ML20078A471
| ML20078A471 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/27/1986 |
| From: | Ramsey W GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20078A351 | List:
|
| References | |
| PROC-860127, NUDOCS 9406010206 | |
| Download: ML20078A471 (250) | |
Text
{{#Wiki_filter:- - - - - -_____ --_--____ _ Georgia Power famp;ny Projtc1 Management j Reute 2 Box 2MA Waynesboro, Georgia 30830 ' Telephone 404 724-8114 404 554-9961 2 O - Vogtle Project ,
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January 27, 1986 Mr. D. O. Foster () Vice President and General Manager Vogtle Project Waynesboro, Ga. 30830 RE: Readiness Review Program Module 17 Raceways LOG: RR-688 I FILE: X7BD102
Dear Mr. Foster:
Pursuant to your instructions I am enclosing Module 17 of the Readiness Review Program entitled Raceways. This module reports the work of the Readiness Review Team and had been prepared in order to present you with an accurate picture of the readiness for operat.ons i of the Vogtle Project, based upon a close examination of the raceway system. The Readiness Review process included an initial assessment and review of basic licensing documents in order to identify Project commitments within the scope of the module. The Readiness s Review Team then verified implementation processes designed to ( meet those commitments, including programs and controls relating to work within the scope of the module. The team then engaged in a process designed to verify that implementation programs were operating as described in procedures, policy statements, and other descriptive documents. C,jg In concluding this verification process, the team then actually verified that the licencing commitments identified during the process were being fulfilled and met. O 9406010206 940512 PDR ADOCK 05000424 P PDR
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Mr. D. O. Foster O January 27, 1986 Page 2 We are confident that the verification methodology used allowed O the Readiness Review Team to properly appraise the actual condition of the raceway system and provided a valid means of assessing the quality of the program, having also considered applicable past audits, inspection reports, and problems experienced by other utilities. Based on the examinations, inspections, and evaluations of the review and the responses and corrective actions committed to by. the Project, it is.the conclusion of the Readiness Review Team that the design and construction-programs that govern the raceway system have produced a final product that meets design requirements and licensing commitments. Additionally, none of the findings identified, either individually or collectively, are such that the adequac1 Sf the project raceway system is called into question. Therefore, the raceway system meets the FSAR commitments. Members of the Readiness Review Team and I are prepared to discuss this module with you at your convenience. If we can O provide you with any further information or assistance regarding this matter, contact me. Very t uly you
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{lIK L CuufU ? William C. Ramsey j WCR/deg R. E. Conway O cc: Readiness Review Board Members Reading File Document Control O 0094q/315-6
4 i i i i t, i 3, 4 a i d e 1 l 4 i r i 1 i VOGTLE ELECTRIC GENERATING PLANT 1 2 UNIT 1 s J 1 READINESS REVIEW i J i MODULE 17 - RACEWAYS i i ii j 4 h 4 A 4 h s E I i i i i D i 1 i, f i I i 4 1
PREFACE l ( Georgia Power Company (GPC), in order to gain added assurance of l the operational readiness of the Vogtle Electric Generating Plant (VEGP), is conducting a pilot Readiness Review Program. The VZGP pilot Readiness Review Program is a systematic, in-depth self-assessment of work processes and verification of comrjliance with regulatory commitments. To accomplish the VEGP ( pilot Readiness Review Program, the work processes and regulatory commitments were divided into manageable segments ; called modules. There are approximately 20 modules. Each module is a predefined scope of VEGP activities. Each module is intended to provide a brief description of the O method of complying with project licensing commitments pertaining to the module scope and is not intended to make further commitments or to revise in any way prior commitments. If any differences exist between the commitments discussed in this document and the licensing documents, they are unintentional; and the licensing document governs. Activities common to several modules are provided as General Appendixes. There are approximately 10 appendixes. These appendixes, as appropriate, are referenced in the modules and l are augmented in each module with module-scope-specific details as needed. l l f, The VEGP Readiness Review Program is being conducted on a l' schedule to provide added operational readiness assurance to GPC management in support of the VEGP Unit 1 operating license. However, conclusions reached regarding programmatic and technical adequacy through review of VEGP Unit 1 are indicative of Unit 2, since both units are being designed and constructed together under a single quality assurance program: with like management controls, procedures, etc.; and to the same specifications and criteria. Stone and Webster Engineering Corporation has been contracted to l provide technical management for, and technical personnel to implement, the Independent Design Review as a part of the Readiness Review program. Additionally, Stone and Webster is O reviewing project responses to Readiness Review findings for technical adequacy. l The VEGP Readiness Review Program is not intended to eliminate or to diminish any authorities or regulatory responsibilities now assigned to or exercised by the Nuclear Regulatory Commission or GPC. Further, the Readiness Review Program is not intended to change the techniques of inspections or assurance of quality program activities. Rather, the VEGP Readiness Review ! Program is an added program initiated by GPC management to assess the VEGP and to provide additional feedback to management 111 l
so that they may initieto any needed correctiva cetions in an orderly and timely manner. The scope of work processes and regulatory commitment compliance covered by each module will be assessed by, and the module prepared and reviewed by, individuals collectively familiar with the design, construction, and operational processes of nuclear power plants. It is the collective opinion of the Readiness Review Task Force, Readiness Review Board, and GPC management that, based on their experience, the methodology used in the module: process will assess, on a programmatic basis, the adequacy of project commitment implementation. Readiness Review Discrepancy Reports and resulting dispositions are reviewed by the Readiness Review Program quality assurance staf f a'nd are input into the normal project process for safety significance and potential reportability evaluations in accordance with regulatory requirements. O O 1 0095q/015-6 iv
i I I 1 i EXECUTIVE
SUMMARY
l . Introduction s This module documents a review program conducted to ascertain i whether raceways for Clase lE cables comply with licensing O commitments and whether compliance is verifiable using existing project documentation. i The scope of this module encompasses programmatic aspects of
- engineering design activities and construction activities as
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they pertain to the design and installation of cable trays, exposed and embedded conduit, flexible conduit, Seismic 7 Category I duct banks, pull boxes, and junction boxes. Technical evaluation of calculations and design activities pertaining to raceways will be included within the separate Independent Design Review report. The raceway-to-raceway and raceway-to-support connections are covered within the scope of this module. Raceway supports, including bolted connections and/or welding integral to these supports or their attachment to the plant structure, are covered in Module 19. Electrical Supports. The review program consisted of two separate verification activities: design program verification and construction
~ program verification. In implementing this program, various raceways were subjected to a field walkdown. In addition, project' documents such as design criteria, drawings, specifications, procedures, installation records, and quality control (QC) inspection records were also reviewed. In selecting hardware / documentation for the review and determining the characteristics or elements to be reviewed, consideration was given to industry problems and to the results of past audit findings within the scope of this module. Discrepancies identified during the review were identified as Readiness Review Findings (RRFs) and were tracked and controlled to obtain adequate resolution. Following evaluation, findings were subjected to categorization as follows:
O Level I - Violation of licensing c omtai tme nt s , project procedures, or engineering requirements with indication of safety concern. Level II - Violation of licensing commitments or engineering requirements with no safety concern. Level III - Violation of project procedures with no safety concern. The review team members included personnel from Georgia power Company, Southern Company Services, and Bechtel Power Corporation (BPC). The Readiness Review Board Technical v i J
Consultant from Stone and Webster provided independent technical oversight and concurrence. Readiness Review Quality Assurance (QA) personnel monitored the review activities. Statements from the technical consultant and QA regarding their involvement and g conclusions are provided in section 7 of this module. A summary of the two verification activities follows. Desion Procram Verification The Readiness Review raceway design verification team was composed of six members having a cumulative experience of 107 years in power plant design. This team expended approximately 1000 manhours performing the verification. Verification of the adequacy of the design program as it pertains to raceways was accomplished in three phases. In Phase I, 43 licensing commitments were identified as being applicable to the scope of this module. Each of these was reviewed to determine whether it was addressed by reference or incorporation in the design criteria manual or other appropriate design documents. In an additional step, the commitments were further reviewed in subordinate design documents such as calculations, drawings, and specifications to ascertain whether commitments had been consistently addressed during the design process. In Phase II, approximately 175 project design documents--including design criteria, calculations, drawings, specifications, procurement and vendor documents, and design change documents--were reviewed for conformance to the design program requirements. This was accomplished using checklists to lh ascertain whether the design process complied with project procedures and licensing commitments [e.g., American National Standards Institute (ANSI) 45.2.11) that govern design control, including coordination between interfacing design organizations. In Phase III, a walkdown was performed to verify that commitments and design requirements were correctly interpreted during the installation process. The walkdown concentrated on areas such as cable spreading rooms, containment penetrations, corridors, and tunnels. The completed design program verification resulted in 12 findings. Of these, none were determined to be Level I, eight were classified as Level II, and four were classified as Level III. The more significant of the findings are 17-7 [ Nuclear Instrumentation System (NIS) conduit separation), 17-16 (EE580 procedures), 17-17 (solid-bottom tray), and 17-18 (tray loading calculation). These are summarized below. gg Finding 17-7 (Level II) noted that, contrary to the Westinghouse guidelines which recommend a 2-ft separation between NIS conduits and electrical noise sources, engineering authorized the option to deviate from these guidelines, provided the noise source was contained in a totally enclosed raceway. g vi
l 1 i S Engineering's judgement for this allowance was based on
) Institute of Electrical and Electronic Engineers (IEEE) 422-1977, which indicates that totally enclosed raceways can reduce the noise generated by power sources; however, the amount of noise reduction was not quantified by the IEEE Standard or by engineering. Due to the difficulty involved in performing an analysis for determining the adequacy of the shielding provided l
(, by the totally enclosing noise source raceway and since the l permitted deviation was not widely utilized, Engineering will ! revise the design documents to be consistent with the Westinghouse guidelines. (A 100-percent field walkdown by the Project disclosed four cases in which a totally enclosed noise source came within 2 ft of an NIS conduit.) Additionally, O* Deviation Reports were issued to track and control rework to the four cases noted above. A review of all other vendor and other Westinghouse guidelines ' pertaining to installation of low-level instrumentation cables i was conducted, and no other instances were found where j insufficiently justified deviations were permitted. The ' Project, upon consultation with Westinghouse, has determined l this finding to be nonreportable. i Finding 17-16 (Level II) notes that the design input process to the EE580 cable and raceway program is not sufficiently , proceduralized. A specific concern was that input data were not l always independently checked by engineering. The finding notes i that in 1 case of 50 safety-related conduits reviewed, the EE580 l program shows 1 conduit as 3 in., whereas, the design drawing shows it as 4 in. In another instance of 35 trays, reviewed by Readiness Review, EE580 shows a tray section as 6 in., whereas, the design drawings show the tray section as a 12-in.-wide tray transitioning to a 6-in.-wide tray. In addition, the EE580 program library was found to use the overall siderail height of the cable trays, instead of the actual usable interior height, to calculate tray usable area; and the inside diameter (ID) of polyvinyl chloride (PVC) schedule 40 conduit was used to calculate the usable area of PVC schedule 80 conduit. Engineering analyzed the two cases of raceway input errors and Os determined that neither would impact installed hardware. The I i conduit discussed above was installed as a 4-in. conduit as shown on the design drawing. Since EE580 calculates the fill for final design, the 3-in. dimension erroneously input into the program is conservative. In the case of the tray section, the engineer apparently conservatively input the transition in tray O sections as the narrower dimension to save a node point in the raceway network in order to reduce computer manipulations. The narrowed dimension would have no detrimental effect on raceway analysis or cable sizing. The two cases of EE580 library input errors were also analyzed O by engineering and were found to have no impact on installed hardware. l vii
The EE580 program calculates the tray usable areas, based in part on the siderail height, and uses this result to determine that trays will not theoretically be filled above the siderails. The difference between the usable height and the j outside height, which was originally used, is approximately ' 1/8 in. (3 7/8 in, versus 4 in.). The use of the actual height is insignificant relative to the conservatism of the EE580 program in predicting overfills above the siderails and will have no effect on tray or hanger design. Regarding the PVC conduit, the use of the schedule 40 PVC 1D could have resulted in an overfill of the schedule 80 PVC conduit. The ID of schedule 80 PVC was entered into the library, and a review was made to determine potential overfills; none were found. The raceway input errors are considered isolated occurrences having no technical impact. A further review of the data base for raceway input errors is considered unnecessary, since the errors were isolated and few in number, and since downstream checking is provided by procedures such as ED-T-02. ED-T-02 requires Construction and OC to check EE580 output against the design drawings for consistency during installation. The input errors to the EE580 program library also have no impact on technical adequacy: nevertheless, Engineering will verify all existing EE580 library criteria input by March 15, 1986. Data input into EE580 is always checked, normally, but not always, by an independent checker. To enhance the design input process to EE580 and ensure an independent check function, a ll procedure will be prepared to complement the BPC standard EE580 User's Manual. Finding 17-17 (Level II) notes that'a control cable tray was shown in EE580 as an as-built solid bottom tray, contrary to the general notes on the design drawings, which call for control cable trays to be punched bottom. Investigation disclosed that the tray was installed using solid bottom sections and the EE580 data base was changed by engineering to reflect the as-built condition without a design change document. This undocumented change to EE580 is viewed as an isolated case that was identified on a deviation report and was corrected by a design change notice (DCN) to the design drawing. A further review of approximately 10,000 trays identified 27 others (all control level) where solid bottom sections were indicated by the EE580 data base, contrary to the. general notes drawing. In all 27 cases, a formal design change process was utilized (i.e., drawing revision, Field Change Request (FCR), or DCN). However, these changes were not consistently and completely incorporated in all design documents. As a result, conflicts between EE580 (which called for solid bottom trays) and the multiple design drawings (which indicated punch bottom trays) existed for these trays. A field walkdown was g viii l
l l l l l l subsequently conducted and disclosed that in 17 of these cases O solid bottom sections were actually used, while in the other 10 i cases punched bottom sections were used. Project construction personnel will be given additional training on the electrical drawing notes and the necessity of assuring
/~' consistency between the EE580 cards and the design drawings. In addition to these steps. Engineering will revise EE580 and other design documents for the remaining 27 trays, as appropriate, to '
ensure consistency and will provide training on this matter to the appropriate personnel. Deviation reports have been written ! on the solid bottom trays and dispositioned use-as-in. l l /~T (_/ Engineering has determined that the use of solid bottom sections on any of the cited control cable trays is not a technical or safety concern. Moreover, even had the opposite condition occurred (use of punch bottom sections for instrumentation cable trays), there would be no technical concern, as no credit is taken for noise reduction due to the use of solid bottom trays for instrumentation circuits. l l l Finding 17-18 (Level II) revealed, among other items, that the calculation on cable tray loading did not address all possible inputs, such as the weight of tray covers on power trays, weight i of attached grounding cable on medium voltage trays, and use ot l worst-case control and instrument cable unit weights for cable () weight calculation. Engineering will revise the calculation on cable tray loading by January 31, 1986, to address worst-case cable unit weights and grounding cable attachments to medium-voltage trays. Neither input is expected to affect the adequacy of design. Since grounding cable weighs about 1/2 lb/ft and since the worst-case medium-voltage tray (with cable) unit weight is 40.6 lb/ft, the impact is minimal versus the allowable 55 lb/ft. The calculation currently addresses the most commonly used control and instrument cable unit weights as the basis for cable weight calculations. Using worst-case cable unit weights is expected to have no impact, since detailed .oight analyses are performed l on trays with cable fill percentages appreciably less than those justified by this generic calculation.
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With respect to power tray covers, it was Engineering's intent l that tray covers would generally not be added to power trays: l l therefore, they were intentionally omitted from the calculation for power trays. To date, only 12 trays have required O authorization (based on support analysis) for actual weight exceeding initial design, and no trays have been identified as l exceeding design weight due to addition of covers. To facilitate identification of instances where addition of a tray cover could ultimately result in a tray loading above design
~s limits, the design documents will identify trays which might exceed allowable design weight should a cover ha added to the tray. Should there be a need to add a cover to a tray ix l
[ . ., . _- .
1 I j identified in the document, prior engineering approval will be i required. The addition of barriers or blankets to trays to satisfy Appendix R requirements could impose additional loads on the tray / support system. To date, analysis of approximately 95 percent of the Unit 1 safe-shutdown circuits has produced only one case that may require wrapping. In any event, Appendix R imposed materials will be factored into tray loading analyses prior to issuance to the field for installation. Further details of the design findings are presented in section 6.1. The 12 findings are based on a review of 175 project documents for approximately 10 elements. Collectively, the findings indicated some inconsistencies in meeting all the documentation g requirements of ANSI N45.2.ll. However, with the effective W implementation of corrective actions committed to by the project responses to the identified findings, the design program verification results indicate that raceway design is adequately controlled by the existing program and meets applicable licensing commitments. Construction Program Verification The Readiness Review raceway construction verification team was composed of four members having a cumulative experience of 48 manyears in power plant construction. This team expended approximately 640 manhours performing the verification. Verification of the adequacy of the construction process as it O pertains to raceways was accomplished in two phases. In Phase I, 14 construction-related licensing commitments were identified as being applicable to the scope of this module. To assure that the commitments were add'ressed by the construction program, each of these was traced to one or more implementing documents. No discrepancies were found during this phase. In Phase II, 71 items of hardware were assessed for approximately 30 work elements each. These work elements included both visually verifiable hardware attributes and documentation attributes. Approximately 1100 records were i reviewed during this assessment, resulting in six findings. Of these, two were categorized as Level I, one was categorized as Level II, and three were categorized as Level III. The more significant findings are summarized below. Finding 17-1 (Level II) addressed the failure of the Construction Engineering Group and the contractor to adhere to g procedural requirements that require documentation of train W separation violations during the ins'tallation process. Of 64 raceways that violated separation requirements, 15 were not l documented on Fire Separation Barrier Requests (FSBRs). (FSBRs are tracking mechanisms for identifying change requests for bscriers as unfinished construction activitieu.) QC accepts the , x l
f-raceway only if the FSBR exists to document the separation (_gj violation. The 15 raceways noted above, were accepted by QC: , however, the subsequent installation of other raceways causing l the separation problems had not yet been inspected by QC j personnel. l The Project has retrained contractor and construction personnel l g-)s q and has emphasized the need to follow established procedures. j Area walkdown procedure GD-A-50 was strengthened to ensure that 1 train separation is checked during the walkdowns for area l turnover. As no instances of QC failing to identify raceway l separation violations were identified, the Project did not walk ; down items that were turned over but not inspected; the Project () will generate FSBRs as QC identifies the violations. Finding 17-2 (Level I) noted, in part, that of 141 spring / stud nuts (which fasten cable trays to the support) checked for i torque, 39 failed to meet specified initial minimum terque test j requirements. A subsequent survey by Engineering on 59 randomly selected support arms, identified an additional 26 of 118 l spring / stud nuts that were improperly torqued, confirming that low-torque conditions on the holddown clip installations were !
< not isolated. Engineering analysis, however, did establish that, even for worst-case conditions postulated as a result of I
data collected, slippage would not occur for the safe-shutdown earthquake (SSE) or the operating basis earthquake (OBE) and I that the existing condition is acceptable as is. To assure that 1 O' future connections will attain the very high margins of safety l against slippage that were originally intended, the contractor's i personnel have been retrained to comply with the installation torquing requirements, and electrical QC has been provided clear instructions for the inspection of these installations. Finding 17-3 (Level 1) noted in part that, contrary to specification, a pull-through conduit fitting and a pull box installed inside containment were not waterproof. A review of 33 raceways inside containment disclosed one other pull box that was not as required. Deviation Reports were issued to correct the specific discrepancies. In addition, the specification was 4 7s changed to allow use of nonwaterproof boxes inside containment () and other washdown areas when exiting conduit is sealed. The field procedure was amended to ensure that all conduits will be sealed as required. Additionally, the finding noted that the current program did not address sealing of conduits which terminate upward into trays. (s) To address this, field procedures were revised'to regaire a check for sealing of conCuits entering floor or wall-inounted equipment from cable trays or nonwaterproof boxes. Further details of the construction findings are presented in section 6.2 xi
Collectively, the findings indicated some deviations in the contractor's compliance with existing requirements and pointed out some specific deficiencies in installation procedures / g specifications and documentation filing /retrievability as they W pertain to raceways. The Project has corrected the procedure / specification deficiencies. In addition, the Project is implementing a plan to correct documentation filing /retrievability problems. The Project has also conducted additional craft training and has increased QC inspection activities on raceway installation. Based on these actions and the overall results of the review of some 1100 documents and 71 items of hardware, the construction program verification indicates that raceway installations are now adequately controlled by existing programs and meet applicable licensing commitments. Readiness Review Conclusion Having performed a review of project documentation and hardware, Readiness Review concludes that with the committed project actions, including final walkdown programs, adequate controls exist to ensure the quality of design and construction activities and the implementation of licensing commitments within the scope of this module through plant completion. Additionally, it is concluded that completion of committed project actions will assure that the compliance with design and construction programs and processes is properly documented. O O 0084q/030-6 l xii l
1 1 MODULE 17 i O ELECTRICAL RACEWAY TABLE OF CONTENTS l I ("T 1.0 Introduction l
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l.1 Module Organization 1.2 Scope 1.3 Status 2.0 Organization and Division of Responsibility 2.1 Design 1 2.1.1 Home Office Engineering 2.1.2 Project Field Engineering 2.1.3 Training 2.2 Construction l 2.2.1 GPC Electrical Project Section 2.2.2 GPC Electrical Quality Control
- 2.2.3 GPC Field Construction Operations - Coordination
, 2.2.4 Cleveland Consolidated 2.2.5 Training 1 3.0 Commitments 3.1 Introduction 3.2 Definitions 3.3 Sources 3.4 Commitment Matrix , 3.5 Implementation Matrix l 1 4.0 Program Description 4.1 Design 4.1.1 Design Criteria 4.1.2 Drawings and Documentation 4.1.3 Design Control and Review O, 4.1.4 Design Change Control l l l 4.2 Procurement i i 4.1.1 Supplier Quality Surveillance Program i 4.2.2 Supplier < Quality Verification Documentation O 4.2.3 Supplier Deviations l xiii i
i 4.3 Site Material Control 4.4 Installation and Inspection 4.4.1 Flow Charts l 4.4.2 Past Program Changes i 4.4.3 Procedure Index ) 5.0 Audits and Special Investigations 5.1 Design Audits 5.1.1 Project Audits 5.1.2 NRC Inspections 5.1.3 Other Audits 5.2 Construction Audits 5.2.1 Project Audits 5.2.2 NRC Inspections 5.3 Past Problem Areas 6.0 Program Verification 6.1 Design Program Verification 6.1.1 Summary and Conclusions 6.1.2 Scope and Plan 6.1.3 Verification Review and Results h 6.1.4 Findings 6.2 Construction Program Verification 6.2.1 Summary Evaluation 6.2.2 Phase I - Commitment Implementation 6.2.3 Phase II - Construction Verification Program 6.2.4 Items of Question 7.0 Program Assessment / Conclusions 7.1 Summary or Open Corrective Actions 7.1.1 Section 6.1 Engineering 7.1.2 Section 6.2 Construction 7.2 QA Statement 7.3 Technical Consultants Certification 7.4 Readiness Review Board Acceptance 7.5 Project Assessment 7.6 Resumes 0067q/030--6 xiv
1.0 INTRODUCTION
1.1 MODULE ORGANIZATION This module is one in a series of modules that provides an O evaluation of the design, procurement, construction, and readiness for operation of the Vogtle Electric Generating Plant Unit 1 and common facilities. It is intended to describe the method of complying 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. ! O Any differences between the commitments discussed in this document and the FSAR, if any, are unintentional. In the unlikely event that a difference between this module and the FSAR should occur, the FSAR shall take precedence and shall define the project commitments. This module contains a review of the design, procurement, storage, and installation of Unit 1 Class 1E Electrical Raceways. The checks, reviews, inspections, audits, and verifications performed to assure the adequacy of these l functions are also examined. The organizations responsible for l performing these activities are identified and the training / qualification of their personnel is reviewed. Project commitments are also identified and their implementation 1 () 7-reviewed for compliance. The effective date of this module is July 1, 1985. Changes to the included programs, organizations, commitments, etc., occurring after this date are not necessarily addressed. The contents of the module are divided into the following review sections: ORGANIZATION AND TRAINING - This section discusses the design and construction organizations and their personnel training applicable to the module. 1 O COMMITMENTS - This section contains project commitments for electrical raceways as identified in the FSAR and other documents, as well as, the means of implementation for each commitment. PROGRAM DESCRIPTION - This section describes, in detail, the O processes used for design, procurement, and construction. Responsibilities, specifications, procedures, and work activities are also addressed. AUDITS - This section describes the activities of internal and/or external auditing agencies, including the Nuclear O Regulatory Commission (NRC) as they apply to the module. Also included in this section is a description of special
i investigations performed on the work covered in the module and significant deficiencies that were identified. PROGRAM VERIFICATION - This section describes verification plan development, implementation, and results. O\ I ASSESSMENT - This section describes the evaluations and ' conclusions by the applicant's Readiness Review Tar;k Force, Headiness Review Board, Readiness Review program Qaality Assurance staff, and Readiness Review Board exper.. This section also identifies any items still open and their scheduled closure dates. O O i O O 0034q/030- 6 l l 1.1-2
1.2 SCOPE Module 17 contains a description of the design. procurement, installation, and inspection of conduit, cable trays, and special raceways for Class 1E cables for Plant Vogtle Unit 1. The following hardware is described in this module: f (_) o Cable tray (including associated separation barriers). o Exposed and embedded conduit. o Pu11 boxes. l O o Junction boxes. l
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o Raceway attachment to suppotts. Raceway supports and associated welding and bolting will be covered in Module 19. See Figure 1. 2- 1 for illustration. I ($) o D O v O 0007q/016-6
-. .. - . . . - - ._- -,. .._, _ ~ - _ - _
O O O O O O O EMBEDS, STRUCTURAL STEEL MODULE B DATUM
> 1 T
l l 1 ' p , . TRAY AND
< ' ATTACHMENT TO O SUPPORT - MODULE 17
- E Ir--
i CONDUlT AND ! L ATTACHMENT TO 2 l } SUPPORT - MODULE 17 I I _ l' SUPPORT, BR ACING, STIF FENERS, AND ATTACHMENT TO EMBEDS, CONCRETE, OR STRUCTURAL STEEL - MODULE 19 Figure 1.2-1 Module Boundaries and Interfaces
r'T 1.3 STATUS U As of the July 1, 1985, module effective date, the design of raceways for Class lE cables was essentially complete. The design effort was primarily confined to construction support activities and updating of design documents to reflect the as-built status of the raceway system. Raceway installation began in August 1978 with the placement of embedded conduit in the base slab of the auxiliary building. As of July 1, 1985, overall Unit 1 and common Class lE and non-Class lE electrical raceway installation status was as shown below: Commodity Estimated Installed Percent _ Type Quantity (ft) Quantity (ft1 Complete Conduit 1,254,015 822,717 66 Tray 155,508 147,338 95 Total 1,409,523 970,055 69 (~T %.) O c, O 0015q/016-6
2.0 ORGANIZATION AND DIVISION OF RESPONSIBILITY Georgia Power Company (GPC), acting on its own behalf and as j
. agent ^for the Oglethorpe Power Corporation, the Municipal j Electric Authority of Georgia, and the City of Dalton, is responsible for the design, procurement, and construction of the i s,) Vogtle Electric Generating Plant (VEGP). l l
The Western Power Division of Bechtel Power Corporation (BPC) is contracted by GPC to provide architect / engineering (A/E) services for the Seismic Category I structures. Southern Company Services, Inc. (SCS) is contracted by GPC to provide A/E services for the Seismic Category 11 structures. . A l small number of safety-related (Class 1E) raceways are routed In-Category II structures. GPC, as the-owner, provides procurement services, controls material issue, and provides construction services for calibrations, tests, and inspections; document control; .and nonconformance control. Cleveland Consolidated is the installer for all Class 1E raceway systems and is responsible for all installation and field ' fabrication activity. l O-This section includes a brief description of the o'ganization GPC, BPC, SCS, and Cleveland Consolidated as related to the r of ' 1 i scope of this module. O
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0035q/030-6 i
- - -- - -. _ --. - - a
i 2.1 DESIGN Design of Class lE raceways is the responsibility of Bechtel Power Corporation (BPC). BPC is directly responsible for Class lE raceway design in all plant areas. The turbine l building is designed by Southern Company Services (SCS). SCS drawings illustrating Class lE raceways are reviewed by BPC to O assure conformance to licensing requirements. BPC responsibility for design of raceways is divided between two project organizations: Home-Office Engineering (HOE) and Project Field Engineering (PFE). HOE is located in Norwalk. CA and is responsible for the majority of the Class lE raceway system (-} (_/ design. PFE is located at the Plant Vogtle site and provides field liaison. PFE is responsible for those portions of the Class lE raceway system design which have been transferred to , them from HOE. I 2.1.1 HOME OFFICE ENGINEERING The design of Class lE raceways within HOE is the principal responsibility of the electrical discipline with specialty support provided by the environmental qualification group. Duet bank structural design is the responsibility of the , civil / structural discipline. i The electrical discipline is divided into four groups under the , direction of the electrical engineering group supervisor (EGS). l These groups are Systems Design, Controls Wiring. Physical l Design, and Circuit and Raceway. Their functions are tabulated i in Figure 2.1-1. Responsibility for the design of electrical raceways is primarily the responsibility of the Physical Design i Group with assistance provided by Systems Design and Circuit and Raceway (EE580) Groups. l l The Equipment Qualification Group is responsible for assuring the seismic and environmental qualification of all safety-related equipment. Their organizational structure is rN depicted in Figure 2.1-2. U The civil / structural discipline is grouped by building / area as I shown in Figure 2.1-3. Duct banks are the responsibility of the miscellaneous Seismic Category I Structures Group. 2.1.2 PROJECT FIELD ENGINEERING Assistance in resolving field-related electrical and civil / structural problems is provided by the PFE electrical and civil / structural disciplines. Their organizational structures are depicted in Figures 2.1-3 and - 4. v
t l I l 2.1.3 TRAINING ! Engineering personnel assigned to HOE and PFE receive training g j to familiarize them with project procedures governing their T ' assigned responsibilities. Part A, section 6 of the Project Reference Manual (PRM) establishes the program structure and requirements for indoctrination and training of BPC personnel j assigned to the Vogtle Electric Generating Plant. It defines l procedures, responsibilities, documentation, and records maintenance for the BPC project training program. Participation { in the program is mandatory for permanently assigned home office i and jobsite personnel. ' The overall training program includes training in the following subject areas: o Quality Program. l o Engineering Indoctrination Program. ! o Project Reference Manual (PRM). o Technical and specialized training. ! o New arrival orientation. o Quality Concern Program. The project engineering manager or his designees are responsible lh for the formulation and implementation of the training program. The discipline engineering group supervisors (EGSs) are responsible for ensuring that assigned personnel attend mandatory training classes, receive training in the requirements and the use of the PRM, and learn the unique technical aspects of their work. The discipline EGSs identify the training requirements for each individual in their disciplines commensurate with assigned tasks and maintain records of training in accordance with the PRM, Part A, section 6. The project administrator receives and stores training records of personnel no longer assigned to the project. O l ll> 0061g/020-6 Gl 2.1-2 I
O O O O O O O ! ENGINEERING GROUP SUPERVISOR SPECI AL DEPUTY ENGINEERING DEPUTY GROUP LICENSING ENGINEERING ~~~~ SUPERVISOR
- ~ ~ -
COORDINATOR GROUP (FOR ELECTRICAL SUPERVISOR TASK FORCE TO ACCELERATE
' PHYSICAL DESIGN) i i
I i _ _ _ , ', I i
' __.______1__ ___ _._________ __,.___-1____,
I I i i . i , I i i CIRCUlT AND PROGRAM FOR PHYSICAL CONTROLS WIRING RACEWAY SYSTEMS DESIGN DESIGN COMPLETION GROW LEADER I GROUP LEADER GROUP LEADER OF WORK GROUP LEADER t I CONTROLS SYS STUDIES PHYSICAL DESIGN STUOlES CIRCulT INPUT PCW ELEC SYS STUDIES CIRCUlf ROUTING CONTROL SYS DESIGN LIGHTING DESIGN COORDINATOR E LEC SYS CALCS ELEC PANELS GROUNDING DEStGN R ACEWAY INPUT ELEC SYS DESIGN SPECIFICATIONS R ACEWAY DESIGN CONSTR*JCTION SUPPORT CRITERIA CONT / WIRING CALCS CONSTRUCTION SUPPORT SCS COORDIN ATION SINGLE LINE DWGS ? ELEMENTARY DI AGRAMS SCS COORDIN ATION EOPT SPECIFICATIONS
. LICENSING SUPPORT WIRING DIAGRAMS CONSTRUCTION SUPPORT CONSTRUCTION SUPPORT SCS COORDIN ATION SCS COORDIN ATION LICENSING SUPPORT , _ _ ,
& COORDINATION 18581-5 Figure 2.1-1 BPC Vogtle HOE Electrical Discipline
ur AA - m - a ,. _# 4 ~ .. a_ m.aa m i 1 l l 9 f I. 1 i 4 9 4 4 d I
- 9. ,
I 9 1 4 l 1 5 l 1 4 0 1 O\ , l O O 1 1 0!
O O O O O O O FUf!CTIONS AND RESPONSIBILITIES
'^ ^
EQ COORDIN ATOR FSAR NUR EG-0588 DESIGN CRITERIA W NSSS EQUIP DEVELOP ACCEPTANCE CRITERIA TRENDS, CEBUS UPDATING GROUP LEADER EQUIPMENT SUPPLIER CUALIFICATION DOCUMENTATION DATA PACK AGES REVIEW REVIEW AND MAINTAIN SUPPLIER EQUIPMENT QUALIFICATION PLANS, PROCEDURES AND REPORTS MECHANICAL / - ELECTRICAL EXPEDITING AND PROCUREMENT SUPPORT CONTROLS EQUIPMENT QUALIFICATION MECHANICAL ^ ELECTRICAL TEST SCHEDULE STATUS EQUIPMENT QUALIFICATION - CONTROLS SUPPLIER CORRESPONDENCE, MEETING l MINUTES, ETC.
- DATA PACKAGE PREPARATION ,,,,,,,
i Figure 2.1-2 Vogtle BPC Equipment Qualification (EQ) Group l
- . . . . - - . ._. . .. .. . . . -w. - a. w.a... - .- - . . . . - . .-.u .x . ~ ~ , , = . .- -. _ _ .
o I l O O J J c I PROJECT l
' ""'"' E R4NG FIELD HOME OFFICE ,, ,cgp l.
I LEGEND PE PROJECT ENGINEER i i, EGS ENGINEERING GROUP SUPERVtSOR CHIEF PE-DE SIGN I PE F6 ELD 3 DGL DRAFTING GROUP LE ADER S L - 4.____ I I CiveLI e CtviLr CIVtLi l STRUCTURAL STRUCTURAL STRUCTURAL
- EGS STAFF EGS I
I-DR AF TfNG ORAFTING SUPE RVtSOR SUPE RVISOR I
. l 1 i *tlXttlARY I,
DE T AILING FUEL HANDLING e ButLDING EGL l l CONTROL
- CONSTRUCTION SUPPORT EGL 4
I 4 I COM Y AINMEN T EGL PROJECT DIRECTION
==*--- FUNCTIONAL DIRECTION i* ======*--*=-* INDICATES PHYStC AL LOCATION I
MISCELLANEOUS l CATEGORY 1 e l Figure 2.1-3 BPC Vogtle Civil / Structural Discipline i
O O O O O O O i ELECTRICAL ENGINEERING GROUP ; SUPERVISOR , r-------- , CONTRACTOR I I I I SUPPORT ' l COORDINATOR l l L___________J : SYSTEM / CONTROLS START-UP PHYSICAL SUPPORT COORD?NATOR CONTRACTOR SUPPORT ENGINEERING , ROUP LEADER GROUP LEADER GROUP LEADER t GROUP LEADER 1 I i I (SCS) l ; L_________J. l > 1 ! i i t CONTROL PANEL i j EE580~ TASK FORCE l GROUP LEADER i .s e i .s 4 1 j Figure 2.1-4 BPC Vogtle PFE Electrical Group i e'
l 1 l I 2.2 CONSTRUCTION l g-] l l %.) This section contains descriptions of duties and responsibilities for the portions of the site construction organization directly involved with electrical raceway receipt, storage, issue, and installation. I (/"} l _j The program description for qualification and certification of quality control inspectors is contained in Appendix F. The training program and those requirements that apply to electrical ; equipment are covered in section 2.2.5. 2.2.1 GEORGIA POWER COMPANY ELECTRICAL PROJECT SECTION The general responsibilities are as follows: o Providing the contractor with approved material requisitions, initiating purchase orders and releases for material, and providing contractor and Quality Control (QC) personnel with EE580 tracking and control syster. information. o Providing schedule and budget information to various site organizations. l (~N o Ensuring that raceway installation supports system l
't) completion dates and resolving any incomplete items.
o Interfacing with Field Coordination and QC regarding problem identification and resolution, o Initiating and revising field procedures, as needed, to support construction activities. 2.2.2 GEORGIA POWER COMPANY ELECTRICAL QUALITY CONTROL The Electrical Quality Control Section (EQC) verifies that fs construction activities comply with the Vogtle Quality Assurance i )_ (QA) program. EOC is subdivided into specialized groups for specific inspection activities. The major divisions are: o Equipment - instrumentation. gg o Terminations. i / o Cable installation, o Raceways.
,e o Drilled-in anchor bolts.
k
2.2.3 GEORGIA POWER COMPANY FIELD CONSTRUCTION OPERATIONS-COORDINATION The Field Coordination Group is responsible for assigning contractor personnel to perform housekeeping, maintenance, and access-barrier construction activities, as well as coordinating work activities and scaffolding and/or cribbing construction around or over installed raceways to ensure that protection requirements are maintained. 2.2.4 CLEVEl.AND CONSOLIDATED Cleveland Consolidated is the electrical contractor performing quality- related work on the Vogtle project. Cleveland is responsible for supplying all craft and supervisory personnel for the electrical scope of work, as well as for providing document control and assistance for their craft. 2.2.5 TRAINING This section describes training and qualification requirements dnd programs for Construction personnel performing activities contained within the scope of this module. 2.2.5.1 Georgia Power Company Electrical Project Section The Electrical Project Section of Vogtle Construction conducts in-house orientation and training of engineering personnel. Most of the training is informal, with the section or engineering supervisor holding procedure or specification refresher classes. Periodically, formal training is held offsite or at the simulator building near Plant Wilson. If time is available during working hours, or after hours as necessary, the Project Reference Manual (PHM) or the Project Policy Manual may be assigned as required reading by an engineering supervisor. Orientation for new engineers (either newly hired or newly transferred engineers) is accomplished as follows. New engineers are given copies of the project and site safety rules, information concerning the Quality Concerns Program, and other information intended to introduce the new employee to the site. l Each person is tested on his understanding of the safety rules: ! further instruction is given in weak areas. Newly assigned engineers normally are given, or informed of, a listing of the applicable specifications and procedures that govern their working area. These engineers, based on available training facilities, are indoctrinated into their specialty (raceways, terminations, cables, etc.) through required reading and testing l 2.2-2 l l l
J of the applicable specifications and procedures. An exam is {-}
% given by the Training Department, the section, or the engineering supervisor. Weak areas, based on the exam results, are discussed with the engineer.
E,ther after completion of testing or after a portion of the testing is completed, the new engineer is assigned to work 1 k'~}/ concurrently,with an experienced engineer on a particular work j area or activity. The experienced engineer provides guidance in the use of procedures, specifications, and drawings. If the new engineer has sufficient difficulty to warrant training, a drawing refresher course is available onsite to which he may be scheduled. Tha 7xperienced engineer will also introduce the new (')i
\_ engineer to the responsible craft, QC, and Design personnel.
The new engineer sna11 be given increased responsibilities as he j is capable of accepting them. 2.2.5.2 Contractor Traininq i Cleveland Consolidated provides training for general orientation
- and also provides skills training for craftsmen as required by 1 the GPC procedures, site safety organization, and project correspondence / commitments. The procedure awareness coordinator (PAC) program wac established to insure craft knowledge of procedures and proceduto changes.
l Cleveland's Training Group develops and revises training courses corres'ponding to procedure issue and revision. They maintain a course outline and description which describes course content, testing method, and certification requirements. The Cleveland Training Group provides the QA vault with lists of qualified personnel for those procedures that require it. Cleveland also has a procedure awareness coordinator who distributes information on procedure changes to craft supervisory personnel so that the craft maintains current knowledge of procedural requirements. t GPC certifies all welders and maintains the certification (x' records. Whenever the need arises, GPC provides staff and craft , specialized training. i 2.2.5.3 Inspectors The QC inspection program for the inspection and acceptance of electrical raceways as identified in this module is conducted by the GPC Electrical Quality ~ Control Section. This section is composed of inspectors employed by GPC, Butler Service Group, BPC, and Continental Technical Services (CTS). Butler, BPC, and , CTS are agencies that provide inspectors who work under GPC
- supervision.
2 2.2-3
The training and certification program for electrical inspectors is developed and administered onsite by the GPC Training Department. Appendix F contains a detailed explanation of the overall site certification program. Certification in raceway installation allows the inspector to : perform inspections in the areas of embedded / exposed grounding, I raceway installation, and Calvert-Bus installation. The primary j training course is Raceway / Embedded Items, which is 40 hours in i length and provides the inspector with direction, instruction, ' and reference material for methods of installing raceways. The ! inspector is also trained in the use of drawings, specifications, procedures, and the proper use of forms and l their routing. Table 2.2-1 defines the activities that the I inspector is qualified to perform and the required training ' courses. A Level I inspector records inspections, examinations, and testing data along with implementing inspections, examinations, and testing procedures. The Level II inspector performs the actual evaluation of she validity and acceptability of inspections, examinations, and testing results, in addition to documenting them. An uncertified inspector is not allowed to independently inspect for acceptance, but is used in data-collecting or inspection assignments, provided he is supervised by a certified inspector who is participating in the inspection, examination, or test. O O O 0000g/030-6 2.2-4
1 1 1 l TABLE 2.2-1 DETAILS OF RACEWAY / EMBEDDED ITEMS CERTIFICATION j l The following work activities may be inspected using this certification: ; k-- I o Grounding (embedded and exposed). j l o Raceway inspection. ' o Calvert-bus inspection. k/ The following courses are required for certification: o Basic Math I. o Basic Blueprint. o Raceway / Embedded Items (a) l l Includes: Drawings j Codes / Standards / Specifications / Procedures l l (} Raceways ' Grounding Supports Equipment / Tools I O l l l
- a. Certification in Visual Inspection or an American Welding
() Society (AWS) certification is required if weld inspection is performed. 0036q/2/020-6
3.0 COMMITMENTS b o
3.1 INTRODUCTION
This section contains, in matrix form, project commitments that affect activities described in this module and their () corresponding implementing documents. These are presented in two matrixes, the commitment matrix and the implementation matrix. A brief explanation of the development process for each matrix is also included. gg Additionally, the project has a commitment to comply with 10 CFR 50, Appendix B, Quality Assurance Criteria, and other (_) commitments such as ANSI N45.2 and N45.2.11. Although they were not identified as specific commitments in this module, Readiness Review considered the applicable requirements of these types of commitments in preparing and assessing the scope of work represented by this module. Any differences between the commitments discussed in this ! section and the Vogtle Electric Generating plant (VEGp) Final Safety Analysis Report (FSAR), if any, are accidental, and the { FSAR prevails. l I l l l 1 0026q/015-6 l l l
j 3.2 DEFINITIONS A commitment Hi:s an' obligation to comply-with an industry l 4 standard, Regulatory Guide. Branch Technical Position, or owner l P l an of specific action. For the purpose of the Readiness 1
- Review (RR) Program, commitments will be' identified from the-
}. - Vogtle Electric Generating Plant (VEGP) Final ~ Safety Analysis Report (FSAR), responses to Generic Letters, and responses.to- ! I I IE Bulletins. An implementing document is the working level document that 4 identifies project commitments as they apply to the specific work activity. 1 J a 1 4 Y I l 1 1
- 3.2-2 J
, r,_ . ._
,_, .c ._,_. ...,.,,__m m -..,r,..... ,,,-_,-,_,,m_, ._,mm.,,,.m_,nm,,_,...-,,..-.- ..m,,,,, ,m.m,
l ~ t l 4
+
1 z 3.3 SOURCES O' Commitments listed in the matrix were identified from the following sources: , o FSAR including responses to NRC questions, o Responses to Generic Letters, o Responses to I&E bulletins. These sources were reviewed for commitments based.upon guidelines developed from the definition' stated in section 3.2. Implementation of commitments stated in the commitment matrix are typically contained in: o Design criteria. o General notes, symbols, and details drawings. o Construction specifications, o Construction procedures. C:) l 1 l l O O 1
l l l I l l 3.4 COMMITMENT MATRIX l O)
\-
Once identified by the Readiness Review Team, the commitments are placed on the commitment matrix. Information identifying the source, source section, subject, and module are also indicated on the matrix. Any relevant comments concerning the commitments or subject of the section are indicated in the O remarks column. i The commitments identified in this module are accurate as of l July 1, 1985, and reflect Amendment 16 to the VEGP Final Safety Analysis Report. O)
\~ .
1 l l 1 l l l \ - O
O @ O O O O COM41 TENTS ~ SORTED BY SOURCE A10 SECTION CON 911ENT CON 9tTENT COpMITENT DOCUENT/ ESPONSIBILITY SOURCE SECTION SUBJECT FEATURE MODULE DESIGN CONST REMARKS EF NO. EXPlWiATION OF FIELDS . COPNITENT SOURCL - The document containing the ccmnitroent (FSAR, Generic Letter, l.E. Bulletin Response, etc.)
~
Ca mlTENT SECTION - Identifies the FSAR section, leHer number, or quesf' ion nun 6er COPNITEN1 SUBJECT - The subject of the FSAR section or Generic l_etter DOCUMEN1/fLATURE - The document discussed in the ISAR section or the plant feature described in the FSAR section MODULE The Readiness Review nodules applicable to the conrnitet under discussion RESPONSIBILl1Y - An X is placed under the heading for the organization responsible for inplomontation of the connitwent ret. NO. - A reference number that corresponds to the appropriate line entry in the implerentation matrix i f 010Iq/Ol5 4 i
. . _ . . . _.-__m___ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ . _ _ - _
_ _ _ _ _ _ _ _ _ _ _ _ _ .m. 4 -<-, -~v - - ._._ ____ a_ _ _ __
_ m . .. m _ . . . . _ . . - - . _ ._m m_ . _ _ _ . _ _ _ = _ . . . _ . . . _ . . . _ _ - - - m_ m..m . . _ _ . _ _ . . . . - _ _ . - _ _ . _ ..=_-_m__ Page No. 1 01/24/86 COMMITMENTS
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FSAR 1. 2. 12. I SINGLE FAILURE. IEEE 279-1971 X 108 REDUNDANCY & INDEPENDENCE CRITERIA FSAR 1. 9. 32 CRITERIA FOR RG 1.32 REV. 2 2/77 I SEE REG. GUIDE 1.6 131 SAFETY-RELATED 1.9 1.75, 1.81 AND ELECTRIC POWER 1.93. SEE FSAR 8.1 - SYSTEMS FOR NUCLEAR AND 8.3 POWER PLANTS FSAR I. 9. 32 CRITERIA FOR IEEE 308-1974 E 132 SAFETY-RELATED ELECTRIC POWER SYSTEMS FOR NUCLEAR POWER PLANTS FSAR 1. 9. 32 CRITERIA FOR 10CFR50 APP. A, GDC 17 X 133 SAFETT-RELATED J ELECTRIC PONER SYSTEMS FOR NUCLEAR POWER PLANTS FSAR 1. 9. 75 PHYSICAL RG 1.75 REV. 2 9/78 I E SEE SECTION 7.1.2.2 160 INDEPENDENCE OF ELECTRIC SYSTEMS FSAR 1. 9. 75 PHYSICAL IEEE 384-1974 X X 162 INDEPENDENCE OF ELECTRIC SYSTEMS FSAR 3. 1. I CONFORMANCE WITH NRC 10CFR50 APP. A. GDC 3 X 789 CENERAL DESIGN CRITERIA. OVERALL REQUIREMENTS i FSAR 3. 1. I CONFORMANCE WITH 10CFR50 APP. A. GDC 2 X 4114 i NUCLEAR REGULATORY COMMISSION GENERAL ! DESIGN CRITERIA. t OVERALL 2 REQUIREMENTS. , l 4 s _.___._______m__.-___.____._._ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. . -- s-- -
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COMMITMENT COMMITMENT COMMITMENT DOCUMENT / RESPONS IBILITY REMARKS REF NO SOURCE SECTION SUBJECT FEATURE DESIGN CON 8T
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FSAR 3. 1. 1 CONF 0$MANCE WITH 10CFR50 APP. A. GDC 4 I 4115 NUCLEAR REGULATORY COMMISSION GENERAL DESIGN CRITERIA. OVERALL REQUIREMENTS. FSAR 3. 1. 1 CONFORMANCE WITH 10CFR50 APP. 4 GDC 5 E 4116 NUCLEAR REGULATORY COMMISSION GENERAL DESIGN CRITERIA. OVERALL REQUIREMENTS FSAR 3. 1. 2 PROTECTION BY 10CFR50 APP. A. GDC 17 I 4118 MULTIPLE FISSION PRODUCT BARRIER 8 FSAR 3. 1. 3 CONFORMANCE WITE NRC 10CFR50 APP. A. GDC 22 I 804 GDC. PROTECTION AND , REACTIVITY CONTROL 21; "1 7. ' SYSTEMS iOT mv FSAR 3. 1. 3 CONFORMANCE WITE NRC 10CFR50. APP. A. GDC 24 I 806 GDC PROTECTION AND REACTIVITY CONTROL SYSTEM 5 FSAR 3. 7.B. 3.12 SURIED SEI5MIC BC-TOP-4A CBAFTER 6 E 1019 CATEGORT I PIPING ENGINEERING ANALYSIS 5YSTEMS AND TUNNELS FSAR 3. 7.B. 3.12 BURIED SEISNIC BURIED ELECTRICAL DUCT BANE 8 E 1020 CATEGORY I PIPING CONTAIRING CLASE lt SYSTEMS AND TURNELE ELECTRICAL CIRCUITS ARE DESIGNED TO NEET SEISMIC CAYR90RT I RROUIREMENTS FSAR 3. 7.B. 3.12 BURIED SEISMIC DUCT BARES ARE PROVIDED WITH E 1021 CATEGORY I PIPING A SEISMIC SEPARATION AT SYSTEMS AND TUNNELS STRUCTURE. MANROLE. AND INTERSECTION INTERFACE. O O O O O O O
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COMMITMENT COMMITMENT COMMITMENT DOCUMENT / RESPONS IBILITY REMARES REF NO SOURCE SECTION SUBJECT FEATURE DESIGN CONST
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FSAR 8. 1. 4. 3 DESIGN CRITERIA, 10CFR50, APP.A. GDC 4 X 5EE TABLE 8.1-1 2360 REGULATORY GUIDES AND IEEE STANDARDS FSAR 8. 1. 4. 3 DESIGN CRITERIA, 10CFR50, APP. A. GDC 5 I 3 REGULATORY GUIDES AND IEEE STANDARDS FSAR 8. 1. 4. 3 DESIGN CRITERIA, RG 1.75, REV. 2 9/78 X X 18 REGULATORY GUIDES AND IEEE STANDARDS " FSAR 8. 1. 4. 3 DESIGN CRITERIA, RG 1.89, 11/74 X 20 REGULATORY GUIDES AND IEEE STANDARDS FSAR 8. 1. 4. 3 DESIGN CRITERIA. IEEE 308-1974 X 27 3 REGULATORY GUIDE 3 1 AND IEEE STANDARDS I FSAR 8. 1. 4. 3 DESIGN CRITERIA. IEEE 384-1974 I X 35 REGULATORY GUIDE 5 AND IEEE STANDARD 5 , FSAR 8. 1. 4. 3 DESIGN CRITERIA, 10CFR50, APP. A. GDC 2 X 95 REGULATORY GUIDE 5
- AND IEEE STANDARDS 3 FSAR 8. 1. 4. 3 DESIGN CRITERIA, 10CFR50, APP.A. GDC17 X SEE TABLE 8.1-1 2352 REGULATORY GUIDES AND IEEE STANDARDS FSAR 8. 3. 1. 4 CABLE DERATING AND CONTROL AND INSTRUMENT CABLE X 73
- CAELE TRAY FILL TRAY DESIGN FILL IS 40 PERCENT OF THE AREA 0F TRE TRAY BRING USED.
FSAR 8. 3. 1. 4 CABLE DERATING AND LON TOLTAGE PONER TRAYS ARE X 74 CABLE THAT FILL LIMITED TO A FILL OF 30 PERCENT OF THE AREA 0F A 3 j IN. LOADING DEPTH TRAY. 1 4 1 1
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FSAR 8. 3. 1. 4 CABLE, ROUTING WITRIN THE CABLE SPREADING I X 76 ROOMS, CONTROL ROOM AND SBUTDONN ROOMS, THE MINIMUM TERTICAL SEPARATION FOR OPEN TOP CABLE TRAT IS 3 FT., AND THE MIMIMUM ROBIZONTAL SEPARATION 18 1 FT. FSAR 8. 3. 1. 4 CABLE ROUTING TBE MINIMUM SEPARATION I X 77 DISTANCE BETWEEN ENCLOSED RACBWAT8 QUALIFIED AS d BARRIER 5 15 1 INCE. FSAR 8. 3. 1. 4 CABLE ROUTING THE MINIMUM SEPARATION DIST. X X 78 BETWEEN NON-CLA85 IR CONDUIT (INCLUDING ALUM. OR COPPER-5REATHED CABLE) AND class IE OPEN TOP CARLE TRATS 15 1 I NCE.- .. - .- FSAR 8. 3. 1. 4 CABLE ROUTING WITRIN GENERA A5 I I 79 TER MINIMUM FB BIPARATIDW 18 5 FT. AND THE MINIMUM NORIEONTAL IS 3 FT. FOR CPEN TOP C,ABLE TRAY. FSAR 8. 3. 1. 4 CABLE ROUTING WHERE SPATIAL SEPARATION I I 84 REQUIREMENTS BETWEEN RACEWAY 5 OF BIFFERENT SEPARATION GROWPS ARE NOT MEY. FIRE BARRIERS ARE INSTALLEB. FSAR 8. 3. 1. 4 CABLE ROUTING WHERE RACEWAT8 OF DIFFERENT X X 85 SEPAR. GROUP 8 ARE BROUGHT TO A SINGLE EWCL., SEPAR. I5 ACCOMPLI 5 RED ST THE USE OF CONBUIT ROUTED IN OPPO5ITE DIRECTIONS FROM THE ENCL.. USING THE ENCL. A5 A BARRIER. i O O O O O O O
O O O O O O O PaBe No. 5 i 01/24/86 COMMITMENTS
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SEPARATE TRATE ARE P907IDED I 86 FSAR 8. 3. 1. 4 CABLE. ROUTING FOR EACE YOLTAGE BERVICE LETEL, 13.857,4.18ET,480V, 130Y AC AND 125V DC, CONTROL AND INETRUMENT. CORBUITE RUWWING BETWEEN I I 88 FSAR B. 3. 1. 4 CABLE ROUTING ETRUCTURRE ARE EITRER CONNECTED WITE A MIN. OF 2 FT. OF FLEEIBLE CONDUIT OR ' ARE PROVIDED WITE EEPANEION/BEFLECTION FITTINGS. RG 1.75 RET. 2 9/78 I 90 FSAR 8. 3. 1. 4 FIRE PROTECTION ANSI M45.2.4-1972 (IEEE X X 2968 FSAR 17A. O INTRODUCTION 336-1971) SEPARATION OF CLASS RG 1.75, REY. I' X X RESPONSE TO 4327 NRC QUEST. 0430. 75 QUESTION. CORRES. IE CABLES IN CONDUIT "Y ^~~ FROM NON-CLASS lE CABLES IN TRAT AT LEAST l-INCE SEPARATION I I RESPONSE TO QUESTION 4900
- NRC QUEST. 0430. 75 SEPARATION OF l
CORRES. ELECTRICAL CIRCUITS IS MAINTAINED BETWEEN TEE ! BARRIER AND THE CABLE TRAT LOCATED ABOYE OR TO THE SIDE OF IT QUALIFICATION FOR RG 1.89, RET. O, 11/74 I SEE FSAR 3.11.B 4958 FSAR 1. 9. 89 CLASS lt EQUIPMENT RG 1.100, REY. 1, 8/77 I 22 FSAR 8. 1. 4. 3 DESIGN CRITERIA REGULATORT GUIDES AND IEEE STANDARDS RG 1.100 REV. l.,8/77 I SEE FSAR 3.10.B.2 175 l FSAR 1. 9.100 SEISMIC CUALIFICATION OF CLASS lE ELECTRIC EQUIPMENT i
..-.._._..._.._....m..m.m. -
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FSAR R. 1. 4. 3 DESIGN CRITERIA. IEEE 323-1974 X 29 REGULATORY GUIDES AND IEEE STANDARDS FSAR R. 1. 4. 3 DESIGN CRITERIA. IBBB 344-1975 I 32 REGULATORY GUIDES AND IEEE STANDARDS e O O O O O O O
__. . . - - - -- . - . - ~ _ - . . . - - . - -- -- .--.--- . . . .- - - ~.-. - i i 1 i a 1
- j. 3.5 IMPLEMENTATION MATRIX i .
. . ~
After the commitments are identified, each team reviews the j . documents controlling its areas of responsibility to verify l compliance with commitment requirements. The depth of verification is to the level of detail stated in the commitment ! matrix. i O-I a i i i 1 l j . i ! .)
- j. :
. 1 lO a t 1 i 1 i ) !,O 1 i 5 : 4 i i i LO n j 0028q/027-6 i i l i i 5 !
}
s____ ____ _ __ .. _ .__ _. _ .. . , _ . _ . - _ . _ _ . . _ - _ _ _ . _ _ . . . _ . . _ . . . _ _ , , _ , . , _ , _ _
O C O lWLEENTATION SORTED BY KFEENCE IANGER 00CUENT/ FEATURE SECTION PEDULE DESIGN LAST DESIGN FIRST O(BIST LAST CONST FIRST EIWES EF NO. EMPUWIATION OF FIELDS 00CUENT/ FEATURE - The document discussed in the FSAR section or the plant feature described in the FSAR section. (See Commitment Matrix.) SECTION - The section of the document / feature that is being discussed MODULE - The Readiness Review modules applicable to the section under discussion j DESIGN LAST, , . CONST LAST - "Last" indicates the project document currently containing the Information found in the conenitment
- DESIGN FIRST, -
, CONST FIRST - "First" indicates the project document that contained the information found in the comitment when the a , ettwities governed by the document first began. i i REF NO. - A reference number that corresponds to the appropriate line entry in the comitment matrix. i i 1 1 1 4 t 2 { 0100g/315-6 } 4
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DC-1000-E, REY. DC-1000-E, REY. 3.00 10CFR50, APP.A. GDC 5, (F5AR 8.1.4.3)-PG.8.1-5 5. 4-3-84 -C.5. 2 12-13-77
. DC-1001 REY. 1 -C.8 DC-1001 8-30-83 -C.S RET. 1, 8-30-83 i DC-1810 REV. 6 -C.S DC-1810, 10-3-83 -C.5 WEV. 6, 10-3-83
-C.S DC-1000-E, REV. X3AR01-58 RET. E3AR01-88, REY. 18.00 RG 1.75 RET. 2 SEPT. DC-1000-E. REV.
1978 (FSAR 8.1.4.3, PG 5, 4-3-84, 2, 12-13-77, 17 (ATT. 3), 5 (ATT. 8).
-C.5.. DC-1001. -C.S. DC-1001, 6-5-85 6-11-81 8.1-6)
REV. 1. 8-30-83 REY.~1. 8-30-83
-C.5 BC-1809 -C.S. DC-1809 e -
RET. 4, 1-21-82 REY. 2
-C.5 DC-1810, 12-20-74, -C.S REY. 6, 10-3-83 BC-1810 REY. 2
-C.5 11-10-77 -C.5 DC-1000-5, REY. DC-1000-5, REV. SEE FINDING 20.00 RG 1.89 NOV. 1974 (F8AR 17-20 ITEMS 5, 4-3-84, 2, 12-15-77 8.1.4.3)-PG 8.1-6 1 AND 2
-C.S.. DC-1007 -C.5., DC-1997 REY. 4 4-30-85, REV. O, 6-8*79,
-C.S. -C.S.
RG 1.100 REV. 1, AUG. 1977 DC-1000-5, REV. DC-lOOO-E. REY. SEE FINDING 22.00
- 5. 4-3-84, 2 12-13-77, 17-20 ITEMS (FSAR 1.900, 8.1.4.3)
-C.S.. DC-1005, -C.5.. DC-1005, 1 AND 2 REV. 1, 4-4-85 RET. O. 3-10-80,
-C.S. -C.S.
DC-1000-E, REY. DC-1000-E, REV. 27.00 IEEE 308-1974 (FSAR 8.1.4.3) -PG 8.1-77 5 4-3-84, 2, 12-13-77
-C.S., DC-1810,
-C.S., DC-1810 REV. 6, 10-3-83 REY. 1
-PG.1 12-20-74, -PG.1 3
DC-1000-E. RET. DC-1000-E, REY. SEE FINDING 29.00 i IEEE 323-1974 (FSAR 17-20 ITEMS 8.1.4.3) -PG 8.1-7 5, 4-3-84, 2, 12-13-77,
-C.S.. DC-1007, -C.S.. DC-1007, 1 AND 2 REY. 4 4-30-85 REY. O. 6-6-79
-C.Ss -C.S.
t 4
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SECTION DESIGN LAST DESIGN FIRST CONST LAST CONST FIRST REMARES REF NO DOCUMENT / FEATURE
==========e========= ==== ======= ================ ================ ================ ================ ====== ====== ========
IEEF 344-1975 (FSAR DC-1810 REY. 6. DC-1810 REV. 2 SEE FINDING 32.00 8.1.4.3) -PG 8.1-8 10-3-83 -PG.I. 11-10-77 -PG.2 17-20 ITEM 2 DC-1000-E. REV. DC-1000-E. REV. 5 4-3-84, 2 12-13-77
-PG.14 DC-1005 -PG.7 DC-1005 REV. 1 4-4-85 REY. O. 4-4-85
-PG.5A -PG.5A IEEE 384-1974 (FSAR DC-1000-E. REV. DC-1000-E. REV. I3AROI-E8 REV. I3AR01-E8 REV. SEE FINDING 35.00 8.1.4.3) -PG 8.1-8 5 4-3-84, 2 12-13-77, 17 (ATT. B). 5..(ATTACHMENT 17-20 ITEM 4
-PC.15 DC-1001 -PG.7 DC-1001, 6-5-85 B), 6-11-81 REV. 1 8-30-83 REV. 1 8-30-84
-PG.2 DC-1809 -PG.2 DC-1809 REV. 4 1-21-82 REY. 3 2-6-78
-PG.1 DC-1810 -PG.1 DC-1810 REV. 6 10-3-83 REV. 4 11-26-80
-PG.1 -PG.1 CABLE TRAT FILL: CONTROL DC-1810 RET. 6 DC-1810 REY. 4, 73.00 AND INSTRUMENT CABLE TRAT 10-3-83 -PG.7 Il-26-80.PO.6 DESIGN FILL IS 40 PERCENT PAR.D PAR.D OF THE AREA OF THE TRAY BEING USED (FSAR 8.3.1.4) .
-PG 8.3.1-31 CABLE TR AY FILL: LOW DC-1810 REV. 6 DC-1810 REV. 2 74.00 VOLTAGE POWER TRATS ARE 10-3-83 -PG.7 11-10-77 -PG.4 LIMITED TO A FILL OF 30 PAR.D PAR.D PERCENT OF TER AREA OF A 3 INCR LOADING DEPTR TRAY (FSAR 8.3.1.4) -PG 8.3.1-31 WITHIN TRE CABLE SPREADING SEE REMARES E3AR01-E8 RIV. E3AR01-EB. RET. DESIGN 76.00 ROOMS. CONTROL ROOM AND 17 (ATTACRMENT 5 (ATTACEMENT IMPLEMENTED SHUTDOWN ROOMS. THE MIN B). 6-6-85 B). 6-11-81 VIA IEEE 384.
VERTICAL 8EPARATION FOR SEE REF. No. OPEN TOP CABLE TRAY IS 3 35. FT. AND THE MIN HORIZONTAL SEPARATION IS 1 FT. (FSAR 8.3.1.4) -PG 8.3.1-31 O O O O O O O
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TRE MINIMUM SEPARATION SEE REMARES K3AR01-58 REV. 13A301-58 REV. DESIGN 77.00 DISTANCE BETWEEN ENCLOSED 17 (ATTACRMENT 5 (ATTACRMENT IMPLEMENTED RACEWATS QUALIFIED AS B), 6-15-85 B), 6-11-81 VIA IEEE 384. BARRIERS IS 1 INCH. (FSAR SEE REF. 35. 8.3.1.4) -PG 8.3.1-31 WALEDOWN OF RACRWATs 2/84 TO IDENTIFT ALL CASES. FSBR'S
- ORIGINATED. ;
THE MINIMUM SEPARATIOM DC-1810, REV. 6, X3AR01-88, REY. X3AR01-58 REV. X3AR01-E8, REV. CONSTRUCTION 78.00 DISTANCE BETWEEN MON-CLASS 10-3-83 -PG.4 5 (ATTACHMENT 17 (ATTACBMENT 5 (ATTACRMENT WALIDOWN OF IE CONDUIT (INCLUDING PAR.E B), 6-11-81, B), 6-5-85 B), 6-11-81 RACEWATS ALUM. OR COPPER-SEEATRED PG.B-9 2/84. 168 , CABLE) AND OPEN TOP CLASS FSBR'S lE CABLE TRATS IS 1 INCR. WRITTEN FROM l (FSAR 8.3.1.4) -PG WALEDOWN. 8.3.1-32 WITHIN GENERAL PLANT SEE REMARKS X3AR01-E8, REV. I3AR01-E8, REV. DESIGN 79.00 , AREAS. THE MINIMUM 17 (ATTACRMENT 5 (ATTACRMENT IMPLEMENTED i VERTICAL SEPARATION IS 5 B), 6-5-85 B), 6-11-81 VIA IEEE 384. FT. AND THE MINIMUM 885 REF. NO. 4 HORIZONTAL SEPARATION IS 3 35 i FT. FOR OPEN TOP CABLE
- TRAT. (FSAR 8.3.1.4) -PG 8.3.1-32 I
t WHERE SPATIAL SEPARATION SEE REMARKS N3AR01-EB, REV. 13AR01-E8, REV. DESIGN 84.00 ) REQUIREMENTS BETWEEN 17, 6-5-85, 5, ATTACRMENT B, IMPLEMENTED i RACEWATS OF DIFFERENT ED-T-02, REV. 7, 6-11-81 VIA IEEE 384. SEPARATION GROUPS ARE NOT 12-19-84 ED-T-02, REV. 5 SEE REF. NO. MET, FIRE BARRIERS ARE 9-26-83 35. RACEWATS INSTALLED. (FSAR 8.3.1.4) INSTALLED c
-PG 8.3.1-33 PRIOR TO
! 2/84. - WALEDOWN AND } FSBR'S ORIGINATED AS i . NEEDED. f ? 1 i i
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DC-1810 REV. 6 DC-1810, REV. 4 23AR01-58 REV. 23AR01-E8 REV. 85.00 WHERE RWAYS OF DIFFERENT SEP GROUPS ARE BROUGHT TO 10-3-83 -PG.3 11-26-80 -PG.2 17 (ATTACRMENT 5 (ATTACHMENT A SINGLE ENCL., SEP IS PAR.2 PAR.A2 B). 6-5-85 B). 6-11-81 ACCOMPLISHED BY THE USE OF CONDUlf RTD IN OPPOSITE DIR FROM THE ENCL. USING THE ENCL AS A BARRIER.(FSAR 8.3.1.4)-PG8.3.1.33 DC-1810 REV. 6 DC-1810 REV. 4 86.00 CABLE ROUTING: SEPARATE TRAYS ARE PROVIDED FOR 10-3-83 -PG.6 11-26-80 -PG.6 EACH VOLTAGE SERVICE PAR.3.2.2A PAR.3.2.2A LEVEL: 13.8EV. 4.16EV. 480V. 120 VAC AND 125 VDC CONTROL. AND INSTRUMENT (FSAR 8.3.1.4) -PG 8.3.1-33 DC-1810 REV. 6 CX3DF002 REV. CI3DF002 REY. CI3DF002 REV. 88.00 CONDUITS RUNNING BETWEEN STRUCTURES A~E EITHER 10-3-83, -PG.1 2 9-25-81, 12, 3-25-85 2 9-25-81 CONNECTED WITH A MIN. OF 2 PAR.3.1.lB -DET.12 CI3DF003 REY. CI3DF003 REY. FT. OF FLEX 1BLE CONDUIT OR CI3DF003 REV. 10, 8-9-84 1. 6-1-79 ARE PROVIDED WITH 1 6-21-79 EXPANSION / DEFLECTION -DET.7 FITTINGS. (FSAR 8.3.1.4) PG B.3.1-34 REV. 2 SEPT. SEE REMARES SEE REF. NO. 90.00 RG 1.75 1978 (FSAR 8.3.1.4) -PG 18 FOR DESIGN 8.3.1-33 IMPLEMENTATIO N 10CFR50, APP.A, GDC 2 DC-1000-E. REV. DC-1000-E. REV. 95.00 (FSAR 8.1.4.3) -PG 8.1-5 5, 4-3-84 -C.8 4 9-20-83 -C.S DC-1000-C. REV. DC-1000-C. RET. 3 9-30-83. -C.S 1 11-22-77 DC-1005. REV. 1. -C.S DC-1005 4-4-83 -C.8 RET. 1 4-4-83 DC-1810 REV. 6 -C.S DC-1810 10-3-83 -C.S REV. 6 10-3-83
-C.S O O O O O O O
s Paga No. 5 01/24/86 IMPLEMENTATION t
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=============== == ====================
l DOCUMENT / FEATURE SECTION DESIGN LAST DESIGN FIRST CONST LAST CONST FIRST REMARKS REF NO I
==================== =======--=== ================ ================ ================ ================ ============= ========
l IEEE 279-1971 (FSAR DC-1000-E. REY. DC-1000-E. REV. 108.00 I 1.2.12.1) -PG 1.2.12-3 5, 4-3-84, 2 12-13-77
- -PG.13 DC-1001 -PG.7 DC-1001, REV. 1 8-30-83 REV. O. 1-24-78,
- -PG.1 DC-1009 -PG.1 DC-1009
- REY. 2, 6-3-83 REY. 1, 3-12-81, f
-PG.1 -PG.1 RG 1.32, REV. 2 FEB. 1977 DC-1000-E. REV. DC-1000-E, REY. SEE FINDING 131.00 (FSAR I.9.32) -PG.I.9-27 5, 4-3-84 -C.S. 2 12-13-77, 17-20 ITEM 3
-C.S.
- IEEE 308-1974 (FSAR SEE REMARKS SEE REF. NO. 132.00 1.9.32) -PG 1.9-27 27 FOR DESIGN IMPLEMENTATIO N
10CFR50, APP.A. GDC 17 DC-1000-8, REY. DC-1000-E, REV. 133.00 (FSAR 1.9.32) -PG 1.9-27 5 4-3-84 -C.S. 2, 12-13-77 DC-1001, REY. 1 -C.S DC-1001, 8-30-83 -C.S REV. O, 1-24-78 DC-1009 REV. 2 -C.S DC-1009, , 6-3-83 -C.S NEv. O, 3-23-77 DC-1809 REV. 4 -C.S. DC-1809, 1-21-82, -C.S REV. 2 DC-1810 REV. 6, 12-20-74, -C.S. 10-3-83 -C.S. DC-1810 REV. 2, 11-10-77 -C.S. L RG 1.75 REV. 2 SEPT. SEE REMARES SEE HEMARKS SEE REF NO. 160.00 1978 (FSAR 1.9.75) -PG 18 1.9-64 IEEE 384-1974 (FSAR SEE REMARKS SEE REMARKS SEE REF. NO. 162.00 1.9.75) -PG 1.9-64 35. RG 1.100 (FSAR 1.9.100) SEE REMARES SEE REF. No. 175.00
-PG 1.9-78 22 FOR DESIGN
.IMPLEMENTATIO N
+
_ _ _ _ _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ __m o._.___________m__ _ _ _ _ _ - .,. ,._.m . , - - - - - - - -
--e.-
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10CFR50 APP. A, GDC 3 DC-1000-E, Rh?. DC-1000-E, REV. 789.00 (FSAR 3.1.1) -PG 3.1-3 5 4-3-84 -C.S. 2, 12-13-77 , DC-1810 REV. 6 -C.S. DC-1810, 10-3-83 -C.S. REV. 6, 10-3-83
-C.S.
10CFR50 APP.A. GDC 22 DC-1000-E. REY. DC-1000-E. REY. 804.00 (FSAR 3.1.3) -PG 3.1-17 5, 4-3-84 -C.S. 5, 4-3-84 -C.S. DC-1001 REY. 1 DC-1001 REV. O. B-30-83 -C.S. 1-24-78 -C.S 10CFR50, APP.A. GDC24 DC-1000-E, REV. DC-1000-E. REV. 806.00 (FSAR 3.1.3) 5 4-3-84 -C.S. 5, 4-3-84 -C.S. DC-1001, REY. 1 DC-1001 REV. O, 8-30-83 -C.S. 1-24-78 -C.S. DC-1810 REV. 6 DC-1810 REV. 2, 10-3-83, -C.S. 11-10-77 -C.S. ENCINEERING ANALYSIS FOR DC-1000-C. REY. DC-1000-C, REY. 1019.00 THE DESIGN OF DUCT BANES 3 9-30-83, 3, 9-30-83 IS BASED ON THE BURIED -PG.44 PAR.6.5 -PG.44 PAR.6.5 STRUCTURE ANALYSIS PROCEDURES OUTLINED IN CHAPTER 6 OF BC-TOP-4A (FSAR 3.7.B.3.12) -PG 3.7.8.3-6 DESIGN OF DUCT BANES: DC-1000-C, REY. DC-1000-C, REV. 1020.00 BURIED ELECTRICAL DUCT 3 9-30-83, 3, 9-30-83, B ANES CONTAINING CLASS lE -PG.44 PAR.6.5 - PG. 4 4 PAR. 6. 5 ELECTRICAL CIRCUITS ARE DC-1810 RIV. 6 DC-1810 REV. 5 DESIGNED TO MBET SEISMIC 10-3-83 -PG.5 12-4-81 -PG.5 CATEGORT I REQUIREMENTS {FSAR 3.7.B.3.12) -PG 3.7.8.3.6 DESIGN OF DUCT BANES: DUCT DC-1000-c REV. DC-1000-c. REV. 1021.00 BANES ARE PROVIDED WITH A 3, 9-30-83, 3 9-30-83, SEISMIC SEPARATION AT -PG.44 PAR.6.5 -PG.44 PAR.6.5 STRUCTURE. MANNOLE, AND DC-1810 REV. 6 DC-1810 REV. 6 INTERSECTION INTERFACES 10-3-83, -PG.5 10-3-83 -PG.5 (FSAR 3.7.B.3.12) -PG 3.7.B.3-6 O O O O O O O
.. ..m.. < ... . . . . . . . .___m. _.m.. ._.s._ . . . .
s - P a g s- No. 7 J G 01/24/86 , IMPLEMEi:TATION
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=.3====================================
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=================== ============ ================ ============e=== ================ ================ ============= ========
10CFR50 APP.A. GDC 17 SEE REMARES SEE REF. NO. 2352.00 (FSAR 8.1.4.3) -PG 8.1-5 133 FOR DESIGN IMPLEMENTATIO N 10CFR50 APP.A. GDC 4 DC-1000-E, RET. DC-1000-E. REY. 2360.00 (FSAR B.1.4.3) -PG 8.1-5 5. 4-3-84 -C.S. 4 9-20-83 . DC-1001 REV. 1 -C.S. DC-1001, 8-30-83. -C.S. REY. O. 1-24-78 DC-1003 REV. 2 -C.S. DC-1003 6-2 9- 8 3. - C . S . REV. O. 1-12-78 DC-1006, REY. 2 -C.S. DC-1006, 7-13-83, -C.S. REV. O. DC-1018 REY. 2, 12-19-77 -C.S. 10-11-83 -C.S. DC-1018 RET. O. DC-1810 REV. 6 12-13-77 -C.S. 10-3-83 -C.S. DC-1810 REY. 6 10-3-83 -C.S. ANSI N45.2.4-1972 (IEEE X3AR01-E8 REV. X3AR01-E8 REY. ED-T-02 REY. 7 ED-T-02 REV. 5 2968.00 STD. 336-1971) (FSAR 17, 6-5-85 10, 8-26-83 12-19-84 9-26-83 17A.0) -PG 17A-3 10CFR50 APP.A. GDC 2 SEE REMARES SEE REF. NO. 4114.00 (FSAR 3.1.1) -PG 3.1-2 95 10CFR50 APP.A. GDC 4 SEE REMARES SEE REF. NO. 4115.00 (FSAR 3.1.1) -PG3.1-4 2360 10CFR50 APP.A. GDC 5 SEE REMARES SEE REF. NO. 4116.00 (FSAR 3.1.1) -PG 3.1-5 3 10CFR50 APP.A. GDC 17 SEE REMARES SEE REF. NO. 4118.00 (FSAR 3.1.2) -PG 3.1-11 133 RG l.75 REV. 2 SEPT. SEE REMARES SEE REMARES SEE REF. NO. 4327.00 1978 (FSAR Q430.75) 18 -VOL.34 MAT 31 1984 -PG 0430.75-4
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AT LEAST l-INCH SEPARATION SEE REMARKS SEE REMARES IMPLEMENTED 4900.00 IS MAINTAINED BETWEEN THE VIA IEEE 384. BARRIER AND THE CABLE TRAY SEE REF. NO. LOCATED ABOVE OR TO THE 35. SIDE OF IT (FSAR Q430.75)
-VOL.34 MAY 31, 1984 -PG Q430.75-4 RG 1.89 REV. O 11/74 (FSAR SEE REMARKS SEE REF. NO. 4958.00 1.9.89) -PG.1.9-71 20 i
i e t 4 1 4 4 -l 9 9 9 9 9 9 9
r l l l ~ 4.0 PROGRAM DESCRIPTION These sections describe the work process followed for each step in the design and construction of electrical raceways. The sections contained within this program description are intended to describe the control mechanisms in place to ensure the O- quality and integrity of the completed raceways. These sections have been reviewed for accuracy and are believed correct. Differences between this section and actual practice, if any, are unintentional. The program for the design, procurement, and construction is described in detail in the following sections: o 4 .1 - Design. o 4.2 - Procurement. 1 o 4.3 - Site Material Control l l o 4.4 - Installation and Inspection. These sections coupled with the general appendixes will expand on certain phases of the operation as they apply. 1C) l O 0037q/020-6
(" 4.1 DESIGN (s This section describes the preparation, control and review, and l change control of Class ,lE raceway design documents. I The preparation and revision of the Design Criteria, drawings, and other design documents is illustrated by the simplified flow {)} (m diagram presented in Figure '4.1-1. Design criteria were l prepared to provide the bases from which the raceway design is l controlled. Calculations and analyses were performed to l evaluate design alternatives, determine required raceway l parameters, and verify design adequacy. Drawings,
] specifications, and reports were prepared to facilitate
( ('_) 1 construction, procurement, and licensing activities, as well as subordinate engineering design functions. 4.1.1 DESIGN CRITERIA This section covers the criteria documents that govern the Southern Company Services (SCS) and Bechtel Power Corporation (BPC) design of electrical raceways. Design criteria were initially provided in the Preliminary Safety Analysis Report (PSAR) which was prepared by BPC and submitted to the Nuclear Regulatory Commission (NRC) in August 1972. Subsequently, detailed design criteria were developed and issued as part of ( the design manual. Sources of design bases, included and. referenced in the criteria, were derived from data provided by Georgia Power Company (GPC), SCS, the Nuclear Steam Supply System (NSSS) vendor (Westinghouse), turbine-generator supplier, other equipment suppliers, NRC [ regulations, regulatory guides, Inspection and Enforcement (IE) bulletins, etc.], industry standards, BPC design guides / standards, and licensing commitments. l The criteria contained in the design manual are organized into sections as follows: I o General Plant Criteria. The General Plant Criteria were issued as the Physical Plant Design Criteria on December 12, 1974. This document provides the overall plant physical protection, as well as maintenance and 1 serviceability criteria. r ( The protection criteria provide acceptable design bases for the protection of systems and equipment important to safeguard against postulated events or hazards. j The maintenance and serviceability criteria define the i t f- design bases pertinent to the development of the general plant arrangement. l
o Interdiscipline Design Criteria. The Interdiscipline Design Criteria provide design bases having multidiscipline applicability. Table 4.1-1 lists the interdiscipline design criteria applicable to this module and the initial issuance date. o Discipline General Design Criteria. The General Electrical and Civil / Structural Design Criteria (DC-1000-E and DC-1000-C) were first issued on June 12, 1973, and February 28, 1974. The electrical criteria summarizes the principal functions and safety design bases pertaining to the functional and physical parameters of electrical raceway design. The civil / structural criteria provides bases for the structural design of underground duct banks. g o System Design Criteria. The System Design Criteria provides detailed criteria (e.g., principal function, safety design bases, etc.) for each plant system. Table 4.1-2 lists the system design criteria applicable to this module, the material covered, and the initial issuance date. 4.1.2 DRAWINGS AND DOCUMENTATION Based on the established design criteria and BPC design guides / standards, drawings and documentation were prepared to describe the design in detail sufficient to facilitate subordinate engineering, fabrication, and installation functions. This section describes the drawings and documentation specifically prepared for electrical raceways covered by this module. 4.1.2.1 Calculations and Hazard Analyses 1 4.1.2.1.1 Calculations Calculations for Class lE raceways were prepared to determine electrical raceway and other system design parameters. The design calculations were prepared based on actual conditions (where known; otherwise, conservative conditions were assumed), ) design criteria, actual design drawings, and licensing ' requirements. Input data for the calculations were obtained from plant material suppliers, industry standards, and BPC design guides / standards. Calculations pertaining to raceways covered by this module are summarized in Table 4.1-3. O 4.1-2
i i i 5 , 4.1.2.1.2 Hazard Analyses A basic design objective was to locate Class lE raceways in I nonhazardous areas. Nevertheless, detailed analyses of all i potential hazards have been performed in accordance with the l appropriate interdiscipline design criteria to assure that components required for safe shutdown are not adversely jO affected. Specific analyses were prepared to study the effects of: ' l-i j o High-energy line breaks (pipe whip and jet impingement). o Internally-generated missiles. { o Flooding. o Seismic II/I interaction. Additionally, measures have been taken to assure the continued functioning of required electrical raceways during and after tornados and fires. 4.1.2.2 Drawings Raceway design drawings diagrammatically describe the design of O the plant electrical raceway system. They conform to the project design criteria and complement other project design documents. Drawings applicable to raceways covered by this module include sketches, cable tray layout / support drawings, conduit and tray _ drawings, underground duct bank drawings, and raceway general notes and details drawings. 4.1.2.2.1 Sketches Sketches were generated to identify design concepts, requirements, and configurations. ~ Sketches were not issued or used for fabrication or construction purposes. However. electrical sketches are used with or attached to procurement O specifications, design proposals, studies, etc. Electrical sketches are listed in the sketch control log and numbering system. 4.1.2.2.2 Cable Tray Layout / Supports The cable tray layout / support drawings illustrate the primary channels through which cables are routed to major items of: electrical equipment or areas of heavy concentrations of mechanical equipment. The drawings below level B also show the O locations of cable tray supports. (Supports for level B and 4.1-3
above are shown on civil / structural support location drawings.) The cable tray layouts were developed based on equipment location drawings, one-line diagrams, and vendor information. The cable tray layouts are listed in CEBUS under Electrical Conduit and Tray Drawing Control Log. 4.1.2.2.3 Conduit and Tray l The conduit and tray drawings illustrate the channels through which cables are routed to the various items of equipment and devices. The conduit and tray drawings were prepared based on equipment location drawings, one-line diagrams, and vendor information. The conduit and tray drawings are listed in CEBUS under Electrical Conduit and Tray Drawing Control Log. 4.1.2.2.4 Underground Duct Banks The underground duct bank drawings illustrate the means by which power, control, and instrumentation cables are transported between outlying buildings or areas of the plant. The duct banks are composed of a group of polyvinyl chloride (PVC) conduits encased in a reinforced concrete envelope. The duct bank system also includes the manholes and handholes required for cable pulling. lf The underground duct bank drawings are listed in CEBUS under Electrical Conduit and Tray Drawing Control Log. 4.1.2.2.5 General Notes, Symbols, and Details Drawings The conduit and tray notes, symbols, and details drawings provide the site with generic notes and details applicable to conduit, tray, and duct bank installations. The raceway numbering scheme is also detailed on this set of drawings. These drawings are listed in CEBUS under Electrical Conduit and Tray Drawing Control Log. 4.1.2.3 Procurement Specifications Procurement specifications provide bases for the purchase of equipment and materials. For electrical raceways, bill of material specifications were prepared. This form of procurement . specification lists standard catalog or off-the-shelf type I materials. This document may also be used to define special equipment when the manufacturer routinely modifies a standard 4.1-4
product to meet specific applications. The specifications O conform to the Design Criteria and complement other prcject design documents. Bill of material specifications for raceway / materials covered by this module are listed in Table 4.1-4. 4.1.2.4 ' Construction Specifications Construction specifications define general construction requirements, the scope of work, governing codes and standards, and provide a complete description of the material and tasks to (' be performed. The construction specifications provide specific instructions / requirements for handling and installing electrical raceways at the.jobsite. Table 4.1-5 lists electrical construction specifications applicable to raceways covered by this module. 4.1.2.5 Cable and Raceway Schedule (EE580) The cable and raceway schedule is an online, computerized data base system. It is used by management, engineering, procurement, construction, and startup for design / construction control and material / status tracking. The program accepts, validates, and stores raceway input data such as type, material, () size, tag number, separation group, voltage service level, facility (building), layout drawing number, and connecting raceways / equipment. This raceway data is taken from conduit and tray drawings, and vendor data. The program performs analyses, issues raceway installation cards, and provides reports specifically tailored for the user function / organization. 4.1.3 DESIGN CONTROL AND REVIEW This section covers the design control and review process for electrical raceway design documents, drawings, and the raceway schedule. In addition, the systematic design verification review process is described. Design control and review were performed in accordance with applicable sections of the VEGP Project Reference Manual (PRM), part C. The design documents and drawings for equipment covered by this module were developed by the BPC Home Office Engineering (HOE) electrical discipline under the direction of the O engineering discipline (group) supervisor (EGS). Upon initial preparation and development, the documents / drawings were reviewed by onproject reviewers (other disciplines, Quality Assurance (QA) for Q-class items. Quality Engineering, etc.) to assure proper implementation of project requirements, and offproject reviewers, including the discipline chief engineer, 4.1-5 l
as reguired by the design control check list (DCCL) to assure technical adequacy.(a) Requirements for the Q-list are contained in the VEGP PRM, l part C, section 14. To facilitate description, the design control and review process is divided into two general categories, documents and drawings, with the computerized raceway schedule and design verification review processes separately described. l 4.1.3.1 Document Category The document category includes design criteria, procurement specifications, and construction specifications. These design documents were reviewed and controlled in accordance with the procedures established in the VEGP PRM, part C, sections 3 and
- 20. Figure 4.1-2 illustrates the review and control process.
After initial preparation of a design document, it is distributed for review via the Document Review Notice (DRN) procedure. The reviewer comments and returns the review copy to the originating discipline. The originator resolves / incorporates the comments. An engineer / designer competent to have prepared the document is assigned to check it and to determine whether the technical content is consistent with the design requirements. The checker also ensures that the supporting contents of the design document have been properly identified and are acceptable for release and use. The chief engineer reviews and approves the design document as required by the DCCL. A DRN is used to obtain approval of the chief engineer, if his approval signature is not included as part of the original document. After obtaining all approval signatures, the design document is logged, issued, distributed, and retained by the Project Administration Group. 4.1.3.1.1 Design Criteria The design criteria control and review process was performed in accordance with the procedures established in preface sections 1, 2, and 3 of the Design Manual. The criteria are listed / controlled via the Design Manual list of contents. The Project Administration Group retains (files) and publishes the design criteria. Responsibility for specific design criteria sections is as follows: 1
- a. The DCCL procedure is described in the VEGP PRM, part C, section 20. The DCCL originals are maintained in BPC HOE project file X7BD68.
4.1-6
l o General Plant Criteria. BPC has principal O responsibility for this criteria. i o Interdiscipline Design Criteria. The designation I I number, description, and BPC project discipline having principal responsibility for interdiscipline design criteria applicable to this module are listed in O Table 4.1-1. { o General Electrical and Civil / Structural Design Criteria. These criteria are designated DC-1000-E and DC-1000-C and are the principal responsibility of the r'g BPC Electrical Systems Group and Civil / Structural (_/ Discipline. o Electrical Systems Design Criteria. The designation number, description, material covered, and project group having principal responsibility for electrical system design criteria are listed in Table 4.1-2. I Review of criteria within the BPC project discipline was reviewed by the discipline EGS or group leader having principal responsibility in accordance with the group interface requirements. Review of criteria within the BPC project organization was I i reviewed by the BPC project engineer in accordance with the ! s-discipline / organization interface requirements. VEGP criteria prepared by the BPC electrical or civil disciplines was reviewed by the BPC chief electrical or civil engineer, as required by the DCCL. 4.1.3.1.2 Procurement Specifications The BPC Electrical Systems Group has principal responsibility for the preparation and control of the raceway procurement specifications listed in Table 4.1-4. Procurement specification control and review were performed in accordance with the procedures established in the VEGP PRM, part C. section 8. The project classification number, indicating the quality classification, is shown on the cover i ! sheet and is listed in Table 4.1-4. This VEGP PRM section addresses the procurement specification l( control, review, and approval process. The originating discipline EGS (or designee) was responsible for preparing, coordinating, initiating the review cycle, obtaining all signatures and approvals, issuing the specification, and ,O providing input to the CEBUS specification control log. Procurement specifications are listed in CEBUS under Electrical 4.1-7
Specs / Material Requests (MRs) Control Log. This log includes the specification number, description, current revision number and date, project classification, and procurement control g procedure letter. W 4.1.3.1.3 Construction Specifications The BPC HOE Electrical Systems Group had initial responsibility for the preparation and control of the raceway construction specifiestions listed in Table 4.1-5. Subsequently, control has been transferred to Project Field Engineering (PFE). Construction specification control and review were performed in accordance with the procedures established in the VEGP PRM, part C, section 26. The specification quality classification is indicated by the project classification number shown on the cover sheet, also shown in Table 4.1-5. The referenced VEGP PRM section addresses specification numbering, review, and approval. The originating discipline EGS (Electrical Systems Group) was responsible for initially preparing, numbering, coordinating, initiating the review cycle, obtaining approvals, issuing the specification, and providing input to the CEBUS specification control log. Construction specifications are listed in CEBUS under Electrical Specs /MRs Control Log. This log contains the specification number, description, current revision number and date, and project classification. 4.1.3.2 Drawing Category The drawing category includes calculations and design drawings. Design drawings comprise sketches and drawings. Design drawings were prepared, reviewed, and controlled in accordance with the procedures established in the VEGP PRM, part C, section 4. (The design drawing review and control process is illustrated in Figure 4.1-3.) This process applies specifically to project drawings and sketches, but is also applicable to calculations and analyses. Significant procedural differences are addressed in the following subsections. After preparation, the EGS or designee assigned a checker to g ensure design adequacy and conformance to established design standards. The originator incorporated / resolved the checker W comments which were indicated on a check print. Coordination prints of design drawings requiring the review of other project disciplines / groups were distributed / coordinated via a DRN by the originating discipline. The originating group was responsible for incorporating / resolving comments made by project reviewers. Upon completion of their functions, approvals of the drafter / originator, checker, EGS, chief engineer (for drawings and calculations listed in the DCCL), and project engineer or designee were indicated by initialing the drawing. The project O 4.1-8
l l l engineer and EGS controlled issuance, including numbering, of l() project drawings. Issued drawings were logged in the drawinq control log, reproduced, distributed, and filed by DDC. 4.1.3.2.1 Calculations I () The DPC Electrical Systems Group has principal responsibility for the preparation and control of the raceway design calculations listed in Table 4.1-3. The calculations were controlled and reviewed in acesrdance with the procedures established in the VEGP PRM, part C, section 9. The procedures s address calculation numbering, controlling, format, checking, ,I reviewing and approving, microfilming, and transmitting to GPC. l The quality classification of the calculation is shown on the l title sheet. For electrical calculations, this entry is the three-digit project classification number. (The raceway calculation numbers are listed in Table 4.1-3.) The electrical discipline EGS assigned the calculation numbers and provided input to, and maintained the CEBUS calculation control log. The design calculation control, review, and approval process is similar to that for drawings; although the forms and format are different as shown in the VEGP PRM. Project Administration microfilms and files the originals of calculations. Electrical calculations are listed in CEBUS under Electrical Calculation Control Log. l This log lists the calculation number,
'N
! description, current revision number and date, project i classification, system number, and approval level required. 4.1.3.2.2 Sketches Engineering sketches were prepared by BPC. Sketch control and review were performed in accordance with the procedures established in the VEGP PRM, part C, section 4, subsection 4.3. This section addresses review, approval, issuance, distribution, I filing, and numbering of sketches. The originating discipline EGS or designee coordinated, approved, and issued sketches. Drawing and Data Control (DDC) input issue dates, distributed and filed sketches, and maintained the sketch control log and () numbering system, which lists electrical raceway sketches in the Electrical Design Section. This list includes the sketch number, title, current revision number, and date. 4.1.3.2.3 Drawings O Design drawing control and review were performed in accordance with the VEGP PRM, part C, section 4. This section addresses numbering, review, approval, issuance, distribution, and filing of drawings. The originating discipline EGS or designee was g- responsible for the preparation, numbering, coordination, () review, and issuance of drawings. In addition, the EGS or I 4.1-9
designee also provided input to the CEBUS drawing control log. DDC ertered issuance dates and distributed and filed the drawings. Drawings describing Q-list items were identified with the letter "Q" . In addition, Class lE electrical drawings were W marked NUCLEAR SAFETY RELATED. The markings were located in the lower right-hand corner of the drawing directly above the title block. These drawings were prepared and controlled by the electrical physical design group. They were checked in accordance with the appropriate electrical group checklist (reference BPC IOM Log No. BB 33958, File No. X3BK14). Coordination prints were reviewed as applicable, by t he Plant Design. Mechanical, Nuclear, and Civil / Structural disciplines, and by the Electrical Circuit and Raceway (EE580) and Control Wiring Groups. The plant Design and Mechanical disciplines reviewed the prints for interference with piping and heating, ventilation, and air-conditioning (HVAC) duct systems. The Nuclear discipline reviewed the prints for hazards interface. The Civil / Structural discipline was responsible for raceway support design, duct bank structural design, and coordination of blockouts and core drilling. The EE580 group reviewed raceway routing and sizing, and was responsible for tray sectionalizing and numbering. The control wiring group reviewed the location of junction boxes. Upon incorporation / resolution of comments, the drawings were approved for issue by the Physical Design and EE580 Groups, and by the electrical EGS. Tray layout drawings depicting supports and underground duct bank drawings were also approved for issue by the Civil / Structural discipline. The drawings are listed in CEBUS Electrical Conduit and Tray Drawing Control Log. The log h contains the drawing number, description, current revision number and date, quality classification, and drawing change notice status. 4.1.3.3 Cable and Raceway Schedule (EE580) The computerized EE580 data base was set up and controlled by the circuit and raceway schedule group. Upon issuance of a conduit and tray drawing, the raceway data was input into the EE580 program data base by the circuit and raceway group. The computer analyzed the data as it was being input into the data base and generated an input response report. This report was reviewed by the EE580 group and appropriate corrective action was taken. Raceway records with complete and verified information in the data base were assigned an engineering release (ER) status by the program. 4.1.3.4 Design Verification Reviews O Design verification reviews (DVRs) were systematically performed to assure that equipment, systems, and structures wece properly e i l 4.1-10 l
! l l designed and that the designs were properly coordinated. They ; j were performed by BPC in accordance with the criteria j l established in the Design Manual, preface section 4. These ' criteria provide guidance supplemental to the VEGP PRM, part C, section 20, design review procedure. The Design Manual i criteria defines the review procedures including requirements l establishing the division of responsibility for preparing and j reviewing DVR packages, requirements for design review meetings, and requirements for the report documenting the design review. Generally, only safety-related electrical systems were subject to design verification reviews. The system 1810, Raceways
- Systems, review package was prepared by the Electrical Systems Group. The package consisted of design criteria, pertinent PSAR l (f,)
g and Final Safety Analysis Report (FSAR) sections, and cable tray layout drawings. The review was performed by the chief electrical engineer, nuclear and control system disciplines, and QA. The review meeting was held on May 2, 1983. 4.1.4 DESIGN CHANGE CONTROL
- Design changes for Class lE raceways are realized by directly revising the design documents, by issuing document change notices, issuing conduit design notices, issuing raceway holds, converting field change requests to change notices, or by l greenlining (see section 4.1.4.2.2 below) raceway installation l cards. Ultimately, the design documents are revised and all l changes incorporated therein. The alternate change methods used are interim measures that afford engineering / construction greater convenience, flexibility, communication, or speed in achieving the desired results.
Changes may be initiated by engineering or construction, or may be the result of a nonconformance (deviation) report. Changes may be approved only by the Design Engineering organization having responsibility for the document. As of July 1, 1985, responsibility for the majority of the Class 1E raceway design i drawings and documents remained with BPC HOE. However, responsibility for some documents have been transferred to PFE. Transferred documents are noted in the CEBUS control log. ! 4.1.4.1 Engineerino-Initiated Changes 4.1.4.1.1 Design Document Revision O The procedures for design document revisions are essentially l identical to the procedures followed for their initial issuance, which were described in section 4.1.3. The major difference is that a diffecent review process may have been followed due to the limited scope of a minor revision or (in the case of 4.1-11
incorporating change notices) the change may already have been reviewed. 4.1.4.1.2 Design Manual Change Notices O Design manual change notices (DMCNs) can be processed and issued as part of the manual faster than a revision which must go through the full review and approval cycle. DMCNs are controlled in accordance with the procedures established in preface section 3.7 of the design manual. DMCNs are prepared by the group responsible for the affected design criteria. They are reviewed and approved by the EGS and project engineer / responsible assistant project engineer (*-PE). Changes affecting safety-related or safety impact material in the manual are reviewed and approved by the BPC project licensing engineer (LE) and project quality assurance engineer. DMCNs are sequentially numbered (by section/ criteria) by project administration and controlled by the project engineer through project administration. Project administration maintains the design manual and is responsible for the Design Criteria Status Log, which is used to record and track revisions and changes to the design criteria. 4.1.4.1.3 Raceway Hold Notices Raceway hold notices (RHNs) afford an expedited means for Design Engineering to temporarily place a hold on the start or continuation of raceway installation activities. They are used only for raceways whose design is in the process of being changed and whose status of installation is indeterminate. RHNs are controlled in accordance with the procedures established in the VEGP PRM, part C, section 36. Hold notices on Class 1E raceways are prepared by the BPC HOE electrical physical design group. They are reviewed and approved by the electrical EGS and the project engineer / designee. The hold notice is logged by the HOE electrical discipline and telecopied to the PFE electrical discipline. The PFE electrical discipline logs the copy and transfers it to GPC Construction. Appropriate action is taken by GPC Construction, and the notice is returned to HOE with the installation status of e affected raceway (s) noted. The hold is removed by issuing a Design Change Notice (DCN), drawing revision, etc. The closing document (s) are referenced on the hold notice, and the notice is initialed by the HOE electrical physical design group leader. A copy is sent to PFE, marked closed. PPE logs the notice and forwards it to GPC Construction for removal of the hold. O 4.1-12
4.1.4.1.4 Drawing Change Notices (~}
\s DCNs afford a convenient method for Design Engineering to make changes to drawings without the immediate need to issue the drawing. DCNs are controlled in accordance with the procedures established in the VEGP PRM, part C, section 4.8.
r' k_)g DCNs are issued by HOE or PFE, depending on which organization is responsible for the drawings. (Drawings transferred to PFE are indicated in CEBUS.) DCNs issued by HOE are designated as DCN; those issued by PFE, as DCN-R (Resident). Either HOE or i PFE may initiate a DCN. Checking, review, and approval is
'~'
similar to that for raceway drawings. The review performed includes a review for hazards and verification of conformance to the FSAR and Design Criteria. DCNs are logged in the computerized DCN design document register (DDR). The DDR includes the DCN issue date, incorporation date, ; drawing revision, issuing organization and discipline, and initiating document. Also, the latest approved DCN and the last . DCN incorporated into the design drawing are listed in the CEBUS l drawing control log. 4.1.4.1.5 Conduit Design Notices I () 1 Conduit design notices (CDNs) allow conduit design data to be I entered in the EE580 circuit and raceway schedule program. The ; data is sufficiently detailed to allow issuance of installation I cards, thereby permitting conduit installation without the need for physical layout drawings. CDNs are not utilized for conduits that contain safe-shutdown circuits or for l safety-related conduits located in areas subject to high- energy j line break hazards. CDNs are controlled in accordance with the ' procedures established in the VEGP PRM, part C, section 4.5.2. CDNs are prepared by the BPC Electrical Physical Design Group. Checking, review, and approval are similar to that provided for conduit and tray drawings, and DCNs. CDNs are sequentially numbered and controlled by a log maintained by the electrical physical design group. They are microfilmed and transmitted to DDC for record retention. They must be incorporated in the design drawing within 180 days of their issuance. 4.1.4.1.6 Specification Change Notices Specification change notices afford a convenient means for making and documenting changes to specifications without the
'g/ immediate necessity of revising the specifications. They can be utilized for revising either Bill of Material specifications 4.1-13
(i.e., MSCNs) or construction specifications (i.e., CSCNs). MSCNs and CSCNs are controlled by the procedures established in the VEGP PRM, part C, sections 8.7 and 26.7, respectively. Preparation, checking, review, and approval of specification change notices are essentially identical to that for the specifications. Specification change notices aie assigned sequential numbers and logged in the MSCN or CSCN register as appropriate. 4.1.4.2 Field-Initiated Changes 4.1.4.2.1 Field Change Requests Field change requests (FCRs) afford a means for field engineering to obtain changes to design drawings or specifications. Field engineering comprises GPC, contractor, field project field engineering, or project field engineering. The change may be requested due to interferences, drawing discrepancies, changes in arrangements required by job conditions, etc. Within the design organization, FCRs are controlled in accordance with the procedures established in the VEGP PRM, part C, section 17. GPC field operations issues FCRs to PFE. FCRs received by PFE are logged in their FCR register DDC. FCRs forwarded to HOE are logged in their FCR register by project administration. h FCRs are reviewed for conformance to the FSAR and design criteria. They may be dispositioned by HOE or PFE. PFE-dispositioned FCRs on Class lE raceway drawings require HOE concurrence. Approved FCRs affecting design changes may be converted to DCNs, CSCNs, or MSCNs, as appropriate. 4.1.4.2.2 Supplemental Design Changes for EE580 (Greenlining) Greenlining affords a method for PFE to process field-requested changes to the EE580 circuit and raceway program when the normal EE500 processes impede work which is in progress or critical to meet schedules. Greenlining is controlled by the VEGP PRM, Appendix 2, section 20. Raceway installation cards requiring changes may be marked up by designated PFE engineers. The PFE engineers are responsible for ensuring that the corrected change is permissible, contacting HOE if necessary. The corrected card is assigned a sequential number and approved for installation by the PFE engineer. A O 4.1-14
copy is transmitted to HOE, where it is reviewed and the EE500 O data base is corrected. The corrected cards and Greenline Control Log are maintained by the GPC electrical EE580 section. 4.1.4.3 Nonconformances (Deviation) Reports Deviation reports (DRs) are prepared by GPC engineering / contractors to report deficiencies in material, documentation, or procedures identified during the construction phase of the , ("%, project. Within the design organization, DRs are controlled in \J accordance with the procedures established in the PRM, part C, section 18. GPC engineering / contractor issues DRs to the PPE DDC. If the DR l cannot be resolved by PFE, it is forwarded to HOE, where it is logged in by project administration. In either case, j engineering provides the " approved disposition." For ; dispositions of Use-As-Is and Repair, a justification is also ! provided. Required design documents are prepared and noted on the DR. Their issuance is tracked via the DR log. Interdisciplinary review is provided as required, and the DR is reviewed against FSAR licensing commitments. The GPC quality assurance site manager, with BPC assistance, reviews the DR for potential 10 CFR 21 or 10 CFR 55.55(e) reportability. The O' disposition is approved by the cognizant EGS and project I engineer (PE); and, for Class 1E raceway, it is reviewed by the Bechtel project quality assurance engineer (BPQAE). O O O 00229/030-6 4.1-15
O O . TABLE 4.1-1 INTERDISCIPLINE DESIGN CRITERIA Designation Initial Principal Nurder issue Title and Description Responsibility DC-1001 01-24-78 Separation - This document provides design bases to ensure that systems, Plant Design i components, and structures.important to safety are adequately separated. DC-1003 01-12-78 Floodina - This document provides design bases to ensure that safety- Nuclear related systems and structures are protected against flooding caused by ! postulated pipe breaks or activation of the fire protection system. t DC-1005 03-10-80 Seismic - This document provides bases for designing systems, structures, Civil / Structural and equipment having safety impact to withstand seismic events. DC-1006 12-19-77 Missiles - This document presents the criteria for analysis of internally Nuclear generated missile hazards. DC-1007 06-06-79 Environmental - This document provides design bases for environmentally Nuclear qualifying safety-related equipment to ensure that it will . perform its required safety functions during normal, abnormal, test, accident, and post-accident conditions. DC-1018 01-25-79 Pipe Break Effects Criteria - This document defines the criteria to be used for determining the assumed pipe break locations and the types of failures and their effects. 0029q/029-6/2 i
O ' O TABLE 4.1-2 SYSTEM DESIGN CRilERIA Designation initial Principal Material Nunber Issue Titie and Function ResponsibiIity Covered DC-1909 05-11-73 Cable System - The cable system provides electrical BPC - Electrical Power, control, connections for power, control, and instrimnentation. Systems. and instrumen-tation wire and cable. DC-1810 % 73 Raceway Systems - The raceway systems provide BPC - Electrical Cable tray, physical support and protection for electrical Systems conduit, under-cables. ground ducts, and boxes. DC-1881 09-27-77 Groundina System - The grounding system limits BPC - Electrical Grounding cable and fault potentials and provides a fault current Systems connector attach-return path. ments to raceways. DC-2166 03-06-78 Raceway Supports - This document provides design BPC-Civil / Structural Cable trays, bus bases for the design of raceway supports. duct, and conduit supports. 1 0029q/027-6/5
/~ TABLE 4.1-3 N-T ) l ELECTRICAL CALCULATIONS i
Calculation Date of Project ; Oesignation No. Initial Issue Calculation Title and Subiect Classification [ X3CK14 07-15-83 Maximum cable pulling length in conduit llE (determines maximum lengths of cable j that may be pulled in conduit without
/\ field calculation).
O X3CK15 03-19-84 Cable pulling calculation for llE l underground duct banks. l X3CLO2 12-01-81 Cable tray weights (determines weight / llE i foot for power, control, and instru-mentation cables for each type and size of cable tray). X3CV01 08-25-73 Amount and surface covered with zinc 628 inside containment and cable insulation inside containment (determines the () surface area of tray, conduit, and boxes coated with zine and the amount of zinc and cable insulation). l j i W w 1 E V 3 O 4 0030q/2/021-6
TABLE 4.1-4 O BILL OF MATERIAL SPECIFICATIONS Date of
- Specification Initial Issue / Project Designation No. Reissue Specification Title Classification X3AH01 02-07-79 Cable tray and fittings llE O X3AH02 08-18-78 Metallic conduit and llE, fittings 62E 1
l
; X3AH03 02-09-78 Nonmetallic conduit llE 1
and fittings X3AH05 08-22-79 Junction boxes llE , (Class lE) 1 4 X3AH09 02-14-79 Junction boxes llE, j (non- Class lE) and 62E , pull boxes (Class lE) X3AJ07 04-04-79 Cable, wire and raceway 628 markers j l
- l 4
X3AJ03 02-22-74 Grounding cable 62E j 9 O V l O
- O 0030g/3/021-6
~ .n -, , .- ,
i TABLE 4.1- 5 Q V i CONSTRUCTION SPEC 1FICATIONS j Construction Specification Date of Initial Construction Specification Project ODesignationNo. Construction Issue Title & Description Classification X3AR01-El Preliminary Issue General Information and Requirements -- Only Specification not required; no further (construction) issue. X3AR01-88 8-25-79 Raceway Systems llE, Specification covers the installation 62E of the underground and exposed power, control, instrumentation, and signal i I cable raceway systems. X3AR01-E15 11-21-78 General OualitY Assurance Requirements llE for Service and Construction Contractors Specification covers the quality assurance requirements for field receiving and inspection of materials. , X3 AR01- E16 Preliminary General Ouality Assurance requirements - Issue only for service and construction contractors (Specification superseded by E15.) O O
/N O
00309 /4/021-6
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De AwsMG AND Fit El D84 Afu'%GS i 4 I Figure 4.1-3 Electrical Drawing Design Control and Review I I
i i 4.2 PROCUREMENT Materials in this module were procured in accordance with the procedures established in the VEGP Project Reference Manual (PRM), part C, section 8 and part D, and in the applicable Georgia Power Company (GPC) Vogtle project procurement r' procedures. A general description of the project procurement I (_ process is provided by Appendixes C and E. l Raceway materials were procured utilizing the bill of material specific,ations prepared by Bechtel Power Corporation (BPC) Project Engineering and described in section 4.1. They were . procured by GPC Project Procurement with the assistance of BPC l (~} (s Project Procurement and BPC Engineering. l 4.2.1 SUPPLIER QUALITY SURVEILLANCE PROGRAM Supplier quality surveillance was performed in accordance with the procedures established in the VEGP PRM, part C, ] section 8.10, and part D, sections 3, 6 and 7. The program is described in Appendixes C and 1. Bill of material specifications for safety-related materials include supplier quality verification documentation lists (SOVDLs) and quality assurance (QA) program requirements, and/or (~D require submittal of a certificate of compliance by the
\/ supplier. In the certificate of compliance, the supplier affirmed that the materials furnished were in accordance with the specification requirements.
The supplier was required to submit a QA program only for , Class 1E junction boxes (Purchase Order (PO) No. PAV-426). He complied by submitting his quality program manual to BPC for review and acceptance. This manual then became the basic document to which his work was audited. Quality surveillance was also based upon the specifications and all standards referenced therein.
'(~ Based on the supplier's history and the function and complexity of the material procured, the Class 1E junction box order was assigned a level 3 quality surveillance level, which entails full-scope quality surveillance. This level was recommended by
, the project engineering manager and other representatives of the BPC project team, and was approved by the Southern Company h Services (SCS) Project Quality Assurance Engineer (POAE). In s _) addition to visits to accomplish activities described by formal notification points, the supplier quality representative visited the supplier on a regular schedule to monitor the work in process. The frequency of visits was in relation to the activity and the quality history of the supplier.
Supplier quality surveillance was implemented and records of the activities were maintained by SCS in accordance with the project procedures. Although SCS manages the supplier surveillance program, BPC Home Office Engineering (HOE) maintains responsibility for review of quality surveillance reports and for taking necessary actions on safety-related items. A deviation discovered during a normal surveillance visit was documented on a Quality Surveillance Deficiency Report (QSDR) in either one of two types. One type covers procedure violations, nonconforming hardware, and deficiencies noted in the documentation that could be related to a single item or group of materials. The other type covers programmatic deficiencies demonstrating lack of implementation to an established quality program requirement. There were no QSDRs written against material (i.e., junction boxes) covered by this module. In addition to normal surveillance visits, full-scope quality program audits or progressive audits of the supplier's quality program have also been performed. These inspections and audits were conducted by BPC on all Reliance- supplied Class 1E equipment including the Class 1E junction boxes covered by this module. 4.2.2 SUPPLIER QUALITY VMRIFICATION DOCUMENTATION The supplier was required to produce certified documentation in executing his QA program. Requirements for this documentation were established by BPC and were based, in part, on the experience of BPC in interpreting and applying the 10 CFR 50 Appendix B criteria. These criteria require documented evidence that materials conform to procurement requirements, and that they be available at the site prior to installation or use of the item. VEGP is committed to meeting the requirements of American National Standards Institute (ANSI) N45.2.13-1976 and Regulatory Guide 1.123 to the extent stated in section 1.9.123 of the Final Safety Analysis Report (FSAR). To establish the documentation each supplier provided, certain , suppliers submitted a Supplier Quality Verification ! Documentation List-Summary (SQVDL-S) form to BPC/SCS, listing a ' summary of the certified documents he would deliver to the jobsite in accordance with the verification requirements. After the SOVDL- S had been accepted, the supplier submitted a Supplier Quality Verification Documentation List-Detailed (SOVDL-D) form, listing the documentation in detail that he would submit with l delivery of the material. I 4.2.3 SUpFLIER DMV1ATIONS Vendor requests to deviate from procurement requirements were processed in accordance with the procedure established in the g 4.2-2
1 VEGP PRM, part C, section 23. It applies primarily to purchane orders that required the supplier to have a QA program. Four supplier deviation disposition requests (SDDHs), including one that was superseded, pertaining to material covered by this module were submitted. The SDDRs were logged into the SDDR log by project administration. The SDDRs requested that specific g, junction boxes ordered under PO No. PAV-426 be released for shipment prior to completion of the Institute of Electronic and Electrical Engineers (IEEE) 323 qualification program. These requests were dispositioned by the BPC Electrical Systems Design Group. They were reviewed and approved by the GPC electrical engineering group supervisor, project quality engineer, Project O Engineering (PE), and the PQAE. l i O l O (:) oo4eg,03o-e
- 4. 2- 3
l q 4.3 SITE MATERIAL CONTROL V Cable tray, conduit, special raceways, and their associated fittings and hardware are received, stored, and issued as bulk materials by the warehouse under the general site receipt inspection program. This program is described in Appendix E. and covers receipt, receipt inspection, document review and O' acceptance, release for issue, storage, and storage inspection of warehouse controlled material. O O : O O O 0017q/020-6 i
4.4 INSTALLATION AND INSPECTION l
}
4 This portion of the module contains descriptions of the basic processes that are used for installation and inspection of electrical raceways. It addresses the applicable electrical
- construction. specifications, field procedures, design drawings,
- and the applicable codes which govern each installation and inspection process.
l The documents used in the installation process are described in j section 4.4.3. ' (~
' \
Schedules relevant to the installation process are the construction summary schedule and the three-week construction. schedule. I 4.4.1 FLOW CHARTS The flowcharts following this section' illustrate the
- installation, inspection, and documentation activities associated with cable trays (Figure 4.4-1), conduit
- (Figure 4.4-2), and wall-mounted equipment (Figure 4.4-3). The
- flowcharts contain notes which represent points where preceding ,
activities must be completed in order to continue with the installation process. Interfaces between cable pulling (Module ()
- 12) and raceway support installation (Module 19) are shown to 4
clarify overall integration of the installation process. 4.4.1.1 Cable Tray I Figure 4.4-1 illustrates the major activities associated with , the installation and inspection of cable trays. Interfaces with Modules 12 and 19 are also shown. Cable tray installation i begins with a walkdown of the proposed raceway route for potential separation violations. If needed, a Fire Separation i Barrier Request (FSBR) is processed. After installation of vertical and horizontal supports, tray sections are installed l i 4 and horizontal supports arms adjusted. If horizontal arms are i welded, they are installed during initial alignment. After the [ final elevations are adjusted, the tray connections are torqued, ; grounding is installed, and numbers are affixed. The completed ! tray length is then input to the EE580 program. l (~' The tray is then released to Electrical Quality control for inspection via the EE580 card. EE580 cards representing , sections to be inspected ,are assigned to inspectors. The tray run is then inspected according to the drawing, specification, , and procedure. If a separation violation is found, the inspector determines whether an FSBR has been written and annotates the number on the back of the EE580 card and signs off O' the tray run.. If no FSBR exists or if any other discrepancy is noted, a DR is written and the EE580 card is held until the
discrepancies are corrected. and signed off, if acceptable. The tray run is then reinspected After all of the cable is pulled through a tray, FSBRs originated earlier are retrieved, tray covers and barriers are O installed, and the completed FSBRs are sent to Quality Control for inspection. Finally, the raceways are turned over to Nuclear Operations, on an area basis, after a final walkdown. 4.4.1.2 Conduit O Figure 4.4-2 illustrates the major activities associated with the installation and inspection of conduit. Interfaces with Modules 12 and 19 are also shown. Conduit installation begins with an evaluation of the proposed rewrite. This walkdown is h performed by the Cleveland engineer and craft foreman. For those areas having potential for separation violations, the engineer will prepare a craft installation package which includes items such as a sketch (showing the most desirable route) and relative elevation and location. Items considered during the development of this package include Field Change Requests (FCR), Heating, ventilation, and air conditioning (HVAC)/ piping support locations, core drill requests, etc. If during this walkdown, an unavoidable separation violation is discovered, a FSER is written. After approval of the FSBR, the conduit is installed, grounded, and numbered. The installed conduit data is then transferred to the EE580 program. The conduit inspection viaisthe then released EE580 card.to Quality Control (QC) for The conduit is inspected as detailed in section 4.4.1.1. FSBRs are verified and any discrepancies are identified on Discrepancy Reports (DRs). Upon closure of open DRs, the conduit run is signed off as acceptable. After cable is pulled through a conduit run. FSBRs originated earlier are retrieved and barriers are installed and inspected. Conduit runs are then turned over to Nuclear Operations on an area basis after a final walkdown. 4.4.1.3 Wall-Mounted Equipment Figure 4.4-3 illustrates the installation, inspection, and documentation also includes flow as it relates to an activity. The flowchart activity. the group responsible for the performance of each lh The flowchart contains 11 node points which represent hold points for which a preceding activity must be completed prior to continuing with installation, inspection, and/or documentation. O 4.4-2
i l The first node shows the activity that is performed prior to C~N) installation of the wall-mounted equipment. The activity, as illustrated, covers the EE580 listing of junction boxes, pull boxes, and equipment that is provided to the contractor by the GPC Electrical Project Section. (-} The second node shows the contractor's installation of the (j wall-mounted equipment and the grounding of it, as required. The third and fifth nodes shows the EE580 listing of completed items that the contractor provides to the GPC Electrical Project Section and the transmittal of EE580 cards to GPC Electrical QC for inspection. (-} , (_/ The fourth node shows the release of the equipment after installation for cable pulling and termination, which are described in Module 12. The sixth, seventh, and eighth nodes show the inspection of the item and return of the EE580 card to the GPC Electrical Project Section for updating of the EE500 data base. The 9th, loth, and lith nodes show the transmittal of EE580 cards to the QA records vault, review of the cards, and filing by EE580 location number. 4.4.1.4 EE580 Procram The attached flow churt shows the process of requesting, statusing, and completing EE580 control and tracking system raceway installation cards. Raceway cards are printed onsite when the EE580 group places a request for cards. The EE580 group bases their requests on information from the area engineer and orders cards for raceways that are engineering released (ER) status by drawing number. After ordering the cards, commands are placed in EE580 to print automatically any additional cards that design releases. fs (,) On the Vogtle site, raceway cards are not used by the craft as an installation document, but are used by QC to record inspections and final acceptance of raceways. Area engineers are provided with computer printouts used for preconstruction checking. The craft installs the raceway per drawings; information (such as from-to locations or raceway type) not
^ clearly shown is provided to the craft by the area engineer based on the EE580 printouts.
After the craft completes installation of a raceway, a listing is sent from the area engineer to the EE580 group. s The EE580 group retrieves the card (s) from a file, transfers the length s measurement from the listing to the card (s), initials the card (s), has the information keypunched into an update file, and 4.4-3
l l i { transmits the cards to QC. The EE580 group notifies Design that the update file exists; Design starts the update run after { reviewing the update file. Construction procedure ED-T-02 allows cable pulling to be performed prior to QC acceptance of the raceways, so the cards are statused CC (construction complete) prior to acceptance for use of standard EE580 cable release programs. l After QC inspects and accepts the raceway, they sign the back of the card and return it to the EE580 group. The EE580 group i transmits the card to the vault, where the document review group j checks number. for proper signatures and files the card by raceway If design modifies the data base information on any raceway that has been released to construction (JR status), then the EE580 program automatically generates a new card with a higher revision number along with a printout that indicates what has changed. The EE580 group files the card and transmits the printout to the area engineer for evaluation. If rework is required, the process described above is used with the new revision being used as reinspection records and is sent to the vault to be attached to the older revision (s). If the change does not require rework, the card is annotated on the back by the EE580 group, and is also sent to the vault. 4.4.2 PAST PROGRAM CHANGES As a result of audits, deviation trends, and added design requirements, field procedure ED-T-02, Raceway Installation, has evolved into its present form. The major additions / changes are discussed below: o Fire / Separation Barrier Request (FSBR) Before field procedure ED-T-02, revision 5, was issued on September 28, 1983, there was no programmatic control that allowed acceptance of raceways prior to installation of barriers where separation could not be achieved. The FSBR program provides a means to identify the future need for a barrier to meet the separation criteria. This is discussed furtF.er in station 6.2.3.2.3. o DR and Torque Wrench Calibrrrion Date Refe"ence on EE580 Card Prior to revision 5 to ED-T-02, issued September 28, 1983, there was no information written on the raceway inspection card identifying the torque wrench used, nor DRs written against raceway deficiencies. The lack of DR number and/or torque wrench number on the raceway card makes it difficult to 4.4-4
l l l
)
(-} (_j adequately retrieve documentation pertinent to the installation of raceways. Revision 5 requires this cross-referencing on the raceway card thus making records more easily retrievable. 1 l 4.4.3 PROCEDURE INDEX
.) The specification and procedure applicable to installation of Class lE raceways and non-Class 1E raceways in seismic areas are as follows: ~T o Specification X3AROl, section E8, Raceway Systems (G
This specification gives design agency requirements for material types, train separation, hot pipe separation, ' l and general installation of conduit, trays, pullboxes, and junction boxes. I o Procedure ED- T-02, Raceway Installation ; 1 This field procedure takes the general requirements of specification X3 AR01- E8 and provides the site construction group with detailed installation, inspection, and documentation requirements. O O O
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l 5.0 AUDITS AND SPECIAL INVESTIGATIONS This module section contains a discussion of Quality Assurance (QA) audits, NRC inspections, and special evaluations performed in the area of electrical raceways. Throughout the Plant Vogtle Construction Program, onsite audits have been performed by Georgia Power Company (GPC) QA. In addition, regularly O scheduled and periodic NRC inspections and investigations have been conducted. Plant Vogtle was also 1 of 22 utility sites that initially participated in the formation of onsite investigations by the Institute of Nuclear Power Organizations (INPO). The Self-Initiated Evaluation (SIE) program was established as a result of the pilot INPO program to provide a i O broadness review and in-depth investigation of the findings resulting from INPO. The content of this section is divided into three subsections: 5.1 Design Audits, 5.2 Construction Audits, and 5.3 Past Problems Areas. The subsections pertain to the subjects that they describe and briefly explain organizations, programs, , investigations, evaluations, and audits. They also list any j findings or violations that are applicable to electrical raceways. Project audits discussed in this section are conducted by QA personnel to provide assurance that design and construction processes function as required by 10 CFR 50 Appendix B; the O- project QA program; commitments defined in the FSAR: and the Design (Criteria) Manual. Project design and/or construction audits are conducted by Georgia Power Company (GPC), Southern Company Services (SCS), and Bechtel Power Corporation (BPC). In addition, the Institute of Nuclear Power Operations (INPO) conducted two evaluations, in 1982 and 1984, which resulted in a team of GPC, UPC, and SCS off-project technical management conducting a self- initiated evaluation in 1982. Routine inspections by the Nuclear Regulatory Commission (NRC) are generally directed to construction, but involve various Os aspects of the design control processes during some of the inspections. The content of the audits, resulting findings, and project ; actions to close the findings were reviewed by the assessment l teams to ensure the inclusion of important problem areas in the s) design and construction verification plans (sections 6.1 l and 6.2). l This section identifies the audits and resultant violations or findings specific to Module 17. l 0038q/020-6
I i 1 1 1 (' 5.1 DESIGN AUDITS U) 5.1.1 PROJECT AUDITS 5.1.1.1 Georgia Power Quality Assurance Audits Georgia Power Company (GPC) conducted several audits addressing design activities associated with raceways, but many of the audits were based on supports and consequently were not included in the scope of this module. Three audits specifically addressed design activities associated with raceways. As (~% indicated in Table 5.1-1, one audit included design criteria, s two addressed drawings, and all three included a review of specifications. No findings related to raceways resulted from these audits. 5.1.1.2 Bechtel Power Corporation Quality Assurance Audits The BPC Vogtle Project maintains a group of Quality Assurance (QA) personnel who regularly conduct audits of project activities. The audits address various activities within the j scope of design engineering. l 1 Bechtel Power Corporation (BPC) QA conducted one audit specific ' [\-)/ to raceway design with no findings. l l 5.1.1.3 Southern Co.mpany Services Audits Southern Company Services (SCS) is responsible for providing dssurance that the quality program provided by Bechtel is properly implemented and is in compliance with Appendix B of 10 CFR 50. Assurance is obtained through regularly scheduled audits conducted by SCS QA personnel and technically qualified individuals as needed. , (' As identified in Table 5.1-1, one audit performed on February ( 20, 1984, addressed design activities within the scope of this module. The audit resulted in three findings pertaining to raceways. The balance of the audit was out of the scope of this I module. l Finding AFR-1 related to raceway drawings. The electrical (~T drawings had been modified to add cable trays, but the (/ corresponding civil drawings did not include the supports for the added trays. This AFR was attributable to poor interdiscipline coordination. Civil / Structural completed all drawings and instituted a tracking log to assure completion of required work involving other disciplines. The balance of the l r~} l (_f findings were administrative and were also closed satisfactorily. l l 1 l
5.1.2 NRC INSPECTIONS The Nuclear Regulatory Commission (NRC) conducted two audits addressing design activities associated with the scope of this module; other iceway audits were directed to supports and/or construction. The two audits reviewed design criteria, drawings, and specifications. No violations or unresolved items were identified in the two audits. 5.1.3 OTHER AUDITS O Audits were conducted by the Self-Initiated Evaluation Team (SIE) and Institute of Nuclear Power Operations (INPO). These audits resulted in the Los Angeles Power Division (LAPD) Engineering Self Evaluation team and the SCS Engineering Design Control Review task force (February 1982). 5.1.3.1 Self-Initiated Evaluation The SIE conducted in 1982 identified one concern, item number DC 2-7 as follows: Electrical construction specification X3AR01, section E- 8, discussing raceway installation was reviewed. It was determined that Appendix R of 10 CFR 50 was not referenced in the construction specification. Design has proceeded on the basis of the project commitment to Appendix A, Branch Technical Position APCSB 9.5.1, which is more stringent than Appendix R. The FSAR and uesign documents are now consistent. 5.1.3.2 INPO Evaluation The INPO evaluation did not result in any design-related findings specific to raceways. 5.1.3.3 Engineerina Desian Review Task Force The Engineering Design Review task force, comprised of SCS personnel, conducted an evaluation in February 1982 to provide assurance that adequate procedures and controls existed at BPC and Westinghouse Electric Corporation. The evaluation resulted in one finding (SCS B-14) related to Module 17: Cable tray seismic design calculations did not meet the latest design criteria requirements; i.e., 20-percent O 5.1-2
i 4 damping versus 4 percent. The subject calculations had
- O been checked and approved, indicating compliance to the design. criteria was not adequately verified. The Design r
Criteria document was not formally approved prior to using the changes in design documents. Corrective action was initiated by submitting the revised ; O damping values to the NRC for approval, providing documented training sessions, and issuing a memotandum to involved Project personnel reiterating the requirement for obtaining approval of design changes prior to implementation. ; (g The Project Reference Manual (PRM) was revised to require that : (,) changes be processed within 60 days of initiation. I f 2 1 l O l O l l OO78q/030-6 5.1- 3 i
O O O O ) DESIGil AUDITS SORTED BY INITIATING ORGANIZATION AIO AUDIT NUpWER ED1T INIT AUDIT DESIGN CALCU- DRAW- SUPPLR DEVIAT. TRAIN DESIGN DESIGN DES 1GN WEST. IID. ORGAN IIUPOER DATE MOD CRIT LATIONS INGS SPEC DATA REPORTS PREM REVIEW DOC CNT CHANGES MISC SCOPE EXPLAIATI(BI 0F FIELDS For convenience, categories were combined where appropriate. The following is a listing of combinations and explanations: EDIT NO. - Used for conplete entry / corrections INIT ORGAN - Initiating or responsible organization: BPC, GPC, NRC, SCS AUDIT NUPEER - Number applicable to specific audit DATE - Date of audit, finding, or report MOD - Module addressing finding DESIGN CRIT - Design Criteria, FSAR CALCULATIONS - Calculations, Failure Modes and Ef fects Analyses (FEAs), engineering studies DRAWINGS - (Sel f explanatory) SPEC - Design specifications, procurement specs, construction specs, bid evaluations SUPPLR DATA - Supplier data includos expediting, inspections, Supplier Deviation Disposition Requests (SDDRs) Supplier data package problems DEVI AT. REPORiS - Deviation Reports, Nonconformance Reports, reportabIe i tems TRAIN PRGM Training program for design personnel DESIGN REVIEW - Design reviews of engineering documents, Design Review Ncticos (DRNs), and interfaco between engineering disciplines DESIGN DOC CNT - Document Control - records, correspondence, Asign control (of design documents), manual control Project Referenco Manual (PRM) DESIGN CHANGES - Field Change Requests (FCRs), Design Change Notices (DCNs), greenlining, Field Engineering Change Orders (FECOs) MISC - Licensing deviation disposition requests procedures, miscellaneous design audits WESl. SCOPE - NSSS and activities specific to Module 17 0098q/Ol'>-6
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MODULE 17 - SORTED BT INIT. ORGANIZATION & AUDIT NUMBER _======================================================- EDIT INIT AUDIT DATE MOD DESIGN CALCUL DRAW- SPEC SUPPLR DEVIAT. TRAIN NO ORGAN NUMBER DESIGN DESIGN DESIGN MISC WEST. CRIT ATIONS INGS DATA REPORTS PROM REVIEW DOC CNT CHANGES SCOPE
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91 BPC-QA VR-TA-4 06-22-84 21B X X 17 . X JULT/19 84 ! 166 GPC-QA ED01-81/42 06-30-81 17 215.217 213 i 167 GPC-QA ED01-83/26 05-23-83 17 431 j 18 t k l 352 GPC-QA ED01-83/60 08-09-83 17 485 483 1 j 353 GPC-GA ED01-84/73 09-12-84 17 I . 362 GPC-QA ED04-84/10 03-23-84 17 I ] , 694 NRC-INS 82-13 07-12-82 17 X X 777 NRC-INS 84-06 03-23-84 17 X X X 265 SCS-QA N/A 02-20-84 218 l 17 X 84-1.84 84-5.84 X ' -8 -7 19 ). b i i i i I i i
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i i 1 1 1 i 4 4 A _ _ . __ _ _. _ _ . _ _ _ _ _ _ . . _ . _ _ _ . . _ . _ _ . _ _ . _ _ _ _ _ _ . _ _ . _ . . _ . _ . _ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ .-- , ----e, m .
5.2 CONSTRUCTION AUDITS O 5.2.1 PROJECT AUDITS ' (~ 5.2.1.1 Georgia Power Audit Findings ( The Georgia Power Company (GPC) Quality Assurance (QA) department conducts regularly scheduled audits to verify project compliance with the applicable project documents. Findings are reported to the management of the audited organization for corrective action. The QA audits discussed in this section provide in-depth reviews of electrical raceway installations while these activities have been in process at Vogtle. The audits focused on the activities as they were conducted including storage, field work, and QA documentation. The audit matrix (Table 5.2-1) outlines the specific areas covered and the types of issues that were raised and resolved. Audit findings have been tracked in four ways by QA. These methods are Audit Finding Reports (AFR), Observations (OBS), Deficiencies (DEF), and Corrective Action Requests (CARS). Of
/~)/ the four methods, only two, AFR and CAR are currently being used on the project. A more detailed explanation of the audit process is found in Appendix I.
Thirteen audits addressed the program involving electrical raceways. Those 13 audits resulted in 15 findings that are listed in the finding matrix (Table 5.2-2). Each audit was reviewed and classified into one or more of the eight categories listed below: Category Audit Frequency .N o . of Findings g Materials 4 2 q) Training Qualification 0 0 Fabrication 9 8 Inspection 4 2 Testing 0 0 M&TE 1 1 l
~ Document Control 0 0 QA Records 2 2 Each finding was reported to project management for evaluation of its impact on the project, corrective action, and action to gs preclude recurrence. j
(- )
The findings, observations, and deficiencies were evaluated by the construction team and incorporated into the assessment of raceways by Readiness Review. lf 5.2.1.2 INPO Evaluations The Vogtle project has participated in two INPO construction project evaluations, one in 1982 and one in 1984. The 1982 pilot evaluation was the first time the criteria had been h applied in the industry. The Institute of Nuclear Power Operations (INPO) evaluations issued no findings pertaining to electrical raceways. ~ 5.2.1.3 O Self-Initiated Evaluation During September and October 1982, the project initiated an evaluation of design and construction activities that was conducted by a team of nonproject senior technical and management personnel from GPC, SCS, and BPC. The evaluation assessed many of the programs and activities on the project using the INPO criteria for construction project evaluation. There were no SIE findings in the area of electrical raceways. 5.2.2 NRC INSPECTIONS The Nuclear Regulatory Commission (NRC) has addressed electrical raceways in two inspections that resulted in the issuing of one finding. The NRC inspections and the finding were reviewed and similarly classified into one or more of eight different categories. The results are summarized in the table below: _Qategory Audit Frequency No. of Findings Materials 0 0 Training Qualification 2 0 Fabrication Inspection Testing 1 0 O 0 lh 0 0 M&TE O O Document Control 0 0 QA Records 1 1 O The NRC findings were evaluated by the Construction team and incorporated into the assessment of raceways by Readiness Review. 0013 q / 02 9- 6 5.2-2
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P... N.. O O O O O O 01/24/86 CONSTRUCTION AUDIT 8
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EDIT INITIATING AUDIT DATE MATERIAL TRAIN / FABRIC- INSPECT- TESTING MEASURE DOCUMENT QA REMARES RO ORGANIZATION NUMBER QUAL ATION ION & TEST EQ CONTROL RECORDS
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4 1586 GPC-QA cpl 7-85/71 09-27-85 I 849.U50 850 I 185 GPC-QA ED01-79/27 11-20-7b I I I I 50 FINDING 8 , 186 GPC-QA ED01-80/07 03-17-80 I I I I NO FINDINGS 187 GPC-QA ED01-81/03 02-04-81 185.166 167 189 GPC-QA ED01-81/85 12-03-81 I I No FINDINGS 191 GPC-QA E001-82/42 04-14-82 I I I I I 193 GPC-QA ED01-83/107 12-20-83 532 198 GPC-QA ED01-83/60 08-09-83 483.487 484 201 GPC-QA ED01-84/41 06-21-84 639 640.641 203 GPC-QA ED01-84/73 09-12-84 712 I 226 GPC-QA 5D03-84/15 03-15-84 582 237 GPC-QA ED04-84/10 03-23-84 593 258 GPC-QA ED05-83/107 12-20-83 532 719 GPC-0A sV01-82/63 06-16-82 I 307 I 724 GPC-QA SV01-82/96 08-16-82 029-085 026-095 330 1048 NRC-INS 82-13 07-12-82 X X 82-13-0 2 1213 NRC-INS 84-06 03-23-84 I I 1
<~ 5.3 PAST PROBLEM AREAS
( L This section discusses past constructability problem areas and their effect on procedural and installation activities. This section is not intended to serve as an in-depth description of all problems associated with raceway installation, but is r~ instead a guide to major program difficulties and their effect on the installation effort. 5.3.1 TRAIN SEPARATION Requirements for separation of raceways of different trains were (^} (,j added to construction specification X3AR01-E8 on Revision 5, dated June ll, 1981. The requirements were not included in field procedure ED-T-02 until FPCNs 25 and 31 were written in November 1983. This discrepancy, identified in site audit ED01/83-60, resulted in the establishment of a construction walkdown team which from December 1983 to February 1984 identified 170 cases of separation violations. These were documented on Fire Separation Barrier Requests (FSBRs), which indicate the need for barriers to be installed at a later date. Discrepancies in the FSBR program, which allows Quality Control (QC) acceptance of raceways having separation violations prior to installation of barriers, are discussed in Readiness Review Finding 17-1.
/^s O
5.3.2 CABLE TRAY SPL1CE BOLTS P&W Industries supplies cable tray and splicing hardware to the Vogtle jobsite. Initially, splice bolts used to connect tray sections were of two generic types, silver-colored (zinc finish) and gold-colored (iridite finish). In late October 1981, Electrical QC issued a Deviation Report indicating failures of zine-finished bolts; specifically, the shearing of the bolt head from the bolt body. This was reported to the Nuclear Regulatory Commission (NRC) as fx a 10 CFR 50.55e finding. An engineering evaluation of the ( problem found that, in manufacturing the zinc- finished bolts, the die that stamped the head of the bolt caused the weakness. This resulted in the issuance of two remedial actions: o The replacement of zine-finished bolts with the g- iridite-finished bolts. O) o The changing of procedural and purchasing requirements specifying the use of only iridite-finished bolts. Additional information dealing with this finding is available in the Final Report File No. X7BG03-M20, Log No. BS3333, dated May 17, 1982. 0072q/030-6
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A 1388 GPC-SW SW-E-04 09-22-82 ER-580 LACKS CONTROLS 1380 GPC-SW SW-E-05 11-11-82 FAILURE OF CABLE TRAT SPLICE BOLTS 1406 GPC-SW SW-E-07 03-31-83 EQUIPMENT MOUNTING WITEOUT NECESSARY DATA 1407 GPC-SW SW-E-09 10-24-83 IMPROPER INSTALLATION OF.UNISTRUT SPRING NUTS 1408 GPC-SW SW-E-11 04-12-84 USE OF RUNNING THREAD NIPPLES IN CONDUIT 1984 PREPARATION AND VERIFICATION OF 1426 IMPO DC.3-1 CALCULATIONS CHECELIST FOR INSPECTORS 1441 INPO QP.3-1 1984 1612 NRC-INS 82-13 82-13-02 ITU 05-24-82 DOCUMENTATION OF NON-CONFORMANCE REPORT REVIEW FOR LICENSEE REPORTABLE ITEMS. VPRM C-36. 1814 SCS-0A 84-05 02-24-84 BOLD NOTICES NOT PROCESSED IN TIMELT MANNER NOR LOGGED PROPERLT. CLOSED 02-26-85, VPRM C-36 1816 SCS-0A 84-07 02-24-84 NOLD NOTICES NOT PROCESSED IN TIMELT MANNER. PARA 3.4.1. 4 i i
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INIT AUDIT FINDING NUM ORG NUMBER MUMBER LEVEL DATE SUBJECT RBMARES BER
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DES CON B14 1982 INADEQUATE SEISMIC ANALTSIS OF CABLE 354
. TRATS DES CON B15 1982 ORGANIEATION RESPONEIBILITIES NOT CLEAR 373 DES CON B16 1982 USE OF INCORRECT DAMPING VALUES 368 GPC-55(e) M20 CABLE TRAT SPLICE 90LTS 398 GPC-55(e) MB4 09-10-85 CABLE TRAT ROLD DOWN CLIPS - IMPROPER 2346 TOROUING GPC-QA SV01-82/96 026-055 08-16-82 JUNCTION BOIES INSTALLED WITHOUT COVERS NFPA 70-1981 2241 GPC-OA SV01-82/96 029-0BS 08-16-82 MATERIALS - POSSIBLE DISTORTION OF ANSI M45.2.2 PARA. 6.3.2. 536 STACEED MATERIAL.
GPC-QA EDI-81/03 165 01-23-81 ELECTRICAL CONDUIT - FAB. - THREADS NOT ANSI CBO.l. PARA 3.6.2 2045 PROTECTED FROM CORROSION GPC-QA ED01-81/03 166 01-23-81 ELECTRICAL - RACRWAYS & CONDUIT - ANSI C80.1, PARA 4.4 & 4.8. 723 MATERIALS - 19. MARRINGS. FIELD PROC. ED-7-02, SPEC. I3AR01 PAR E8.7.2B GPC-QA ED01-81/03 167 01-23-81 RACEWATS & CONDUIT - MATERIALS- ID ANSI C80.1, PARA 4.7(3). 724 MARKINGS FIELD PROC. ED-t-02, SPEC. THREAD CHAMFERING NOT DONE. X3AR01, PAR. E8.7.28. GPC-CA SV01-82/63 307 06-02-82 ELECTRICAL DOCTBANK R3AR01, SECT. E8.7.5C&D. 864 GPC-OA SV01-82/96 330 08-09-82 ELECTRICAL EQUIPMENT NFPA 70-1981, NATIONAL 887 ELECTRICAL CODE, p110-Il7 d GPC-QA ED01-83/60 482 I 06-27-83 ELECTRICAL - RACENATS - DESIGN - SPEC. K3AR01-E8, REV. 9 ATT. 1039 VIOLATION OF SPACING. B, SECT 1.2.1 i GPC-QA ED01-R3/60 484 II 06-27-83 ELECTRICAL - RACRWATS - INSPECTION SPEC. X3AR01-88 REY. 9 SEC. 1041 8.7,0.] i i 1 _____ . _ _ . _ _ _ _ m ._ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ . . _ _ _ __ ____
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GPC-QA ED01-83/60 485 II 06-27-83 ELECTRICAL - RACEWATS - FAB. & VNP DESIGN MANUAL DC-1810, 1042 INSTALLATION PAR. 3.2.2.C GPC-QA ED01-83/60 487 III 06-27-83 ELECTRICAL - RACEWAYS - FAB. & CONDUIT & TRAT DRAWING, 1044 INSTALLATION. CI3DF001, NOTE 14. GPC-QA ED01/EDCS/GD06- 532 II 12-20-83 FAILURE TO PRECLUDE RECURRENCE OF PAST ANSI N45.2, SECT. 17 IEEE 1089 83/107 PROBLEMS STANDARD 498 MANUFACTURES INSTRUCTIONS GPC-QA E D03- 71/15 582 II 02-06-84 ELECTRICAL TRAY INSTALLATION - FAB - DC-1810/3.1.1.G. 1139 COLOR CODING OF RACEWAYS EXCEED 15 FT. MARIMUM. GPC-QA ED04-84/10 593 I 01-23-84 MISCELLANEOUS STEEL - MATERIALS - V0GTLE Q. A. MANUAL SECT. 8 1150 CERTIFICATION OF BOLTS. PART A & C. GPC-QA ED01-84/41 639 II 05-17-84 RACEWAYS - DESIGN - LACE OF "AS BUILT" N/A 1197 RECORDS. GPC-QA ED01-84/41 640 III 05-17-84 RACEWAYS - O. A. RECORDS ELECT. SPEC. X3AR01, REV. 12, 1198 J SECT. E8.7-B GPC-QA ED01-84/41 641 III 05-17-84 RACENAYS/ CONDUITS - Q. A. RECORDS. V0GTLE FPM GD-T-01, REY. 10, 1199 SECT. 6.6. GPC-QA 2201-84/73 712 II 09-12-84 RACENAY8, FAB. & INST. CONDUITS GPC PROC. ED-T-02, SECT. 3.3. 1270 INSTALLED CONTRARY TO SPECS. (CLOSED, REF. 04-18-85) GPC-QA cpl?-85/71 849 II 09-27-85 CABLE TRATS INE50TNBGA AND INI50BTMBO 2344 AND SUPPORTS FOR TRAT8 INE51BTLBR AND INE51BTMBE IN VIOLATION OF SEPARATION CRITERIA. SUPPORT FOR TRAY IBE50ZTRAA IN CONTACT WITH LINER PLATE UNISTRUT GPC-QA cpl 7-85/71 850 II 09-27-85 CABLE TRATS IBE3ICTSCE AND IBE3ICTSCD 2345 OVERFILLED O O O O O O O
F 6.0 PROGRAM VERIFICATION , This section describes the program developed and actions performed to ascertain whether the design and construction activities have been adequately controlled in a manner that implements licensing commitments, and to verify that the results of these activities conform to project procedures and design O v requirements. This section is divided into two parts. Section 6.1 describes activities related to design program verification and section 6.2 describes activities related to construction program verification. ; Findings resulting from the design and construction verification 1 programs are also discussed and are tabulated at the end of each ! section. . I k ' 0039q O 1 1 O O 1
6.1 DESIGN PROGRAM VERIFICATION The objective of the design program verification was to ascertain whether the design processes for electrical raceways and junction boxes have resulted in proper implementation of licensing commitments in design documents. The verification was performed by the Readiness Review design verification team. The six members of the team had a cumulative experience of 107 years in power plant design engineering. Approximately 600 manhours were expended performing the verification. (._f The following sections describe the design program verification and resulting findings and corrective actions: section 6.1.1 provides a summary of the verification including assessment: section 6.1.2 provides a description of the verification scope and plan: section 6.1.3 provides a detailed description of the verification review results: and sections 6.1.4 and 6.1.5 provide the findings. responses, and cumulative significance of the findings. 6.1.1
SUMMARY
AND CONCLUSIONS Module 17 addresses Unit 1 raceways and junction boxes for (~h Class 1E circuits. Included are cable trays, exposed and embedded conduit, flexible conduit, . Seismic Category I duct banks, pull boxes, and junction or terminal boxes. Verification of the adequacy of the design program associated with the raceways and junction boxes was accomplished by reviewing documents associated with a selected hardware sample and by visual inspection of typical hardware installations. Criteria for selection of a verification sample were developed to ensure that all types of hardware and documentation were addressed. The subsequent document review and visual inspection or walkdown would ensure that an adequate sample of commitments p applicable to this module were addressed. U The verification was performed in three phases. In Phase 1 the design-related licensing commitments that apply to this module (listed in the commitment matrix of section 3.2) were reviewed to determine whether they were implemented in the appropriate Design Criteria (DC) or other governing design documents. The O results of this review are documented in the commitment implementation matrix of section 3.3. The commitments were also reviewed to determine whether they were incorporated in subordinate design documents (e.g., calculations or drawings). The results of this review are documented in the verification r- matrix of Table 6.1-1. (_g/
i l l l l I In Phase II, a programmatic review of design documents, design processes, and adherence to project procedures pertaining to a selected sample was performed. The results of this review are documented in section 6.1.3. In Phase III, a walkdown was performed to verify that selected i commitments and design requirements were implemented during the
- installation of the electrical raceways. The results of the walkdown are also documented in section 6.1.3.
The review of the documents and walkdown resulted in 12 findings which are summarized and categorized in Table 6.1-2. The Design team assessed the overall design of the raceway system and determined that it has been properly executed. Although programmatic deficiencies have been revealad, as evidenced by the findings, none resulted in a technical or safety impact. Programmatic deficiencies were observed in such areas as completeness of documentation, independent checking, interdiscipline reviews, inconsistencies between project documents, etc. More attention on the part of the Design organization is required to assure compliance with project procedures and quality requirements during the design process. The Project has indicated, through the responses to the findings, a positive attitude toward correction of the deficiencies identified during the review. The responses indicate that the design process will be further strengthened by lh the implementation of committed corrective actions. With these improvements, the Design review team finds the Module 17 design program to be satisfactory and to meet both project licensing commitments and quality requirements. It is also the Design team assessment, as evidenced by the Construction team findings and corroborated by the Design team walkdown, that raceway separation requirements imposed by Design Engineering have not been strictly adhered to during the installation process. This is further evidenced by project reliance on as-built walkdown verification programs to assure adequate separation compliance < Instances of lack of separation have occurred in the past and will occur in the future. Nevertheless, future walkdowns, in conjunction with the additional emphasis being placed on the identification of separation problems before installation, should result in a final completed installation that effectively implements the project commitments. O 6.1-2
6.1.2 SCOPE AND PLAN 6.1.2.1 Scope The scope of this module includes approximately 12,500 Unit 1 taceways for Class lE cables. Included are cable trays, exposed (~} \d and embedded conduit, flexible conduit, Category I duct banks, and pull boxes. Junction boxes associated with Class 1E cables are also addressed. Documentation associated with the raceways and junction boxes ( \ includes engineering design documents, design change documents, vendor documents, Deviation Reports (DRs), and the associated procedures that control the documents during ptocessing. Table 6.1-3 presents a summary of the types of documents, the total number of each type, and the number of each type reviewed during the verification. 6.1.2.2 Plan The verification was accomplished by reviewing documents associated with a selected hardware sample and by visually inspecting typical raceway installations. If a representative sample of the document types could not be obtained by this means, additional samples of the document types were reviewed to [)
' ensure adequacy of the verification effort.
The hardware selected for verification includes 66 raceways and junction boxes that are identified in Table 6.1-4. The sample was selected based on the following criteria 1 o The sample included all hardware types, o The sample included raceways carrying auxiliary feedwater, residual heat removal, and nuclear service , cooling water circuits. This sample provides a review l of raceways for systems that were selected for verification in other modules, and provides continuity O between modules. i o The nuclear instrumentation system (NIS) conduits were i selected to verify implementation of Westinghouse l interface criteria. o The raceways were selected to provide some hazards interface such as missile and jot impingement. o The raceways were selected from areas which have the potential for Class lE train separation problems. - O V c .1- 3
i ( l t o The raceways from the Construction team's samples were l selected to better verify adequacy of the design- cons t ruct ion interface. The selection criteria ensured that all types of hardware and design documentation applicable to this module are addressed. It should also be noted that most of the comnitments applicable to this module are generic in nature, and any sample that would include all hardware types would therefore encompass most of the commitments. The design verification program was performed in three phases. Phase 1 verified the implementation of licensing commitments into project design documents. Phase II verified that design documents were processed in accordance with project procedures and commitment requirements, both when originating documents and during the revision. Phase III was a visual inspection of the installed hardware. 6.1.2.'.1 i Phase 1 Verification The coramitment implementation review consisted of two parts. In oart 1. a review was made to ensure that each commitment could be identified in an apprcpriate design basis document such as Design Criteria or other appropriate design documents; in i part 2, a review of commitments was made to ensure that
- subordinate design documents such as calculations, drawings, l procurement specifications, and construction specifications adequately implemented the commitments during the development of h the detailed design. Parts 1 and 2 of the Phase I review were accomplished as follows:
6.1.2.2.1.1 Part 1. Commitments in Design Criteria. In part 1 of Phase 1, the specific commitments identified from the Fin.al Safety Analysis Report (FSAR) or other source document were reviewed against selected design documents to ensure that the commitment was included in the Project Criteria or other appropriate design document. The following steps were involved in accomplishing part 1: o A commitment matrix was developed by reviewing the FSAR and other licensing documents and then listing commitments in a matrix. o Bhsed upon the identified commitments, an implementation matrix was developed that identified the appropriate i design document in which the commitment was I incorporated. For commitments pertaining to standards dnd NRC regulatory documents, implementation was verified by checking that standards and regulatory documents were referenced in the appropriate governing 9 6.1-4
\
l i l l design document. The implementation matrix identifies (~) the document revision where the commitment was first (_) implemented and the most recent revision that included 1 l ' the commitment. In this manner, the implementation l matrix provides a cross-reference between governing design documents and commitments, thereby ensuring that r' each commitment is properly recognized and incorporated ( in the design and/or construction process. l o Most commitments were correlated to the Design f Criteria. Exceptions are raceway installation details ) or standards related to construction that would not be l appropriate to be included in the basic design l (~}/ x_ criteria. The commitments were verified to be in other I appropriate implementing design documents such as the Construction Specifications. These implementing documents were then identified in the implementation matrix. The described steps ascertained that commitments vere recognized by the Design Engineering Group as requirements for detailed l design or construction, as appropriate. 6.1.2.2.1.2 Part 2. Implementation in Detailed Desion. In part 2, the commitments were reviewed to ascertain whether they were consistently and correctly applied during the design process. The verification was accomplished by reviewing i affected design documents to ensure that the commitments were incorporated. The documents reviewed included representative samples of calculations, drawings, design change documents, and 1 specifications. The verification matrix was prepared, listing the commitments ! that were verified through the reviewed documents. l Commitments pertaining to standards and NRC regulatory documents were reviewed, and the specific requirements related to raceways were selected for review. These requirements were identified in the verification matrix as design requirements. The design (S s requirements were reviewed to the same level of detail used in
/
the verification of the other commitments. 6.1.2.2.2 Phase II In Phase II, project design documents were reviewed for conformance to the design program requirements. The emphasis of the review was to verify that the design process was controlled in accordance with the quality program licensing commitments. This was accomplished by verifying that the desigr. process complied with project procedures and other documeats governing O 6 .1 - 5
, - , ~ , -
design control te.g., American National Standards Institute (ANSI) N45.2.11] and that appropriate design coordination between interfacing design organizations had occurred. Design documents were reviewed to ensure compliance to selected aspects of the design control program. Checklists were developed for each type of document to provide verification guidelines. Documents that were reviewed included design criteria, calculations, drawings, specifications, procurement and vendor documents, and design change documents. The design documents reviewed primarily pertain to the hardware selected. Samples pertaining to other hardware were taken to address specific issues identified during module preparation or to provide a representative sample when the selected hardware did not yield sufficient documentation. 6.1.2.2.3 Phase 111 In phase Ill, a walkdown or visual inspection was performed to verify that commitments and design requirements were implemented during the installation proceos. The walkdown concentrated mainly on areas such as cable spreading rooms, containment penetrations, corridors, and tunnele. The intent was to walk down areas that historically have a potential for problems. A checklist was developed that lists the more important aspects to be reviewed during the walkdown. O 6.1.3 VERIFICliT10N HEVIEW AND RESULTS The following subsections identify the documentation reviewed during the verification, the review method, and the findings associated with the review. 6.1.3.1 Commitments The 43 commitments listed in the commitment matrix of section 3 e were reviewed to the level indicated in the verification matrix of Table 6.1 1. Although all the findings relate to the project commitments, including ANSI N45.2.11, there were no cases identified in which the project failed to implement the commitments through the design bases and/or project procedures. The findings identified were failures to totally implement the commitments in the detailed design documents. 6.1.3.2 Design Cr,itoria O The Design Criteria (DC) documents listed in Table 6.1-5 were reviewed to verify the implementation of current FSAR l
- 6. L- 6
commitments. Design-related commitments listed in section 3 ("]j q, were reviewed to ascertain that they were incorporated in the appropriate DC document. DC-1810 was also reviewed to the applicable requirements of ANSI N45.2.11 and other project procedural requirements utilizing the checklist of Figure 6.1-1. The results of the review are documented in the implementation matrix, section 3, and the verification matrix, Table 6.1-1. There were three findings identified during the review. Finding 17-7 addresses the failure to fully implement rT Westinghouse NIS separation criteria. Finding 17-8 addresses
< (a) conflicting criteria regarding grounding cable attachments to trays. DC-2166, Raceway Supports, did not allow attachments to the trays or tray supports, including grounding cable, due to their impact on the damping value used in the seismic design.
DC-1811, Grounding, and general notes and details drawing CX3DE001 require that grounding cables be attached to the - medium-voltage trays. Finding 17-20 addresses the omission of raceways from the project classification list, the omission of safety design bases for junction boxes f rom t he DC, and an incorrect version of Institute of Electrical and Electronics Engineers (IEEE) Standard 384 listed in the DC. Refer to section 6.1-4 for details of these findings. 6.1.3.3 Calculations Verification was performed to ensure that design calculations I comply with the project procedures, Design Criteria, industry l standards, FSAR, and other licensing commitments. In addition, I the calculations were reviewed to ascertain whether the calculation results had been implemented correctly into associated documents. Four design calculations were identified that were applicable to this module. The calculations are listed in Table 6.1.6. The checklist of Figure 6.1-2 was used to review the calculations for compliance with the Project Reference Manual (pRM), part C, {w, section 9, and ANSI N45.2.11, sections 4 and 6. This review I included verification that the calculations conformed to the j project licensing commitments, that output data was incorporated ' into affected documents, and demonstrated to appropriate disciplines, that an independent checker and discipline f w engineering group supervisor (EGS) reviewed and approved the , calculation as required by the pRM, and that input data was I consistent with referenced documents. Three findings (17-10, 17-11, and 17-18) were documented by the review team. Findings 17-10 and 17-18 address deficiencies in
s quality classification, design inputs, and interfaces with other
)
6.1 /
project documents. Finding 17-11 addresses duct bank design which had not been substantiated by a calculation. The details of these findings are contained in section 6.1.4. 6.1.3.3.1 Hazard Review Class lE electrical raceways, including junction boxes, were located or routed to avoid areas of high fire hazard and areas subject to externally generated missiles. Provisions against damage from seinmic events were made by installing flexible joints across the seismic gaps. High-energy line breaks were addressed utilizing zones- of-influence packages generated by the hazards group. A zone-of-influence package consists of a cover memorandum identifying the system and the break event numbers, a blank impact list, the pipe whip restraint isometric sketch, the zones-of--influence sketches, and jet tables which show the pressure of the jet at varying distances from the pipe break. Two packages, file X6BB06, log BB35204, dated March 23, 1984, and X6BB06, log 35929, dated May 2, 1984, were selected for review. Each of the packages was processed in the following manner: The zones of influence were evaluated by the responsible area leader for impact on Class lE raceways. The impacted raceways were itemized on the impact list and were noted when they carried essential safe-shutdown circuits. The zone-of-influence package was then returned to the hazards group for review. A master package was prepared and maintained by the hazards group to monitor the problem areas. A copy of the master package was forwarded to the Electrical Group to resolve the jet impingement problems by rerouting or providing adequate barriers. Although both packages selected for review contained Revision 0 zones of influence. it was determined, by interview with hazards personnel, that revisions to the packages would be reviewed in the same manner. There were no findings resulting directly from this review. Iloweve r , Finding 17-13, addresses the rigid installation of trays to equipment as shown in construction specification X3AR01, which fails to fully implement criteria for controlling the seismic hazard. 6.1.3.4 Drawings and Drawing Change Notices 6.1.3.4.1 Conduit and Tray Drawings A procedural review to verify compliance with ANSI N45.2.11 and the PRM, part C, section 4, was performed on 27 conduit and tray drawings. The checklist shown in Figure 6.1-3 was used as a guide during this review. Fifty-two Drawing Change Notices (DCNs) from the layout drawings associated with the hardware sample were reviewed utilizing the checklist shown in Figure 6.1 4. The drawings and DCNs are listed in Table 6.1-7. O 6.1-8
The drawings selected contained all of the conduit and tray O segments and boxes in the raceway sample to be reviewed. In addition, the drawings were reviewed for compliance with the e separation criteria of IEEE 384 and Regulatory Guide (RG) 1.75. , The raceways were also checked against the EE580 documents to = verify that the raceway number, type, size, layout drawing, and ,
"from" and "to" locations have been correctly input into the l
3 EE580 data base. A total of 35' cable tray segments, 24 l l conduits, and 7 boxes was reviewed. These raceways are listed in Table 6.1-4. Commitment implementation is documented in the commitment implementation
- matrix, section 3.3. t
(
~
6.1.3.4.2 Underground Duct Bank Drawings A procedural review was conducted on eight undarground duct bank drawings, including four general notes and detail drawings, to verify compliance with ANSI N45.2.11 and PRM, part C, ; section 4. The checklist of Figure 6.1-3 was used as a guide i during this review. The drawings are listed in Table 6.1-7. ' Additionally, the drawings were reviewed for compliance with the ; separation criteria of IEEE 384 and RG 1.75. The drawings were = also checked to verify that raceway number, type, size, layout ! drawings, and "from" and "to" locations have been correctly 1 input into the EE580 data base. A total of four Class 1E duct bank conduits was reviewed. The ducts are listed in ! Table 6.1-4. l 6.1.3.4.3 Summary of Findings There were two findings resulting from the drawing review, Finding 17-12 addresses a raceway group separation violation i { shown on the design drawing. The 5-ft vertical separation ! required by IEEE 384 was not maintained. Finding 17-15 addresses inconsistencies between the raceway numbering system, defined on general notes drawing CX3DF002, and the raceway numbers actually being assigned on other documents. Also addressed are raceway numbers identified on design documents which were not defined on drawing CX3DF002. See i
, section 6.1.4 for further details.
6.1.3.5 Bill of Material Specification and Chance Notices Six Bill of Material specifications and the associated change notices relating to raceway markers, junction boxes, pull boxes, () conduits (metallic and nonmetallic), and cable trays were reviewed. The specifications are listed in Table 6.1-8. The checklists shown in Figures 6.1 5 and 6.1-6 were used as guidea in the review. The checklists were developed from applicable project procedures (i.e., PRM part C, sections 3, 5, Oi and 8) and current FSAR commitments to ANSI N45.2.11. 6.1-9 _ _ _ _ - . _ - = ~ - _ _ ~_-
l , Requirements for design, inspections, tests, environmental and I seismic requirements, and quality assurance (QA) specific to the l types of items specified were reviewed for incorporation into I the specifications. l The specifications were in compliance with project procedures and current FSAR commitments. The project classification listed i on the cover sheet of the specifications and the technical l provisions were consistent with the Design Criteria requirements. l The specification revisions reviewed had documented evidence of interdiscipline review on Document Review Notices (DRNs). QA, environmental qualification, and seismic requirements were part of the specifications. No instances of inconsistencies with licensing commitments were identified. l 6.1.3.6 Construction Specifications and Change Notices Construction specification X3AR01, sections E8 and E15, were reviewed for implementation of commitments and compliance with the quality program requirements. Commitment implementation is documented in the commitments verification matrix, Table 6.1-1. Procedural compliance was reviewed by verifying interdiscipline review, Chief's approval, DRN attachment, and incorporation of construction specifications and change notices (CSCNs). Figures 6.1-7, construction specification checklist, and 6.1-8, CSCN checklist, were used as guides during this review. The teview resulted in Finding 17-13, which addresses guidelines for installation of wall mounted equipment. 6.1.3.7 Review of Deviation Reports A review of Deviation Reports (DRs) was completed based on the scope of Module 17. The sample consisted of 20 DRs and are mentioned on Table 6.1-9. This sample was randomly selected from a Georgia Power Company (GPC) Document Control printout of DRs issued for Module 17 documents (drawings and specifications), during the period 1979 through 1985, covering the installation phase of the raceways. Figu r e 6.1- 9, Deviation Report Checklist, is the guide used for the review. During the review of DRs, several discussions were held with the l responsible organizations [Bechtel Power Corporation (BPC) and GPC] regarding the dispositions that were initiated. Finding 17-21, addressing a failure to initiate preventive corrective dCtion, Was issued. O 6.1-10
A concern was expressed that DRs were placed in the QA vault as (~)) ( a completed record, but did not have an indication when a design change was required. The concern was not documented in a finding, since a similar condition was identified to the Project for resolution in Module 13C as Finding 13C-13Rl. 6.1.3.8 Field Chance Recuests Approximately 10,000 electrical Field Change Requests (FCRs) have been issued since construction activities began. A review of the FCR log indicated that approximately 50 percent of the FCRs were written against raceways and supports. A sample of 30 (~} (_) FCRs shown in Table 6.1-10 addressed layout drawings pertaining to the design hardware sample and was chosen for detailed review. The review of the FCRs was conducted using the checklist shown in Figure 6.1-10 as a guide, resulting in no findings. 6.1.3.9 Vendor Documentation Several areas relating to vendor documentation were reviewed. Supplier Deviation Disposition Requests (SDDRs), equipment qualification documentation, and supplier quality verification I. documentation lists (SQVDLs) were reviewed to ascertain whether project procedures had been followed and whether the equipment meets licensing commitments. There were no concerns noted during this portion of the review. 6.1.3.9.1 Review of Vendor Drawings The vendor drawings reviewed are listed in Table 6.1-11. One of each type or category of vendor document identified in the supplier document register was reviewed to verify that BPC review and transmittal of the documents was performed based on project procedural requirements. Vendor documents were also r~g reviewed to verify programmatic compliance and conformance with ( s/ the contractually specified requirements. The review' elements used in the verification process are listed in Figure 6.1-11. The review of selected vendor documents verified that the , O- documents were reviewed and approved by BPC in accordance with ! I the project procedural requirements. Drawing and data control updated the vendor print package log book and recorded vendor document resubmittal dates as evidenced by a review of the BPC supplier document register. No findings resulted. b a 6.1- 11
l l 6.1.3.9.2 Supplier Deviation Disposition Request There were only three SDDRs that apply to this module. All three were written for specification X3AH05, Junction Boxes, to - request shipment of the equipment prior to completion of the qualification program. l i l A review for procedural compliance was performed using the l checklist shown in Figure 6.1- 12 as a guide: no findings were noted. 6.1.3.9.3 Equipment Qualification Document 6 tion Package Specification X3AH05, Junction Boxes, so tne only specification i within the scope of this module that contains an Equipment Qualification Documentation Package (EQDP). The checklist of Figure 6.1-13, used during the review, was prepared from applicable sections of the PRM and IEEE 323. There were no findings written as a result of the checklist review. There is l one associated finding, Finding 17-13, which addresses a concern i that the construction specification, as written, would permit l rigid attachment of trays to wall-mounted equipment, thereby impacting seismic qualification equipment. l 6.1.3.9.4 Supplier Quality Verification Documentation Lists Three Supplier Quality Verification Documentation Lists - Summary ( SQVDL- S ) . Table 6.1-12, related to the Bill of Material h specifications applicable to this module were identified in the BPC vendor print record file. The SQVDL-S forms were reviewed to verify that the suppliers had completed the forms and listed the quality verification documents to be delivered to the ; jobsite in accordance with the specification requirements. The review of the SQVDL-S forms verified that the completed forms were reviewed and approved by the BPC electrical-engineering group supervisor (EGS) and Quality Assurance Engineering (QAE). BPC returned the approved copies of the SQVDL-S to the supplier, as evidenced by a review of the BPC supplier document register. i 6.1.3.10 Cable and Raceway Schedule (EE580) ' Approximately 300 records in the EE580 program were reviewed to ensure that data in the program was consistent with the source data or other design documents. Information in the program data W base such as raceway type, size, the "from" and "to" locations, and the raceway identifications were verified against the conduit and tray layout drawings. The data in the EE580 library, generic information required to set up the program, was O 6.1-12
verified against the source data such as vendor drawings. Items reviewed were raceway identification formats, conduit' and tray usable areas, and cable diameters. Inconsistencies, such as the EE580 data base not agreeing with drawing information and the EE500 generic data or library not agreeing with source data, were noted during the review. Discussions with the EE580 group and the document review led the review team to the conclusion that the process associated with the EE580 program is not adequately proceduralized in accordance with ANSI N45.2.11 to eliminate the inconsistencies. Finding 17-16 was written to address this concern, additional O data inconsistencies were discovered as a result of the walkdown verification discussed in the next section. These inconsistencies are described in the response to Finding 17-17. Details of these findings are located in section'6.1.4. 6.1.3.11 Walkdown A general walkdown was conducted to verify that the design requirements listed in the walkdown checklist of Figure 6.1 14 had been implemented. The areas selected for walkdown are listed in Table 6.1-13. As the terminology indicates, this was a general walkthrough in which all raceways in each area were O not necessarily inspected. noted. The following observations were o IEEE 384 Raceway group separation deviations:
- Separation criteria: 5 ft or greater vertically, 3 ft or greater horizontally, and/or 1 in. or greater if enclosed in raceways that qualify as barriers.
- Separation deviations noted:
1BE51BRW180 1NE51BTMBC 1BE51BRW181 1NE51BTMBC 1BE513RL092 INE51BTMBA O 1BE513RLO93 1BE51BRX207 1NE51BTMBA 1NE51BTHAA 1BE302RX131 1NE311TEBN 1BE302RX132 INE311TEBN 1BE302RX133 1NE311TEBN I 1BE302RY373 1NE302TEAA O 1DE311RS259 1DE311RS259 1NE311TEBN 1NE31CRX160 1DE404RXO91 1BE31CTFCE 1DE413RS431 1BE31CTVCE 1DE413RS431 1BE31CTWCE 1DE311RS259 1BE31CTSCE
.O. 1BE322RS086 1NE322TAAB 6.1 13
. _ . . _ . . _ - . __. . _ _ . _ . . _ . ~ .
1BE322RS086 INE322TKAB 1BE322RS115 1NE322TAAB 1BE322RS115 1NE322TKAB 1BE322RS116 1NE322TAAB 1BE322RSil6 1NE322TKAB 1BE322RS118 1NE322TAAB 1BE322RSll8 1NE322TKAB 1AE333RXO28 1NE322TAAB 1AE333RX028 1NE322TKAB 1AE302RLO28 1NE302TQCB 1AE302RLO28 1NE302TQCCVA 1AE302RLO28 1NE302TQCEVA GPC has a fire separation barrier request (FSBR) program that identifies and documents separation problems. The FSER log was not reviewed for identification of the violations observed during the walkdown, since Finding 17-1 and electrical assessment audit CP01-85/29, dated April 19, 1985, already address problems with implementation of the program. The violations noted above were found to be either identi'ied or existing PSBRs. or had not yet been accepted by QC. o Control level tray 1BE7C3TOAB, approximately 200 ft in length, was installed as a solid bottom tray. The FSAR and design criteria require that control level trays be punched bottom. Finding 17-17, discussed in section 6.1.4, addresses this concern. 6.1.4 FINDINGS O o Finding 17-7 (Level 11) A minimum of 2-ft separation is required between NIS conduit and electrical noise sources per Westinghouse document ESE-1. Engineering DC-1810 permits deviations from the 2-ft requirement when the noise source is electromagnetically shielded by a totally enclosed raceway. Concurrence with this deviation had not been obtained from g Westinghouse. W Proiect Response: Westinghouse correspondence dated November 20, 1981, makes it clear that "The field installation requirements recommended by Westinghouse are to be used as guidance...." Westinghouse letter dated August 27, 1985, Log No. GP-9817, confirms that
" cont. col and electrical systems standard ESE-1, Section 4.1 are [ sic) considered guidelines for routing of NIS cables." Since the Westinghouse document is submitted as a guideline. Westinghouse recommends only that any 0
6.1-14
i i deviation from its design guideline be brought to its () attention (PRM, Part C, Attachment D to section 2). This was accomplished as noted in Conference Notes CM704 (November 20, 1981) and letter GP-9817. No Westinghouse , approval is required for deviations trom their guidelines. The Westinghouse guidelines require that -j all cables between NIS cabinets and sensors be separated by 2 ft from low-voltage noise sources such as 118 V-ac, 10 amps and higher power sources, or circuits with , switched load such as relays or silicon-controlled rectifiers (SCRs). Bechtel design permitted some deviations to the 2-ft recommendation. These were ,() I allowed only where the 2 ft could not be maintained and the noise source circuits were routed in totally enclosed raceways to provide an electromagnetic shield. This deviation was permitted by engineering judgment based on the IEEE 422-1977, paragraph 6.2.3.3, recommendation which states that totally enclosed l raceways can reduce the noise generated by power sources. , t As a result of this Readiness Review Finding, this l practice has been reviewed by the Electrical Group. l Since an analysis to establish the exact amount of shielding provided by the totally enclosed noise source raceway is not feasible at this time and since the i (T' permitted deviation was rarely utilized (two cases were found in which a totally enclosed noise source came l within 2 ft of an NIS conduit), this departure from the l Westinghouse recommendation has been rescinded. DC-1810, construction specification No. X3AR01, and . design drawing Nos. 1X3DF507 and 1X3DF51C will be j revised to reestablish the 2-ft requirement as recommended by Westinghouse without deviation. Additionally, DR ED-10197 has been issued to track and control rework to the cases noted above. The affected design document will be revised by February 28, 1986. A review was conducted of all other vendor and other i Westinghouse guidelines with regard to the criteria used () in the installation of low-level instrumentation cables. There were no other instances where deviations ( were permitted by Engineering without sufficient justification. Therefore, this is considered an isolated occurrence. () Readiness Review
Conclusion:
acceptable based on committed corrective actions. Project response is o Finding 17-8 (Level II) Design Criteria DC-2166, raceway supports, section 3.5, () includes the following requirement. " Conduit or conduit 6.1-15
i supports, lighting fixtures, grounding cables, or any other items shall not be attached to the cable tray and cable tray supports due to its impact on the damping values used in the seismic design." DC-1811, Grounding, section 3.2.6.B, and drawing CX3DE001, Grounding General Notes, Symbols and Details, note 25, require that a 4/0 ground cable be run with and attached t) the 4-kV and 13.8-kV trays. Grounding cable has been thstalled per note 25. Proiect Response: Civil Design Criteria 2166, Electrical Raceway Supports, was revised on August 6, 1985, to allow the attachment of grounding cable to cable trays and cable tray supports. This change in requirements to the civil design criteria now agrees with the current requirements in the Electrical Design Criteria Document DC-1811. A conflict previously existed between the two design criteria, and the apparent conflict was not identified during the formal design criteria interdiscipline review process. During the cable tray testing program, grounding cable was not attached to the cable trays. As a result, grounding cable was conservatively identified as an item that might impact damping in the earlier issue of the civil Design Criteria document (DC-2166). Later input from the civil / structural chief's staff has shown that its attachment will have no impact on the test results. This is because grounding cables are 4/0 American Wire Gauge (AWG) multistrand cable with flexibility similar to that of the cables installed in the trays, and the weight is only approximately 0.5 lbs/ft. The grounding cable is therefore flexible and light enough to be considered to have the same effect as adding one more cable to the cable tray. As a result, the grounding cable, unlike other components, when attached to cable trays will not impact damping. Attachment of the grounding cable to the tray does not violate any licensing commitments. The critical elements in the VEGP cable tray support system that affect damping were presented to the NRC in the VEGP Report on Cable Tray Support System Damping Values. This report justifies the use of 15 percent damping values for the VEGP design based on the Bechtel cable tray testing program. The testing program clearly l demonstrated that the significant portion of the system g i damping was the result of the energy absorbed between adjacent moving cables and through friction between the W l cables and the cable tray and that the contribution of the tray and tray support system to the system damping was insignificant. Differences between the VEGP design, O 6.1-16
I r- including tray type and support type, and the tested
'(_S j system were specifically addressed (refetenced in FSAR section 3.7.B and submitted to the NRC in GPC letter, Docket Nos. 50-424 and 50-425, dated March 5, 1982).
l l ' A related issue is the concern that the grounding cable may inhibit the seismic independence of the tray and s j support system (i.e., the flexibility required for seismic isolation across building gaps, and building or l equipment attachments). The tray details currently in l use ensure that this independence is maintained. Grounding cables connected between tray systems that are (-)
' _j
( supported independently are generally provided with enough slack to ensure independence. This is not, however, required by the design documents. Grounding cable connected between independently supported tray l l systems without enough slack will restrict the independent movement of the tray systems, resulting in probable stress concentrations at the points of l attachment. This could cause local yielding of the tray; however, the effect will be limited, as the maximum deflections of the support systems are small. l The concentration of stress could potentially cause disconnection or breaking of the grounding cable. This, however, is not a problem as documentation is available , { justifying that the tray system without the grounding '
/~) \/
cables provides an adequate path for returning ground fault currents to the source. Civil / Design Criteria document. DC-2166, will be reviewed by the electrical discipline in order to ensure that a detailed interdiscipline review is performed. l This will be completed by February 15, 1986. ' Readiness Review
Conclusion:
Project response is acceptable based on committed corrective actions. o Finding 17-10 (Level III) A. () Calculation X3CV01, Revision 3, which is a supporting calculation for establishing the amount of zinc from raceways and cables installed inside containment, is classified 62E. The results of the calculation are used for determining the corresponding amount of hydrogen generation inside g- containment. D B. The amount of zine in the raceway systems inside the containment is deduced from preliminary raceway quantity data. pg C. Calculation X3CV01 does not consider the amount of (,) zinc contributed by the interlocked cables installed in the containment. 6.1-17
i l D. The weight of cable insulation does not correspond to the values listed in Table 6.1.2-4 of FSAR section 6.1.2. Proiect Response: A. Calculation No. X3CV01 was incorrectly judged to be of a nonsafety classification 62E. Nevertheless, the calculation was generated, checked, reviewed, and verified within the electrical discipline using l the same process used for a Class lE calculation. Calculation No. X3CV01 will be revised to change the nonsafety classification 62E to safety classification l llE. A review was made of all other electrical
- calculations relevant to this module, and no other classification errors were found.
l ! B. The total curface area of the galvanized raceway material inside the containment as obtained from Revision 2 of calculation No. X3CV01, dated April 17, 1981, was conservatively estimated and provided adequate allowances for increases in material quantities from initial design layouts. Since the containment design was nearing completion l and relatively few components had been added since 1981, Engineering judged the information provided for sizing the hydrogen recombiner as still adequate. As a result of this finding, calculation X3CV01 was revised to incorporate as-built quantities of zinc. The results confirmed the adequacy of engineering judgment, and the current design is not impacted. Additionally, all other calculations relevant to this module were reviewed to determine the extent of procedural noncompliance with the requirements for scheduling revisions to incorporate final design data, and to include all applicable design input or to provide justification ; when specific input is not included. Two cases (calculation X3CK14, X3CK15) of the former and one case (calculation X3CLO2) of the latter were identified. These calculations were reviewed and were found to have no impact on final design. Calculation X3CLO2 is the subject of Finding 17-18. i C. The weight of cable insulation does not correspond l to the value listed in Table 6.1.2-4 of the FSAR. I The value of cable weight shown in FSAR Table ! 6.1.2-4 is the value from calculation No. X3CV01 l increased by 50 percent to ensure adequate margin over the estimated weight. As stated in B above, the calculation was updated to reflect the as- built quantities to ensure that the design is still O 6.1-18
r~ adequate. There is no impact on the current design. Calculation No. X3CV01 is being revised to (_}f show the weight differential from the FSAR value as additional margin. There is no conflict between the FSAR and actual design. A review of all other raceway calculations did not disclose any nonconformances with licensing commitments. Revisions to calculations X3CV01, X3K14, and X3CK15 Will be made by January 13, 1986. A training ) session will be held by January 31, 1986. The PRM will be revised by February 28, 1986. r i Readiness Review
Conclusion:
Project response is acceptable based on committed corrective action. o Finding 17-11 (Level III) There is no project calculation that substantiates the design of Category I duct banks. Project Response: Generic duct bank designs, consisting of several physical options dependent on site- and seismic-related conditions, complete with approved calculations, was prepared by the Civil / Structural Chief's office based on BC-TOP-4A methodology. A set of t' simplified instructions was, transmitted by memorandum \ from the chief civil engineer to aid in selecting the appropriate details to be used on specific jobs. The Vogtle Civil / Structural Group-- on the basis of the Vogtle shear wave velocity, seismic level, and the generic instruction memorandum--selected the appropriate duct bank option details for this project. Because the instructions and process for design selection are relatively simple and easily duplicated by the Civil / Structural Group, the group did not feel there was a need to issue a calculation. In retrospect, it is recognized that project procedures imply that a calculation should have been generated. Therefore, ,g calculation No. X2CD13.5, Revision 0, was issued on t s_) July 19, 1985, to document the selection of the duct bank details. No other design items provided by the Civil Group to the electrical raceway design lack supporting calculation. Therefore, this item is considered isolated. () Readiness Review
Conclusion:
acceptable. Project cesponse is o Finding 17-12 (Level II) Cable tray sections 1NE321TilAE and 1AE321TYAK, (drawings O 1X3DF321, Revision 18 and 1X3DK321. Revision 6) show 6.1-19
vertical separation of 2 ft 6 in. with no barrier callout. The minimum separation for this installation per IEEE 384 should be 5 ft 0 in. unless a barrier is installed. Project Response: Cable tray sections on 23 conduit and tray drawings and associated tray support / layout drawings were reviewed by Readiness Review to assure that separation requirements were considered by Design Engineering. Of all the trays reviewed, one case was found where 5.-ft separation was not maintained and a barrier requirement was not shown. Drawing Nos. 1X3DF321 and 1X3DK321 do not show a fire barrier between cable tray section 1NE321THAE and 1AE321TYAK, even though the sections are separated h vertically by only 2 ft 6 in. IEEE 384 tequires a vertical spatial separation of 5ft and a horizontal spatial separation of 3 ft between cable trays of different raceway separation groups. If this separation requirement is not satisfied, then an acceptable alternative (e.g., a fire protection barrier installed between the trays, enclosed trays, etc.) must be provided. The design criteria and checking procedures normally ensure compliance to separation requirements during the tray design effort. In cases where spatial separation cannot be followed, a requirement for a barrier or other approved spatial separation alternative is normally identified on the raceway design drawings in the form of a note and a detail of location. For the case noted (separation of trays 1NE321THAE and 1AE321TYAK), information regarding the lack of adequate spatial separation and the requirement for the installation of a fire barrier between the trays was omitted. Addition of a barrier to conform to the IEEE 384 requirement has subsequently been shown on cable tray layout drawing No. 1X3DK321 as of August 1, 1985. There is no need to revise drawing No. 1X3DF321 to show the separation barrier requirement, because this drawing is used only for conduit installation and tray identification, not h tray installation. Based on the number of drawings reviewed by Readiness Review, the inadvertent omission of one barrier note is considered an isolated instance. Furthermore, the omission of this detail for the case noted is not h considered significant, as field procedures require Construction to verify separation requirements during installation and to initiate an FSBR accordingly (see construction Finding 17-1). Additionally, area l 6.1-20
/"' walkdowns for room turnovers also contain requirements for separation verification. Any additional barrier requirements will be identified as a result of these efforts.
Readiness Review
Conclusion:
Project response is acceptable. Of the 23 drawings, Readiness Review O- determined that, for all other cases, barriers were indicated by Engineering as required. The one omission was seen as an isolated occurrence. l l o Finding 17-13 (Level II) : Construction specification X3AR01, section E.B.7.1, requires that a tray run terminating at the wall-mounted junction box, switchboard, or other enclosure be terminated with a rigid, bolted connection. Although no wall-mounted equipment was identified which had a tray ; termination, there is no analysis to justify the requirement. Project Response: To ensure as-built installation is consistent with vendor seismic qualifications, cable trays should not be rigidly attached to seismically tested vendor equipment. Although construction fg specification X3AR01, section E8.7.1, paragraph F, - (_j required cable tray to be rigidly bolted to junction boxes, switchboard or other enclosures, upon review of j Unit 1 installation it has been verified that no cable ! trays have been attached to any Class lE equipment.- The verification consisted of a review of cable tray l entrances to major distribution centers. The cable i trays were installed in accordance with drawing CX3DF001 ' (conduit and tray general notes, symbols, and details), . note 13 of which states, " Cable trays shall not be directly attached to any electrical equipment which has been seismically tested." Therefore, the cable tray installation meets the seismic requirements. The general construction specification has been clarified per E-FCRB-10, 568, and the attachment of cable tray to Class lE equipment is now prohibited. The CSCN was written to provide consistency between specification X3AR01 and drawing CX3DF001. Additionally, a general revision was made to the
/~) specification, and comparison to other design documents ,
k/
% (drawing and specifications) was done to ensure !
consistence. In addition, the general notes on drawing No. CX3DF001 ! were reviewed against construction specification No. O X3AROl, section E8, by the electrical chief engineer's staff. The documents were reviewed for clarity. l 6.1-21
consistency, and lack of definitive directions in the installation of cable trays and conduits. Although some
)
vagueness was noted, no conflicting information was found. Readiness Review
Conclusion:
Project response is acceptable. o Finding 17- 15 (Level III) Raceway numbering is inconsistent with the numbering system established on general notes drawing No. CX3DF002 as follows: A. Slots and gutters are identified using two characters (positions 9 and 10) instead of one (position 9). Characters 11 and 12 are being used to provide a unique sequence number instead of characters 10 and 11. B. The Conax connector number is not defined on drawing CX3DF002. C. Several trays and conduits on drawing No. 1X3DF414 do not follow the defined numbering system.
- 1. Trays use 11 characters instead of 10 or 12 characters.
2. Conduits use 12 characters instead of 11 characters. D. The following raceways shown on drawing Nos. 1X3DF50A and 1X3DF514 are not defined on drawing No. CX3DF002:
- 1AE504KXIHCS.
- 1AE514VDVLV4, 6, 8, 12.
Project Response: The concerns expressed in the finding address inconsistency of raceway numbering as follows: A. Slots and gutters are identified using two characters (9th and loth characters) instead of one character (9th character) specified in electrical general notes of drawing No. CX3DF002. This then requires that the llth and 12th characters be used to identify a unique sequence number in lieu of the loth and lith characters specified in the general notes. H. Eleven characters were used to identify several trays on drawing No. 1X3DF414 instead of 10 or 12 characters apparently specified in the general notes. l l 6.1-22 1
.= . - . . - - _ - - . _ . - . . .
k i C. Twelve characters are used to identify several i O. conduits on drawing No. 1X3DF414 in lieu of the maximum 11 characters indicated in the general notes. ; D. Numbering system for Conax connectors is not defined i in the general notes. t E. Raceway Nos. LAESO 4KXIHCS, IAE514VDVLV4, -6, -8. and l
-12 are not defined in the general notes. l 1
In accordance with the existing numbering system j requirements as shown on drawing No. CX3DF002, each' T raceway (tray, conduit, or special raceway) is to be : identified with a maximum of 11 or 12-alphanumeric l characters. Each character indicates the following: ; i Common All Raceways ; First character ' Unit .!
- l. Second character Separation group :
l Third character Responsible discipline' Fourth character Facility j Fifth character Area i Sixth character Drawing sequence ! l Seventh character Commodity (tray, conduit, or l l special raceway) l Eighth character Service level j l Conduit l l i Ninth character : Tenth character Sequence number for conduit ] Eleventh character l Tray Ninth character Tray section Tenth character (Alpha character) Eleventh character Tray subsection Twelfth character (Alphanumeric character) ( ~ l Special Raceway l I Ninth character Type of special tray Tenth character Unique sequence number Eleventh character The second character is the character that identifies the raceway safety classification and separation l grouping. The rest of the characters are for the unique identification of the raceway. Discrepancies noted in review of the design drawings for tray slots and conduit O were in the loth through 12th characters which represent 6.1-23
the unique sequence numbering of the raceway. Discrepancies in sequence numbering between the general notes and actual raceway identifications assigned are explained as follows: A. For slots and gutters, two characters, SL for slot and GT for gutter (characters 9 and 10), are sometimes used as an alternate to the S for slot and G for gutter (character 9) as specified in the general notes. This results in using the lith and 12th characters to identify a unique sequence number for slot or gutter instead of using the loth and lith characters specified in the general notes. Thus, slots and gutters may be denoted by either an 11 or 12 character identifier. B. Tray identification is consistent except for the 12th character. General notes drawing indicates an alpha sequence character in 11th and a numeric sequence character in 12th (V1, V2 for vertical tray sections 1, 2). The 12th character was sometimes dropped, indicating only V in lith character spot. However, total raceway number is still unique without duplication. C. Conduit identification is consistent using 11 characters except for two special nonsafety-related systems, where it was found necessary to add a 12th alpha character. General notes indicate a maximum of 11 characters. h D. Raceway for Conax connectors is considered a special raceway. (See item E, below.) M. Special raceways for Conax (lAE504CONAX9), mineral insulation cable (lAE504KXMICl), and Westinghouse i special cable (IAE504KXIHCS, IAE514VDVLV4, etc.) are ' not covered by any of the classifications shown on the general notes drawing. A note covering these special types of raceways will be added to the general notes drawing No. CX3DF002. These discrepancies exist because the general notes on ; drawing No. CX3DF002, with regard to the numbering l system, have not been updated to cover all aspects of design development, such as the use of special raceways ! which require the application of special number ! designations to distinguish them from the standard g raceways, the need for a 12th conduit character for W special applications, or the lack of a need for the 12th tray character in certain instances. Slot and gutter sequence characters were inconsistently applied. O 6.1-24 I m w =
The discrepancies exist only for special raceway O applications or for the sequence characters of the raceway identifiers in some standard raceways. Each identifier is still unique: therefore, there is no impact on plant safety, cable routing, or ability to uniquely identify each piece of raceway. To ensure that all the exceptions will be covered, a review of the EE580 data base and the physical drawings l will be made to confirm consistency in numbering with l general notes drawing No. CX3DF002. The general notes. on drawing No. CX3DF002 with regard to the numbering system will then be revised to accommo6 ate all the l O- exceptions made during the design processes. This will be completed by January 31, 1986. Readiness Review
Conclusion:
Project response is acceptable based on committed corrective action. o Finding 17-16 (Level II) The design process associated with the EE580 cable and raceway program is not sufficiently proceduralized to assure that design output (raceway installation, cable pull, and cable. termination cards) correctly reflects the design shown on other project documents such as () raceway layout drawings, elementary drawings,-etc. A specific concern was that checking of the input data was not always independently performed. Additional details to substantiate the above-stated concerns are as follows: A. Electrical drawing No. 1X3DF411, Revision 23 (tray section 1BE411TEAB), shows a 12-in.-wide tray transitioning to a 6-in.-wide tray. The EE580 printout shows tray IBE411TEAU as a 6-in.-wide tray. B. Electrical drawing No. 1X3DF307, Revisic' 12, shows conduit 1AE30lRS070 as 4 in. EE580 shows conduit 1AE301RS070 as 3 in. C. Electrical drawing No. 1X3DF430 Revision 19, O identifies tray section 1BE414TLCM. EE580 shows tray section 1BE414TLCM as being on drawing 1X3DF414. 1 I 6.1-25 l J
D. Electrical drawing No. 1X3DF414, Revision ll, shows conduit 1NE414RS055A. EE580 does not show this conduit. ! Additionally, regarding the EE500 program library: l E. For trays, the siderail height instead of the actual usable interior height is used to calculate the tray usable area. ' P. For conduits, the inside diameter (ID) of polyvinyl chloride (PVC) schedule 40 has been used to calculate the usable area of PVC schedule 40 and schedule 80. Project Response: The finding addresses a concern that the design processes associated with the EE580 cable and raceway program are not sufficiently proceduralized to ensure that the design output used in the installation of cables and raceways correctly reflects the parameters shown on the lead documents (i.e., design drawings). The EE580 circuit and raceway program is a large, online BPC Standard Computer Program (SCP) used by Engineering to provide Construction with timely and accurate information concerning the electrical raceway installation, the installation of circuit cables, and cable terminations. In addition, the program is used to track raceway fill and cable lengths. It also performs analyses to ensure that circuits are installed in the correct service level raceways, equipment, and/or , devices, as well as the correct separation groups. The EE580 program is documented and managed the same as other standard computer programs developed and used by BPC. Its use is governed by the requirements of the EE580 user manual, which contains sufficient information to operate the program effectively. This manual is issued and controlled by Bechtel San Francisco Information Services and governs user actions relative
; to implementing the computer program. ,
l Raceways (tray, conduit, duct, etc.) are inputted into ' the EE580 program from the raceway layout design drawings. The review, checking, and verification are done by the comparison of the output data generated through the EE580 program and the raceways shown on the g design raceway layout drawings. The process of inputting the raceway data from the design drawings into W the EE580 program and the verification and checking of the EE580 output against the design drawings are required to be done by different individuals. However, O l 6.1-26
r- there have been occasions when inputting and checking of > ( g/ data have been performed by the same individual. The checker is only one line of defense against EE580 input errors. The first line of defense is the EE580 program itself. The program screens the designer's input data for conformance to specific protocol criteria. Any data ( not consistent with the criteria are identified to the designer for resolution. Data passing this program screen are submitted for checking. Data inconsistencies not caught by the checker should be picked up in the field by GPC Construction Engineering, the electrical contractor, or GPC Quality Control (or GPC Nuclear ( ' Operations /Startup for cable data errors). ~ For circuit cable routing, the EE580 group inputs into the EE580 program the raceway paths in which the cable i is to be installed. The EE580 group, in selecting the ' paths for the cable, utilizes an EE580 program computer dump, which is a listing of interlinked raceways. This ; listing is the product of the previously completed raceway input activities (Lee discussion above). The EE580 program is then utilired to route the cable through the previously inputted raceway paths, which have been verified against the design raceway layout drawings. The routed cable is automatically placed on
,I hold so that it cannot be released to Construction for pulling. A program output of the routed cable (a \ complete listing of the paths the cable will traverse) will then be turned over to an independent group, the Electrical Physical Layout Group, which will perform a cable route verification (RV) check. This activity ensures that the cable is routad in the shortest and/or correct paths as shown on the design drawings. No routed cable will be released to Construction unless it has been route verified and an RV status has been
- assigned to the cable in the EE580 program.
Everyone in the VEGP Project HOE involved in the EE580 program has received formal training on the use of the g-).s EE580 program, including interfacing with jobsite ( entitles. Based on the above, it can be seen that an acceptable process exists which requires the review, checking, and verification of the results of the design processes
} performed based on the assumption that no tray cover will be used in power cable trays, while total tray weights for control cable trays and instrumentation cable trays were based on covered trays).
(2) The weight of grounding cable attached to medium-voltage cable trays is not considered. l 1 l
- 3. Case-by-case analyses of tray fills greater than 40 percent for control and instrument trays are
, () ! being performed as allowed by the FSAR and DC-1810 using an unverified version of a l computer program. The analyses are not being properly documented. I
- 4. Analyses are not being performed to ensure that trays will not be filled above siderails as required by the FSAR and DC-1 BIO.
B. Construction specification X3AR01, section E8, attachment B, paragraph 1.2.2.3, allows jobsite tray installer to add tray covers without revising design drawings (including EE580). C. No procedure / instruction specifically covers documentation of adequacy of overloaded trays. Project Response: The finding addresses the following concerns in regard to cable tray loading. A. Calculation did not reference the source of the
- design input data as required by PRM, section C-9.6.
B. Examples of cable tray configurations exceeding their maximum nominal design weight limitation are
'N provided without indicating how these deviations are
(% controlled. Also, standard tray accessories (covers 6.1-35
and grounding cables) are not generically addressed. C. Cable trays with overfill were analyzed and checked against the tray maximum unit weight, and authorized by using an unverified version of the computer program. Authorization of tray overfill above siderails is not properly documented. D. Construction specification No. X3AR01, section EB, attachment B, paragraph 1.2.2.3, allows Construction to install cable tray covers without revising the tray layout drawings or indicating that in EE580 program. E. No procedures are available to control and document cable tray overfill and overweight authorization. The response to each of the above addressed concerns is as follows: F. Calculation No. X3CLO2 did not reference the source of the design input data for tray weight, cable weight, or cable outside diameter (OD). Although the source data was not referenced in the calculation, the correct data supplied by the vendor, with the exception of one cable OD, was utilized in the calculation. The source data will be annotated to show vendor data references. Correction of the one incorrect cable OD will not have any impact on the results of the calculation since it is not used as the worst-case OD.
- 1. To ensure that trays will not exceed weight limits, the EE580 program has been conservatively set to identify trays with fill exceeding 30 percent for instrument and control trays (where the maximum allowable fill is 40 percent). The tray fill is allowed to increase on an incremental basis beyond the 30-percent fill, and the fill is authorized if the cable tray weight does not reach the unit weight limit of 54.2 lb/ft. Once the tray weight reaches the weight limit, regardless of the tray fill, no additional cables will be added to this tray, or Civil / Structural will be consulted to confirm the tray support adequacy if additional cable has to be routed in the tray.
Calculation X3CLO2 currently utilizes the most commonly used control and instrument cable types as the basis for the cable weight calculations. On this basis, 35- percent tray fills were O 6.1-36
( identified that could result in reaching the tray weight allowable limit. To make the calculation completely address generic conditions, the calculation will be revised to address the worst-case control and instrument cable types (i.e., those types with the highest r density) generally used in trays (the ( calculation already addresses worst-case power cables). The tray loading for other cable types used for special applications will be addressed individually as required. These revisions should justify the existing 30-percent cutoff point in EE580, and therefore no impact on l(r-}. j m, installation is expected. The weight of trays exceeding the 30-percent l fill limit are analyzed on a case- by- case basis ; utilizing the WTCALC program, which is discussed ; in G, below. j
- 2. The calculations that generate the 66.9 lb/ft
- power cable tray weight are being deleted in I calculation X3CLO2, Revision 3. This weight is !
l for a hypothetical tray overfill condition that does not exist in the plant. Power cable tray weight is reviewed with computer program WTCALC l e (see 3, below) anytime a tray fill that is
\- greater than the standard allowed value is authorized. This includes review of maintained spacing cables whenever the maintained space is ;
reduced below the standard value (covered by l X3CLO2). This is acceptable since calculation X3CLO2 (when revised per 1, above) is expected to demonstrate that no tray overweight condition ! can exist using the worst-case cable (s) at standard allowable fill values.
- a. It was the Vogtle Project's position during initial tray design layout that tray covers would generally be avoided on power trays.
( Therefore, it was decided not to penalize in the calculations for both tray cover and maximum cable weight for all power tray support designs. Weights of these trays would be monitored; and, where a cover was
requirements have been properly made.
Concerning part 3, RG 1.32 is the regulatory guide that 1 endorses IEEE 308-1974, Criteria for Class lE Power Systems for Nuclear Power Generating Stations. Although I these documents are relevant to the design of electrical s systems, there is no guidance in either of these that ( ) has input to the design of raceway systems. In fact, raceway per se is not even mentioned in either document. Physical separation is required and is imposed in RG 1.32 by reference to RG 1.75. Since all l separation criteria are provided by RG 1.75 and its l endorsement of IEEE 384, both of which are referenced in DC-1810, there is no need to reference RG 1.32 on the cover sheet of DC-1810. The fact that IEEE-308 is also referenced in DC-1810 does not impose the requirement that RG 1.32 be referenced. No action is required as a result of this finding. As described by part 4, the reference to IEEE 384-1981 (" in DC-1001 is incorrect. The correct version is the
\- 1974 revision as endorsed by RG 1.75 and as referenced in DC-1000-E and in the FSAR (section 8.1). DC-LOO 1 vill be revised to correct this error. This change will n3t affect the design or have any hardware impact since Detign and Construction (via construction specification X', AR01, section E8) have been using the correct version
. \ et IEEE 384. With respect to a broadness review, the only design docuiaent identified in the electrical discipline that refers to a date for IEEE 384 is DC-1000-E. The FSAR is consistent with DC- 1000-E. The control systems General Design Criteria DC-1000 J also (' N references IEEE 384-1974. The only other project design document that could be identified that provides separation criteria is DC-1001. Therefore, this problem 6.1-43
is limited to DC-1001 and will be eliminated by revising it. The discrepancies identified in parts 1, 2, and 4 of this finding are isolated and are attributable to cases of engineering oversight. lI Since the concerns identified in this finding are random and isolated in nature, no further action is required. DC-1001, DC- 1010, and DC-1810 will be revised by January 31, 1986. An FSAR change notice will be issued in accordance with DC-1010 by February 15, 1986. Readiness Review
Conclusion:
Project response is acceptable based on committed corrective action. o Finding 17-21 Revision 1 (Level III) Unauthorized removal of a safety-related tray grounding cable was reported on DR-1912 without being reported on a Corrective Action Report (CAR) as required by field procedure GD-T-01. Project Response: Investigation of this finding has revealed that, although DR- 1912 may have been an isolated incident to raceways, the problem of unauthorized concern. During rework of electrical items has become a the investigation of a Quality Concern on unauthorized reworks, it was learned that the Technical Support Group was also reviewing this area of concern. The results of Electrical Engineering's review were similar to those of the Technical Support Group: i.e., corrective action would be required to resolve the recurring deficiencies. Eighteen deviation reports had been initiated to document field rework without authorized documentation. CAR E-0003 was issued by the Technical Support Group on December 7, 1985, to correct the problem of reworking items without a Rework Request. The 18 DRs are listed on this CAR. The recommended action and corrective action required are as follows: A. Provide training to responsible engineers. Retrain when major changes are made to the procedure and document training attendance. Estimated completion date for this item is January 31, 1986. B. Identify, through established in-house program, l personnel responsible for repetition of similar violations and provide feedback. Estimated completion date for this item is January 31, 1986. O 6.1-44 l l
J l i C. Evaluate procedure ED-T-17, paragraph 4.12, and make i changes as applicable. Estimated completion date for this item is January 31, 1986. l Readiness Review
Conclusion:
Project response is acceptable based on committed corrective action. O O O O 1 O , 0023q/030-6 l f 6.1 45 .
)
TABLE 6.1-1 (SHEET I 0F 20) 1 i C0pellTMENTS VERIFICATION MATRIX Classification Design i Ref. FSAR Commit- Design Criteria Desinn Document No. Requirement Section ment Roo't Section Tyge Ember Comments i { 4114 10 CFR 50, APP. A, GDC 2, 3.1.1 Yes DC-1000-E, Design criteria were { 95 Design Bases for Protection and Rev 5, reviewed to verify j against Natural Phenomena. 8.1.4.3 4-3-84; inclusion of GDC 2. j DC-1000-C, for seismic qualifi-
] Rev 3, cation, refer to veri-9-30-83; fication of RG 1.100.
DC-1005, j Rev 1, j A-4-83; DC-1810, hv 6, 10-3-83. 1 j 789 10 CFR 50, APP A., 3.1.I Yes DC-1000-E, Design eriteria were ! GDC 3 Fire Protection. Rev 5 reviewed to verify 4-3-84; inclusion of GDC 3. DC-1810, for review of fire pro-Rev 6, tection considerations ! j 10-3-63. covered by this module, i refer to verification
. of RG l.75.
1 i i T j 0043q/029-6/I i i h I i
4 l TABLE 6.l-1 (SHEET 2 OF 20) Classification Design Ref. FSAR Connit- Design Criteria Desion Document ! No. Requirement Section med Rea't Section Type Number Corrments 4115 10 CFR 50, APP. A, GDC 4, 3.1.1 Yes DC-1000-E, Design criteria and 2360 Environmental and Missile 8.1.4.3 Rev 5, hazards were reviewed to . Design Bases. 4-3-84; verify inclusion of GDC 4. DC-1001, For environmental quali-
- Rev i, fication, refer to verifi- +
8-30-83; cation of RG l.89. For i DC-1003, hazards review, refer to f' ] Rev 2, verification of RG l.75. , ! 6-29-83; DC-l006, 4 hv 2 i 7-13-83; DC-1018, Rev 2, 10-11-83; ! DC-1810, Rev 6, 10-3-83. i t i t I _._. ,._ I 0043q/029-6/2
+w+h w*._-s _ -w-a.. w 1c._- s_. y .pw _ w -- w _ u e L a s. _eu_* m__ __.____m_m- __ __ -_._-m_m _ _ _ _ _ - ma
O O - TABLE 6.1-1 (SHEET 4 0F 20) Classification Design Ref. FSAR Comit- Design Criteria Deslan Document No. Reaairement Section ment Rea't Section M Number Coments 804 10 CFR 50, APP. A, GOC 22, 3.l.3 Yes DC-1000-E, Design criteria were re-i Protection System Rev 5, viewed to vertfy inclusion Independence. 4-344; of GOC 22. For seismic DC-1001, qualification, refer to GDC 22 requires, in part, Rev 1, verification of RG l.100. that the protection system 8-30-83; For protection system inde- ; shall be designed to assure DC-1000 -C, pendence, refer to verifi-I that the effects of natural Rev 3, cation of RG l.75 and IEEE phenomena, and of normal 9-30-83; 279, operating, maintenance, DC-1810, testing, and postulated Rev 6, accident conditions on 10-3-83; redundant channels do not DC-1005, result in loss of the Rev 1, protection function or shall 4-4-83. be demonstrated to be acceptable on some other defined basis. 806 10 CFR 50, APP. A, GOC 24, 3.1.3 Yes DC.1000-E, Design criteria were re-Separation of Protection Rev 5, viewed to verify inclusion and Control Systems. 4-344; of GDC 24. For physical DC-i001, independence, refer to: Rev 1, verification of RG 1.75. 8-30-83; (Protection system circuits DC-1810, pertain to Class IE separa-Rev 6, tion groups that are physi-10-3-83. cally separated from control systeen circui ts. , These cor. trol system circuits pertain to the j non-Class IE separation f group.) 0043q/029-6/4 w --- _.__w.---_-------___---__+a v - m +-v,a-, , v, , , a w ,s w - +w-- + a _ , -- ,u___ --_ _ _ - - - - - - - . _
O O O O O O O TABLE 6.l-1 (SHEET 5 OF 20) Classification Design Ref. FSAR Commit- Design Criteria Desian Document No. Requirement Section ment Reo't Section Type Number Cw ments 131 RG 1.32, 1.9.32 Yes DC-1000E, Review of design criteria Criteria for Safety- Rev 5, verified that RG l.32 is Related Electric Power 4-3-84. referenced. See Finding Systems for Nuclear 17-20, item 3. For physi-Power Plants. cat independence of Class IE circuits, including receways, refer to veri fi-cation of IEEE 384. 18 RG l.7%, Rev 2, 8.1.4.3 Yes DC-1000E, Const. X3AR01-E8, Review of design criteria 160 September 1978, l.9.75 Rev 5, Spec. Rev 17. and construction specifi-Physical Independence 4-3-84; cation verified that of Electric Systems. DC-1001, RG l.75 is referenced. Rev 1, I 8-30-83; DC-1809, Rev 4, 1-21 42; OC-1810, Rev 6, 10-3-85. 90 Where redundant safety - 8.3.l.4 Yes for physical separation related raceway systems of redundant safety-related traverse each other, raceway systems, refer to separation in accordance verification of IEEE 384. with RG l.75 as a minimum is maintained. 0043q/029-6/5 4 1
~
f I TABLE 6.1-1 (SHEET 6 0F 20) Classification Design Ref. FSAR Comit- Design Criteria _De_sh n Document No. Requirement Section mejn Rea't Section Tyge Number Coments 4327 Class IE circuits in metal- Q430.75 Yes For physical separation of lic conduit shall maintain safety-related raceway sys-minimum separation in ac- tems from non-Class IE , cordance with RG l.75 when raceways, refer to verifi-routed in the proximity to cation of IEEE 384. non-Class IE cables in open ventilated trays, unless acceptable barriers are provided. Where feasible, redundant Yes DC-1810, Design criteria were cable spreading areas Rev 6, reviewed to verify that the i should be utilized. 10-3-83. requirement for separate train A and B cable spreading rooms is included as a design basis. In general, locating Yes DC-1810, Design criteria were redundant circuits and Rev 6, reviewed to verify.that the equipment in separate 10-3-83. method of separation for safety class structures redundant raceways is in affords a greater degree accordance with IEEE 384. of assurance that a single The design criteria verified event will not af fect the requirement for redundant systems. This providing separate spreading method of separation rooms, safe-shutdown rooms,
- should be used whenever penetration rooms, cable practicable and where its chases, electrical tunnels, use does not conflict with duct banks, electrical other safety objectives, corridors and safety-related equipment rooms. These separate areas were required i
0043q/029-6/6 i h i 1
- _ _ _ . - _ _ _ _ _ _ _ _ - _ . - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ ._-__- ___ _ - ___ _ ___ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ ~
TABLE 6.1-1 (SMEET 7 0F 20) Classification Design Ref. FSAR Comit- Design Criteria Desian Document No. Requirament SectIon ment Rea't Section Type ge<aber Comants to be physically separated from each other by 3-hr minimum rated barriers. Review of design criteria verified that in tunnels, where redundant safe shutdown circuits are installed with less than 20 ft, physical separation, circuits of one separation group are installed in conduits adedded in the tunnel
- ffoor.
1 4 A degree of separation com- Yes DC-1840, For hazards review, refer l mensurate with the damage Rev 6, to verification of potential of the hazard shall 10-13-83. IEEE 384. be provided such that the j independence of redundant i Class IE systems are main-j tained at all acceptable levels. 'This should not be construed to inply that adequate separation of re- , dundant circuits can be achieved in a confined space. l !. 20 RG 1.89, 8.I.4.3 Yes DC-1000E, Review of design criteria ! 4958 Qualification of Class IE 1.9.89 Rev 5, verified that RG l.89 is ! Equipment for Nuclear 4-3-84; referenced. See finding Power Plants. DC-1007, 17-20, items I and 2. l j Rev 4 Also, refer to verification 1 4 8*> . of IEEE 323. i 0043q/029-6/7 i i i I I
O 3 TABLE 6.1-1 (SHEET 8 0F 20) l C assification Design Ref. rSAR Conynit- Design Criteria Desion Doctsnant Requirement Section ment Roo' t . Section Type Ntsi6er Convnents No. 22 RG l.100, 8.1.4.3 Yes DC-1000E, Review of design criteria 175 Seismic Qualification of I.9.100 Rev 5, verified that RG 1.100 is ! Electric Equipment for 4-344; referenced. See Finding Nuclear Power Plants. DC-1005, 17-20, items I and 2. Rev 1, Also, refer to veri fica-4-445. tion of IEEE 344. 2968 ANSI N45.2.4-1972/IEEE 336- 17.A.0 Yes DC-1000-E, Const. X3AR01-E8, Review of design criteria 1971, Installation, inspec- Rev 5, Spec. Rev 16. and construction specifi-tion, and Testing Require- 4-3-84. cation verified that this monts for Instrumentation and standard is referenced in Electrical Equipeent During these documents. the Construction of Nuclear Power Generating Stations. i 108 IEEE 279-1971, DC-1000E, Review of design criteria Criteria for Protection Rev 5,- verified that IEEE 279 is Systems for Nuclear 4-3-84; referenced. i Power Stations. DC-1001, Rev 1, 8-3043. , Essential safety actions 1.2.12.1 Yes f or physical separation are provided by equiprent of protection system i of suf ficient redundancy raceways, refer to and independence so that verification of IEFE 384 no single failure within the system can prevent proper protective action at the system level, when required. 0043q/029-6/8 I i - _ - - - _ . - - - _ _ _ . - _ - - - _ _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ - . - . - . - . - . . - . , - , . - . . , . , - . . . . .. , - . - . ~ - . - . - . . . - . -
P
\ \ (
TABLE 6.1-1 (SitEET 9 OF 20) Classification Design Ref. FSAR Comit- Design Criteria Desion Document No. Requirement Section ment Rea't Section Type Number Coments Channels that provido Yes DC-1000-E, Raceways for the Westing-signals for the same Rev 5, house nuclear instrumenta-protective function shall 4-3-84; tion system (NIS) are de-be independent and physi- DC-1001, signed in accordance with cally separated to Rev 1, the Westinghouse separation ' acconplish decoupling of the 8-30-83; requirements for the four effects of unsafe environ- DC-1810, NIS channels. Refer to RRF mental factors, electric Rev 6, 17-7. For physical separa-transients, and physical 10-3-83. tion of protection system accident consequences raceways, refer to verifica-4 documented in the design tion of IEEE 384. basis, and to reduce the likelihood of interactions between channels during . maintenance operations or in the event of , channel malfunctlon. i In order to provide Yes For identification of assurance that the require - cable raceways for the ments of IEEE 279 can be different separation applied during the design, groups, refer to i construction, maintainence, verification of IFEE 384. and operation of the plant, the protection system 4 equipment (i.e., i n tercon - necting wiring, components,
~
modules, etc.), shall be identified distinctively as being in the protection system. I This identification shall distinguish between redundant portions of the protection
]
1 system. OGUq/029-6/9 i
> 0 0 TABLE 6.1-1 (SHEET 10 0F 20)
Classification Design Ref. FSAR Comit- Design Criteria Desian Document No. Requirement _Section ment Rea't Section m T Number Coments 132 IEEE 308-1974, l.9.32 Yes DC-1000E, Const. X3ARDI-EB, Review of design criteria , 27 Class IE Power Systems 8.l.4.3 Rev 5, Spec. Rev 17. and construction specifica-for Nuclear Power Generating 4-3-84; tion verified that IEEE 300 . Stations. DC-1001, is referenced. See Finding Rev I, 17-20, Itern 4 B-30-83; DC-1810, Rev 6, 10-3-83. Corpor,ents of Class IE Yes DC-1000-E, See the following for raceway identification power systems and their Rev 5, tables for docu- refer to verification of associated design documents 4-3-84 ments reviewed: IEEE 384. shall be marked or labeled 6.1-4 in a distinctive manner. 6.1 -5 Drawings were reviewed to 6.14 assure that the letter "Q" 6.l-7. and " Nuclear Safety
'Related" appeared thereon. Design criteria, calculations, biii of material specifications, and construction specifications were reviewed to assure that fhey were identified by the appropriate project classification number.
Suf ficient physical separa- Yes For physical independence tion and redundancy shall of Class IE circuits, refer be provided to prevent the to verification of IEEE occurrence of a comon f ail- 384. ture mode in the Class IE power systems for any DBE. 0043q/029-6/10
O O O TABLE 6.1-1 (SHEET II 0F 20) Classification Design Ref. FSAR Comit- Design Criteria Desian Document Requirement Section Rea't ,S_ec_t ion, Type Number Coments , No. mJen 29 IEEE 323-1974, 8.1.4.3 Yes DC-1000E, Pro- X3AH05, Review of design criteria
- Standard for Qualifying Rev 5, cure. Rev 14, to verify that IEEE 323 is Class IE Equipment 4-3-84; Spec. 3-7-85; referenced. See Finding for Nuclear Power DC-1007 EQDP. EQOP for 17-20, items I and 2.
Generating Stations. Rev 4, X3AH05. Procurement specification 4-30-85. X3AH05 and EQOP verified that the Class IE junction boxes were spectfled and were envIronmenfalIy qualifiod to meet the requirements of IEEE 323. 4 32 IEEE 344-1975, 8.l.4.3 Yes DC-1000-E, Pro- X3AH05, Design criteria were i l Recomended Practices for Rev 5, cure. Rev 14, reviewed to verify that Seismic Qualification of 4-3-84; Spec. 3-7-85; the design of raceways j for safety-related circuits Class IE Equipment for DC-1810, EQDP. EQOP for Nuclear Power Generating Rev 6, X3AH05. Include requirements to Stations. 10-3-83. support the raceways with Category I supports to I meet the seismic 4 qualification requirements of IEEE 344 I t Procurement specification l and EQOP review verified that the Class IE junction boxes wre specified and { seismically qualified in' accordance with the requirements of IEEE 344. I Refer to Finding 17-13. i l . 00439/029-6/11 i i
^ '
O O ' O TABLE 6.l-l (SHEEI 12 0F 20) 3 C ssification Design Ref. FSAR Comnit- Design Criteria Desian Document Section Tyge Number Comnents No. Requirement Section ment _ _Rea't 8.1.4.3 Yes DC-1000E, Const. X3AR01--E8, Review of design criteria 35 IEEE 384-1974, and construction specifi-Criteria for Separation Rev 5, Spec. Rev 17. of Class IE Equipment 4-3-84; cation verified that IEEE DC-1001, 384 is referenced. See and Circuits. Rev 1, Finding 17-20, item 4. B-30-83; DC-1809, Rev 4, 1-21-82; DC-1810, Rev 6, 10-3-83. 162 All raceways are uniquely I.9.75 Yes DC-1810, Pro- X3AJ07. Design criteria and Rev 6, cure. construction specification identified (by permanent 10-3-83 Spec. X3AR01-E8 were reviewed numbering markers and color coding) to distinguish to verify that the raceways Draw- CX30F002, of each separation group between redundant Class IE and non-Class IE systems ing Rev 12. are required to be color coded with indelible Ink, at intervals not to exceed 15 ft and at points Const. X3AR01-E8, paint, or adhesive markers of entry and exit from Spec. Rev 17 applied to the raceway at enclosed areas. (Att. 8). intervals of 15 ft or less ! along the length of the Comp. EE580. raceways and on both sides Prog. of a well or floor penetration. Procurenen+ specification X3AJ07 verified that raceway markers were specified with distinct color coding in accordance i
- with the design criteria.
0043q/029-6/12 < 6 i
l O O O O O TABLE 6.1-1 (SHEET 13 OF 20) Classi f ica tion Design l Ref. FSAR Comit- Design Criteria Desian Document ! No. Requirement Section ment Rea't Section y T pe_ Nunber Coments i The raceway markers were procured as non-safety class items. Review of ; EE-580 and general notes drawings was done to check that each raceway is assigned a unique i component number which consisted of several alpha-numeric characters with one of these characters used to denote which separation group the raceway belongs to. 76 Within the cable spreading 8.3.1.4 Yes Const. X3AROI-08, Review of construction rooms, control room, and Spec. Rev 17 specification verified shutdown rooms, the mini - (Att. B). comitments for control mum ver tical separation for room and spreading
! open top cable tray is 3 ft, roms. (inclusion of and the minimum horizontal shutdown rooms is allowed separation is I ft. by section 5.l.4 of IEEE 384.)
i 79 Within general plant eroas, 8.3.1.4 Yes Const. X3AR01-E8, Review of construction the minimum vertical Spec. ftev 17 specification X3AR01-E8 i separation is 5 ft and ( At t. B) . verified that the comi t-the minimum horizontal ment is included in the i specification. i separation is 3 ft for open top cable trays. , 1 4 00439 /029-.6/I3 i I
-~ s._._....._m.mm... . .. _ .. m .. . .. _ _ . ... _ . _ _ _ _ _ _ .. - .. m _ . . . , . _ _ . . . _ _ _ . _ _ . _ .. O O TABLE 6.I-l (SHEET 14 OF 20) Classification Design Ref. FSAR Commi t- Design- Criteria Desion Document No. Requirement Section ment Rea't Section Typo Nureer Coments 84 Where spatial minimum 8.3.1.4 Yes ' Const. X3AR01-E8, Review of construction separation requirement Spec. Rev 17 specification verified between raceways of (Att. B). that the comitment is difforent separatton groups included. are not met, fire barriers are Installed.
- Draw- AX30F030, Tray and conduit drawings ings. Rev 9; were reviewed for potential AX30F032, tray deficiencies. The Rev 10; potential deficiencies were IX30F30F, reviewed in detail on the Rev 4; associated tray support and IX3DF301, civil / structural-drawings Rev 18; for deficiency verifica-IX3DF302, tion. See Finding 17-12.
Rev 15; IX3DF307, Rev 12; -i IX30F 31C, Rev 14; IX3DF3tE, Rev 5; IX5DF 311, Rev 17; IX3DF 321, Rev 18; IX30F405, Rev 13; IX3DF406, Rev 10; IX30F4tl, Rev 23; _ IX30F413, Rev 12; 0043q/029-6/14
O - TABLE 6.I-1 (SHEET IS OF 20) j I Classification Design ! Ref. FSAR Connit- Design Criteria Desian Document Requiremont Section ment Rea't Section TJ2e Number Comnents No. _ i IX30F414, Rev II; IX30F422, Rev II; IX30F424, Rev 13; IX3DF430, Rev 9; IX30F50A, Rev 16; IX30F513, Rev I2; IX30H7C3, Rev 10; IX3DH7C4, ! Rev 5;
- IX30H7E2, Rev 9; IX30H7E3, Rev 12; IX3DH7E6, t Rev 9; ,
IX30H7F4, ; Rev 6. 77 The minimum separation 8.3.I.4 Yes DC-1000-E, Const. X3AR06 -E8, Design criteria were re- i distance between enclosed Rev 5, Spec. Rev 17 viewed to verify the in-l raceways qualified as 4-3-84 (Att. B). clusion of the require-i barriers is I in. ment. Review of construc - tion specification verifled l , that the connitment is l ! included. a 1 i 00439/029-6/I5
n ( v TABLE 6.l-1 (SHEU 16 0F 20) Classification Design Ref. FSAR Comit- Design Criteria Desian Document No. Requirement Section ment bv2' t Section Tyge Number _ Coments 4900 At least 1-in, sepe ntion Q430.75 Yes Const. X5AR01-E8, Review of construction is maintained between the Spec. FSs i7 specification verifled barrier and the cable tray (Att B). that the comitment is located above or to the side included. *s' of it. Power supply feeders Yes DC-1810, Comp. EE-500. Design criteria review to instrument and control Rev 6, Prog. verified that power supply room distribution panels 10-3-83. feeders are installed in ! shall be installed in en- Draw- IX30F302, enclosed raceways. ] closed raceways that qualify Ings. Rev 15; I as barriers. IX30F3tC, Drawings and EE500 were ^ I Rev 14; reviewed to verify that j IX3DF304, nonenclosed raceways in Rev 10; both the upper and lower j IX3DF3ld, spreading rooms carry only Rev 10. Instrument and control circuits. 1 . In the cable spreading areas, Yes Const. X3AR01-E8, Review of construction l the minimum separation dis- Spec. Rev 17 specification verifled . tance between redundant (Att. B). that the correitment is l Class IE cable trays shall included. l be i ft between trays sepa- ! rated horizontally and 3 ft j betwen trays separated vertically. { The routing of Class IE Yes DC-1810, Haz- 88-35204, Design criteria and hazards circuits and location of Rev 6, ards BB-35929. packages were reviewed to verify ihat these documents equipment served by these 10--3-83. Pkg. Class IE circuits shall define the potential be reviewed for exposure to hazards against which the potential hazards such a- raceway systems should be designed. 0043q/029-6/16 l 4 ___._.___________m-__ _ _ _ _ _ _ . _ _ _ _ _ _ _ - . _ < _ _ _ _ - - , -w~_ a- * < . -i e-.r-, 4- - -r ,ma w.,-e---- e - ---e-- .- . . -- em, -e.--- - =__ _____________.2 ~ _ _ _ _ _ _ _ _ _ _ - . ___
O O O O TABLE 6.l-1 (SHEET 17 OF 20) 1 Classification Design hf. FSAR Comi t - Desi gn Criteria Desian Document No. Requirement Section ment Rea't Section Tm Ember Convnents high pressure piping, missiles, flanineble The review also verified material, flooding, and that the methods for wiring that is not flame protection of plant safety-retardant, related circuits and safe-shutdown circuits, based on the degree of potential hazards, are included in the design requirements, a Raceways shall be flam Yes Pro- X3AH01, Procuremont specification curo- hv 15, was reviewed to verify retardant. " ment 2-2545. that cable tray coating is Spec. flame retardant. DESIGN OF DUCT BANKS: 9 1020 Buried electrical duct 3.7.B.3.12 Yes DC-1000-C, Draw- AX30F030, Design criteria were banks containing Class IE Roy 3, ings. Rev 9; reviewed to verify 9-3043; AX30F032, comi tment. Drawings electrical circuits are designed to meet Category I DC-1810, Rev 10; were reviewed to verify require =nts. Rev 6, IX3DH7C4, that Category I duct banks 10-3-83. hv 5; are located within Category IX3DH7E6, I backfiII. Also, see Rev 9 Finding 17-l1. i 1019 Engineering analysis for 3.7.B.3.12 Yos DC-1000 -C, Design ca i teria were the design of duct banks Rev 3, reviewed to verify that is based on the buried 9-30-83. topical report BC-TOP-4A l structure analysis is referenced as the procedures outlined in required document for Chapter 6 of BC-10P 4A. the analysis of Cate-i gory I duct banks. $ /tso, see Finding 17-11. t 4 0043q/0294/17 i i 1..___._______.._____ ____________,______.________________________________________._____i
O f C O TABLE 6.l-l (SHEET 18 0F 20) ! Classification Design
- Ref. FSAR Commit- Design Criteria Desion Document Requirement Section ment Rea't Section Type Number Coments No.
1021 Duct banks are provided 3.7.B.3.12 Yes DC-1000-C, Draw- CX30F006, Design criteria were
- Rev 3, ing. Rev 7. reviewed to verify with a seismic separation at structure, manhole, and 9-30-83; comi tmen t.
DC-1810, Conduit and Tray General at intersection interfaces. Rev 6, Notes, Symbols and Detalis 10-3-83. Drwaings verifled that the design of duct banks is based on the design requirements. CABLE 1 RAY FILL: 73 Control and instrument 0.3.l.4 Yes DC-1810, EE-580; Design criteria were re-cable tray design fill is Rev 6, Calc. X3CLO2, viewed to veri fy comit-40 percent of the area of 10-3-83. Rev 2. ment. EE580 data base the tray being used. was reviewed to check that
- the actual usable tray depth is used. Refer to j
4 RRF 17-16. Refer to RRF 17-16. Calculation was reviewed to' verify that analysis is i performed for cases where tray fill is greater than
'40%. Refer to RRf 17-18.
1 1 74 Low voltage power trays 8.3.1.4 Yes DC-1810, Comp. EE-580. Design criteria were - are Iimitod to a fili of Rev 6, Prog. revlewed to verify 30% of the area of a 3-in. 10-3 83. comi tmen t. EE580 was f reviewed to verify that loading depth tray. ] tray fills are limited to
- 30% of the ares of a 3-in.
i
' loading-depth tray. '
(Refer to RRF 17-16.) 0043q/029-6/18 i W _m--.m--..____ - _ - _ _-. .. __.-_--_._..___-m. _ _ _ _ _ _ _ _ . - _ _ - - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_ >a-r .- w - + ,.. e ---- -,m-w-* er- m
--7m--- - + --N --'
O - ( I 1ABLE 6.1-l (SHEET 19 OF 20) Classification Design hf. FSAR Comit- Design Criteria Desion Document No. Requirement section gient Reg't Section Tm ihm6er Coments 78 The minimum separation 8.3.l.4 Yes DC-1810, Const. X3AR01-E8, Review of design criteria distance between non-Class Rev 6, Spec. Rev 17 and construction specifi-IE conduit (including 10-3-83. (Att. B). cation verified the aluminum-or-copper comitment. (Note: Refer sheathed cable) and Class to the NRC acceptance of IE open top cable trays this comihent in section is I in. 8 of the SER.) 85 Where raceways of different 8.3.1.4 Yes DC-1810, Const. X3AR01-E8, Review of design criteria separation groups are Rev 6, Spec. Rev 17 and design documents brought to a single 10-3-83. (Att. B); verified conmitment. enclosure, separatior' is Draw- CX3DF006, accomplished by the use of ing. Rev 17. conduit routed in opposite directions from the enclo-sure, using the enclosure as a barrier. 86 Separate trays are provided 8.5.l.4 Yes DC -1810, Comp. EL-580. Review of design criteria for each voltage service Rev 6, Prog. and EE580 verified that level: 13.8 kV, 4.16 kV, 10-3-85. separate trays for each 480 V, 120 V-ac, and voltage service level were 125 V-dc, control, and designated. instrument. Draw- CX3DF002, Raceway numbering system ing. Rev 12. on drawing CX3DF002 includes a distinct alpha-numeric character to denote each of the different voltage service levels of the raceways. 00439/029-6/19 __J
O O O TABLE 6.I-l (SHEET 20 0F 20) Classification Design Ref. FSAR Comit- Design Criteria Desion Document No. Requirement Section ment Reg *t Section m T Number comien ts 88 Conduits running between 8.3.1.4 Yes DC-1880, Draw- CX30F001, Review of design criteria structures are either con- Rev 6, Ings. Rev 18; and drawings verified nected with a minimum of 2 10-3-83. CX30F002, commitment. ft of flexible conduit or Rev 12. i are provided with expansion / deflection fittings. i l i ? i l l 0043q/029-6/20 .:
- - . ._ -- . . - _ . . . - . - . - . . . . . - . . . . . ~ . . - . . . . . - . . . - . - - = - - .
( 'r TABLE 6.I-2 (SilEET I 0F 8) SUPMARY OF FINDINGS Finding Conclusion / Number Findina Level Resolution / Pro. lect Response Assessment 17-7 A minimum 2-ft separation is 11 DC-1880, X3AR01-E8, IX3DF507, and IX3)f51C Response is acceptable required per Westinghouse to be revised by February 28, 1906. The based on connitted project between NIS conduit and field walkdown identified two occurrences; actions. electrical noise sources, DR 10197 was issued to control rework ESE-l. Deviation from this for both cases that were identified. was not approved by Westinghouse. 17-8 The Civil design criteria 11 Civil design criteria will be reviewed Response is acceptable based requires that grounding by February 13, 1906, to ensure agreement on connitted project cables and other items are with Electrical design criteria. actions. not to be attached to the cable tray and cable tray Attachment will not inpact damping. supports. Drawing CX30E01 Cable is flexible and Iight enough requires a 4/0 grounding to have the same offact as adding cable to be attached to the one more cable to tray. 4-kV and 13.8 kV trays (installed). 17-10 Calculation X3CV01, Revision lli Calculation will be upgraded to Response is acceptable based 3, used in establishing the safety classification of IIE by on conni t ted project amount of zinc inside January 31, 1986. No safety impact actions. containment presented the has occurred. following findings:
- a. Classified 67E (non- Calculations X3CKl4 and X3CKl$ will be safety). updated to show the actual racoway i b. Used preliminary data. quantities and interlocked cable by January 31, 1906.
i 0033q/030 4/l i
TABLE 6.I-2 (SHEET 2 OF 8) Finding Conclusion / Number Findine Level hsolution/ Project Response Assessment 17-10 c. Did not consider inter- The value of % cable weight in % Cont. locked cables. FSAR table is N t from the calculation
- d. Cable insulation values increased by 505 to ensure adequate not consistent with margin over estimated weight for FSAR, section 6.l.2. licensing purposes.
17-11 No calculaticn was prepared til Generic duct bank designs conplete Response is acceptable. to substantiate % design with approved calculations were of Category I duct banks. prepared by % Civil / Structural Chief's Of fice based on BC-TOP-4A methodology. The Vogtle Civil / Structural Group, in the basis of the Vogtle shear wave velocity and seismic level established appropriate duct bank option details and instructed N Electrical Discipline to use them. This has been documented by calculation X2CDl3.5, issued July 19, 1985. 17-12 Cable tray sections show 11 The requirement to install a barrier Response is acceptable, vertical separation of to satisfy the vertical separation 2 ft 6 in, with no barrier requirement between Class IE and non-required. Minimum separ - Class IE cable fray was indicatoJ ation should be 5 ft 0 in. on layout drawing No. IX3DK321 on unless barrier is installed August 1, 1985. Drawing No. IX30F321 is i as required by IEEE 384. not required to be revised because it I only depicts conduit and tray ; ' identification, not installation. I 0033q/030-6/2
O O O TABLE 6.I'-2 (SHEET 3 0F 8) , Finding Conclusion / Nunber finding Level bsolution/ Project Response Assessment 17-13 The construction specifi- Ill Drawing No. CX30F001 prohibits this Response acceptable. cation X3AR01 requires connection. A field walkdown verified that tray runs tominating that the tray was installed per the drawing. at a wall mounted Junction A CSCN was written to correct X3AR01. box, switchboard or other enclosure be tominated i with a rigid bolted connectlon. No analysis is available to justify requirement. 17-15 Numbering system for cable til Drawing CX30F002 will be revised Resp 2nsa is acceptable based I trays, conduits, and special by January 31, 1986, to correct on committed project l raceways present the deficiencies. actions. I following findings:
; EE500 data base and physical drawings
- a. Nunte characteristics will be reviewed against CX3DF002 by were inconsistent January 31, 1986.
! wi th general notes.
- b. Conax connector numbers Training and revision of physical were not defined on design checklist will be performed drawing. oy January 31, 1906.
- c. Conduits and trays nunbering systen wre not consistently followed.
- d. Raceways were omitted
, from drawing. l a i 0033q/030 4/5 f i
- - . - , - - . . . . , . . - - - - - - - .-- - .._-- . ~- - , - , - . _ . - - ~ - - . ..
Q O O O U
^%
J V U U U U TABLE 6.1-2 (SliEET 4 OF 8) Finding Conclusion / Number findir.c Level Resolution / Project Response Assessment 17-16 The design processos 111 Revise PRM, part C, section 36, to add Response is acceptable based associated with the EES%) formal requirements for the review, on corrnitted project program are not contrviled check, and verification of the design scti'.sns . by a procedure. Specific processes associated with the EE580 deficiencies cited were: program by March 15, 1986.
- a. Checking of raceway issue desk top instruction to provide input data is not detailed instructions by March 15, 1986.
always performed independently. Conduct and document training sessions
- b. locorrect dimensions by March 30, 1986.
in the program library wore utilized for Review, check, and revise (if nece zary) calcula ting cross - existing EE580 library data by sectioral areas. March 15, 1986.
- c. Incorrect data was input for three of Raceway data deficiencios were the raceways reviewed. determined to have no technical /
Another raceway was safety impact. omittec;. 1 1 1 0033q/030-6/4
O O O , e TABLE 6.I-2 (SHEET 5 0F 8) Finding Conclusion / Level Resolution / Project Response Assessment Nunber Findino I A solid bottom control cable Review of EE500 data base found 27 Response is acceptable based 17-17 il tray has been installed, additional control trays indicated as on project connitted inspected, and cluded in solid-bottom trays in data base. actions. EE500, rather than a punched- Walkdown revealed 17 were installed as bottom tray as required by solid-bottom. Design changes allowing general notes drawing No. changes were incompletely incorporated. CX3DF001. DRs were written and dispositioned j use-as-is. Design documents will be revised to reflect as-built conditions 1 by February 28, 1986. 17-18 1. Calculation X3CLl02, il Calculation X3CLO2 will be revised to Response is acceptable based Revision 2, revealed the indicate sources of design input by on committed project following discrepancies: January 31, 1906. actions.
- a. Sources of design input FSAR change notice and associated LDO were not referenced. were issued to correct the overfill
- b. Cable tray weights may control requiremont on December 31, 1985.
I exceed the 55 lbs/ft limitation of DC-1810. Desk instruction X3Dil0, will be SpecificalIy, issued by January 31, 1906, to
- 1. Covered, 6 x 24 in. assure proper fill control.
trays may reach the weight limitation Design documents indicating potentially 4 with only 35% overloaded trays (when covers are added fill whereas, thu will be issued by January 31, 1986. j criteria and FSAR permit 405 fill. Iloid documented training sessions by
- 2. Essentially non -spaced January 31, 1986.
l 1 3/C 500 MCM cables i are considered which j result in 66.9 lbs/ft. l 0033q/030-6/5 i 1
. __mm__. _ . _ . _ m.... . . . . _ . . _ . . _ ...__-_.-.-~._.m. ._.m_.. . .. . . . . . . . . - - . _ . . . . = . _ _ . _ . . _ _ _ _ . . . . _ . _ - _ - _ . . _ . _ _ _ .
U TABLE 6.1-2 (SHEET 6 0F 8) 1 Finding Conclusion / Finding Level Resolution / Project Response Assessment , Nunber 17-18 3. The potential applica-4 Cont. tion of tray covers had i not been consistently applied (e.g., total tray weight computations for
! power cable trays are 4
performed on the assunp-tion that no tray cover i ~ will be used, although I total tray weights for i control cable trays and instrumentation cable l trays were based on l covered trays). The l weight of grounding - cable attached to medium I j voltage cable trays I was not considered. i c l . Case-by-case analysis i of tray fill greater ! -than 405 is being performed with an un - i verified version of ' a cornputer program l and the analyses are not i being properly 6)cumented. l
- 2. An analysis was not per-l formed to assure that
! trays would not be - filled above siderails i as required by the FSAR i and DC-1810. i i 0033q/030-6/6
~ . . .m.. m.._ _... .
. _ . . . .___._...-.m __m ,_ . _ . _ . . . . _ , - _ . . - . . _ _ . .._.._,..m.._. .-- . _ _ . . _ . _ . _ _
t O c O 1ABl.E 6.l-2 (SHEET 7 0F 8) Finding Conclusion / Nunter Finding Level Resolution / Pro. lect Response Assessment 17-18 11. Construction specification Cont. X3ARDI, section E8, attachment B, paragraph 1.2.2.3 allows the jobsite tray installer to add covers to trays without revising design drawings or EE580. Ill. No procedure or instruc-tion specifically addresses I documentation of adequacy of " overload" trays. 17-20 The following items were Revise DC-1001, DC-1010, and DC-1810 by Response is acceptable , identified during the January 31, 1986. based on comitted 1 inplementation review of project action. the Design Criteria. a) Raceways (system 1810) Reviso FSAR to agree with revised were not listed on the DC-1010 by February I's, 1986. RG l.32 project classification is not applicable. list in DC-1010. b) Safety design bases for , ) junction boxes were not l covered in DC-18tO. j c) RG l .32 was not ref - i erenced on the cover ! shoot of DC-1810. d) DC-1001 coreitments were q to the 1981 revision of
- IEE E-384, not the 1974 revision as referenced l in the FSAR.
I 00339/030-6/7 i 5 i ( a 1
(~ . ' O O TABLE 6.I-2 (SHEET 8 0F 0) Conclusion / Finding Finding Levei_. Resolution / Pro. lect Responso Assessment Nuder During investigation of a quality Response is acceptable based 17-21 Unauthorized removal of a concern, it was determined, concurrent on cormnitted project action. safety-related grounding cable was reported on with this finding, that unauthorized DR-1912 without being rework was a recurring deficiency. reported on a Corrective Corrective action report E-3 was Action Report, as required issued listing this and 17 other by field procedure GD-1-Ol. deviation reports which had been initiated to identify field rework that had been perfomed without authorized documentation. Training for responsible engineers will be provided by January 31, 1986. An established in-house program will identify personnel responsible for repetition of similar violations and provide feedback. j Completion of this corrective action is I oxpected January 31, 1986. i Procedure ED-1-17 will be evaluated by January 31, 1996, and changes made, if I applicable. i a i
- 00339/030-e/8 1
4 l-5 - __ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
/"N TABLE 6.1-3 VERIFICATION DOCUMENTATION
SUMMARY
Total Total Associated O Review Area Number Reviewed Findings
)
- Design Criteria 12 12 3 4
- Calculations 4 4 3 l
- Drawings
- Tray and Conduit 130 27 3 O Underground Duct 4
- Procurement Specifications 6 6 Material Specification 96 96 Change Notices
- Construction specifications 1 L 1 construction Specification Change Notices
- Deviation Reports 6000 20
- Field Change Request 5000 30
[O - Vendor Documentation 'UI Vendor Drawings 83 20 Supplier Deviation 3 3 Disposition Requests Equipment Qualification 1 1 Documentation supplier Quality Verifi- 3 3 cation Documentation
- Field walkdown 1
- EE580 Cable and Raceway 1 1 1 Program ___ __ _
O V TOTALS 11,349 228 13 0 0024q/10/021-6
4 i l l l [ TABLE 6.1- 4 (SHEET 1 OF 2) DESIGN VERIFICATION SAMPLE l CABLE TRAY 1BE411TEAB 1BE411TLAB 1BE411TSAB 1BE411TKAB RHR 1BE411TEAC O 1BE411TLAC 1BE411TSAC 1BE411TKAC 1BE302TWAC 1AE7E3TFBE 1AE7E3TLBE NSCW 1AE7E3TSBE 1AE7E3TYBE 1AE302TTAK 1AE321TYAA 1BE31CTVAER4 1BE403TLCD () 1BE414TLCM 1BE301TRAJ Random from Construction 1BE311TRAJ 1BE321TRAE 1BE302TVSQ 1BE31CTVCD RHR to Control Room 1BE31CTUCA 1BE413TUCJ i 1BE31CTWDA 1BE31CTSDE AFW 1BE311TRAJR O 1BE3OlTQAH 1BE7C3TQAB 1AE302TSCE 1AE30lTSAAR1 1AE414TSAG 1AE424TSAL O 1AE7E2TSBA 0024q/1/021-6 I i
Table 6.1-4 (SHEET 2 OF 2) CONDUIT 1BE411RLOO7 1BE411RS008 l O 1BE411RLOO9 1BE411RS010 RHR i 1BE411RS011 1BE411RS012 1BE7C4RS035 O 1BE7C4RS064 IBE7C4RS065 AFW l 1BE7C4RXO69 l 1BE7C4RLO77 1AE7E3RXO36 , IAE7E3RS055 1BE7E3RS054- NSCW ; 1BE7E3RLO55 1BE7E3RS058 1AE3OlRS270 1AE31CRSO23 j O 1BE406RS007 1BE422RX179 Random from Construction i 1BE50ARIO61 1BE7F4RS075 1AE50ARXO62 ' 1AE50ARX243 NIS SPECIAL/ MISC. l 1BE7C4S0011 1BE7C4RX012 DUCTS 1BE7E6RLOO1 1BE7E6RS002 1BE7C4KLJ023 i 1BE7C4KSJO8 l 1AE3OlKSJ031 1AE422KSJ03 BOXES
% 1DE513KXJ46 1AE30lKPJ05 1AE302KXJ24 O
0024q/2/021-6
l l 1 Table 6.1-5 I DESIGN CRITERIA REVIEWED Criteria Title :
)
DC-1000-C, General Design Criteria Revision 3 (Civil Structural) DC-1000-E, General Design Criteria Revision 5 (Electrical) DC-1001, Separation - Interdiscipline Revision 1 DC-1003, Flooding - Interdiscipline ! Revision 2 DC-1005, Seismic Interdiscipline Revision 1 DC-1006, Missiles - Interdiscipline Revision 2 DC-1007, Environmental Interdiccipline Revision 4 DC-1009, Single Failure Criteria f l Revision 2 DC-1018, Pipe Break Criteria - Interdiscipline Revision 2 DC-1809, Cable System l Revision 4 9 DC-1810, Raceway System Revision 6 DC-2166, Electrical Raceway Supports Revision 1 O O 0024q/3/021-6
I
- Table 6.1-6 CALCULATIONS REVIEWED t
j Number Title / Description
\-) X3CK14 Revision 0, Maximum cable pulling length in conduit ,
1 J
- X3CK15 Revision O. Cable pulling calculation !
j for underground duct banks ) X3CLO2 Revision 2. Cable tray weights 1 i X3CV01 Revision 3, Amount and surface covered ) with zine inside containment l k 1 4 O O O 0024q/4/021-6
p Table 6.1-7 DRAWINGS AND DCNs REVIEWED Conduit and Trav Drawinos DCNs Reviewed f8 'h 1X3DF30F - Revision 4 1X3DF301 - Revision 18 88, 92, 97, 101, 105 1X3DF302 - Revision 15 119, 122, 123, 138, 139 1X3DF307 - Revision 12 39, 40, 41, 42, 43 1X3DF31C - Revision 14
<~s 1X3DF31E - Revision 5
-1
~
1X3DF311 - Revision 17 66, 67, 69, 79, 84 1X3DF321 - Revision 18 64, 72, 76 1X3DF403 - Revision 13 18 1X3DF406 - Revision 10 1X3DF411 - Revision 23 75, 80, 82, 83 1X3DF413 - Revision 12 1X3DF414 - Revision 11 1X3DF422 - Revision 11 47, 50, bl. 52, 57, 58, 62, 64, 68, 69, 73 1X3DF424 - Revision 13 86, 89, 95 1X3DF430 - Revision 9 1X3DF50A - Revision 16 16, 20, 23 1X3DP513 - Revision 12 1X3DH7C3 - Revision 10 (~}
\m- 1X3DH7C4 - Revision 5 19, 20, 21, 23, 25 1X3DH7E2 - Revision 9 1X3DH7E3 - Revision 12 1X3DH7F4 - Revision 6 CX3DF001 - Revision 18 46, 48 CX3DF002 - Revision 12 CX3DF003 - Revision 10 CX3DF006 - Revision 7 31, 34 Duct Bank Drawings AX3DF030 - Revision 9
- ( )
AX3DF032 - Revision 10 1X3DH7C4 - Revision 5 19, 20, 21, 23, 25 1X3DH7E6 - Revision 9 CX3DF001 - Revision 18 46, 48 l CX3DF002 - Revision 12 CX3DF003 - Revision 10 i( ) CX3DF006 - Revision 7 31, 34 l u,l 0024q/5/021-6
~ . .
i TABLE 6.1--8 j PROCUREMENT SPECIFICATIONS REVIEh'ED ' specification Title MSCNs X3AH01, rev. 15 Cable tray and f1ttings 15 X3AH02, rev. 23 Metallic conduit and fittings 39 l X3AH03, rev. 8 Nonmetallic conduit and fittings 7 j p,y
, X3AH05, rev. 14 Junction boxes, Class lE None written i X3AH09, rev. 19 Junction boxes, (non- Class lE) and 35
- Pull boxes (Class lE) l X3AJ07, rev. 2 Cable, wire, and raceway markers None written l.
d j iO1 1 4 J d d 4 O i !O ^ O I 0024q/9/021-6
I ' TABLE 6.1-9 DEVIATION REPORTS REVIEWED , Number Subiect ; l(:) ED-78 Storage of cable tray fittings and hardware
+
i ED-79 Storage of metallic conduit j ED-635 Installed condulets. type not approved by engineering l ED-1516 Torque wrench 7 days out of calibration : i ED-1852 Detail for bolting tray to support arms omitted i l ED-1856 Bonding jumpers not installed at seismic gap t l' ED-1857 Tray bolts are loose and tray is not grounded l l ED-1911 Tray has tie bars missing i l ED-1912 End points of tray not grounded I f ED- 1919 Raceway turned over for final inspection, conduit j l not installed l l ED-1941 Raceway turned over for final inspection, conduit not inspected ED-3259 Tray installation not per drawing l ED-3447 Tie bars not installed per drawing ED-5555 Raceway not identified per procedure ED-7425 Tray installation not per requirements ED-7905 Conduit installation not per specification ED-8111 QC inspection omitted in rework ED-8666 Assignment of pull' box numbers not per procedure I ( ED-9573 Conduit installation not per drawing l ED-10000 Rework request omitted in work process 0 0024q/6/021-6 l
TABLE 6.1-10 PCRs REVIEWED FCRs hubiect E-FCRB-361F Tray Relocation E-FCRB-367 Conduit Stub-up Above Slab E-FCRB-625 Conduit Relocation q E-FCRB-807 Conduit Relocation V E-FCRB-808 Conduit Relocation E-FCRB-899F Conduit Size Change E-FCRB-1206F Drawing Revision to incorporate DCN E-FCRB-2330 Junction Box Relocation E-FCRB-2646 Duct Bank Expansion Joint E-FCRB-3549 Conduit to Tray Detail E-FCRB-3560 Tray Relocation l E-FCRB-4219 Tray Edge Cable Protectot E-FCRB-5565 Tray Separation ! E-FCRB-5848 Tray Identification E-FCRB-6110 Conduit Relocation E-FCRB-6208 Conduit Relocation E-FCRB-6459 Conduit Relocation E-FCRB-6743 Conduit Deletion E-FCRB-6758 Tray Addition to Drawing E-FCRB-6966 Conduit Relocation E-FCRB-7683 Conduit Redesign E-FCRB-8013 Materla1 Substitution C/ E-FCRB-8063 Conduit Relocation E-- FCRB- 810 5 Field Fabricated Box E-FCRB-8526 Vendor Supplied Junction Boxes E-FCRB- 8 621 Equipment and Conduit Holocation E-FCRB-8662 Tray Identification E-FCRB-9267 Conduit Relocation E-FCRB-9393 Junction Box Modification E-FCRB-9447 Seismic Protector for Conduit 0024q / 7 / 021- 6
TABLE 6.1-11 VENDOR DRAWINGS HEVIEWHD (_- Vendor Drawings Subiect , EX3A-H01-1-1 Cable tray load / deflection test report l l l X3A-H01-4-0 Cable tray applicable codes and standards
\/ X3 A-1101 0 Cable tray spacer detail drawing i
X3A-H01-23-1 Cable tray test report X3A-H01-24-1 Cable tray physical properties test report X3A-H01-26-1 Torque testing of connector bolts l X3 A-H01-2 9- 1 Clarification of specification requirement ! l X3 A-llO 3- 6-1 PVC conduit data sheet i X3A-H03-9-1 PVC conduit fittings data sheet i X3A-H05-4-8 Junction boxes - subpanel layout X3A-H05-5-3 Junction boxes summary of materials , i X3A-H05-28-1 Junction boxes - summary of materials X3A-H05-31-3 Junction boxes - codes and standards list X3 A- H0 5- 3 2 - 1 Junction boxes - welding procedure X3 A- H05-4 6-2 Junction boxes finishing j i
/~s X3A-H05-49-1 Junction boxes - removal of terminal blocks X3A-H09-1-2 Pull boxes - excore detector box X3A-H09-2-1 Pull boxes - aluminum content in paint X3A-H09-3-2 Pull boxes - list of codes and standards
(~} V X3A-H09-4-1 Pull boxes - cast iron grade for HELBA boxes ( 0024q/8/021-6
O O O O O O O TABLE 6.1-12 SQVDL-S MATRIX Material item Description Certificate of Compliance SODR HOTE X3AH01 Cable tray and Document listed on SQVDL-S - fittings X3AH02 Metallic conduit - - No SQVDL-S issued for this ' and fittings bill of material specification. Quality documentation requested by specification section 6.0 X3AH03 Nonmetallic Document listed on SQVDL-S - conduit and fittings X3All05 Junction Boxes Document iisted on SQVDL-S Document Iisted (Class IE) on SQVDL-S X3AH09 Junction Boxes - - No SQVDL-S issued for this (non-Class IE) bill of material specification. and Pull Boxes Quality documentation requested (Class IE) by specification section 7.0. X3AJ07 Cable, wire, and No SQVDL-S issued for this bill ! raceway markers of material specification.
! Quality requirements requested
} by specification section 6.0 for non-safety class
- materials.
i' 00449 /020-6/2 t
i u ,,.=r WALK 00WN AREAS Orawina Title Area Reviewrxi IX3DF302, rev. 15 Conduit / tray plan area 0, A. Cable spreading room (see el 200 ft-0 in., level A, control note 1) building, Unit i B. Auxiliary relay panel room IX30F322, rev. 12 Condult/ tray plan area 2, A. Train B switchgear room el 200 f t-O In., level A, control O building, Unit I B. Corridor, east end of switchgear rooms, column line Cl8 l IX30F31C, rev. 14 Condult/ tray plan area 1, A. Train B shutdown roan j el. 200 ft-0 in., level A, control B. Corridor, east of shutdown building, Unit I room, column line Cid IX30F332, rev. 15 Conduit plan area 3, Penetration area f el 180 ft-O in., level B, control building, Unit i l IX30H7C3, rev. 10 Conduit, lighting, and Diesol tunnel, train B comunications plan, area 7C, tunnels IT4A and IT4B IX30F51B, rev.12 Condult/ tray plan area 1, Perimeter outside secondary
- el 210 ft-0 in, to 220 ft-0 in., shield containment building, Unit I ;
)
l , ) l O a l lO , l 0032q/020-6/2
i 4 'l N 1 1 s 4 i I i 4 4 Page 1 of 2 4 READINESS FO/TW PFNRAM VRIFICATICW OfEE.klIT s t* SIGN CRITERIA 6 h itse Cont. Document i 1 1s the system classification (Safety- DM Preface Sect. 3.4.1.4 Related, safety impact and other) { consistent with licensing commitments 3 ar.5 the Project Classification List (Dc-1010)? 2 Is the Safety Class indicated consistent DM Preface Sect 3.4.1.6 with licensing commitments and the Project Cleosification List (DC-1010)? 3 la the seismic Category indicated DM Preface Sect. 3.4.1.7 1 i consistent with licensing causitments and the Pro)eet Classification List ] (DC-1910)? i i 4 Are the NRC Beg. Ouides General Design DM Preface Sect. 3.4.1.8 Criteria, Standard Review Plans, and stanch Technical Positions listed 1 consistent with the licensing commitments? a 5 Do the references listed include all DM Preface Sect. 3.4.1.10 those sections of the SAR discussed? 6 Are the principle design codes and DM Preface Sect. 3.4.2 standaros listed consistent with the licensing commitments? W 7 Does the text of the Design criteria DM Preface Sect. 3.4.3 section/ safety Design Bases 1 ' subsection clearly specify .ae criterie that must be met to satisfy licensing commitments? 'i I i
- opesg/1/020-6 a
Figure 6,1-1 Design Criteria Checklist (Sheet 1 of 2) 4 i i i
. - . , , . - _ _ . , , , _ . . , , , , , . _ . _ ,_.c... .... . _ , .
i j i a l ' 'r l 4 i l 1 t Page 2 of 2 1 ggDipaSS REVIEW PROGRAM vsRIFICATION CHECKL M J I4510p CFITERIA
& Item cont. Document 1
i 8 Mas the destyn criteria been reviewed and DM Preface Sect. 3.5 approved by all 505's responsible for ANSI N45.2.11. Sect. 5.2 defined interface? 9 Mave revisions and change notices to DM Preface Sect. 3.6 and the design criteria affected by the 3.7 ANSI N45.2.11. Sect. 5.2 change been reviewed and approved by ses's responsible for interface?
)
[ , 00 5g/2/020-6 Figure 6.1-1 Design Criteria Checklist (Sheet 2 of 2)
4 j j 4 e (,Mi ps e/A .n ,
. ~
1 1 l 4 I i i l 1 Page 1 of 2 4 R{@INESS REV1BV PROGRAM VERIF1 CATION CHECK (lgI
*DESIN CRLCULATIONS i
i i lt!2,, item cont. Document j 1 Does the calculation conform to current PRM Part C, sec. 9.3.3 1 selected project licensing cossaiteents/ ANSI W45.2.11. Sec. 4 design criteria requirements? 2 1s selected input data consistent with PRM Part C, sec. 9.3.3 j the referenced documents? ANSI M45.2.11, sec. 6 i ! 3 Have selected output data (results) been ANSI W45.2.ll, Sec. 4 ~, provided to the af fected disciplines? 8 I 4 was selected output date incorporated ANSI W45.2.11 sec. 6 into the affected documents? i 1 5 Has the calculation been processed as ANSI W45.2.11, sec. 4 a *0' classification document? 1
- 6 Has an independent checker and ANSI W45.2.11. Sec. 4 Discipline 308 reviewed / approved the calculation?
J l ? Are engineering judgements/ assumptions ANSI N45.2.ll, sec. 6 clearly identified? .i 8 Has the calculation been revised to PRM Part C Sec. 9.3.3 reflect changes due to FCR/DRa? ANSI W45.2.ll, sec. 4. 4 I !. 9. Have the results from calculations ANSI W45.2.ll. Sec. 6 been implemented in the procurament specifications? i 1 J 0052q/1/c20-6 M. i' Figure 6.1-2 Design Calculations Checklist (Sheet 1 of 2) I,
- >q
l i i e i i . ! { s I k P i t ? Fage 2 of 2 1 1 3EADINESS REVIEW PkOGRR. i 1 VDIFICATION CHECKLISJ l d DESIGN CALClu TIONS j 4 ,1 1 l% Ites Cont. Document i ! 10 Have revisionf to calculations ANSI N4s. 2- 11 Fkm c9 9. 3. 3 i been s.ade in a timely manner ? d 1 I l i p } J
- i. I I l 1
i 4 4 e i 1 I ! I i l i,; ) J, I i
]
00529/ 2/020-6 i i k Figure .1-2 Design Calculations Checklist (Sheet 2 of 2)
8 4 j i i d 4 i a 4 3 4 4 k i Page 1 of 1 ] RfJLDINESS FEVIEW PROGRAM 1 l VERITICATION CHECKLIST I j DRAWINGS i , Cont. No. Item Document , 1 Has the DRN been submittet ANSI N45.2.11-5, , for coordination with other PRM C4.7 1 disciplines and departments? ! 2 Eas the design document received ANSI N45.2.11-7 t all required signatures? PRM C4.7.3 1 1 J l 3 Mas design criteria been ANSI N45.2.11-3, maintained or incorporated? PRM 4.7
\
d 4 Has the coordination print review ANSI N45.2.11-5 ! been accoisplished in accordance PRM 4.7.5 , 1 with 4.7.5 of PRM and Table C4-27 i i 5 Was the design document reviewed ANSI N4 5. 2.11- 3 by the Harards Group and Equipment PRM 4.7.5 , Qualifications Creup as required by i i PRM7 '* 5 a 6 Did drawings and associated DRN ANSI N45.2.11-4, indicate 11 supporting calculations PRM 4.7.5.a were acteeted?
~ ~ -
0051g/#/020-6 l Figure 6.1-3 Drawing Checklist
1 i n no. h l d s (" Page 1 of 1 f PEADJNESS REVIEW PROGRAM VERIFICATION CHECKL111
- k j DCN/DCN-R i
a i Cont. j No. Iten Document ___ 1 la the DCN in compliance with ANSI N45.2.11 See. 3.0 current design criteria PRM C4.4.8 r equirement s ? l 2 Does the DCN af f ect FSAR ANSI N45.2.11 Sec. 3.0 commitments? ) l l 2a If yes, was a licensing de- ! 4 viation document initiatedt a I ~ 3 la an interdiscipline review ANSI N45.2.11 Sec. 5.0 required? (Initials and dates PRM C4.4.8 on form, "NA* if not appropriate) u j 4 If revision to affected document ANSI N45.2.11 Sec. 5.0 is required. was revision or CN PRM C4.4.6
- incorporated?
t 5 Was DCN consistent with applic. ANSI N45.2.11 Sec. B.0 t able calculation? If DCN changed PRM C4 calculation, did revision of I calculation occur? i i j 6 was Hazards or Equipment Qualifi. t cation impact considered? If ANSI N45.2.11 Sec. 3.0 PRM C4.4.8 impact occurred, was Hazards or Equipment Qualification checklist j completed? 4 i i I l\
. 0055g/1/020-6 1
a a 1 4 Figure 6.1-4 DCN/DCN-R Checklist 4 m -m- -e g7- --w - 7- 7--t-- m- --tse<w w w e w-t' n-ww- + -&awr-w wr-w v w -4,-w-ni ev w wwsf-e+--ew-wew---erwmw--ew+-et**- e-gr-wWe em&w+w-r-'we-wcw-m--t
1 i s 4 4 t.nnAN/AW s d .sv'9
' % f, p 1M %'- .U i
j Page 1 of 2 4 4 READINESS REVIEW P19 GRAM j VERIFICATION CHECKLLgI j PROCVEEMENT SPEcirICAT10N t Cont. No. Item Document 1 Did the specification receive PRM C3.4 required approval signatures j on the DRN? ? l 2 Was an interdiscipline review ANSI N45.2.ll Sec. 5 accomplished and the DRN signed? & PRM C3.4 & 8.4.2d i i 3 Does the specification include ANSI N45.2, the requirements of ANSI Sections 3 &4 M45.2-1971? PRM C8.4.2e A 4 Did the proposal form FRM C6.4.le contain the quality veri-fication documentation list (SQvDL) for 0-class items? 5 was it necessary that the item ANSI N45.2.11, be subject to environmental Section 0.3.3 qualification testing as per PRM CB.5 ANSI W45.2.11-1974 and, if ! so, were the requirements for qualification testing includeJ7 6 were calculati ns available and ANSI N45.2.11, current that rapport equipment sections 4.2 & 6.3.2 size and rating requirements? (Refer to Calculation Checklist for completing calculations.) 7 Are calculations or other ANSI N45.2.11, documents available or have Sections 4.2 & 6.3.2 Code requirements been referenced to suppert the natorial requirements? 0053g/1/020-6 I j l I'igure 6.1-5 Procurement Specification Checklist (Sheet 1 of 2) l
i l l 1 s, u+ - , r I I l J T
- O 4
a i Page 2 of 2 j BEADIMESS FEVIEW PROGPAM l VERIFICATION CHECKLLI.T j PROCUEEMENT SPECIFICATION , 1 1 1
- l t Cont.
t
- 50. Item Document
- 1 t
8 Were tests required to ensure PRM CB.4,2b.6 i the specified performance and, if so, were the test j results documentedt i 9 Was the specification certified PRM C8.4.3 and stamped by a professional l
- engineer registered in the
- State of Coorgia?
10 Were outstanding SDDRs incorpo. PRM C23.5 i rated into the specification? ] a I 11 Were all outstanding MSCNs PRM C8.4.2b J incorporated into the specificatient l PRM C8.4.2b j 12 Does the specification comply with the requirements of the I design criteria and licensing 1 commitments documented in the FSARt 4 13 Were OA requirements included i in the specification? ;
- 1
! I 14 were seismic requirements !
i included 7 1 i I 4 00539/2/020-6 00530/2/020-6 i
' i Figure 6.1-5 Procurement Specification Checklist (Sheet 2 of 2) i l
t- ,s-Vage 3 cf 2 % READINESS REVIEW PROGRAM VERIFICATION CHECKLIST MATE 11AL SPECIFICATION CHAN0E NOTICE (MSCN) Cont. No. Item DoegatDt , *1 Did the NGCN receive required PRM C26.7.1
; approval signatures i
(responsible EGS. nuclear BGB. PE. PQAE)? t
*2 Were other disciplines ANSI N45.2-11-5.2.1 affected besides the FRM C26.7.lb responsible discipline, i and if so, was the fora
- signed?
2 1 l . *3 Does MSCN conflict with PSAR ANSI h45.2.11-8 ' 4 licensing commitments? If so. FRM C26.7.1c l was licensing document j deviation (LDD) initiated? ) i 4 Dio change affect material ANSI N45.2.11-6 1 subject to qualification j testing - was retest 1 accomplished? (If so. go l to Equipment Qual. Checklist). l I 5 Were design ec1culations. ANSI N45.2.11-3 drawings or specifications Ie affected by this change and i revised accordingly? J j 6 Did change impose more ANSI N45.2.11-6 i stringent requirements, if so, a was retrofit of work already in place accomplished? j a
'MSCEs are processed in same wenner as CSCNs per C8.7.
] oos79/1/o2o-s l 1 .i Figure 6.1-6 MSCN Checklist (Sbeet 1 of 2) 4
. _ -._ _ _ . . ,_ _ . _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ , _ _ _ _ _ _ .._... _ _ __. _ ~ .. .._.. _ . . _ _ . _ _ _ _
4 l l 1 t p 1/ ', g *, 1 i i 4 1 J 1 1 Page 2 of 2 l ' READINESS REVIEW PROGRAM d VERIFICATION CHECKt.16T MATERIAL EPECIFICATION CHANGE NOTipE (MSCN) i , I Cont.
- me. Item Document i 7 Were procurament documents NJSI N45.2.11-0 i identified and revised if I necessary?
4
)
8 Was change in compliance ANSI N45.2.11-6 i with cuttent design criteria? I J l l a f ) 1 l 1 i i l 5 i i 1 i 1 i ] oo47e/2/o2o-s i l 1
- )
Figure 6.1-6 MSCN Checklist (Sheet 2 of 2)
J l i 1 i i f 4
. 2. i e, A42A1 f g esuae - ,
l i l l l i l 1 1 1 A Page 1 of 1 i j READINESS PEVIEW PROGRAM ! VERIFICATION CHECFLIST i I (*M87RUCTION SPEC 1FICATIONS 1 1 1 4 Cont, j WD. Iten DopJp.gnt i 1 If the spec. involved more than P9M C-B.4.2.d & j one discipline, was interdisci. 8.4.3 & C-3.3
- plinary review performed and documented 7 l
2 If spec, is identified in PRM C-8.4.2.c & the DCCL, was it reviewed 8.s.3 & C-3.3 i and approved by the chief , engineer? Was DRN attached? i j 3 Were all outstandiug CSCNs FRM-26.8
- incorporated into the construction spec.7
? d 4 W6te incorporated CSCN's PRM C-8.4.2 j noted in the revision block? j '. 5 Ara licensing commitaants included and/or consistent with the SAR? ) 4 4 i, 4 i l i 1 j l 1 0056q/1/020-6 1 j Figure 6.1-7 Construction Specifications Checklist 1 w,-n-n -,-wn- r,----,e,<, ------,--,,--,-,,--,--,,.e-,, ,.-,...e.,, r, --m,-w,- - , , , ---r--,,w,n,,- -awe.s-,.-.-
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l l Page 1 of 2 READINESS REVIEW PROGFAM VERITICATlpN CHECKLIST can Cont. ! No. . Item _ Document 1 Did the CSCN receive required PRM C26.7.1 approval signatures (responsible SGS, nuclear EGS. PE. PQAE. 11 required.)? 2 Were other disciplines affec- ANSI N45.2.11. J tad beside the responsible Sections 5 & 8 one, and it so. are PRM C26.7.1B signatures provided? k 3 Were design documents revised. if necessary - (drawings, etc. analysis, calculations)? 4 Does this CSCN corflict with ANSI N45.2.11. FSAR (licensing) commitments. Sections 3 & B and if so, has a licensing PRM C26.7.lc. document deviation (LDD) , form been initiated by I the responsible EGS? 5 Are specification change PRM C26.8 notices being incorporated in accordance with 26.8 of the PRMt 6 Did this change impose more PRM C26.9 stringent requirements, and if so, was a retrofit required of work already in place? 0086g/1/020-6 \ _ Figure 6.1-8 CSCN Checklist (Sheet 1 of 2) 1
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i l !- l .. ! i i i j i l 1 Fage 2 of 2 READINESS REVIEW PFOGRAM f 4 i YKBIFICATION CHECKLIST I~ ' CSCN
~
Cont. No. Itea ko C.u anL_,__ ___ 7a was material requisition PRM C29, Att. B responsibility involved in this change, and 11 so were appropriate changes made in the documents? l 7b Were purchase orders affected PRM C29 Att. B by this change, and if so, were appropriate changes O made to the documents? 8 Was this change in compliance PRM C26.7.la with current design criteria? O 1 l l l l i 0086g/2/020-6 Figure 6.1-8 CSCN Checklist (Sheet 2 of 2)
1 \ Page i of 2 EEADINESS EEVIEW PROGRAM ' YKElflCAT10N CHECKLIST DEVIATION REPORTS Cont. No. Item Documtpt__ 1 1s the deficiency clearly (.1.18 GD-1-01 identified? ANSI N45.2-16 2 is the source or cause of ANSI N45.2-17 the deficiency clearly GD-T-01 6.5 identified? 3 !s the disposition clear? ANSI N45.2 16 G D- T- 01 6.5
., 4 If ites was dispositioned ANSI N45.2-16
- Repair", "Use-As-Is". " Void",* CD-T-01 6.11.6 and " Hardware Not Affected" was justification prepared?
sa Did justification require a ANSI N45.2-16 calculation? If so, is calculation checked, approved as required by calculation procedure? 5 Does a design document, ANSI N45.2.11-8 revision or change notice incorporate DR7
, 6 1s interface review required / ANSI N45.2.11-5 accomplished (interdisei- PRM C1B pline, client, Westinghouse.
V-SAMU. etc.)? 7 Was a licensing commitment AN!! N45.2.11-P affected? If so, has LDD been initiated?
" Void and Hardware not affected not required by ANSI N45.2 16 0048q/1/020-6 l
\s l l Pigure 6.1-9 Deviation Reports Checklist (Sheet 1 of 2) l
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3 e i 4 I i i i l i i Page ? of 2 2 BEADINESS REVIEW PROGRAM i VERIFICATION CHECKLIST 4 I 1 j DEVIATION REPORTS 4 Cont. ) N_o . Item DE Lment i j 8 Have all required approvals ANSI N45.11-7 3 been obtained - (EGS. PE. FEM C16.5.2/3 r QA, etc.) i, il 1 i i 1 4 i d A i 1 a 1 1 1 i t a 4 4 i A 1 i d. 1 i
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i l 00489/2/020-6 a 1 1 i A { Figure 6.1-9 Deviation Reports Checklist (Sheet 2 of 2) 4
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l i l Page 1 of 1 i READINESS REVIEW PROGRAM i l VERIFICATION CHECKLIST FCRs cont. l No. Iten Document l 1 Is the rationale for the ANSI N45.2.11-6 disposition provided? PRM C17.6.5 2 Was interdiscipline review ANSI N45.2.11-5 a performed when required? PMM C17.5.3 3 Were approvals present. PE ANSI N45.2.11-7 4 BCS. QAE if applicable? PRM C17.6.2.5 < l 4 were affected documents PRM C17.5.2 eevis.or 1 0050q/1/020-6 Figure 6.1-10 FCR Checklist
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) Page 1 of 2 READINESS REVIEW PROGRAM j VERIFICATION CHECKLIST 1 vanDos oocunrm s -i l
- i
! Cont.
t No. Item DoCUEent 1 1 1 Has this document been properly ANSI N45.2.11 See. 4 4 dispositioned and the correct PRM Part C. Sec. 5 status by the responsible engibeer indicatedt 2 Was vendor data reviewed PRM Part C, See.5 by effected disciplines to satisfy interface requirements? I a j 3 Are selected data and INSI N45.2.11. Sec. 4 materials on the vendor P.'M Part C. Sec. 5 4 document in compliance a with the procurement specification? f l* 4 For Bechtel revised supplier ANSI N45.2.11. Sec. 4 drawings PRM Pr.rt C. Sec. 5.7 Have the required signatures ; (responsible EGS and APE ' i or PE) been obtained for i revisions to drawings? 5 Does the vendor 's design PRM Part C. conform to the project Section 5.5.3 design and licensing commitments as described in the FSAR7 i 1' 6 Was the proper data in the vendor's documents used in the BPC design documents, 3 calculations, etc.? l
; ooseg/l/o20-6 i
i j - i Figure 6.1-11 Vendor Documents Checklist (Sheet 1 of 2)
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J l I 3 I Fage 2 of 2 i READINEES EEVK 1 fEO__C W VfRif!CATJON CHECKLIST i ! VENDOR DOCUMENlE l l j cont. l l No. I t ern Docurent l 7 Does the equipment quali. PRM Part C. Sec. 37 fication documentation j meet the qualification 1 and licensing require-
- ments of the specification?
l i i 8 Do the Codes and Standards FPM Part Sec. 5.9 lists submitted by vendors , include the applicable
- revision date of each j document?
i i i i e i 4 l a I i 4 s 1 i i 4 i i l 0054e/2/ozo-s i
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Page 1 of 1 gEjp1 NESS REVIEW PROGRAM VERIFICATION CHECrLIST SDDRs Cont. No. Item _ Document _ __ 1 Did the SDDR receive required PRM C23.4 (OE, PE, ORE) signatures? 2 Did the SDDR receive required ANSI N45.2.11 interdisciplinary reviews? Sections 5.0 & 8.0 3 Mas the responsible ANSI N45.2.11 discipline incorp. SDDR Section B.O changes into the appropriate PRM C 23.5 procurement documents (i.e., 4 specifications) as required by thg PRM7 4 Does the SDDR conflict with ANSI N45.2.11 commitments? If so, have Eections 3.0 & 3.8 deviations (LDD) been submitted? PRM C 23.4 4 5 Was a FECO required to be ANSI N45.2.11 initiated? If so, was it Section 8.0 completed and issued? PRM C J3.4 6 Has the information described ANSI N45.2.ll in the SDDR been incorporated Section 8.0 into other affected documents PEM C 23.5 as required? 5 7 Have deviations in supplier ANSI N45.2.11 hardware occurred without Section 8.0 the processing of an SDDR7 PRM 23.2 and 23.3.; if so, what effects have occurred? Have the procurement documents been revloed to refleet the changes? 0049q/1/020-6 Figure 6.1-12 SDDR Checklist
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eta- Ts y. I k Page 1 of 3 RE_ADINESS FEVIEW TROGRAM VERIFICATIQF CHECKl<lST LQ2E
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cont. No. Item Docurent 1 Did the equipment qualification PEM Part C 37.4.; data packages (EQ DPs) include:
- a. Seismic and environmental test reports and procedures
- b. Setonic and environmental analysis and pertinent backup data
- c. Pertinent correspondence from BPC, the hardware supplier, and/or outside consultants as required)
- d. Required certificate of PEM Appendix EA l comformance Section 6.3 E 1
- e. Equipment qualification design change verification form
- f. Seismic qualification review team (SQRT) form 9 Nuclear regulation (NUREG) .
0588 checklist (HARSH l environment only) I h. Table of Contents
- i. Approval of equipment l qualification document !
review sheet l I 2 Was the EQ documentation PRM Part C, reviewed by: c37.4.1 l a. Environmental qualification group
- b. Seismic review group 1
l l 00571/1/020-6 I l Figure 6.1-13 EQDP Checklist (Sheet 1 of 3) l
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1 I. 4 i O I l l 1 l { Page ' ct ) J FLA_QlEE.I E._6.g3 I EW FROGPM j VEh1F 1 CAT 1ON ItiLC.FA111 ) EEEE Cont. No. Item pocument . I 6 If qualification is being based IEEE 323, sec. t.4 on operating history, has and PRM
- supporting documentation been Appendix EA provided? Section 3.6 7 If qualification is being based 1EEE 323, Sec. 6.5 l
on analysis, was data provided and FRM in the EO report supporting the Appendix EA 1 analysis? Section 3.5 i l 8 If on-going EQ testing la being IEEE 323 Sec. 6.6 performed, is the hardware that and PRh j is being qualified stated to be Appenoix EA i identical to what is Section 3.4.A j installed? i i 9 Did the EO documentation include PRM Part C. C37.4.2 all referenced material / documentation? 4 If not, did the hardware IEEE 323, Sec. 8 I supplier provide and PRM i documentation location Appendix EA and file no. for audit purposes? Sec. 6.3-C.4 10 Did the EO documentation IEEE 323. Sec. e . - include dated supplier and PRM I ! s approval signatures? Appendix EA l Section 6.3.E C t p V ,I 0057q/3/020-6 i Figure 6.1-13 EQDP Checklist (Sheet 3 of 3) i
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1 i J J l 2 Fage 2 of 3 READINESS BEVIEW PEOG,R_AM Vgg1FICATION CHECKLIST E2EE Cont No. Item Qe c yn e ra t 2a Were the proper identification PEM Part C, C37.t.1 designators EA (environmental). QG (Seismic). or EQ (both) used to identify the scope of the EQ documents? 3 Were EQ and seismic review group PEM Part C. C37.4.1 comments incorporated on the review document returned to the vendor? 4 Did the environmental and IEEE 323 service conditions (used to Lee, 6.5.4 quality the haroware and PRM envelope the conditions Append 4v EA stated in the hardware Secti specification? 4a. Accident ambient 4b. Seismic 5 If type testing was used to IEEE 323. qualify the equipment, were Sec. 6.3 the following addressed in and PEM the EQ report? Appendix EA Sa, Test plan Section 3.2.1 5b. Test sequence 5c. Aging 5d. Radiation Se. Vibration 5f. Operation under normal and accident conditions Sg. Inspection after testing 5h. Calibration of test instruments and traceability to nationally recognised ( standards 0057q/2/020-6 i s Figure 6.1-13 EQDP Checklist (Sheet 2 cf 3)
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s . , 1 i i 1 j i 4 l MODULE 17 - RACEWAYE i DESIGN VERIFICATION WALKDOWN (SHEET 1 OF 2) iO 4
- ltea kequirements Reference 1
] 1 Does general routing agree Construction spec. X3AR01 j with raceway layout drawing? E.8.7.B i 2a. Are raceways identified at Construction spec. X3ARO1 15' intervals? EB.7.1H. EB.7.2H
- b. Is identification stenciled Construction spec. X3ARO1 j if raceway is in containment? E8.1.D i
j 3 Are separation requirements Construction spec X3AR01 j malatained?
- a. Raceway groups E6 Attachment B
- b. Hot pipe E8. Attachment D
- c. Nuclear instrumentation E8.7.2.P system j 4 Are raceway terminations CX3DF002 e
(SEISMIC) per requirements? CX3DF003 CX3DF004 5 Are there any unspecified Construction spec X3AR01 attachments to the raceways? E8.7.1S. T 6 la there any tray over-loading (above side rails)?
. 7 Are fire wall penetr. tion Construction spec K3AR01 sealing condulets installed? E8.6.2 8 Are SE1SMIC gaps maintained CX3DF001 Note 8 when crossing construction CX3DF002 Detail 12 SEISMIC gaps? CX3DF003. Detail 8 9 Are tray covers installed CX3DF001. Note 11 in working areas (under platforms, etc.)?
0086q/1/020-6 ( Figure 6.1-14 Walkdown Checklist (Sheet 1 of 2)
L MODULE 17 - BACEWAYS DESIGN VERIFICATION WALKDOWN (SHEE1 2 OF 2) C . _ . . _ . _ lteE Requirements Reference 10 Are there any aluminum race- Construction sger X3AH01 vays or boxes (containment EB.7.D only)? 11 Is stainless steel flex used Constructicn rpec K3AR01 (containment only) E8.7.2.E 0086g/2/020-6 Figure 6.1-14 Walkdown Checklist (Sheet 2 of 2)
(} 6.2 CONSTRUCTION PROGRAM VERIFICATTON This section contains a description of the development of the l implementation matrix for construction commitments and the verification process to evaluate the adequacy of the installation of electrical raceways. The Readiness Review leam for Module 17 consisted of 4 team members who have a combined total experience of 48 manyears. These team members devoted approximately 40 manhours to the investigation and resolution of the implementation process, and 600 manhours to the investigation and resolution of the verification process. Verification of the adequacy of the construction process as it i pertains to raceways was accomplished in two phases. In phase 1, 14 construction related licensing commitments were identified as being applicable to the scope of this module. Each of these was traced to_one or more implementing documents -l l to assure that the commitments were addressed by the i construction program. No discrepancies were found during this phase. j i In Phase II, 71 items of hardware were assessed for approximately 30 work elements each. These work elements j included both visually verifiable hardware attributes and () documentation attributes. Approximately 1100 records were. reviewed during this assessment. Phase 11 resulted in six findings that are discussed in section 6.2.3.2. 6.2.1
SUMMARY
EVALUATION , Program evaluation activities resulted in six findings (17-I through 17-6). The construction team reviewed these findings to assess their impact on the project and concluded that the findings fell into three categories: o Category A - Paperwork; required documentation missing ! or misfiled, or violation of procedural
- s_ requirements relating to documentation.
l o Category B - Ilardware; hardware deficiencies or violation of procedural requirements l relating to hardware installation. l o Category C - Programmatic; failure to follow existing procedural requirements, procedural requirements failing to implement licensing commitments, or failure to follow engineering guidelines. I t
's The findings, their level of importance, and their category are given in Table 6.2-1.
l
i Category A, paperwork concerns, contains one finding (17-5): the inadequate referencing of supporting documentation on the j inspection reports. Deviation Report (DR) numbers were not g l referenced on the back of the EE580 cards which are used to y document inspection records. Four DRs were checked which involved nine raceways. None of the associated inspection reports for these raceways had the DR number noted. Further, rework numbers associated with rework documentation were similarly ommitted from the inspection cards. This finding does not impact hardware, since the information is available by manually reviewing all DRs/ Reworks. Two findings (17-4 and 17-6) were classified as Category B, hardware concerns: raceways and junction boxes not grounded per the drawing, and isolated field installation inadequacies. In Finding 17-4, the assessment team found 1 item out of 58
- raceways / junction boxes inspected that was not grounded per j drawing. I n 17 - 6 the team found other isolated discrepancies, l such as one junction box not correctly identified, one splice l
plate not flush, and two cable trays with damaged bottom sections. Finally, three findings (17- 1 through 17-3) were classified as Category C, programmatic. These findings include raceway separation (17-1), bolt torque process / documentation (17-2), and water intrusion (17-3). In 17-1, of 58 raceways reviewed, 7 l were determined to require fire separation barriers. Of these seven, three did not have the procedurally required Fire Separation Barrier Request (FSBR) initiated. In Finding 17-2, the bolt torque process / documentation verification revealed that l l approximately 20 percent (i.e., 42 of 192) of the Z-clip bolts that were verified failed to meet the minimum required torque. In addition, there were related minor problems with the torque program dealing with the torque wrench activity log not referencing the item torqued; the EE580 card not referencing the torque wrench number used; and personnel entering the wrong calibration date on the EE580 card. The final item in this category (17-3) deals with water intrusion into conduits. At the time of the assessment, there was no defined program to ensure the identification, tracking, and sealing of those conduits whose configuration would allow a route for water entry into plant equipment. In addition, the review team noted that of 20 PTC boxes verified, none had box cover gaskets installed. One of these 20 was located inside the containment (which requires waterproof boxes). The construction assessment concluded that the following l activities were acceptable: 1) The review of inspectors'
- certification indicated that for the inspection documents reviewed, all inspectors were certified at the time of inspection. 2) The general material requirements (i.e., size, typt, identification, etc.) were acceptable. 3) With the exception of those items previously mentioned, workmanship is O
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acceptable. ()g Based on the results of the hardware assessment. documentation review, and the project responses to resultant findings, the construction assessment team concludes that, at the time of this review, the program for installatian and inspection of electrical raceways generally met project commitments; however, specific specification and procedural (gj f- deficiencies were identified in the areas of water intrusion and documentation filing /retrievability. In addition, contractor compliance to existing requirements for safety train separation and bolt torquing was deficient. The Project corrected the procedural and specification gg deficiencies, conducted additional craft training, and has (#i increased QC inspection activity in the areas identified as defleient above. The Project is also implementing an acceptable plan to correct documentation filing /retrievability problems. An extensive review of installed hardware by the design agency (Bechtel) indicated that failures to comply with the existing requirements for bolt torquing did not affect the ability of the safety-related systems to function during postulated seismic events. With the completion of corrective actions, the construction assessment team is satisfied that the installation and inspection program is a quality program that meets project commitments, meets design requirements, and insures that
/"} installed hardware is of a quality nature. The team is further
(/ satisfied that the quality of installations is documented by readily retrievable installation and inspection records. 6.2.2 PHASE I - COMMITMENT IMPLEMENTATION Section 3 contains the commitment matrix for this module. Each commitment identified by the Final Safety Analysis Report (FSAR), Inspection and Enforcement (IE) Eulletins, or generic letters applicable to this module is listed. Those commitment s indicating construction responribility for implementation were tracked down to the working level document (that project document that interprets and specifies action to be taken).
~~'
For this module, 14 commitments were identified as the responsibility of construction. For each commitment, the Readiness Review Team member identified the project document currently implementing the commitment and that project document <~ first containing the commitment. The team then reviewed, for (- content, the document identified as the commitment and compared it to the practices or directions stated in the implementing document. If the commitment was not implemented prior to the start of the construction activity affected, programs for rework and/or reinspection were identified. 6.2-3
Ot the 14 implementation entries reviewed, no items of concern were identified. 6.2.3 PHASE II - CONSTHUCTION VERIFICATION PROGRAM O The verification program was structured to ascertain whether necessary documentation requirements for each procedure and revision are verifiable and to establish confidence in the quality of the work performed. To accomplish this, a verification plan was developed and implemented for a systematic review of installed hardware and its associated quality documentation. The plan, as implemented, identified approximately 30 elements for verification and resulted in the review of approximately 1100 documents. The following procedures and specifications were used to establish inspection and documentation requitements: o ED-T.02 Installation of Electrical Raceways. o GD- T- 2'/ Anchor Bolt Installation and Inspection, o GD-A-04 Calibration Control. o X3ARO1, Section E8, Raceways. 6.2.3.1 Verification Plan O The verification scope a.ad plan was formulated to establish the dffeCtdd population, Sdmple size, and checklist items for field verification. The population size was determined using the following criteria: o Unit 1 o IE only. o CC status { construction complete and Quality Control (QC) inspected). Use of these criteria resulted in a total population of 5160 items representing 2000 conduits, 1490 trays, and 870 special raceways. at random, The sample size was determined by celecting a raceway doing an dCtual field WalkdoWR to determine an average verification time per item, and dividing that average . time into Doing the totalintime so resulted available a sample size offor 71field verification. items. A random number list was then used to select items and the sample was examined for adherence to the following criteria: O
- 6. 2- 4
o Representation of the construction time trame. o All buildings included. o Adequate representation of all trains (A,B,C.D). The verification sample chosen is detailed in Table 6.2-2. Verification checklists and a brief set of instructions to guide the team members through them (Figures 6.2-1 through 6.2- 4 ) were developed using the verification cttributes listed on Table 6.2-3. These attributes were compiled from the site procedures, r'g site specifications, Quality Assurance (QA) audits, Quality (J Concerns, and Nuclear Regulatory Commission (NRC) construction appraisal team inspections of other nuclear sites. An acceptable response in the results column required no further action. Unacceptable items were noted in the remarks column, and a Readiness Review Information Request (RR1R) and/or a Readiness Review Finding (RRF) were generated and forwarded to the responsible project organization. The verification process was implemented in two steps. Step 1 consisted of a field walkdown of the items selected to ascertain whether the items complied with the attributes / requirements listed on the checklist. Step 2 consisted of a review of documentation to determine whether the as-found condition was O properly reflectad by the inspection documents (including deviation reports and/or rework requests). The documentation attributes / requirements are included on the item checklist so that the checklist reflects both hardware assessment and documentation review for each item selected. 6.2.3.2 Results This section contains a ': view of the verification findings by category. This review contains a description of the finding. the project response, and the Readiness Review conclusions. The finding matrix (section 5.3) is provided as an overall listing of the findings. During the verification process, the review team noted many activities that were completely in compliance with the verification criteria. Inspector qualification; installation of the correct size, type, and material items; stud nuts oriented properly; field pull boxes oriented correctly: raceways O supported at proper intervals; and proper pulling fittings used were all items on the checklist for which no discrepancies were noted. There were also activities, although some individual components violated the criteria, in which the overall level of compliance O was such that a finding was not issued, but an HR1R was generated or the construction organization was notified to 6.2-5
document and correct the specific item. These are discussed in section 6.2.4. 6.2.3.2.1 Category A Findings O This section covers the item classified as Category A. Software. The one finding in this category is described below: o Readiness Review Finding 17-5 (Level III)
Description:
Field procedures ED-T-02 and GD-T-27, and 10 CFR 50, Appendix D, identify the requirements for retrievabi'.ity and identification of QA documentation for activities affecting quality. During verification, l it was noted that Deviation Report (DR) numbers are not l being referenced on the back of the associated EE580 : cards as required. Also, rework numbers are not being identified on the back of the associated EE580 cards, which prevents retrievability in a timely manner. This was also noted during a recent QA audit, CP01-85/29. Further, the conduit EE580 cards do not reference the 1 applicable support numbers to which the conduit is supported and the associated Concrete Expansion Anchor Inspection Report was not filed in the QA vault, as required by procedure. Proiect Response: A DR tracking system has been developed to enable identification of DRs against specific commodity items for all disciplines. h Additionally, the field electrical section has developed a tracking system to identify FSBRs. Rework Reque6ts, and Conditional Releases against specific commodities. The procedute has been modified to require QC to send another card to the vault whenever DRs or reworks are written against previoucly accepted itens. Reference on the raceway inspection (EE580) card of associated supports is not required by site procedures. Acceptance of the completed raceway signifies acceptance of all associated supporte. All anchor bolt inspection reports not located by the Readiness Review Team were found to be filed in the vault by the raceway layout drawing. For those items on section drawings, the main drcwing is used for filing references. Two items were incorrectly identified on the inspection forms. _ Readiness Review
Conclusion:
The Readiness Review Team selected additional commodities to verify the existence and accuracy of the cross-reference system. The results of this additional verification indicated that identification of documents associated with deviations 6.2-6
6 and reworks is acceptable: therefore, Readiness Review O concurs with the above response. 6.2.3.2.2 Category B Findings This section covers those items classified as Category B. O Hardware. The two findings in this category are given below: o Readiness Review Finding 17-4 (Level III)
Description:
Per construction specification X3AH01, field procedure ED- T-02, and drawing CX3DE001/002 metal O conduit systems shall be grounded by copper cable connections to the ground system. Readiness Review identified that out of 58 items reviewed, 11 items were apparently not grounded in accordance with the above requirement. Proiect Response: Of 11 raceways identified, 3 were not grounded because the flex conduit had not been installed (grounding is installed with the flex conduit); 6 were grounded through other raceways attached to them: I was not grounded; and 1 was grounded, but had substained damage to the ground connection. DRs were issued to rework the last two items.
\-- Based on the results of the investigation, a generic deficiency does not appear to exist and no additional sampling was performed. There is no root cause since all but one item was installed in accordance with deu;Jn requirements (the damage to the item was apparently substained after QC acceptance). No action was required to prevent reoccurrence.
Readiness Review
Conclusion:
Readiness Review concurs with the above response. o Readiness Review Finding 17-6 (Level 111)
Description:
Construction specification X3AR01, design drawings, field procedure ED-T-02, and Institute of Electrical and Electronic Engineers (IEEE) 336 delineate requirements for installation and inspection of electrical raceways. During the field verification. several field installation and documentation O inadequacies were noted. These inadequacies are as follows: one junction box incorrectly identified, one cable tray not having splice plates flush with the tray, one junction box not installed on location according to the drawing, two cable trays having damaged bottom sections, and failure of the EE580 group to status O completed work to the data base as required by the procedure. 6.2 7
Eroject Response:
- 1) Twenty additional boxes were sampled for identification and were found to be correctly identified. A DR was written to document the incorrect labeling. This was determined to be an isolated incidence.
- 2) Two hundred additional splice connections were checked and no violations were found. A DR was written to document the violation found. This was considered to be an isolated incidence.
- 3) Note 21 on drawing CX3DF001 allows relocation of junction boxes to avoid interference. Thus, this item is not a violation.
- 4) A walk- through of the control building did not identify any additional violations. A DR was generated to document the two violations noted in the finding. This was considered to be an isolated incidence.
- 5) Field procedure ED-T-02 was revised to state that "CC" status is placed into the data base prior to forwarding the cards to QC. This procedural discrepancy did not affect the quality of the raceway or the installation.
Readiness Review
Conclusion:
Based on the additional walkdowns performed above and review of the above mentioned DRs and procedure changes, Readiness Review concurs with the above response. 6.2.3.2.3 Category C Findings This section covers those items classified as Category C. Programmatic. The three findings in this category are described below: o Readiness Review Finding 17-1 (Level II) pescription: Per ED-T- 02, section 5.1, an FSBR shall be initiated if field conditions preclude maintaining minimum separation distance. Of 71 raceways assessed, 7 were found to be in violation of minimum spatial separation requirements. FSBRs had not been initiated l for tour of these seven raceways. I Project . Response: The fire separation barrier program is described in field procedure ED-T-02. The purpose of the program is to have the craftsmen and foremen identify prior to installation those situations where 6.2-8
O spatial safety-train separation required by X3AH01, section E8, cannot be achieved due to field conditions. This is done by the foreman originating an FSBR and forwarding it to the Construction area engineer. The area engineer must then decide whether it is feasible to reroute the racevay to maintain the required spatial O separation proceed (in which case the FSBR is rejected) or to with the installation and install a barrier at the later date (usually after cable pulling is completed). This decision is based, in part, on the guidelines presented in Attachment B of X 3 AR01- E8. Design is presently preparing specific barrier O installation details and does not forsee any construction problems arising if the existing guidelines are used. For approved FSBRs, the form is logged in, assigned a control number, and tracked as an unfinished construction item against the raceway. The Project lacking FSBRs.investigated the four raceways identified as Two were in the upper which has reduced separation requirements; spreading were room, in accordance with X3AR01-E8: and did not require FSBRs. The other two, althcagh accepted and inspected, were not separated sufficiently from a conduit that had not been inspected and accepted. A DR was initiated to identify failure of conduit. the contractor to initiate an FSBR for the An additional sample of 78 the Project. Of the 78, 58 raceways was walked down by were so documented. required FSBRs, but only 45 required on the remaining 13. FSBRs were initiated as DRs and Both the 13 items identified by the Project and the 2 items identified by Readiness Review as lacking FSBRs had been accepted by QC; however, a closer check revealed that later date, other raceways had been installed at a None of the thusnewlycreating installedthe separation violation. by QC. raceways had been inspected The root cause determined to befor FSBRs not being originated was existing procedural requirements. lack of compliance by the contractor to Remedial consisted of retraining the craft with the procedure action G requirements, and revision of the desktop procedures for inspection by the craft prior to turnover to QC. Additionally, field procedure ED-T-02 was revised to add further instructions for disposition, processing, and closeout of the FSBR when the barrier is installed. i To reduce the number of DRs that may result from raceways released to QC for inspection without FSBRs, ED-T-02 was modified to permit lack of an PSBR being 6.2-9
- - - - - - - - - ~ ~ ~ ~ ~
processed as a punchlist item. It should be noted that area walkdown and turnover procedures also contain separation eriteria and barrier installations as walkdown checklist items. This finding will therefore have no impact on plant safety. Readiness Review
Conclusion:
The Readiness Feview Team
'has examined the procedure revisions and agrees that the above response adequately addresses the problem.
o Headiness Review Finding 17-2 (Level I)
Description:
Field procedure ED-T-02 requires that bolts be torqued: torque wrench numbers and their Cdlibration dates be noted on the EE580 card, and QC verifies the torque on a sample basis. Further, field procedure GD-A-04 requires that the tag number of the item being torqued be entered on the Torque Wrench Activity Log. Contrary to the above, bolts securing the raceway to the support were found to be improperly torqued. Information noted on the back of the EE580 card was in conflict with some torque wrench calibration records. Also, the raceway numbers were not referenced on some of the Torque Wrench Activity Logs. Proiect Response:
- 1) To evaluate the generic implications of low bolt torquing on the tray support connections, the Project selected at random an additional 59 tray lh arms to determine installed Z-clip bolt torque. The results confirmed that the low torque in 2-clip installations was not an isolated incidence. A generic DR was written'and evaluated by Project Engineering. Analysis showed that even for worst case configurations postulated as a result of the data collected, slippage would not occur for Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake (OBE) condit'ons; therefore, no rework was required f or existing Z-clip attachments. This deviation was reported to the NRC as a potentially reportable item. Final evaluation of DER-106 (project evaluation for reportability) had not been completed at the time of publication of this module.
The root cause of this discrepancy was twofold. First, the contractor failed to comply with existing g torque requirements. Second, the QC inspection T method was based on a sampling program whose requirements were not rigorous enough to have identified the problem. O 6.2 10
r~ To assure that future installation will attain the
\ very high multiples of safety margins against slippage that were originally intended, the contractor was retrained in the procedure requirements and electrical QC sampling was increased to 50 percent of the Z-clip bolts. The increased QC attention will be maintained until
( adequate assurance of contractor compliance to the torquing requirements is demonstrated.
- 2) The torque wrench activity logs serve only as a quick means of determining affected items should a f'T particular wrench fail recalibration. Alternate
(_/ methods are available to make this determination, including reinspection of all items inspected by the person to whom the torque wrench was issued. A sample of 94 raceways accepted from January 1, 1985, to July 1, 1985, indicated that 12 of these raceways indicated a torque wrench number, but the torque wrench log did not reference the raceway number. It d was determined that some inspectors were listing the raceway number, and some were listing the support number. Training was conducted July 12, 1985, to ensure that procedural requirements for indicating raceway numbers were consistently followed. () Because of the availability of other methods to determine torque wrench usage, no retrofitting of old logs was required.
- 3) Investigation of the items, identified from different calibration dates recorded on the EE580 cards, determined that the calibration group personnel mistakenly wrote the wrong dates on the calibration stickers located on the wrenches. This had no quality impact since the wrenches were within the calibration period on the date used. All other items on the issue shelf were checked and calibration dates agreed with the sticker dates.
(Q_/ This was determined to be an isolated incidence of personnel error. Readiness Review
Conclusion:
Readiness Review concurs with the above project response.
~
o Readiness Review Finding l'i-3 (Level I)
Description:
Construction specification X3AR01 requires that where exposed to outdoor conditions, National Electrical Manufacturers Association (NEMA) type- 4 boxes be used. This includes the containment building and areas subject to wash down or excessive moistures. (]_f Further, the above specification states that conduits entering electrical equipment from above be located to 6.2-11
prevent water entry or be sealed with approved sealant. f Contrary to the above requirement, pull boxes were found ' not to have gaskets installed; raceways have been installed in wet locations (containment) that are not of NEMA-4 (waterproof) construction; and no program exists to identify, track, and seal those conduits where water intrusion is possible. project Response: Design approval was obtained through a change to Construction Specification X3AR01-E8 to allow the use of NEMA-12 (nonwaterproof) boxes in wet areas, provided conduit entering the box is sealed. Field procedure ED-T-02 was changed to ensure sealing of conduits entering these boxes. Procedures ED-T-02 and CD-A-50 were changed to include moisture / water barriers g in walkdown inspections. Details for installation of W the sealing compound were obtained from the design agency. Readiness Review
Conclusion:
The procedure changes were reviewed and adequately address the finding. Readiness , Review concurs with the project response. ' 6.2.4 ITEMS OF QUESTION This section discusses observations during the verification process that were questionable to the review team, but were too + minor to be clanned as findings or were the subject of an h existing reinspection program, o Trash in Trays Several minor instances of' scrap material and trash in tray sections were noted; however, the review team later observed personnel walking-down trays and noting whether cleaning was needed. The existing program to maintain cleaning was then deemed to be adequate. Additionally, the instances noted above were judged to have no detrimontal effect on the tray or cable, o Hot Pipe Separation Conduit 1DE513RX010 was found to have 2 in, of clearance from spool number 1-1204-020-S-12. This specific item was not identified as a finding since Readiness Review Finding 4- 56 (Module 4) identified generic hot- pipe--to-raceway separation problems; the project response was to walkdown all hot pipe to identify separation criteria violations. 0010g /024- 6 6.2-12
To assure that future installation will attain the very high multiples of safety margins against slippage that were originally intended, the contractor was retrained in the procedure requirements and electrical OC sampling was increased to 50 percent of the Z-clip bolts. The increased QC attention will be maintained until O adequate assurance of contractor compliance to the torquing requirements is demonstrated.
- 2) The torque wrench activity logs serve only as a quick means of determining affected items should a
' V('} particular wrench fail recalibration. Alternate methods are available to make this determination, including reinspection of all items inspected by the person to whom the torque wrench was issued. A sample of 94 raceways accepted from January 1, 1985, to July 1, 1985, indicated that 12 of these raceways : indicated a torque wrench number, but the torque ! wrench log did not reference the raceway number. It was determined that some inspectors were listing the raceway number, and some were listing the support number. Training was conducted July 12, 1985, to ensure that procedural requirements for indicating raceway numbers were consistently followed. Because of the availability of other methods to ,k determine torque wrench usage, no retrofitting of l old logs was required. I
- 3) Investigation of the items, identified from j i
different calibration dates recorded on the EE580 ' cards, determined that the calibration group personnel mistakenly wrote the wrong dates on the calibration stickers located on the wrenches. This ! had no quality impact since the wrenches were within the calibration period on the date used. All other items on the issue shelf were checked and calibration dates agreed with the sticker dates. l This was determined to be an isolated incidence of personnel error. Readiness Review
Conclusion:
Readiness Review concurs i with the above project response. o Readiness Review Finding 17-3 (Level I)
Description:
Construction specification X3AR01 requires that where exposed to outdoor conditions, National l Electrical Manufacturers Association (NEMA) type-4 boxes lgs be used. This includes the containment building and areas subject to wash down or excessive moistures. Further, the above specification states that conduits entering electrical equipment from above be located to i 1 6.2-11
I prevent water entry or be sealed with approved sealant. Contrary to the above requirement, pull boxes were found not to have gaskets installed; raceways have been installed in wet locations (containment) that are not of NEMA-4 (waterproof) construction; and no program exists to identify, track, and seal those conduits where water intrusion is possible. Proiect Response: Design approval was obtained through a change to Construction Specification X3AR01-E8 to allow the use of NEMA- 12 (nonwaterproof) boxes in wet areas, provided conduit entering the box is sealed. Field procedure ED-T-02 was changed to ensure sealing of conduits entering these boxes. Procedures ED-T-02 and GD-A-50 were changed to include moisture / water barriers in walkdown inspections. Details for installation of the sealing compound were obtained from the design agency. Readiness Review
Conclusion:
The procedure changes were reviewed and adequately address the finding. Readiness Review concurs with the project response. 1 I 6.2.4 ITEMS OF QUESTION This section discusses observations during the verification process that were questionable to the review team, but were too minor to be clansed as findings or were the subject of an existing reinspection program. o Trash in Trays Several minor instances of scrap material and trash in tray sections were noted: however, the review team later observed personnel walking-down trays and noting whether cleaning was needed. The existing program to maintain cleaning was then deemed to be adequate. Additionally, the instances noted above were judged to have no detrimental effect on the tray or cable. o Hot Pipe Separation Conduit 1DE513RX010 was found to have 2 in. of clearance from spool number 1-1204-020-S-12. This specific item was not identified as a finding since Readiness Review Finding 4-56 (Module 4) identified generic hot-pipe-to-raceway separation problems; the project response was to walkdown all hot pipe to identify separation criteria violations. 0010g/024-6 6.2-12
TABLE 6.2 1 (SHEET 1 OF 3) l C:)
SUMMARY
OF CONSTRUCTION ASSESSMENT FINDINGS l Level of RRF Catecory(a) Significance (b) Number Description C II 17-1 Eight raceways were identified as having , separation distance violations. Four do not have FSBRs on file. Tray () numbers are 1BE311TRAA, 1BE311 TRAL, and i 1DE314TQAPVA. l C 1 17- 2 1) Of 192 bolts verified, , 42 failed to meet the l required torque (i.e., l installation torque of 50 ft/lb, inspection torque of 40 ft/lb, and verified at 15-20 ft/lb).
- 2) Torque wrench activity k'~' log does not reference J l the tray number on 14 of 29 raceways.
- 3) Information concerning the torque wrench i calibration number and '
calibration date on the back of the EE580 card is in conflict l with the calibration ! records. 1 I() 4) No evidence of torque activity indicated on the back of 27 out of 38 EE580 raceway cards. C I 17-3 Of 20 PTC boxes verified, () 20 failed to conform to the specification requitement that gaskets be installed under the box covers. Also there l I 0009q/1/OlS-6
TABLE 6.2-1 (SHEET 2 OF 3) Level of RRF Category (a) SiQnificance(b) Number Description _ __ _ is no program in force to O identify, track, and seal those conduits to prevent water entry. B III 17-4 Raceways and junction boxes were not grounded O per the drawing on 12 of 58 items verified. A III 17 - b 1) DR numbers not referenced on the EE580 card. Four DRs were checked which involved nine raceways. None of the above raceway cards had the DR number noted.
- 2) Inadequate O retrievability of rework documentation as it is noted on the back of the EE580 card.
B III 17-6 Numerous field l installation / documentation l inadequacies: l ! l
- 1) One junction box I incorrectly identified.
I
- 2) One cable tray did not have splice plates O flush with the tray.
- 3) One junction box not installed on location according to the drawing.
- 4) Two cable trays have bottom damaged.
i 0009q/2/015-6
TABLE 6.2-1 (SHEET 3 OF 3) Level of RRF Category (a) Significance (b) Number . Description ,__.
- 5) EE580 group not O statusing completed work to data base in accordance with the procedure.
O l O l
- a. Category A - Hardware concern.
B - Paperwork concern. C - Program concern.
- b. Level 1 - Violation of licensing commitments, project procedures, or engineering requirements with indication O, of safety concern.
Level II - Violation of licensing commitments or engineering requirements with no safety concerns. Level 111 - Violation of project procedures with no safety concerns. - O OOO9q/ 3 /015- 6
TABLE 6.2-2 ( S11EET 1 OF 2) VERIFICATION SAMPl.E 4 _ Cable Trays (38 Sections) 1AE30lTYAFR1 1AE302TEAJ lAE302TYCD 1 1AE321TMAC 1AE321TYAA 1AE332TLAH O 1AE332TSAF 1AE421TIAF 1AE422TSAH 1AE423TLZH 1AE424TEAN 1BE3OlTRAH IBE30lTRAK 4 1BE301TRAJ 1BE30lTRAM l 1BE30lTRAN . 1BE311TRAA 1BE311TRAG 1BE311TRAH 1BE311TRAJ , 1BE311 TRAK 1BE311 TRAL 1BE314 TRAX IBE31CTSDF IBE31CTVAER4 j 1BE321TRAD 1BE321TRAE 1BE321TRAF IBE321TRAG 1BE332TRAA 1BE403TLCD 1BE404TLCCR1 I IEE41tTLAB
,,~) IBE412TYCQ l 1BE413TLCH
- IBE414TLCM 1BE423TLDW 1DE314TQAPVA Conduit (22 Sections) 1AE12ARS004 1AE12ARS009 1AE30lRS070 r^ IAE30lRS270 IAE302RT105 1AE302RU251 1AE31CRS023 j 1AE7DIRS232 0003q/015-6/1
TABLE 6.2-1 (SIIEET 2 OF 2) 1BE301RM252 1BE406RS007 1BE415RLO51 0 1BE422RS161 1BE423RLO32 1BE425RS087 1BE50ARX061 1BE7DlRS009 1BE7DIRSO47 1BE7F4RS075 Os 1CE30lRS072 1CE30lRS074 1DE311RS133 IDE513RX010 Special Raceway (11 each) 1AE30lKPJ05 1AE301KSJ31 1AE3blKXJ24 1AE31DKSJ16 1AE322KSJ19 1AE322KSJ21 1BE422KSJ03 1ABJBOl71 1BBJB0169 1BBJB0173 1CRJB2766 , 1 I l 'O l lO 1 I i 1 l 0003 q / 015- 6 / 2 ) f
-_m ,_m.m, -..., _ .., . -, , .,. -.-.. ,- ,..
l l 1 1 i TABLE 6.2-3 VERIFICATION ATTRIBUTES i l Special Attribute Tray Conduit Raceway i j Size X X X 3 Material X X X 1 i j Type X X X l ] Location X X X ! Identification X X X t } Visible damage X X X Grounding X X X } ! Proper fittings X X X
- Number of bends X i
- Distance between pull points X > j Train separation X X X ) Hot pipe separation X X ll i Attachment to support X X X i e i l i l i i I i d k 0004 q /1/008- 6 1 1 _ , , . , , _ .. . . . . , _ , . . _ _ . .o,,m, ,~ . ,
1 s O I CHECKLIST INSTRUCTIONS 1 Hardware - Checklist Preparation A) From EE580 listing, transfer to checklist:
- 1) Conduit a) Item # 4 - installed length I
b) Item # 7- design size & type I c) Item # 10 - from & to locations
- 2) Tray a) Item # 4 - design type b) Item # 5 - design width c) Item # 6 - design depth d) Item # 23 - from & to locations B) From specification X3AR01-E9 transfer to:
- 1) Conduit !
a) Item # 29 line from Att.D that correspor2ds to raceway size C) From EE580 for conduit, tray, spec. raceway
- 1) Using from - to locations. locate raceway on !
physical drawing
- 2) Highlight raceway, and transfer building location.
floor elevation, and layout drawings to front of ' checklist II Hardware - Field Walkdown A) Proverification support
- 1) Make preverification walkdown to locate all items. Note those locations where scaffolding.
ladders, etc. will be required.
- 2) Contact coordination and operations for installation of scaffolding, room access, etc.
B) Walk-down Field
- 1) Using checklist. verify that the installation of the item is in accordance with the applicable items on the checklist.
0002q/1/009-6 Figure 6.2-1 Checklist Instructions (Sheet 1 of 2)
a 1
- f d.,
l i 1 i 1
- 2) If noncomplying conditions are noted, indicate in 1 the area under the yes/no space.
I j 3) While in area, observe surrounding items to ascertain sample selected is representative of adjacent items. 1 l III Software
- A) QA Records Vault
- 1) Locate EE580 control and tracking system l installation cards and record appropriate j information on checklist.
, 2) Locate deviation reports and reworks corresponding 1 to the item and record their #'s j 3) Record any torque wrench M's used for step *b" B) Field Records i ! 1) Verify in M&TE trailer calibration dates of torque 5 wrenches C) Findings ' ! 1) Write findings for any noncomplying items found " l that are not already documented by deviation ' W reports. I f i 1 0002q/2/009-6 Figure 6.2-1 Checklist Instructions (Sheet 2 of 2)
l l l i l \ I l I I I i I l i Raceway Tag No: Separation Group: Separation Color Code: Building Location: Room No,' Floor Elevation: Procedute/ Specification Revision Date FCR/DCN/FPCN ED-T-02 X3AROI GD-T-01 CD-T-07 I l Remarks: j TEAM MEMBERS PERFORMING VERIFICATION' Section Sionature Date 0040V/2 Figure 6.2-2 Construction Checklist for Cable Tra'- (Sheet ] of 9)
4 y i 1 l i f CHECKLIST ITEM REF. DOC. RESULTS/IEMARKS l 1. Verify the cable 13A901-EB Acceptable: ___ tray section is SECT E8.7.1.H 1 identified. SECT E8.1.D l ED-T-02 SECT 5.7.9 i l 2. If the ID marker X3AROl-E8 Acceptable * , is of the adhesive SECT E8.7.1.1 type, verify the
- lettering is black
. bold face, and i 1.75 inch high
} on a colored . background per the e separation group i . color code.
- 3. If the ID marker X3AR01-E8 Acceptable:
is of the stencil SECT E8.7.1.1 1 type, verify the a
~ lettering is 1.75
'4 inch high and j k', colored per the ]' separation group color code. 1 I 4. If the cable tray X3AROl-E8 Acceptable: 1 run is in excess SECT E8.7.1.H l of 15 feet verify l that there are j TD markers every 15 feet maximum. Engineered Length: j NOTE: Enter , length from EE580 1 data.
- 5. Verify the cable ED-T-02 Acceptable: ____
. tray's type is per .~ - SECT 3.3 is per design. l Type: NOTE: Enter design I type punched bottom i ladder or solid 1 bottom. t 4 0040V/3 i 4 1 9 i j Figure 6. 2-2 Construction Checklist for Cable Tray (Sheet 2 of 9) i 4
.-- e ,. , . . - - - .
. , , . . . . , . , _ - - . . . , - - - , . . n._n, n _.m_. . , . , .e,. ..n_,n.- w. _ . , _ , , , ,m.w-- , , , , , . . ,
- c. . i .
t a-l 1 I t l CHECKLIST ITEM REF. DOC. EESULTS/ REMARKS i
- 6. Verify the cable LD-T-02 Acceptable:
tray's width is SECT 3.3 per design. Width. , NOTE: Enter design width, 6", 9", 12", i 18" or 24". l l
- 7. Verify the cable ED-T-02 Acceptable.
tray's depth is SECT 3.3 I l Per design. Depth: NOTE: Enter design depth 4", 6".
- 8. Verify that the CX3DF001 Acceptable:
cable tray is Cable Tray galvanized. Note No. 1 l
- 9. Verify the bolted X3ARO1-E8 Acceptable joints between SECT E8.7.1.D tray sections are ED-T-02 tight and rigid. SECT 5.7.4 (Bolt heads and nuts flush with the tray and the splice plate.)
- 10. Verify that there X]AR01-E8 Acceptable: I are no ventilation SECT E8.7.1.T '
ducts or non-electrical material or equipment permanently at-tached to or supported by the cable tray.
- 11. Verify that the X1ARO1-E8 Acceptable:
" gold" color bolts SECT EB.7.1.B are used on splice ED-T-02 plates. SECT 5.7,04 0040V/4
( Pigure 6.2-2 Construction Checklist for Cable Tray (Sheet 3 of 9)
CHECKLIST ITEM PEF. DOC, EE_SyLJSfREMARKS
- 12. Verify that there is 33AR01-E8 Acceptable:
a minimum separation SECT E8.7.E of 8-inch maintained between the top of the tray siderall and the bottom of the tray above, pro-vided all affected affected trays contain cables within the same separation group.
- 13. Verify the separation A3AR01_El Acceptable: I e criteria between the ATTACH B cable tray and adjacent raceways is per spec / drawing requirement.
o if the minimun ED-T-02 FSDR NO: O separation is not met, verify that fire /separdtion SECT 8.1 barrier request (FSBR) has been initiated.
- 14. Verify the separation X3AR01-E8 Acceptable; criteria between ATTACH D cabletray and l i
insulated pipes I and tanks or uninsulated pipes and tanks is per requitement.
- 15. Where circuits 33AR01-E8 Acceptable:
serving free E8.7.1.F standing equipment ment are involved, verify the tray is terminated a mini-minimum of 6 inches from the enclosures. i 0040V/5 Figure 6.2-2 Construction Checklist for Cable Tray (Sheet 4 of 9)
1 d l 1 i 1 1 l J 4 l CHECKLIST ITEM REF. DOC. ~~~ EESULTS/ REMARKS
- 16. Verify that the cable ED-T-02 Acceptable:
tray is free of sharp SECT 7.2 q edges and burra. X3AR01-E8 } SECT E8.7.1.E i } 17. If tray run is over 12 X3ARO1-E8 Acceptable: __ l
- feet long, verify that SECT E8.7.1.C j
- it is grounded at each ED-T-02 ;
J end. SECT 5.7.3 l X3AR01-E10 i SECT E10.5.D l l 18, if tray section and X3AR01-E8 Acceptable: ' riser is 12 feet and SECT E8.7.1.C ' loss, verify that the ED-T-02 ground is connected to SECT 5.7.3 a grounded parent tray X3AR01-E10 run, which may be any SECT E10.5.D ; tray of the same ser- I vice level as the riser in a bank of trays. If no parent tray run Acceptable: _ _ ___ exists, verify that the ground is con- , nected to the ground grid of structural steel member. l
- 19. At tray expansion X3PR01-E8 Acceptable: _ _ _ . _ _ _
joints or seismic SECT EB.7.1.C gaps verify that the ED-T-02 flexible copper cable SECT 5.7.3 jumper is used. X3AR01-E10 SECT E10.5.D
- 20. Verify the tray is X1AR01-E8 Acceptable:
securely fastened to SECT EB.7.1 0 support members by CX3DF003 bolted steel clip on DETAIL 10 each side of the tray (for horizontal run) or bottom head bolt thru the bottom (for vertical tray). 0040V/6 O saamer Figure 6.2-2 Construction Checklist for Cable Tray (Sheet 5 of 9)
4 4 a
- t. <
'A i
I d 4 l CHECKLIST ITEM HEF. DCC ._ BESULTS/BEHARKS l
- 21. Verify the cable tray GD-T-17 Acceptable:
4 it clean and free of SECT 5.2.2.1 l l /" trash / debris. Quality Concern l 84Vl99 l j 84B207 ) 84V229 l lj ! 4 22. Verify the cable ED-T-02 Acceptable: l tray's From-To loca- SECT 3.3 i i ! tions are as indi- ! cated by EE580. I 1 From/To: i j NOTE: Enter info from EE500 data, ] j 23. Verify that the cable X3AR01-E8 Acceptable:
- tray is not being used SECT E8.7.1.5 l as walkway or working j platform.
\ If used as temporary X3AROl-E8 Acceptable:
work platform, verify SECT E8.7.1.s i that it is within the j guidelines specified. ,
- 24. Verify that there is na JEEE 336 Acceptable: _ _ _ _ _
, visible damage to the SECT 3.4 cable tray. SECT 5.1.1
- 25. Verify that the bolts ED-T-02 Oty Available:
j attached to the SECT 4.1.3.1 Qty Available: g channel strut with Qty Acceptable: 1 i a spring / stud nut are i torqued per design
- requirements.
j Bolt Size i l Torque Valve NOTE: Enter design
! bolt size and torque valve.
a q 1 0040V/7 iO i i q Figure 6.2-2 Construction Checklist foi Cable Tray (Sheet 6 of 9) 1 1 = l
.,- -_ _ - - - . ._._.-__..,..._,..___.__-._._.._...__._._.-l
2 1 i l
\
) i ' i 1 a 1 i 4 i CHECKLIST ITEM REF. DOC. RESULTS/ REMARKS _ i . 1
- 26. Verify the installa- ED-T-02 ; Qty Available:
tion of the spring / SECT 4.2.4 Qty Checked: i stud nut is correct: SW-E-10 Oty Acceptable: 1 1.e.. the spring / stud 10 CFR.55e NOTE: if string / stud nut nut grooves are prop- Report No. grooves are not properly I erly engaged to the M-50 engaged. state the extent j in-turned edges of the of misalignment: I strut channel. If j stud nut is used. this ! may be checked by ver- ) ifying that the indi-l cator line on top of the stud nut is perpen- ! dicular to the face
- sides of the strut channel 1 4 I
- 1 9
1 a f i i l 1 i l 3 l i I. l i 1 l l l d 4 ? d a i 0040V/8 I i i
)
3 1 b l -{ Figure 6. 2- 2 Construction Checklist for cable Tray (Sheet 7 of 9) 1 i f
I CHECKLIST ITEM REF. DOC. RE F ULTS / it EMAR K E
- 1. Verify that the ED-T-02 l Acceptable:
control and tracking SECT 3.2 -
' l system raceway in- SECT 12.1 ,
sta11ation card ? (ED-T-02 Exhibit 1) l 1s on file.
- 2. Verify that the ED-T-02 Acceptable: _..
control and track- SECT 5.9.3 ing system raceway installation card ED-T-02 Exhibit 1) { is signed and accepted by elec- l trical QC inspector ! and reviewed by QC inspection supervisor. o " Verify the QC in ED-T-02 spector is cer- SECT 3.3 Date Certified: tified to the re-quired level. QC Inspector: _ Certification Level: _ Date Signed: NOTE: Enter into from EE580 raceway card. l l 0040V/9 Figure 6.2-2 Construction Checkli st_ for Cable Tray (Sheet 8 of 9)
i l t 1 1 4 ) d i l, I 4 9
- i l CHFCKLIST ITEM REF. DOC. RESULTS/ REMARKS i
l 3. Verify the torque ED-T-02 Acceptable: d wrench used for SECT 4.1.3 Date Cal.: ) bolting is Date Issue: 7 ' I i calibrated. Cal Due: ? Torque Wrench: Torque Value: d 7 l Inspection Date: NOTE: Enter info from
- calibration tool log.
j Torque value: ' I 2 Cal Due Date: 1 3 l ! ! 4 l l NOTE: Enter available I l info from EE580 i
- raceway card. !
i } i I i, . I I 4 5 ! 1 i i ! l 1 1 I i ! i i i' l' i l i i 0040V/10 1 1 4 3 I i t j i rigure 6.2-2 Construction Checklist fo: Cable Trai ( Slien t 9 of 9) j 1 _ . . . , . , . . , , _ _ . , .,,_,,..._,,.,,_..,.,,m,,.,, m,, ._-._r,,,.m,.._,,,,_,,.y.,m.,n.,.,,,.
Raceway Tag No: _ . . _ Separation Group: _ _ _ _ _ _ _ _ _ , _ _ _ _ _ Separation Color Code. _ _ _ _ _ . _ _ . _ Building Location: Room No.. _ _. _ _ _ _ Floor Elevation: _ _ _ Procedure / ! Specification Revieion/Date FM/DCN/FPCN I ED-T-02 _.,,,__ _ _____ _ X3AR01 ._ _ _ . _ _ _ _ _ _ _ _ _ _ . . GD-T-01 _ _ _ _ . . . _ . _ CD-T-07 _ _ _ _ . _ . _ _ . _ _ i Remarks: __ _ . _ . , _ _ _ _ . _ _ _ , _ _ . Team Members Performing Verification: Section Sicnature iptp 0041V/2
-% 1 Figure 6.2-3 Construction Check.!ist for conduit.
(Sheet 1 of 11)
i l l l l l I i j l CHECKLIST ITEM REF. DOC.
] 1 HESULTS/PEMARKE I
- 1. Verify the conduit X3AR01-E8 Acceptable: _
i is identified. SECT E 8. 7. 2.11 SECT E8.1.D ' ED-T-02 SECT 5.7.9
- 2. If the ID marker E8 RA_R._0_J _E Acceptaole:
is of the adhesive SECT E8.7.2.1 ' type, verify the lettering is black i , boldface, and 0.5 ! inch high minimum on a colored back-ground per the separation group l color code.
- 3. If the ID marker X3AR01-E8 Acceptable- ____ ,__.
is of the stencil SECT EB.7.2.1 t}pe, verify the l 1ettering is 0.5 ; inch high and l colored per the separation group . color code.
- 4. If conduit X3AR01-F.8 ! Acceptabis: ___ _,
run is in excess S ECT E 8 . '/ . 2 . H I . of 15 feet verify ! < that there are ID l l markers at 15 feet ! maximum intervals. , Installed Length: l i i
! l NOTE: Enter length !
from EE580 data. 3 i
- 5. For floor or wall X 3 AR01- E8 Acceptable: ' ~ ~ ~ ~ ~ ~ ~ ~
sleeve, verify that SECT E8.7.2.li there is an ID j marker applied at each end of the i sleeve. 1 I - l -_ l_._....__. ! 0041V/3 rigure 6.2-3 Construction Check 1ist for renduit (Sheet 2 of 11) l
J % . N U D's CHECKLIST ITEM EEP. DOC. RESULTS/ REMARKS ]
- 6. Verify the conduit X3AR01-E8 Acceptable: i is galvanized SECT E8.7.2.A rigid steel. CX3DF001 Conduit Note No. 5 7 Verify the conduit's ED-T-07 Acceptable:
size is per design. SECT 3.3 Size: i NOTE: Enter requitel size.
- 8. Verity the threads X3AR01-E8 Acceptable: __.
of the conduit ends SECT E8.7.2.B are coated with a non-insulating thread compound.
- 9. Verify that there is X3AR01-EB Acceptable; no welding done on SECT E8.7.2.B the conduit.
- 10. Verify the conduit ED-T-02 Acceptable: _.
has the correct SECT 3.3 From/To location. From/To: l
,i NOTE: Enter info l
from EE500 data. '
- 11. Verify the conduit .i X3AR01-E8 Acceptable:
is grounded per SECT E8.7.2,C ~ ~ ~ ~ ~ ~ ~ drawing require- ED-T-02 l ments. SECT 5.7.3 i
- 12. Verify that the X3ARO1-E8 Acceptable:
conduit is not SECT E8.7.2.M ~ supported from cable tray supports. l i l l. 0041V/4 Figure 6.2-3 Construction Check 12st for conduit (Sheet 3 of 11) t _. _ _ _ _
g CHECKLIST ITEM REF. DOC,_ RESULTS/ REMARKS
- 13. If conduit is X3ARO1-E8 Acceptable:
supported from SECT E8.7.2.M FCR/DCN: cable tray DWG: support, verify that there is an engineering design approval (FCR, DCN).
- 14. Verify that there X3AR01-EH Acceptablo: j are no conduit of SECT E8.7.2.H I different Class 1E separation ,
groups (A.B.C. & t D) supported from the same conduit support. j i
- 15. Verify that there 33AR01-E8 Acceptable: _
are no " TEE" type SECT E8.7.2.L condulets used.
- 16. Verify that there X3AR01-E8 Acceptable: __
are no "LB". "LL", SECT E8.7.2.L or "LR" type condulets used.
- 17. Where conduits K3ARO1-E8 Acceptable: __
penetrate fire SECT E8.6.2 rated walls, ED-T-02 verify that there SECT 5.7.6 is a condulet or SECT 7.2 small pull box installed (for sealing purposes) as close as practicable to the wall (one side only). i 0041V/5 E'igure 6. 2-3 Construction Checklist for Con <luit (Sheet 4 of )))
)
~~
CHECKLIST ITEM REF. DOC. EE.SlJLTS / It EMAR K S l
- 18. For conduit entering X3AR01-E8 Acceptable:
equipment enclosures SECT E8.7.2.D l from above, verify that it is so located that water will not drip into , the equipment. I or verify that the X3AR01-E8 Acceptable: conduit is sealed SECT E8.7.2.D at the higher con-duit end using an j approved sealing compound.
- 19. Conduit entering X3AR01-E8 Acceptable: __
boxes or enclosures SECT E8.7.2.D outdoors or in locations subject to wetting through j knockouts or : drilled holes in I I the top. Verify I it is terminated ! I with water sealing ' l fittings to i prevent the entrance i of water. l
- 20. Where conduits X3AROl-E8 Acce pt +.bl e ' !
l connect to other SECT Ea.7.2.D ' dissimilar metals. in wet or outdoor locations, verify that penetrox com-pound or equal is used on the meeting l surfaces. I
- 21. Verify there is a X3AR01-E8 Acceptable: _
minimum 1 inch ATTACH B horizontal. ver- i tical, or diagonal l separation between conduits of differ-ent separation l groups. l 0041V/6 l Figure 6. 2- 3 Construct. ion Check]iat Ior Conduit (Sheet 5 of )))
.r.
CHECKLIST ITEM REF. DOC. RESULTS/ REMARKS
- 22. Verify there is a X3AR01-EB Acceptable:
minimum horizontal ATTACil B zontal separation (3 feet in general i D plant area and 1 foot { in cable spreading rooms) between con- , duit of any safety- I related separation I group and cable trays of any other f separation group. o if the minimum ED-T-02 . FSUR NO: , separation re- SECT 8.1 1 1 quirement is not I met, verify that ' fire / separation barrier request (ySBR) has been initiated.
- 23. Verify there is a X3ARO1-E8 j Acceptable:
minimum vertical ATTACll B separation (5 feet ! in general plant { area and 3 feet in I i cable spreading ' i rooms) between , conduit of any ' safety-related ' separation group i ' and cable trays of I any other ! separation group. I i o if the minimum ED-T-02 FSUR N): separation re- SECT 8.1 quirement is not I met, verify that fire / separation i bat .er request I (FSbH) has been l initiated. ! l 1 i l
.--_a _ _ _ . _ .a 0041V/7
\ Figure 6. 2- 3 Construction Checkiist for Cr.nduit (Sheet 6 of 11)
1 ! f 4 i i I i i l l( i
- CHECKLIST ITEM REF. DOC. EESULTS/ REMARKS j 24. Where conduit X3AR01-E8 Acceptable
enter panels / ATTACH B i equipment having ED-T-02 l 2 or more safety SECT 5.1 ! 4 related separation ! I
- group, verify
, there is a minimum ,
'q of 6 inches separation betweer. 1 the conduits of different separation groups? o If the minimum ED-T-02 FSPR NO: separation re- SECT 8.1 4 quirement is not
' met, verify that !
i fire / separation i 1 barrier request i { [' (FSBR) has been { initiated.
- 25. Verify the minimum X3AR01-E8 Acceptable
a separation (4 inches ATTACH D j for 2 inch conduit and less and 8 inches ! for conduits larger ! , ihan 2 inches) i distance between j 2 power and control - service level ! I conduit and sample i i
- and instrument i !
lines is maintained. 2 l j 26. Verify the minimum X3AROl-E8 Acceptable: i separation distance ATTACH D between the power ! and control level i ] conduit and hot j
- pipe is maintained.
- 1
- 27. Verify the pull boxes X 3 AR 01- E 8 Acceptable:
4 indicated on the SECT E8.6.1.A 3 drawings are installed. 4
' - ~ ~ ~ ~ ~ - - ~ ~ ~ ~~
OO41V/8
- i Figure 6.2-3 Construction Checklist for Conduit (Sheet 7 of .i])
i
I Jf 1 i l l
- I
! l 1 f I j i 6ECKLIST ITEM EEP. DOC. j RESUL_IS/FEMAhEE i j 28. If the conduit exceeds X3AROl-E0 Acceptable; j j j the configurations in SECT E8.6.1.A Pull Box Size: _) l i 1 X3AR01-E9 Attach SECT E8.6.1.D In: Conduit Size: No.4 verify that CX3DFOO1 Out: Conduit Size: 1 the field add pull Conduit Note I boxes appropriately. No. 9 i ED-T-02 ! SECT 5.7.5 ! j 29. Verify that the field Lt3AR01-E8 Acceptable: __ added pull box is the ATTACH C correct size, i .e.. ED-T-02 ! l j does it meet the SECT 5.7.5 [ i minimum size re- I . quirement of the sizing criteria?
- 30. Verify the fittings CX3DP006 Acceptable: _ _ . ,
, (locknut, sealing DETAIL 5 qasket, bushing) for CAR l
. conduits at pull E-037 i boxes are f installed. ! 31. Verify that the DC-1810 Acceptable: __ l conduit is supported SECT 4C at the required intervals. l Mar allowable f unsupported i Length ' i NOTE: Enter design , requirement. j
- 32. Verify that there is IEEE 336 AcceptaMe
- ._.
4 no visible damage to SECT 3.4 l the conduit. SECT 5.1.1 1 i $ 1 i l 4 l
! l i '
i
! l
! 1
'~
0041V/9 i i e l ) i E'igure 6. 2-3 Construction Checklist'for conduit (Sheet 8 of 11)
, , - - - - - , , , - , - , , , - - - - - - - - - - - , . - ~ , - - . - .--.----,-e--,,, -- nnw-,
CHECKLIST ITEM REF. DOC. DESULTS/hEMARK_q
- 33. Verify that the bolts ED-T-02 Qty Available: __
attached to the SECT 4.1.3.1 Oty Checked: . _ . - channel strut w) Oty Acceptable: a spring / stud nut are torqued per design requirements. { Bolt size: Torque Value: NOTE: Enter design bolt size and torque value. l I
- 34. Verify the installation ED-T-02 pry Availdble:
of the spring / stud SECT 4.2,4 Qty Checked: nut is correct: 1.e.. SW-E-10 Oty Acceptable: > the spring / stud nut 10 CFR .55e NOTE: If spring / stud nut i grooves are properly REPORT NO M-50 grooves are not properly l engaged to the in- engaged. state the extend turned edges of the of misalignment. I l strut channel. l If stud nut is used, I this may be checked _ _ . _ _ _ , _ by verifying that _ _ _ _ the indicator line on top of the stud nut is perpendicular to the face sides of the strut channel.
- 35. If conduit is ED-T-02 Acceptable: _.
supported directly SECT 4.1.3.2 Torque Wrench No: I to the wall bith GD-T-27 Cal Due Date: 1 concrete expan- l sion anchor bolts, f verify that they [ are torqued per design require-ments. l Bolt size: 1 I Torque Value: NOTE: Enter design , bolt size and j torque value. I ! I I i
~1 1 0041V/10 .l_. + .-
Figure 6. 2- 3 Construction Checklist for Conduit (Sheet 9 of 11) 1
, _ . - , _ . . . . . . . . _ . . _ . , . _ _ - , . . . _ . , , m.- . .... _ .-.,,. -..--. ._m. _
1 i i l I a ! l 5 i ! i l J ' I a i i a CHECKLIST ITEM FEF. DOC. j RESULTS/BEMARKS ~I i 1
- 1. Verify that the con- ED-T-02 Acceptable: __
- trol and tracking SECT 3.2 system raceway in- SECT 12.1 sta11ation card (ED-T-02 Exhibit l
{ 1)on file. i
- 2. Verify that the con- ED-T-02 Acceptable:
trol tracking system SECT 5.9.3 ~~1 raceway installa- ! l l tion card (ED-T-02 {' Exhibit 1) is signed and ac-cepted by electrical QC inspector and , reviewed by QC inspection l 4 supervisor. l o Verify the QC ED-T-02 Ac c e p t.a b l e : I inspector is SECT 3.3 Date Certified; ~~ i ! certified to cartification Leveii 1 I the required level, j QC Inspector: Date Signed: NOTE: Enter info from EE580 raceway - card. 1 i I i e i 1 0041V/11 i Figure 6.2-3 Construction Checklist for conduit (Sheet 10 of 1]) i
i I 4 I ! l 1 i i l I s CHECKLIST ITEM REf. DOC. R ESULTS / PEMA.H_Kji
- 3. Verify the torque ED-T-02 Acceptable: _ __
wrench used for SECT 4.1.3 Date Calibrated: bolting is Date issued: calibrated. Cal Due Date: Torque Wrench: Torque Value: [ NOTE: Enter info from Inspection Date: calibration tool log. i Torque value: Cal Due Date- 1 I I I 1 NOTE: Enter - available info from EE580 l racaway card. ; I
- 4. Verify that the G_D-T-27 Acceptable: i i
concrete expansion EXHIBIT 2 j 1 anchor inspection report (GD-T-27 exhibit 2) is on file. NOTE: This applies it conduit is i supported directly l
' to the wall with concrete expansion l' anchors. See hardware checklist ,
item no. 35. ; i l 0041V/12 Figure 6. 2- 3 Construction Checklist for conduit (Sheet 11 of 11) _ . . _ . . , _ _ _ . _ . _ _ _ _ . _ _ , _ . . ,_..____.._.m._,_
O Raceway Tag No: Separation Group: Separation Color Code: Building Location: Room No.* Floor Elevation: Procedure / Specification Revision Date FCR/DCN/FPCN 1 ED-T-02 X3AR01 GD-T-01 l GD-T-07 _ Remarks: TEAM MEMBERS PERFORMING VERIFICATION: Section Sionature Date OO42V/2 Figure 6.2-4 Construction checklist for Wall-Mounted Equipment and Specia] Raceways (Sheet 1 of 6) e,w.w- , - w re ,y- -- ,,,m.,. .w. _ , . ... . ..--..wie.... ,,m,...e .. ..%~,.., .-- - - ., <w .-. men... . . . . . - -
i l l l CHECKLIST ITEM REP, DOC. FEGULTS/1WMARKS {
- 1. Verify the wall ED-T-02 Acceptable: ___
mounted equipment or SECT 5.7.9 i special raceway is identified. l
- 2. Verify the equip- ED-T-02 Acceptable: __
ment /special race- SECT 5.1 way location is j correct. ; 1
- 3. Verify the equip- Ep_yio? ! Acceptable: '
ment /special ' SECT 5.1 raceway orien- CX3DF003 I tation and DETAIL 13 l configuration is correct per I design drawing.
- 4. If equipment / GWS-SW special raceway Acceptable: _ _ _ _ ,
Torque Wrench No. is supported by the Cal Due Date: use of welded stud _ I bolts, verify that ; ' they are torqued I per design require-ments? l Welded Bolt Size i Torque Value NOTE: Enter design welded stud bolt size and torque. value. ' t i I i I s i 0044V/3 -~ -- Figare 6.2-4 Construction Checklist for WalJ-Mounted Equipment and Special Racewaye (Sheet 2 of 6)
CHECKLIST ITEM REF. DOC. RESULTS/faMAbKS ] A'
- 5. If equipment / ED-T-02 Acceptable:
special raceway is SECT 4.1.3.2 Torque Wtench No, supported directly GD-T-27 ' Cal Due Date: [ to the wall with con-crete expansion i anchor bolts, verify l that they are I torqued per design ' requirements. Bolt Size: l Torque Value: } NOTE: Enter design ; bolt size and torque l { value. ; I
- 6. If equipment / ED-T-02 Oty Available:
special raceway is SECT 4.2.4 Qty. Chk: ,_ supported on strut Oty. Acceptable: _ . _ , channel, verify that the installation NOTE: If spring / Stud nut of the spring stud , grooves are not properly nut is correct. i.e.. engaged. state the extent the spring / nut groovea of misalignment. are properly engaged to the in-turned edges i of the strut channel. , , _ _ l If stud nut is used, this may be checked 4 by verifying that the indicator line { on top of the stud nut is perpendicular l to the face sides of ! the strut channel. f i
- 7. If equipment / I ED-T-02 Acceptable-special raceway SECT 4.1.3.1 Torque Wrench NO.
is supported on Cal Due Date; l strut channel, verify ~~ } i that the bolts are . torqued per design ! requirements. ; Bolt Site: Torque Value: i NOTE: Enter design bolt size and i torque value. 0042V/4 l'igure 6,2- 4 Construction Check 1ist for '*;a J J -Po un t.ed Equipment and Frecial Raceways (Sheet 3 of b) _ _ _ _ _ _ _ _ _ _ _ ___. _ _ - _ _ ___ - - . - _ ~. . _ _ . . . . _ __ .__ . . , _ , _ .
i l I l i l i I l HECKLIST ITEM REF. DOC. RESULTS/FiEMARKS
- 8. Verify if there are GD-T-25 !
Acceptable: any FECO packages SECT 5.2 FECO No. applicable to the _ _ _ ,} equipment. , 1
- 9. Verify that the FECO GD-T-25 Ac c e p t.a t,l e :
packages have been SECT 5.11 i incorporated and ! completed. i
- 10. Verify the visible ED-T-02 Acceptable: __
internal wiring is SECT 5.1 per design drawing. , i
- 11. Verify the equipment ED-T-02 Acceptable: ___
is grounded per SECT 5.7.3 l design drawing. I
- 12. Verify that there is IEEE-336 Acceptable: _ l no visible damage to SECT 5.1.1 ,
the equipment. ! I y 13. Verify if there CD-T-01 Acceptable: are any hold tags SECT 6.4 Hold Tags: attached to the i
)
equipment. l l l i l l l l l i . I, l : 4 I I - oo42V/5 O Figure 6.2-4 Construction Checklist for Wall-. Mounted Equipment and Special F.aceways (bheet 4 of 6) 1
CHECKLIST ITEM REF. DOC. RESULTS/ REMARKS l
- 1. Verify that the con- ED-T-02 Acceptable:
trol and tracking SECT 3.2
]
system raceway in- SECT 12.1 i sta11ation card I (ED-T-02 Exhibit 2) is on file. ! {. l
- 2. Verify that the con- ED-T-02 Acceptabin:
g trol and tracking SECT 5.9.3 i system raceway in- , sta11ation card l (ED-T-02 Exhibit 2) , [ is signed and , i accepted by j l electrical QC ( inspector and reviewed by QC supervisor, o Verify the QC in- ED-T-02 Acceptable: spector is certi- SECT 3.3 fled to the re-Date certified. _j quired level. Certli'ication Level: j t QC Inspector: ! Date Signed: l l NOTE: Enter info from EE580 race-l way card.
- 3. Verify that all ED-T-02 Acceptable:
the inspection EXHIBIT 2 - i requirement items !
) i i l listed on the I i raceway in- )
sta11ation l card (ED-T-02 ! l Exhibit 2) were j inspected and i accepted. I i l 0042V/6 l i l Figure 6.2-4 Construction Checklist for Wali-Mounted ) 1 Equipment and Special Raceways (Sheet 5 of 6)
f l [ CHECKLIST ITEM EEF_ DOL l RESULTS / F t: MAR KG li
- 4. Verify the torque ED-T-07 l Acceptable: __
Wrench used for SECT 4.1.3 Date Calibrated
=- bolting is f' Date issued: ,
calibrated. Cal Due Date: ! Torque Wrench: l 1 Torque Value: __ l NOTE: Enter int o frcm ' Inspection Date: I aalibraticn tool log. l Torque Value: Cal Due Date: NOTE: Enter available into I from EE500 raceway card. i 1
- 5. Verify that the GD-T-27 Acceptable.
concrete expan- Exhibit 2 sion anchor inspection report , (GD-T-27 Exhibit ! 1
- 2) is on file. i i
NOTE: This applies if equipment / I I special raceway is supported directly l to the wall with {' concrete expansion anchors. See hardware checklist item no. 5. I 1 0042V/7 a
- Figure 6.2-4 Construction Checklist for Wall-n unted Equipment and Special Raceways (Slieet 6 et 61
-- . _= ..
Responsible Oroanization: Project Engino.+ ring. Completion Date: January 31, 1986. o Finding 17-20 e- Action: (1) Revise DC.1001, DC 1010, and DL: 1810 L. o provide proper references. (2) Issue PSAR change notico j to add raceway to project classification list. Responsible Organization: Project Engineering. Completion Date: For (1), January 31, 1986: for (2), l O- February 15, 1986. o Finding 17-21 Action: Complete Corrective Action Request No. E-0003. Responsible Oroanization: Project Construction. Completion Data: January 31, 1986. 7.1.2 SECTION b.2 CONSTRUCTION o Finding 17-5 t Action: Issue matrix to identify primary and secondsty - inspection requirements. documents and to clarity storaqc/ filing Responsible Organization: Project Cons t t uc t ion. Completion Date: January 31, 1986. O O . 4 O 0104q/030-6 7 ,1- 3
e l 7.0 PROGRAM ASSESSMENT / CONCLUSIONS l 7.1
SUMMARY
OF OPEN CORRECTIVE ACTIONS l l I~) km/ 7.1.1 SECTION 6.1 ENGINEERING l o FINDING 17-7 Action: Revise Design Criteria (DC) 1810, Construction 1
)
Specification X3AR01, section E8, and raceway drawing '
"T Nos. 1X3DF507 and 1X3DF51C to eliminato deviation from
[V 2-ft Nuclear Instrumentation System (NIS) ceparation recommendation. i
)
Responsible Orcanization: Project Engineering. Completion Date: February 28, 1986. o Finding 17-8 Action: Perform and document interdiscipline (electrical) review of DC 2166. Responsible Orcanization: Project Engineering. Completion Date: February 15, 1986. o Finding 17-10 Action: (1) Revise calculations X3CV01, X3CK14, and ; X3CK15. (2) Revise Project Reference Manual (PHM) to j ensure adequate quality control of interdiscipline calculations. Responsible Orcanization: Project Engineering, i Completion Date: For (1), January 31, 1986; for (2), February 28, 1986. , Responsible Orcanization: Project Engineering, o Finding 17-15 Action: (1) Revise general notes and details drawing f]/ L No. CX3DF002 to encompass some raceway numbers not addressed by the present numbering system. (2) Revice physical design checklist to ensure the identification numbers assigned to raceways conform to drawing No. CX3DF002. (3) Instruct desi.gn personnel to follow / modify the numbering system.
Rasponsible Organization: Project Engineering. Comp _1.etion Date: January 31, 1986. o Finding 17-16 Action: (1) Revise the PRM, part C, section 36, to include basic requirements for design, review, checking, and verification associated with the EE580 program, with emphasis on independent checking. (2) Review EE580 library for raceway size compatibility and revise as needed. Resolve any resultant overfill conditions. (3) lasue deck instruction to complement PRM requirements above. (4) Conduct documented training sessions for electrical engineers on requirements of the revised PRM and new desk instruction. (5) Review and check the existing EE500 library criteria input. Responsible Organization: Project Engineering. Completion Date: For (1), (3), and (5), March 15 L986; for (2) and (4), March 30, 1986. o Finding 17-17 Action: (1) Revise affected engineering documents to ensure consistency between the as-built condition, EE580, and other design documents for the punched / solid bottom trays. (2) Write GPC requesting that they r e- emph6 ize the necessity to check the tray installation against all the requirements of the engineering drawings. (3) Train engineers to ensure that documents are modified consistently. Responsible Org_anization: Project Engineering. Comp.letion Date: For (1), February 28, 1986; for (2), January 15, 1986; for (3), March 15, 1986, o Finding 17- 18 Action: (1) Revise calculation X3CLO2 to incorporate reference for the source of design input and to address worst-case cables and medium-voltage grounding cables. (2) Issue design documents listing trays which could be 1 overloaded by the addition of tray covers. (3) Issue ; desk instruction X3DIl0. (4) Conduct documented t r a i n i. n g sessions with electrical engineers. l l l { 7.1-2 l l t 1
7.2 OA STATEMENT The process for the development of this module was monitore<l by the Readiness Review Quality Assurance (QA) staff for general adequacy. The primary focus of the monitoring effort was the identification, N documentation, analysis, and resolution of Readiness Review I I Findings. The finding reports issued by the Readiness Review Team and their responses were reviewed, individually and collectively, for root causes and generic issues; i.e., trends. Based upon review of the responses and commitments to individual finding reports and generic concerns, the resolutions were determined to j
'O be adequate. All findings were initially distributed to project QA for review for reportability [10 CFR 21, 10 CPR 50.55(e)] in accordance with existing QA procedures. In addition, findings were screened by Readiness Review to determine whether any required additional evaluation by the project fot reportability.
Five were so identified, but subsequently, only one was determined j to be reportable by the Project. Other monitoring activities consisted of Leviewing personnel qualification and training records for the team members, reviewing the verification plan, and reviewing completed checklists to assure adequate identification of findings. Ad d i t. io na ll y , an g independent reverification was performed on a sampling basis under (' Readiness Review QA overview to determine the adequacy of the ! Commitment / Implementation matrixes and the Design / Construction verification efforts. ( l Based upon these monitoring efforts, this module and the Headiness Review Team conclusions are judged to be acceptable. 1 O
;x
- 3. Tay)or "
LW fohn 11. Draggs Headiness Review Team " Readiness Review Team Quality Assurance Representative Quality Assurance Reptesentative 0103 q / 021- 6
4 7.3 TECHNICAL CONSULTANTS CERTIFICATION On the basis of the review of this Module 17 Haceways, and appropriate project documents such as construction < specifications, engineering reports, design criteria, and selected drawings, I certify that to the best of my belief and
- (O knowledge, the information and conclusions contained herein are A factually and technically correct. Under the program described in'Section 4 of this report and on the basis of corrective action described in sections 6 and 7, the commitments of the Vogtle Electric Generating Plant Final Safety Analysis Report are being implemented.' The analysis, design and construction
,O) programs that relate to electrical taceway systems have produced Nd a final product that meets design requirements and licensing commitments.
gd / /dfdlM) _ Edward F. IIe ne be r ry , RFE.
- O P
O O O
4 Raceways - Module 17 Readiness Review Board Acceptance O The Readiness Review Board has been apprised of the neope and content of Module 17 Raceways. The Board has reviewed the program verification, as well as corrective actions, both proposed and implemented, by the Vogtle Project. Based upon this review and based upon the collective h experience and professional judgement of the members, the s Readiness Review Board is of the opinion that the corrective actions proposed are acceptable, and that the raceway system at Plant Vogtle is sound and complies with commitments set forth in the FSAR and acceptable practices. I bm ( APPHOVMD: _ IMTV __ _ Doug Dutton j Chairman, Readiness Review Board Vogtle Electric Generating Plaat
. n%)
F'T
\)
f L' 009 3 q / 315- 6
Georgia Power Company Project Management Post Off ce Box 282 Waynesboro, Georgia 30830 Telephone 404 7244114 404 Ss4 9961 l Southern Company Services. Inc Post Office Box 2625 b l %"%nns%*c" ,52 2 Vogtle Project lO l Date: January 30, 1986 l Q Re: Plant Vogtle - Units 1 & 2 b Readiness Review Module 17 File: X7BD102 From: 0. Batum l To: W. C. Ramsey Engineering has reviewed Module 17, Raceways, for general accu rac y and completeness. To the best of our knowledge and belief, the module is a complete and accurate representation of the Raceways, and the engineering process and commitments related thereto, s , [ [L . . _ , OzpfBatum p Deputy to Vice President ( Project Engineering xc: Project File O O
i Interoffice Correspondence ( avigiit !'ower m\ l f i January 22,1986 i MEMO TO: W. C. Hamsey FROM: M. H. Googe 1 RE: Plant Vogtle - Units 1 & 2 Readiness Review Module 17 ILE NO: X7BD102 CORRESPONDENCE NO: MQC-875 l SECURITY CODE: NC l l l ' Nuclear Construction has reviewed Module 17. To the best of our imowledge and belief, j the Module is a complete and accurate representation of the site Electrical Raceway installation 5 program and commitments related thereto. i f i
/
'(, ')f T, k. -
Af. fl. Googe
- Project Construction Afanager ;
GA R/MHGimg O O O l l l
7.6 RESUMES C)s The following resumes, arranged in alphabetical order, present a brief professional history of those people instrumental to the development of Module 17. ISMAEIL ALVAREZ, Electrical Designer. IMaign Team Member Mr. Alvarez has over eight years in the electrical raceway decign for nuclear power plants with Bechtel Power Corporation. He is presently assigned to the San Onofre Nuclear Generating, Station where he was previously deputy to the physical group ( s) leader. His responsibilities have included conduit layout, lighting and grounding design, and routing of cables for various design change packages. He is also responsible for resolution of field questions and inputs to the circuit and raceway program, j l
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j Education: Institute Superior Comercio B.S., Cost Accounting l i
/~N GILUERT S. CARMONA, Electrical Engineer, Design Team Member b Mr. Carmona has over 14 years of nuclear powet plant experience
- with Bechtel Power Corporation. His most recent assignment, at the San Onofre Nuclear Generating Station, was the deputy group supervisor responsible for planning and scheduling of task completions to support plant modifications during refueling outages. Other responsibilities have included review of logic diagrams, schematics, bid evaluations, vendor documents, and all electrical licensing activities for nuclear power plants in Korea and Spain.
Education:
- /s Ecole Polytechnique Superieur
(_ ) B.S., Electrical Engineering Illinois Institute of Technology M.S., Electrical Engineering () P.E., P.E., State of California State of Illinois BERNICE L. DOHERTY, Senior Quality Engineer, Desion Team Member () Ms. Doherty has been associated with the nuclear power industry for 13 years, 12 of them in Quality Assurance (QA) and Quality Engineericg (QE). Her most recent assignment was to
develop, implement, and coordinate the QA and QE programs on the San Onofre Nuclear Generating Station (SONGS) 1 retrofit project to satisfy the requirements of 10 CFR 50, Appendix B, and ANSI N45.2. Education: Univerisity of North Carolina at Charlotte Nuclear Phycies DAVID L. E D E N I' l E L D , Engineering Supervisor, Construction Team Leader 4 Mt. Edenfield has been employed by Georgia Power Company at the Vogtle site for over seven years. His responsibilities have included electrical design, construction, and maintenance of site construction support facilities, construction interface activities between craft and design for raceway and raceway supports, and supervision of construction interface activities for cable pulling and termination. His most recent assignment was supervision of electrical construction interface for Balance of Plant (BOP) areas. Education: Georgia Institute of Technology I nachelor of Electrical Engineering DtN I D K . FERRIER, Engineering Supervisor, Design Team Leader Mr. Ferrier has been employed with Bechtel Power Corporation for 19 years and has 14 years of experience in the nuclear power j industry. He has been the electrical group supervisor for the ' ASCO and Sayago Nuclear Power projects in Spain and Consumer's I' Power Company's Palisades Modifications and Quanicassee projects. He was also deputy group supervisor on the Korea 5/6 and 7/8 ptojects and has worked on other nuclear power plants throughout the United States. Education: Drexel Institute of Technology H.S., Electrical Engineering P.E., State of California j O
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MICHAEL E. GRIFFITH, Senior Electrical Engineer, Design Team O Member Mr, Griffith has over 13 years of experience with Souther n Company Services in the field of nuclear and fossil power generating plant design. His nuclear experience includes /~T electrical engineering for Alabama Power Company's Plant Farley (_) and Georgia Power Company's Plant Vogtle. He also participated in institute of Nuclear Power Opertions (INPO)- Pilot and INPO Self-Initited Quality Evaluations for Plant Vogtle. Education: Auburn University U.S., Electrical Engineering P.E., State of Alabama EDWARD F. HENEBERRY, Senior Electrical Engineet Technical Consultant Mr. Heneberry is a senior electrical engineer in the Electrical Division of Stone and Webster Engineering Corporation, ile has over 16 years of engineering experience which consists of assignments in the engineering and deciqn of electrical systems O for pressurized water reactor nuclea its, integrated gasification combine-cycle plants, and various process plants. He was formally the lead electrical engineer on the North Anna Nuclear Power Plant, Units 1 and 2, and is currently the lead electrical engineer for the Diablo Canyon Nuclear Power Plant study. Education: Northeastern University B.S., Electrical Engineering P.E., State of Massachusetts P.E., State of Virginia . ( 1 l MANUAL HUGHES MAGBOO, JR., Supervising Conuttuction Engineer. l Construction Team Member Mr. Magboo has over 19 years of progressive experience in
,f various areas of construction / field engineering supervisory work. He is experienced in heavy construction, including nuclear power plants; support facilities in refinery and chemical plants; pipeline work, both cross-country and submarine; and terminal near-shore construction.
Responsibilities have ranged from material control-warehouse (-)g (_ manager to project engineer, project manager and project construction coordinator. l l
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Education: lleald Engineering College li. S . , Civil Engineering JAMES M. RICll ARDS , Electrical Physical Designer. Design Team Member Mr. Richards has been employed with Bechtel Power Corporation h for more than 21 years. For the past 15 years, he has been the physical group leader on the Ormond Beach Generating Station: Kuosheng, Unita 1 and 2, Nuclear Plant (Taiwan); and Vogtle, Units 1 and 2, Nuclear power Plant. His responsibilities as group leader included supervision of raceway design, underground system, grounding, lighting, communications, scheduling, and manpower assignments. Education: Pennuylvania State College JAMES B. STEELE, Senior Electrical Quality Control Engineer, Consttuction Team Member Mr. Steele has five years of nuclear experience as an electrical inspector and quality control (QC) engineer at several nuclear construction projects. His responsibilities have included QC dCtiVities, as Well as Quality Assur3nce (QA) surveillance of contractors' QA programs and supervision of QC departments. His most recent assignment was supervisor of the Electrical QC Department at Diablo Canyon. Education: Western Illinois University MICilAEL G. U PCIIUHCll, Project Section Supervisor, Construction Team Leader Mr. Upchurch has over 10 years experience in the nuclear lhl industry as an inspector, inspection supervisor Quality Control ! j (QC) supervisor, and OC section supervisor in the mechanical and electrical disciplines of Georgia Power Construction. He also ! has served as an auditor in the Quality Assurance Department. His responsibilities have included ASME piping inspection, HVAC l inspection, tool calibration control, Nondestructive Engineering (NDE) inspection, and inspector training / qualification. His lhl ' most recent assignment was as electrical QC section supervisor, l'1 ant Vogtle. O i */.6-4 l l l
1 . l A s J E,ducation: l DeKalb Area Technical School Mechanical Technology
- Dekalb Community College A.S., Mechanical Engineering Technology 1
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