Supplemental Deficiency Rept CP-85-11 Re Drawing Requirement That No Tube Fittings Be Installed Between Two 45 Degree Bends in Instrumentation Tubing.Initially Reported on 850410.Installations Will Be Reinspected

Supplemental Deficiency Rept CP-85-11 Re Drawing Requirement That No Tube Fittings Be Installed Between Two 45 Degree Bends in Instrumentation Tubing.Initially Reported on 850410.Installations Will Be Reinspected

ML20238D733
Person / Time
Site:	Comanche Peak
Issue date:	09/08/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CP-85-11, TXX-6673, NUDOCS 8709110362
Download: ML20238D733 (2)

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'p' Log # TXX-6673 L  : File # 10110 E E 903.10- . -

Ref # 10CFR50.55(e)

MV .c.CTRIC .

Wimam G. Coundl September 8, 1987-O. S. Nuclear Regulatory' Commission ATTN: Document Control Desk Washington, D.C. 20555

$UBJECT: . COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50-445-INSTRUMENT FITTING LOCATIONS SOAR: CP-85-11 (SUPPLEMENTAL REPORT)

Gentlenen:

On April 10, 1985, in our report logged TXX-4454, we notified you of a deficiency, which we deemed reportable under the provisions of 10CFR50.55(e),

regarding a drawing requirement that no tube fittings be installed between two 450 bends in. instrumentation tubing. This item was subsequently identified

'by our letter logged TXX-6435, dated May 13, 1987.as an item for which a final -

report had been issued, however "the corrective actions wero formulated but the schedule-for'the implementation of those actions was not-established."

This report is submitted to status the implementation of corrective actions.

In our repcrt logged TXX-4454, we identified the following three activities as corrective action.

1) !Using the instrument seismic support drawings, engineering will identify the specific insta11ations'for which specific as-built information will.be required for evaluation. These installations (approximately 100) will be re-inspected by site quality personnel. For the. purposes of identification and inspection, the tubing length requirement between bend radii will be reduced to eight inches (8").

2) Based upon the results of the inspection, individual installations will be evaluated on a case-by-case basis. Rework, if required, l

will be specified and implemented. The subject note has been ,

! .. clarified to preclude further recurrence. i

3) In order to validate the identification and inspection process described in item 1, engineering personnel will perform a field verification of an additional 100 installations. The sample will be expanded as required.

i l s709110362 870908 i PDR ADOCK 05000445 A B PDR

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TXX-6673 September 8, 1987 Page 2 of 2 j As a result of the activities described above, an engineering walkdown was conducted of all safety related tubing installations which culminated in the  !

identification of 134 instrument installations potentially involving the "450 offset" discrepancy.

In accordance with Nonconformance Report (NCR) I-85-100222 (closed August 22, 1986), inspections of these installations resulted in the identification of 85

" sat" and 49 "unsat" conditions. As a result of individual engineering evaluations, 48 of the "unsat" installations were accepted. The. remaining unsat instrumentation installation was reworked as documented by NCR-I 100526-S (closed July 23,1985).

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The corrective actions implemented above were necessary due to the di srepancy discovered between Note 13 of drawing 2323-I-002-GN02, " General Notes"9 Revision 4 (06-22-81) and design change CMC-57487, Revision 0 (10-26-8J). :..The information in CMC-57487 was incorporated in drawing 2323-I-002-GN02, " General Notes," Revision 5 (11-24-84), Note 13, to clearly state the correct 2 4 installation criteria. Unit 2 instrumentation tubing was not installed pr'i'or to Revision 5 of the subject drawing. .' <

Recordssupportingtheimplementationofcorrectiveactionareavailab5for your inspectors to review at the CPSES site.

Very truly yours,

/N'? -

W. G. Counsil CBC/gj c- Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) l l

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