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l J08 35-1195 Comanche Peak Steam Electric Station Sheet 1 of 3 Construction Procedure DOCUMENT CHANGE NOTICE NUM8ER 1
This notice applies to Construction Procedure No. 35-1195-CPM 15.2 Revision 1
This change will be incorporated in the next revision of the procedure.
Change the procedure as follows:
Replace the following page with the attached:
. --Page-2W-2 ----
Page 1 of 1 Attachment 1 i
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'Date arown & Reet Quality Msurtnce Gate 7
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Approved by:
TUGCo Qua W Assurance Date g.
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1/28/83
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BROWN & ROOT, INC.
PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE i
JOB 35-1195 CP-CPM 15.2 i1 1/25/83 1 of 2
.I-/JSSE TITLE:
ORIGINATOR:
mr WORX ACTIVITIES ON
/
ROOMS WHICH HAVE REVIEWED BY:
9#45V5 BEEN TURNED OVER bgth[
iUGC0 QA
'DATE APPROVED BY ud.
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^a CONSTRUCTION PROJECT MANAGER OATE CP C.i TABLE OF CONTENTS
1.0 INTRODUCTION
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2.0 PROCEDURE
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2.1 TURNOVER AND PUN IS w
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2.2 TAGGING gs TOR I
2.3 NOTIFICATION OF WO
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2.4 ROOM SUBDIVIDING C0H1pgi0 STATUS AND g "j
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s I.0 INTRODUCTION This procedure provides a means of notifying the responsible depart-ment of work performed in rooms which have been turned over. This procedure is applicable to Brown & Root and subcontract personnel.
2.0 PROCEDURE 2.1 TURNOVER AND PUNCHLISTING Area Management shall decide when a room is ready for turnover. At this time. Area Management shall request the different craft organ-tzations to provide a listing of incomplete items in each room.
Area Managenent shall then advise Completions that the room is ready for turnover.
2.2 TAGGING After the room is ready for release to Completions Area Management shall have the room cleared, and identified with signs which state g.j :,,.
that the room / ha@e been turned over and that all work,shall be per-
.gj formed in accordance with this procedure.
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PROCEDURE EFFECTIVE PAGE BROWN & ROOT, INC.
NUMBER REVISION DATE CPSES JOB 35-1195 CP-CPM 15.2 1
1/25/83 2 of 2 2.3 NOTIFICATION OF WORK TO BE PERFORMED 2.3.1 When work in a turned over room needs to be performed, the craft shall initiate a Room Work Notification form (RWN; Attachment 1).
This fonn shall be submitted to the Document Control Center who shall make distribution of the form to:
1 Startup 2
TUGC0QA(Construction) 3 Damage Study 4
Area Management NOTE: After distribution is made, the original form should be returned to the originator by the DCC. The originator may retain the form in file, or discard the form.
2.3.2 In completing the fonn, the craft shall provide a concise description of the work to be performed, e.g., installation of conduit support C12K09723-5, and should include other information such as design changes, SWA numbers, etc.
Q When multiple disciplines are involved, each discipline shall complete!JM form.
m up w ar 2.3.3 When an inspected item has to be removed to accomplish the work described in the RWN, an IRN shall be prepared in accordance with CPM 6.10'or 6.10-1, as applicable, describing the removal of theinspecteditam(s). If work is to be performed on a turned over system, a SWA shall be obtained as required by CP-CPM 12.2 for the system work; however, a SWA is not required for the room work.
I 2.4 ROOM SUBDIVIDING Rooms mayl be subdivided into areas when authorized in writing by Area Management. The areas shall be designated with the room number and an alphabetical suffix. Once divided, the areas shall be physically identified by signs, barriers, or any other method which clearly establishes the boundary. The boundaries will be i
defined hy coordinates, e.g., column lines, elevation, etc. by Area Management.
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- 4 18 PROCEDURE EFFECTIVE BROWN & ROOT, INC.
WMBER REVISION DATE PAGE i
i JOB 35-1195 t
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1/25/83 1 of 1 l
4 ATTAC}9 TENT 1 l
I ROOM WORK NOTIFICATION i
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Room Number:
Date:
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G' x ' f-j p.o. sox tooi on.EN ROSE. TEXAS 79043 I
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0 According to my records you have a response due
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a TI-053 - Procedure for Final Condition Inspection l
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TI)Q,-1215 TEXA ILITIES GENERATING COE NY e-y OFFICE MEMOR ANDUM B. C. Scott 7,
clen no... Texas March 24,1982 Subject NRC Inspection Report 82-01 1
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The attached form documents an Unresolved Item recently identified in NRC-Inspection Report 82-01. Please prepare ~an evaluation and send a written response in order to close, or actions that have been or will be tkane in this matter, to this office on or before April 8,1982.
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R. G. Tolson
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TUGC0 Site QA Supervisor RGT/bil Attachment l
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O DATE: 3/17/82 7RACxtNc No: TI-053 ADVANCE REPORT oN NRC INSPECTION NRC REPORT No.
82-01 l
C ITEM OF NON COMPLIANCE O oetictency O tarraction l
l DEVIATION
% UNRESOLVED ITEM REQUIREMENT:
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FINDING:
Procedures for Final Condition Inspection
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The Senior Resident Inspector-Construction (SRIC) toured the most active areas of the facility during the period to observe the status of construction and:the practices utilized by the craft personnel, as well as to observe the activities of the quality control personnel. During one such tour made in conjunction.
with the Senior ~ Resident Insoector fdr Operations, it was noted that in a few instances electrical cables in high routing density areas were being pressed against the edges of cable trays and in one instance a cable had been forced into a relatively sharp bend as evidenced by wrinkles in a cable jacket.
Having observed cable installation for well over two years and being familiar with the licensee's inspection procedures for cable installation, the SRIC Judged that the on-going installation effort, which is nearing completion, i
has probably caused cables installed months ago to become unacceptable due 4
to the increasi_ng cable density.
In most instances, it did not appear tha't.
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the situation could easily be corrected if detected. in a timely manner. The iM.
matter was brought to the licensee's attention. The licensee. stated that'a' g(
final condition inspection program wa,s under development that would be A
applicableJto piping, piping support, electrical cable installations, and to
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3 instrument installation activities to detect damage and other conditions which develop as a consequence of the on-going activities affecting earlier accepted work. The SRIC's experience indicates that such final inspections are usually necessary in long term, complex construction activities. The licensee indicated that the necessary implementation procedures are under development, I
along with the manning requirements for the effort. This matter will remain
) unresolved until such time as the procedures have been published and reviewed by NRC inspectors.
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PAGE 10F RECElVED s
NOV 8 1983 CcMANCHE PEAK STEAM ELECTRIC STATION DESIGN CHANGE AUTHORIZATION GBBS.& E!!!.f :fac.,'
3E INCORPORATED IN DESIGN 00CUMENT CCA NO.19.139
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SAFETY RELATED CCCUMENT: XX YES NO 2.
CRIGINATOR:
CPPE XX ORIGINAL DESIGNER 3.
DESCRIPTION:
A.
APPLICABLE SPEC,,0WGV00CUMEIK 2323-ES-100 REY.
2 8.
OETAILS Add the fo11 ewing paragraph to ES-100:
4.11.3.3(3): The minimum separation requirement of 6" within equipment for field run cables may be waived between Class 1E cables of one train and non-CTass TE fiber cotic cables.
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SUPPORTING 00CUMENTATION:
DOCUMENT CONTROL 11-7-83 5.
APPROVAL SIGNATURES: FLP:gh A.
CRIGINATOR:
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CATE N-7-f S B.
DESIGN REPRESENTATIVE:
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DESIGNREVIEWPRIORTOISS*h([.
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VENDOR RELATED CHANGE XX NO Yb 7.
STANDARD DISTRIBUTION:
ARMS (CRIGINAL)
(1) Fred Powers EE (1)
OUALITY ENGINEERING (1) Mark Welch CA (1)
DCTG FOR ORIG. DESIGN
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SPEC, HAH,TUGC0(2) AM PAGE 1 0F 2 CHANGE INDEX:0EI COMANCHE PEAK STEAM ELECTRIC STATION
- II '
OESIGN CHANGE AUTHORIZATION
- III xx gf>
(WILL) (WIEEXMGT) BE INCORPORATED IN DESIGN DOCUMENT DCA NO. 17,A64 REV. 1.
1.
SAFETY RELATED 00CUIENT:
XX YES NO 2.
ORIGINATOR: CPPE xx ORIGINAL DESIGNER 3.
DESCRIPTION:
A.
APPLICABLE SPEC /02'I/DC:"JEm 2323-ES-!C0 REV. 2 S.
DETAILS THIS REVISION VOIUS AND SUPdRSE:E5 M =17. E RE, C.
PCO?t E*4: The dinensions shown in 'Dlan 8" on Pace 4 da Si EC 100 are ant <cosis.
cone,hoa reisenrone si,e,enduire ira. is a.1 -
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REV. 1 : Chances horizontal diMen conduit and :rav in Caele Soreadinc
//7 CPSC D %
' Area to acree wittf/orint 2323.E4 17C2W2.
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SUPPORTING DOCUMENTATION:
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CRIGINATOR:
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DESIGN REPRESENTAT IE:
7//.t'< v OATE 9 '2 M 6.
VENDOR TRANSMITTAL RECUIRED: YES NO XX 7.
STANDARD DISTRIBUT!0N:
ARMS (ORIGINAL)
(1) Clock Conzatti EE (1)
QUALITY ENGINEERING (1) Pete Bush QA (1)
TS FOR ORIG. DESIGN (1) Frec ace.ers EE (1)
WESTINGHOUSE - SITE (1)
COMP'.ETIONS (1)
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PAGE 1 CF 2 CHANGE INDEX:CEI N PEAK STDM EIACRIC STL"ICN
- II DESIGN CHANGE ACTBCRIZATICN
- III ^^ n (WIIL) (XJet2JCNODQ BE INCCRPORAT!D IN DESICN DOCGEfr DCA NO.
14,403 1.
SAETIY REIAT!D DOCDtENT: XX ES NO 2.
CR.M"CR: CPPE ORIGriAI. DESIGIER XX 3.
OESCRIFr!CN:
A.
APPLICABLE SPEC GQWtECCHEMX 2323-ES-100 RE7. 2 f
3.
CEMIIS Revise table in paragraph 4.11.2a as shown on page 2.
NOTE: Other changes prooosed by DECD-5-2554 are shewn on DCA 4 7790 REY 2.
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CESIGi REPRESETIA".T/E:
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VE"IR SANSMII"AL PICUIRED: YES NO XX 7.
SDNCARD DISTRIBLTICN:
AMS (Original)
(1)
Suren Simon EE (1)
DCA Etm 11-a0 Cuality Engineerin; (1)
R.K. Crowell EE (1)
Admin. Fe't 7-62 5 for Orig. Design (1) t e stinahouse-site (1) l Completions (1) ~
Jerry Henson-Prod. Control (1) i l
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OCA 14403 PAGE 2 0F 2 Revise table in paragraph 4.11.2a as shewn.
DWG TRAIN OR CLASS SYMBOL r-ANNO _
UCP4Y AJNC~ TON **
"lE" A
Train "A"
- 19, 29, 39, 4 "1E Associated" "lE" Train "B"
- 1G, 2G, 3G, 4G "1E Associated" E
Ncn "lE" NOME Train "C"
- 1K, 2K, 3K, 4K, SK, 6KC "1 E" O
Caannel I 4a 5a "1E" Channel II 4W SW "lE" Channel III 48 SB Channel IV 4Y SY "1 E" a
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I FTGURE 1.
Paga 1 of COMANCHE PEAX STEN 4 ELECTRIC STATICN DESIGN CHANGE AUTHORIZATION
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(WILL) (MVXM SE INCORPORATED IN DESIGN COCUMENTS CCA NO.
12,921 1.
SAFEIT REUTED COC12EiT:
XX-YES NO I
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CRIGINATOR: C;pE XX ORIGINAL CESIGNER 3.
CESCRI?TICN:
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APPLICABLE SPEC,%u = =m.1 2222.~s 100 REV.
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CETAILS Revisa caragrach 4.11.3.2 (1) as fc11cws:
" Minimum sacaratien between conduits havine different trains and/or channels shall be one (11 inch."
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DESIGN CHANGE AUTHORIZATION
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CRIGINATOR: CPPE XX ORIGINAL DESIGNER 3.
DESCRIP' TION:
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APPLICABLE SPEC /CNGECCCCEXX 2323-ES-100 REV.2 3.
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Page 2 of 2 Revise Paragraph 4.11.3.2.5 of Specification 2323-ES-100 to read as follows:
" Minimum clearance between conduits containing power cables (raceway
. function 19, 29,1G, 2G, IK, 2K and SK) shall not be less than out-side diameter of larger conduit except as defined below:
The clearance criteria as explained above may be waived; a) At such points wher.e exposed conduits 'nter cr exit any e
equipment or box to a point of 4'-0" from such equipment or box.
b)ingeneralplantareaswhereconduitshaveaminidum clearance of 1/4 0.0. of the larger conduit, but not less than 1" between different train conduits, for conduit runs not exceeding 10 Ft.
All other~ violations of the clearance criteria shall be reviewed by Engineering on case by case bases."
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EE 463
- I N N S S N IYE' ! N "
Inter office Memorandum W. C. Dumper DE January 17, 1984 p
alaji/S.P.
h 00-2323 JOB NO:
FROM:
)
g %. Cable Tray Conduit REF. NO:
/
Seearation
References:
1)
Memo from B. Lus n to P. Lalaji/S. Martinovich dated 11-72-83.
2)
Sandia Report # SAND 77-112SC 1979 3)
IEEE Paper by L.J. Klamerus #A79091-0, 4)
General Engineering Handbook 2nd Ed, C.E.
O'Rourke.
In regard to reference 1, we offer the following for your consideration.
IEEE-384, 1974 provides no specific criteria for separation between conduits and cable trays.
The term
" enclosed raceways", where used in the standard, refers to both trays and conduits.
However, as shown in figures 2 and 3 of the standard, trays may be only partially enclosed depending upon orientation with respect to each other. Nowhere does the standard explicity set forth criteria correlating partially or totally enclosed tray with conduit regarding electrical separation requirements.
Separation philosophy of tray from conduit must therefore be based upon an inter-pretation of IEEE-384, 1974 using engineering judgement where necessary.
The following points are made in response to design review comments (ref.1) and in support of the judgement used in developing the electrical separation details currently in the construction specification (ES-100).
Item numbersbelow correspond to those used in reference 1:
1.
The intent of the memo (EE-828) should not be misinter-preted since the subject of the memo concerns itself with DCA-15917 and not IEEE-384 specifically.
Compliance with IEEE-384 is of course,. the topic of the discussion.
2a. The term " raceways" does apply to either cable trays or conduits.
This is not inconsistent with criteria provided in ES-100 for conduit to tray separation.
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W.C. Dumper Memorandum.
2b.
IEEE-384 states that "where plant arrangements preclude maintaining the. minimum separation distance, the redundant circuits shall be run in enclosed raceways or other barriers shall be provided between redundant circuits." (Note that minimum separation given in the standard applies to cables routed in open ladder - type tray).
The standard goes on to say "The minimum distance between these redundant enclosed raceways and between barriers and racewavs shall be 1 in".
In certain instances, conduits satisfy the definition of "other barriers" as well as " raceways".
2c.
The stan'dard defines a barrier as "A device or structure interposed between Class 1E equipment or circuits and a 1
l potential source of damage to limit damage to Class 1E Systems
.acceptaby_'rni".
/
When a conduit contains only non-Class 1E (and non-associated) 4 l
/
circuits for example, it clearly satisfies the requirements i
of a barrier.
It should be noted that the barri'er need not
\\
limit damage to non-safety circuits to any level.
Logically!
i then, a conduit containing non-Class 1E circuits can be Cliiss 1E open top tray since the conduit provides-4 protectiv\\
placed up to 1 inch from tne too, bottom or sides of a e'
barrier separated my at least 1 inch from the Class 1E
/.
circuits.
It should be noted that IEEE-384 1981,4ces not specify any minimum separation between the re dant circuits i
--LQthis case Class 1E and non-Class 1E) and the barrier.
A i
v 3a.
Figure 9 of the GsH Separation Criteria is not in error.
. -The pra'sTimption that an enclosed tYay should-have -been-
~
shown assumes that totally enclosed tray and conduit must j
f' be used interchangeably in Figures 2 and 3 of IEEE-384.
This would further imply that enclosed tray affords the same degree of circuit protection (both internally and externally) as conduit.
l This is certainly not true for rigid. conduit which has:
1)
Substantially heavier gauge body than tray - providing a more effective heat sink than equivalent cross-sectional area of tray.
l' I
2)
Threaded connections providing essentially air-tight I
medium which inhibits internal combustion and effectively isolates internal events from the external surroundings.
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W.C. Dumper Memorandun,
(It.should be noted that a conduit system provides enclosure integrity far superior to an assembly of tray, sections Etr.ay., covers, solid bottoms.and_solice
, plates between sections.)
3)
Size typically -limited to 5" OD thus limiting both volume of cables contained and exposed surface area.
4)
Curved surface providing radial distribution of heat and much less favorable heat transfer characteristics to or from an adjacent tray than a flat surface of equivalent area.
Tha above features of conduit were considered in developing the required separation between open tray and conduit as shown in the separation criteria E-ES-100.
3b.
The statement in ES-100 permitting a conduit containing non safety-rela,ted cables to have a minimum separation of 1 inch from the top of an open safety-related tray does not violateIEEE-384 criteria for the reasons stated in item 2c previously.
T"he comment is made in ref. I that "In this case IEEE-384 requires cover on the tray, because both trains can affect each other due to the close spacing".
There is no basis however, to assume that circuits in a conduit can have any deleterious effect upon circuits external to it 1 inch or more away.
The results of the investigation
- conducted by NRC (subsequent to issuance of IEEE-384, 1974) to confirm the suitability of then current design standards and regulatory guides, are supportive of the judgements used in developing Conduit Separation Criteria for CPSES back in 1975 regarding self-induced fire effects on IEEE-383 qualified cables.
A3 Noteworthy are the results of cable tray fire tests conducted at Sandia Laboratories from 1974 through 1977.
Summarizing some of the findings in these tests:
1.
In electrically initiated fires, the intense period of the fire persisted at a particular location for between 40 and 240 seconds before die out began to occur.
In propane-
\\
fueled exposure fires, the minimum period found to consistently ignite a tray of IEEE-383 qualified cables was 300 seconds j
with die-out begining a,t about 400 seconds..
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W.C. Dumper 1
Memorandum -
4 1
i 2.
The luminous zone of the electrically initiated fire was optically thin which enabled immersed objects to radiate l
j heat to the cooler suroundings.
Thus equilibrium surface temperatures of engulfed' cylindrical objects varied from J'
about 1200*F just above the tray to 650* at a height of 10 inches.
Objects immersed in larger exposure firatare
~
more likely to reach temperature equilibrium with the l
flames (about 1900*F)..
3.
'In the electr,1cally initiated fire, cables in the tray 10.5" above the donor (fire) tray were exposed to a convective heat flux of about 6000 Btu /hr/ft2 which corresponds to a local gas temperature of=1000*F.
The circuits remained functional and samples of the insulation from the bottom of the tray over the fire zone which were given elongation measurements, showed less than a 10%
increase.
4.
In the electrically initiated fire, heat trans'fer to immersed objects is. convection dominated with radiation accounting for no more than 30% of the total heat flux, even in tne luminous region.
1 In the exposure fire, this heat transfer is radiat. ion dominated with convection accounting for less than 20% of the total heat transfer.
{
The above characterization of the electrically initiated fire
-vs-the exposure fire are important in this discussion because conduits were included during exposure fire tests.
In these tests, fourteen trays were stacked 10.5" apart.
Directly 1
above each tray within 10.5", a conduit containing additional cables was located (see figure attached).
No separation was i
j provided between any conduit and the bottom of the tray above.
Although all circuits in conduits above the third tray failed during the fire (the conductors short-circuiting.to the conduit or each other), circuits in the lower two conduits maintained circuit integrity throughout the duration of the. exposure fire.
considering that the fire in the lower trays was externally fueled and of longer duration than the electrically initiated i
fires, it provides a conservative worst case for discussing j
conduit separation requirements regarding electrical fires.
I I
t
- d W.C. Dumper Memorandum.
The G&H conduit separation criteria in question involves conduits traversing below or beside an open ladder tray of opposite train as shown below:
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CASE 1 CASE 2 CASE 3 In the above cases, the raceway orientation is such that the conduits are never engulfed in the flame or the convective heat flux from a fire in the tray.
As previously stated, the radiated heat transferred in the fire accounts for not more than 30% of the total heat flux.
tobeapproximately7000 Btu /hr/ft}hiswasshowninreference2 for a cylindrical ebject immersed in the fire.
In the above Case 1, the conduit is effectively shieldad from radiant energy by the tray side rail,.thus no appreciable conduit heating is anticipated.
l Case 2, has been conservatively simulated in the exposure' fire tests previously discussed.
The circuits in the conduit survived the broad exposure fire raging in trays directly above it in addition to the fully developed fire in the tray' about 10" below.
Case 3 is similar to Cases 1 and 2 except that the conduit rises above the tray side rail where it becomes partially exposed to the radiant and convective heat flux of a tray fire.
Considering that the conduit runs adjacent to (and not above) the fire, and is never engulfed in same, it is free to radiate heat away to the cooler surroundings virtually throughout its circurnference.
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Since the conduit is vertically oriented, convective heat transfer is essentially negligible and radiant heat flux would.
be significant only if the conduit came in contact with the fl 4
The following analysis will show that even if all the radiant energy of the fire were transferred to that portion of the con:
exposed to the fire, surface temperature would not reach 650*F.under worst case conditions, Since exposed cables of one train cannot run within 3' vertica:
4 of another train per IEEE-384, it can be very conservatively i
assumed that the minimum length of conduit will never be less t this distance.
Reference 2 establishes the time-mean height o:
theluminouszoneas5-7incgesabovethetrayandtheradiated i
heat flux as 7000 Btu /hr. ft Assuming this entire radiated heat flux were transferred to 501 of the conduit circumference (facing the tray) heat input rate.is given as:of 7" corresponding to the height of the lu q in = 7000 x
. 5 (9MP d) 7" Btu /hr.
]
2 i
144"/ft 1
Where d = conduit diameter (inches) 1 i
Since the only heat dissipation considered herein will be via convection to surrounding air, the worst case value of d is for the minimum conduit size.
has an inside diameter of /.05".Per NEC, a 1" trade size conduit the outside' diameter.
This will be assumed also for 4
Then q in = 7000 x
.08018 = 561 stu/hr.
i The heat dissipated to surroundings is given by:
s q out =
hA4T (ref. 4)
Where a T = difference between conduit surface i
temperature and surrounding air A = free surface area of conduit for convection h=C (A T) 0.25 for natural convection of solid surface in still ai i
i C = 0.4/.d 0.25 for ~ vertical pihes more t:
j 2 ft in length with diameter = d (inches) 4 e
i
.s W.C. Dumper Memorandum
- i Assuming:
q in = q out q in hAaT or A T = q in/hA
=
2 and A =
r7 d
[ 36"
.5(7")]
.744 ft
=
144 0.25 4'
h = 0.4 d
(A T) 0.25 0.395 (A T) 0.25
=
then A.T =
561
(. 3 9 5 ) (. 7 44 ) A T.'O. 25 ~ or AT1.25 1908.2
=
a.
and AT=
421*F Even in a 122*F ambient, the maximum conduit surface temperature would not exceed 543*F. (122 + 421).
This is well below the temperatures to which exposed cables where subjected (650*F) in reference 2 with satisfactory results.
The analysis herein -
is also extremely conservative in that conduit supports (and heat conducted to them).and radir.nt heat dissipation are i
neglecto.1, a continuous 7" flame is assumed adjacent to the conduit, and a conduit length of only 3' is assumed.
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G The item reworked, emergency light ESB1-41, was turned over to TUGCo on a circuit, not raceway, basis. Circuit acceptance includes wiring and e quipment, and is made at completion of light testing, where as raceway acceptance for the conduit and tray will be made at room turnover.
Since QC was performing post-inspection at the time the separation violation was identified, the raceway was not turned over to TUGCo. Rework of the conduit may be implemented either by authorization of a SWA or by in-process construction where such rework has been determined not to impact the circuit and does not require a SWA. The separation violation between ESB1-41 and C14K30975 documented above was so minute that a SWA was not needed for resolution. Observation of the conduits by the Engineer showed that rework of the ESB1-41 conduit in place would not affect the circuit integrity,and there is no evidence of damage to the conduit. Rework of this type does not consist of making a bend or offset in the conduit. Therefore, QI-QP-11.3-23, paragraph 3.1.g, does not apply.
The conduit is acceptable "as is".
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FTS 492-3939 1
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GIBBS & lit t L. lNC.
ENGINEERS DESIGt4ERS CONSIRUCTORS HE W YORK CLIENT IEXAS HIILI4PE5 SERVICES INC.
CABLE & RACEWAV SCllEDULE 2323-E'l-tTO0
__$iATION COM ANCllE F &'f*Hl&COM)_ ____ _.__
____,__j$$UE 326_
JOB NUMBER 2323A*
DATE 04/13/84 PAGE NO.
2.
I REPORT SECTJON-IlOT
~2^ M uiRODUCIORY REMARKS AM) CONVE NT IONS ANO GE NE R AL NO T E S NOT[
- 1. REFER G 2323-Et-17 GENERAL NOTES.
- 2. CABLE LENGilt5 s rw s rs t s 5CHE DUL E AR E SCALED LENGTHS & ARE NOT TO BE USED FOR CUTTING. ACTUAL LENG1HS SHAtt BE VERIFIED IN_Fl[tD_ bet 0RL Cu!!1 tag _______ ____
1 3.
All. CARLE DIAkETERS ARE IN INCHES. CROSS-SECTIONAL AREA IN SOUARE I NCi tE S AND WE I Gili S I N POUND S P E R F OO T.
4.
ALL LENGTH ME ASUREMENT S FOR CABL ES. CONDUITS. TRAVS. DUCTS, ETC. AND C00RDINAlf PolNTS ARE GIVEN IN FEET.(NOTE 16)
St_ POWER _ CABLE _talMBER$, ARE ARRANGED _FUNCJ IONALLY JH_ GROUPS OF NUMBERS BY_ygtlAGE L[ VEL & BV [90lPMEN{_BU$_p[$[GNATJON$.
6.
INSTRUMENTAll0N AND CONTROL CABLE NUMBERS ARE ARRANGED FUNCTIONALLY IN GROUPS OF NUMBERS BV PLANT SYSTEMS.
3
- 7. EACH CABLE NUMBER CONSISIS OF A MAXIMUM OF HINE ALPilABAIMERIC CHAR ACTERS.
EXAMPLE OF A CABLE NUMBER----EGl234568 U).IHE F[R$L_&_$((0ND_(HARAQiERS ARE ALPHARET]C__PR[flX(S_A%_{NUMERAT[D,gELOW FIRST EXPLANATION SECOND EXPLANATION PREFIR PREFIX CABLEC080R SAFEIV CLASS E
SAFEGUARD SYSTEMS O
ORANGE TRAIN A A
ASSOCIAIED WITH G
GREEN IRAIN 8
. pFgGugRD.$Y$1tM$
N NON-SAFEGUARD SYSTEMS K
BLACK _ _ _.
TRAIN C (COMMON FOR UNIT 4 & 2)
R RED PROTECTION CalANNEL I W
wt[TE -
_,PRQ!ECl19N_CIMNNEL_1]
B BLUE PROTECTION CilANNEL III Y
VELLOW PROTECil0N CHANNEL IV
__ NO T Q CAB ([$_ PREF [XED_yl))L*$P* ARE $ PAR LCAB(($_WHI H ARLQ1$ CONN (Gl[D AT B0]!t,ENO$_ AND REIl RED IN PL ACE a
(B) THE ilitRD CitARACTER IS A talMBER REPRESENTING PL ANT UNIT NUMBER l 9-UNIT t ; 2-UNIT 2 I O-COMMON)
(C) IltE FotlRTH THROUGil SEVENilt Cl4ARACTERS ARE BASIC CABLE NUMBERS 0000-9999
__(0 ).1 HLE ! Git!U_CitAR8CI E R _! $ A _ NUME R I G AL SU[ F [ X _ F ROM p !O_9. ADDE Q_A $_P AR { _OF_T HLE X P ANDE D_tJNI QUE_G AB L LNUMB E R (El iltE LAST CitARACTER IS AN ALPilA DESIGNATOR (fROM A 10 L OR F ROM 0 10 2) ADDED TO IPADICATE A BRANCH OR AN INTERRtlPTED CIRCUIT. 10 INDICAT E AN UtilNIERRtJPIED CABLE IHE LAST CHARACTER WILL BE M OR N.
_.__8 ABL{S Wlilt THE SAME PREFIXE$._SHALL BE RUN IN THE SAME RACEWAY ONLY WilEN THEY HAVE THE_$AH LVOL{ AGE F UNCT l9th u ( SEE REPORI a 10 )
- 9. CABLES WIIH DIF FERENT PREFIXES SHALL NOT BE RtWa IN IllE SAME RAGEWAY. (SEE NOTE to)
._ _to,_ C ABL E S Wi lle PRE F I N E S, { 0 & _A0_ ( E G, & AG)_AND_ STAVING THE _SAME RAGE WAY fuNCilot45 MAV,,RUN,{N_THE_SAME_RACFWAL BUJ_MAY NOT BE RUN IN IllE SAME RACEWAV WR Ill EG & AG (E0 & AOI PREFIXED CABLES.
St. FOR ApolTIONAL CABLE SEPARAil0N REQUIREMENTS SEE 'CRIIERIA FOR SEPARATION OF CLASS IE EQU!PMFNT AND CIRCUITS'
,DA!!D 2/83/75
- 12. CABLE TRAY RUN PAIMBER ASSIGNMENIS.
EXAMPLE OF TRAY DESIGNAll0N----T120SDA19 TRAY RUN CONSIST OF TRAV SEGMENIS. E ACit ' T R AV SEGMENT DESIGNATION !$ MADE UP OF HINE ALPHAPAIME RIC CHARACTERS
._.{!)_((R$T_CHARAQIER_I$_A lei!ER
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(B) SECONO CHARACIER 15 PL ANI LJNI T PAJt40ER I. 2 OR O (C) THIRD AND FOURill CIlARACTERS ARE RACEWAY FUNCTI,0piVP ODE CONSISTING OF A PAJMERIC VOLT AGE LEV L DESIGNATOR AND AN ALPHA SEPARAIION REQtilREME NT DE SIGNAT018 ($EE REPORI'lO hh (D) F IFilt CHARACIER DEN 0lE S IllE AREA CODE WitERE THE TWAYS' RE RtWa. ARFA CODE EPAIME RAIFO AS FOtt 0WS:
\\ ~ 1 AREA CODE LOCAll0NS 3,f
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C E L E CIRIC AL & CONIROL BillL DING D
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EIECTRICAt E Otll PME N T AREA (PART OF SAFFGilARD *"II. DING) r
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f (E) SIVill G SEVENIH CHARACIERS &%E ALPilA DESIGNAIORS (8tDal AA 10 22 ASSIGNED 10 E& Cit IRAV RtW i
(F
- LAST IWU CHARACB E RS ARE NUMe6ERS 5 R006 Os 10 ES DESIGNATING Ild END P24NIS FOR E Acit SEGMENI ON llE SAteE TRAY RUN 53.*ALL CONDuti RUN NugeBERS ARE ASSIGNED SV IHE COMPUIER.EACH SEGetENT RUN 85 ASSIGNED A IEN ALPHANuteERIC CHARACTER
- DESIGNAil0N.
(A) THE F IRST CHARACT E R I S THE L E l iE R
- C* F OR CONDut i
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_(9)JtM Igugitt.g_r gr yte.gHAReCIgR$ ARLRACggeyluuC11gg Numsgg5[ygtI Agtt[ygLa_MPegelIgM ggguiggongi$-MLe[Pgel}9)
- (E ) THE LAST FIVE CHARACIERS ARE UpslQuf NuBGERS (00000 99999)A5 SIGNED SV IHE PROGRast SEQUENilALLY AS THE SEGNENIS ARE
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INPUTIED CONgu1 L { {Ngitt$. AND_[.L g X tet L [ND1_ptgyN ARL[0R_eu g pAsegtgN(L,_$ { iLR[gq[g_[M[NL$NA(L}jgy[y[I!,g[ { [R8[jNL]tjE AC lugh
- i CODeuli LENG1H AND THE NO. & LENGTH OF FLEX ENDS REQUIRED.
j-Q
- 14. EQUIPteENT DESIGNATIONS CONSIST OF NINE LETTERS asAXiseugt.THE DESIGNATIONS CAN BE DERIVED Frost IleREE SOURCES AS
's
_[9t(OW$ L _.._________. ___ _ _____.
[
(4) FR000 THE EQUIPteENT PW64 SUS DESIGNAil0NS - SUCH DESIGNAllONS APPLY 10 ALL POWER SWITCHGEARS.SWiiCimOARDS.000 LOR CONI '
4 CENIERS.DISTRieluil0N CENTERS & PANELS. EXA84PLE X84-3-04 & M84-3-lO DEMOIE leCC sus X84-3 FR48et NO.4 & No. AO b
_. _ _.11 tit.1 E RM f g Aaeg M N0; g 1, 6 V[ g I ; C eL M G { j 0N ) _,_,_ _,_,_ _ ___ _ ___[__,____ __, _ ___ ___ _ _,,.., _ _, __, __ _,, _,, _ _, _ _ __,
ii,
(0) FRose THE SPIM NueeBER OF IHE E0ulP90ENT (SASED UPON WESilNGHOUSE SPIN Nuge8ER SVSIEN USING 83 LEllER SPACES) p'*.s
, _ _ LEIIEB_1PeCils___ _ ___._.- _____
(E XA8ePL ES:_ _ _ _. _ _ _MSE-Os & ESE DESIGNAil0NS ASSIGNED NOTE THE FIRST & SECOND LETTERS AND ALL HVPHENS IN THE SPIN NO. ARE 0088 TIED. REDUCING EQUIPteENI DESIGNAil0N TO NINE i
L (C) FRoot OTHER T AGGING SYSTEles AS USED IN MISCELLANEOUS EQUIPteENT 10 E0ulPteENI PURCHASED SV DittERS IN teAINIENANCE SulLDING)
O
_ _Ilif 00.WEHINGtIOU$L$P)M.$[$1[00_M[,)fP{;jl4.ge((g_g-39-]}JL19_SEE_d98_2123_ELEG etEltG_t9tLieGGINg_Df_p9P_111-8-73).
I
(
- 13. THE PROGRAte USES A SPATI AL COORDINAIE SYSTE8e 10 LOCAIE CASLE ORIGINS & DESTINATIONS AS WELL AS RACEWAV NETWORe(
SE GesE N T S.
(USERS ARE CAull0NED 1 HAT COORDINAIE LOCATIONS ARE NOT EXACT INSTALLATION PARA 8eEIERS SUI A Gul0E 10 i
efePOM I NA I LL OGeI l0NL _ [gR Q[ { A J L [g_[ OQ4{ { gN, )N[geseA.JjgN_UM65, AglR(([R[g_ Jg_ It4[ APPL IGeg(Le(([g[NGLQgeglNQ1)
'l THE SP4flAL C00RDINAIES CONSIST OF 1HREE DlIIENSloNAL seEASUREleENIS.1HE THREE DI8eENSIONS ARE: X (ACTUAL ELEVAllON).
4-
-Y (DIST ANCE E AST OF CABLE SCHEDULE BASE LINE V*0). & 2 (DISTANCE NORIH OF CASLE SCHEDULE BASE LINE 2*0). THE X. V.
Z
] S l eCei. e_[OuR_g l G [ L _ NUMM g, AND_ ((M _ lNCH[M[ N[ _ g[, II[ g $UR[Mt ML l1J ' -OL______
l THE ORIGIN (Y*0.2=O) OF THE caste SCHEDULE COORDINATE SVSTEtt IS LOCATED AT E5600 & N4708.5 __
- 87. CA8tE TAME-OFF SEGetENIS ON CASLE TRAVS ARE SELECIED SV C000PUTER BASED ON SPAll AL COORDINATES ASSIGNED FOR CASLE E M! g4NCE_e!@_ [!! L _ IHE SE__1PA l [ AL $9999{ NA s [ $__AglUMg,[gR_ GgeIPg{ [6_lNPg [ gN(L8HD,99_NgLGgN$ [ { {gl[ A R ACE WAY INSTALLAll0N REQUIRE 8eENT. AS SUCH. THERE WILL BE INSTANCES WHEN CABLE TAME OFF FROtt IHE TRAY SEGIGENT IDENilFIED ON IHE CA8LE PULL CARD WILL N01 seAICH THE PHv51 CAL. INSTALLATI0$f. THEREFORE. CA8LE ROUilNG WILL BE C00ePLIED WITH IF THE IN11ALLgg Rgu]L1LIN_4GggegANgtygIU_Juttgttgvitegt_ _ _._
A.) IF PHYSICALLV. THE CASLE EXIIS BEFORE 1HE SEGMENT.NUIESER CALLED FOR IN CABLE PULL CARD: ilWN THE CABLE PULL CARD NEED Noi BE REVISED.
ad_l L EttY11 gel LL _ IHLCAM E [ M [ { $ _ e[ { [6. {teL $[Gae[ N[. [ 5 l Lj g[NJ ((j [p, _jfL]lg _g Ag(lpg (( C ARD;,{ H[ _ G A81[Jun C ARD SHALl. BE REVISED TO INCLUDE ADDill0NAL TRAY SEGNENIS.
C.) iltE ACCEPTI8LE RANGE OF'ANY NODE NueeBER SHALL INCLUDE ALL OF THE 1 RAY LOCATED BETWEEN THE CENIERS OF ADJACENT
._. tauDgh D. ) SINCE A T F i l f lNGS SUCH AS T E E ' S Am X 's, teuRE THAN 1 NODE NUseBER APPEARS. PULI. CARDS NEED Not SE REVISED AS LONG AS AT LEA $i DNE OF THE NODE NupeBER APPEARS ON THE CABLE route.
_ l'A !dgLgMD, a
- 43. 10 CDeePLEIE CABLE NUseBERS IN Il4E CA8LE NO. INDEX(RPI 5):
- 8) ADD A SUFFIX 0 10 IHE LOWEST INDEX BANGE No. SHDWN l
2)_AgD,4_ $g((15 9, {0,!!IE._H!Get[$ijfeE!_ RANGE.N0u$4tDyeL____ *
- '20. CA8tES AND RACEWA%S FOR IHE FOLLOWING SYSTEteS ARE NOT INCLUDEO IN THIS SCIIEIMM E:
.A)LIGHilNG SYSIEN (t!)CAlts00lc PROIECI!ON (C)llE AT IRACING (D) PLANT & EQUIPfeENT GROUNDlHG.
_2L_yH[RL {s g_CA86 L AND, gACE WAY.$C5400t E OR, tef ou{ _gegylNQ. ]tdDIG A { { $,6_ QNDyj [.[gNN[Q{ J ON, S(( W((N. $ _MGae[N{ _g[,l ggL lN _j CASLEROUTE AND A SWIICHGEAR. SeCC. PANEL. OR RACK. THE FBELD 8eAV SELECI ANT OF Tite OPil0NS DEPICIED IN " DETAIL 25' ON DRAWING 2323 El-1702.
IF A CA81E AIR DROP 15 Uit t l2ED. THE CONDUIT NUseBER ASSIGNED 10 THAT COF m 2 "*
IM.((t[ onePul[Rl2[D CABLE Asa! RA [WAY $Gt4DU[E.$11ALL SE APP [ l[R.10_{t_e[ C0f0U { I, $ { US,,8U$41[NQ,. O ((PR [ _ A l { Apl_0[D, IHE E00*P94ENT.
SEPARAllON OF DISSibellAR 1 RAIN ANU/DR CllANHELS 80UST BE 80AINI AINED PER SPECIF ICA ON 2323-ES-LOO.
- 22. FOR LISilNG OF CARIES REVISED BY FIELD DESIGN CllANGE AUHIORIZAilONS (DCA*St. IllE REVISION CODE Of CABLE PULL.
. __ e8E.GGE R ( [ONNECllON SIGN-OFF,CARU$. R[F[g[NC[p lN, {HE pCA., AND,jH[,9CAf $, AF[EC{ jNG E AQH_ QgHL[
M[, REPORL w m,
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-FOLDER NO.
80 Draft No.
Date COMANCHE PEAK ALLEGATION WORK PACKAGE
- ELECTRICAL Category I-Improperly Installed Electrical Components X-3 s-sin Ct.te.rsa V. o IskS!.
AC - A } ^U ~
Allegation Numbers:
E j D? As -s Statement of Allegation: Electrical allegations - construction concerns.
Group I Electrical component installation deficiencies AE-13, AE-14, AE-16, AE-17.
Group II Electrical separation criteria AE-15.
Reference Documents:
Refer to CP allegations chart and statement of allegations from source documents attached.
78 *^-'c
' '" - " ** ^^
Source of A11sgation:
Refer to CP allegations chart attached I
Date Received: 1979 - 1983 The above information prepared by D. M. Hunnicutt 6/6/84 Name Date Group Leader.
Name Date Assigned Team Members Date Assigned Date Assigned Date Assigned 6
Date Assigned j
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Date COMANCHE PEAK ALLEGATION WORK PACKAGE NCde.
- (AtG,
QAmr rm+ yy L Adherence )to Procedures 3
Allegation Numbers: AQ-28, AQE-30, AQO-2, AQO3, AQO-16,r-4GQ-17, AQO-18, AQO-19, AQO-20, AQ0-23, AQO-29c, /A0E-6, MQB-1, AQ-52, AQ-61, AQ-78, AQ-79 Ul D\\AA/
Statement of Allegation: Safety-related work activities were not conducted in accordance with specifications, industry standards and QC/ construction procedures in the following areas: weld repair, coatings, automatic welding with Dimetrics machine, electrical, Hilti bolt documentation, out of round pipe repair, valve maintenance, procurement orders to fab shop, inspection hold points, and general disregard for following procedures.
Reference Documents:
See source docum'ents marked on attached pages from allegation ~ list.
Source of Allegation: Various allegers - see allegation list Date Received: Various The above information prepared by H. S. Phillips.
6/6/84 Name Date Group leader Name Date Assigned Team Members Date Assigned Date Assigned Date Assigned Date Assigned fh
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COMANCHE PEAK OPEN ISSUE ACTION PLAri Task:
Ref. No.: AQ-28, AQE-30, AQO '
003, AQO-16, AQO-17, AQO-18, AQO-19, AQO-20, AQO-23, AQO-29c, QE, QB-1, AQ-52, AQ-61, AQ-78, AQ-79 Characterization:
k 1.
Craft would satisfy a component fication card (CMC) on an inadequate weld by welding over it instead of cutting its defects out per procedure.
2.
Safety-related welds were repaired with weld tech (W.T.) holdpoints instead of QC holdpoints in violation of procedures.
3.
There are various technical and procedural problems in coatings QC dept.
at CPSES.
4 Coating dept. supervisors are not properly implementing QC procedures.
5.
The supervisor of the paint QC dept. gave verbal instructions to perform' inspections at "an arm's length" instead of performing visual inspections (close to the paint surface) as required by QC procedures. This inadequate inspection will cause inspectors to accept substandard coating work.
6.
The same supervisor in 5, above, forced.QC inspectors to allow painting operations to continue even though it was not in accordance with procedu'res.
7.
Inspection acceptance / rejection criteria for inspecting "backfit coa' ting" operations were vague.
J 8.
Numerous design change authorizations (DCA) have been issued to downgrade l
the surface preparation requirements from SP10 to SP6; i.e., nuclear standard to heavy industry standard surface prepasation. Management allows SP6 requirements to be downgraded by allowing DCA to be dispositioned "do the best you can" in areas where access is difficult. Note: NRC CAT team did an extensive review of DCA system.
9.
DCAs are also written to deviate from AS 31 specs. At least 40% of the DCAs are nonconforming condition.
- 10. There are problems regarding the calibration of the Dimetric automatic welding machines.
- 11. The CPSES coating program does not satisfy ANSI 1.014 requirements.
- 12. A QC superviser repeatedly told QC inspectors to violate inspection procedures; do not do in-process inspection; OC buvino off terminatinne w we_not in accordance with crocedures/drawinos, 13.
Inspection.qf_Hilti bolt documentation packages may have been approved d vf ji despite inspectors recognizing that the documentation package does not b/
conform to CPSES procedures.
- 14. Out of round pipe was heated and reformed with engineering authorization
'and/or procedures.
- 15. Valve maintenance (i.e. disassembly-reassembly) was not controlled and parts of diff'erent valves intermingled making material traceability invalid.
- 16. Supervision advocates following proc.edures until "we get in a jam where something is holding up something and we want something welded immediately,..., then go ahead and weld it cut of procedure."
- 17. There have been improper sign offs on " hold points" on travelers.
- 18. Craft by passed _ procedures by telephoning orders to the fabrication shop in lieu of sending drawings.
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Initial Assessment of Significance: The disregard for fellowing procedures concerning work activities described in the previous paragraph pertain to work that.is safety related.
The degree of safety significance would depend on the system and location of weld for example inside or outside containment or primary coolant versus secondary piping, etc. The same would be true for coatings, terminations, Hilti bolt, pipe reforming, and unauthorized purchase of materials.
It appears that several of these items have potentially high safety significance if procedures resulted in defective sys*ams, parts, components, or materials.
Source: Various allegers. See allegation list'.
Approach to Resolution:
1.
Review background material referenced in the allegation list.
2.
Review project procedures index to determine applicable specifications and procedures.
3.
Review applicable procedures.
4.
Interview a sample of QC, engineering and construction personnel responsible for implementing the applicable procedures. Also coordinate with team member the task No. f_or AQW-10,15. aM 1 5.
Examine the specific work activities in progress (if possible) to determine if procedures are followed.
if procedures are routinely followed. Select one or two other areas to determine 6.
Refer any examples of wrongdoing to the TRT manager.
7.
Evaluate tha allegation for generic / safety implications.
8.
Report on results of review / evaluation of allegations.
Related Open Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
from the tracking system open item list.
to this work package.)
(Region IV identify and add 2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
3.
While performing physical inspections above, examine surrounding systems, components, and structures for related apparent defects or indicators of faulty workmanship.
' 4.
If workmen are still in the area of a physical inspection, interview them for any knowledge of other potential deficiencies.
5.
Complete po-tion of IE Modules pertaining to welding, coatings, Hilti bolt, valve maintenance, misuse of DCAs versus use of NCRs, elec*rica_1 terminations, unauthorized purchases, and heating /refo,rming of piping,
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1-Status:
Review lead:
Support:
Estimated Resources:
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CLOSURE:
Reviewed by:
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EIS activities involving inspection and testing raise substantial ieu[
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questions as to the adequacy of construction?
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A.50.
(Taylor) No. Considering the nature of the findings and the Applicants' corrective actions, these findings do not raise sub-stantial questions as to the adequacy of construction.
[Q.51.
In addi. tion t6 the routine inspections described above, did the NRC staff conduct investigations of allegations of improprieties in construction activities involving inspection and testing?
Yes. The NRC staff conducted an investigation of j
A.51. j(,aylor) allegations-that might be assignable to this area of Contention 5.
The investigation was documented in t @ _e_q. tion Recort 81-04 and involved allegations that ele _ctrical inspectors were directed byJeir supervision not to follow procedures; that electrical inspectors had not performed required inspections; that certain electrical inspectors were not qualified to do the inspections to,
whicitthey.were assigned; and that electr.ical drawings utilized for inspections were, in some cases, obsolete.
Q.52. What were the results of the investigation?
A.52.
(Taylor) None of the allegations were substantiated.
The investigation did reveal that one of the QC senior sup 1 sors for j/ {'
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Oo the routine inscection findings concerning construction f.
activities involving ins.pection and testing raise substar,tial b--
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questions as to the adequacy of construction?
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No. Considering the nature of the findings and the
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Applicants' corrective actions, these findings do not rai
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se-sub-stantial questions as to the adequacy of construction.
' Q.51.
> 2-In addition t6 the routine inspections described above
, did the i
e NRC staff conduct investigations of allegations of impro j ;
prieties in construction activities involving inspection and testin j
i A.51.
( aylor)
Yes.
The NRC staff conducted an investiga' ion of I
allegations that might be assignable to this area of'Cont n 5.
The investigation was documented in NRC Inspection R eport 81'04 and involved allegations that electrical inspectors were d by their supervision not to follow procedures; that el e
e trical inspectors had not performed required inspections;'that certain electrical inspectors were not qualified to do the inspectio ns to which they were assigned; and that electr.ical drawings ut zed for inspections were, in some cases, obsolete Q.52.
What were.the results of the investigation?
i A.52.
(Taylor)
None of the allegations were substantiated The investigation did reveal that one of the QC senior s upervisors for (LO
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jpg5-4 U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Investigation No. 50-445/81-04 50-446/81-04 Docket Ncs. 50-445; 50-446 Licensee:
Texas Utilities Generating Company
~
Facility:
Comanche Peak, Units 1 and 2 Investigation at:
Glen Rose, Somervell, County, Texas
- Investigation conducted:
February 25-27 and March'9-13, 1981 M
9-?_t-%I Investigators:
Date
- 0. D. Oriskill, Investigator Investigation and Er.forcement Staff
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Date R.'
K. Herr, Investigator Investigation and Enforcement Staff Inspectors:
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f L. E. Marti, Reactor Inspector
'/ Date Projects ction No. 3
> h Date R. G. Taylor, Resident Reactor Inspector rojects Section No. 3 i
U II Reviewed by:
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Date*
J. NE. Gagl\\ardo, Director Ir.vestigatifon and Enforcement Staff Md NNcbu--
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j Approved by:
Date J
G. L. Madsen, Chief Reactor Projects Section i
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Summary Investigation on February 25-27 and March 9-13, 1981 (Report No. 50-445/81-04; 50-446/81-04)
Area Investicated:
Allegations were made that a Comanche Peak Steam Electric Station (CPSES) Brown and Root, Inc. (B&R),, Quality Control (QC) supervisor repeatedly told electrical QC. inspectors to violate inspection procedures; that a QC supervisor told electrical QC inspectors not to do required in process
' inspections; that electrical QC Department blueprints are not always of the current revision; that electrical QC management is " tight with the craft" due to their being sympathetic to production management needs; that some electri QC inspectors are inadequately qualified ~and have been helped to pass certifica-tion test; and that scme electrical QC inspectors have " bought off" electrical terminations in nonconformance with drawings.
Another allegation was received stating'that pipe hanger packages are being divided making final QA reviews inadequate. This investigation involved 154 investigator / inspector man-hours by two NRC investigators and two NRC inspectors.
Results:
Personal intersiew of the source and numerous interviews of electrica'.
QC personnel disclosed no instances wherein-the QC Supefvisor allegedly instruct electrical QC inspectors to violate procedures or not to conduct required in-process inspections.
Interviews disclosed that the electrical QC Department blueprints are only rarely found not to be of the current revision and no extended delay or nonconformances relating to blueprints, were identified.
Numerous interviews of electrical QC inspectors disclo, sed a unanimous cpinion that they possess independence in conducting their duties without pressures from either QC or production management.
In depth investigations of qualifica-tions of some electrical QC inspectors identified none who were unqualified for their position; however, examination.of the certification tests for one electrical QC inspector disclosed that the electrical Quality Engineer con-ducting the examination had deleted several' incorrectly answered questions from the test, which resulted in a passing grade for the inspector vice a failing grade.
Numerous interviews identified no instances wherein electrical terminations were intentionally " bought off" 'in nonconformance with drawings.
Investigation disclosed that pipe hanger packages were formerly divided and filed separately; however, the packages have recently been combined eliminating the admitted inconvenience factor in their final QA review..
During this investigation it was identified and confirmed that a member of QC management was prohibiting QC inspectors from obtaining NCR numbers in order to insure that all NCRs were brought to him for approval prior to being issued.
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3 INTRODUCTION Comanche Peak Steam Electric Station Units 1 and 2 are under construction in Somervell County, Texas near the town of Glen Rose, Texas.
Texas Utilities Generating Company (TUGCO) is the construction permit holder with Brown and Root Incorporated as the constructor and Gibbs and Hill Incorporated (G&H) as the Architect / Engineer.
REASON FOR INVESTIGATION On January 23, 1981, Individuals A and B were interviewed by a member of the NRC Region IV staff regarding their expressed concerns relating to alleged procedural violations in the B&R electrical QC Department at CPSES and relating to review of pipe hanger packages at CPSES.
SUMMARY
OF FACTS On January.23,1981, Individuals A and B were interviewed by Mr. R. E. Hall, Chief, Systems and Technical Section, Engineering Inspection Branch, Region IV, Nuclear Regulatory Commission, at which time the following safety related concerns were identified:
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A QC Supervisor has repeatedly told electrical QC inspectors to violate inspection procedures and once stated " don't worry about the flowers in the trees," which was interpreted to mean don't reject on looks alone.
A CL G -7 2.
A QC Supervisor instructed electrical QC inspectors not to do in process inspections, but only to inspect completed work, which is contrary to procedures.
2, (_
3.
Field copies of blueprints used by the electrical QC department for inspections are not always of the current revision.
gg _1I 4 Electrical QC management is " tight with the craft" as a result of their being sympathetic to production management.
l} 1 6 J 5.
Some electrical QC personnel are inadequately qualified; were helped to pass certification tests and their experience requirements were " pencil whipped."
Electrical terminations were'being made and " bought off" by some electrical QC personnel, in nonconformance with drawings.
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Construction and inspection records relating to some pipe hangers are being separately maintained resulting in their final QA review being inadequate.
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Persons Contacted Licensee Employees 4
J. Hawkins, Project QA Manager, TUGC0
- R. Tolson, Site QA Manager, TUGC0
- D. Chapman, QA Manager, TUGC0 "J. Ainsworth, QE Supervisor, TUGC0 Other Persons Contacted Individur.ls A thru X
- Denotes those attending exit interview.
2.
Investigation -of Allegations Allegations No.1 A QC Supervisor has repeatedly to'd electrical QC inspectors to violate,
,.,Q inspection procedures and one; s+ated " don't' worry about the flowers q6 in the trees," which was interpreted to mean don't reject on looks alone.
Investigative Findings _
On February 24, 1981, Individual A was interviewe'd.- Indiv e' dual A stated it was his opinion that an electrical QC Supervisor, Individual C, en-courages electrical QC inspectors to overlook certain safety-related aspects of their inspections.
Individual A recalled one occasion when Individual C made statements to the effect of " don'.t reject on looks alone' and " don't worry about the flowers in the trees," which Individual A statec he interpreted to mean the inspectcrs should not find fault with the
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work they were inspecting. Individual A was unable to provide any specific instances when Individual C explicitly told him or another electrical OC inspector to violate a specific procedure.
Interview of Electrical QC Insoectors l
Between February 25, 1981 and March 12,'1981, Individuals 0 thru K were individually interviewed concerning various aspects of their employment t
as B&R electrical QC inspec' tors.
Individual D recalled one instance wherein an electrical QC Supervisor, Individual C, stated "I know what j
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the procedure calls for'and I'm telling you to do it this way."
Individua D stated this comment was made when Indivudal C was being questioned l
cancernino inspection of cable separations.
Individual D also added that electrical cable separation has presented _a _long term problem and that about three months ago their requirement to docun.entla'ble'~ '
separatio'ns, as suitable or otherwise, _was deleted from the electrical
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QC inspection form and an alternate avenue Tof documenting unsuitable cable separations was initiated in order to avoid the submission of "unsatisfactor; inspection reports" when cable separation Vere the only area of noncomplianc-Individual D was unable to identify any other occasions when he believed that Individual C had instructed or inferred that a CPSES procedure be violated.
When interviewed Individuals E, F, G, H, I and J, each stated that Individual C's comments regarding " flowers in the trees" and " don't reject on looks alone" were interpreted to mean the inspectors responsi-bility is to ensure the quality of the specific task conforms with procedure and that the individual inspectors should not impose his/her own subjective criteria, regarding appearance, on task they inspect.
Individual K stated he had not given consideration to the specific comments, made by Individual C, and did not know what they meant.
None of the foregoing individuals supported a contention that the electrical QC inspectors were either directly or by inference directed to violate any procedure or limit the quality of their respective inspection duties.
Interview of Former Electrical OC Inspectors On March 9,1981 and March 11, 1981, Individuals L and M, respectively, were individually interviewed.
Both Indiviudals L and M stated that they interpreted Individual C's comment regarding " flowers in the trees" to mean that their inspection responsibility was limited to the safety-related aspects and adequacy of the task being inspected.
Neither Individuals L or M recalled an instance wherein they were instructed to disregard compliance with CPSES procedures.
Interview of Electrical QC Supervisors On March 12, 1981, Individuals C and N, both electrical QC supervisory personnel were individually interviewed.
Individual N stated Individual C's comments regarding " flowers in the trees" meant inspection should con-centrate on the safety-related functions of items being inspected and not nonsafety related aspects of the system or components which was not a part of the respective inspectors responsibility to inspect.
Individual N stated no comments'made by Individual C should have been interpreted to mean a procedure should be violated. When questioned concerning his alleged past statements " don't reject on looks alone" and " don't worry about the flowers in the trees," Individual C corrected the latter to " don't worry about the flowers and the trees."
He stated these comments were directed to some electrical QC inspectors who were frequently finding nonsafety-related problems in areas of their inspections.
Individual C stated that he was not aware there had been any misinterpretation of his statements and said "perhaps I didn't choose my words carefully enough." He said he had meant, by these statements, that inspectors should not apply their personal standards to a condition in order to reject it, if, in fact, it meets the required specifications.
Individual C also stated he frequently made comments to intpectors O
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6 such as "you're not designing this place" when their criticism of an item took them outside the scope of their inspection responsibility.
Individual C stated he never knowingly instructed anyone to violate a CPSES procedure. /
Allegation No. 2 A QC Supervisor instructed an electrical QC inspector not to do in process inspections, but only to inspect completed work, which is contrary to pro-cedures.
Investigative Findings On February 24, 1981,. Individual A was interviewed and stated it was his opinion that Individual C discouraged electrical QC inspectors from performing the procedurally required in process inspections.
Individual A stated that a rumor exists within the electrical QC Department that one QC inspector was fired for doing "too many in-process inspections" and other QC_ inspectors are now usina that as an excuse for not doing in process inspections._ Individual A could provide no information reian;ng T.o~ specific i W ces wherein the Supervisors told inspectors not to do in process inspections.
Individual A further stated that Individual J was known to rarely cohduct in process inspections and had been heard to say "they take too long and they are boring.". Individual A stated CPSES procedures require each inspector to conduct a minimum of 10 in process inspections per day.
Individual A stated that Individual J had probably never con-ducted 10 in process inspections in a single day..
Interviews of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were individually interviewed.
Individuals 0, E, F, G, H, I and K each stated they regularly performed in process inspections during the course of their duties.
Individual J related that in process inspections are "too time consuming and they are boring."
Individual J admitted avoiding in process 1
inspections whenever possible, but stated in recent weeks everyone conductir termination inspections has been getting to do a lot of in process work.
Individuals D thru K uniformly stated that they had never been instructed by Supervisors, not to conduct in process inspections nor had Supervisors ever disco 6 raged their conducting in process inspections.
Individual G i
related that his understanding of CPSES procedures required that the electrical QC Department conduct a total of 10 in process inspections per day; however, there was no requirement for a specific inspector to conduct any required number of in process inspections.
Interviews of Former DC Inspectors.
On Mcrch 9, 1981 'and March 11, 1981, Individuals L and M respectively, were individually interviewed.
Both stated that when formerly employed in the electrical QC Department they each regularly performed in-process l
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inspections and neither recalled having ever been discouraged from, or
_ instructed not to do in process inspections.
Individual L explained i
that during 1980 the electrical QC Department had many more terminations inspectors than now employed, due to the larger quantity of terminations being done.
Individual L stated some of these inspectors did numerous in process inspections during each week day while other inspectors were
" lazy" and did very few, if any, in process inspections.
Individual L stated that he believed this disparity in total individual productivity, as well as with in process inspections conducted, created some resentment towards several of the less motivated inspectors.
Individual M also related that some termination inspectors, whom he did not identify, were
" lazy."
Interview of Electrical craft Supervisor i.
On March 10, 1981, Individual 0, an electrical craft supervisor, was inter viewed.
Individual 0 stated some termination QC inspectors had worked cic with the. electrical termination department and had conducted numerous in process inspections of work performed by'his personnel.
He stated othe QC inspectors were not particular1,y responsive to the needs of his personc and that he had heard criticism regarding some QC inspectors who would, or many occasions, make excuses or refuse to conduct in process inspections.
Individual 0 stated he never heard nor had any indication that electrical QC Supervisors had instructed their personnel not to conduct in process inspections.
Interviews of Brown and Root (B&R) Electricians On March 9,1981, Individuals P and Q were individually interviewed con-cerning their knowledge of in process electrical QC inspections.
Irdividual P stated most electrical QC personnel are not reluctant to cc.iduct in process inspections.
Individual P identified Individual J at having refused, on numerous occasions, to conduct in process inspectior stating "it is boring."
Individual Q also_ identified Individual J as the only electrical QC;ir.soedor_ he__ knew whofhideo or r'efus.ed,, facts
.to conduct in process inspections.
Neither P or Q were aware of any
~whTchTould indicatFeliidtFiYaTQC inspectors had been instructed not to conduct in process inspections.
Interviews of Electrical QC Supervisors i
On March 12, 1981, Individuals C and N were individually interviewed.
Individual C stated.that the' electrical QC Department is required by procedure to conduct a total of 10 in process inspections each day.
i Individual C stated the purpose of the in process inspection is to sample the-work of various electrical deparment craftsman to ensure they are doing the work properly.
Individual C stated that during the past year the electrical QC Department has far exceeded the required number of in process ' inspections daily.
Individual N also stated.the P
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Both Individuals C and N stated they have never told inspectors not to conduct in process inspections nor have they ever discouraged the inspectors from conducting in process inspections.
Allegation No. 3 Field copies of blueprints used by electrical QC departments for inspectior are not always of the current revision.,
Investigative Findings On February 25, 1981, Individual A was interviewed.
Individual A stated that during the course of the last year, on several occasions, blueprints obtained from the electrical QC Department, for use during inspections, ha-not been of the current revision.
Individual A stated this problem never 4
resulted in an inspection being done improperly.
Individual A was unable to identify any specific date or blueprint associated with this problem no was Individual A able to identify any other inspectors who were aware of this problem.
i Interview' of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were L
individually interviewed.
Individaals E, F, H and J related they had never identified a blueprint, they were using for inspection purposes, as being out-of-date.
Individual D stated he had,.on several occasions, identified blueprints as being out-of-date; however, the problem was quickly resolved.
Individuals G, I, L and K indicated they had identified blueprints as being not of the current revision on several occasions and it had created no problem for them during the course of their inspections, as the proper blueprint was readily accessible.
None of these inspectors indicated that a problem with blueprints leads to a QC inspection being improperly done.
Interview of Electrical QC Suoervisors i
On March, 12, 1981, Indivudals C and N were individually interviewed.
Individual C stated that during a short period in 1980 the electrical QC Department had received revised blueprints approximately one day later than the. electrical craft department due to hand delivery.
Individual C stated that upon notifying the B&R Document Control Center of this problem it was quickly resolved.
Individual C stated he was aware of no problem, created for the QC inspectors by out-of-date blueprints, aside from the inconvenience of having to obtain a current revision.
Individua' i
N stated that on rare occasions the electrical QC Department does not have the current revision of. a particular blueprint.
He stated this i
l problem -is always resolved quickly and to' his knowledge has never created i
l' an inspection problem.
Individual N additionally stated that an audit of l
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the electrical QC Department blueprints is conducted every three months and rarely is any problem ever identified.
Allegation No. 4 Electrical QC management is " tight with the craft" as a result of.their being sympathetic to production management.
Investigative Findings on February 24, 1981, Individual A was interviewed.
Individual A stated tt it was his impression that Individual C is overly sympathetic to the needs of production management and that this may contribute to a compromise of Quality Control inspections at CPSES.
Individual A related, as an example of this, G requently encountered M Ao nroblem-relatina to se taration requirements for safety-related cables coina to the CPSES control room.
[ Individual A stated QC inspectors had been required to prepare two ' separate inspection reports regtedina some cables on which the required Sarat{on
.,had.aot been met.
Individual A stated that when QC inspections of cables l
were conducteWnd.all aspects were found to be acceptable, with the exception of separation, two reports would have to be prepared.
One report would document the inspection acceptability of the cables and/or terminatic and a Qarate report would be prepared documenting that the reauirTd s"E6ar
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tio had notTeen.4--L 6J5ual A statec this was obviously being done t preclude 'tne separation aspect being the basis for an unsatisfactory inspection report for the cable as a whole.
Individual A stated that he felt this policy was the result of an informal ag'reement between Individual and-production management.
Individual A was unable to cite any additional examples of Individual C being sympathetic to production management needs.
Individual A agreed that, insomuch as the unsatisfactory seoaration con-2 ditions were documented and must be addresself,~no further safety-related priiblems are ineiy T.o occur.
Interview of Electrical QC Insoectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were individually interviewed concerning their independence as QC inspectors ll and the possibility that quality may be compromised due to management being sympathetic to production needs or requests.
Individual D related 4
that on several occasions he has overheard members of his Department, whose identities he was unable to recall, relate instances wherein Individual ~C had told them to ease-off on some inspections to avoid conflict' with the craft.
Individual D stated he had no personal knowledge of this having occurred.
Individual D stated he felt totally independent in conducting Quality Control inspections and believed he was supported by.QC management to the fullest extent in his decisions.
Individuals E thru K al.so stated they felt totally independent in their Quality Control evaluations and believed they had the full support of other Supervisors with regard to decisions they made.
None of these Individuals recalled having ever personally been asked to " ease off on inspections" nor did they believe that electrical QC Supervisors are sympathetic to' the needs of production management when quality might be adversely affected.
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Individual C stated his Supervisors allow him the independence and latitud to manage his. Department as it should be.
Individual C stated he maintain a good relationship with Craft Supervisors however, his primary goal is to ensure that the Quality Control objectives at CPSES are achieved.
Both Individuals C and N stated they were totally independent from craft pressures and that they had never been pressured by their own Supervisors or production management to compromise Quality Control standards.
i (Investigators Note:
While conducting the foregoing facets of this investigation a possible noncompliance with CPSES procedures was identifie relating to NCRs, within the electrical QC Department.
Investigative finc concerning this matter are contained in this report.)
Allegation No. 5 Some electrical QC personnel are inadequately qualified; were helped to past the Certification Tests and their experier.ce requirements were "gencil whipped."
I vestigative Findings On February 24, 1981, Individual A was interviewed.
Individual A stated that several persons working as QC inspectors in the area of electrical termination were not qualified for their positions when they began working as QC inspectors.
These persons were identified as Individuals H, I and J.
Individual A stated none of them had prior electrical or construction experience, therefore the experience portion of their applications'must have been " pencil whipped." (Falsified to document them as having a certain degree of experience.)
Individual A related that Individual I has worked hard and would probably now be qualified, due to the experienci level achieved.
Individual A related having heard that Individual J got hired as a QC inspector due to Individual's C being a close friend of Individual J's brother.
Individual A stated numerous other persons emplo; i
as electrical QC inspectors and also some electrical craftsman concurred in the aforementioned -evaluations of Individuals H, I and J.
Interviews of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals 0, E, F,.G and were individually interviewed.
Individual D identified Individuals I and J as being only marginaly qualified for their duties as QC inspectors Individual D stated that IndividualsLI and J seemed to make no effort to improve their ability and due to their having apparently gained the favor of their Supervisors (Individuals C and N) they can usually be O
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Individuals E and F stated they felt all persons working as electrical QC inspectors are qualified for their jot Individual G stated Individual H was qualified and works hard.
Individual related having never worked with Individuals I and J, but stated some inspectors, whom he refused to identify, are " lazy."
Review of Former QC Inspectors j
On March 9, 1981 and March 11, 1981, Individuals L and M were individually interviewed.
Individual L stated that Individuals H and I were pretty 4,
good workers and are probably qualified in all phases of the inspections they perforia.
Individual L stated Individual J, at best, was probably only marginaly qualified as a QC inspector and was a very poor performer.
l Individual L stated that electrical QC Supervisors displayed an obvious favoritism towards Individuals H, I and J over other QC inspectors, which would probably account for their doing less field work and spending more j
time around the office.
Individual M stated a belief that all QC inspecto:
are qualified, but stated some (not identified) are " lazy."
4 Interview of B&R Electricians
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OnMarch9,1981,IndividaTsPandQ,B&Relectricians,wereindividually interviewed.
Individual P stated that Individual J was not adequately qualified as a-QC inspector.
Individual P related that on occasions Individual J would ask questions about work being inspected which would indicate a lack of knowledge regarding the field.
Individual P stated tha' Individuals H and I also do not appear adequately knowledgeable regarding electrical QC work.
Individual P also. identified Individual R as probably not being qualified and performing poorly.
Individual Q stated-Individual J may rst be qualified as a QC inspector ard related details regarding occasio 6 when Individual J did not understand simple aspects of work to be inspected.
Individual Q related no knowledge regarding Individuals H and I being qualified as electrical QC inspectors.
A Review of B&R QC Qualifications and Training Records On February 26, 1981 and March 12, 1981, CPSES requirements for QC inspect qualifications and the-training records for Individuals H, I, J and R were reviewed.
It was determined that each met the required background qualifications and satisfactorily completed the required written and oral examinations and the required on-the-job training necessary for certi-fication as electrical QC inspectors.
It was noted that Individual J passed the certification exam for the inspection of electrical terminations with a score of E4 parcentile, subsequent to the disqualification of two incorrectly answered questions.
Examination of other electrical terminations certification exams taken by other persons durirg a similar time frame. disclosed the same questions had not been disqualified.
It was determined that Individual J'would not have passed this certification exam had these questions not.been deleted j
from the exam.
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- i 12 Interview of B&R Quality Engineers On March 12, 1981, Individuals 5 and T, B&R electrical Quality Engineers (QE were interviewed.
Each explained that a combination of on-the-job training and classroom training are required of individuals prior to taking a particular QA Certification Exam.
Individual S stated all certification exams are administered by a QE, subsequent to which an oral exam is administered.
Individual 5 stated that the QE, based.on the results of i
l the oral exam, has the right to adjust, upward or downward, the score
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of the written examination.
Individual 5 stated the certification can be denied solely on the results of the oral exam.
Individual 5 stated; however, that a person who displays a obvious understanding of the material required for certification, but has not scored above the 80% required on the exam, is usually required to take the examination again.
Individual 5 stated the QE who administered the written and oral exam to Individual J i
was no longer employed at CPSES; therefore no reason could be provided i
for the disqualification of questions on the written exam of Individual J..
I Interviews of Individuals H, I and J 4
On March 11-12, 1981, Individuals H,II and J were each separately interviewe
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by an NRC inspector (Electrica1 Specialist) and NRC investig,ator in an effort to determine their respective qualifications.
The interviews indicated that each possessed an adequate degree of familiarity with the inspection procedures and. techniques to perform the termination inspection requirements.
Individuals H, I and J also indicated that they freely l
exercise the prerogative of asking their Supervisors for the answers to any questions that they encountered during the performance of inspections, both technical and administrative.
These interviews determined that QC inspectors H, I and J were each qualified to conduct the QC inspections in the area of electrical cable termination inspections or instructed by site procedures.
When specifically queried concerning the possiblity that Individual C had influenced Individual J's employment in the QC Department and influenced certification, Individual J related having no personal knowledge to support such allegations and stated no personal relationship existed with Individual C, aside from a professional one.
Interview of Electrical QC Suoervisors i
On March 12, 1981, Individuals C and N individually were interviewed. When questioned concerning the qualifications of Individuals H, I and J, as i
electrical QC inspectors, Indisiduais C and N each stat,ed they believed those individuals to be qualified.
Both stated a belief that the training program for QC inspectors was sufficient, but each added that more training would be desirable.. Individual C stated that as an adjunct to the initial training program new electrical QC inspectors are encouraged-to always ask l
questions of either ~ Supervisors or more experienced Electrical QC inspector:
l when they had questions concerning an area they were inspecting.
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13 Individuals C and N stated that over a period of time this process can develop good inspectors. ~When specifically. questioned concerning Individuals H, I and J, both Individuals C and N stated they believed the training and experience had mutually been responsible for the better qualifications of those persons.
When questioned concerning the alleged favoritism received by Individuals H, I and J, Individual C stated that the attention received by these individuals during their training was apparently misunderstood as being favoritis.m.
Individual C stated that Individuals H, I and J, due to their inexperinece, had required more assistance of the Supervisors during recent months, which may have been misunderstood, by some, as favoritism or special attention.
- Lastly, Individual C stated he was a personal friend of Individual J's brother; however, this had in no way influenced Individual J's receiving a job within the electrical QC department.
Furthermore, Individual C stated that he had not been responsible for hiring Individual J nor had Individual J's brother been aware that Individua.1 J was being transfered to the electrical QC Department.
Allegation No. 6 Electrical terminations were being made and " bought off" by some electrical QC personnel, in nonconformance with drawings.
Investigative Findings On February 24, 1981, Individual A was interviewe.d.
Individual A stated he believed electrical terminations have been " bought off" (approved by inspectors) which are in nonconformance with drawings.
Individual A statec this situation is specifically attributable to some electrical QC inspectors being unqualified for their job, rather than any intentional wrongdoing. -Individual A provided two examples of nonconforming con-ditions which were approved by electrical QC inspectors (Individuals I and J).
Individual A was' unable to provide any additional information pertiner to the identification of nonconformances which have been approved by electrical QC inspectors.
Inspection of Alleged Nonconforming Conditions On February 25, 1981, an inspection of the alleged nonconforming condition:
approved by Individual J, was conducted.
The inspection disclosed that no i
nonconformances existed in the alleged component, at this time.
On February 26, 1981, a review of the documentation relating to the allegedly nonconforming conditions approved by Individual I was conducted.
The review disclosed the work associated with this inspection required only a visual inspection after the work was completed.
The dccumentation for thi work indicated that Individual I had visually observed and apprnved the wo and additionally the work was also independently approved by.one other electrical QC inspector at ancther time.
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.2 14 Interview of Electrical QC Inspectors Between February 25, 1981 and March 12, 1981, Individuals D thru K were individually interviewed.
Individual D stated he believed that allegatio made that electrical QC inspectors have " bought off" inspections would probably more aptly relate to the qualifications of an individual inspect and his/her ability to identify a particular nonconformance.
Individual stated he has no knowledge of a nonconformance being knowingly approved b electrical QC inspector.
Individual D stated he had personally reinspect the task which had been visually inspected by Individual I (reported ab'ov and found the work to be in conformance with drawings. -Individuals E thr K related having no personal knowledge of nonconformances being approved by QC inspectors.
Individuals H and J each stated if they had approved a nonconforming condition in the past, it was done unintentionally.
Individuals H and J stated that such an occurrence would be the result of their not understanding all aspects of the work they were inspecting.
Nc of the aforementioned inspectors recalled having ever been asked'to
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approve a nonconforming condition.
Interview of Brown & Root Electricians On March 9,1981, Individuals P and Q were individually interviewed regar
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electrical QC inspections being " bought off" in an nonconforming conditic by electrical QC inspectors.
Both Individuals P and Q comments regardinc inspections being " bought off" related directly to the qualifications of j
specific inspectors and.the diligence with which.they conducted their l
inspections. Neither Individuals P or Q was aware of any nonconformance l
being intentionally approved.
Interview of Electrical QC Supervisors On March 12, 1981, Individuals C and N were* individually interview'ed.
When questioned concern.ing electrical QC inspections being " bought off",
Individual N related that occurrences of nonconforming conditions being approved by an electrical QC inspector would probably be the result of t!
respective inspector's inexperience.
Individual N stated that during the summer and fall of 1980, when much electrical termination work was i
being done and when a number of terminations inspectors were new on the job, the likelihood of nonconforming conditions not being identified dur
- i an inspection was much greater than now.
Individual N stated he frequen I
during that timeframe, reinspected work done by the less experienced inspectors and, on occassions, did identify mistakes they had overlooked Individual N stated that termination inspectors were encouraged to conta j
him when they had questions regarding a particular inspection, in order.
l to preclude errors being made.
Individual N stated he did not believe any intentional approval of a nonconforming item had ever occurred.
Individual C also stated if errors were made during inspections and a nonconforming condition was approved, it was due to the inexperience of the respective inspector.
Individual C. stated that the less experien
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inspectors were assigned less complex inspection task when they began in order for them to gradually acquaint themselves with the inspection l ~
process and avoid errors.
Furthermore, he stated that, as an adjunct l
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Individual C stated this process made better inspectors and helped ensure that mistakes were not made during inspections.
Allegation No. 7 Construction and inspection records relating to some pipe hangers are bein
,'i separately maintained, resulting in their final QA review being inadequate Investigative Findings On February 23, 1981, Individual B was interviewed.
Individual 5 stated that prior to April 1,1980, procedures for the construction, installation and inspection of every pipe hanger was very rigorous and that each step in these processes was documented.
Individual -B stated that on April 1,1980, the procedures for most of this inspection and documenta-tion were eliminated.
Individual B stated that a new procedure was implemented which required each safety class hanger have NDE and i
mechanical inspections performed following its instal.1;ation.
Individual j
B stated that the problem exists with regard to hangers being fabricated prior to a April 1,1980, and which were completed subsequent to the l.
initiation of the new inspection procedure.
Individual B stated that the hanger packages (containing all documents relating to the fabrication
, and inspection of each hanger) in existence on Ap,ril 1,1980, were filed away and a new hanger package was started for every hanger which was 4
not yet installed and QC approved.
Individual B pointed out that the Documentation Review Group, now reviewing the fabrication and inspection history of each hanger, is only receiving the hanger packages containing documentation prepared after April 1, 1980.
Individual B stated that this prevents a complete review being accomplished 3
on hangers which were in the fabrication process on April 1,1980.
Individual B stated the Welding Engineering Department currently main-tains the old hanger packages for hangers which were being fabricated on April 1,1980, and they refused to give the old packages to the Documentation Review Group wi.thout a written request from the QA Depart-ment.
Individual B stated this constitutes a violation of CPSES pro-cedures, in that all documentation is not being incorporated into a final review package.
Interview of Documentation Review Group Suoervisor
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1 On February 25, 1981, Individual U was interviewed regarding the review o-i hanger packages.. Individual U stated that since January 1980 numerous procedural char.ges have occurred relating to fabrication and inspection of pipe hangers which has resulted in problems regc.rding a mutually agree.
consolidation of all records. relating to the respective hanger packages.
t Individual U stated that on September 1, 1980, a major procedural change
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was implemented regarding the documentatiori format for both construction and QC preparation of structural hanger packages.
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He stated this division involved separation of old documentation (prepared prior to September 1, 1980), into a package tha would be maintained by the Welding Engineering Department and another packa of documents prepared in accordance with the new procedural change (subseqt to September 1, 1980).
Individual U stated that subsequent to the installa and inspection of the hangers having two documentation packages, only the new package was being forwarded to the CPSES vault for final component revi Individual U stated this separation of the packages did not always affect i
his final review and acceptability of a respective hanger.
He stated that 4.
when the old documentation was required to make a final determination of acceptability, his group was required to submit a written request, through his Supervisor, to the Supervisor of the Welding Engineering Department in order to obtain the old hanger. package.
Individual U stated that on every occasion his Department's requests for the old hanger packages were approve Individual U stai.ed that approximately one month ago (early February,1981:
the Welding Engineering Department had agreed that upon notification that a new hanger package had been sent to the Documentation Review Group for review, they would send the old package to also be reviewed.
Individual,U stated that during the past week, according to information he had received j
the Welding Engineering Department had sent several boxes of old hanger packages to the vault room for storage with the new hanger packages.
Individual U stated this would ensure availabilty of all documentation relating to hanger packages.
Individual U stated that the Welding Engineering Department had never refused to send a package for the reviews his group was conducting and no CPSES procedures or code.; have been violats Lastly, he stated that had he ever been refused a hanger package, to. compii his review, he would have refused to determine the acceptabilty of the respective hanger. ~
l Allegation No. 8 Electrical QC Supervisors require that nonconformance report (NCR) drafts be submitted to them and they are the only individuals within the electric QC Department authorized to obtain an NCR number for the draft.
Investigation Findings l
On March 11-12, 1981, Individuals H, I,.J, L and M were interviewed indivi j
regarding matters associated with this allegation.
During the interview of Indivudal M, he commented that the electrical QC Department policy regarding NCRs, is that the inspector prepares the draft and gives it to either Individual C or Individual N (electrical QC Supervisors) who are l
the only persons authorized to obtain an NCR number for the draft.
l Individual N recalled that during November 1980, Individual C had. stated a l
prepared by Individual M related only to the " cosmetic" aspect of the item inspected and had directed it be withdrawn which it was.
Individual stated this was the only occasion in which he ever had an NCR denied by a Supervisor.
Individual M did not recall any specific information regarding that NCR.
Interview of Individuals H, I, J and L disclosed they each were aware of the electrical QC Department policy designating I
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17 electrical QC Supervisors as the only persons, in that Department, authorize to obtain NCR numbers for NCR drafts.
None of these individuals recalled ever having been denied the right to submit an NCR.
Interview of NCR Coordinators On March 11,~1981, Individual V, a TUGC0 NCR Coordinator was interviewed regarding electrical QC Department policy relating to obtaining of NCR numbers.
Individual V stated that in about September 1980, Individual C had directed that only he and Individual N be allowed to obtain NCR numbers for the electrical QC Department.
Individual V stated that no electrical QC Department NCR, without Individual C or Individual N's signature on it, had been processed, in accordance with this direction.
On March 12, 1981, Individual W, a B&R NCR Coordinator was interviewed.
Individual 'l stated that B&R NCR Coordinators office processes only civil and mechanical QC inspection department NCRs.
Individual W related having no association with the eiectrical QC Department or their NCRs.
Individual W stated that no agreements exist between the B&R NCR Coordinators office and civil' or mechaaical QC Supervisors.
Individual stated however, that 99% of the NCRs issueo from the B&R NCR Coordinators Office, to the civil and mechanical QC Depa-tments, are issued to Supervisor Interview of Electrical QC Supervisors On March 12, 1981, Individuals C and N were individually f aterviewed i
regarding their department policy relating to NCRs.
Individual N stated
.a policy exists in the electrical QC Department requiring electrical QC inspectors to provide an NCR draft to an electrical QC Supervisor (either Individual C or Individual N), for review and that the respective Superviso:
l is responsible for obtainiag the NCR number from the NCR Coordinator.
Individual N stated that ne had never " turned down a legitimate NCR; however, he stated that he had questioned the legitimacy of some and has required that a Field Deficiency Report (FDR) be prepared instead of an NCR on occasion." Individual N stated this problem happens only occasional (two or three times per month), and usually involves an inexperienced inspector.
Individual C, when interviewed, stated he was responsible for initiation of the policy requiring electrical QC inspectors to have their NCRs approved by a Supervisor because, during the early fall,1980, he learned some electrical QC. inspectors were obtaining NCR numbers for their NCR drafts and never submitting the NCR.
Individual C stated he implemented the policy to assure accountability of NCR numbers and to ensure each NCR submitted, by his department adequately explained and identified the problem found.
Individual C stated he was not aware his policy contradicted TUGC0 (CPSES) Procedure No. CP-QP-16.0 (Revision 3),
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dated July 9, 1980.
Individual C stated he would rescind his policy and ensure compliance with the site procedure.
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Individual X stated he was unaware the site NCR procedure was not being properly followed by the
- electrical QC Department.
Individual X stated he believed this was an isolated situation and that corrective action would be immediately taken to properly implement the site NCR procedure.
Individual X, furthermore; state "I will make it clear how this procedure is to be interpreted and imple-mentea" to all QC Departments."
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-FOLDER NO.
40 Oraft No.
Date COMANCHE PEAK ALLEGATION WORK PACKAGE (IS/t$.
QA,9PCategory
- Management Allegation Numbers:
AQ-1, A0-2, AQ-6, AQ-25, AQ-62, AQ-66, AQ-67, A0-69, AQ-81, A0-80, AQ-56, AQO-01, AQO-28, AQO-29a,-A00-29b AQO-30, AQ0-31,/%QE"
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trelatehallegationsinvolving:
Statement of Allegation: Various mana a.
Poor management practices 6.
QA/QC deficiencies.
c.
Management not qualified d.
Poor construction QA and practices Lack of coordination, poor supervision, shoddy e.
workmanship, and hundreds of unidentified defects f.
Pressure on QA/QC by management g.
60 coatings allegations h.
Engineering evaluation to fix problems.
Note: Reference AQO-29b in folder 48 Reference Documents:
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See source documents marked on attached pages from allegation list.
Source of Allegation: Various - see enclosed allegations list Date Received:
1980 - 1984 The above information prepared by O. M. Hunnicutt 6/8/84 Name Date Group Leader Name Date Assigned Team Members Date Assigned Date Assigned Date Assigned Date Assigned
._._________...a (qeG.
COMANCHE PEAK OPEN ISSUE ACTION PLAN
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l' Y'.. i Task: Determine management, supervision, and others' involvement in poor practices including QA/QC, poor practices, construction, pressure on workers,3,[
coatings applications, and engineering.
'g Ref. No.: AQ-1, AQ-2, AQ-6, AQ-25, AQ-62, AQ-66, AQ-67, AQ-69, AQ-81 AQ-8,
AQ-56, AQO-01, AQO-28, AQO-29a, AQO 29b AQO-30, AQO-31, c-1 Characterization: Various concerns involving all areas of management, A deficiencies, lack of independence of QA/QC, lack of job coordination, shoddy workmanship, coatings applications, engineering problems away, management symphatic to production, and hundreds of unidentified problems (if problem unidentified, how does anyone know there is a problem and what specifically can be done about it?).
Initial Assessment of Significance: Some of these allegations have been dispo-sitioned as follows:
IR 83-47 (AQ-1), IR 83-52 (AQ-66), IR on coatings by BNL AQO-28, AQO-29, AQO-30 and AQO-31. There appears to be sufficient specificity to warrant followup on many of these allegations. Difficult to determine safety significance of these_ broad allegations.
Source: QA/QC Category 5 - Management Accroach to Resolution:
1.
Review IR 83-47, IR 83-52, and IR on BNLJnterim report to determine if documentation adequately supports findings for AQ-1, AQ-66, and AQO-28, AQO-29a, AQO-29b, AQO-30, and AQO-31.
If documentation does not support C
findings, take appropriate action to close allegations.
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2.
Review the $98TETOinterim recort 75 the second BNL report is available, M,A this report should be reviewed in-depth. Determine if fequate documentation is available to support BNL report (s). Take appropriat. action to close allegations.
y 3.
Review licensee's three documents entitled TUGC CPSES " Analysis of the Clogging of ECCS Sump Trash Racks by Debris and Paint Peels Following Accident"; "Model Testing of the Recirculation Containment Sump"; and
" Evaluation of Paint and Insulation Debris Effects on Containment Emergency Sump Performance."
4.
Review procedures, in question, for adequacy at time work was performed; were codes / standards, FSAR commitments met?
5.
Discuss adequacy of procedures with personnel involved with various allegation topics. Discuss adequacy of other related procedures. Examine areas that are associated with any inadequate procedures identified duri interviews.
6.
Refer any examples of wrongdoing or significant deficiencies TRT manager.
7.
Evaluate allegations for generic / safety implications.
8.
Report on results of review / evaluation of allegations.
Related Open Issues 1.
Using system codes, pull open items, previous inspection findings, etc.,
from the tracking system open item list.
(Region IV identify and add to this-work package.)
2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additional inspection while the inspector is familiar with the areas.
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While performing physical inspections above, examine surrounding systems, components, and structures for related apparent defects or indicators of faulty workmanship.
4.
If workmen are still in the area of a physical inspection, interview them for any knowledge'of other potential deficiencies.
5.
Complete portions of any applicable IE Modules that relate to effort made on allegations.
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