ML20133M807
| ML20133M807 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/08/1985 |
| From: | Barnes I, Ellershaw L, Hale C, Andrea Johnson, Will Smith, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133M720 | List: |
| References | |
| 50-445-85-11-02, 50-445-85-11-2, 50-446-85-06, 50-446-85-6, NUDOCS 8510280254 | |
| Download: ML20133M807 (26) | |
See also: IR 05000445/1985011
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APPENDIX E
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j U. S. NUCLEAR REGULATORY COMMISSION
i REGION IV
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NRC Inspection Report: 50-445/85-11 Construction Permit: CPPR-126
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50-446/85-06 CPPR-127
- Dockets
- 50-445
50-446
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- Applicant
- Texas utilities Electric Company (TUEC)
- Skyway Tower
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400 North Olive Street !
j Lock Box 81 I
Dallas, Texas 75201 ,
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l Facility Name: Comanche Peak Steam Electric Station (CPSES), Units 1 and 2
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Inspection At: Glen Rose, Texas *
InspectionCondu7ted: August 1-31, 1985
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Inspectors: \ b/ b /13 ; /d 'N l
! E. E. Ellershaw, Reactor Inspector, Region IV Date !
- CPSES Group
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- (pars. 1, 5d, Sf, Sg 51, Sj, Sk, 51, and Sn)
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C. J. Hale, Reactor Inspector, Region IV CP$lS
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! Date e
'. Grcup !
(pers. 1, 2, 3, 4, and Sm)
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hd 0i] 11sp> t_ Q
k. Johns n, Reactor Inspector, Region IV CPSES
\ b ~ W 95
Date :
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W. F. Smith, Resident Reactor Inspector (RRI), ;
I Region IV CPSES Group
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Consultants: EG&G - R. Bonnenberg, L. Jones, A. Maughan, W. Richins
Parameter - D. Brown, J. Gibson, D. Jew, T. Young (
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Reviewed By: ,v du, r M - J ' - M s' '
j I. Barnes, Group Leader, Region IV CPSES Group Date j
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Approved: - ( N /6//[7 5 !
( T. F. Westerman, Chief, Region IV CPSES Group Date
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Inspection Summary
Inspection Conducted August 1-31, 1985 (Report 50-445/85-11; 50-446/85-06)
Areas Inspected: Nonroutine, unannounced fr,spection of the Comanche Peak ;
j Response Team (CPRT) procedures and instrNtions, evaluation of Evaluation i
- Research Corporation (ERC) inspector cert ,t(cation, and CPRT issue-specific
i action plans (ISAP). The inspection involved 1,585 inspector-hours onsite by
} five NRC inspectors and eight consultants.
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l Results: Within the three areas inspected, one violation (failure to report !
l nonconforming conditions, paragraph 5.e) and two deviations (non identification !
to NRC of the use and justification for a CPRT employee with some prior CPSES '
involvement in area of current review activity, paragraph Sm failure to denote i
areas of revision in procedures, paragraph 3) were identified. l
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! DETAILS
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1. Persons Contacted
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l J. Arros, TERA Civil / Structural Issue Coordinator l
W. Bailey, ERC Supervisor, QA/QC Reinspection Engineering l
C. I. Browne, Project Manager, RL Cloud & Associates, Inc. l
- R. E. Camp, Assistant Project General Manager, Unit 1 (Impell Corp.)
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J *J. D. Christensen, Deputy QA/QC Review Team Leader ERC {
, E. Farino, ERC Electrical Discipline Engineer !
l J. Finneran, TUGC0 Lead Pipe Support Engineer [
j *S. M. Franks, TUGC0 startup Engineer :
- J. L. Hansel, ERC QA/QC Review Team Leader '
j J. R. Honekamp, TRT Issues Manager, TERA i
j *C, R. Hooton, Project Civil Engineer '
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i P J. Hudson, certification Administrator
N. B. Jones, CPRT Electrical Review Team Leader
- R. A. Jones, TUGC0 Manager, Plant Operations t
3 M. Keathley, ERC. Level Ill Electrical Inspector !
l J. Keller, CPPE Engineer
j *J. C. Kuykendall, TUGC0 Manager, Nuclear Operations
! H. A. Levin, CPRT Civil / Structural / Mechanical Team Review Leader 1
l *0. M. McAfee TUGC0 Manager, QA
! *S. Helancon, CPRT Issue Coordinator j
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} *C. K. Hoebiman, TUGC0 Project Mechanical Engineer '
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M. Obert, TRT Issue Coordinator
i A. Patterson, ERC Engineering Supervisor ,
H. Porter, Brown & Root Welding Engineer l
J. Saltare111, TUGC0 Field Mechanical Engineer l
B. Shair, ERC Lead Electrical Engineer ;
R. Shipp, ERC Issue Coordinator !
l D. W. Snow, Brown & Root QA/QC Coordinator
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C. Spinks, ERC Inspection Supervisor !
j P. Streeter, TERA Sr. Mechanical Engineer i
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W. Stroupe CPRT Electrical Team Consultant
- K. Thompson, ERC Records Management & Documentation
- T. G. Tyler, CPRT Program Ofrector (Energex) {
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- W. I. Vogelsang - TUGC0 Electrical Coordinator
I *A. H. Welch, TUGC0 QC Supervisor .
D. West, TUGC0 Damage Study Supervisor !
- M. J. Wise, CPRT Testing Review Team Leader
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T. Wright, TUGC0 Civil Engineer l
J. E. Young ERC Supervisor, Training Certification l
J. Ziemlan, ERC Level III Mechanical Inspector I
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j * Denotes those persons who attended the exit interview. !
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2. CPRT Program
l The NRC Region IV inspection of the CPRT program activities during this
- report period was based on the CPRT Program Plan, Revision 2. Overall
8 coments on this plan were forwarded to the applicant by NRC letter of
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August 9, 1985. NRC staff comments on the plan details are in preparation. i
j The applicant informed the NRC Region IV staff that an umbrella QA program :
j addressing overall CPRT activities is currently in preparation. l
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l 3. Comanche Peak Response Team Procedures and Instructions
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The CPRT
Team (SRT). consists
The groupsof four
andbasic groups
their scope reporting)to
are: the Senior
(1 ERC - Q.VQC Peview
program
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) adequacy and quality of construction; (2) TERA Corporation - civil, ;
j structural, mechanical issue specific items and design adequacy '
evaluation; (3) electrical issues being evaluated by one principal :
individual; and (4) testing issues being evaluated by one principal '
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individual.
The SRT has issued policies and guidelines to which the Review Team
Leaders (RTLs) in each of the four groups are required to comply while
implementing the CPRT Program Plan. This requires the development of
r procedures and instructions when necessary. The following is a
j description and NRC evaluation of the procedures that have been developed :
{ and the status of the implementation of the CPRT policies and guidelines. [
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A. ERC Procedures and Instructions
ERC has developed the following four manuals for controlling their
effort:
1. ERC Quality Assurance Management Program Plan (MPP) - This l
i manual describes the principal positions and the specific l
- responsibilities, the functional organization, and the various [
] interfaces. -
2. ERC Quality Assurance Procedures (QAPs) - This manual, which is ;
the second part of the MPP, includes those portions of the ERC
Corporate Quality Manual that apply to the CPRT activities.
l 3. ERC Comanche Peak Procedures (CPPs) - This tranual, presently
< consisting of 20 procedures, provides the guidance / direction of .
j essentially all ERC activities, except the inspection function. '
- 4 ERC Quality Instructions (Qls) - This manual, consisting of 56
i identified procedures at this writing, provides the direction ;
for the ERC reinspection ef fort with respect to quality of ,
construction. These procedures define the inspection attributes j
in the specific area of inspection or documentation review, i
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l A commitment position with respect to the requirements of
j 10 CFR Part 50, Appendix B, is, to date, only identified in the ;
] applicant's letter of August 16, 1985, to the NRC concerning overview '
j of the CPRT program. The ERC manuals were reviewed, however,ffor !
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l compliance with the relevant criteria of 10 CFR Part 50, Appendix B,
i and, as applicable, ANSI N45.2.6; and Regulatory Guide 1.58.
The ERC MPP was reviewed to determine if it appropriately
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implemented the commitments of Appendix B of the CPRT Program !
Plan. No discrepancies were noted. This same process was l
l repeated assuring that the ERC QAPs properly implemented the i
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MPP, that the CPPs implemented the QAPs, and that the CPPs i
provided the necessary guidance for the development of the Qls. ;
- The following is the results of these reviews. i
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! As of this writing 56 Qls have been identified,19 have been j
- issued, and several (mostly electrical) are being implemented.
- The ERC inspectors (electrical discipline) have encountered .
j numerous difficulties with the implementation of Ols. The NRC (
- believes these difficulties are due, in part, to a lack of QI r
j clarity with respect to inspection requirements. Examples noted ,
, in NRC review were: (1) Ql-008 - unclear recuirements with (
) respect to channel separation, fire stops anc seals, and certain
l attachment criteria; and (2) Q1-014 - unclear instructions with ;
j respect to inspection of cables not accessible for their full ;
j length. This matter is considered unresolved and will be
f evaluated further during the next reporting period
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(445/8511-U-01).
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One deviation from comitment us identified in this area of
l Inspection. CPP-001 states that revisions to CPPs will be
i indicated by a bar in the right hand margin. Of six revised
l CPPs reviewed, three did not have all revisions indicated and
i one had none of the revisions indicated as required l
! (445/8511-0-01).
B. TERA Procedures and Instructions !
f The principal onsite activities being conducted by TERA are ISAPs in !
j the civil, structural, and mechanical disciplines. At present these
i dCtivities are being controlled by preliminary work instructions t
j prepared by the assigned issues manager. This manager anticipates that l
- the Design Adequacy Procedures (DAPs), scheduled for issuance by ,
4 September 20, 1985, will provide the formalized procedural control for [
l the activities currently covered by the preliminary work instructions. l
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Utilization of DAPs and impact on work performed prior to their issue
areconsideredanopenitem(445/8511-0-37).
The balance of TERA's responsibilities, design adequacy evaluations,
I are being performed offsite in Bethesda, Maryland and Berkley,
California. The inspection (.f these design adequacy evaluations is ;
being performed by the NRC Office of Inspection and Enforcement, i
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l 4. Evaluation of ERC Inspector Certificatica
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Organizationally all CPRT inspectors are located in the QA/QC Review Team ;
' i.e., ERC. There is a single supervisor over the total inspection force
I' and lead inspectors over each inspection discipline; e.g., electrical, !
mechanical, etc. j
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CPRT Procedure CPP-003, " Indoctrination, Training, and Certification of
Personnel," has been established for control of the indicated activities.
All inspection supervisors, leads, and personnel have been or are being
certified as Level II or III in compliance with Regulatory Guide 1.58,
i Revision 1, which endorses ANSI N45.2.6-1978.
Before any onsite duties are assumed, each inspector is certified in I
i accordance with CPP-003. This certification process includes: ;
! (1) verification of previous employment; (2) reconciliation of any !
i previous employment conflicts and education; (3) review of previous
I certifications; (4) indoctrination in the CPRT scope of ef fort;
I (5) training and examination, where applicable, in the areas of general QA
! and specific discipline requirements; (6) review of all inspector records ,
j by the certifying agent (usually the lead discipline inspector), then a :
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i recommendation regarding certification; and (7) review and approval of all
i certifications by the RTL. .
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] Every 2 weeks, a list of all certified inspectors onsite is distributed to ,
j various individuals of the CPRT. This list identifies the inspector's ;
- certification level, discipline, and any exceptions or limitations to
i their certifications.
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j A permanent file is maintained for each inspector. These files contain a f
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resume, eye exams, CPRT certifications including any limitations or [
l exceptions, CPRT indoctrination and training records, employment and i
( education verifications, and records of prior training and certifications.
The files of all 51 inspectors onsite as of August 13, 1985, were
reviewed. Each file was reviewed for the following: (1) potential ,
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conflicts from previous employment; (2) the validity of the eye exams; f
1 (3) the current CPRT certification level for compliance with ANSI N45.2.6; '
j (4) CPRT indoctrination, discipline specific training and testing, and
j records of required reading accomplished; and (5) the appropriateness of
- the individual recommending and approving the inspector's level of i
j certification.
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Of the 51 files reviewed, 6 inspectors' files were not complete enough for
I certification nor were they listed on the bi-weekly list of certified
i inspectors. Of the remaining 45 files, no departures from ANS! N45.2.6 or
CPP-003 were found and each inspector was identified on the bi-weekly list
with the proper certification, discipline, and level, j
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While reviewing these certification files, three inspectors were
identified that had previously worked for Brown and Root (B&R) at the ;
South Texas Project. Based on the NRC review of their files, there is no
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apparent loss of objectivity or conflict with their previous employment
and their current areas of assignment. The ERC certifying agent stated
that this prior employment was considered during certification review, but
this effort was not documented nor was there a requirement that it be. No :
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further NRC action is planned concerning this matter; however, NRC staf f 's
will continue to be alert to such potential conflicts.
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5. CPRT ISAPs .
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Heat Shrinkable Cable Insulation Sleeves (ISAP No. I.a.1)
Status of CPRT Activity
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TUGC0 construction procedures and TUGC0 quality inspection ;
procedures, with associated inspection forms have been reissued to
ensure that applications involving heat shrinkable cable insulation
(H5CI) sleeves are properly documented during QC inspections, p
TUGC0 is currently training craf t and QC inspectors to the reissued
construction and inspection procedures, including certification of -
their QC inspectors.
The CPRT-Electrical have identified a total population of 1359 HSCI
sleeves on: (1) electrical penetration assembly (EPA) pigtails; '
(2) cable reductions to 6.9 kV and 480V AC motors and heaters;
(3) solenoid (125 VAC) valves; and (4) bolted type cable reductions
at 125V distribution panels. Sixty safety-related samples of HSCI
sleeve installation inspection reports (irs) have been reviewed by the
CPRT-Electrical. The sample size was increased by 35 more irs due to
a potentially defective sample which was later identified as not
defective. One defective sample out of a total sample of 95 was
identified. No further sampling was required per the program action s
plan Appendix 0. ,
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All cable locations where reduction splices could possibly be used .'
were visually inspected by ERC to confirm that no other cable , i
reduction splices, other than those identified above, were used at
terminations. No other reduction splices were identified.
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A nonconformance report (NCR) has been issued to disposition the
above defective sample.
An evaluation by the CPRT-Electrical to: (1) provide reasonable '
assurance that sleeves are installed where required; and (2) to
establish root causes of the one defective sample out of 95, is
currently in process and will be reported in the CPRT-Electrical
final results report for ISAP No. I . a.1.
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Status of NRC Inspection Activity
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The NRC inspector has reviewed the CPRT Action Plan I.a.1,
Revision 3, and the implementing CPRT quality instruction (QI-003,
', ! / Revision 0).
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Craft construction procedure EEI-8, Revision 5. " Class IE and
'/ o non-Ciass IE Cable Terminations," is currently being reviewed to
verify that installation requirements for HSCI sleeves have been
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ndequately addressed. TUGC0 quality inspection procedure
QI-QP-ll.3-28, Revisions 24 and 25, " Class IE Cable Terminations," is
. also being reviewed to verify where HSCI sleeves are required.
Inspection forms (attachments to QI-QP-11.3-28) which have been
revised are also being reviewed t'y the NRC.
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No NRC violations or deviations were identified,
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b. b reement Between Drawings and Field Terminations (ISAP No. I.a.4)
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Status of CPRT Activity
The sampling inspection plan, calling for reinspection of cable
terminations in the Unit I control room and cable spreading room for
the essential Class 1E circuits which interface with the alternate
shutdown panel, has been completed. The total population of 3812
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" safe shutdown" terminations was identified by TUGC0 Engineering in
October 1984. TUGC0 Engineering prepared 335 cable verification
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packages to which ERC performed a reinspection to verify that the
physical terminations were in agreement with as-built drawings, as
modified by applicable design changes.
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, All terminations met the acceptance criteria outilned in the ISAP.
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One drawing error was identified and corrected involving cable
identification. A cable tag was also noted to be marked in error and
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corrected. No deviations were identified.
'CPRT-Electrical is currently in the process of verifying the 883 cable
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conductor configurations against the cable conductor sampling IIst.
s Stone & Webster is currently assisting CPRT-Electrical in checking the
, c.@!e conductor sampilng list against as-built drawings.
Status of NRC Inspection Activity
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Inspection of this activity included review of CPRf Action Plan I.a.4,
Revision 3, and the conformance of impicmenting CPRT quality
instruction, QI-001, Revision 3, to the action plan,
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c. NCRs on Vendor Installed AMP Terminal Lugs (ISAP No. I.a.5)
Status of CPRT Activity
The CPRT-Electrical has received and is reviewing the AMP Incorporated
Engineering Evaluation Report No. EER-136 results for acceptability. The
accepted results will be addressed in the CPRT-Electrical Results
Report now in draft form. The CPRT-Electrical has addressed whether
i the observed condition at the ring terminal tongue is a bend or a
twist. The CPRT-Electrical concluded, after physical inspection, that
the identified twist is actually an oblique bend, but to avoid
misunderstanding the use of the word " twist" will remain to depict
the condition observed.
The NCRs went through two separate redispositionings by TUGC0. The
first provided a clarification of the physical condition of the
terminal lugs and the basis for using the terminal lugs "As Is". The
second redisposition addressed the use of twisted terminal lugs as
based on the results of the AMP Incorporated Engineering Evaluation
Report No. EER-136. l
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, The CPRT-Electrical is currently in the process of deciding whether j
root cause determination is necessary. Final acceptance of the anal-
ysis could negate these items from a "noner aforming" classification.
Status of NRC Inspection Activity
Inspection of this activity included the review of the CPRT Action
Plan I.a.5, Revision 3. No CPRT quality instruction governs this
activity, other than the SRT Draft Policies and Guides, which were
approved for use by the SRT on February 28, 1985. Assessment of the
adequacy of this approach is an open item (445/8511-0-38). l
The NRC inspectors are currently reviewing the AMP Incorporated
Engineering Evaluation Report EER-136.
No NRC violations or deviations were identified,
d. Electrical Conduit Supports (ISAP No. I.c)
Status of CPRT Activity
The Unit 1 Damage Study program conducted by CPSES for conduits
greater than 2" is currently being reviewed by TERA (Third Party).
The Unit 1 and common 11/2" and 2" conduit population has been
tabulated by run; random and engineering samples have been selected
with as built drawings completed accordingly. Seismic analysis is
complete for all runs in the random sample and is ongoing for the
engineering sample runs, with the seismic analysis report presently
scheduled for completion by early December 1985. Preliminary results
indicate approximately 5% of all runs analyzed could interact with
safety related items. CPRT is currently reevaluating the potential
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conservatism of support failure criteria. The NRC inspector was
informed that interactions will be evaluated as to safety significance
in the ongoing damage analysis. Third party review is ongoing for
sample selection, as-built documentation, and seismic analysis.
Status of NRC Inspection Activity
Sample selection adequacy and compliance with the FSAR, CPRT Action
Plan, and SRT policy statements are currently being inspected. This
inspection includes the following activities: review of the Damage
Study for greater than 2" conduit, verification of populations, review
of as-built drawings, review of dynamic analysis methods with related
support failure criteria, and review of the Gibbs & Hill evaluation of
greater than 2" Category II conduit for Unit 1.
No NRC violations or deviations were identified.
e. QC Inspector Qualifications (ISAP No. I.d.1)
Status of CPRT Activity
Six electrical QC inspectors have been identified by the Phase I and
II stages of this plan to have qualifications which could not be
substantiated as meeting project requirements. Phase III
reinspections of sampled work accepted by four of the inspectors are
complete. Reinspection was being performed of samples of work
accepted by one of the two remaining inspectors during this time
period. The inspections were being performed by an ERC inspector and
an accompanying TUGC0 QC inspector.
Status of NRC Activity
1. The following three ERC reinspections of work accepted by the
inspector were witnessed by the NRC:
- Conduit C13030625
- Pull Box JB15-595G
- Essential Lighting Circuit ESB1-42
2. During the above reinspections, ERC identified the following
condition to the NRC inspectors as subject to evaluation as a
potential deviation:
- Pull Box JB15-595G - Acceptance of box location on the
apparent basis of a drawing which did not identify box
location.
Disposition of this finding is an open item (445/8511-0-01)
3. During the ERC reinspection on August 6-7, 1985, of
Circuit ESB7-12, the following deficiencies outside of the
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defined ERC inspection scope (i.e., work not inspected by the
inspector in question) were orally identified to the C
inspector:
- One pull box (ESB1, above exit sign) was b. n 5!ae
shown on drawing 2323-El-0909
- Exit sign above door 201 did not 1: ;n aeta: (. m
drawing 2323-El-1704
- The exit sign seismic cable wa- * " 'S1' ilowable and
plain washers were used on U-bt -
2. or lockwashers.
- Drawing 2323-El-1704 calls for 1/4 inch U-bolts on lighting
fixtures, but some U-bolts were 5/16 inch.
The NRC inspector was informed that a TUGC0 NCR would be issued
for the out-of scope findings. As of August 29, 1985, an NCR
was ascertained by NRC followup to have not been initiated. It
was additionally ascertained that the necessary information for
NCR issue had not been maintained. The failure to promptly
document nonconforming conditions is a violation (445/8511-V-01).
f. Reinforcing Steel in the Reactor Cavity (ISAP No. II.a)
Status of CPRT Activity
A detailed reanalysis of the as-built condition of the structural
integrity of the Unit I reactor containment between elevations 812'0"
and 819'1/2" was completed by Gibbs and Hill, Inc., (G&H) and
subsequently reviewed by TERA personnel. Other instances of
reinforcement omissions for Units 1 and 2, as documented in project
NCRs, were researched. A random sample of 60 concrete pour cards was
selected and reviewed. The final results report is in the course of
preparation.
Status of NRC Inspection Activity
An analysis of the as-built condition of the Unit I reactor cavity by
G&H (i.e., calculation number SRB-115C, Set 5, 26p) was reviewed by
the NRC inspector. The methodology and assumptions used were
compared against the design commitments contained in Section 3.8 of
the FSAR. The reactor cavity design pressures were verified to be in
agreement with Table 6.2.1-23 of the Comanche Peak FSAR. Numerical
calculations were spot checked for arithmetic accuracy. Structural
drawings showing reactor cavity dimensions and as-built reinforcing
steel placement were checked during the review to verify the
dimensions used in the calculations.
The G&H analysis of the as-built condition of the Unit 1 reactor
cavity appeared to appropriately address the omitted reinforcing
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steel. The methodology, assumptions, and load combinations appeared
to be consistent with Comanche Peak FSAR. Spot checking of the
numerical calculations substantiated the conclusions made by G&H with
respect to omitted reinforcing steel not being required to maintain
the structural integrity of the reactor cavity.
Plan items scheduled to be inspected by NRC personnel include: (1) a
review of the circumstances and engineering evaluation that led to
provisions for, and subsequent deletion of the subject reinforcing
steel, (2) a review of all other instances of reinforcement omissions
for Units 1 and 2 covering all safety related Class I building
structures, (3) a review of 60 concrete pour cards, and (4) a review
of procedures governing design changes including the flow of design
changes to the field.
No NRC violations or deviations were identified.
g. Rebar in the Fuel Handling Building (ISAP No. II.e)
Status of CPRT Activity
An analysis of the effects of cutting two layers (1st and 3rd) of the
east-west No. 18 reinforcing steel associated with the installation
of the trolley process aisle rails in the Fuel Handling Building was
completed by G&H and reviewed by TERA. Procedures for ultrasonic
measurement of the length of the installed Hilti bolts were prepared
and reviewed. Ultrasonic testing was carried out by Southwest
Research Institute (SWRI) and the results report on the testing is
currently being reviewed by TERA. The final results report is in the
course of preparation.
Status of NRC Inspection Activity
G&H calculation number SRB-102c, Set 1, Revision 10, for TUGC0 was
reviewed by the NRC inspector. The analysis is designed to
demonstrate that the structural integrity is maintained if No. 18
reinforcing steel on both the first and third layers was cut. The
methodology and assumptions used were compared against the design
commitments contained in Section 3.8 of the FSAR. Spot checks were
made of the arithmetic accuracy of the numerical calculations.
Structural drawings showing dimensions and reinforcing steel
placement were checked during the review to verify the dimensions
used in calculations. The analysis assumes that only two bars were
cut along only one rail line based on the relative dimensional
locations of the Hilti bolts and the embedded reinforcing steel.
The G&H analysis of the effects of cutting both (1st and 3rd) layers
of the east-west No.18 reinforcing steel in the top reinforcement of
the concrete mat appears to adequately address the situation. The
_ , _ - - - - __ _- - .-_. _ _ _ . - _ _
- . . . - - . .
I
13
methodology and assumptions used appeared to be consistent with the
FSAR. The SFB-102C, Set 1, Revision 10, calculations by G&H used
"the gover ning design bending moment and steel reinforcement required
as given in the original calculations." The values used were verified
to be accurate by reference to the original calculations. The
analysis was found to be supportive of the conclusion that the mat
is structurally sound inspite of the possible cutting of two No.18
reinforcing bars along one rail line.
A review of the SWRI procedure NOT-800-103 for ultrasonic measurement ;
of Hilti bolt lengths was complcted which indicated the procedure is
adequate. Inspection reports on Hilti bolt lengths generated using
this procedure were also reviewed.
Additional plan items scheduled to be inspected by NRC personnel
include: (1) a review of the adequacy or procedural controls
governing rebar cutting, (2) a review of all cases for Units I and 2
where rebar cutting was requested for installation of Hilti bolts,
(3) a review of the determination of the possibility of additional
unauthorized rebar cutting, and (4) a review of Hilti bolt
installation work performed by the construction crew that installed
the subject Hilti bolts.
No NRC violations or deviations were identified.
h. Hot Functional Testing (HFT) Data Packages (ISAP No. III.a.1)
This ISAP deals with HFT completed data packages which were reviewed
by the NRC Technical Review Team (TRT) during the 1984 inspection, as
documented in NUREG-0797, Supplement No. 7, " Safety Evaluation
Report," (SSER) dated January 1985.
'
The applicant has informed the NRC inspector that the actions
committed to by ISAP No. III.a.1, Revision 3, have been essentially
completed with the exception of the final results report. The NRC
has therefore commerced a followup inspection to verify the
completeness and adequacy of corrective action taken.
! In order to maintain a correlation between areas inspected and the
applicable sections of the ISAP, this inspection report will address
,!
each area using the ISAP section or paragraph number assigned by the
applicant:
4.1.1. The applicant committed to develop guidelines for reevaluation
of completed test data packages by the Joint Test Group (JTG)
members, or their designee, qualified to review preoperational
test results and who did not perform the original review, as
stated in 4.2.1 of the ISAP. The guidelines were furnished
as Attachment 1 of the ISAP. The NRC inspector reviewed the
l
1
_ _ _ _ _. . _ - . -- __- . - -. -- - _
_ , . - . , _ _ -
.
14
guidelines and found them to be adequate. However, during a
followup inspection of the reevaluation on 1CP-PT-49-05,
" Boron Thermal Regeneration System" preoperational test data
package, the NRC inspector found two test steps signed by the
same individual who participated in the reevaluation. The
impact this may have on objectivity was discussed with the
applicant. The NRC inspector was provided with the explanation
that if a System Test Engineer (STE) was responsible for the
conduct of a given test, he would not be utilized for the
reevaluation. However, there will be instances where STEs who
may have assisted, such as in the above test, would be utilized
due to qualified manpower limitations. Since there is an
independent, multi-discipline reevaluation being conducted by
all JTG members or their designees, the level of objectivity
required by the NRC appears to have been achieved.
4.1.2. This section of the ISAP commits to issuance of Test Deficiency
Reports (TDRs) to fully document the results of the reevaluation
of HFT data packages for ICP-PT-34-05 and ICP-PT-55-05. The NRC
inspector verified that TDR 3653 and TDR 3654, respectively, were
issued and properly filed in the TUGC0 Records Center. These
TDRs and the associated tests are discussed in detail in
paragraphs 4.1.4 through 4.1.6 below.
4.1.3. The completed test data package for ICP-PT-02-12, " Bus Voltage
and Load Survey" was verified by the NRC inspector to have
been reevaluated in accordance with the ISAP. The disposition
was consistent with the TRT findings reported in the SSER and
thus the JTG directed that the test results be voided and the
test repeated. Subsequently 1CP-PT-02-12, RT-1, Revision 0,
" Bus Voltage and Load Survey, Retest 1" was performed during
the second HFT conducted in November - December, 1984. The
completed test data package was reviewed by the NRC RRI with
satisfactory results as documented in NRC Inspection
Report 50-445/85-06.
4.1.4. The completed test data package for 1CP-PT-34-05, " Steam
Generator Narrow Range Level Verification" was reevaluated as
documented in TDR 3653. The reevaluation summary report
attached to the TDR addressed the fact that three temporary
transmitters were used during the test, but the TRT's primary
concern, the adequacy of the retest for the subsequently
installed permanent transmitters, was not. In the SSER, the
TRT reported a concern that replacement transmitters 1-LT-517,
-518, and -529 were not adequately retested because they had
been subjected to a cold calibration only, when in addition,
,
'
they should have been operationally tested at hot, no ioad
conditions. Regulatory Positions 2 and 3 of Regulatory
Guide 1.68 require adequate retests to be performed which
subject components to actual plant operating conditions to the
_ _ _.__ _-- _ _ ___
.
15
extent practical. The applicant explained in Section 3.1 of
the ISAP, and during several discussions with NRC
representatives, that all the transmitters will be verified to
be operational at hot plant conditions as required by Technical
Specifications. The applicant has not documented this as a
specific retest requirement for the replaced transmitters.
Region IV is evaluating the applicant's position regarding
this issue. This matter and the similar subject material found
in regard to test data packages 1CP-PT-55-05 and ICP-PT-55-10
is an unresolved item (445/8511-U-02).
4.1.5. The completed test data package for 1CP-PT-55-05, " Pressurizer
Level Control" was verified to have been reevaluated as
documented in TOR 3564. Although the objectives of the test
appear to have been met, level transmitter 1-LT-461 was found
subsequently to have been out of calibration. Efforts to
calibrate the instrument were unsuccessful, thus it was
replaced. As in the case with 4.1.4 above, a cold calibration
retest was specified in the TDR, again as discussed in
Section 3.1 of the ISAP, on the apparent basis that the
instrument will be functionally tested later. The same
documentation problem for retesting applies as was the case in
4.1.4 above. This matter as discussed in 4.1.4 above is part
of unresolved item (445/8511-U-02).
4.1.6. TDR 4015 was issued as a supplement to 1CP-PT-55-05 to track
and document the reevaluation by the JTG of the apparent
unauthorized change of chart speed on the pressurizer level
recorder, as committed by the ISAP. Corrective action
documented in the TDR states, " . . since the procedure
suggested the chart speed, it could have been misinterpreted
not to require a test procedure deviation (TPD) report."
Paragraph 7.2.6.c of the test procedure directs the STE to
" Select and record chart speed (1"/ min or comparable)." The
NRC inspector did not find any room in the procedure step for
an interpretation that might allow the STE to select and
record chart speed, sign off the step, and then while the test
is in progress change the speed by a factor of 10 without
changing the procedura (in accordance with administrative
requirements). This issue is being considered for enforcement
as a part of the followup to the TRT findings.
'
4.1.7. There were seven HFT preoperational test data packages that
were not previously reviewed by the TRT. This section of the
ISAP committed the applicant to a reevaluation of these
packages in accordance with the guidelines established in
Attachment 1 of the ISAP. The NRC followup inspector is
reviewing the documentation associated with the reevaluation
of each data package to determine the following:
- _
- _
. . , _ - .- - .-
'
.
16
. That the applicant's reevaluation appeared to follow the
guidelines established by Attachment 1 of the ISAP,
. that documented questions raised by the reevaluation were
properly dispositioned and approved by the JTG, and
. that the disposition approved by the JTG are not contrary
to regulatory requirements.
The following test data package reevaluations were followup
inspected during the reporting period:
a. ICP-PT-49-02, "Sealwater and Letdown Flow Performance."
The reevaluation appeared to meet the above inspection
criteria with two exceptions. In the first case, the
reevaluation questioned why the JTG failed to consider the
impact on test results caused by replacement of the letdown
orifices with a different size, specifically in the
determination of letdown heat exchanger capacity, which is
a function of flow through these orifices. The JTG -
approved response was that the objectives of the test were
not compromised because the FSAR does not require
operational testing of these heat exchangers. The test
method on sheet 11 of FSAR Table 14.2-2 states, " Verify
. . . operability of heat exchangers . . . ." In the
second case, the reevaluator questioned why TPD-4 did not
state the reason for changing letdown flow from 120 to 75
GPM. The JTG - approved disposition provided the reason, '
which appeared to be technically correct, however, no
reference was made to any corrective actions to ensure a
proper reason is entered on TPDs. The above two cases were
discussed with the applicant's representatives. At the
time there was no satisfactory explanation available as to
why the letdown heat exchangers did not need to be retested,
but the applicant committed to provide one at a later date.
Permanent corrective actions to ensure TPDs are properly
justified are being taken by revisions to the Standard
Administrative Procedures, as part of the programmatic
improvements being made by the CPRT. These actions shall be
tracked under Open Item (445/8511-0-02).
b. 1CP-PT-49-05, " Boron Thermal Regeneration System." This
reevaluation met the above inspection criteria.
c. 1CP-PT-55-10, " Pressurizer Pressure Control System." The
reevaluation summary report stated that the deficiency
reported by TDR 1226 was not corrected by the specified
corrective action. Pressurizer pressure bistable 1-P8-455A
failed to trip at the required setpoint when the data
appeared to indicate that it should have. The JTG -
- ._ - - - - - .
.
17
approved disposition relates to a 2400 PSIG limit as having
prevented the trip, yet the bistable subsequently tripped
at 2385 PSIG. This was discussed with the applicant's
representative, who indicated that a valid explanation
exists and will be included in the data package. This is
an open item (445/8511-0-03).
The reevaluation summary report stated that contrary to
Regulatory Guide 1.68, a temporary instrument, different
than the permanent plant component, was used during this
test in lieu of pressurizer pressure transmitter PT-458.
The JTG - approved disposition reflected the applicant's
position that this is an acceptable practice, and noted
that the replacement permanent transmitter will be exposed
to operating plant conditions prior to reactor operation.
The NRC followup inspector reviewed TDRs 738, 742, and 905
and noted that the retest of the permanent transmitter
specified on TDR 738 was signed off as satisfactorily
completed. The retest documentation did not refer to any
functional test at operating plant conditions. As such,
there is no apparent intent to identify this part of the
retest as a pending retest at licensing. This matter is
discussed in 4.1.4 and 4.1.5 above and is part of unresolved
item (445/8511-U-02).
No NRC violations or deviations were identified during this part of
the inspection.
i. Inspection for Certain Types of Skewed Welds in NF Supports (ISAP No.V.a)
Status of CPRT Activity
Reinspection of a minimum sample size of 60 type 2 skewed welds is
currently in process. At this time, 12 type 2 skewed welds have been
identified as deviating from drawing requirements; i.e., undersize.
Status of NRC Activity
NRC personnel have reviewed CPRT ISAP No. V.a and witnessed seven
pipe support skewed weld inspections to assure compliance with
inspection procedure requirements. Independent NRC inspection will
be initiated. Review and assessment of the dispositions relating to
the 12 deviating skewed welds is considered an open item
(445/8511-0-04).
No NRC violations or deviations were identified.
l
j. Design Consideration for Piping Systems Between Seismic Category I
and Non-Seismic Category I Buildings (ISAP No. V.c) l
4
l
l
.- - - . ____ _
'
.
18
Status of CPRT Activity
A list identifying all Unit 1, 2 and common piping with
seismic /nonseismic interface has been completed by Comanche Peak
Project Engineering (CPPE). The committed review and discussion
related to the events of the Auxiliary Steam Piping situation and
recommendations to the Project Piping and Supports Program (PPSP)
and/or Design Adequacy Program (DAP) are complete, pending final
review. The final results report is in the course of preparation.
Status of NRC Inspection Activity
A review of the list identifying all Unit 1, 2, and common piping
with seismic /nonseismic interface is currently being performed to
assure both validity of the list and that no lines have been omitted.
NRC inspection of available documentation relative to the
Auxiliary Steam Line and the recommendations to the PPSP and/or DAP
will be performed after issuance of the final results report.
No NRC violations or deviations were identified in this area of
inspection,
k. Plug Welds (ISAP No. V.d)
Status of CPRT Activity
,
'
A reinspection was initiated on two random samples of ASME
Section III component supports and base plates, with one sample
representing Unit 1 and common, and the other sample representing
Unit 2. Each sample consisted of 60 component supports and/or base
plates.
Similarly, a reinspection of two random samples of cable tray
supports, consisting of 60 from Unit 1 and 60 from Unit 2, was
initiated.
Approximately 92% of the reinspection program has been completed.
Status of NRC Activity
Review of CPRT ISAP V.d has been completed. NRC personnel observed
22 pipe support base plate, and cable tray support reinspections.
Two pipe supports and seven cable tray supports indicated the
potential presence of plug welds and were therefore etched and
visually examined Five cable tray supports were confirmed by
etching to contain plug welds. Original inspection documentation
was reviewed from which it was ascertained that the plug welds had
been inspected and accepted.
Plug welds in one non-ASME pipe support and four cable tray supports
'
were independently inspected by NRC personnel. Design Change
,
- ,-- - - - --- .-.,--v- -- -- ,,,,---,,r-r.-
. ___ - _ _ - _ _ - - _ _ _ - . .
.
19
Authorization No. 5347 is currently being reviewed by the NRC
inspector for appropriate applicability to identified plug welds.
No NRC violations or deviations wer e identified.
1. Installation of Main Steam Pipes ISAP No. V.e)
Status of CPRT Activity
The specific engineering investigation of the steam line adjustment
is about 90% complete. Interviews with personnel involved with the
- steam line adjustment have been completed. An analytical report
issued by R. L. Cloud Associates (RLCA) for TERA has been prepared.
i
This report describes the analytical evaluation of stresses and ;
support load changes which occurred during Unit 1. Loops 1 and 4,
steam line movement. It also establishes engineering significance of
stresses, reviews the existing ultrasonic examination and hydrostatic
'
test results and determines the need for reinspections at highly
stressed points on the main steam piping. Review of procedures for
pipe erection and placement of temporary and permanent supports as
well as engineering significance of these procedures is presently
being done.
The generic study of possible damage in other piping is about 85%
complete. Interviews with pipe installation personnel, review of
NCRs and Piping Deviation Request Forms (PORFs), and review of other
sources of residual stress as well as engineering significance has
been completed pending review.
Status of NRC Inspection Activity
The RLCA stress report is being reviewed for adequacy of the methods
of analysis. The supporting computer output, calculations, and
piping models will be reviewed upon receipt at site. Assessment of
NCR and PDRF reviews is planned to be performed in the next
inspection period, with review of revised procedures and
, specifications scheduled upon issuance of the final results report.
No NRC violations or deviations were identified in this area of
inspection.
m. Material Traceability (ISAP No. VII.a.1)
The ERC's issue coordinator for this item has completed Phase I and
issued a report documenting their position on material traceability
of ASMr items. The report states that an ASME survey in 1981
resulted in the withdrawal of Brown and Root's certification. After
corrective action was initiated and a resurvey was conducted the
certification was reinstated by the ASME. Subsequently, the ASME
conducted an unannounced survey and in 1984 a certificate renewal
- sur vey was conducted. None of these subsequent surveys identified
further problems with material traceability.
l
l
l
l -
__ . . . , . -. , , - - - - - - - - - - -- - - - - - - - -
. . . . .- .. - - - - - . _ . - - ..
<,
20
The ERC issue coordinator considers the present practices adequate
and will refer the ASME survey findings to the issue coordinator for
nonconformances and corrective actions (ISAP No. VII.a.2) to assess
the possibility of a QA/QC breakdown. The remainder of the material
traceability issue (Phase II) is dependent on the results of the ISAP
No. VII.c reinspection effort. Therefore, this subject will be
continued in a future report.
One deviation (445/8511-D-02) was identified during the NRC inspector
review of this item. The CPRT Program Plan,Section VII, provides
criteria for assuring the objectivity of CPRT personnel. One
'
criterion states that any CPRT consultant who has had previous CPSES
involvement in areas of current CPRT review responsibility will be
identified to the NRC with the justification necessary to show
continued objectivity. The issue coordinator for this item was a
consultant to B&R in 1981 which included an audit at Comanche Peak;
however, this was not identified to the NRC nor was the necessary
justification provided.
n. Valve Disassembly (ISAP No. VII.b.2)
i
! , Status of CPRT Activity
I
l
Valves that required disassembly for construction, testing, or other
reasons, have been identified and a reference data base established.
1 The applicable construction and quality control procedures and
drawings have been reviewed. In conjunction with the
procedure / drawing review, an analysis was made to determine the
safety consequences of improperly reassembled valves. The analysis
.
includes potential failure modes resulting from improper reassembly
1 of the identified valves. The selection of a random samplc and an
engineering sample was performed and the reinspection documentation
packages prepared. Reinspection was initiated and is now
approximately 95% complete. There is an approximate 2% deviation
rate identified thus far, related to valve body and valve bonnet
, serial number mismatch. The deviations are being evaluated and the
l programmatic and generic implications are being reviewed. This is an
1
open item (445/8511-0-05).
The estimated completion of this activity and issuance of a results
report is currently scheduled for October 15, 1985.
Status of NRC Inspection Activity
Seven valve reinspections have been witnessed. The rev'ew of all
pertinent activities associated with this action plan are continuing.
No NRC violations or deviations were identified.
l
1
.. . . , - - , , - - . . , - - . . .-.- -.--..- --, --,._-.,, --_,,--- , -_._ ,~.nn
.
21
o. Construction Reinspection / Documentation Review Plan - Cable Trays
(ISAP No. VII.c)
Status of CPRT Activity:
ERC completed 32 reinspections of sampled cable trays as of
August 23, 1985.
Status of NRC Activity:
1. The following seven ERC reinspections of sampled cable trays
were witnessed by the NRC.
Verification Package No. Cable Tray No.
I-E-CATY-004 TI40CDJ17
I-E-CATY-023 T120CBD68
I-E-CATY-036 T140SDA05
I-E-CATY-047 T130ACP16
I-E-CATY-049 T130CCP70
I-E-CATY-055 T120FBUO4
I-E-CATY-060 T120FBUO5
2. During the above -* inspections, ERC identified the following
conditions to the NRC inspector as subject to evaluation as
potential deviations:
a. I-E-CATY-004: Cable Tray T140CDJ17 had a loose ground
strap bolt near node 16.
b. I-E-CATY-004: Cable Tray T140CDJ17 had two approximately
one inch openings in the solid bottom cover. With these
openings 3 feet vertical separation is required by the
electrical erection specification. The distance to the
tray below is only 2 feet 9 inches.
c. I-E-CATY-004: Drawing showed that cable tray T140CDJ17
elevation to be 817' instead of 819' (actual).
d. I-E-CATY-047: Sharp edges observed in tray T130ACP16 at
1720' marker. Adjacent Rockbestos 7C AWG 600V cable jacket
was slightly damaged.
e. I-E-CATY-074: Bottom tray run was notched to allow a
wrench to tighten a solid bottom cover bolt to the tray
rung.
f. I-E-CATY-036: Cable tray T140SDA05 had a loose bolt on a
splice plate.
Dispositions of the above findings are open items
(50-445/8511-0-06 to 445/8511-0-11).
. - - _ _ _ . .= . - . . -
.
22
3. ERC also noted the following deficiencies outside of the defined
inspection scope:
'
a. I-E-CATY-047: A welded splice plate was observed as having
two out of eight bolts missing.
b. I-E-CATY-055 & 060: Pipe F0-1-880-21A was less than the
required 6 inches from a tray.
Dispositions of the above findings are open items (445/8511-0-12
and 445/8511-0-13).
4. Additional NRC observations were made during the electrical
l cable trays reinspections with respect to fire wrap damage and
i missing cable tray covers. The results of NRC evaluation of
these subjects will be documented in a subsequent inspection
'
report. These are open items (445/8511-0-14 and 445/8511-0-15).
No NRC violations or deviations were identified.
p. Construction Reinspection / Documentation Review Plan - Electrical
i
Conduit (ISAP No. VII.c)
Status of CPRT Activity:
ERC completed 51 reinspections of sampled electricei conduit as of
August 23, 1985.
, Status of NRC Activity:
4
1. The following six ERC reinspections of sampled electrical
conduit were witnessed by the NRC:
Verification Package No. Conduit Tray No.
, I-E-CDUT-007 C13010190
I-E-CDUT-065 C13G08606
I-E-CDUT-070 C14R13047
I-E-CDUT-066 C12G04985
i
I-E-CDUT-051 EAB1-1
I-E-CDUT-064 C13016037
2. During the above reinspections, ERC identified the following
! conditions to the NRC inspectors as subject to evaluation as
potential deviations:
'
a. I-E-CDUT-066: Conduit to tray separation was measured to
be 6 1/2 inches rather than the required 12 inches.
i
i
!
!
i
'
l
l \
l
, . , , , . , _ . . _ _ _ _ _ . _ _ . _ _ _ _ , . _ . _ _ _ . _ _ _ _ _ _ . . _ _ . . . _ . . _ . . . _ _ . . ,. . _ _ _ _ . _ _ _
. _ _ _ . . _ _ ._ _ . _ _ _ _ _ _ _ _ ~ . _ _ _ . _ _
-
__ . _ _ . _ _. _ _ _ _ _.
,
.
I
.
23
i
,
b. I-E-CDUT-064:
t
3 (1) Tray T14KCCL23 is required to have 2 inches of
separation from conduit. One inch separation was
l measured.
(2) Trays T13KCCT22, T13KCCV18 and T14KCCL23 do not meet
separation requirements.
(3) No fire seal was installed in end of conduit in
j control room.
i
Dispositions of the above findings are open items (445/8511-0-16
to 445/8511-0-19). .
l 3. ERC also noted the following deficiencies outside of the defined
j inspection scope:
I
~
Verification Package No. I-E-CDUT-066
At the Motor Control Center (MCC) 1EB4-1, the cables.:oming out
of the conduit stove pipes into the cable tray above are
partially covered with thermal lag. These cables do not meet
.
the requirement for 2 inches of movement (slack) in all
l directions for conduit to cable tray transitions for free air
j cables.
Verification Package No. I-E-CDUT-064
I
a. In the bottom of Control Room Rack CPI-ECPRCR-15, rear
j
'
section, five of the eight conduit stubs did not contain
any fire stop sealing material. The sealing material is a
4
requirement anytime a conduit penetrates a fire rated wall
or floor.
I
b. Conduit C13016035 runs from above tray T130CCQ64 and ends
>
just under the tray. The cables from this conduit enter
the tray from the bottom. Conduit requirements call for
- conduit to make cable transitions 10 inches above the tray. '
)'
Dispositions of the above findings are open items (445/8511-0-20
to 445/8511-0-22).
l No NRC violations or deviations were identified in this area of
- inspection.
i
!
i
'
!
.-. -
- -.- - . _ , _ _ - _ - . _ _ _ -
- - . __ _
- . - _ - - . _ _ - - . - _ -_- . ._- . = - - _. - - -.. .
,.
24
'
q. Construction Reinspection / Documentation Review Plan - Electrical
Cable (ISAP No. VII.c)
Status of CPRT Activity
'
ERC completed 15 reinspections of sampled electrical cable as of
August 23, 1985.
'
Status of NRC Activity L
- 1. The following 11 ERC reinspections of sampled electrical cable
were witnessed by the NRC: i
Verification Package No. Cable Tray No.
'
I-E-CAB L-004 EG123625Z
I-E-CABL-037 EG015661
I-E-CABL-040 E0106091
I- E-CAB L-042 EG123834
I-E-CABL-045 E0121890
I-E-CABL-054 E0100440
I-E-CABL-035 EG112939
I-E-CABL-028 E0015951D
I-E-CAB L-058 E0015944B
I-E-CAB L-011 ESB2-13
I-E-CAB L-036 EG126972X
During the above reinspections ERC identified the following
j conditions to the NRC inspectors as subject to evaluation as
potential deviations:
l
'
a. I-E-CABL-037: A group of cables exiting tray T13GCCM13 and
entering tray T13GCCH36 were bearing on a cable in the
bottom of tray T13GCCM13. This cable, which could not be
individually identified due to the numerous other cables in
the tray, could possibly suffer conductor damage.
i
b. I-E-CABL-040: Cable E0106091 was found to not have the
required 2 inches of slack in free air as it exited tray
T13 SCC 65 and entered conduit C13015570.
c. I-E-CABL-045:
(1) Wall sleeve TWS-A-020 existed in the plant but was not
shown on routing s-hedule 2323-El-1700 as a designed
raceway.
, (2) Cable E0121890 was found to not have the required 2
inches of slack in 'ree air as it exited tray
T130CCQ22 and entered conduit C13011615.
i
!
l
l
.
,,---w - ----,.- -
,- , , - _ - _ _ - . , + , , , , , , - _ - - ,w y
. .-- - .- - -- . . .. . . -. ..
'.
i
25
(3) Cable E0121890 was found to not have the required 2
inches of slack in free air as it exited tray
- T130CCQ45 and entered C13003316.
(4) The electrical penetration assembly for cable E0121890
was not identified on the outboard side.
d. I-E-CABL-028: Drawing 2323-El-0035, Sheet 38, did not have
termination points A through H listed for cable E0015910
terminating at a limit switch,
e. I-E-CABL-058 - Drawing 2323-El-0035, Sheet 37, did not have
termination points A through H listed for cable E015944B
which terminated at a limit switch.
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l Dispositions of the above findings are open items (445/8511-0-23
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to 445/8511-0-30).
2. ERC also noted the following deficiencies outside of the defined
inspection scope.
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a. I-E-CABL-040: ERC discovered a two conductor - 12 AWG -
600V cable with a cut outer jacket. The cable (E0122946)
is located at the floor penetration of 480V MCC 1EB1-1.
TUGC0 QC applied a hold tag upon ERC identification,
b. I-E-CABL-040 - Cable tray T130 SCC 68 had less than the
required 1 inch separation between a covered tray and a
lighting conduit.
Dispositions of the above findings are open items (445/8511-0-31
and 445/8511-0-32).
3. Additional observations were made by the NRC inspectors during
the ERC'reinspections with respect to wall sleeve to conduit
connection documentation and verification practices used for
reinspection of cable to electrical penetrations. These
subjects are considered open items (445/8511-0-33 and
445/8511-0-34) pending completion of NRC evaluation. During NRC
inderendent inspection, it was noted that trays T130ECG41 and
T130CCP80 in the Unit 1 lower cable spreading room had 1 inch
! openings in the solid bottoms. This is an open item
i (445/8511-0-35) pending completion of NRC review in regard to
the permissibility of this condition.
6. Unresolved Items
.
Unresolved items are matters for which more information is required in
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order to ascertain whether they are acceptable items, violations or
deviations. Two unresolved items disclosed during the inspection are
discussed in paragraphs 3 and 5.h.
,
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- -- _ ._ . __ ,. .. _. . _ . - .. .-. . . . _ - ._
.
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7. Exit Interview
An exit interview was conductr.d on August 29, 1985, with the applicant
representatives denoted in paragraph 1 of this report. During this
interview, the NRC inspectors summarized the scope and findings of the
inspection. The applicant acknowedged the findings.
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